OFFICE OF INSPECTOR GENERAL
Evaluation Report
The Effectiveness of the Office of
Children's Health Protection
Cannot Yet Be Determined
Quantitatively
Report No. 2004- P- 00016
May 17, 2004
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Report Contributors:
Jerri Dorsey
Laurie Adams
Jeffrey Harris
Abbreviations
EPA Environmental Protection Agency
OCHP Office of Children's Health Protection
OIG Office of Inspector General
ORD Office of Research and Development
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
May 17, 2004
MEMORANDUM
SUBJECT: Hie Effectiveness of the Office of Children's Health Protection Cannot Yet
Be Determined Quantitatively
Report No. 2004-P-00016
FROM: KwaiChan /*/
Assistant Inspector General for Program Evaluation
TO: Stephen Johnson
Acting Deputy Administrator
Bill Saunders
Acting Director, Office of Children's Health Protection
This is a final report on the subject review conducted by the Office of Inspector General (OIG)
of the U.S. Environmental Protection Agency (EPA). This report contains findings that describe
the problems the OIG identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and the findings contained in this report do not necessarily
represent the final EPA position. Final determinations on matters in the report will be made by
EPA managers in accordance with established resolution procedures.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 days of the date of this report. You should include a corrective actions plan for
agreed upon actions, including milestone dates. We have no objections to the further release of
this report to the public. For your convenience, this report will be available at
http://www. epa. gov/'oi g/.
If you or your staff have any questions, please contact me at (202) 566-0827 or Jeffrey Harris,
Director for Program Evaluation, Cross-Media Issues, at (202) 566-0831.
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Executive Summary
Children are more vulnerable to environmental health hazards than the general
population. Recent Environmental Protection Agency (EPA) reports have
indicated that children face significant and unique threats from such hazards.
These hazards range from air pollution and lead-based paint in older homes to
treatment-resistant microbes in drinking water and industrial chemicals.
During this review, we therefore sought to determine:
What is EPA's agenda for fostering children's health and how does the Office
of Children's Health Protection (OCHP) ensure its achievement?
What are the impediments to OCHP ensuring the achievement of the
Agency's National Agenda to Protect Children's Health From Environmental
Threats?
How well does OCHP plan and coordinate children's health activities within
the Agency?
OCHP was established in 1997 to formalize and integrate EPA's efforts on behalf
of children, to coordinate those efforts with other government agencies, and to
cany out Executive Order 13045 ("Protection of Children From Environmental
Health Risks and Safety Risks," issued April 27,1997) and implement the
Agency's "National Agenda to Protect Children's Health From Environmental
Threats," announced September 1996. In 2002, EPA announced its Aging
Initiative to promote environmental health protection to older persons and named
OCHP as the Agency's lead for that Initiative as well.
While OCHP is responsible for implementing the National Agenda, it is not
directly responsible for many-of the goals outlined in the National Agenda.
OCHP's mission is not a task that can be undertaken in isolation, and a full and
active partnership with stakeholders must be established and fostered. However,
we found that there was no overall, coordinated strategy integrating children's
environmental health^efforts into the Agency as a whole and no active
communication process in place among the program offices and OCHP. Further,
OCHP has not had a permanent Director since April 2002. Recognizing that
OCHP cannot implement the National Agenda without collaborating and
partnering with stakeholders, the lack of a permanent director could have a
negative impact on such efforts.
We found that OCHP has no formal mechanism in place to ensure performance
results or assess the relationships between program costs, activities, and results.
OCHP has a strategic planning process that includes an annual office planning
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meeting followed by a mid-year meeting to assess the status on the current year's
plan and to begin consideration of potential focus areas for the following year.
However, despite these meetings, mere is no formal tracking to ensure that goals
are met. More specifically, data and information systems are not available to
measure, analyze, and demonstrate overall performance specific to National
Agenda on a continuing basis.
We recommended that the Acting Deputy Administrator:
expedite the appointment of a permanent Director for OCHP,
establish an official children's health contact within each media program
office to improve coordination and communication, and
direct OCHP to make improvements to its annual planning process to include
a methodology to set priorities to ensure resources are being allocated to those
problems that pose the greatest environmental risks to children, as well as
periodic meetings with the program offices.
The Agency concurred with most of our recommendations and positions, and
agreed to explore options for improving coordination within EPA and ways to
better measure progress and results. However, the Agency expressed concern that
the report did not recognize the role of OCHP and the accomplishments made to
protect the Nation's children. We had noted in the report that many of EPA's
program and regional offices have projects focused on children's environmental
health protection; our concern was that OCHP's role was not clear. Also, while
the Agency commented that it was not beneficial to define parameters for aging,
we believe it is necessary for the Agency to develop a clear and concise definition
of the target audience before it can take sufficient action on issues regarding that
audience. We summarized the comments and provided our evaluations at the end
of each chapter. The full text of EPA's memorandum and comments are in
Appendix A, while additional attachments to that memorandum are available at
http://www.epa.aov.oig/.
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Table of Contents
Executive Summary i
Chapters :
1 Introduction 1
2 Impediments to OCHP Effectively Implementing the
National Agenda 7
3 Strengths, Weaknesses in OCHP Implementation
Efforts Noted 15
Appendices
A Auditee's Response 19
B Offices Visited and Contacted 25
C Distribution 27
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Chapter 1
introduction
Purpose
The Office of Inspector General (OIG) initiated a review to determine how the
Environmental Protection Agency (EPA) planned, prioritized, coordinated,
implemented, and evaluated activities related to children's health protection and
the environment. This is the second in a series of planned reports1 on EPA
children's health activities. During this review, we sought to determine:
What is EPA's agenda for fostering children's health and how does the Office
of Children's Health Protection (OCHP) ensure its achievement?
What are the impediments to OCHP ensuring the achievement of the
Agency's National Agenda to Protect Children's Health From Environmental
Threats?
How well does OCHP plan and coordinate children's health activities within
the Agency?
Background
Children's Unique Health Threats and Susceptibilities
According to recent EPA reports, children face significant and unique threats
from environmental hazards and industrial chemicals. These hazards range from
air pollution and lead-based paint in older homes to treatment-resistant microbes
in drinking water. It has been documented that children are more vulnerable to
environmental hazards for many reasons. For example, "The EPA Children's
Environmental Health Yearbook" of June 1998 noted that:
Children spend more time close to the ground and engage in more
hand-to-mouth activities; and
hi proportion to body weight, children breathe more air, drink more water, and
consume more food than adults, thus receiving higher doses of contaminants.
Further, it has been documented that children are more susceptible because of the
immaturity of their biochemical and physiological functions. For example, air
pollutants that would produce only slight breathing difficulties in adults may
'The first was Report Number 2003-M-OOOO17, Selected Children's Health Annual Performance Measures
far Goal 8, Sound Science, issued September 26,2003.
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contribute to a more serious breathing problem in young children because
children have smaller airways.
Evolution of National and EPA Children's Health Policy
A 1993 National Academies' of Science report, "Pesticides in the Diets of Infants
and Children," noted that the Federal government needed to improve some of its
scientific and regulatory procedures to afford children greater protection from
possible adverse health effects of pesticides in their diets. On April 21,1997, the
Presidential Executive Order 13045, "Protection of Children From Environmental
Health Risks and Safety Risks," was issued directing Federal agencies to place a
high priority on protecting children from environmental and safety risks and
ensure mat their policies, programs, activities, and standards address
disproportionate risks to children. Additionally, the executive order established
the President's Task Force on Environmental Health Risks and Safety Risks to
Children. In October 2001, Executive Order 13229 was signed extending the
mandates of the original order, and the Task Force until April 2003. In April
2003, the original executive order was amended extending the Task Force for an
additional two years.
During the 1990s, EPA took steps to identify environmental risks unique to
children. An outline of key actions taken by EPA during the 1990s is in
Table 1.1.
Table 1.1: Key Actions Taken by EPA
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consistently and expffeftly evaluates environmental health
i of infants atidcMfchm :.
1997: Off fee of Children's Health Protection Established
by EPA fc formatted and Jhtagfate thfc Ag&*cy'$ efforts on behalf of
Oflice of Ressaroh and
These steps included the issuing of a report in 1996, "Environmental Health
Threats to Children," that set an agenda for a national commitment to ensure a
healthy future for children. The National Agenda calls for the Agency to ensure
that all standards set by EPA protect children, there is a scientific research
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strategy that focuses on gaps related to children, new policies are developed as
needed, communities' right to know is expanded, educational efforts are
expanded, and needed funding is provided.
Creation of OCHP
OCHP was established in 1997 to formalize and integrate the Agency's efforts on
behalf of children, to coordinate those efforts with other government agencies, to
carry out Executive Order 13045, and to implement the Agency's Agenda.
OCHP's original mission was to "make the protection of children's health a
fundamental goal of public health and environmental protection in the United
States." The mission statement was revised to incorporate the Aging Initiative
announced in 2002 (see Chapter 2). The current mission statement is to "make
the health protection of children and the aging a fundamental goal of public health
and environmental protection in the United States and around the world."
OCHP's overall goal is to ensure that every individual, community, organization,
corporation, and government agency understands the link between children's ,
health and the environment and takes positive action to improve children's
environmental health.
To accomplish its overall mission and goal, OCHP focuses its efforts on two
broad categories: (1) building infrastructure and capacity; and (2) "getting the
word out."
Building Infrastructure and Capacity: OCHP's plans include investing
efforts to institutionalize children's environmental health protection within
Federal agencies, States, and the private sector, as well as within EPA. Due to
the small size of the office, OCHP considers EPA program offices and regions
to be its partners, as well as external interest groups.
"Getting the Word Out": OCHP's outreach plans include making
communities, parents, care-givers, school systems, etc., aware of
environmental risks to children and providing these groups with information
and/or resources that might enable them to take their own future actions,
OCHP's annual budget is approximately $6 million, which includes an estimated
$4 million in extramural resources (grants and contracts). The office as of our
review consisted of 14 staff members, divided into the following four speciality
area teams:
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Table 1.2: OCHP's Four Specialty Area Teams
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Regulations, This team conducts a retrospective review of EPA's existing
Economics, standards to select standards that should be protective of children.
Data
Analysis
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Aging In October of 2002, EPA's Administrator announced the EPA Aging
Initiative Initiative. This team is charged to develop a national agenda for the
< Agency in protecting the elderly from environmental health threats.
OCHP is currently acting as the lead office for this Initiative.
Internal Stakeholders
According to the organizational proposal creating OCHP, their internal
stakeholders include each of the media program offices at EPA, as well as the
Agency's research, administrative, and policy programs. The Office of
Enforcement and Compliance Assurance, especially its Office of Environmental
Justice, also plays a key role in implementing the goals and objectives of OCHP.
At the front lines of the Agency's efforts to protect children's health are EPA's
regional offices. Each EPA region has a Children's Health Coordinator whose
primary role is to ensure that all regional programs consider children within their
on-going work. During Fiscal Year 2001, the Agency's budget for issues related
to children's health peaked at approximately $71 million. As shown in the
following chart, the budget for children health protection activities declined to
approximately $62 million in Fiscal Year 2003.
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Children's Health Funding
$
1999
2000 I 2002
2001
Fiscal Year
2003
Scope and Methodology
In determining how the Agency plans, prioritizes, implements, and coordinates
children's environmental health protection, we interviewed a number of Agency
officials. We gathered information from OCHP and EPA program offices, as well
as EPA Regional Children's Health Coordinators, to determine activities planned
and implemented regarding children's environmental health protection, to identify
the various roles, and to obtain documentation. We also interviewed outside
stakeholders and representatives from other Federal agencies to document the
Agency's coordination efforts with these entities regarding children's
environmental health protection issues. A list of the offices visited and contacted
is in Appendix B.
We evaluated OCHP practices against criteria that the EPA OIG has adopted in
assessing systems/organizations. The EPA OIG developed "Assessing
Organizational Systems: A User's Guide" (November 2002) as a tool in assessing
organizations. This guide's components are based on key program management
practices consistent with the President's Management Agenda, the Government
Performance and Results Act, and the Office of Management and Budget's efforts
to assess effectiveness endorsed by the Agency.
We performed our evaluation in accordance with Government Auditing
Standards, issued by the Comptroller General of the United States. We
performed our field work from November 18, 2002, through October 31,2003.
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Chapter 2
Impediments to OCHP Effectively implementing the
- \ National Agenda ' ' '
During our review, we identified several impediments to OCHP's overall
effectiveness. While OCHP is responsible for implementing the National
Agenda, it is not directly responsible for many of the goals outlined in the
Agency's National Agenda. Additionally, according to OCHP, its mission is not
a task that can be undertaken in isolation, and a full and active partnership with
stakeholders must be established and fostered. However, we found that there was
no overall, coordinated strategy and no active communication process in place
among the program offices and OCHP. The Agency needs to develop a
coordinated strategy with milestones and targets, establish a Children's Health
contact within each media program office, and aid in coordinating children's
health issues within the Agency.
