Environmental Health
High-level Strategy and Leadership Needed to Continue Progress toward Protecting Children from Environmental Threats Gao ID: GAO-10-205 January 28, 2010Exposure 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.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-10-205, Environmental Health: High-level Strategy and Leadership Needed to Continue Progress toward Protecting Children from Environmental Threats
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
January 2010:
Environmental Health:
High-level Strategy and Leadership Needed to Continue Progress toward
Protecting Children from Environmental Threats:
GAO-10-205:
GAO Highlights:
Highlights of GAO-10-205, a report to congressional requesters.
Why GAO Did This Study:
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.
What GAO Found:
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.
Figure: Children Are Exposed to Many Sources of Potentially-harmful
Environmental Pollutants:
[Refer to PDF for image: illustration]
Infant/Young Child: Exposures for the infant and young child can occur
through all environmental media. When breastfed, the mother‘s exposure
to environmental media can be an additional source of exposure to the
infant.
Mother:
Air;
Water;
Diet;
Physical factors;
Other.
Infant/young child:
Breast milk;
Air (inhalation);
Water (ingestion, inhalation, dermal);
Diet (ingestion, dermal);
Physical factors;
Other (ingestion, inhalation, dermal).
Source: EPA, A Framework For Assessing Health Risks of Environmental
Exposure to Children (2006).
[End of figure]
What GAO Recommends:
GAO recommends improvements to help EPA protect children, and EPA
agreed to implement them. GAO also suggests that Congress consider
reinstating a government-wide task force on children‘s environmental
health.
View [hyperlink, http://www.gao.gov/products/GAO-10-205] or key
components. For more information, contact John Stephenson at (202) 512-
3841 or stephensonj@gao.gov.
[End of section]
Contents:
Letter:
Background:
EPA Has Not Focused Attention on Children's Health in Agencywide
Priorities, Strategies, and Rulemakings:
In Recent Years, EPA Has Not Fully Utilized Its Office of Children's
Health and Other Child-Focused Resources:
Opportunities Exist for EPA to Lead and Coordinate National Efforts to
Protect Children from Environmental Threats:
Conclusions:
Recommendations for Executive Action:
Matter for Congressional Consideration:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: EPA Policy on Evaluating Health Risks to Children:
Appendix III: Executive Order 13045 and Amendments:
Appendix IV: EPA Regulations Subject to Executive Order 13045:
Appendix V: Comments from the Environmental Protection Agency:
Appendix VIGAO Contact and Staff Acknowledgments:
Tables:
Table 1: Provisions in Selected Environmental Statutes Expressly
Concerning Children or Other Susceptible Subgroups:
Table 2: Priorities From EPA's National Agenda and Examples of Related
Actions:
Table 3: Placement of EPA's Regional Children's Health Coordinators
within the Offices of the Regional Administrator:
Table 4: Key Physical Environment and Safety Indicators of Children's
Well-Being, 2009:
Table 5: Summary of Commitments and U.S. Implementation of the 1997
Miami Declaration, as of 2002:
Table 6: EPA Regulations Subject to Executive Order 13045:
Figures:
Figure 1: Exposure Routes and Levels Change During Major Developmental
Periods Of Childhood:
Figure 2: Steps Where Children Are Considered in the EPA Rulemaking
Process:
Figure 3: EPA Regional Children's Environmental Health Coordinator
Staffing Levels by Region, in FTEs:
Figure 4: Number of Children's Health Protection Advisory Committee
Recommendations by Category:
Abbreviations:
ACE: America's Children and the Environment:
Advisory Committee: Children's Health Protection Advisory Committee:
CDC: Centers for Disease Control and Prevention:
EPA: Environmental Protection Agency:
Executive Order: Executive Order 13045--Protection of Children from
Environmental Health Risks and Safety Risks:
Healthy SEAT: Healthy Schools Environments Assessment Tool:
Interagency Forum: Federal Interagency Forum on Child and Family
Statistics:
Miami Declaration: Declaration of the Environmental Leaders of the
Eight on Children's Environmental Health:
NAAQS: National Ambient Air Quality Standards:
National Agenda: National Agenda to Protect Children's Health from
Environmental Threats:
Office of Children's Health: Office of Children's Health Protection:
OMB: Office of Management and Budget:
RAPIDS: Rule and Policy Information Development System:
Task Force: Task Force on Environmental Health Risks and Safety Risks
to Children:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
January 28, 2010:
The Honorable Barbara Boxer:
Chairman:
Committee on Environment and Public Works:
United States Senate:
The Honorable Amy Klobuchar:
Chairman:
Subcommittee on Children's Health:
Committee on Environment and Public Works:
United States Senate:
Children face disproportionate health risks from environmental
contaminants such as pollution in air, lead paint in homes, pesticide
residues on food, and treatment-resistant microbes in drinking water.
Such hazards contribute to asthma, cancer, neurodevelopmental
disorders, and other diseases, and many of the nation's 74 million
children are exposed to them daily. In 2007, for example, 66 percent
of children lived in counties where air exceeded one or more of the
six principal pollutants.[Footnote 1] 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.
The environment's effect on children's health is complex, and
scientists' understanding has continued to evolve. It can be
challenging to assess the contribution of environmental exposures to
childhood illnesses, because factors such as family history,
nutrition, and socioeconomic factors also contribute. Nonetheless,
scientists agree that children often are more significantly affected
by environmental risks from exposure to air pollution, toxic
chemicals, and the disease-transmitting vectors that are expected to
increase with global warming. Research has also shown that childhood
exposures to environmental contaminants may affect risk of diseases,
such as cancer, later in life.
