The System is Broken

The safety of chemical mixtures, including the unique mixtures to which nurses are exposed, is unknown — no safety testing is required.

Environmental Working Group studies have documented the presence of 469 chemicals in the blood, urine, and breast milk of 94 people tested, with diverse mixtures of up to hundreds of industrial chemicals, pesticides, and other pollutants in each person (e.g. EWG 2005). These exposures, called the "body burden" of chemicals, stem from contaminants in food, air, tap water, and even house dust, and also from ingredients in consumer products. People inhale these chemicals, ingest them, or absorb them through the skin.

Nurses are exposed not only to the range of chemicals found in these studies, but also to the many chemicals used in hospitals and other health care facilities. And while some health care chemicals (like drugs) have been tested for safety, the same is not true for industrial chemicals used in consumer products and found in people everywhere:

  • The complex mixtures of chemicals in the human body have never been tested for safety.
  • Even singly, chemicals are rarely tested — what's done is voluntary.
  • For chemicals invented 50 years ago or last month, the story is the same: No required testing.

Most people assume chemicals in consumer products are thoroughly tested before they are sold. But for nearly all chemicals, there is no requirement that manufacturers test their products for health effects at any stage of production, marketing, and use (Wilburn 2005). Under the Toxic Substances Control Act, the law that regulates industrial chemicals in the United States, chemical companies can put new compounds on the market with no studies of their effects on people or the environment (GAO 1994 & 2005).

When the Toxic Substances Control Act was passed in 1976, EPA grandfathered in 63,000 chemicals presumed safe or slated for review. Since then, EPA has reviewed the safety of only a small fraction:

  • EPA has not reviewed or even begun gathering safety data for more than 80 percent of the 15,000 chemicals produced or imported in annual quantities exceeding 10,000 pounds.
  • Through a voluntary program, chemical manufacturers submit screening studies on nearly 3,000 chemicals people are most likely to be exposed to. EPA, however, has no plan on how to use this data to assess public health risks.

Under current law, companies debut new consumer product chemicals in a 90-day "Premanufacturing Notification" process (EPA 1997). EPA approves the vast majority of submissions with no restrictions, and in more than half of all cases, in the complete absence of toxicity data.

  • Fewer than half of all applications to the EPA for new chemicals include any toxicity data.
  • The government approves 80 percent with no restrictions, usually in less than three weeks.
  • Any data provided are cursory, because the government lacks authority to request more.
  • If there are no data, the government uses chemical models — widely acknowledged to be inaccurate — that estimate harm to human health or the environment.

In addition to their everyday exposures to consumer product chemicals that haven't been tested for safety, nurses are also exposed to an array of unregulated hazards found in hospitals. Thus, nurses experience unique exposures that raise serious questions about potential health impacts. These exposures also argue for broad changes that would address not only nurses' exposures in hospitals, but the full scope of their exposures.