OCHP has not had a permanent Director since April 2002. Recognizing that
OCHP cannot implement the National Agenda without collaborating and
partnering with stakeholders, the lack of a permanent director could have a
negative impact on such efforts. Further, EPA named the OCHP as the lead for
the Agency's Aging Initiative following the announcement of the Initiative in
2002 which increased OCHP's workload and areas of responsibility. The Agency
needs to determine whether that Initiative should be lead by the same office
responsible for children's environmental health and if so, provide it with
additional resources to adequately protect both populations.
EPA Lacks Overall Children's Health Strategy
OCHP is responsible for integrating the Agency's efforts on behalf of children.
According to OCHP, its mission is not a task that can be undertaken in isolation,
and a full and active partnership with stakeholders must be established and
fostered. While many EPA program and regional offices had projects focused on
children's environmental health, we found there was no overall, coordinated
strategy to establish and foster a full and active partnership with stakeholders.
While OCHP is responsible for implementing the National Agenda, it is not '
directly responsible for many of the goals outlined in the National Agenda.
See table 2.1 that follows for further details.
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Table 2.1: National Agenda to Protect Children's Health
from Environmental Threats
Develop a scientific research strategy focus on the gaps in knowledge regarding
child-specific susceptibility and exposure to environmental pollutants;
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Expand community right to know allowing families to make informed choices
concerning environmental exposures to their children;
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Encourage and expand educational efforts with health care providers and
environmental professionals so they can identify, prevent, and reduce
environmental health threats to children; and
For example, the National Agenda specifically states that the Agency is to ensure
that all standards set by EPA are protective of any heightened risk faced by
children; however OCHP does not set standards within EPA. Additionally,
OCHP is not responsible for setting comprehensive policies to address cumulative
and simultaneous exposures to children. While OCHP does not have direct
control over many of the goals outlined in the National Agenda, we found the
Agency has taken several steps towards meeting this Agenda For example,
ORD coordinated with OCHP as well as with other program offices to develop
"The Strategy for Research on Environmental Risks to Children."
Coordination Improvements Needed
OCHP has taken actions to coordinate its efforts with EPA program offices and
regions, but has not been consistent with program office coordination efforts.
Because children's environmental health efforts were not coordinated, there was
inadequate assurance that limited resources were being used to the maximum
extent possible to protect children from risk.
Coordination Efforts with Program Offices Need Improvement
OCHP has not been effective in coordinating and/or communicating with EPA's
media program offices. OCHP officials recognized that their role differs among
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program offices and their relationship with some program offices has not been as
strong or consistent as with others. We also found that OCHP does not conduct
standard annual meetings or monthly conference calls with EPA's media program
offices like it does with the regions. Further, unlike the regions, the program
offices do not have designated children's health coordinators.
We also found that OCHP is not a part of the program office's annual or strategic
planning process, unless the program office requests their participation, and
OCHP officials indicated that usually does not occur. The program offices had
varying perceptions of the role and impact of OCHP. OCHP officials indicated
they had limited resources for labor intensive projects.
According to the organizational proposal creating OCHP, this office was to chair
an EPA Board on Children's Environmental Health. The Board's primary charge
was to ensure the integration of Agency activities effecting children and to serve
as a catalyst for actions that will be protective of children. Among its specific
responsibilities, the Board was to consider developing a comprehensive strategy
and action plan with milestones for Agency-wide activities related to protecting
children's health. This Board was to include the Deputy Office Director level and
higher, including the Assistant Administrators from ORD and Office of
Prevention, Pesticides and Toxic Substances. We spoke with OCHP officials
about the status of this board and they advised us that the Board has not been
active since 2000.
Coordination Efforts with Regional Offices and ORD Beneficial
In contrast to the communication efforts with the Program Offices, we found that
OCHP communicates with the Agency's regions through the use of Regional
Children's Health Coordinators. These coordinators hold annual meetings and
conduct monthly conference calls with OCHP. These interactions provide the
opportunity for the regions and OCHP officials to discuss on-going relevant
issues and network amongst themselves, and facilitates coordination efforts and
information sharing. While it varied among regions, we found OCHP had input
in regional planning efforts related to children's health activities. The Regional
Coordinators said that OCHP provides key areas of emphasis during their annual
meetings to be incorporated within the regions' annual planning and strategic
processes. They also indicated that OCHP serves as a focal point at Headquarters
for children's issues, and provides important information and funding.
In contrast to OCHP's efforts with the media program offices, we found that ORD
has a process to coordinate with OCHP and program offices in planning EPA's
children's health research through the use of Research Coordination Teams for
each media office. These teams, which meet throughout the year; allow each
program office to be involved in the planning for research in their media area.
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Lack of A Permanent Director
OCHP has not had a permanent Director since April 2002 - over 2 years.
Recognizing that OCHP cannot implement the National Agenda without
collaborating and partnering with stakeholders, the lack of a permanent director
could have a negative impact on such efforts. Various EPA regional coordinators,
the former OCHP Director, the Chair of me Children's Health Protection
Advisory Committee., and the Director of the Children's Environmental Health
Network (a national children's environmental health advocate) expressed concern
that the lack of a permanent Director may have a negative impact on the longevity
and importance of the children's environmental health program within EPA.
Specifically, the Director of the Children's Environmental Health Network said
that it is difficult to view EPA as having a unified children's health program
without the presence of a permanent Director. Additionally, the Children's
Health Protection Advisory Committee, in a memo to the Administrator dated
December 16, 2002, wrote that OCHP could not continue to play a key role
within EPA, and across the nation without permanent leadership.
It is imperative mat all internal and external stakeholders know that children's
health protection is a priority within EPA. The Administrator responded to the
Children's Health Protection Advisory Committee on May 2, 2003, that selecting
a permanent director for OCHP was a high priority for EPA. OCHP officials
indicated an announcement for the Director position was closed in May 2003, but
as of May 2004 a final decision had still not been made on a permanent OCHP
Director.
OCHP Named EPA Lead for Aging Initiative
The United States is undergoing a demographic transformation with respect to the
elderly. By 2030, ihe U.S. population over the age of 65 is expected to double to
an estimated 70 million. As people age they become more susceptible to
environmental hazards, such as: microorganisms in drinking water; second-hand
smoke and carbon monoxide in indoor air pollutants; ozone and particulate matter
in ambient air; volatile organic compounds; radon; temperature extremes; and
such neurotoxins as lead and mercury. Additionally, as people age, they have
accumulated a lifetime of exposures, and their immune systems diminish.
In October 2002, the EPA Administrator announced the EPA Aging Initiative,
making protecting the health of older persons a new priority of the Agency. The
goal of tile Initiative is tiiat every citizen, community, organization, corporation,
and particularly the Federal government, including EPA, is encouraged to
understand the link between the environment and the health of older Americans;
and take appropriate action to identify and reduce environmental threats to protect
the health of older Americans.
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OCHP was named the Aging Initiative's lead and revised its mission statement,
accordingly. Children and the elderly are both considered susceptible
populations. To ensure adequate coverage under this new area, OCHP
reorganized, adding a fourth team ("Aging Initiative Team") and hired one
additional full-time staff member. OCHP officials said they received $300,000
from the Agency in their 2003 operating plan/budget to fund the Aging Initiative.
However, to ensure adequate coverage within this new area, OCHP estimated that
it spent an additional $300,000 from its children's environmental health annual
budget toward the Aging Initiative. Further, these estimates did not take into
consideration the time spent by OCHP officials other than the one hired for the
Aging Initiative.
A May 2003 report issued by the Children's Environmental Health Network, a
national children's environmental health advocate, raised concerns about OCHP's
mission being "severely compromised" due to such decisions as placing the
Aging Initiative within OCHP without sufficient additional resources being
provided. The report, "Are Children Left Behind?: Children's Environmental
Health Under the Bush Administration," noted that by doing this EPA was doing
a disservice to both the children and the Aging Initiative. Additionally, the
Children's Health Protection Advisory Committee2 raised concerns that
expanding the mission of OCHP to include the aging would diminish OCHP's
effectiveness with children's environmental health.
The decision to make OCHP the lead of the Aging Initiative would greatly
increase OCHP's workload and areas of responsibility. Therefore, EPA needs to
carefully consider whether making the same office responsible for protecting the
environmental health of both the children and the aging is appropriate and, if so,
provide it with additional resources to adequately protect both populations.
Also, we noted that the term "aging" had not clearly been defined by OCHP,
According to OCHP, different Federal agencies have different age parameters in
defining "aging." An unclear definition could cause OCHP problems in
implementing programs.
^he Children's Health Protection Advisory Committee is a body of researchers, academicians, health care
providers, environmentalists, children's advocates, professionals, government employees, and members of the public
who advise EPA on regulations, research, and communication issues relevant to children.
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Recommendations
We recommend that the EPA Acting Deputy Administrator:
2-1. Develop a coordinated strategy that ties specific measures, milestones., and
targets toward meeting the Agency's National Agenda to Protect
Children's Health from Environmental Threats.
2-2. Reevaluate the role of OCHP and redefine its function and areas of
responsibility within the Agency.
2-3. Establish an official children's health contact within each program office.
2-4. Expedite the decision making process in appointing a Director for the
OCHP.
2-5. Ensure that OCHP is given resources to effectively implement the Aging
Initiative.
2-6. ' Clearly define the parameters for "Aging" as part of the Aging Initiative.
Agency Response and OIG Evaluation
The Acting Deputy Administrator concurred with all recommendations and
positions except Recommendation 2.6, which related to the aging parameters
under the Aging Initiative. According to the Acting Deputy Administrator, it is
not beneficial to define parameters for aging. The response further added that it is
important to recognize that aging is a process that is not tied to a specific age.
We recognize mat while aging is a process, we believe it is important for the lead
of the Aging Initiative to establish a clear and concise definition of what
constitutes aging under the Aging Initiative to ensure consistency within EPA
program offices. The Older Americans Act of 19653, for example, defines "older
individuals" as individuals who are 60 years of age or older. Recognizing that the
National Agenda for the Aging will consist of three parts, including identifying
research gaps in environmental health and encouraging older adults to volunteer
to address similar concerns, it would be prudent for EPA to clearly define the
target audience.
In response to our other recommendations, the Agency agreed to explore other
options for improving coordination within the Agency and ways to better measure
their progress and results. The Agency cited as an example a plan to work with
the Office of the Chief Financial Officer to explore options to improve the way
3 Older Americans Act of 1965, Public Law 89-73, was enacted to provide assistance in the development of
new or improved programs to help older persons.
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children's health is coordinated and measured in the Agency's strategic and
annual budget planning process. Additionally, the Agency agreed to reiterate the
role of OCHP to EPA senior managers to ensure OCHP can be an effective
participant with EPA's programs that affect children.
Although the Agency concurred with most of the recommendations and positions
of the report, the Agency expressed a concern that the OIG did not recognize the
role of the OCHP and the accomplishments that OCHP and EPA have made to
protect the Nation's children. They recognized that there is always room for
improvement, but they believe the focus of the OIG report did not recognize the
substantial and significant progress that the EPA and OCHP - working with
internal and external collaborators - have made in a relatively short period of
time. According to the response, the Agency has made significant progress in
developing science related to children's health and regulatory policy, as well as
developing tools and information for communicating children's health issues.
In addition, the response added mat the Agency has taken significant actions in
recent years to protect children's health from pollution in the air, water and land.
A snapshot of some of the examples of EPA's accomplishments were included in
the response and a more detailed summary of accomplishments was provided as
an attachment
As cited in the body of our report, we recognize that many of EPA's program and
regional offices have projects that focused on children's environmental health
protection. However, the role OCHP had in developing and implementing these
programs is not clear. OCHP identified several EPA accomplishments in their
response memorandum, but support was not provided to illustrate the role of
OCHP in these projects. OCHP also provided an attachment in their response that
related to overall EPA accomplishments and, again, it is not clear as to the role
and impact of OCHP on these projects. We recognize that OCHP has taken
actions in several areas related to children's health protection, but OCHP needs to
focus on results rather than activity.
The Acting Deputy Administrator expressed concern regarding the title of the
report. Consequently, we modified to title to more clearly articulate the findings
in the report. Clarification was also provided for a date referenced in the report
pertaining to the lack of a permanent director. This date was modified based on
information provided by OCHP.
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Chapter 3
Strengths, Weaknesses in OCHP Implementation
Efforts Noted '' '
We found that OCHP has no formal mechanism in place to ensure performance
results or assess relationships between program costs, activities, and results.
OCHP has a strategic planning process that includes an annual office planning
meeting followed by a mid-year meeting to assess the status on the current year's
plan and to begin consideration of potential focus areas for the following year.
