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Before the Committee on Environment and Public Works, U.S. Senate: 

United States Government Accountability Office: 

For Release on Delivery: 
Expected at 10:30 a.m. EDT:
Wednesday, March 17, 2010: 

Environmental Health: 

Opportunities for Greater Focus, Direction, and Top-Level Commitment 
to Children's Health at EPA: 

Statement of John B. Stephenson, Director: 
Natural Resources and Development: 


Madam Chairman and Members of the Committee: 

I am pleased to be here today to discuss highlights of GAO's report 
about the Environmental Protection Agency's (EPA) efforts to 
institutionalize the protection of children's health. EPA's mission is 
to protect human health and the environment. As a result of mounting 
evidence about the special vulnerabilities of the developing fetus and 
child, the federal government and EPA took several bold steps to make 
children's environmental health a priority in the late 1990s. In 1996, 
EPA issued the National Agenda to Protect Children's Health from 
Environmental Threats (National Agenda) and expanded the agency's 
activities to specifically address risks for children, documenting 
EPA's plans to achieve seven goals, such as (1) ensuring that all 
standards set by EPA are protective of any heightened risks faced by 
children; (2) developing new, comprehensive policies to address 
cumulative and simultaneous exposures faced by children; and (3) 
expanding community right-to-know to allow families to make informed 
choices concerning environmental exposures to their children. 

In April 1997, the President signed Executive Order 13045--Protection 
of Children from Environmental Health Risks and Safety Risks 
(Executive Order), which mandated a concerted federal effort to 
address children's environmental health and safety risks. The 
Executive Order established, among other things, an interagency Task 
Force on Environmental Health Risks and Safety Risks to Children (Task 
Force) and charged it with recommending strategies to the President 
for protecting children's health and safety. Also in 1997, EPA created 
the Office of Children's Health Protection (Office of Children's 
Health) to support the agency's efforts and formed the Children's 
Health Protection Advisory Committee (Advisory Committee) to provide 
advice, information, and recommendations to assist the agency in the 
development of regulations, guidance, and policies relevant to 
children's health.[Footnote 1] 

EPA's Advisory Committee has raised concerns about whether the agency 
has continued to maintain its earlier focus on protecting children or 
capitalized on opportunities to tackle some significant and emerging 
environmental health challenges. For example, the Advisory Committee 
wrote to the Administrator in April 2007 to reflect on EPA's 
achievements in the 10 years since the Executive Order was signed. The 
committee cited successes, such as increased margins of safety for 
pesticides mandated under the Food Quality Protection Act and the 
creation of the National Children's Study. However, the Advisory 
Committee also expressed serious concerns about EPA's continued lack 
of focus on children's environmental health issues and the lack of 
progress in addressing the committee's many recommendations. In the 
intervening years, children's environmental health has become no less 
pressing. In fact, 66 percent of children lived in counties where air 
exceeded one or more of the six principal pollutants. Two of them-- 
ozone and particulate matter--are known to cause or aggravate 
respiratory diseases such as asthma. According to the Centers for 
Disease Control and Prevention (CDC), asthma is the third most common 
cause of hospitalizations for children, resulting in $3.2 billion for 
treatment and 14 million days of school lost annually. 

In light of concerns about EPA's focus on children, you asked that we 
assess the agency's consideration of children's environmental health. 
This statement summarizes highlights from our report being released 
today that addresses the extent to which EPA has institutionalized the 
protection of children's health from environmental risks through (1) 
agency priorities, strategies, and rulemakings, including 
implementation of Executive Order 13045; (2) the use of key offices 
and other child-focused resources, such as the Office of Children's 
Health and the Advisory Committee; and (3) involvement in federal 
interagency efforts to protect children from current and emerging 
environmental threats.[Footnote 2] To perform this work we, among 
other things, interviewed officials from multiple EPA program offices 
most directly involved with children's health issues; reviewed key EPA 
children's health-related policies, strategic and performance plans, 
and guidance documents; analyzed regulations subject to the regulatory 
requirements of the Executive Order; and identified the 
accomplishments of the Task Force. 

In preparing this testimony, we relied on our work supporting the 
accompanying report. That report contains a detailed overview of our 
scope and methodology. All of our work for this report was performed 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

EPA's Past Efforts to Institutionalize Children's Health Through its 
National Agenda and Strategic Plan Have Not Been Sustained: 

As detailed in our report, EPA has developed policies and guidance to 
consider children, but it has not maintained attention to children 
through agency priorities and strategies. Specifically, EPA has not 
institutionalized the agency's commitment to children's health 
through, for example, an update to its National Agenda and an emphasis 
on protecting children in its forthcoming strategic plan. 

