Re: ALERT: EPA to Allow Pesticide Testing on Orphans & Mentally Hadicapped Children
1) Question: I read on Snopes that this alert is false. Is that true?
Answer: The Snopes/Urban Legends posting is actually in regards to an EPA proposed study called CHEERS and an alert we had sent out regarding that in late 2004 (http://www.organicconsumers.org/epa-alert.htm). It is not directly related to this alert. The Snopes posting did a great disservice to that issue in their inaccuracy and lack of research into this issue. We spend massive amounts of staff time researching these issues, confer with outside experts on the topic, and cite dozens of references. The Snopes website, while valuable with most of its information, is not always accurate, and that is the case here. In fact, you'll find they reference only a couple of newspaper articles to backup their stance on this issue. Fortunately, enough concerned citizens, several nonprofits, dozens of mainstream newspapers, and many congress members, actually did their research on the EPA study and found that study was, in fact, very problematic. In fact, in early 2005, the EPA CHEERS study was permanently dropped, thanks to pressure from Congress. In August of 2005 Congress went a step further and mandated the EPA pass a rule that bans all testing of chemicals on children and pregnant women, without exception. That is what this alert pertains to. Snopes hasn't posted any information about this particular alert, and we hope they do their research this time. We ask our readers to do your research, as well. No single alert or single website will provide you with all of the information you need. We provided dozens of links on our alerts to external resources that allow you to further research and reference all of the information we provide. If you have questions, we're always happy to help out firstname.lastname@example.org
2)Question: I read the EPA website and part of the introduction of the rule, claims the rule is to prohibit all such testing and to establish sanctions. That sounds like a good thing. So what's the problem?
Answer: The EPA is proposing a rule that they would like to have approved. Anytime you are marketing a product, you sell its best points and hope that people won't look too deeply and find its flaws. The EPA website and the introductory description of the rule are very long winded and flowery, claiming this rule abides by the congressional mandate to ban all testing of women and children, without exception. In fact, if you read the rule, which is 30 pages of fine print, there are multiple exceptions. We have noted those in our template letter to the EPA and on our action alert page. This is a specific layout of the problematic text as taken directly from the actual EPA rule. In short, these are the loopholes in the document that need to be removed, as mandated by congress, which says the rule must have no exceptions.
3) Question: The rule says these waivers apply when the IRB sees a benefit of the test for the children involved, and also calls for supplementary protective measures when necessary. That sounds like a good thing. So what's the problem?
Answer: Actually, you are referencing a point made under subpart §26.405 of the rule. That subpart is designed to only address "research presenting the prospect of direct benefit to the individual subjects." In that subpart, it says that "more than minimal" risk to children subjects is acceptable if there is a chance it could benefit the child. Outside of that subpart, there are no stipulations requiring that the studies be beneficial to the test subjects. Anywhere else in the document where this type of situation is noted, it is under an "or" clause. In other words, the loopholes for this rule state that the rule can be disregarded if the study was done overseas, OR the test subject's guardian consents, OR if the study may be of benefit to society as a whole, OR if the study may be of benefit to the test subject, etc. The study also calls for supplementary protective measures when necessary but outlines no criteria for how this "necessity" is defined or determined. Without a clearly defined line of what is acceptable and what is not, it's at the whim of the IRB, EPA administrator or third party research organization to determine whether or not supplementary protective measures are necessary. In that sense, it could simply mean the IRB might determine, for example, a test subject should wear safety goggles when being doused with atrazine. In other words, without specific definition of what defines a situation that calls for further supplementary protective measures, this becomes a simple, flowery token statement with no meaning and no teeth.
I hate it when they say, "He gave his life for his country." Nobody gives their life for anything. We steal the lives of these kids. We take it away from them. They don't die for the honor and glory of their country. We kill them."-- Admiral Gene LaRocque