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Woodruff TJ, Rayasam SDG, Axelrad DA, Koman PD, Chartres N, Bennett DH, Birnbaum LS, Brown P, Carignan CC, Cooper C, Cranor CF, Diamond ML, Franjevic S, Gartner EC, Hattis D, Hauser R, Heiger-Bernays W, Joglekar R, Lam J, Levy JI, MacRoy PM, Maffini MV, Marquez EC, Morello-Frosch R, Nachman KE, Nielsen GH, Oksas C, Abrahamsson DP, Patisaul HB, Patton S, Robinson JF, Rodgers KM, Rossi MS, Rudel RA, Sass JB, Sathyanarayana S, Schettler T, Shaffer RM, Shamasunder B, Shepard PM, Shrader-Frechette K, Solomon GM, Subra WA, Vandenberg LN, Varshavsky JR, White RF, Zarker K, Zeise L. A science-based agenda for health-protective chemical assessments and decisions: overview and consensus statement. Environ Health 2023; 21:132. [PMID: 36635734 PMCID: PMC9835243 DOI: 10.1186/s12940-022-00930-3] [Citation(s) in RCA: 8] [Impact Index Per Article: 8.0] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [MESH Headings] [Grants] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Accepted: 10/27/2022] [Indexed: 06/17/2023]
Abstract
The manufacture and production of industrial chemicals continues to increase, with hundreds of thousands of chemicals and chemical mixtures used worldwide, leading to widespread population exposures and resultant health impacts. Low-wealth communities and communities of color often bear disproportionate burdens of exposure and impact; all compounded by regulatory delays to the detriment of public health. Multiple authoritative bodies and scientific consensus groups have called for actions to prevent harmful exposures via improved policy approaches. We worked across multiple disciplines to develop consensus recommendations for health-protective, scientific approaches to reduce harmful chemical exposures, which can be applied to current US policies governing industrial chemicals and environmental pollutants. This consensus identifies five principles and scientific recommendations for improving how agencies like the US Environmental Protection Agency (EPA) approach and conduct hazard and risk assessment and risk management analyses: (1) the financial burden of data generation for any given chemical on (or to be introduced to) the market should be on the chemical producers that benefit from their production and use; (2) lack of data does not equate to lack of hazard, exposure, or risk; (3) populations at greater risk, including those that are more susceptible or more highly exposed, must be better identified and protected to account for their real-world risks; (4) hazard and risk assessments should not assume existence of a "safe" or "no-risk" level of chemical exposure in the diverse general population; and (5) hazard and risk assessments must evaluate and account for financial conflicts of interest in the body of evidence. While many of these recommendations focus specifically on the EPA, they are general principles for environmental health that could be adopted by any agency or entity engaged in exposure, hazard, and risk assessment. We also detail recommendations for four priority areas in companion papers (exposure assessment methods, human variability assessment, methods for quantifying non-cancer health outcomes, and a framework for defining chemical classes). These recommendations constitute key steps for improved evidence-based environmental health decision-making and public health protection.
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Affiliation(s)
- Tracey J Woodruff
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA.
| | - Swati D G Rayasam
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
| | | | - Patricia D Koman
- Department of Environmental Health Sciences, School of Public Health, University of Michigan, Ann Arbor, MI, USA
| | - Nicholas Chartres
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
| | - Deborah H Bennett
- Department of Public Health Sciences, University of California, Davis, Davis, CA, USA
| | - Linda S Birnbaum
- National Institutes of Environmental Health Sciences and National Toxicology Program, Research Triangle Park, NC, USA
- Duke University, Durham, NC, USA
| | - Phil Brown
- Social Science Environmental Health Research Institute, Northeastern University, Boston, MA, USA
| | - Courtney C Carignan
- Department of Food Science and Human Nutrition, Department of Pharmacology and Toxicology, Michigan State University, East Lansing, MI, USA
| | - Courtney Cooper
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
| | - Carl F Cranor
- Department of Philosophy, University of California, Riverside, Riverside, CA, USA
- Environmental Toxicology Graduate Program, College of Natural and Agricultural Sciences, University of California, Riverside, Riverside, CA, USA
| | - Miriam L Diamond
- Department of Earth Sciences, University of Toronto, Toronto, ON, Canada
- School of the Environment, University of Toronto, Toronto, ON, Canada
| | | | | | - Dale Hattis
- The George Perkins Marsh Institute, Clark University, Worcester, MA, USA
| | - Russ Hauser
- Department of Environmental Health, T.H. Chan School of Public Health, Harvard University, Boston, MA, USA
| | - Wendy Heiger-Bernays
- Department of Environmental Health, School of Public Health, Boston University, Boston, MA, USA
| | | | - Juleen Lam
- Department of Public Health, California State University, East Bay, Hayward, CA, USA
| | - Jonathan I Levy
- Department of Environmental Health, School of Public Health, Boston University, Boston, MA, USA
| | | | | | | | - Rachel Morello-Frosch
- School of Public Health, University of California, Berkeley, Berkeley, CA, USA
- Department of Environmental Science, Policy and Management, University of California, Berkeley, Berkeley, CA, USA
| | - Keeve E Nachman
- Department of Environmental Health and Engineering, Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD, USA
- Johns Hopkins Risk Sciences and Public Policy Institute, Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD, USA
| | - Greylin H Nielsen
- Department of Environmental Health, School of Public Health, Boston University, Boston, MA, USA
| | - Catherine Oksas
- School of Medicine, University of California, San Francisco, CA, USA
| | - Dimitri Panagopoulos Abrahamsson
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
| | - Heather B Patisaul
- Department of Biological Sciences, Center for Human Health and the Environment, North Carolina State University, Raleigh, NC, USA
| | | | - Joshua F Robinson
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
- Center for Reproductive Sciences, Department of Obstetrics, Gynecology & Reproductive Sciences, University of California, San Francisco, San Francisco, CA, USA
| | | | | | | | | | - Sheela Sathyanarayana
- Department of Pediatrics, University of Washington, Seattle, WA, USA
- Department of Child Health, Behavior, and Development, Seattle Children's Research Institute, Seattle, WA, USA
| | - Ted Schettler
- Science and Environmental Health Network, Ames, IA, USA
| | - Rachel M Shaffer
- Department of Environmental and Occupational Health Sciences, University of Washington School of Public Health, Seattle, USA
| | - Bhavna Shamasunder
- Department of Urban & Environmental Policy and Public Health, Occidental College, Los Angeles, CA, USA
| | | | - Kristin Shrader-Frechette
- Department of Biological Sciences, University of Notre Dame, Notre Dame, IN, USA
- Department of Philosophy, University of Notre Dame, Notre Dame, IN, USA
| | - Gina M Solomon
- School of Medicine, University of California, San Francisco, CA, USA
- Public Health Institute, Oakland, CA, USA
| | - Wilma A Subra
- Louisiana Environmental Action Network, Baton Rouge, LA, USA
| | - Laura N Vandenberg
- Department of Environmental Health Sciences, School of Public Health & Health Sciences, University of Massachusetts, Amherst, Amherst, MA, USA
| | - Julia R Varshavsky
- Department of Health Sciences, Northeastern University, Boston, MA, USA
- Department of Civil and Environmental Engineering, Northeastern University, Boston, MA, USA
| | - Roberta F White
- Department of Environmental Health, School of Public Health, Boston University, Boston, MA, USA
| | - Ken Zarker
- Washington State Department of Ecology, Olympia, WA, USA
| | - Lauren Zeise
- Office of Environmental Health Hazard Assessment, California Environmental Protection Agency, Oakland, CA, USA
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