http://www.ewg.org/issues/humantesting/20041029/letter_20041029.php
October 29,
2004
Letter
from Kenneth A. Cook, President, Environmental Working Group to
Dr. Paul Gilman,
Assistant Administrator
Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Dear Dr. Gilman:
Thank you
for your October 27, 2004 letter discussing the Environmental
Protection Agency's (EPA's) $2 million partnership with the chemical
industry's lobbying arm, the American Chemistry Council (ACC),
in a precedent-setting study of the effects on pesticides in children.
Apparently,
ACC does not share your "no strings attached" view of
its $2 million payment to participate in your study.
In its Fall
2004 Long-Range Research Initiative Update, (http://www.uslri.org/news.cfm?id=newsletters)
the ACC wrote that this "project also contains considerable
leverage, in that $2 million of ACC funds add to $7 million of
EPA funds" [emphasis added].
It's hard
to read that without thinking that the ACC has far more in mind
than you do, particularly given the fact that the ACC's reason
for existence is to lobby the government — and your agency
in particular — on behalf of a powerful, polluting industry.
It's an industry with a checkered history and one that has a key
member, DuPont, in court now with your agency over the fate of
a marquee product.
Your study
now appears to be a Trojan horse for the industry's effort to
gain acceptance for the morally corrupt practice of paying people
to expose themselves and their families to pesticides. It is the
accepted norm in science that human beings should not be used
as test subjects unless there is a plausible, direct benefit to
participants. Instead of paying parents to continue exposing their
kids to pesticides and other chemicals, a responsible government
would assess initial levels of the toxins in those children, and
then help parents reduce the exposures and measure the results.
Don't we want
people using fewer dangerous pesticides, not continuing their
use?
What safeguards,
other than a questionnaire, do you have in place so that low-income
people won't start using pesticides in order to get the $970 being
offered in a difficult economy?
Let us be
clear: it's an extremely bad idea to pay people to expose their
children to dangerous pesticides, while giving the regulated industry
"leverage" by accepting its money to do this.
You should stop — today — this outrageous study, immediately
return the pesticide lobby's money, and start afresh on studying
the important question of chemicals' health effects on children.
Surely the $7,000,000 the Agency is putting into this study, or
$120,000 per child, could be redirected to projects that more
effectively advance public health protections — and the
health of study participants.
Meanwhile,
the public has a right to know the role chemical industry lobbyists
will play in a precedent-setting study directly affecting their
industry's bottom line. Industry representatives will be on the
Peer Advisory Committee providing technical advice for the study.
Your fact sheet says, "the EPA benefits from external expertise,
product development." Two companies that are regular contractors
of the chemical industry, Battelle and Aerostar Environmental
Services, will conduct the study.
Given all
these facts, are you then saying industry representatives will
have no contact, consultation, or influence on the:
•
study protocol;
•
testing in the study;
•
gathering of data;
•
data analysis and interpretation;
•
presentation of the findings;
•
method of publicizing and releasing results to the public; and,
•
decisions about what parts of the study will be released to
the public?
Finally, we
think it's important to correct you on several important points:
•
The list you sent to show that other "non-profit organizations"
have partnered with EPA on research projects doesn't yield any
public interest groups, but instead the majority of them are
polluting industries you are supposed to watch. It's worth noting
that the ACC represents Teflon maker DuPont, which just announced
$331 million in quarterly profits — more than the maximum
possible fine the EPA is now considering leveling against the
company for illegally suppressing health and water pollution
research.
•
CHEERS is fundamentally different from the type of technology
innovation and transfer that was outlined in the Federal Technology
Transfer Act (FTTA) as amended. This health study would research
the very chemicals made and used by the ACC's paying members,
which EPA regulates. ACC is not developing a technology but
funding a health study that will affect the health standards
its lobbyists are paid to weaken.
•
In addition, the FTTA provides for confidentiality and lack
of public access for up to five years. How can the EPA engage
in a health study with the polluting industry it is supposed
to monitor, with the potential that results could be hidden
for years under the umbrella of "confidential business
information?"
At a time
when a policy that weakens clean air laws is called "Clear
Skies" and a large-scale logging initiative is called "Healthy
Forests," pardon our suspicion about a study of children
being exposed to toxic chemicals that is called "CHEERS"
and is partly paid for by the very companies whose toxic chemicals
end up in the kids.
Sincerely,
Kenneth A. Cook
President