Lynda Van Kuren
lyndav@cec.sped.org
The Council for Exceptional Children (CEC) says the Environmental Protection
Agency's (EPA's) proposal to allow testing of chemicals and pesticides on
children who are abused and neglected is abhorrent. Though the EPA says
it will protect pregnant women and children, its new rules on human testing
include "exemptions" that open the door to using children and
pregnant women as test subjects. The EPA's rules state that testing of humans
can occur under the following circumstances:
- It is not reasonable to obtain parental permission, such as in the case
of abused and neglected children.
- The research is "ethically deficient" but crucial to protecting
the public health.
- There is a direct benefit to the child being tested and the parents
or guardians agree, even if there is more than minimal health risk to
the child.
- The studies are performed in countries that have few or no ethical standards
for testing as long as the tests are not done directly for the EPA.
"CEC is appalled that the EPA has taken such a position," says CEC's
Interim Executive Director Bruce Ramirez. "These rules endanger the lives
and health of children who have no one to protect them. If this goes forward,
we, as a nation, have moved backwards, running roughshod over those who are
vulnerable or simply unaware of the ramifications of the tests being administered."
CEC has submitted comments to the EPA expressing its hope that the EPA will
"uphold high ethical standards and protect all children from becoming
subjects of toxic experiments."
This is not the first time human testing has come under scrutiny. Studies
by the National Academy of Sciences and the Joint Subcommittee of the Science
Advisory Board have expressed great concern over using children as subjects
and stated that there are too many unknowns to justify such studies. Also,
in 1998 EPA Administrator Carol Browne issued a moratorium on human experimentation.
The Bush administration reversed the moratorium.
Send your comments on using children who are abused and neglected for chemical
testing to opp-docket@epa.gov, Attention:
Docket ID Number OPP-2003-0132 by Dec. 12, 2005.
CEC has a draft letter on this issue on its Legislative Action Center, http://capwiz.com/cek/home/
