Policy Reforms to Protect Our Children
Current laws permit children to be exposed to mixtures of hazardous substances in their homes, schools, play areas, occupational settings, and in transit on a daily basis. Most laws do not define the rights of children to clean air, food, water, and safe consumer products. The following principles could guide reform of laws to better protect children from environmental risks.

1. Right-to-Know
Finding:
Many U.S. laws protect information on environmental hazards (e.g. product ingredients, chemical release to the environment, contamination levels, and some chemical toxicity data) as trade secrets or confidential business information. Trade secret law, defamation law, and confidentiality provisions of various statutes inhibit public access to information. This protection limits the public's ability to recognize important health hazards in their environments and in consumer products. Examples include inert ingredients in pesticides, building materials, paints, and food additives, and genetically modified substances. Although EPA reports chemical releases to the environment as a requirement of several statutes, gross releases are difficult to translate into probable levels of exposure and risk, and many chemicals and polluters are exempt from the reporting requirements.

Recommendations:
Amend current laws to establish the public's right-to-know about hazardous substances-chemical, biological and physical in air, water, food, consumer products, workplaces, schools, recreation areas and other places frequented by children and women of child bearing age. Knowledge of risk should be public, not private property.

2. Surveillance
Finding:
The absence of information on chemical production, release to the environment, movement through it, and toxicity makes it impossible for regulators, or anyone else, to know where hazards lie in wait. It also makes it impossible for government to ensure that exposures are safe. Past monitoring efforts have produced insufficient understanding of the variability in exposures. Exposure is likely to vary across space, time, and demographic groups, defined by age group, income class, and ethnicity. Current health surveillance efforts are also insufficient to detect important childhood illnesses and disabilities that may be associated with environmental hazards.

Recommendation:
Laws should be amended to ensure the sufficiency and public availability of information regarding environmental hazards. Surveillance should occur at a scale and frequency necessary to understand and manage children's exposure to hazards. Monitoring should be conducted in schools, play areas, vehicles, and occupational settings to better understand children's exposure to environmental health hazards.

National registries should be developed or expanded for major childhood diseases: e.g. cancer, birth defects, neurological and behavioral disorders including autism, and respiratory diseases. The National Children's Study will provide invaluable information on patterns of exposure, illness and relative potency of diverse hazards. Considerable progress could be made immediately in improving surveillance efforts already authorized by laws governing the quality of air, food, water, soils and consumer products.

3. Fair Warning
Finding:
Current product labeling practices provide the public with little understanding and warning of consumer product hazards. Product benefits are normally prominent, while hazards are rarely labeled with clarity. If labeled, small print size and technical language often restrict public comprehension of risks, ingredients often remain unspecified. When specified, percentages are rarely provided. Many manufacturers assume that hazards will be manageable if printed directions are followed. Labeling however will never be an effective means to manage risks faced by children, those with limited literacy or inadequate technical competence.

Recommendation:
Standardize product warnings to alert and educate consumers about product safety. Fair warning demands standardized symbols of hazard that are easily recognized and understood.

4. Health Protective Law
Finding:
Most environmental laws do not demand that pollution and contamination standards be set ensure protection of human health. The Food Quality Protection Act is the one clear exception, demanding that standards be set to assure "a reasonable certainty of no harm". Other statutes permit technological feasibility, economic costs of compliance, and uncertain information to be considered and balanced against health threats as government agencies make choices to limit pollution, contamination, or risk.

Recommendation:
Establish health protection as a uniform standard for environmental laws. Amend laws to require that contamination and pollution limits protect the health of children, infants and pregnant women. This change would require the reevaluation of thousands of existing standards not yet set to protect health. Strict deadlines should be set to achieve health protective standards for air, water, food, soil, and consumer products.

5. Chemical Mixtures
Finding:
No laws now limit cumulative cancer, neurological, or respiratory health risks. These threats are permitted to accumulate chemical-by-chemical from contaminated air, water, food, soils and consumer products. Human exposure to mixtures of hazardous chemicals is largely unstudied and unregulated.

Recommendation:
Ensure that children's exposure to chemical mixtures are managed to prevent additive or synergistic effects. Mixtures may best be managed by planning to reduce hazardous chemical use and release at sites where children spend most of their time: homes, schools, recreational areas, and during transport.

6. Hazardous Places
Finding:
The public is rarely informed of the location of hazardous sites, facilities, land uses, or landscapes. Lands and industrial sites that pose significant threats to children's health are often disguised. These areas may include solid and hazardous waste repositories, underground storage tanks, former agricultural lands, contaminated aquifers, industrial sites, military facilities, and transport and power corridors.

Recommendation:
Create a national registry of sites that pose special hazards to children. Centralize current and historical information on facilities, lands and aquifers with a history of contamination. Establish clear criteria for site listing, and include all known sources of emissions on the registry. If followed, these recommendations could guide parental choices concerning where to reside, send children to school and play. This knowledge would also improve current residents' potential to influence those who own or manage hazardous properties. It may also encourage real estate market values to more truly reflect environmental quality and contamination.

7. Precautionary Policy
Finding:
Few laws demand the use of precautionary policy, or safety factors, when setting allowable emission or contamination limits, or levels of acceptable exposure. Two exceptions include the Food Quality Protection Act and the Clean Air Act. Both require that safety margins protect against underestimates of health threats when information is uncertain. The history of toxicity testing suggests that government scientists and regulators have underestimated both chemical toxicity and children's exposure. Once fully tested, few chemicals are found to be less toxic than originally believed. The absence of chemical production, release, exposure and toxicity data creates a level of uncertainty that justifies the use of safety factors and other precautionary policies.

Recommendation:
Regulations that limit exposures should assure protection of fetuses, infants and children with an adequate margin of safety. Until credible evidence of safety is produced, cautious assumptions should be applied to set standards for allowable contamination of air, water, food, consumer products, and the environments that children live within homes, schools, workplaces, recreational facilities and vehicles.

source: Children's Health Environmental Coalition http://www.checnet.org/