November 2, 1998
Dear Administrator Browner:
We regret very much the impending departure from EPA of Dr. Lynn Goldman as Assistant Administrator for Prevention, Pesticides, and Toxic Substances. We are writing to urge, in the strongest possible terms, the appointment of a successor who brings the same special sensitivities, knowledge and skills that Dr. Goldman applied to this position.
As a trained pediatrician, Dr. Goldman was especially attuned to the challenges toxic chemicals pose to developing fetuses, infants, and children. While there are numerous issues for which those skills and expertise are crucial, this letter focuses on three - endocrine disrupting chemicals (EDCs), children's health, and persistent organic pollutants (POPs) - that are of special interest and concern to our undersigned organizations.
During the past two years, Dr. Goldman and her staff have been charged with responding to the special provisions of the Food Quality Protection Act (FQPA) that are especially designed to protect young individuals, and the FQPA and Safe Drinking Water Act amendments requiring EPA to establish a screening program for EDCs. Dr. Goldman provided stellar leadership to the EPA Endocrine Disruptor Screening and Testing Advisory Committee (EDSTAC), which generated strong stakeholder-based consensus recommendations on how EPA should respond to this congressional mandate.
Growing scientific knowledge about EDCs, and their possible links to a broad range of diseases and disabilities, poses a fundamental challenge to the traditional toxicological approaches that underlie current EPA procedures for judging hazards from chemicals. There is growing recognition that it is not only the dose, but also the timing, that makes the poison - low dose exposures in the womb, to synthetic chemicals commonly found in the environment, can have serious long term effects for developing humans and wildlife. Traditional high-dose testing on adult animals simply is insufficient for identifying hazards from EDCs. As a pediatrician, Dr. Goldman understood this innately.
Endocrine disruption is an integral part of the Clinton Administration's broader initiative on children's health, an initiative that you championed internationally through the G-8 consultative process. Achieving full FQPA protection of infants and children from exposure to hazardous pesticides in food will likely result in the elimination of and/or severe restriction on
use of certain high-risk pesticides. Fortunately, FQPA implementation is occurring in an era of rapid progress in the discovery and registration of safer bio-pesticides and innovation in pest and soil management techniques.
When you appointed pediatrician Dr. Philip Landrigan as your senior advisor for children's environmental health, this signaled your recognition of the special skills and knowledge that are necessary for dealing with developmental and other health-related threats. You should make a similar appointment for replacing Dr. Goldman.
Dr. Goldman's expertise also has benefited U.S. government planning for and participation in the UNEP-hosted global POPs treaty negotiations now underway. POPs represent a global challenge: they are extremely toxic, with the potential to injure wildlife and humans even at low concentrations; they can travel far from their original sources; they are highly persistent, resisting photolytic, chemical and biological degradation; and they bioaccumulate in fatty tissues of living organisms, increasingly so as they move up the food chain. Moreover, all twelve of the priority POPs receiving special, up-front attention in the treaty negotiations are EDCs.
In people as in wildlife, injury caused by exposure to POPs is often expressed, not in the exposed adult population, but in the offspring population. Maternal body burdens of POPs are transferred through the placenta to the developing fetus and through breast milk to the nursing infant, and can cause injury at vulnerable stages of development that many not be expressed until the infant reaches puberty or adulthood. Dr. Goldmanís medical training strengthened her hand in calling for strong action on POPs when she spoke on behalf of the U.S. government in forums such as the opening round of the POPs treaty talks this past summer in Montreal.
We encourage you to search broadly for an individual who through her or his professional training and accomplishments has the necessary background to understand and champion forceful action on the above recognized environmental and human health hazards, among others. Among other tasks, this person should be prepared to strongly advocate:
Substantially Increased Funding for Work on Endocrine Disruption: EDSTAC's recommendations should not languish and suffer from the same slow implementation as TSCA's testing requirements. Testing should be combined with substantially increased research on endocrine disrupting chemicals, collaboratively with industry and internationally with other governments;
Vigorous Protections Against the Highest Risk Crop-Pesticide Combinations Responsible for the Greatest Risk to Children: Along with USDA, EPA should prioritize transition efforts to ensure that risk reduction consistent with FQPA health standards is achieved. These efforts should promote and accelerate farmersí progress along the pest and soil management continuum toward safer, more biologically based pest management systems; and
Phase Out and Elimination of POPs and Any Significant Anthropogenic Sources Thereof: This should be accomplished through an expedited, orderly and just transition globally, as well as through regional and bilateral initiatives. Where uncertainty remains about the effects of a POP, action should be taken based on the weight of evidence approach, consistent with the precautionary principle, giving special consideration to the risks to fetuses, children and other vulnerable populations.
If, rather than selecting a new administrator, you opt instead to appoint an acting administrator from within existing EPA staff for the duration of the current Administration, this person should be closely allied with Dr. Goldmanís efforts and should bring to this position the same sensitivities.
At a time that is mutually convenient to you and a core delegation of representatives of the undersigned organizations, we would appreciate having the opportunity to meet and discuss our views on this matter with you in more detail.
Respectfully,
List of organizations/representatives with degree and title, where appropriate, as well as phone, address and e-mail.
Comments on this posting?
Click here to post a public comment on the Trash Talk Bulletin Board.
Click here to send a private comment to the Junkman.
Copyright © 1998 Steven J. Milloy. All rights reserved on original material. Material copyrighted by others is used either with permission or under a claim of "fair use." Site developed and hosted by WestLake Solutions, Inc.
Material presented on this home page constitutes opinion of Steven J. Milloy.