NOTE: This letter is a follow-up to EWG's July 14 letter to Mr. Gerard.
Jack N. Gerard, President
American Chemistry Council
1300 Wilson Boulevard
Arlington, VA 22209
Dear. Mr. Gerard,
You didn't answer my question, so let me repeat it.
Which chemicals manufactured by the companies the American Chemistry Council represents have been detected in the blood of American babies?
I'm asking that same question this week of a number of your member companies. Our review of the open literature indicates, surprisingly, that comparatively few of the thousands of chemicals your member companies produce have been tested for in human umbilical cord blood.
Surely any chemical company that professes concern about the potential health impacts of their products would take the rudimentary step of testing to see if those products end up in people, especially during the period in life when people are most vulnerable to chemical insultÑin the womb, during infancy, and throughout early childhood.
What we want to know is whether or not your members have performed, but not published, laboratory tests to determine if their chemicals end up in babies through transplacental movement.
If your member chemical companies have performed those tests, we ask that they make public the results. If they haven't tested, we would like to know why not.
Our inquiry touches on important matters not only of public health science, but also of ethics and law. You may be aware of the lawsuit the Environmental Protection Agency filed against DuPont in 2004 for multiple violations of federal laws, including the Toxic Substances Control Act. Figuring prominently in EPA's complaint was the company's failure to report a 1981 finding of the Teflon-related chemical perfluorooctanoic acid (PFOA) in umbilical cord blood, in a study that measured the chemical in babies born to female employees. The EPA's complaint puts the matter very clearly:
"DuPont's failure to immediately inform EPA about the information concerning the human blood sampling [Teflon ingredient contaminating human cord blood] constitutes a violation of TSCA Section 8(e)..." (paragraph 46)
"The Agency considers the human blood sampling information confirming transplacental movement of PFOA [the Teflon ingredient] to reasonably support the conclusion of a substantial risk of injury to health or the environment." (paragraph 47)
"DuPont's failure or refusal to submit the human blood sampling information as required under TSCA Section 8(e) is an unlawful act..." (paragraph 52)
If the ACC and your member companies are such big supporters of the CDC's national exposure assessment, why is it that not a single chemical company has nominated even one chemical for inclusion in the assessment? Why hasn't the ACC or your members recommended chemicals for testing by the CDC?
We look forward to your response.
Sincerely yours,
Kenneth A. Cook
President
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