January 24, 2005
Stephen L. Johnson
Deputy Administrator, Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave. NW
Washington, DC 20460
Dear Deputy Administrator Johnson:
On November 10, 2004, the EPA announced the suspension of the Children's Environmental Exposure Research Study, known as CHEERS, and the creation of a panel of experts to review the ethics, scientific integrity and methodology of the proposed study.
The Environmental Working Group (EWG) supports this decision, and we are writing today to request that you ensure fair and balanced representation on this panel. By that we mean that there should be no past or present pesticide or chemical industry employees, consultants or contractors on the review panel, and that there must be several individuals with strong public health credentials, including expertise in pediatric environmental health.
As you know, EWG and others found fault with many aspects of this proposed research, from the use of industry money and scientists to the small sample size, enormous expense per child, numerous methodological lapses, and above all, the fundamentally unethical nature of the study design, which proposed to stand by and simply observe what the study acknowledged to be high pesticide exposures to infants and small children.
Given this litany of fundamental flaws, we are hard pressed to see how a study that in any way resembles the CHEERS study could proceed at all.
We look forward to your reply and thank you very much for your attention to this matter.
Senior Vice President
Susan B. Hazen, Acting Assistant Administrator for Office of Prevention, Pollution and Toxic Substances
James J. Jones, Director, Office of Pesticide Programs
Michael Brown, Associate Assistant Administrator for Research and Development