However, despite these meetings, there is no formal tracking to ensure that goals
are met. More specifically, data and information systems are not available to
measure, analyze, and demonstrate overall performance specific to the National
Agenda on a continuing basis.
Improved Focus Needed
To evaluate OCHP's efforts in integrating children's health protection throughout
the Agency's operations, we used the OIG's "Assessing Organizational Systems:
A User's Guide," issued in November 2002. This tool was designed to assess
organizational "Systems" by providing managers with seven key areas that
establish the foundation for an organization or program to be successfully
implemented. We assessed OCHP's planning process and operations in
implementing children's health protection against these key areas.
While OCHP has taken actions in different areas related to children's health
protection, OCHP needs to focus on results. OCHP should have a methodology in
place to set priorities to ensure resources are being allocated to those problems that
pose the greatest environmental risks to children, and needs to efficiently measure
those results to ensure sufficient strides are being made in improving children's
environmental health. OCHP's broad overall mission, limited resources, and
unclear role contributed to the shortcomings found.
We believe an OCHP annual internal review of results or outcomes versus planned
activities would be beneficial. This should become an annual assessment or
review of OCHP's work. The results should be incorporated into OCHP's annual
strategic planning meeting, as well as in its mid-year meeting. This review should
verify performance results and analyze more accurately the relationship among
costs, activities, and results.
The results of our evaluation for each of the seven key areas are in Table 3.1.
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Table 3.1: Seven Vital Areas
Leadership
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Information and
Analysis
Hurhan Capital
Process
Management
OCHP has defined a vision and
mission statement
partnerB; ha ve :t>een;idehfified;; :: !|
$9iiy>$
partnsrs on: yanousjprpjects: :
OCHP produces episodic
summary products that illustrate
Agency activities in children's
health
OCHP developed a book on
trend analysis
OCHP maintains a website
status
;i^^i^;(i^^^g^«ri^^
; actiyjties,; and ^outputs a re: linked; tnjachieye; the.;;^
! objetitives arid: '6 nvfronmerital reiailfe ';;l;K '? '-\ ;'> -;'* '
:-: ::,.:::::-::::: -x::-: :x:::-:::::::-:::::::-:"-::::.::^:^:x:::.:::::..::::x:x.:;..'::. 'x'.x.'x:'::-.:'
Leadership has not ensured understanding
throughout the Agency of the vision and mission
of OCHP
OCHP has not had a permanent Director since
April 2002
Data and information systems are not available to
measure, analyze, and demonstrate overall
performance specific to National Agenda on a
continuing basis
OCHP's objectives and goals are not specific and
clearly measurable
There is no documentation or explanation of
deviation from action plan
There is no formal followup to ensure
completeness of projects
"''"''' """''"""" *'" """
16
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Recommendations
We recommend that the Office of Children's Health Protection:
\
3-1. Make improvements to its annual planning process to include, at a
minimum:
a. more complete and measurable details on how planned activities are
projected to be completed, identifying quantifiable attainable goals
and targets;
b. a plan of what potential resources, either internally within OCHP or
externally within EPA or other stakeholders, are to be used;
c. proj ected allocations of these resources and what the end products
will be; and
d. a methodology to set priorities to ensure resources are being
allocated to those problems that pose the greatest environmental
risks to children, recognizing that OCHP has limited resources.
3-2. Perform an annual internal review of results or outcomes versus planned
activities.
3-3. Conduct periodic meetings with program office officials to discuss
upcoming children's health projects, coordination efforts, and future areas
of focus.
Agency Response and OIG Evaluation
OCHP agreed with our recommendations and positions outlined in this chapter.
In response to our recommendations, OCHP is planning to develop quantifiable
measures and develop long term objectives and strategic targets. Additionally, in
future years, they plan to incorporate a review and analysis of the strategic targets
and projects to determine if the results and outcomes identified were met.
17
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18
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Appendix A
Auditee's Response
MEMORANDUM
SUBJECT: Draft Evaluation Report: Effectiveness of the Office of Children's Health Protection '
Cannot Be Determined
TO: Kwai Chan
Assistant Inspector General for Program Evaluation
We welcome the OIG report and concur with some of the observations and recommendations. However,
we are concerned that the OIG did not appear to recognize the role of the Office of Children's Health
Protection (OCHP) and the enormous accomplishments that OCHP and EPA have made to protect the
Nation's children. We appreciate and highly value having an independent, unbiased review and evaluation
of our efforts in this area. Protecting children from environmental hazards remains a very high priority for
EPA, We also continue to view the role of the Office of Children's Health Protection (OCHP) as critical
to the Agency's perseverance in moving forward on children's environmental health issues. We believe
that it is very important to understand the role of OCHP within the Agency. OCHP was established to
raise awareness and facilitate change in the way EPA does business so that protecting children's health
becomes an integral part of all of the Agency's work from research to regulatory activities. While OCHP
does not conduct research or set standards, they do work with Agency offices in those areas to insure that
risks to children are considered. They are also responsible for working outside the Agency to increase
efforts focused on children's environmental health (i.e., with other federal agencies, States, healthcare
providers, and the private sector).
We recognize the difficulty in assessing the full scope of work for any program being
evaluated. As you point out hi the report, implementing the National Agenda to Protect Children From
Environmental Health Threats is the responsibility of the Agency as whole, not just OCHP. While we
recognize that there is always room for improvement, we believe that the focus of the IG report does not
recognize the substantial and significant progress that the EPA and OCHP - working with internal and
external collaborators - have made in a relatively short period of time.
We do agree with the OIG that we do not yet have the tools to quantitatively evaluate
environmental health results of the program, a finding not inconsistent with many of our environmental
programs as we all seek improvement in our ability to measure environmental and public health outcomes.
We are committed to doing what is needed to measure the results of all of EPA's programs. However, we
think that the report does not adequately recognize the qualitative advances made by the Agency on
children's health and presents an unbalanced picture of the overall value of the program.
The Agency has made significant progress in developing science related to children's
health and regulatory policy, as well as developing tools and information for communicating children's
health issues. The Agency has taken significant actions in recent years to protect children's health from
pollution in the air, water and land.
A snapshot of some of the examples of EPA's accomplishments include: the phaseout of
chromated copper arsenate (CCA) which will significantly lower potential risks to children; establishment
of Centers of Excellence in Children's Environmental Health Research dedicated solely to the study of
19
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children's environmental health; cancellation or use restriction of pesticides affecting children's health
including methyl parathion, azinphos methyl, chlorpyrifos, and diazinon; the first-ever collaboration of
State environmental and health officials to reduce childhood asthma; the National Children's Study, a
longitudinal cohort study to investigate the relationship of the environment to children's health; the diesel
rule which will reduce emissions of NOx by 2.6 million tons each year when the program is fully
implemented; the Toxic Release Inventory (TRI) lead standard which requires more reporting of
environmental releases of lead; the off-road diesel rule that will reduce emissions by more than 90 percent;
the Clean School Bus U.S.A. initiative which will reduce both children's exposure to diesel exhaust and the
amount of air pollution created by diesel school buses; and the Voluntary Children's Chemical Evaluation
Program which will evaluate 22 chemicals for potential risks to children. In addition, efforts with the
States, healthcare providers, and the international community have resulted in significant actions on
children's environmental health where there was virtually no activity prior to EPA's involvement. A more
detailed summary of accomplishments is in attachment 2. We hope that you will consider recognizing
these accomplishments in your final report to present a more balanced evaluation of the program.
Further, we believe that the current title of the report does not accurately reflect the actual
findings of the report. We believe that" Improvements Are Needed in Efforts to Measure the
Effectiveness of EPA's Efforts to Protect Children" or "Effectiveness of the Office of Children's Health
Protection Cannot Yet Be Quantitatively Determined" would better describe the reports findings.
Please refer to attachment 1 for a detailed response to the recommendations. In addition to
the summary of OCHP accomplishments mentioned above (attachment 2), a September 2003 report
"Evaluation of EPA Activities Related to Children's Health Protection" is also attached for your
consideration in finalizing the report.
Nikki Tinsley
Jeffrey Harris
Jerri Dorsey
Laurie Adams
Tom Gibson
JeffHolmstead
Paul Oilman
Marianne Horinko
Benjamin Grumbles
Dona DeLeon
Natalie Gochnour
Rich McKeown
William Sanders
Joanne Rodman
Elizabeth Blackburn
Stephen L. Johnson
Acting Deputy Administrator
Attachments
20
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OCHP's Response to the IG Report:
Effectiveness of the Office of Children's Health Protection Cannot Be Determined
GENERAL COMMENTS AND CORRECTIONS:
We believe that the report does not adequately credit the great strides that the Agency has
made in the area of Children's Environmental Health Protection. For example, prior to the
efforts of OCHP and other EPA programs there was little or no activity on children's
environmental health in the States or in the health care provider community. Now we
have significant programs in both areas. The same is true in the area of science and
economics. We refer you to the September 2003 report "Evaluation of EPA Activities
Related to Children's Health Protection"(attached), which evaluated EPA's progress in
implementing the EPA National Agenda to Protect Children From Environmental Health
Threats. We have also attached an appendix to this response which highlights the
children's environmental health (CEH) accomplishments over the last several years. We
hope that the OIG will be able to use these documents to include examples of die
significant progress that has been made in the final report.
We believe that the current title of the report does not accurately reflect the actual findings
of the report. We believe that "Improvements Are Needed in Efforts to Measure the
Effectiveness of EPA's Efforts to Protect Children" or "Effectiveness of the Office of
Children's Health Protection Cannot Yet Be Quantitatively Determined" would better
describe the reports findings.
The report states that the office has been without a permanent director since April 2001 -
nearly 3 years. The correct date is April 2002 - nearly 2 years.
RESPONSE TO RECOMMENDATIONS FOR THE EPA ACTING DEPUTY ADMINISTRATOR:
2-1. Develop a coordinated strategy that ties specific measures, milestones, and targets toward meeting
(he Agency's National Aeenda to Protect Children's Health from Environmental Threats.
We agree that it is important that EPA efforts focus on children's environmental health be coordinated and
that we need to do a better job measuring results in this area. An attempt to do this is reflected in the
September 2003 report "Evaluation of EPA Activities Related to Children's Health Protection".
We recognize that, while useful, that report fell short of quantitatively measuring health outcomes, but it
did look at progress made related to the National Agenda. OCHP and the Deputy Administrator will
explore other options for improving coordination in the Agency and ways to better measure our progress
and results. For example we will work with the Office of the Chief Financial Officer to explore options to
improve the way children's health is coordinated and measured in the Agency's strategic and annual
budget planning process.
2-2. Reevaluate the role of OCHP and redefine its function and areas of responsibility within theAeencv
We agree with this recommendation, with modification.
While OCHP's mandate is to facilitate the implementation of the National Agenda to Protect Children's
Health from Environmental Threats, it was never intended that the office would have responsibility to
implement most areas in the National Agenda. For example, although OCHP is an active voice for
21
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children's health in the Agency standards and regulation development process, the office does not develop
standards. Developing standards is the responsibility of the program offices. Protecting children from
environmental hazards remains a very high priority for EPA and the role of OCHP is critical to the
Agency's continuing progress. OCHP was established to raise awareness and facilitate change both inside
and outside EPA. With support from the Agency's leadership, they have been tasked with raising
awareness and facilitating change in the way EPA does business so that protecting children's health
becomes an integral part of all of the Agency's work from research to regulatory activities. While OCHP
does not conduct research or set standards, they do work with Agency offices in those areas to insure that
risks to children are considered. They are also responsible for working outside the Agency to increase
efforts focused on children's environmental health (i.e., with other federal agencies, States, healthcare
providers, and the private sector). EPA leadership will reiterate the role of OCHP to EPA senior managers
so that OCHP can continue to be an effective participant in all of the Agency's programs that affect
children.
t
2-3: Establish an official children's health contact within each program office.
We agree with this recommendation.
We believe it is very important to have a management-designated CEH contact in each program office to
facilitate our collaborative efforts implementing the National Agenda and other issues relating to CEH.
Many programs have designated CEH contacts already, and OCHP currently works closely with these
contacts throughout the Agency. OCHP has been very effective at leveraging resources within the Agency
to ensure that the directives of the National Agenda are met and has drawn upon ongoing efforts
throughout EPA to develop collaborative relationships with regional and program offices.
OCHP and the DA are exploring ways to assure that the current CEH contacts represent their offices and
ways to increase management involvement in CEH throughout the Agency.
2-4: Expedite the decision making process in appointing a Director for OCHP.
We agree with this recommendation.