In the late 1990s, the federal government took several steps to make
children's environmental health a priority. 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, the
Environmental Protection Agency (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 2]
EPA's Advisory Committee and the EPA Office of Inspector General have
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 EPA
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. The EPA Inspector General had also
raised many of those concerns in 2004.[Footnote 3]
To address concerns about EPA's focus on children, you asked that we
assess the agency's consideration of children's environmental health.
In September 2008, we testified on our preliminary assessment of EPA's
efforts to address children's environmental health, focusing on the
Advisory Committee.[Footnote 4] This report completes our work for
you, addressing more broadly 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.
To address those objectives, we interviewed officials from multiple
EPA program offices most directly involved with children's health
issues and referred to long-established quality management criteria
from the Government Performance and Results Act.[Footnote 5] To assess
the extent that EPA prioritized children's health in its agencywide
strategies and goals, we reviewed key EPA children's health-related
policies, strategic and performance plans, and guidance documents. To
assess the implementation of the Executive Order through EPA's
rulemaking process, we reviewed regulations subject to the regulatory
requirements of the order, as well as internal workgroup documents
detailing EPA's rulemaking--National Ambient Air Quality Standards for
Particulate Matter--published in October 2006. To assess EPA's use of
its Advisory Committee, we analyzed documents--including meeting
agendas, letters from the Advisory Committee to the EPA Administrator,
and EPA's response letters. To examine EPA's involvement in national
children's health efforts, we identified the accomplishments of the
Task Force that EPA co-chaired, and we reviewed reports from groups
such as the Federal Interagency Forum on Child and Family Statistics
(Interagency Forum). Appendix I provides a more detailed description
of our scope and methodology. We conducted this performance audit from
November 2008 through January 2010 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.
Background:
The following section discusses issues related to children's
environmental health risks and key actions that EPA, the President,
and Congress took in the early 1990s to help address those risks.
Children's Environmental Health Risks:
Children are often disproportionately affected by environmental
contaminants, such as pesticides and lead, for many reasons, including
greater exposure levels, unique exposure pathways, and greater
vulnerability due to their still-developing bodies. For example, EPA
noted that children may receive higher doses of contaminants, because
they spend more time close to the ground; engage in more hand-to-mouth
activities; and breathe more air, drink more water, and consume more
food in proportion to their body weight than adults. Contaminants may
also affect children disproportionately because of their unique
exposure routes such as transplacental and breast milk. Figure 1
illustrates the relevant exposure routes during three major
developmental periods of childhood.
Figure 1: Exposure Routes and Levels Change During Major Developmental
Periods Of Childhood:
[Refer to PDF for image: illustration]
Prenatal:
All exposures to the fetus occur transplancentally or via physical
factors. The mother‘s exposure to environmental media can be a
significant source of exposure for environmental media for the fetus.
Mother:
Air;
Water;
Diet;
Physical factors;
Other.
Fetus:
Transplacental.
Infant/Young child:
Exposures for the infant and young child can occur through all
environmental media. When breastfed, the mother‘s exposure to
environmental media can be an additional source of exposure to the
infant.
Mother:
Air;
Water;
Diet;
Physical factors;
Other.
Infant/young child:
Breast milk;
Air (inhalation);
Water (ingestion, inhalation, dermal);
Diet (ingestion, dermal);
Physical factors;
Other (ingestion, inhalation, dermal).
Older child/Adolescent:
Exposures for the child and adolescent can occur through all
environmental media. The mother‘s exposure is no longer a factor for
the child.
Older child/Adolescent:
Air (inhalation);
Water (ingestion, inhalation, dermal);
Diet (ingestion, dermal);
Physical factors;
Other (ingestion, inhalation, dermal).
Source: EPA, A Framework For Assessing Health Risks of Environmental
Exposure to Children (2006).
[End of figure]
Children also are more vulnerable than adults because of the relative
immaturity of their biochemical and physiological systems. For
example, air pollutants that would produce only slight breathing
difficulties in adults may contribute to a more serious breathing
problem in young children because of their smaller airways. Finally,
EPA has noted that children have limited ability to communicate and
urge action about their environment, so others must act on their
behalf.
In 1993, the National Academy of Sciences summarized the state of the
science concerning the effects of environmental contaminants on
children's health and helped institutionalize the idea that children
are not "little adults."[Footnote 6] That groundbreaking study
outlined some of the profound differences between children and adults
and was followed, in 1996, by congressional enactment of the Food
Quality Protection Act, which mandated use of a 10-fold safety factor
for children in setting pesticide residue tolerances.[Footnote 7]
Since the early 1990s, scientists have expanded our understanding of
environmental health consequences beyond childhood diseases and
disorders and began examining how childhood exposures affect people
throughout all lifestages. The term lifestage refers to a
distinguishable time frame in an individual's life characterized by
unique and relatively stable behavioral and physiological
characteristics that are associated with development and growth. EPA
now views childhood as a sequence of lifestages from conception
through fetal development, infancy, and adolescence, rather than
considering children as a subpopulation.[Footnote 8] In its 2005
Guidance on Selecting Age Groups for Monitoring and Assessing
Childhood Exposures to Environmental Contaminants, EPA recommended use
of the following childhood age groups for assessing risk from
environmental exposures:
* age groups less than 12 months old include: birth to
