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Natural Resources Defense Council Backgrounder
September 20, 2005

The Baltimore Sun published an article last week titled "Exceptions in New EPA Rules Would Allow Testing Pesticides on Children." In a letter to the editor in response, EPA charges that the Sun's article "seriously misleads the public regarding a complex issue." However, the Sun had it right in its original report, and EPA continues to mislead the public about what its human testing rule allows.

EPA's Claim: "The proposed rules would ban any person or entity who intends to submit his or her research to EPA under the pesticide laws from conducting any intentional dosing studies with pregnant women or children."

What EPA Leaves Out: EPA will accept the chemical industry's human studies if they are found to be "crucial to the protection of public health," expressly including an "intentional dosing study involving pregnant women or children as subjects." A "ban" with an exception is not a ban.

Human tests conducted after the rule is finalized need only "substantially comply" with the rule. This escape clause undercuts the entire rule. As Representative Hilda Solis said on this issue: "The vague standard of substantial compliance wrongly sends the signal that EPA will not demand strict adherence to ethical standards in human pesticide experiments." There is no such thing as "substantial compliance" with a "ban" - certain human tests are either forbidden or not.

EPA's Claim: "The proposed rules would ban the Environmental Protection Agency from conducting or supporting any intentional dosing study of pregnant women or children with pesticides or any other environmental substances"

What EPA Leaves Out: The proposed rules allow EPA to conduct or support intentional dosing studies on children with pesticides or any other chemical by doing the research overseas. The rules also allow EPA tests that intentionally expose pregnant women or children to food sprayed with pesticides up to the current legal limit.

EPA's Claim: "The proposed rules also include further protections for other types of research that do not involve 'intentional dosing.'"

What EPA Leaves Out: 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, EPA's claims about protecting pregnant women and children obscures the more important issue: EPA's rule will allow, for the first time in our country's history, systematic testing of pesticides on people. Even if in some circumstances EPA will not allow that testing on pregnant women or children, EPA has thrown open the door for chemical tests on other "volunteers." Furthermore, the rule is rife with loopholes and exceptions that will allow human tests that most people would consider unethical and inappropriate. This rule will benefit the chemical industry's bottom line at the expense of public health.