The Agency is in the process of recruiting nationally for a permanent director. In the interim an SES level
manager, the Deputy Assistant Administrator for Prevention, Pesticides and Toxic Substances, has been
appointed as Acting Director for OCHP. He has extensive experience with children's issues both in Region
5, where he dealt with the impact of lead poisoning on minority children in the Midwest, and in
Headquarters where he dealt with implementation of the lead program, including development of
regulations to put into place a protective infrastructure for kids.
2-5: Provide a formal decision on what office should be given the lead for implementing the Aging
Initiative* aad ensure that whichever office is designated is given resources to effectively implement the
program.
We agree with this recommendation with modification.
The Agency has made the decision to have OCHP take the lead for the Aging Initiative. Recognizing
OCHP's experience and success in working within EPA as well as with outside stakeholders on issues
relating to susceptible populations, we believe that they are the appropriate office to manage the initiative.
We also agree that, within budget constraints, appropriate resources are needed to implement the initiative.
It is important to acknowledge that the Aging Initiative is still at the early vetting stage. More discussion
22
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and deliberation is required with outside stakeholders and with EPA programs to determine whether or not
additional work in this area-beyond existing efforts in science, outreach and communications-might be a
beneficial and productive use of agency resources.
2-6: Clearly define the parameters for "aging" as part of the Asins Initiative.
We disagree with this recommendation.
It is not beneficial to define parameters for aging. It is important to recognize that aging is a process that is
not tied to a specific age. EPA's Aging Initiative was established to protect the environmental health of
older persons, independent of specific chronological age. For example, outreach and educational efforts are
targeted to older people with chronic conditions that can be exacerbated by the environment This
approach is consistent with professionals working in this field.
The aging population in the United States is a heterogeneous group reflecting a broad diversity in health
status, behavioral patterns, social and cultural influences and environmental conditions.[U.S. Census, 65+
in the United States (1996)].
As we age, we may become more susceptible to environmental hazards. Aging is a natural progressive
decline in organ function and compensatory reserves, accompanied by a reduced capacity to detoxify and
eliminate toxicants. Health effects resulting from a lifetime of environmental or occupational exposures to
persistent agents may also manifest as one grows older [National Academy of Sciences Workshop on the
"Differential Susceptibility of Older Persons to Environmental Hazards," December 2002].
Understanding the biology underlying differing age-related responses can inform a scientific rationale for
decisions on how to appropriately incorporate the differential sensitivity of aging adults into environmental
risk assessment, decisions and actions.
RESPONSE TO RECOMMENDATIONS TO THE OFFICE OF CHILDREN'S HEALTH PROTECTION:
3-1: Make improvements to its annual plannine process to include, at a minimum:
1.1 More complete and measurable details on how planned activities are projected to be
completed, identifying quantifiable attainable goals and targets:
1.2 A plan of what potential resources, either internally within OCHP or externally within
EPA or other stakeholders, are to be used:
1.3 Projected allocations of these resources and what the end products will be: and
1.4 A methodology to set priorities to ensure resources are being allocated to those problems
that pose the greatest environmental risks to children, recoenizins that OCHP has limited
resources.
We agree with this recommendation.
OCHP is committed to continuing to make improvements to ensure that the directives of the national
Agenda are met. As pointed out in the IG report, OCHP has a vision, mission and goals to guide the
office's decision-making. OCHP supports and facilitates Agency efforts in three primary areas: 1)
regulations and standards, 2) science and risk assessment, and 3) public awareness, community-based
programs, and education. In addition, OCHP develops an action plan annually based on the goals and
23
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identifying areas where there appear to be gaps and needs. These annual decisions are revisited several
times throughout the year.
In September of FY 2003, OCHP began to reevaluate its goals and to develop long-term
objectives, sub-objectives and strategic targets to assure that we can move forward in achieving
our goals.
OCHP has set aside funds in the office's FY 2004 budget and has acquired a knowledgeable
detailee for six months that will spend full time managing a project to establish quantifiable
measures for the office.
The results of both activities above will be used to inform decisions and set priorities at OCHP's
annual planning meeting.
3-2: Perform an annual internal review of results or outcomes versus planned activities.
We agree with this recommendation
In future years OCHP's annual planning process will include a review and analysis of the strategic
targets and projects to determine if the results and outcomes identified have been met, and if not,
why not, lessons learned, and whether additional efforts are required to meet them.
All proposed projects will include clearly defined expected results and the methodology that will
be used to measure the results.
3-3: Conduct periodic meetines with the proeram office officials to discuss upcoming children's health
projects, coordination efforts, and future areas of focus.
We agree with this recommendation.
OCHP intends, with the Deputy Administrator's help, to make the relationship with the program
offices more "official" at a management level. However, as mentioned under recommendation 2-3,
OCHP has consistently worked closely with dedicated CEH contacts in all of the Agency program
offices and regions, and could not have the same level of success without their assistance.
24
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Appendix B
Offices Visited and Contacted
EPA
Office of Air and Radiation: Indoor Environments Division
Office of Prevention, Pesticides, and Toxic Substances:
Office of Science Coordination and Policy
Office of Pollution Prevention and Toxics
Office of Pesticide Programs
Office of Solid Waste and Emergency Response
Office of Water
Office of Children's Health Protection
i
Office of the Chief Financial Officer: Office of Planning and Budget Analysis
Office of Research and Development
Regional Children's Environmental Health Coordinators (Regions 1-10)
Other Federal Agencies
Agency for Toxic Substances and Disease Registry
National Institute of Environmental Health Sciences
Outside Stakeholders
Children's Environmental Health Network
National Resources Defense Council
25
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26
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Appendix C
Distribution
Acting Deputy Administrator
Acting Director, Office of Children's Health Protection
Agency Followup Official (the CFO) (2710A)
Agency Audit Followup Coordinator (2724A)
Audit Followup Coordinator, Office of Children's Health Protection
Acting Associate Administrator, Office of Public Affairs (1101A)
Acting Associate Administrator for Congressional and Intergovernmental Relations (1301 A)
Acting Director, Office of Regional Operations
Assistant Administrator, Office of Research and Development
Assistant Administrator, Office of Air and Radiation
Assistant Administrator, Office of Prevention, Pesticides, and Toxic Substances
Assistant Administrator, Office of Solid Waste and Emergency Response
Assistant Administrator, Office of Water
Audit Liaison, Office of the Administrator
Audit Followup Coordinator, Office of Air and Radiation
Audit Followup Coordinator, Office of Prevention, Pesticides, and Toxic Substances
Audit Followup Coordinator, Office of Solid Waste and Emergency Response
Audit Followup Coordinator, Office of Water
Audit Followup Coordinator, Office of Research and Development
Inspector General (2410)
27
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EVALUATION OF EPA ACTIVITIES
RELATED TO CHILDREN'S HEALTH PROTECTION
Prepared for:
United States Environmental Protection Agency
Office of Children's Heallh Protection
Prepared by:
Industrial Economics, Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140
and
Abt Associates
480 Montgomery Lane
Bethesda, MD 20814
September 19,2003
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TABLE OF CONTENTS
INDEX OF EXHIBITS i
EXECUTIVE SUMMARY ES-1
INTRODUCTION 1
STRUCTURE OF ANALYSIS 3
ORGANIZATION OF THE REPORT ' 4
REGULATORY PROGRAM REVIEW 5
ANALYSIS OF EPARULEMAKINGS 5
CRITICAL EVALUATION OF MAJOR REGULATORY IMPACT ANALYSES 9
INTERVIEWS WITH EPARULEWRITERS 12
SUMMARY OF FINDINGS OF REGULATORY PROGRAM REVIEW 13
RESEARCH AND SCIENCE POLICY 14
RESEARCH 14
CUMULATIVE AND SIMULTANEOUS EXPOSURE POLICY 17
SUMMARY OF FINDINGS ON RESEARCH AND SCIENCE POLICY 20
OUTREACH 21
PUBLIC OUTREACH 21
ENVIRONMENTAL EDUCATION GRANTS 24
INFORMATION FOR HEALTH CARE PROVIDERS 25
COMMUNITY RIGHT-TO-KNOW 27
SUMMARY OF FINDINGS ON OUTREACH 28
BUDGETARY ANALYSIS 30
FUNDING 30
TRACKING CHILDREN'S ENVIRONMENTAL HEALTH 32
CONCLUSIONS 38
REGULATORY PROGRAM REVIEW 38
RESEARCH AND SCIENCE POLICY 38
OUTREACH 39
BUDGETARY ANALYSIS ! 40
NEXT STEPS 41
;
APPENDIX A: METHODOLOGY MEMORANDA A-l
APPENDIX B: REGULATORY IMPACT ANALYSIS MATERIALS B-l
APPENDIX C: CUMULATIVE EXPOSURE MATERIALS C-l
APPENDIX D: HEALTH CARE PROVIDER MATERIALS D-l
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INDEX OF EXHIBITS
EXHIBIT 1: Organization of Analysis 3
EXHIBIT 2: Regulatory Actions By Regulatory Area 6
EXHIBIT 3: Health or Safety Based Actions by Regulatory Area 7
EXHIBIT 4: Health or Safety Based Actions that are Economically Significant or
Have a Disproportionate Impact on Children '. 8
EXHIBIT 5: Percentage of Health or Safety Based Actions Including Discussions of EO13045
and Evaluations of Children's Health 9
EXHIBIT 6: Summary of Children's Health Impacts Discussed in the Major Regulatory
Impact Analyses 10
EXHIBIT 7: Number and Percent of Children's Health STAR Projects 1993-2001 15
EXHIBIT 8: Total Children's Health STAR Funding and Centers for Excellence Funding 16
EXHIBIT 9: Children's Health STARFunding as Percentage of Total Funding 17
EXHIBIT 10: Cumulative and Simultaneous Exposure: Overview of Major Accomplishments
and Current Progress 18
EXHIBIT 11: Number of Children's Health Cumulative Exposure NCEA Research Activities 20
EXHIBIT 12: Number of Children's Health Outreach Tides in NEPIS 22
EXHIBIT 13: Children's Health Topics as a Percentage of All EPA Outreach Titles in NEPIS 23
EXHIBIT 14: Number of Children's Health Outreach Documents in NEPIS by Subject and
Foreign Language Availability 23
EXHIBIT 15: Children's Health Environmental Education Grants as a Percentage
of Total Environmental Education Grants 25
EXHIBIT 16: Summary of EPA's Efforts to Provide Information to Health Care Providers 26
EXHIBIT 17: Children's Health Budget as a Percentage of EPA's Budget 31
EXHIBIT 18: Total Pounds of TEACH and VCCEP Chemicals Released 36
EXHIBIT 19: Risk-Related Results to Children of TEACH and VCCEP Chemicals 37
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EXECUTIVE SUMMARY
The U.S. EnvironmentalProtection Agency (EPA) has IcmgrecognizedthatcMdrmrequirespecial
protection from environmental hazards. In 1996, EPA developed the National Agenda to Protect
Children's Health from Environmental Threats (National Agenda) and in 1997 created the Office of
Children's Heallh Protection (OCHP). OCHP advocates the consideration of children's environmental
health risks across EPA activities identified in the National Agenda and also works to promote
consideration of children's health risks wilhin all levels of government and across the non-government
sector.
In addition to these ongoing internal EPA activities, Executive Order 13045-Protection of
Children from Environmental Health Risks and Safety Risks (EO 13045)»was issued in 1997 and
implemented by EPAinApril 1998. EO 13045 requires feat all federal agencies evaluate health and safely
risks to children and consider the effects of rulemaking actions on children For rules meeting the criteria
for EO 13045 (i.e., rules that concern an environmentalhealthor safety risk, are economically significant,
and may disproportionately impact children), agencies must explain why the chosen regulatory action is
preferable to other reasonable alternatives.
A number of stakeholders, including Congress, EPAmanagement, other agencies, and the general
public, are interested in learning how well EPA is addressing children's health concerns. Accordingly,
OCHP has conducted a review of progress in this area, focusing on tiie elements of the National Agenda
and compliance with EO 13045.
SCOPE OFTHI REVIEW
Based on a review of existing reports and assessments as well as a series of interviews with key
EPA officials, OCHP identified five major categories of analysis around which to organize the review: (1)
Regulatory ProgramReview; (2) Researchand Science Policy; (3) Outreach; (4) Budgetary Analysis; and
(5) Tracking Children's Environmental Health. These measures are not a comprehensive accounting of all
EPA activities related to children's health; rattier, they provide an indication of EPA's progress. When
developing the suite of measures for this analysis, publicly available databases or tracking systems were
selected in order to facilitate future OCHP efforts to track progress.
Regulatory Program Review
To assess tile responsiveness of EPA regulatory actions to the higher risks faced by children, the
analysis focused on EPA's formal considerations of children's health risks in the regulatory content of the
Evaluation of Children's Health Protection
ES-1
September 19, 2003
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Federal Register.1 This quantitative analysis was augmented with a qualitative review of a subset of
relevant Regulatory Impact Analyses (RIAs) and targeted interviews ofEPApersormelto better understand
how EPA conducted evaluations of children's health risk and how EO 13045 affected these efforts.
