The American Academy of Pediatrics Proposes Changes to U.S. Chemical Management Policy

We come in contact with countless chemicals found in the products we use day-to-day. Although we encounter these chemicals regularly, little is known about the extent to which these chemicals adversely affect our health. Moreover, the ways in which these chemicals impact the health of children during crucial developmental stages (e.g., in utero, infancy, childhood, and adolescence) is not fully understood. For this reason, the American Academy of Pediatrics (AAP), Council on Environmental Health suggests revisions to United States (U.S.) policy on chemical management to better support the health of children, pregnant women, and other populations.

U.S. chemical management is currently governed by the Toxic Substances Control Act (TSCA), which is carried out by the U.S. Environmental Protection Agency (EPA). The TSCA was established in 1976 to regulate, among other things, the production, importation, and marketing of chemical substances (typically excluding those found in food additives, pharmaceuticals, cosmetics, and pesticides). Many have expressed dissatisfaction with the overall function of the TSCA. After the 35 years since its introduction, the TSCA regulates only five of the tens of thousands of chemical substances that exist in the marketplace today. These chemicals include polychlorinated biphenyls, fully halogenated chlorofluoroalkanes, dioxin, asbestos, and hexavalent chromium.

In the policy statement, the AAP gives light to many flaws under the TSCA. For one, the TSCA does not require companies to conduct pre-market or post-market safety studies on the chemicals they manufacture. Furthermore, if such tests are performed, the results may be deemed confidential by the manufacturers, thus prohibiting public access to research findings on potentially harmful chemicals.

To remedy the current state of affairs, the AAP suggests that U.S. chemical management policy be revised. Below are some of the AAP’s proposed changes.

  • The regulation of chemical substances should be based on evidence found in premarket testing. On the other hand, the decision to limit or ban chemical substances after they are released should be based on realistic degrees of concern.
  • Chemical testing should include the study of potential effects on the health of pregnant women and children, more specifically, the effects on reproduction and child development.
  • Chemicals should meet specific safety criteria with exceptions made for chemicals that have no known safer alternatives.
  • Chemicals should undergo post-marketing observation and the EPA should have the authority to ban a chemical if deemed necessary.
  • When proposing a new chemical, manufacturers should be responsible for securing the funds to perform premarket testing.
  • Manufacturers should be required to produce public information about any new chemicals they release.

Many of the chemicals we encounter daily have never been tested on their potentially harmful effects to our health. Considering the role that environmental toxins play in child development, it is alarming that these chemicals are not required to undergo rigorous testing prior to their introduction into the marketplace. We must advocate for changes to U.S. chemical management policy that will better protect our health and give special consideration to the health of more vulnerable populations including pregnant women and children.

If you are interested in reading the AAP’s full policy statement, it can be accessed here.


Council on Environmental Health. (2011). Policy statement—Chemical-management policy: Prioritizing children’s health. Pediatrics, 127, 983-990. doi: 10.1542/peds.2011-0523

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