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Loopholes allow testing on children
Baltimore Sun
9/26/2005
Letter to the Editor from Natural Resources Defense Council: Aaron Colangelo

The Sun's article "Exceptions in new EPA rules would allow testing pesticides on children" (Sept. 14) exposed loopholes in an Environmental Protection Agency proposal that would allow the testing of pesticides on humans in ways many consider highly unethical.
In a letter to the editor in response, the EPA continues to mislead the public about what its human testing rule would allow ("EPA rules will not allow pesticide testing on children," letters, Sept. 20).


The EPA claims that its rule would ban certain chemical industry experiments on pregnant women and children. But EPA's rule has a "public health" exception that specifically permits tests on pregnant women and children in certain circumstances. A "ban" with an exception is not a ban.


The rule also has an escape clause for industry tests that "substantially comply" with its requirements. This undercuts the entire rule. There is no such thing as "substantial compliance" with a ban - certain human tests are either forbidden or they are not.
The EPA also insists that its rule goes to extra lengths to include "further protections" for children involved in pesticide tests. But the rule allows testing on children of "limited capability" without their consent, and on "neglected or abused children" without parental consent. These are not "further protections."


Most important, the EPA's letter avoids the fundamental problem: The EPA's rule will allow, for the first time in our country's history, systematic testing of pesticides on people.
Economic coercion will induce low-income "volunteers" to endure the significant health risks of participating in these unnecessary chemical tests.


This rule will benefit only the chemical industry's bottom line.


Aaron Colangelo
Washington