The analysis revealed that EO 13045 is applicable in only a very small number of the regulatory
actions promulgated. However, a high percentage of health or safety based rulemakings consider EO
13045, and a substantial number of rules include evaluations of children's health, even whennot required
by EO 13045. The examination of the Federal Register notices did not reveal any cases where children's
health should have been examined but was overlooked.
The results of the analysis of relevant RIAs and interviews with EPA rulewriters support the more
quantitative findings. EO 13045 itself did not have a substantial impact on whether or how an evaluation
of children's health was conducted, because existing laws or requirements to address sensitive populations
generally compelled the rulewriters to consider the potential impacts on children.
Research and Science Policy
EPA has already made progress in achieving the National Agenda goal to "develop a scientific
research strategy focused on the gaps in knowledge regarding child-specific susceptibility and exposure
to environmental pollutants." The 1999 EPA Strategy for Research on Environmental Risks to
Children2 oudinesmultiple objectives, children's risk topics, research questions, and researchpriorities that
are to be addressed inresearch plans developed by EPA OCHP was one of several EPA offices to assist
the Office of Research and Development in developing the Strategy. The Research and Science Policy
category of this analysis measures success in implementation of the Strategy.
The analysis found that EPA increased the amount and percentage of research funding related to
children's concerns in the Science to Achieve Results (STAR) program from 1995 through 1999, with a
decrease in 2000 and a slight increase againin2001. While these trends suggest a response to the National
Agenda and EO 13045, the short time period represented warrants continued monitoring to assess more
meaningful, longer-termtrends. Overtheperiod 1997-1999, EPA also funded other relevant research that
expands the base of knowledge in the area of human health risk assessment generally, and, to a lesser
extent, targeted gaps in cumulative/simultaneous exposure of children to environmental pollutants.
Outreach
EPA's progress in creating and disseminating children's health outreach to key audiences-parents,
1 This effort extends a previous OCHP analysis, "Analysis of EPA Implementation of Executive
Order 13045," September 30, 2001.
2 Viewed at http://www.epa.gov/nceawwwl/risk2kids.htm.
Evaluation of Children's Health Protection ES-2
September 19, 2003
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teachers, caretakers, and healthcare providers - was assessed using a series of qualitative and quantitative
metrics in four areas: (1) information available throu^ilheNationalEnvironmaitalPublications Internet Site
(NEPIS); (2) funding disbursed to the Environmental Education grants program; (3) materials and activities
aimed at children's health care providers; and (4) initiatives related to community-right-to-know.
The analysis found that the number of EPA's children's health outreach publications in NEPIS
peaked in 1998, and has decreased since then. However, the proportion of children's health publications
inNEPIS after 1998 is stillgreaterthantheproportionintheyearspriorto 1998. Environmental education
grant amounts awarded to projects educating the public in environmental exposure and health risks to
children also peaked in 1998 and have dropped off since. EPA continues to initiate and maintain programs
aimed at educating health care professionals in children's environmental health issues. While metrics are
not available for all the programs, available data indicate that these programs are well-focused and meet
their stated objective.
Budgetary Analysis
The National Agenda specifies that funding be allocated as is necessary to "address children's
environmental health as a top priority among relative environmental risks." This analysis employs tie
proportion of the EPA's total budget devoted to children's health across FY2001-2003 as a quantitative
measure of EPA priority placed upon this issue (amounts for 2003 are projected).
For fiscal years 1999 - 2003, the data show an approximately two-fold increase in both the
proportion and the total amount of money committed ($32,419,900 to $67,580,100) from EPA's total
budget ($7.6 billion) dedicated to children's health between 1999 and 2000. After 2000, the proportion
of die total budget dedicated to children's health remains relatively steady.
Tracking Children's Environmental Health
EPA has published two reports on trends in environmental factors related to the health and well-
being of children in Ihe United States. America's Children and the Environment: A First View of
Available Measures was published in December 2000, and America's Children and the Environment:
Measures of Contaminants, Body Burdens, and Illnesses was published in February 2003. The 2003
edition of the report finds that there is a continued decline in the number of children with elevated blood
lead levels, a reduction in children's exposure to second hand smoke, and decreases in exposures to air
pollution and contaminants in drinking water. However, the report also finds that there is still much work
to be done, as asthma rates are increasing, many children continue to have elevated blood lead levels, the
potential for mercury exposure in the^womb is of growing concern, and there is a disproportionate impact
of childhood diseases on low-income and minority children.
EPAhas also examined the relative risk posed by releases of selected chemicals reportedto TRI.
Using Risk-Screening Environmental Indicators (RSEI), a computer-based screening tool, EPA assessed
Evaluation of Children's Health Protection ES -3 September 19,2003
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the relative impacts of releases of toxic chemicals by combining estimates of toxicity, exposure level, and
the exposed population. This information was used to analyze potential risks to children's health from TRI
releases. Overall, while total pounds of these chemicals emitted over the period increased, children's risk-
related impacts from these chemicals, as estimated by the RSEI tool, decreased over the time period of
this analysis.
NEXT STEPS
The report contains a discussion of appropriate next steps the Agency could consider to better
understand the degree to which children's health risks are being considered in Agency decisions. These
include:
D Conduct a focused and structured qualitative analysis of each of the five categories of
analysis in order to supplement and enrich understanding of the more quantitative
measures;
D Conduct a formal assessment of the quality of children's health evaluations conducted
as part of Regulatory Impact Analysis and other rulemaking actions, to determine how
thoroughly these risks are considered;
D Track1 the outputs and outcomes described in its Strategy for Research on
EnvironmentalRisks to Children (1999) in order to better assess progress in science
policy;
D Evaluate the effectiveness of information contained in public outreach efforts; and
D Develop a central database for outreach activities that could augment interoffice
collaboration and sharing of various outreach approaches and successes. Such a
database could be used to track continued efforts in disseminating community right-to-
know information gleaned from Toxic Release Inventory (TRI) data.
Evaluation of Children's Health Protection
ES-4
September 19, 2003
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INTRODUCTION
The Environmental Protection Agency (EPA) has long recognized that children require special
protectionfromenvironmentalhazards. In 1996, EPA developed a National Agenda to Protect Children's
HealthfromEnvironmental Threats (National Agenda) and in 1997 created an Office of Children's Health
Protection (OCHP). OCHP advocates the consideration of children's environmental health risks across
EPA activities identified in the National Agenda and also works to promote consideration of children's
health risks within all levels of government and throughout the non-governmental sector. The elements of
the National Agenda include the following (an abbreviated Me for each element is noted in parentheses and
is used throughout this report):
«D Ensure that all standards set by EPA are protective of any heightened risks faced by
children (analysis of EPA rulemaking; evaluation of major regulatory impact analysis,
interviews wilh EPA mlewriters);
D Develop a scientific research strategy focused on the gaps in knowledge regarding
child- specific susceptibility and exposure to environmental pollutants (research);
D Develop new, comprehensive policies to address cumulative and simultaneous
exposures faced by children (cumulative and simultaneous exposure);
0 Encourage parental responsibility1 for protecting their children from environmental
health threats by providing them with basic safely information (public, environmental
education grants);
D Encourage and expand educational efforts with health care providers and
environmental professionals so they can identify, prevent, and reduce environmental
health threats to children (health care providers);
D Expand community right-to-know allowing families to make informed choices
regarding environmental exposures to their children (community right-to-know); and
Q Provide the necessary funding to address children's environmental health as a top
priority among relative environmental health risks (funding).
In addition to these ongoing internal EPA activities, Executive Order 13045 - Protection of
Children from Environmental Health Risks and Safety Risks (EO 13045) - was issued in 1997 and
implemented by EPAin April 1998. EO 13045 requires that all federal agencies evaluate health and safety
risks to children and consider the effects of rulemaking actions on children. For rules meeting the criteria
for EO 13045 (i.e., those that concern an environmental health or safety risk, are economically significant,
and may disproportionately impact children), agencies must explain why the chosen regulatory action is
Evaluation of Children's Health Protection 1 September 19,2003
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preferable to other reasonable alternatives.
A number of stakeholders, including Congress, EPA management, other agencies, and the general
public, are interested in learning how well EPA is addressing children's health concerns. Accordingly,
OCHP has conducted a review of progress in this area, focusing on the elements of the National Agenda
and compliance with EO 13045. Among the key findings of the review, as detailed in this report, are the
following;
D Only a very small number of rules issued since 1998 (fewer than one percent) actually
met all the criteria and triggered the provisions of EO 13045;
0 When EO 13045 did apply, EPA rulemakers completed children's health risk-based
analyses and incorporated the results into the regulatory actions;
D EPAachieved a significant milestone in responding to the National Agenda through the
publication of the 1999 Strategy'for Research on Environmental Risks to Children;
D EPA has devoted significant resources to funding for scientific research on children's
health, prior to the publication of the formal strategy, with a particularly large influx of
resources when the Centers for Excellence were initially funded in 1998;
D EPA has published two reports on America's Children and the Environment, which
present the most current quantitative information available on trends in levels of
environmental contaminants in air, water, food, and soil; concentrations of
contaminants measured in the bodies of children and women; and childhood illnesses
that may be influenced by exposure to environmental contaminants;
D A sharp rise in the number of children's health related publications in the National
Environmental Publications Internet Site (NEPIS) and a rise in the proportion of
NEPIS publications related to children's health occurred in 1998 with a gradual
decrease detected thereafter,
D EPA environmental education grant amounts awarded to projects dealing with
children's health, as well as the proportion of children's health grant amounts,
increased between 1997 and 1998, witha decline and leveling off between 1999 and
2001;
D EPA has been successful in providing information to health care professionals
regarding environmental health threats to children;
D For fiscal years 1999 - 2003 the data show an approximately two-fold increase in
Evaluation of Children's Health Protection
September 19, 2003
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both the proportion and the total amount of money committed ($32,419, 900 to
$67,580,100) from EPA's total budget ($7.6 billion) dedicated to children's health
between 1999 and 2000. After 2000, Hie proportion of the total budget dedicated to
children's health remains relatively steady.
D Using the Risk-Screening Environmentallndicators model(RSEI)to evaluate potential
outcomes, the risk index (comprising toxicrty, exposure, and population
considerations) for chemicals that disproportionately affect children has decreased
over the modeled time period (1988 -1999).
STRUCTURE OF ANALYSIS
Based on a review of existing reports and assessments as well as a series of interviews with key
EPA officials (see Appendix A for detailed methodology discussion), OCHP identified five major
categories of analysis around which to organize the review. Exhibit 1 shows the five categories, how they
relate to the agenda items, and Hie quantitative and qualitative measures chosen to report on progress of
each. These measures are not a comprehensive accounting of all EPA activities related to children's health.
Rather, they provide an indication of EPA's progress in addressing these issues.
EXHIBIT 1
ORGANIZATION OF ANALYSIS
Category of
Analysis
Regulatory
Program
Review
Research and
Science
Policy
Outreach
National
Agenda Item
Analysis of EPA Rulemakings
Evaluation of Major Regulatory
Impact Analyses
Interviews with EPA Rulewriters
Research
Cumulative and Simultaneous
Exposure Policy
Public
Environmental Education Grants
Quantitative
Measure(s)
Compliance with EO 1304S
Extramural research through
the Science To Achieve
Results (STAR) Program
Agency outreach
publications
Environmental education
grants
Qualitative
Measures)
Summary of children's health
impacts in major regulatory
impact analysis
Results of interviews with EPA
Rulewriters
Summary and overview of major
accomplishments and current
progress
Evaluation of Children's Health Protection
September 19, 2003
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EXHIBIT 1
ORGANIZATION OF ANALYSIS
Category of
Analysis
Budgetary
Analysis
Overall
Children's
Health Status
National
Agenda Item
Health Care Providers
Community Right-to-Know
Funding
Quantitative
Measures)
Agency budget devoted to
children's health
Trends in children' s
exposures/risks from
environmental factors
Qualitative
Measure(s)
Summary and overview of major
accomplishments and current
progress
Summary and overview of special
initiatives under Emergency
Planning and Community Right-
to-Know Act (EPCRA)/Toxic
Release Inventory (TRI) related
to children's health
ORGANIZATION OF THE REPORT
The following sections of the report discuss each category of analysis, presenting the data collected
and the specific metrics used to track both qualitative and quantitative progress. The last section of the
report presents conclusions and recommendations for additional steps that could improve the Agency's
understanding of how well it is addressing children's health issues.
