Environmental Health:

High-level Strategy and Leadership Needed to Continue Progress toward Protecting Children from Environmental Threats

GAO-10-205: Published: Jan 28, 2010. Publicly Released: Mar 17, 2010.

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Exposure to toxic chemicals or environmental pollutants may harm the health of the nation's 74 million children and contribute to increases in asthma and developmental impairments. In 2007, 66 percent of children lived in counties exceeding allowable levels for at least one of the six principal air pollutants that cause or aggravate asthma, contributing to medical costs of $3.2 billion per year, according to the Centers for Disease Control and Prevention. In 1997, Executive Order 13045 mandated that agencies place a high priority on children's risks and required that policies, programs, activities, and standards address those risks. In response, the Environmental Protection Agency (EPA) created the Office of Children's Health Protection and convened the Children's Health Protection Advisory Committee. This report assesses the extent to which EPA has institutionalized consideration of children's health through (1) strategies and priorities, (2) key offices and other child-focused resources, and (3) participation in interagency efforts. GAO reviewed numerous documents and met with EPA and other officials for this report.

EPA has developed policies and guidance to consider children, but it has not maintained attention to children through agency strategies and priorities. In 1996, EPA created a national agenda on children's health, and its 1997 and 2000 strategic plans highlighted children's health as a key cross-agency program. As a result, the agency's research advanced the understanding of children's vulnerabilities. However, EPA has not updated the agenda since 1996, and the focus on children is absent from the 2003, 2006, and September 2009 draft strategic plans. EPA has not fully used the Office of Children's Health Protection and other child-focused resources. The active involvement of managers from the office and experts from the Children's Health Protection Advisory Committee has been lacking, as has the involvement of key staff throughout EPA. Although EPA now has a new Director of Children's Health, the office had not had consistent leadership since 2002, hampering its ability to support and facilitate agencywide efforts and elevate matters of importance with senior officials. For example, a previous director established workgroups to bring together officials from the program offices and the children's health office, but a subsequent acting director eliminated these groups, effectively halting work on a key set of children's health recommendations. In addition, the regional children's health coordinators--who provide outreach and coordination for EPA--have no national strategy or dedicated resources. Finally, the advisory committee has provided hundreds of recommendations, but EPA has requested advice on draft regulations only three times in the last decade. While EPA leadership is key to national efforts to protect children from environmental threats, EPA's efforts have been hampered by the expiration in 2005 of certain provisions in the executive order. For example, the Task Force on Children's Environmental Health provided EPA with a forum for interagency leadership on important federal efforts, such as the National Children's Study. It also provided biennial reports that helped establish federal research priorities.

Matter for Congressional Consideration

  1. Status: Open

    Comments: pending

    Matter: Because EPA alone cannot address the complexities of the nation's challenges in addressing environmental health risks for children, Congress may wish to consider re-establishing a government-wide task force on children's environmental health risks, similar to the one previously established by Executive Order 13045 and co-chaired by the Administrator of EPA and the Secretary of Health and Human Services. Congress may wish to consider charging it with identifying the principal environmental health threats to children and developing national strategies for addressing them. Congress may also wish to consider establishing in law the Executive Order's requirement for periodic reports about federal research findings and research needs regarding children's environmental health.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA has addressed this recommendation by taking the following actions. First, EPA updated its children's health agenda as described by the EPA Administrator in a February 2010 memo to staff. EPA's agenda focuses on protecting children through safe chemicals management, stating that the agency will use the best science to ensure that regulations protect children's environmental health, and coordinating national and international community based programs to eliminate threats to children's health. Second, in September of 2010, EPA submitted its FY2011-2015 strategic plan to the U.S. Congress and the Office of Management and Budget (OMB). The plan included a cross-cutting strategy entitled: "Working for Environmental Justice and Children's Health." The cross-cutting strategy guides EPA's children's health work and is supported by annual action plans and progress reports.

