Lessons learned from the Children's Environmental Exposure Research Study

Dollars and Deadlines: Rule Reforms in Short Time Frames

In “At Last! Aye, and there’s the Rub,” (2017), Capron describes challenges related to the timing for development, adoption, and revision of the Common Rule. Capron argues that the difficulty of making changes over the ten years required before agencies adopted the original Common Rule created an “all or nothing” atmosphere. That is, because of the effort required, agencies were loath to make incremental changes and instead “take up every possible revision at once” with the process that culminated in the recently revised Rule. Here we briefly describe the efforts of one agency -- the U.S. Environmental Protection Agency (EPA) -- that made interim changes to its human subjects protections within a 180 day time frame, and the opportunities and challenges that such an ambitious goal created.

Environmental and Occupational Health

Environmental and occupational health is affected by chemical, physical, radiological, and biological agents in the air, water, and soil. Health risks include injury, and exposure to toxic radiation, carcinogenic and teratogenic agents, leading to cancer, lung and heart diseases. Environmental factors may result in instant death or long-term illness from unsafe environmental or working conditions. The environment affects populations from small workplace settings to large-scale communities, as well as having global effects. International and governmental responsibility, through policies, laws, regulations, standards, policies, and planning, is vital for tackling global aspects of pollution, including climate change, cataclysmic natural events, drought, air and water pollution, and the potentially catastrophic effects of weather changes. Preparation for disasters is a core public health function in managing the after-effects of tsunamis, hurricanes, floods, and drought. These are potent political and public health issues with huge economic and societal effects.

Environmental health research and the observer's dilemma

BACKGROUND

Environmental health researchers frequently study people in occupational, educational, recreational, or domestic settings who are exposed to hazardous agents.

OBJECTIVE/DISCUSSION

Deciding whether-and how-to inform research subjects about risks they face in their environment can be a challenging task for investigators. Because legal rules and professional guidelines do not cover this topic, investigators must carefully consider their ethical obligations in light of the facts and circumstances.

CONCLUSION

To navigate through this dilemma, investigators should consider the evidence for the risks, the nature of the risks, the usefulness of risk information to the subjects, and the effects on the study and community of informing subjects about risks.

Environmental Health Research Involving Human Subjects: Ethical Issues

This article reviews some of the ethical issues that arise in environmental health research with human subjects, such as minimizing risks to subjects, balancing benefits and risks in research, intentional exposure studies with human subjects, protecting third parties in research, informing subjects about environmental hazards, communicating health information to subjects, and protecting privacy and confidentiality.

EPA's 2006 human-subjects rule for pesticide experiments

Arguing that the 2006 Environmental Protection Agency (EPA) human-subjects rule allows use of unethical third-party research (on pregnant women and children) in setting pesticide regulations, this article first (a) provides a brief history of U.S. pesticide regulation, particularly regarding childhood safety. Next it (b) outlines ethical and scientific loopholes in the 2006 EPA rule; (c) shows how the Human Subjects Review Board, mandated by the 2006 rule, has been implemented in flawed ways; and (d) illustrates that one source of problems with the rule may be influence by those with conflicts of interest.

Are the new EPA regulations concerning intentional exposure studies involving children overprotective?

The Environmental Protection Agency (EPA) has adopted new regulations that prevent the agency from conducting or funding intentional exposure research involving children, pregnant women, or fetuses. This commentary argues that these regulations overprotect children, and that the EPA should revise its regulations to bring them into conformity with the Common Rule’s special protections for children.