First, EPA has not updated the National Agenda in more than 10 years. 
Issued in 1996, the National Agenda established children's 
environmental health as a top priority and a central focus of all 
agency efforts. In it, EPA articulated the agency's commitment to 
children's health by identifying an array of environmental threats to 
children and specifying a multifaceted approach to accomplishing its 
children's health goals. The National Agenda also was the impetus for 
the creation of EPA's Office of Children's Health, which was formed to 
support the agency's implementation of the National Agenda. Moreover, 
the National Agenda also helped to institutionalize the agency's 
commitment to the issue. According to current and former officials 
from the Office of Children's Health, the National Agenda and 
Executive Order helped legitimize the office's importance across the 
rest of the agency. As detailed in our report, several demonstrable 
children's health-focused activities were initiated in the years 
immediately following EPA's issuance of the National Agenda. For 
example, in 1999 the agency explored--through the Task Force--the 
feasibility of a longitudinal cohort study of environmental effects on 
parents and children, which Congress later established as the National 
Children's Study.[Footnote 3] In 2000, EPA issued a strategy for 
research on environmental risks to children that established EPA's 
long-term program goals and documented its rationale.[Footnote 4] The 
National Agenda also asserted EPA's leadership across the federal 
government and called on partners in Congress, industry, health 
professions, and interest groups to adopt and help EPA implement these 
children's health priorities. EPA officials with whom we spoke 
recognized the importance of the National Agenda for helping to 
institutionalize children's health as a priority across EPA, noting 
that it gave children's health more traction and consideration in EPA 
programs and activities. Our report provides examples of key actions 
that EPA took in accordance with the National Agenda's seven priority 
areas. More recently, however, EPA took actions that directly 
contradicted a National Agenda priority, indicating that the agency 
lost some of its initial focus on children's environmental health. For 
example, as we reported in 2007, EPA finalized a rulemaking in 
December 2006 that significantly reduced the amount of publicly 
available information reported to the Toxics Release Inventory (TRI) 
about toxic chemicals released into air, water, and land.[Footnote 5] 
This action undermined EPA's National Agenda priority of expanding 
community right-to-know, which was designed to allow families to make 
informed choices about their children's exposure to toxic chemicals in 
their communities. In 2009, Congress acted to overturn EPA's 
rulemakings by restoring the original TRI reporting requirements for 
toxic chemicals released into the environment.[Footnote 6] 

Our report also addresses concerns related to EPA's strategic plans. 
The forthcoming plan, originally scheduled for issuance in September 
2009, has been delayed to allow additional time for review by the 
agency's new leadership. EPA identified children's health as a cross- 
agency program in its 1997 and 2000 strategic plans. However, EPA's 
2003 and 2006 (current) plans did not include children's health as an 
explicit goal or program. To help develop the agency's 2009 strategic 
plan, EPA held meetings in 2008 and 2009 to identify target areas for 
improvement. In the latest draft of that plan that EPA provided to us, 
the agency identified target areas for improvement--significant 
changes in strategy or performance measurement that are critical for 
helping the agency achieve and measure environmental and human health 
outcomes. We found that children's health was not included as a target 
area in the draft strategic plan, and it is not yet clear to what 
extent children's health will be addressed in the final plan, which is 
subject to revision before the Administrator finalizes it in the 
coming months. We also found that the Office of Children's Health was 
not a lead office for developing the plan's Healthy Communities and 
Ecosystems goal, the strategic goal that includes children's health. 
Development of this goal has been co-led by EPA's Office of 
Prevention, Pesticides and Toxic Substances; Office of Research and 
Development; and Office of Water. EPA planning officials told us that 
staff from the Office of Children's Health attended at least one 
development meeting for the goal. However, the office staff said their 
input was not given much weight, since three other offices were 
assigned the leadership role for coordinating the goal's team. EPA 
officials said that a possible reason the Office of Children's Health 
did not become central to the process was that it is not directly 
responsible for implementing or overseeing any of the EPA programs and 
subobjectives included under the plan's Healthy Communities and 
Ecosystems goal. 

