Environmental Health:

EPA Efforts to Address Children's Health Issues Need Greater Focus, Direction, and Top-Level Commitment

GAO-08-1155T: Published: Sep 16, 2008. Publicly Released: Sep 16, 2008.

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According to EPA, children face disproportionate risks from contaminants such as air pollution and lead paint. The health consequences to the country's 74 million children are significant. In 2006, 55 percent of children lived in counties exceeding allowable levels for at least one of the six principal air pollutants such as ozone which causes or aggravates asthma. Asthma is the third-most common cause of childhood hospitalization, resulting in $3.2 billion in treatment costs and 14 million lost school days annually, according to the Centers for Disease Control and Prevention. In 1997, EPA created the Office of Children's Health and convened the Children's Health Protection Advisory Committee (Advisory Committee) to provide advice and recommendations to assist in developing regulations, guidance, and policies to address children's health. In April 1997, the President signed Executive Order 13045, creating an interagency Task Force to recommend federal strategies for protecting children. Our testimony is based on ongoing work on the extent to which EPA has used the Advisory Committee and addressed the committee's key recommendations. It also includes information about the Task Force. We met with numerous EPA officials and analyzed the committee's letters. GAO recommends, among other things, that EPA expeditiously complete its review of the Advisory Committee's key recommendations.

EPA has not proactively used the Advisory Committee to ensure that the agency's regulations, guidance, and policies address the disproportionate risks that environmental contaminants pose to children. Our analysis found that the Advisory Committee met more than 30 times and discussed a variety of environmental health issues with dozens of officials from EPA offices such as Pesticides and Toxic Substances, and Research and Development. However, we identified just three instances where EPA specifically asked the committee for recommendations and advice on regulations--most notably an October 1997 request that the committee identify five regulations or standards for EPA to re-evaluate in order to better protect children. In the absence of focus and direction from EPA, the Advisory Committee has taken the initiative to write more than 70 letters to the Administrator since 1998 containing hundreds of recommendations on a wide variety of children's health concerns. EPA has not addressed key recommendations from its Advisory Committee, particularly those in a major April 2007 letter and in recent letters advising EPA on proposed revisions to national air quality standards. The April 2007 letter, which marked the 10th anniversary of the Executive Order, provided recommendations in seven key areas. These included the need for EPA to eliminate environmental health disparities among low-income and minority children. While EPA generally responds to the Advisory Committee's letters, the agency has not fulfilled the Administrator's commitment in his response to the 10th anniversary letter to collaboratively review recommendations from the advisory committee. The Office of Children's Health had begun forming internal workgroups, but a new acting director stopped the process in late 2007 to hold individual meetings with EPA's assistant administrators, and the process remains stalled. We also analyzed EPA's responses to the committee's specific recommendations on three recently-considered EPA air quality standards--the National Ambient Air Quality Standards for particulate matter, ozone, and lead--and we found that EPA either offered to consider the committee's recommendations as part of the public comment process or rejected them. The President's Task Force, which was authorized in April 1997, provided high-level interagency leadership and coordination on children's environmental health, but it expired in April 2005. According to the children's health experts with whom we spoke, the task force provided important leadership on initiatives such as the National Children's Study and the Healthy Schools Environmental Assessment Tool. The task force also developed federal strategies to address four threats to children--asthma, developmental disorders, cancer, and unintentional injuries. In 2003, the President ordered the task force to be extended by 2 years, but the order eliminated the provision for reassessing the task force. Since the task force's expiration, EPA no longer has a high-level infrastructure or mandate to coordinate federal strategies for children's environmental health and safety.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: Starting in September 2009, the EPA Administrator sought the advisory committee's input on regulations, programs, plans and other issues. In 2010, many of these efforts were implemented, including a request for assistance in developing school siting guidelines, air issues and in September 2010, the advisory committee presented areas of mutual interest to the EPA Science Advisory Board.

    Recommendation: The Administrator of EPA should examine ways to more proactively use the committee to reinvigorate its focus on protecting children's environmental health.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: EPA has taken actions to address its advisory committee's recommendations, despite the elimination of the cross agency process. For example, to demonstrate EPA's vision on children's health, the EPA Administrator issued a memo in February 2010 demonstrating the agency's commitment to ensuring that children's health proteciton is the driving force in all agency decisions including regulation, implementation of community based programs, research, and outreach. In addition, to address a key advisory committee recommendation to help eliminate health disparities among children EPA has taken actions includilng the development of a cross agency strategy for environmental justice and children's health. Further, EPA has taken actions to ensure healthy environments where children live, learn and play by awarding cooprerative agreements for place based approaches to promote children's environmental health in underserved communities and released its School Siting Guidelines in 2011 among other efforts.

    Recommendation: To honor the Administration's commitment to the Children's Health Protection Advisory Committee, the Office of Children's Health Protection should expeditiously complete the cross-agency process to review the committee's key recommendations.

    Agency Affected: Environmental Protection Agency: Office of Children's Health Protection

 

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