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What
we recommend:
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- A
significant commitment of federal research dollars
to resolve scientific questions and determine which of these
potential risks are real and which ones are not. Industry
should be encouraged to support research on these issues, but
the funds should be placed in a trust fund overseen by a governing
body including appropriate representation of all major stakeholders
to insulate researchers from the pressures of special interests.
- Improvement
of existing protections. Regulations should protect the most
vulnerable members of our community, especially children, the
unborn and the elderly. They should explicitly recognize that
compounds interact unpredictably in the real world and they come
from many sources. Enough information is already available to
warrant dramatic strengthening of the constraints on use and distribution
of a number of persistent organic pollutants, known as POPs, by
implementing international
protocols. Far more stringent testing should be required before
allowing new compounds to enter into widespread commercial use.
New products should be designed with the goal of reducing exposure.
And there should be an accelerated research program to test compounds
now in use that have escaped scrutiny.
- Fulfill
the public's right to know. People want to make informed decisions
for themselves about these issues and right now a variety of laws
and practices prevent access to crucial information.
- Build
the capacity in the United States to monitor contamination
levels, health impacts, and the links between them. The
National Center for Environmental Health at the US Centers for
Disease Control is an extraordinary national resource and needs
public support to ensure it can do its job.
- Support
implementation of the precautionary principle. Current
regulatory practices give chemical manufacturers the benefit of
the doubt. Substances can be removed from the market only
if their health impacts can be demonstrated with scientific certainty.
This burden of proof needs to be shifted. If plausible doubt
can be justified about the safety of chemical compounds, their
use should be allowed only if the manufacturer can prove they
represent no inappropriate threat to human or ecosystem health.This
is especially important for endocrine disrupting chemicals because
increasingly it appears that aspects of their modes of action
make it very difficult for epidemiological science to demonstrate
causality with certainty. On the contrary, epidemiological
studies of endocrine disruption in humans are biased toward finding
false negatives.
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