Evaluation of Children's Health Protection
September 19, 2003
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REGULATORY PROGRAM REVIEW
To assess the responsiveness of the EPA's regulatory program to the potentially higher risks faced
by children, the analysis focused on 1he Agency's formal considerations of children's health risks in the
Federal Register3. This quantitative analysis was augmented with a qualitative review of a subset of
relevant regulatory efforts and targeted interviews of EPA personnel to better understand how EPA
conducted evaluations of children's health and how EO 13045 affected these efforts.
ANALYSIS OF EPA RULEMAHNGS
Background and Methods
The analysis first identified the number of EPA rulemaking actions (rules and proposed rules) that
met the criteria for EO 13045, from April 1998 (the date when requirements under EO 13045 went into
effect) through My 2002. This Order requires that all federal agencies evaluate health and safety risks to
children and consider the effects of rulemaking actions on children for rules that are determined to be
health- or safety-based, economically significant under EO 12866,4 and that may pose a disproportionate
impact to children. In addition, the analysis examined the degree to which rulemaking actions included
consideration of children's health concerns, even if the actions did not meet the specific criteria for EO
13045.
The analysis focused oh the following quantitative metrics of performance:
Regulatory actions by regulatory area (Exhibit 2);
Health- or safety-based actions by regulatory area (Exhibit 3);
Number of actions that meet criteria for EO 13045 (Exhibit 4); and
Percentage of health-based actions that discuss EO 13045 or include an evaluation of
the impact on children (Exhibit 5).
Results
BetweenApril 1998 and July 2002,4,825 EPAregulatory actions were published in ^Federal
Register. Exhibit 2 sorts these actions out by regulatory topic area. Sixty-five percent of the rules are air-
3 This effort extends a previous OCHP analysis, "Analysis of EPA Implementation of Executive
Order 13045," September 30, 2001.
4 Viewed at http://www.archives.gov/federal_register/executive orders/pdf/12866.pdf
Evaluation of Children's Health Protection 5 September 19.2003
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related while pesticide and waste-related actions each account for roughly 14 percent of the total regulatory
actions.
EXHIBITS
REGULATORY ACTIONS BY REGULATORY AREA
Regulatory Topic Area
Air
Pesticides
Waste
Water
Toxics
Other
TOTAL
Total Number of Actions
3,133
660
652
252
112
16
4,825
Percent of All Actions
65%
14%
14%
5%
2%
<1%
100%
Source: EPA's Federal Register Website, www.epa.gov/fedrgstr
Of the 4,825 actions published, only 25 percent, or 1,180 rules, were determined to be health-
or safety-based. The analysis relied on EPA's Rule Writer's Guide to Executive Order 13045 to guide
tiiis characterization5. While the guidance does not provide a specific definition ofhealth- or safety-based
rules, it does note that rules based on technology performance, sampling methodologies or test procedures,
ecological standards not based on human health, rules implementing specific standards specified in statutes,
and individual State program approval decisions are not considered health- or safety-based. Exhibit 3
presents the breakdown ofhealth- or safety-based regulatory actions by regulatory area
Sixty-five percent of the regulatory actions identified in the Federal Register over the analysis
period are air-related, yet according to Exhibits, only seven percent (226 out of3,133) ofthese air-related
actions are considered health- or safety-based. On the other hand, nearly 80 percent (527 out of 660) of
pesticide actions are categorized as health- or safety-based, representingnearly half of all health- or safety-
based actions identified. The total number of waste-related regulatory actions was nearly equivalent to the
number of pesticide-related actons (652 compared to 660), however, onfy 47 percent of the waste-related
actions are health- or safety-based. Water, toxic, and other related regulatory actions made up
approximately eight percent of the total number of actions considered in the analysis and ten percent of die
total number ofhealth- and safety-based actions.
5 "EPA's Rule Writer's Guide to Executive Order 13045, Guidance for Considering Risks to
Children During the Establishment of Public Health-Based and Risk-Based Standards." Office of Policy,
Regulatory Management Division. October 1998. Page 6.
Evaluation of Children's Health Protection 6 September 19,2003
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EXHIBIT 3
HEALTH OR SAFETY BASED ACTIONS BY REGULATORY AREA
Regulatory Topic Area
Air
Pesticides
Waste
Water
Toxics
Other
Total
Total Number of
Actions
3,133
660
652
252
112
16
4,825
Number of Health or
Safety Based Actions
226
527
305
73
49
0
1,UO
Percent Health or Safety
Based Actions
7%
80%
47%
29%
* 44%
0%
25%
Source: EPA.'s Federal Register Website. www.epa.Rov/fedrRstr.
In reviewing these results it is important to rememberthat state actions are not, for purposes ofthis
review, defined as health- or safety-based. Accordingly, 1,832, or 58 percent, of the air-related actions,
which are related to State Implementation Plans and 173, or 27 percent, of the waste regulations, which
are concerned with state hazardous waste programs, were deemed not based on health or safely issues.
EO 13045 is only applicable to those health- or safety-based actions that are economically
significant as defined by EO 12866 and to those actions where rulewriters indicated the regulatory action
may have a disproportionate impact on children's health As Exhibit 4 shows, of the 1,180 health or safely
based actions, 27 are economically significant and 55 have a disproportionate impact on children Sixteen
regulatory actions meet all four criteria for EO 13045. Each of these includes a discussion of EO 13045
and an evaluation ofthe impact on children's health. These sixteen actions are discussed in more detail in
a later section of this report entitled "Critical Evaluation of Major Regulatory Impact Analyses" and in
Appendix B.
Evaluation of Children's Health Protection
September 19, 2003
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OCF. 9.2DD3 4:
ST
HEALTH OR SAFEfV BASED ACTIONS
THAT ARE EC0NQ3SICAU.V «GMnCA»T OR
HAVE A IHSPfcOaOier lOKATKIBSPACr OS CfBUXREN
BO 13045, regardless of -whether the acfieo soeets the BMBHising criteria for BO 13045.* Of the
1,180 health m safety baaed actions examined, 934, or 79 jwacent, discussed or m3detefe»mce to
BD 13041 As Exhibit 5 shows, the analysis revealed that nearly 100 percent of bsal&- or safety
based pesticide acd toxics niks dlsctm EO 13045 ami neady 85 pciceat of relevant air and wslcx
a <8$ca$siofl. A sigmfjcaatiiy $raaller portion of health- « safety-based waste
by th» inclusion of aU acdon* tel»te4 to the National Oil and Hazardous St&aaaees
Crailin^cyPlM,NatiotiME«OTtic*y«t(^L)ashedth.or3^e^-b»sMs^dai^.Tl^
S»JEL actions in this category, which account for 73 percent of afl health- or safety-based waste
actions; fewofihesei«clude&
-------
EXHIBITS
PERCENTAGE OF HEALTH OR SAFETY BASED ACTIONS INCLUDING
DISCUSSIONS OF EO 13045 AND EVALUATIONS OF CHILDREN'S HEALTH
100%
H Actions Discussing EO 13045
a Actions Conducting Evaluations of Children's Health
Pesticides
Toxics
Water
Regulatory Ana
Waste
A total of 158 health- or safety-based actions, representing over 13 percent, include an evaluation
of the impacts on children Over 20 percent of health- or safety-based toxics and water rules include such
an evaluation. Evaluations were conducted in over 10 percent of both pesticide and air rules based on
health or safety. As with the discussions of EO 13045, evaluations are included in a smaller percentage
of the health- or safety-based waste actions, but the percentage increases if NPL actions are not
categorized as health- or safety-based. In addition, the analysis did not uncover any specific instances of
rules that failed to include an evaluation of children's health when such an evaluation was required
CRITICAL EVALUATION OF MAJOR REGULATORY IMPACT ANALYSES
Background and Methods
EPA reviewed in more detail the 16 regulatory actions that met Ihe four EO 13045 applicability
criteria For purposes of this analysis, proposed and final regulatory actions were combined, yielding a total
of 11 distinct regulations. The regulatory impact analyses (RIAs) conducted as part of these actions were
Evaluation of Children's Health Protection
September 19, 2003
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assessed to determine the following:
D How did the considerationofchildrenchange the analyses (e.g., was a lower reference
dose used?) and/or how would the RIA results differ in the absence of special
consideration of children's health risk?
D Did the regulatory action consider children as the most sensitive subpopulation or did
the action consider a more sensitive subpopulation?
Results
Appendix B includes detailed summaries of these rules and Exhibit 6 below includes a brief
description of each of the eleven distinct rules.
EXHIBIT 6
SUMMARY OF CHILDREN'S HEALTH IMPACTS DISCUSSED IN MAJOR REGULATORY IMPACT
ANALYSES
Regulation
Control of Air Pollution from New Motor Vehicles: Tier
2 Motor Vehicle Emissions Standards and Gasoline
Sulfur Control Requirements (1999)
Control of Emissions of Air Pollution from Highway
Heavy-Duty Engines (2000)
The Proposed Ground Water Rule (2000)
Final Rule to Modify Reporting of Persistent
Bioaccumulative Toxic Chemicals Under EPCRA
Section 313 (1999)
Impacts on Children
The reduction of NOx, paniculate matter, and other
pollutants will result in an estimated 7,900 fewer cases
of acute bronchitis, 87,200 fewer cases of lower
respiratory symptoms, and 86,600 fewer cases of upper
respiratory symptoms in asthmatic children.
The regulation will result in reduced ozone emissions,
associated with harmful respiratory effects, that most
severely affect people with compromised respiratory
systems, children, and outdoor workers.
The occurrence of illness due to waterborne pathogens
is significantly higher in children than adults.
Estimates indicate that this proposed rule will result in
26,566 fewer viral illnesses per year in children under 16
years old.
Studies have demonstrated that children and fetuses
are at the greatest risk to Persistent and
Bioaccumulative Toxic (PBT) exposure. By adding
chemicals and/or lowering the reporting thresholds for
certain PBT chemicals on the Toxics Reporting
Inventory (TRI), the regulation enables citizens to
access chemical release data and allows them to make
better decisions in lowering their exposure to chemicals
in their community.
Evaluation of Children's Health Protection
10
September 19, 2003
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EXHIBIT 6
SUMMARY OF CHILDREN'S HEALTH IMPACTS DISCUSSED IN MAJOR REGULATORY IMPACT
ANALYSES
Regulation
Final Rule to Modify Reporting of Lead and Lead
Compounds Under EPCRA Section 313 (2000)
Heavy-Duty Engine and Vehicle Standards and
Highway Diesel Fuel Sulfur Control Requirements
(2000)
The Radionuclides National Primary Drinking Water
Regulations, Final Report (2000)
The Proposed Metal Products and Machinery Rule
(2000)
The Proposed Revisions to the National Pollutant
Discharge Elimination System Regulations and the
Effluent Guidelines for Concentrated Animal Feeding
Operations (2001)
Toxic Substances Control Act Section 403: Lead-Based
Paint Hazard Standards (2000)
Air Quality Index Reporting (1998)
Impacts on Children
By lowering the reporting thresholds for lead, a PBT
chemical, the public will have increased access to
chemical release data that may assist them in
decreasing their (and their children's) exposure to lead
and lead compounds, to which children are at greatest
risk.
This national program will reduce the adverse health
effects associated with air pollution (e.g. asthma in
children) by providing more stringent rules for diesel
engines, thus reducing emissions of ozone precursors.
In setting these levels, the lifetime radiogenic cancer
risks associated with the current and final maximum
contaminant levels (MCLs) were evaluated based on
age-specific and organ-specific cancer risk models that
explicitly consider children's higher per unit dose risks.
The benefits of reducing lead levels in fish tissue and
drinking water in this regulation were calculated on a
dose-response basis. This method accounted for the
susceptibility of children who are exposed to lead
during development. 'This analysis considered several
measures of children's heath benefits from reduced
lead exposure up to the age of six years.
This study evaluated the environmental health or
safety effects of pollutants from concentrated animal
feeding operations (CAFOs) on children.
This analysis focuses almost exclusively on assessing
the exposure and risk of lead hazards to young
children. The standards were selected and designed to
protect children from lead in residential paint, dust, and
soil.
The proposed Pollutant Standard Index (PSI)
categories take into consideration the increased health
risk to children that may result from exposure to ozone.
Each ofthese actions complied withEO 13045 by discussing Ihe specific impacts on children. For
example, the Tier 2 Motor Vehicle Emissions Standards rule recognized that the regulated pollutants are
believed to have a disproportionate effect on children. The Proposed Ground Water Rule noted that the
action will likely result in 25,566 fewer viral illnesses in children. In some instances the role of children
dominates the risk analysis, as in the Heavy-Duty Engine and Vehicle Standards Requirements, whichnote
Evaluation of Children's Health Protection
11
September 19, 2003
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that "although adults, children and even plants are subject to the negative effects associated with ozone
exposure, children are especially susceptible."
