Why this Issue is Important: House and Senate Conferees will meet soon to take up the Interior, Environment and Related Agencies Appropriations bill for FY 2006, including consideration of the U.S. Environmental Protection Agencys (EPA) testing of pesticides on humans. EPA has a prevailing policy that allows for consideration of human testing of pesticides in its regulatory decision making process. Due to the nature of such testing, the USCCB submitted comments to EPA in September 2003 on proposed rulemaking to establish criteria and standards for testing of pesticides on humans (comments available at /sdwp/national/pesticide.shtml).
USCCB has urged the EPA to consider certain principles when establishing criteria and standards relating to research involving human subjects to ensure the protection of all people, especially children, born and unborn, and farmworkers from the risks involved in participating in such studies. (See letter to Conferees on human testing of pesticides).
Background: Human testing of pesticide exposure is rare. In 1996, Congress passed the Food Quality Protection Act (FQPA), which set more stringent safety margins, including a 10-fold factor of safety margin for children because of their vulnerability to pesticide exposure. However, there remains a significant loophole to the 1996 law. Companies (and foreign governments) wanting to register a new product or re-register a current one can petition the EPA to consider human tests, which are exempt from the additional safety margin that is required of animal experiments in order to determine what dose of a pesticide has no effect on people. The EPA has issued a moratorium in the past disallowing such testing, but is now considering these on a case-by-case basis without a consistent set of standards and criteria.
USCCB Position: We approach this issue from our perspective as pastors and teachers, based on our respect for human life and dignity. We believe that human exposure to pesticides and other toxic substances must be approached with the greatest degree of caution. We urge the EPA to enact regulations that allow human testing of pesticides in the course of pesticide registration, only if the Agency ensures that these are absolutely necessary and that they have been conducted with the very highest of scientific and ethical standards.
Take Action Now! Please contact your Representative or Senator from the list of conferees for the Interior, Environment and Related Agencies Appropriations Subcommittee below and urge him or her to get the EPA to stop accepting human testing of pesticides until the Agency goes through the formal regulatory process for establishing a definitive policy that includes safeguards consistent with the comments provided by USCCB and the criteria recommended by the National Academy of Sciences.
Allard, Wayne (R-CO), 202-224-5941
Bennett, Robert (R-UT), 202-224-5444
Burns, Conrad (R-MT), 202-224-2644
Byrd, Robert (D-WV), 202-224-3954
Cochran, Thad (R-MS), 202-224-5054
Craig, Larry (R-ID), 202-224-2752
Domenici, Pete (R-NM), 202-224-6621
Dorgan, Byron (D-ND), 202-224-2551
Feinstein, Dianne (D-CA), 202-224-3841
Gregg, Judd (R-NH), 202-224-3324
Kohl, Herb (D-WI), 202-224-5653
Leahy, Patrick (D-VT), 202-224-4242
Mikulski, Barbara (D-MD), 202-224-4654
Reid, Harry (D-NV), 202-224-3542
Stevens, Ted (R-AK), 202-224-3004
Aderholt, Robert B. (R-4th AL), 202-225-4876
Dicks, Norman (D-6th WA), 202-225-5916
Doolittle, John T. (R-4th CA), 202-225-2511
Hinchey, Maurice (D-22nd NY), 202-225-6335
Istook, Ernest (R-5th OK), 202-225-2132
Lewis, Jerry (R-41st CA), 202-225-5861
Mollohan, Alan (D-1st WV), 202-225-4172
Moran, James (D-8th VA), 202-225-4376
Obey, David (D-7th WI), 202-225-3365
Olver, John (D-1st MA), 202-225-5335
Peterson, John (R-5th PA), 202-225-5121
Sherwood, Donald (R-10th PA), 202-225-3731
Simpson, Michael (R-2nd ID), 202-225-5531
Taylor, Charles H. (R-11th NC), 202-225-6401
Wamp, Zach (R-3rd TN), 202-225-3271
For more information, contact:
Roxana U. Barillas, Project Administrator, USCCB, 202-541-3445, email@example.com