Washington State Public Health Association
Resolution 03 - 2007
Resolution 07-03
SUPPORTING FEDERAL AND WASHINGTON STATE ACTION TO IMPLEMENT A COMPREHENSIVE CHEMICALS POLICY TO IMPROVE AND PROTECT PUBLIC HEALTH
WHEREAS the global scale of industrial chemical production is immense and is expected to grow four-fold by 2050;1,2 and
WHEREAS the U.S. chemical industry produces or imports a total of 42 billion pounds of chemicals per day for use in products and industrial processes;3 and
WHEREAS many of these substances that are useful to society are also known to be hazardous to human biology and ecological systems; andWHEREAS hundreds of chemicals used in consumer products or industrial chemicals are found to be accumulating in human tissues in studies by the CDC and EPA; and
WHEREAS harmful chemical exposures pose the greatest threat to children and women before and through reproductive age, and as stated in scientific consensus statement from the 2007 International Conference on Fetal Programming and Developmental Toxicity which concludes “susceptibility to adverse effects is increased during development, from preconception through adolescence” and “developmental exposures to toxicants can lead to life-long functional deficits and manifestations of increased disease risks,”4; and
WHEREAS the Toxic Substances Control Act (TSCA) of 1976 (P.L. 94-469) is the federal statute that is broadly intended to enable regulation of chemicals both before and after they enter commerce; and
WHEREAS analyses conducted by the National Academy of Sciences (1984),5 the U.S. General Accounting Office (1994),6 the Congressional Office of TechnologyAssessment (1995), 7 Environmental Defense (1997),8 the U.S. EPA (1998),9 former EPA officials (2002),10 the U.S. Government Accountability Office (2005),11 and theUniversity of California (2006) 12 have concluded that TSCA has fallen short of its objectives and has not served as an effective vehicle for the public, industry, or government to assess the hazards of chemicals in commerce or control those of greatest concern, and that, as a consequence, the statute has not served to motivate industry investment in cleaner technologies, including green chemistry; andWHEREAS The chemicals market in the United States therefore operates primarily on the basis of the function, price, and performance of chemicals, with much less attention to their toxic and ecotoxic properties; and
WHEREAS these market conditions have failed to safeguard health, producing a set of chemical problems for workers, the public, ecosystems, government, businesses, and industry that will broaden and deepen in coming years, concomitant with expanding global chemical production, with an accompanying result of this market failure being that the true costs of the harm from chemicals are not included in prices and create an economic burden due to costs related to illness and diseases linked to harmful chemical exposures,13 and;WHEREAS these problems include the appearance of hundreds of industrial chemicals in human tissues and fluids, including those of infants; the development of chronic diseases and premature death related to chemical exposures in the workplace; and disproportionate risks due to chemical exposures among members of minority, immigrant, and low-income communities, as residents and workers; and
WHEREAS changes in public environmental health policy in the European Union are driving global interest in cleaner technologies, including green chemistry, which also provides the US a unique opportunity to implement a modern, comprehensive chemicals policy that could position the United States to become a global leader in green chemistry science and innovation; andWHEREAS maintaining current policy and industrial practices, creates a danger that the U.S. could become a “dumping ground” for hazardous substances no longer permitted for sale in the European Union and other regions; and
WHEREAS the American Public Health Association has established prior policies in the area of chemical safety for workers and the general public;14,15,16,17,18,19 and
WHEREAS WSPHA has established prior policy supporting safer chemicals policies to improve public health, recognizing the imperative and ethical responsibility to protect children’s health and their futures; and
WHEREAS WSPHA members at the 2006 Annual Meeting proposed additional policy for 2007 supporting federal safeguards to ensure safer chemicals policies;
THEREFORE BE IT RESOLVED that the WSPHA calls upon the U.S. Congress to fundamentally restructure the Toxic Substances Control Act such that it (1) requires the generation and distribution by chemical producers of comprehensive chemical hazard and chemical use information in forms that are appropriate for use by the public, workers, industry, and government; (2) expands the capacity of federal and state agencies to efficiently assess the hazards of chemicals in commercial use and steadily reduce the production and use of those of greatest concern; and (3) motivates investment, education, and research in green chemistry science, technology, and education; and
BE IT FURTHER RESOLVED that WSPHA supports and encourages its members to support the proposed APHA policy to restructure TSCA and implement federal chemicalpolicy reform at the APHA Annual Meeting in November, 2007; and
BE IT FURTHER RESOLVED that the WSPHA supports Washington State’s Department of Health, Department of Ecology and Labor of Industries policy actions, and legislative efforts in Washington State to protect the public, particularly children and workers, from harmful chemicals in consumer products, to reduce the burden of toxic exposure and improve public health for Washington’s citizens.Signed by: Rick Porso, WSPHA President 2006-2007
