Advisory Committee Regulatory Re

- evaluation Report

- Office of Children's

Health Protection



### Report of the

**Children's Health Protection Advisory Committee to the U.S. Environmental Protection Agency**  **Regarding the Selection of Five Regulations**

**for Re**  **- Evaluation**  **Submitted by Dr. J. Routt Reigart, Chair**  **Children's Health Protection Advisory Committee**

**May 28, 1998 Report of the Children's Health Protection Advisory Committee** 

**to the U.S. Environmental Protection Agency Regarding the Selection of Five R**  **egulations for Re**
**- Evaluation** 

**PREA MBLE**  The Children's Health Protection Advisory Committee (CHPAC) was formed to advise, consult with, and make recommendations to the U.S. Environmental Protection Agency (EPA) on issues associated with the development of regulations to address the prevention of adverse health effects to children. One of the CHPAC's primary

missions is to identify

five existing EPA regulations, which if re

- evaluated, could lead to better protection for children. The CHPAC established a high ly iterative process, which involved the development of guiding criteria, review of potential environmental health risks to children, and an assessment of the status of regulation, enforcement, and implementation. The CHPAC, with its broad representation o f industry , environmental, health, and children's organizations, arrived at consensus agreements through its deliberations. This reflected the CHPAC members' common commitment to find better way s to incorporate children's health concerns into environmental regulatory decision making. One key tool used by

the CHPAC in its deliberations was the development of seven screening criteria to select rules for re

- evaluation that would positively impact children's health protection either substantively

or procedurall y (Attachment A). The CHPAC approached the assignment to identify five existing regulations from a holistic, health

- based strategy . First, the CHPAC considered specific substances and routes of exposure that may pose a greater health risk to children and s econd, determined which regulatory

provisions were applicable. For instance, if the CHPAC determined that new evidence suggests a reanal ys is because of a potential risk to children for a particular substance, then it recommended that this information shoul d be considered in all regulations of that chemical. In re

-evaluating regulations, children's differential and cumulative routes of exposure should be considered.

Thus, the CHPAC's recommendations are listed as issues of concern with the specific regulatio ns identified under each heading. The five issues selected by the CHPAC are: 1. Mercury 2. (Farm) Worker Protection Standard 3. Triazine Pesticides 4. Organophosphates and Carbamates 5. Air Quality

and Asthma During the CHPAC's deliberation process, several critical issues that impact children's health were identified but not selected because they were beyond the immediate task of identifying five existing regulations for expedited review or because of regulatory timing conflicts. These issues represent important oppo rtunities for EPA to address serious potential health risks to children, but broader agency policies, authorities, or structure may need to be reconsidered. Therefore, the CHPAC also provided broad recommendations that merit the attention of EPA. The CHPAC is hopeful that the broad recommendations for process improvements will receive expeditious action and contribute meaningful long term enhancements to EPA's efforts to protect children's health. The CHPAC expects EPA to report back on its recommendations to repropose or not repropose the selected regulations by

December 1998, and is also hopeful that it will continue to advise EPA throughout its regulatory

re - evaluation process. **MERCURY Specific Standard to Re** 
**- Evaluate:**  National Emission Standard for Hazardous Air Pollutants (NESHAP) for Chloralkali Plants **Other Focus Areas for Multimedia Strategy:** Water Quality

Criteria Standard Regulatory

Determination for Electric (Coal

- Burning) Utility Boilers Hazardous Waste Combustion Rule Medical Waste Combustion Rule Municipal Waste Combustion Rule
The CHPAC recommends that EPA take a holistic approach to evaluate all sources of mercury emissions. Mercury

is a relevant issue to more than one media (air, water), which contributes to its entry into the environme nt, for example, by electricit y (coal

- burning) generation, incineration and discharge into water sources. Human exposure occurs primarily through fish consumption. Mercury exposure is associated with adverse health effects in humans. Depending on dose, the effects can range from severeto less severe, most notably , neurological, developmental, and reproductive effects.