    Recommendation: To help ensure that EPA assumes high-level leadership and develops strategies and structures for coordinating efforts addressing children's environmental health both within the agency and throughout the federal government, and to maximize opportunities to institutionalize children's health throughout the agency, the EPA Administrator should update and reissue a child-focused strategy, such as the 1996 National Agenda, to articulate current national environmental health priorities and emerging issues.

    Agency Affected: Environmental Protection Agency

  2. Status: Open

    Comments: pending

    Recommendation: To help ensure that EPA assumes high-level leadership and develops strategies and structures for coordinating efforts addressing children's environmental health both within the agency and throughout the federal government, and to maximize opportunities to institutionalize children's health throughout the agency, the EPA Administrator should strengthen the data system that identifies and tracks development of rulemakings and other actions to ensure they comply with the 1995 policy on evaluating health risks to children.

    Agency Affected: Environmental Protection Agency

  3. Status: Open

    Comments: pending

    Recommendation: To help ensure that EPA assumes high-level leadership and develops strategies and structures for coordinating efforts addressing children's environmental health both within the agency and throughout the federal government, and to maximize opportunities to institutionalize children's health throughout the agency, the EPA Administrator should re-evaluate the 1995 policy to ensure its consistency with new scientific research demonstrating the risks childhood exposures can have on risks for disease in later lifestages.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Implemented

    Comments: On September 30, 2010, EPA submitted its FY 2011-2015 strategic plan to the U.S. Congress. In it, EPA included children's health and environmental justice as a cross-cutting strategy. This cross-cutting strategy, "Working for Environmental Justice and Children's Health" is supported by annual action plans and progress reports. The action plans contain children-specific goals. For example, EPA committed to advancing the use of Integrated Pest Management (IPM) in settings where children are present with a focus on schools, with the long-term goal that every school in America is managed under a verifiable IPM program. Further, the strategic plan also contains children-specific goals. For example, one of EPA's goals related to children's health is to reduce the percentage of children with blood lead levels above 5 ig/dl to 1.0 percent or less by 2014. In addition, the Office of Children's Health Protection (OCHP) finalized its office-wide strategic plan in September of 2010. The plan describes the goals, objectives, and measures that OCHP will use to fulfill the office mission. Further, OCHP plans to set targets for the strategic plan measures to support the priorities of the Agency and OCHP. EPA's and OCHP's actions meet the intent of our recommendation.

    Recommendation: To help ensure that EPA assumes high-level leadership and develops strategies and structures for coordinating efforts addressing children's environmental health both within the agency and throughout the federal government, and to maximize opportunities to institutionalize children's health throughout the agency, the EPA Administrator should ensure that the EPA's 2009-2013 strategic plan expressly articulates children-specific goals, objectives and targets.

    Agency Affected: Environmental Protection Agency

  5. Status: Closed - Implemented

    Comments: In a February 2010 memo to EPA senior managers, the Administrator reaffirmed EPA's commitment to protecting children's health, described EPA's children's health agenda, and identified OCHP as having the lead in ensuring that EPA programs and regions are successful in their efforts to protect children's health. Further, she identified the OCHP director as the main contact to assist in these efforts. In its role as the agency's lead, OCHP developed an office-wide strategic plan for fiscal years 2011-2013. The plan, which was finalized on September 2010, aligns with EPA's cross-cutting strategy on environmental justice and children's health.

    Recommendation: To help ensure that EPA assumes high-level leadership and develops strategies and structures for coordinating efforts addressing children's environmental health both within the agency and throughout the federal government, and to maximize opportunities to institutionalize children's health throughout the agency, the EPA Administrator should re-evaluate the mission of the Office of Children's Health Protection and its director to make the office an agencywide champion for implementation of a reissued national children's environmental health agenda, policy, and related goals in the next EPA strategic plan.