Submitting Primary Author:
Contact Name: Steven G. Gilbert, PhD, DABT
Agency: INND (Institute of Neurotoxicology & Neurological Disorders)
Agency Address: 8232 14th Ave. NE
City, State, Zip: Seattle, WA 98115
Phone: 206.527-0962
E-mail: sgilbert@innd.org
Co-Authors:
Contact Name: Aaron Katz, PhD, Senior Lecturer, Dept of Health Services,
Agency: University of Washington School of Public Hlth and Comm Medicine
Agency Address: 1107 NE 45th Street, Suite 400, Campus Mailstop 354809
City, State, Zip: Seattle, WA 98105
Phone: (206) 616-5227
Contact Name: Margaret Shield, PhD, Coalition Coordinator
Agency: Toxic-Free Legacy Coalition
Agency Address: 4649 Sunnyside Ave N, Ste. 540
City, State, Zip: Seattle WA 98103
Phone: 206-632-1545 ext 123
E-mail: mshield@toxicfreelegacy.org
Contact Name: Nancy Dickeman, MA, Environment & Human Hlth Coordinator
Agency: Washington Physicians for Social Responsibility
Address: 4554 – 12th Ave NE
City, State, Zip: Seattle WA 98105
Phone: (206) 547-2630 – main office; (206) 354-2170 – cell
E-mail: nancyd@wpsr.org
Individuals and Organizations Supporting the Resolution:
Supporting Federal and Washington State Action to Implement a Comprehensive
Chemicals Policy To Improve and Protect Public Health
• Karen Bowman, MN, RN, COHN-S
• Patricia Butterfield, PhD, RN, FAAN
• Robert Duff, MS; Toxicologist
• Catherine Karr, MD PhD MS
• Katherine Davies M.A.,
• D.Phil. WSPHA Member
• Richard Grady, MD, Co-Chair, Environment & Human Health Coordinator,Washington Physicians for Social Responsibility
• Laura Hart, MD, President, Washington Physicians for Social Responsibility
• James Krieger, MD, MPH
• Denise Laflamme,MS, MPH
• Elise Miller, M,Ed, Executive Director, Institute for Children’s EnvironmentalHealth
• Maria Peeler
• Janet Primomo, PhD, RN
• L.B. Sandy Rock, MD, MPH
• Anne C. Steinemann, PhD
• Roger A. Rosenblatt MD, MPH, MFR
• Sheela Sathyanarayana, MD
Organizations:
• Institute for Children’s Environmental Health
• Institute of Neurotoxicology and Neurological Disorders
• Local Hazardous Waste Management Program in King County
• North American Hazardous Materials Management Association
• Washington Association of Occupational Health Nurses
• Washington Physicians for Social Responsibility
• Washington State Nurses Association
Organizations Supporting Related Safer Chemicals Policies:
Washington State Public Health Association
References:
1 American Chemistry Council. Guide to the Business of Chemistry, p 37. Arlington,Virginia: American Chemistry Council, 2003.
2 Organization for Economic Cooperation and Development (OECD). Environmental Outlook for the Chemicals Industry (http://www.oecd.org/dataoecd/7/45/2375538.pdf)(accessed February 8, 2006). p. 34-36, 2001.
3 National Pollution Prevention and Toxics Advisory Committee (NPPTAC) Broader
Issues Work Group. How can EPA more efficiently identify potential risks and facilitate
risk reduction decision for non-HPV existing chemicals?, 2005.
4 Washington State Public Health Association, October 2006: “Supporting SaferChemicals Policies to Benefit Human and Environmental Health”
5 National Academy of Sciences Commission on Life Sciences. Toxicology Testing:Strategies to Determine Needs and Priorities. Washington, D.C.: National Academy of
Sciences Press, 1984.
6 United States General Accounting Office. Toxic Substances Control Act: LegislativeChanges Could Make the Act More Effective (GAO/RCED-94-103). Washington, D.C.:
U.S. Government Printing Office, 1994.
7 Congress of the United States Office of Technology Assessment. Screening andTesting of Chemicals in Commerce: Background Paper. Washington, D.C.:U.S.
Government Printing Office, 1995.
8 Roe D, Pease W, Florini K, Silbergeld E. Toxic Ignorance: The Continuing Absence ofBasic Health Testing for Top-Selling Chemicals in the United States
(http://www.environmentaldefense.org/pdf.cfm?ContentID=243&FileName=toxicignoran ce.pdf) (accessed February 12, 2005). Washington, D.C.: Environmental Defense,1997.
9 U.S. Environmental Protection Agency. Chemical Hazard Data Availability Study (http://www.epa.gov/opptintr/chemtest/hazchem.htm) (accessed June 15, 2005).
Washington, D.C.: U.S. Government Printing Office, 1998.
10 Goldman L. Preventing pollution? U.S. toxic chemicals and pesticides policies and
sustainable development. Environmental Law Review 32:11018-11041(2002).
11 United States Government Accountability Office. Chemical Regulation: Options Existto Improve EPA's Ability to Assess Health Risks and Manage its Chemicals Review
Program. Washington, D.C.: U.S. Government Printing Office, 2005.
12 Wilson, Chia, Ehlers. Green Chemistry in California: A Framework for Leadership inChemicals Policy and Innovation (http://coeh.berkeley.edu/news/06_wilson_policy.htm)
(accessed March 15, 2007). Special Report to the California Legislature. University of
California Policy Research Center, Office of the President (2006).
13 Davies, Kate. How Much Do Environmental Diseases and Disabilities Cost?Northwest Public Health, Fall/Winter 2005. Available at:
http://www.nwpublichealth.org/docs/nph/f2005/web_ex_davies_f2005.pdf
14 APHA Policy 200011 The precautionary principle and children's health;
15 APHA Policy 20008 Affirming the importance of regulating pesticide exposures toprotect public health;
16 APHA Policy 20009 Support for International Action to eliminate persistent organicpollutants;
17 APHA Policy 2002-5 Preserving Right-to-know information and encouraging hazardreduction to reduce the risk of exposure to toxic substances;
18 APHA Policy 2005-5 Protecting human milk from persistent toxic chemicalcontaminants;
19 APHA Policy 96-06 The Precautionary Principle and Chemical Exposure Standardsfor the Workplace.