In some cases, the analyses explicitly considered the risks to children and set standards in order
to protect children. For example, in the Economic Analysis of Radionuclides National Primary Drinking
Water Regulations, the Agency set Maximum Contaminant Levels using riskmodels that explicitly consider
children's higher risk per unit dose. In the Toxic Substances Control Act (TSCA) Lead-based Standards
Rule, the impact analysis focused exclusively on assessing the risk to young children. The Economic and
Benefit Analysis of the Proposed Metal Products and Machinery Rule contained an assessment
methodology that specifically accounted for the susceptibility of children who are exposed to lead during
development Because of data gaps, some rules, such as the Rule on Effluent Guidelines for Concentrated
Animal Feeding Operations (CAFOs), were unable to set standards directly related to the impact on
children. Despite this, for those rules that meet the criteria of EO 13045, it is clear that EPA rulemakers
are taking children's health concerns seriously by incorporating results of analyses appropriately into
regulatory actions.
INTERVIEW WITH EPA RULEWRITEIIS
Background and Methods
In order to supplement Ihe information gathered from the review of RIAs, the analysis included a
series of interviews with EPA rulewriters. The interviews sought additional information about how the
Executive Order was applied and what impact it had upon the methodology or content of the children's
health analysis. The list of potential interviewees included the EPA staff listed as the contacts for the rules
that met all of Ihe EO 13045 criteria, and contacts for four other rules that met all ofthe EO 13045 criteria
except for the potential for disproportionate impact on children. These four rules contained evaluations of
children's health eventhough they were not formally subjectto EO 13045. Of these potential interviewees,
14 were identified as final candidates for interviews. The interviews focused on determining how EPA
conducted the evaluation, how the evaluation affected the final rule, and the role played by EO 13045.
In a separate effort, fifteen7 rulewriters received email questionnaires, asking:
D whether EO 13045 influenced the decision to conduct an evaluation of children's
health; and
D whether EO 13045, or any guidance associated with it, influenced the methodology
or content of the children's health evaluation.
The analysis randomly identified fifteen rulewriters who had conducted an evaluation of children's health
issues, for inclusion in the email survey.
Evaluation of Children's Health Protection
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September 19, 2003
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Results
At the time this analysis was completed, only eight of ihe 14 EPA staff have scheduled and
conducted interviews. Similarly, only three of the 15 rule writers contacted by email have responded. This
response rate notwithstanding, a few key points emerge from the effort. Respondents indicate that EO
13045 had little influence on the decision to conduct an evaluation or on Ihe assessment itself. In those
actions that met the criteria for EO 13045, rulemakers stated that they would have conducted an evaluation
ofchildnai'shealthregardless ofEO 13045, either because of an existing statutory requirement or because
safety factors to protect sensitive populations were included in the risk assessments. One rulewriter also
noted that while the guidance documents for EO 13045 were too general to guide modeling or technical
aspects of the evaluation, they did affect the types of information that were collected and how they were
presented in the Federal Register.
SUMMARY OF FINDINGS ON REGULATORY PROGRAM REVIEW
The analysis of EPA's regulatory programs revealed that EO 13045 is applicable in only a very
small number of the regulatory actions promulgated. However, a high percentage of health-based
rulemakings are considering EO 13045 and a substantial number of rules include evaluations of children's
health, even when not required by EO 13045: The examination of the Federal Register notices did not
reveal any cases of rules that failed to consider children's health when an evaluation was required
The analysis of relevant RIAs and interviews with EPA rulewriters support the findings from the
Federal Register review. EO 13045 did not have a substantial impact on whether or how an evaluation
of children's health was conducted, since existing requirements or provisions to address sensitive
populations generally compelled the rule writers to consider the potential impacts on children.
Evalaatian of'Children's Health Protection 13 September 19,2003
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RESEARCH AND SCIENCE POLICY
EPA has already achieved the National Agenda goal, "develop a scientific research strategy
focused on the gaps in knowledge regarding child-specific susceptibility and exposure to environmental
pollutants," with the publication of 1he 1999 EPA Strategy for Research on Environmental Risks to
Children* The Strategy outlines multiple objectives, children's risk topics, research questions, and
research priorities that are to be addressed in research plans developed by EPA. OCHP was one of
several EPA offices to assist the Office of Research and Development (ORD) in developing the Strategy
for achieving certain desired outcomes and outputs. Ibis section of the analysis measures implementation
of Ihe Strategy.
RESEARCH
Background and Methods
Ihe National Center forEhvironmentalResearch's (NCER's) ScienceTo Achieve Results (STAR)
program provides research grants and graduate fellowships in numerous environmental science and
engineering disciplines. The programrunds research fromlhe nation's top scientists, focusing on the health
effects of paniculate matter, drinking water, water quality, global change, ecosystem assessment and
restoration, human health risk assessment, endocrine disrupting chemicals, pollution prevention and new
technologies, children's health, and socio-economics. Furthermore, in 1998, EPA, in conjunction with the
National Institute of Environmental Health Sciences (NIEHS) and the Center for Disease Control (CDC),
established eight Centers of Excellence in Children's Environmental Health and Disease Prevention
Research. In 2001, four additional Centers were established. These Centers conduct basic and applied
researchand preventionefforts, the aim of which is a better understanding of the causes of environmentally-
induced disease among children.
This analysis evaluated extramural projects pertaining to children's health, using NCER's STAR
Project Database. This database contains information on the STAR program, including those projects
funded under the Centers of Excellence.
To measure the extent to whichEPAhas promoted efforts to develop a scientific research strategy
focused on children's environmentalheal1h,1heMowingmetricswerequantifie4usingthe STAR database:
STAR children's healthprojects as a percentage of total STAR projects started each
year,
STAR children's health award amounts as a percentage of total STAR award
amounts given out each year; and
Viewed at http://www.epa.gov/nceawwwl/risk2kids.htm.
Evaluation of Children's Health Protection 14 September 19,2003
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Centers for Excellence award amounts as apercentage oftotal STAR award amounts
given out each year.
Results
Exhibits 7,8, and 9 present the results of Ihe review of the STAR database. Exhibit 7 presents
the number of children's health STAR projects over the period 1993-2001, as well as the proportion of
all STAR projects that children's health projects comprise. Exhibit 8 summarizes STAR children's health
award amounts given out each year. The bars inlhis exhibit showthe amount of funding for (1) Center for
Excellence projects, (2) other STAR projects and (3) the sum of these. The Centers for Excellence fund
multiple-year projects, and it is important to note that this exhibit presents the funding as being issued in a
lump sum in the first year, rattier than armualized over the term of the project. For example, the peak in
funding and numbers of projects that occurs in 1998 (Exhibits 7 and 8) coincides with the establishment
of the Centers for Excellence in Children's Environmental Health and Disease Prevention Research. The
subsequent decline in 1999 and 2000 reflects that many ofthe Centers projects awarded in 1998 were for
three year periods. The increase in 2001 is most likely due to the renewal of some of the 1998 Center
projects and the establishment ofthe four additional Centers of Excellence.
EXHIBIT 7
NUMBER AND PERCENT OF CHILDREN'S HEALTH STAR PROJECTS
1993-2001
**"* rJumbtf of CMdrait HuHi STAR
Proltctt
Evaluation of Children's Health Protection
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September 19, 2003
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EXHIBIT 8
TOTAL CHILDREN'S HEALTH STAR FUNDING AND CENTERS FOR
EXCELLENCE FUNDING
ten
a Center* tor Exc«l«nc» Awird Amounts
otlur CMdranl Hu«h STAR Awvd Amount
2000 2001
Exhibit 9 displays 1he total dollar funding of STAR children's health projects as a percentage of
overall STAR project funding. This exhibit shows that in 1998, the children's health projects accounted
for more than 50 percent of overall STAR-funded prqj ects, indollarterms, although they made up less than
15 percent of the total number of projects (as shown in Exhibit 7).
Evaluation of Children's Health Protection
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EXHIBIT 9
CHILDREN'S HEALTH STAR FUNDING AS A PERCENTAGE OF TOTAL FUNDING
»I20
$100
tiO
ChHdren'i Hnldi STAR Funding
-CWI»«Ti H«utn STAR Funding 11 > P.rcenl
ol Total
1BB7
V»«r
1MB
2000
CUMULATIVE AND SIMULTANEOUS EXPOSURE POLICY
Background and Methods
To support analysis in the consideration of children's health and environmental exposures, EPA
has been developing a number of analytical tools, policies, references and guidance documents that address
issues critical to evaluating impacts on children's health. This analysis presents a qualitative discussion of
EPA's recent efforts to address cumulative and simultaneous exposures faced by children. It includes an
overview of major accomplishments and current progress of these Agency efforts, and a count of internal
agency children's exposure projects over the last six years, as recorded in EPA's National Center for
Environmental Assessment (NCEA) Science Inventory database.
Results
Appendix C contains a summary of the key projects recently completed or currently underway at
EPA that are directly related or support exposure assessment for cumulative/simultaneous exposures.
Exhibit 10 below presents a brief description of these activities.
Evaluation of Children's Health Protection
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September 19, 2003
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EXHIBIT 10
CUMULATIVE AND SIMULTANEOUS EXPOSURE:
OVERVIEW OF MAJOR ACCOMPLISHMENTS AND CURRENT PROGRESS
Project
Child-Specific
Exposure Factors
Handbook
Cumulative Risks of
Pesticides
Cumulative Exposure
Project
Draft Framework for
Cumulative Risk
Assessment
Industrial Surface
Impoundment Study
Regional Activities
Office
National
Center for
Environmental
Assessment
(NCEA)
Office of
Pollution
Prevention and
Toxics
(OPPTS)
Office of
Policy,
Economics and
Innovation
(OPEI)
NCEA
Office of Solid
Waste (OSW)
Regions 3, 5, 6
Summary
Consolidates all children's health-
related exposure data into one
document.
Cumulative risk assessment of a group
of pesticides (organophosphates) that
accounts for variability in potential
exposures based on age and other
factors.
Uses existing data and methods to
evaluate combined exposures to
multiple pollutants through multiple
pathways: food, water, air. Breaks out
results by demographic groups.
Offers a simple, flexible structure for
conducting and evaluating cumulative
risk assessment, which serves as a
foundation for development of future
guidelines. In the short term, it
provides a basic structure and starting
principles for EPA's cumulative risk
assessments. In the longer term, the
report offers the basic principles
around which to organize a more
definitive set of guidance for
Cumulative Risk Assessment
Cumulative risk of surface
impoundments studied by looking at
co-occurrence of chemicals in the
waste water.
Varying studies on effects of urban
environmental stressors on asthma,
blood lead; long term concerns for
neighborhoods adjacent to industrial
facilities; GIS as tool for planning and
scoping cumulative risk.
Relevance to Children's
Health
Clearinghouse for children's
health information; aids
efforts to better
understand/assess
exposures to children when
conducting risk
assessments.
Considers Food Quality
Protection Act safety
factors for protecting
sensitive populations,
including infants and
children.
Focus on identifying
pollutants and sources with
the greatest impact on
specific demographic
groups, one of which is
children.
Implications for all risk
assessment work, including
risks to children.
Potential implications for
children's health.
Potential implications for
children's health.
Evaluation of Children's Health Protection
18
September 19, 2003
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EXHIBIT 10
CUMULATIVE AND SIMULTANEOUS EXPOSURE:
OVERVIEW OF MAJOR ACCOMPLISHMENTS AND CURRENT PROGRESS
Project
Integrated Urban Air
Toxics Strategy
Total Risk Integrated
Methodology
Draft Reassessment of
Dioxin and Related
Compounds
Office
Office of Air
and Radiation
(OAR)
OAR
NCEA
Summary
Cumulative risks of exposure to
Hazardous Air Pollutants (HAPs) from
aggregate sources; performed at
neighborhood and national scale.
Neighborhood-scale risk assessment
of HAPs and criteria air pollutants.
Reassessment of dioxin toxicity,
background exposure/body burden,
and methods for assessing incremental
exposure/body burden.
Relevance to Children's
Health
Potential implications for
children's health.
Potential implications for
children's health.
Fetuses, infants, and
children are more sensitive
to dioxin than the general
population; breast milk may
be a significant source of
dioxin exposure for nursing
infants.
A number of projects are dedicated to cumulative/siinultaneous exposure, many of which will
contribute to the broader body of knowledge regarding risk assessment in general. Four projects (Child-
Specific Exposure Factors Handbook, Cumulalive Risks ofPesticides, Cumulative Exposure Project, Draft
Reassessment of Dioxin and Related Compounds) explidHy consider children's exposure and healthissues.
The first of these is a compilation of pertinent information related to children's healthrisk; ihe final three are
actual risk assessments for various contaminants of concern for children.
Exhibit 11 depicts the number of NCEA research activities related to children's exposure since
1997, the year form whichNCEA publications are included on the website. These data do not suggest an
immediate reaction to the National Agenda or EO 13045. In fact, year 2002 research activities have
decreased from 1997 levels.