In Recent Years, EPA Has Not Fully Used Its Office of Children's 
Health and Advisory Committee: 

We also found that, in recent years, EPA has not fully used the Office 
of Children's Health Protection and its Advisory Committee, among 
other child-focused resources. Although EPA now has a new Director of 
Children's Health, EPA's Office of Children's Health experienced 
multiple changes in leadership over the last several years, impairing 
its ability to fulfill its priorities and commitments. From 2002 to 
2008, the office had four acting directors and no permanent director. 
EPA staff told us the Office of Children's Health had difficulty 
maintaining focus because of the varied priorities and initiatives of 
each director. For example, in 2007, the acting director tasked office 
staff to form workgroups and collaborate with senior program office 
staff across the agency in response to a set of key recommendations 
from the Advisory Committee. In April 2007, to mark the 10th 
anniversary of the Executive Order, the Advisory Committee provided 
recommendations in seven key areas of concern, including the need for 
EPA to eliminate environmental health disparities among low-income and 
minority children, strengthen the national approach to regulating 
toxic chemicals, and provide necessary leadership and infrastructure 
to protect children's health. For example, the Advisory Committee had 
recommended expanding research and committing additional EPA 
infrastructure to children's health, among other things, and the EPA 
Administrator and office's acting director committed to addressing the 
recommendations. The office's subsequent acting director eliminated 
the workgroups, and EPA has yet to meaningfully address the Advisory 
Committee's recommendations.[Footnote 7] 

In our September 2008 testimony, we recommended that the Administrator 
examine ways to more proactively use the Advisory Committee to 
reinvigorate the agency's focus on protecting children's 
health.[Footnote 8] Since that time, EPA's Administrator and the 
Director of EPA's Office of Children's Health have met with the 
Advisory Committee in March and July 2009, respectively. In his 
remarks to the Advisory Committee, the Director expressed his 
commitment to more proactively use the Advisory Committee to support 
EPA's efforts to protect children's health. Specifically, he said that 
EPA could more effectively use the Advisory Committee for advice in 
developing regulations, and he asked for input on how to engage the 
Advisory Committee early and often in rulemakings. He also said that 
the committee could provide leadership in the area of science policy 
at EPA and advise the agency on policies for conducting research and 
making decisions in instances where EPA lacks conclusive information 
about children's vulnerabilities. The Director also recently asked the 
committee to provide EPA with advice on its draft school siting 
guidelines, voluntary guidance that takes into account factors such as 
the special vulnerabilities of children to hazardous substances or 
pollution at a potential school site.[Footnote 9] 

Task Force Fulfilled a Critical Role for Strategy Development and 
Interagency Coordination until it Expired in 2005: 

The Executive Order provides EPA with opportunities for leadership and 
coordination across the federal government. However, key provisions of 
the Executive Order--specifically an interagency task force that 
reports to the President--were allowed to lapse in 2005. The 
President's Task Force on Children's Environmental Health and Safety 
Risks was authorized by the Executive Order in April 1997 for a period 
of 4 years to provide high-level leadership and interagency 
coordination on children's environmental health. It comprised nine 
cabinet officials and seven White House office directors and was co- 
chaired by the Administrator of EPA and the Secretary of the 
Department of Health and Human Services (HHS). The Task Force convened 
five times for meetings in October 1997, April 1998, January 1999, 
September 1999, and October 2001. As part of National Children's 
Health Month in October 2001, the President extended the Task Force 
for 2 years. According to EPA officials, the Administrator urged the 
President to continue the Task Force; in April 2003, the President 
extended it for a final 2 years. However, the final order eliminated 
the provision for reassessing the need for continuance of the Task 
Force, which was not convened after the October 2001 meeting. 
According to EPA officials involved on the steering committee, the 
agency was not able to convene the Task Force thereafter, for reasons 
related to new priorities following the September 11, 2001, terrorist 
attacks. Nonetheless, a senior career-level staff steering committee 
continued to meet until 2005 to coordinate and implement the 
strategies that the Task Force developed to address the threats to 
children's health. 

The Task Force contributed to eight areas related to children's 
health, including the establishment of the National Children's Study, 
the largest long-term study of environmental influences on children's 
health and development, which was initiated as part of the Children's 
Health Act of 2000. The Task Force also identified four major 
environmental and safety threats to children--asthma, developmental 
disabilities (including lead poisoning), cancer, and unintentional 
injuries--and created national strategies for each of them. In its 
strategy documents, the Task Force recognized that an integrated 
solution was needed across the federal government to address the 
complex interaction between a child's biology, behavior, and the 
physical, chemical, biological, and social environment. The Task Force 
provided critical leadership on several important initiatives such as 
the National Children's Study and the Healthy Schools Environments 
Assessment Tool (HealthySEAT). These national programs focus heavily 
on the environmental influences on children's health, with the 
National Children's Study examining the role of environmental factors 
on health and disease and HealthySEAT offering school districts a self-
assessment tool for identifying and evaluating environmental, safety, 
and health hazards. 