By the end of 1998, EPA is scheduled to complete a multimedia strategy addressing mercury . We support EPA's multimedia approach and schedule for the issuance of this strategy

. We encourage EPA to proceed diligentl y with implementation to protect children from mercury emissions, including those from municipal, medical, and hazardous waste combustion. Although the CHPAC selected the National Emi ssion Standard for Hazardous Air Pollutants (NESHAP) for Chloralkali Plants for re

- evaluation, EPA resources should not be diverted from the evaluation of other larger sources of mercury emission. Important criteria for its selection are that the standard has not been re

- evaluated or revised since its promulgation in 1973, children's health was not considered in the original development of the standard, and new information and data based on peer reviewed science suggest that risks to children and the persis tent and bioaccumulative nature of mercury were not considered during the setting of the standard. The CHPAC recognizes the Water Qualit y Criteria Standard as one means by which the EPA can regulate the prevention of contaminated fish b y m ercury and ensure children's protection from hazardous levels of mercury . The CHPAC recommends that EPA address the largest sources of mercury emissions expeditiously

and prevent further contamination of fish by revising the Water Quality Criteria Standard. Studies have sh own that once mercury enters water, either directly or through air deposition, it can bioaccumulate in fish and animal tissue at the top of the food chain in concentrations much greater than those found in water. Another specific concern is the emission of mercury from Electric (Coal

- Burning) Utility Boilers (regulatory

determination by

the EPA is due in November 1998). Important criteria for its selection are that there is currentl y no regulation of hazardous air pollutant emissions, such as mercury , from electric utility boilers, and electric utility boilers are the largest contributor of overall anthropogenic sources of mercury emissions in the United States (EPA Mercury Report to Congress 1997). **(F ARM) WORKER PROTECTION STA**  **NDARD Specific**  **Regulations/Standards:** Worker Protection Standards (WPS)
Children may

be exposed to pesticides through employ ment in farm work, by

eating fruits and vegetables directl y from the fields while at work, or by drift from field applications to neighboring r esidential areas and schools. Pregnant and lactating women who work in farm fields or reside in neighboring areas can also expose fetuses and neonates to pesticides. The current (farm) worker protection standard has not considered these pesticide exposures to children. Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA has the authority to regulate these childhood and prenatal exposures to pesticides through the worker protection standardincluding labeling, reentry intervals, person al protective equipment, worker education and training, and

posting and signs. The CHPAC recommends that EPA expeditiously re - evaluate the worker protection standard in order to determine whether it adequately protects children's health. In its re

- evaluati on, EPA should, for example, consider using standardized data on size and age

- specific weight and height for modeling children's exposure when more specific data on children's exposure to individual pesticides may be lacking. **TRIA ZINE PESTICIDES**  **Specific R egulations/Standards:**  Atrazine Drinking Water Maximum Contaminant Level (MCL) Atrazine Pesticide Tolerance
Atrazine is an herbicide that belongs to the triazine class. Atrazine has been linked to adverse health effects including cancer and birth defects. Atrazine has been detected in drinking water throughout the midwest and other parts of the nation. When EPA established the tolerance and 1991 drinking water standards for atraz ine, children's differential exposure was not considered and children's differential susceptibility

was not fully

evaluated. New information has since becomeavailable to the EPA concerning the mechanism of action underl yi ng its carcinogenic effect. Hormona l effects were further investigated and triggered the need for the re

- evaluation of both the carcinogenic effects of this compound as well as the developmental and reproduction studies. Reviewing the tolerances and the established drinking water standard i n concert will provide EPA with an opportunity to evaluate a chemical's impact on children's health via aggregate routes of exposure. Reconsideration of the tolerances and drinking water standard for atrazine should be given top priority in EPA's implement ation of the Safe Drinking Water Act and the Food Quality Protection Act. **ORGA NOPHOSPHA** **TES A ND CA**  **RBA MA** **TES Specific Regulations/Standards:**  Pesticide Tolerances for Methyl Parathion, Dimethoate, and Chlorpy rifos
EPA scientific panels have found that organophosphate and carbamate insecticides disrupt the central nervous s ys tem via a cholinesterase inhibition mechanism of toxicity . Because children's central nervous s ys tems continue to develop until puberty , they are particularl y vulnerable to the effects o f some neurotoxins. Children can be exposed to these insecticides through food, homes, schools, employ ment, and other sources. Data indicate that children's patterns of dietary intake are distinct from adults' patterns. When EPAestablished the tolerances for these insecticides, children's differential exposure was not considered and

children's differential susceptibility was not full y evaluated. Of the 39 pesticides registered for use on food, thirteen are detected in food according to FDA and USDA pestici de residue data. Five of these account for 90 percent of the dietary risk of neurotoxicity

and three (methyl parathion, dimethoate, and chlorpy rifos) represent the bulk of that risk. Reconsideration of the tolerances for these three pesticides should be gi ven top priority in terms of data collection and other necessary steps in EPA's implementation of the Food Quality Protection Act. **AI R QUA**  **LITY AND**  **ASTHM A** 
**Areas for Review:** Indoor Air Quality Ambient Air Quality

Standards (Particulate Matter (PM), Sulphur Dioxide (SO2))