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Environmental Health: EPA Has Made Substantial Progress but Could Improve Processes for Considering Children's Health

GAO-13-254 Published: Aug 12, 2013. Publicly Released: Sep 11, 2013.
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What GAO Found

The Environmental Protection Agency (EPA) has made substantial progress in addressing more than half of the recommendations GAO made in a January 2010 report concerning the agency's efforts to protect children's health. Specifically, EPA has fully implemented five of the eight recommendations made by GAO. For example, for a recommendation that EPA ensure that its strategic plan expressly articulate children-specific goals, objectives, and targets, in September 2010, EPA issued an agency-wide strategic plan that identifies children's health as a top agency priority with goals, objectives, and targets. In addition, EPA took some steps to address the remaining three recommendations from GAO's January 2010 report but has not fully implemented them, including a recommendation that the agency 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.

The Office of Children's Health Protection (OCHP) has increased its role to ensure that EPA program offices consider children's health protection in their regulatory activities. Specifically, the EPA Administrator issued a memorandum in February 2010 directing OCHP to take the lead in ensuring that all EPA programs are successful in their efforts to protect children's health. Since the issuance of the memorandum and the office's reorganization in July 2010, OCHP has played a greater supporting role in program offices' development of selected regulations that potentially affect children's health. However, OCHP has no regular involvement in the Office of Pesticide Program's (OPP) decision-making process addressing tolerances for pesticide residues. In addition, OCHP officials may not be aware of these decisions, and there are no mechanisms in the tolerance setting process to alert OCHP when matters that could pose a significant risk to children's health are being considered. Until the disconnect between the direction identified for OCHP in the Administrator's memorandum and the current process is addressed, OCHP will not have a role to ensure that children's health protection is considered in the area of pesticide tolerance decisions.

OCHP has worked extensively with a variety of partners to leverage its resources to better protect children's health. Through its coordination with federal partners, OCHP has helped to improve children's environmental health in schools and homes. For example, training courses for about 800 participants through the National Center for Healthy Housing are being offered around the country addressing topics such as pest management and energy efficiency. In addition, OCHP has financially supported children's health efforts in underserved communities across the country by providing grants totaling $1.2 million. For example, OCHP awarded a $100,000 grant to Farm Worker Justice, a group which provides outreach and educational activities for families of farm workers to improve the environmental health of their children. OCHP has also worked with Pediatric Environmental Health Specialty Units (PEHSU) to help train 15,000 health care providers across the country about the health implications of prenatal and childhood environmental exposures. PEHSUs also work with federal, state and local agencies to address children's environmental health issues in homes, schools, and communities.

Why GAO Did This Study

Scientific studies have shown that because children's bodies are still developing, they can be more vulnerable than adults to certain environmental hazards, including air pollutants, pesticide residues on food, contaminants in drinking water, and toxic chemicals in the home. EPA has made protecting children's health part of its mission by establishing a policy in 1995 to ensure that the agency consistently considers children in its actions and creating OCHP to support those efforts. In a 2010 report, GAO found that EPA had not fully utilized OCHP and other child-focused resources to protect children's health.

GAO was asked to review EPA's progress in protecting children's health. This report determines (1) the extent to which EPA has implemented GAO's 2010 recommendations on children's health protection and (2) the role, if any, that OCHP has played in ensuring that key EPA program offices consider children's health protection in their regulatory activities. The report also describes how OCHP has worked with external partners to leverage its resources. To conduct this work, GAO reviewed relevant laws and EPA regulations and guidance, analyzed EPA data, and interviewed EPA officials and other stakeholders.


GAO recommends, among other things, that EPA direct OCHP and OPP to establish procedures to identify those tolerance decisions that could pose a significant risk to children's health and provide opportunities for OCHP involvement when appropriate. EPA generally agreed with GAO.

Recommendations for Executive Action

Agency Affected Recommendation Status
Environmental Protection Agency The EPA Administrator should make children's health training a priority for rule writers that includes how to respond to the screening questions.
Closed – Implemented
EPA reported to us in December 2016 that OCHP worked with the Office of Policy and the Office of Environmental Justice to create the children's health segment of the Action Development at EPA training course. According to EPA, this class targets new EPA rule writers and provides guidance on methods for ensuring children's unique vulnerabilities are appropriately considered in EPA's regulatory actions. In addition, OCHP developed a webinar-based training available to all EPA staff, but targeting rule developers. The purpose of this training is to enhance the understanding of how to apply children's environmental health principles within EPA's regulatory process. The training course was finalized following an internal review, and then presented to EPA staff in September 2013. Both courses cover how to respond to children's health screening questions in the Action Development Process. EPA's Office of Children's Health reported that it believes this combination of classes will ensure that rule writers are properly trained.
Environmental Protection Agency The EPA Administrator should require lead program offices to document their decisions in rulemakings and other actions regarding how health risks to children were considered (e.g., conducting a children's risk assessment) and that their decisions are consistent with EPA's children's health policy.
Closed – Implemented
In October 2014, EPA finalized a revised template for Executive Order 13045. The template is available to all EPA employees and outlines how to address Executive Order 13045 and EPA's Policy, in action preambles under various situations. The template instructs lead program offices to document their decisions in rulemakings and other actions, such as conducting a children's health risk assessment, regarding how they considered health risks to children.
Environmental Protection Agency The EPA Administrator should reaffirm the 1995 Policy on Evaluating Health Risks to Children to clarify the intent of the policy to reflect the best available science, emphasize the importance of using applicable guidance, and reiterate EPA's commitment to protecting children's health.
Closed – Implemented
In October 2013, the EPA Administrator reaffirmed the 1995 Policy on Evaluating Health Risks to Children by issuing a memorandum. The 2013 memorandum stated that new scientific data continue to show that children frequently have a greater potential for exposure to and toxicity from environmental hazards. Further, it stated that EPA's assessment must strive to keep up with advances in knowledge, and emphasized the importance of using applicable guidance, such as EPA's Framework for Assessing Environmental Risks to Children, and the agency's Supplemental Guidance for Assessing Susceptibility from Early-Life Exposure to Carcinogens, among others.
Environmental Protection Agency The EPA Administrator should direct OCHP and OPP to establish procedures to identify tolerance decisions that could pose a significant risk to children's health and provide opportunities for OCHP involvement consistent with the Administrator's 2010 memorandum.
Closed – Implemented
EPA reported that on November 24, 2014 OCHP and OPP finalized a Memorandum of Understanding (MOU) that outlines procedures to identify tolerance decisions that could pose a significant risk to children's health. The MOU also provides opportunities for OCHP involvement throughout the process.

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ChemicalsChild health servicesChildrenContaminantsContaminated foodsEnvironmental monitoringHealth hazardsInfantsPesticidesRisk assessmentSchoolsStrategic planningToxic substancesPollution controlHealth policySchedule slippagesRisk managementEmployee trainingReporting requirementsDecision makingPolicies and procedures