In the May Health Affairs issue, Sarah Vogel and Judy Roberts map out the disastrous history of the 1976 Toxic Substances Control Act (TSCA), the major legislation that regulates chemicals. TSCA makes it difficult for the Environmental Protection Agency (EPA) to restrict use of any of the 62,000 chemicals already in commerce. It does not empower EPA to rigorously assess potential health concerns posed by newly produced chemicals submitted for approval, either. Whatever number you use (the 83,000 cited by Vogel and Roberts or the 130,000 registered with the European Chemicals Agency), a large number of chemicals are still being released into the environment without a clear sense of the hazards posed, especially to children.
Failure to assess risks posed by chemicals before widespread distribution begins places a large burden on researchers to assess the implications of these exposures on populations of children and their families, studies which often take years to conduct and need to be repeated in different settings to confirm their reproducibility and consistency. The environmental exposures may produce subtle effects on outcomes that are also influenced by other, external factors (behavioral and social environments, not to forget health care delivery either), and interpretation of the results is fraught with uncertainty about the nature of the relationships between dose and response as well as thresholds at which effects may or may not begin to emerge.
Using the language of economics, production continues by entities that do not pay for the negative consequences borne by others (sometimes generations later). In the May issue, Yinghua Liu and I followed a tried and true method of estimating costs of diseases of environmental origin in children, and find that they now cost on the order of $76.6 billion annually. That estimate focuses only on those conditions for which the evidence for causation is strongest, and leaves aside costs for conditions such as low birth weight and childhood obesity for which evidence is increasingly suggesting a role for chemical factors.
Complicating the resolution of these so-called market externalities are many actors that may no longer be producing chemicals of concern (the producers of now-banned polychlorinated biphenyls, which continue to contaminate fish and be detected in human serum in national surveys led by the Centers for Disease Control and Prevention) and other chemicals for which the science documenting health effects is only now and retrospectively beginning to emerge.
It doesn’t only make common sense from a health perspective to take extra measures to protect children who are vulnerable; it also makes economic sense, too. We need to refocus resources on efforts to identify those chemicals already in widespread use. That will largely come through research funded by the National Institutes of Health, the Environmental Protection Agency, and the Food and Drug Administration, just to name a few agencies. The other urgent need is to modernize TSCA and empower the federal government to get the science necessary to judge potential hazards in chemicals up for approval, and to take action when the science merits it. The Safe Chemicals Act proposed by Senator Frank Lautenberg (D-NJ) does that and builds upon the legacy of the newer and major pesticide regulatory legislation, the Food Quality Protection Act of 1993, acknowledging children’s unique vulnerability and taking explicit steps to proactively protect children in the absence of data specifically addressing this vulnerable population.
The right mix of weather may be clustering for this legislation. The European Union’s Registration, Evaluation, Authorization and Restriction of Chemicals already requires stronger protection for chemicals currently in use and newer chemicals, and indeed principles for TSCA reform have been mutually agreed upon by the Obama Administration, American Chemistry Council and the Safer Chemicals, Healthy Families Coalition. The United Nations Environment Programme is considering chemical policy reform globally as part of its Global Outlook on Chemicals, and the American Academy of Pediatrics recently published a policy statement supporting chemicals policy reform along the lines of these principles. This reform also has some very public and highly regarded supporters, including actress Jessica Alba, who is speaking out today on behalf of the Safe Chemical Act. (The Health Affairs Facebook page includes an item with a picture of Alba, post author Leo Trasande, and Marla Weston, CEO of the American Nurses Association, at today’s press conference in support of the legislation.)
Let’s not harbor false expectations that the $76.6 billion payout will emerge immediately. But through thoughtful efforts to reduce exposures for those chemicals with risks, especially for children, the payout indeed can be huge. It will accrue annually as each cohort of children passes through unexposed, just as reductions in the lead content of gasoline still produce hundreds of billions of dollars in improved economic productivity as each cohort of US children is born with lower levels of lead in their blood and has higher cognitive potential.
Editor’s note: The May issue of Health Affairs is the journal’s first-ever thematic volume on environmental health. Leo Trasande, Sarah Vogel, and other authors from the issue discussed their research at a May 4 Washington D.C. briefing. Both the issue and the briefing were supported by a grant from the Kresge Foundation.