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EPA Sets an Ominous Precedent

EPA Sets an Ominous Precedent

Monday, October 29, 2007

October 15, 2004

Michael Leavitt
EPA Administrator
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Dear Administrator Leavitt:

Environmental Working Group is deeply troubled to learn that the EPA has decided to make the lobbying arm of a powerful regulated industry its "partner" in a major chemical research initiative. This agreement relegates the public and independent scientists to second tier status, and it suggests that any polluter or regulated industry can become a full partner with the EPA if the price is right.

This is an ominous precedent.

Specifically, the U.S. EPA and American Chemistry Council (ACC), a lobbying organization representing over 150 of the largest chemical companies in America, signed a Cooperative Research and Development Agreement through which ACC will provide approximately $2 million to the Agency to collect data on young children's (ages 0-3) exposures to several household chemicals, including phthalates, brominated flame retardants, and perfluorinated chemicals.

According to the Agency's website, "Results from this study will be used to evaluate the potential for children's exposure to these chemicals, determine the impacts of age and activity patterns on exposure, and reduce the uncertainty in exposure and risk assessments for children." Notably, the goal is to reduce uncertainty in risk assessments, as opposed to reducing exposure and risk from the chemicals themselves. To be clear: Environmental Working Group strongly supports greater study of children's exposure to chemicals, but not through a "partnership" between polluters and the government that grants the regulated industry access to, and power over critical aspects of study design, study methods, data collection, data review and analysis, and data interpretation.

This partnership, called the Children's Environmental Exposure Research Study, whose ironic acronym is "CHEERS," essentially is a gift to an industry that has a long, checkered history.

In the EPA's September 22, 2004 news release announcing the study, the acting director of EPA's Human Exposure and Atmospheric Sciences Division acknowledged that the Agency has "very little information about how children may be exposed to chemicals in household products, whether it is through the air they breathe, food they eat or the surfaces they touch."

Instead of assigning a qualified team of independent scientists to gather this information using government funds, your Agency has instead accepted industry funding and guidance from the makers of the very chemicals in question.

In a document labeled "intended for internal Agency use only," yet publicly available for public download at EPA's CHEERS website ( ), this study of young children's exposure to phthalates, brominated flame retardants, and perfluorinated chemicals is referred to as "the ACC study."

Children subjected to these pesticides and chemicals do not have $2 million to represent themselves in this study. How can your agency justify this unprecedented, cozy relationship with an agency you are supposed to be policing? Aren't you concerned that this mixing of corporate and government science will communicate to the public that the government's stamp of approval can be bought?

I call on you to end this questionable relationship now, and instead put scientists free of industry ties in charge of the study — with no way for the industry to manipulate the outcome. Particularly in the wake of recent controversies, your Agency should work to avoid mixing corporate and government science.


Kenneth A. Cook President