PEER: EPA Delays Experiments Exposing Children to Chemicals

The U.S. Environmental Protection Agency is temporarily shelving two studies that involve exposing infants and schoolchildren to pesticides and other hazardous chemicals, according to a Sept. 22 press release from Public Employees for Environmental Responsibility (PEER).

The federal regulatory agency cited ethical and perception concerns (the need "to ensure the utmost confidence in the approaches used") as the basis for suspending applications for funding, according to EPA documents posted by PEER. To learn more, visit

The two studies, "Observational Studies to Characterize the Determinants of Exposure to Chemicals in the Environment for Early-Lifestage Age Groups" (involving infants under age 3 in the Las Vegas area) and "Novel Approaches for Assessing Exposure for School-Aged Children in Longitudinal Studies" have been "canceled until further notice."

EPA formally legalized human subject experimentation in February 2007, but prior to that, the Bush administration conducted and encouraged human subject studies on a case-by-case basis.

In late 2007, EPA commissioned a new effort to allay public unease about using humans as subjects for pesticide and chemical experiments, called Scientific and Ethical Approaches for Observational Exposure Studies (SAEOES). It does not, however, provide any concrete guidance on an array of ethical quandaries, such as vulnerable populations, payments to participants, and conflicts-of-interest by scientists.

The September 8 EPA announcement states that "Administrator Johnson is taking action to identify [SEAOES] as an Agency Guidance Document, setting its procedures and protocols as official EPA policy" prior to restarting the two suspended studies. "This is a smokescreen to prevent a new controversy prior to the election about the government using babies as guinea pigs," said PEER Executive Director Jeff Ruch. "Nothing in SEAOES will prevent ethically questionable studies from continuing, even if the document does become official EPA policy. This document does not have any hard and fast rules to protect children used as experimental subjects."

"Observational" studies are controversial because they often involve payments to parents to participate under the fig leaf of the parent attesting the child would be exposed to the chemicals anyway. Moreover, truly observational studies preclude medical, safety, or other assistance to prevent damage to the child.

"These EPA experiments, in essence, legitimize vastly more numerous human subject experiments by industry and corporate consultants, often in Third World countries," Ruch added. "Corporate-sponsored experiments are usually designed to justify higher human exposures to pesticides or other noxious chemicals, particularly for children, while serving no discernible public health purpose."

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