    Agency Affected: Environmental Protection Agency

  6. Status: Open

    Comments: pending

    Recommendation: To help ensure that EPA assumes high-level leadership and develops strategies and structures for coordinating efforts addressing children's environmental health both within the agency and throughout the federal government, and to maximize opportunities to institutionalize children's health throughout the agency, the EPA Administrator should establish key children's environmental health staff within each program office and regional office, with linkages to the Office of Children's Health, to improve cross-agency implementation of revised priorities and goals, and ensure coordination and communication among EPA's program offices.

    Agency Affected: Environmental Protection Agency

  7. Status: Closed - Implemented

    Comments: EPA is using the Children's Health Protection Advisory Committee proactively, as we recommended. For example, in March 2012, EPA sought advice form CHPAC in developing lead regulations and in coordinating agency programs to prevent childhood lead exposure. Additionally, at the request of the OCHP Director, CHPAC assisted in developing information about asthma disparities among racial and ethnic groups for EPA to use as part of its work on the President's Task Force on Environmental Health Risks and Safety Risks to Children, which was established in 1997 and charged with recommending strategies for protection children's environmental health and safety. In May 2012, the task force published hate Coordinated Federal Action Plan to Reduce Racial and Ethnic Asthma Disparities. Furthermore, EPA program offices have also worked more closely with CHPAC on a number of issues related to children's health since we issued our January 2010 report, according to CHPAC's Co-Chair. For example, EPA"s Office of Air and Radiation provided a briefing to CHPAC on indoor air quality to help the committee identify priority areas. CHPAC's Designated Federal Office (DFO) also works with other federal advisory committee, such as EPA's Clean Air Scientific Advisory Committee and the Science Advisory Board on other issue to coordinate as needed.

    Recommendation: To help ensure that EPA assumes high-level leadership and develops strategies and structures for coordinating efforts addressing children's environmental health both within the agency and throughout the federal government, and to maximize opportunities to institutionalize children's health throughout the agency, the EPA Administrator should use the Children's Health Protection Advisory Committee proactively as a mechanism for providing advice on regulations, programs, plans, or other issues.

    Agency Affected: Environmental Protection Agency

  8. Status: Closed - Implemented

    Comments: OCHP officials told us they have been active participants in two key interagency organizations-the Federal Interagency Forum on Child and Family Statistics (Forum) and the President's Task Force on Environmental Health Risks and Safety Risks to Children. Through their work with the Forum, OCHP officials have helped to prepare statistical data and descriptive text on children's well-being, such as lead levels in the blood of children that are included in the Forum's biennial publications: America's Children (2011) and America's Children in Brief (2010). Additionally, an OCHP official is a member of the Forum's reporting committee, which works on a number of issues involved in the creation of these reports, and has the responsibility to write and edit the Physical Environment and Safety section of America's Children in Brief. OCHP also contributed to the 2012 edition of America's Children in Brief: Key National Indicators of Well-Being and is working on the 2013 edition of America's Children. OCHP officials also told us that they have had a major role in reinvigorating the President's Task Force Steering Committee. The Task Force officially expired in 2005. Although the task force has not been officially reauthorized, EPA and other agencies that were members of the task force have been participating in various efforts to address children's health concerns since January 2010. For example, OCHP's Director has served as the Co-Chair of the Task Force that, among other things, addresses healthy homes, chemical exposures, and asthma disparities. For example, the task force held a workshop on asthma disparities in December 2010 and, as we stated previously, in May 2012, published the Coordinated Federal Action Plan to Reduce Racial and Ethnic Asthma Disparities. OCHP officials said the office also played a major role in the task force's 2012 efforts to coordinate federal action on lead exposure.

    Recommendation: To help ensure that EPA assumes high-level leadership and develops strategies and structures for coordinating efforts addressing children's environmental health both within the agency and throughout the federal government, and to maximize opportunities to institutionalize children's health throughout the agency, the EPA Administrator should ensure participation, to the fullest extent possible, by the Office of Children's Health or other key officials on the interagency organizations identified in Executive Order 13045.

    Agency Affected: Environmental Protection Agency

 

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