With the Task Force's expiration, EPA and HHS no longer have a high- 
level infrastructure or mandate to coordinate federal strategies for 
children's environmental health and safety. According to the EPA staff 
and children's health experts with whom we spoke, had the Task Force 
continued, it could have helped the federal government respond to the 
health and safety concerns that prompted the 2007 recall of 45 million 
toys and children's products because of lead contamination. 
Furthermore, since the Task Force provision of the Executive Order 
expired in 2005, the Task Force's reports are no longer generated. 
Those reports collected and detailed the interagency research, data, 
and other information necessary to enhance the country's ability to 
understand, analyze, and respond to environmental health risks to 

Since the President signed the Executive Order in 1997, every EPA 
Administrator has stated that children's environmental health is a 
priority at the agency, and Administrator Jackson is no exception. We 
would like to note the Administrator has made children's environmental 
health a signature item at EPA. In her first memo to EPA staff, the 
Administrator highlighted children as a key focus. Also, in her 
remarks at the April 2009 G8 Environmental Minister's Meeting, the 
Administrator stated, 

We have learned much in the last 12 years about the ways that 
environmental exposures uniquely affect children. With that increased 
knowledge, our sense of urgency for further action on children has 
also increased….The U.S. government, under this new administration, 
will keep faith with the promise we've made to future generations. I 
hope we can continue the work we started in 1997, renewing our 
commitment to protect children from environmental threats where they 
live, learn, work and play. 

In our report being released today, we are making eight 
recommendations to help EPA reinvigorate its early emphasis on 
children, assume high-level leadership, and develop strategies for 
coordinating efforts addressing children's environment health both 
within the agency and throughout the federal government. For example, 
we recommend that the EPA Administrator update and reissue a child-
focused strategy, such as the 1996 national agenda, to articulate 
current national environmental health priorities and emerging issues. 
We further recommend that EPA's forthcoming strategic plan expressly 
articulate children-specific goals, objectives, and targets. We make 6 
additional recommendations to the EPA Administrator to maximize 
opportunities to institutionalize children's health throughout the 
agency. EPA responded that our report accurately portrays the agency's 
challenges in addressing children's environmental health and sets 
forth sound recommendations to better incorporate protection of 
children's health as an integral part of EPA's everyday business. 

Because EPA alone cannot address the complexities of the nation's 
challenges in addressing environmental health risks for children, we 
encourage Congress to re-establish a governmentwide 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. 
We encourage Congress to charge it with identifying the principal 
environmental health threats to children and developing national 
strategies for addressing them. We further encourage Congress to 
establish in law the Executive Order's requirement for periodic 
reports about federal research findings and research needs regarding 
children's environmental health. 

Madam Chairman, this concludes my prepared remarks. I would be happy 
to respond to any questions that you or other Members of the Committee 
may have. 

GAO Contacts and Acknowledgments: 

For questions or further information regarding this statement, please 
contact John Stephenson, Director, Natural Resources & Environment at 
(202) 512-3841 or Diane Raynes, Assistant 
Director; Elizabeth Beardsley; Timothy Bober; Mark Braza; Emily 
Hanawalt; Terrance Horner, Jr.; Aaron Shiffrin; Benjamin Shouse; and 
Kiki Theodoropoulos made key contributions to this statement. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this testimony. 

[End of section] 


[1] In 2005, EPA expanded the office to include environmental 
education and aging initiatives, renaming it the Office of Children's 
Health Protection and Environmental Education. 

[2] GAO, Environmental Health: High-level Strategy and Leadership 
Needed to Continue Progress toward Protecting Children from 
Environmental Threats, [hyperlink,] (Washington, D.C.: Jan. 28, 

[3] Children's Health Act of 2000, Pub. L. No. 106-310. 

[4] The research strategy has not been updated since its publication. 
Instead, EPA integrated children's environmental health into Office of 
Research and Development multi-year human health research plans. 

[5] GAO, Toxic Chemical Releases: EPA Actions Could Reduce 
Environmental Information Available to Many Communities, [hyperlink,] (Washington, D.C.: Nov. 30, 

[6] Omnibus Appropriations Act, 2009, Pub. L. No. 111-8, § 425 (2009). 

[7] The Advisory Committee has previously noted leadership challenges 
in the office, writing in a December 2002 memo to the Administrator 
that the office could not continue to play a key role within EPA and 
across the nation without permanent leadership. In May 2004, EPA's 
Inspector General reported that the lack of a permanent director may 
have a negative impact on the longevity and importance of the 
children's environmental health program within EPA. 

[8] GAO, Environmental Health: EPA Efforts to Address Children's 
Health Issues Need Greater Focus, Direction, and Top-Level Commitment, 
[hyperlink,] (Washington, 
D.C.: Sept. 16, 2008). 

[9] EPA Siting of School Facilities, [hyperlink,], accessed March 11, 2010. 

[End of section] 

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