Evaluation of Child-en's Health Protection
19
September 19, 2003
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EXHIBIT 11
NUMBER OF CHILDREN'S HEALTH CUMULATIVE
EXPOSURE NCEA RESEARCH ACTIVITIES
1997
1998
1999
2000
2001
2002
Year
SUMMARY OF FINDINGS ON RESEARCH AND SCIENCE POLICY
The analysis indicates that EPA increased the amount and percentage of STAR research funding
related to children's concerns from 1995 through 1999, with a decrease in 2000 and a slight increase again
in 2001. EPA's participation in 1he STARprogramindicates an apparent reaction to the National Agenda
and EO13045. However, the short time period represented warrants continued monitoring to assess more
meaningful, long-term trends. In addition, EPA has developed a number of important tools and research
projects that expands the base of knowledge in the area of human health risk assessment, while targeting
gaps in cumulative/simultaneous exposure of children to environmental pollutants.
Evaluation ofCUldren 's Health Protection
20
September 19, 2003
-------
OUTREACH
This section describes and assesses EPA's progress in creating and dissenmating children's health
outreach to key sectors: parents, teachers, caretakers, and health care providers. A series of qualitative
and quantitative metrics were employed to assess EPA progress in four areas, including 1) information
available throughNEPIS; 2) funding disbursed to the EnvironmentalEducationgrants program; 3) materials
and activities aimed at children's health care providers; and 4) initiatives related to community right-to-
know.
PUBLIC OUTREACH
Background and Methods
The National Agenda directs the EPA to provide information on children's health to parents,
teachers and others who interact frequently with children. Agency outreach publications on NEPIS served
as a quantitative measure to evaluate EPA's progress in outreach to parents, teachers, and other
caretakers. The NEPIS database contains over 9,500 full-text, online EPA publications, but is not
exhaustive. Non-print publications such as videos, posters, CD-ROMS, etc. are not included in this
database.
The analysis used information available on NEPIS from 1995 through 2001 to count EPA
publications related to children's health that were targeted at the caretaker audience9. Two tiers of search
criteria were used to identify outreach documents relevant to children's health. The Tier 1 set includes
publications with titles that include words relating to children's life stages and physical environment, and
caretaker audiences such as parents, teachers and health care professionals. The Tier 2 set includes
publications with titles that include words relating to environmental problems known to have a
disproportionate impact on children, such as mercury, lead, radon, and secondhand smoke10. The number
and the percentage of publications withtitles relating to these two Tiers contained in NEPIS per year serve
as metrics for public outreach.
Results
Titles of EPA outreach documents in NEPIS from 1995 to present were examined. The number
of titles relating to children's health peaked in 1998 for both Tier 1 and Tier 2 search criteria (Exhibit 12).
The Tier 2 category fluctuates between 1995 and 1997, while the number of Tier 1 titles remains nearly
constant The number of titles relating to children's health in both categories increase substantially in 1998,
n
1995 was chosen as a logical starting point because that was the year in which EPA Administrator Browner
announced a national policy to address children's health.
10The full list of these search terms can be found in ICF's September 29,2001 memorandum to the OCHP.
Evaluation of Children's Health Protection 21 September 19,2003
-------
and then decrease gradually in subsequent years. . When the two tiers are aggregated, and duplicates
removed, die same peaking trend is observed (Exhibit 13). The number of children's health publications
increased slighfly from 1999 to 2000, though still less than the number in 1998. Children's health
publications represent a higher percentage of total NEPIS publications in 2000 than in 1998 due to a
decrease in total NEPIS publications between those years.
EXHIBIT 12
NUMBER OF CHILDREN'S HEALTH OUTREACH TITLES IN NEPIS
1995
2000
2001
Evaluation of Children's Health Protection
22
September 19, 2003
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EXHIBIT 13
CHILDREN'S HEALTH TOPICS AS A PERCENTAGE
OF ALL EPA OUTREACH TITLES IN NEPIS
16
i,,
*
i-
c
4
J
= NunbOf ol CMIdrm'i HMlm OMroich TIIHl
-*-P«rc.nC or AH Tltlot Rllovml lo CMKion'l
H»tth
/
s
NUn iSS^
8!i§! |M
(%M %88£
m iPii
. .'..-.-.:-, . ,i<,-Kw.
/
1998 1991 1997
/
₯
m
-------
EXHIBIT 14
NUMBER OF CHILDREN'S HEALTH OUTREACH DOCUMENTS IN NEPIS BY
SUBJECT AND FOREIGN LANGUAGE AVAILABILITY
Foreign Language Availability
Spanish
Other
Total
8
6
14
ENVIRONMENTAL EDUCATION GRANTS
Background and Methods
The Environmental Education grant program, administered by the Office of Environmental
Education (OEE), provides another avenue for oulreachby EPA The OEE awards approximately two
to three million dollars annually for environmental education efforts. Grant award data from each state were
compiled for the years 1997 to 2001l1 and titles were screened for those relevant to educating the public
about environmental exposures/risks to children. The environmental education grants each year for
children's health issues, in terms of dollar value and percentage of total environmental education grant
funding, were used to measure public outreach.
Results
Exhibit 15 presents the number of environmental outreach grants provided. The number of grants
pertaining to children's health peaked in 1998, as did children's health grants as a percentage of total grant
funding by the OEE.
11 OEE was started in 1992, but it was not until 1997 that detailed information was available on projects and
grant amounts
Evaluation of Children's Health Protection
24
September 19, 2003
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EXHIBIT 15
CHILDREN'S HEALTH ENVIRONMENTAL EDUCATION GRANTS AS A PERCENTAGE OF
TOTAL ENVIRONMENTAL EDUCATION GRANTS
$800,000 T
$700,000
1997
T 25%
=523 Children's Health EE Grant Amounts
-«Grant Amount as a Percentage of Total EE Grants
2001
0%
INFORMATION FOR HEALTH CARE PROVIDERS
Background and Methods
The National Agenda includes a goal to "encourage and expand educational efforts withhealthcare
providers and environmental professionals so they can identify, prevent and reduce environmental health
threats to children." This analysis surveyed related EPA programs and initiatives to evaluate EPA efforts
to provide educational opportunities for health care and environmental professionals. Metrics are specific
to each project and are included when available. A qualitative summary and overview of some of the major
accomplishments and ongoing efforts by EPA is contained in Exhibit 16. Appendix D provides a more
detailed description of these efforts.
Evaluation ofChilcten 's Health Protection
25
September 19, 2003
-------
Results
Exhibit 16 shows that various offices wilhin the EPA have initiated a diverse group of programs
designed to increase awareness of children's environmentalhealthrisks in key professional sectors. Where
included, metrics speak to the successes of these initiatives in both educating and training health care
professionals.
EXHIBIT 16
SUMMARY OF EPA'S EFFORTS TO PROVIDE INFORMATION TO HEALTH CARE PROVIDERS
PROJECT
American Academy
of Pediatrics (AAP)
Handbook of
Pediatric
Environmental Health
AAP Chief Resident
Workshops
Continuing Education
Programs for Nurses
in Environmental
Health
OFFICE
Office of Children's
Health Protection
(OCHP), Office of
Research and
Development (ORD)
OCHP
OCHP
DESCRIPTION
Handbook includes summaries of
environmental health hazards to
children and guidance to
pediatricians for the prevention,
diagnosis, and treatment of
environmentally-related illnesses in
children.
Special education sessions of the
AAP for pediatric Chief Residents
to heighten awareness of pediatric
environmental health issues in
residency training programs.
Continuing education program for
nurses in environmental health,
developed by the American Nurses
Association and the University of
Maryland School of Nursing and
supported by OCHP.
OCHP also assisted in the
facilitation of preconference
workshops at the annual meetings
of the American College of Nurse
Midwives; the American Nurses
Association; the Association of
Women's Health, Obstetrics and
Neonatal Nursing; and the
American Public Health
Association (to be held Nov. 2002)
METRICS
027,000 handbooks
distributed to U.S.
pediatric residents
[593,209 funding from
OCHP (FY 1999)
QORD also provided a
financial contribution
120 Chief Residents
trained to date
40 Chief Residents
projected for 2003
2.6 million nurses
eligible to take
courses online - e.g.,
a sample, 370 nurses
registered for the
Environmentally
Healthy Schools
online module (Jan.
2002)
150,000 nurses
receiving a bi-
monthly newsletter
with three education
modules
Evaluation of Children's Health Protection
26
September 19, 2003
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EXHIBIT 16
SUMMARY OF EPA'S EFFORTS TO PROVIDE INFORMATION TO HEALTH CARE PROVIDERS
PROJECT
Pediatric
Environmental Health
Specially Units
(PEHSU)
Managing Asthma
Triggers: Keeping
Children Healthy
Secondhand Smoke
Prevention
Pesticides and
National Strategies
for Health Care
Providers
OFFICE
OCHP, EPA regions,
Office of Solid Waste
(OSW), Office of
Emergency and
Remedial Response
(OERR)
Office of Air and
Radiation (OAR) Indoor
Environments Division
OAR Indoor
Environments Division
Office of Pollution
Prevention and Toxics
(OPPTS)
DESCRIPTION
Network of PEHSUs, based at
academic centers, provide
education and consultation for
health care professionals about
children's environmental health
topics.
Asthma education training manual
developed by National Association
of School Nurses and EPA.
Developed a Secondhand Smoke
Speaker's Kit to provide
pediatricians with information and
assistance in informing, educating,
and sustaining public awareness
on the health effects associated
with children's exposure to
secondhand smoke.
Aimed at incorporating pesticide
information into the education and
practice of health care providers.
The goal is to improve the
recognition, diagnosis,
management, and prevention of
adverse health effects from
pesticide exposures.
METRICS
16,000 health care
providers trained by
PESHUsin2001
32,000 projected for
2002
- Over 3000 nurses
trained 2001 -2003
No metrics given;
project ongoing
No metrics given;
project ongoing
COMMUNITY RIGHT-TO-KNOW
Background and Methods
The Emergency Planning and Community Right-to-Know Act (EPCRA) was enacted in 1986 to
allowpublic access to information regarding chemical hazards in their communities. The National Agenda
re-emphasized the importance of EPCRA, directing EPA to "expand community right-to-know, allowing
families to make informed choices regarding environmental exposures to tiieir children." In addition to
providing general public information under EPCRA, EPA has also developed special programs and tools
directed specifically at analyzing and providing information on impacts of environmental exposures on
children.
Evaluation of Children's Health Protection
27
September 19, 2003
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Results
The Voluntary Children's Chemical Evaluation Project (VCCEP) has been implemented by ihe
EPA to collect and disseminate information on 1he environmental release of toxicants that are particularly
harmful to children.
VCCEP was implemented in 2000 to enable 1he public to understand the potential heahhrisks to
children associated with certain chemical exposures. Twenty-three chemicals are included in the project
because biomonitoring programs indicated 1heir presence as contaminants in human tissues and fluids
(blood, breath, breast milk, urine), the food and water children eat and drink, and the air children breathe.
EPA asked companies lhat manufacture and/or import these chemicals to volunteer to collect and/or
develop health effects and exposure information on each chemical, integrate that information in a risk
assessment, and assess to fully characterize the risks the chemical may pose to children.
The Risk-Screening Environmental Indicators (RSEI) model is a screening tool, developed by
EPA's Office of Pollution Prevention and Toxics, that combines release data with spatial, temporal and
demographic informational order to provide a more complete characterization of the risks, including risks
to children. RSEI is a computer-based screening tool for the evaluation of emissions and transfers of toxic
chemicals from industrial facilities that is used to assess the relative impacts of releases of toxic chemicals
by combining estimates of toxicily, exposure level, and Ihe exposed population. The RSEI model can
evaluate many of the risk-related chronic humanhealth effects associated toxic releases and can compare
risk-related results for facilities, chemicals, geographic areas, and time periods. Since RSEI facilitates
comparisons of the relative contribution of specific chemicals, industries, and exposure pathways to overall
risk, it allows for more sophisticated prioritization and strategic planning. RSEI provides a clearer picture
of the impact of toxic releases on sensitive groups such as. children, the elderly, and men and women of
reproductive age. Accordingly, RSEI can be used as a tool for parents and other caretakers to screen Ihe
hazards and risks to their children of emissions and transfers of toxic chemicals from industrial facilities
within their community.
SUMMARY OF FINDINGS ON OUTREACH
D EPA's children's health outreach publications in NEPIS peaked in number in 1998,
and have dropped off since that time, though it should be noted that children's health
outreach publications in NEPIS has increased in its proportional share of all NEPIS
outreach titles, compared to 1995 levels.
D Environmental education grant amounts awarded to projects pertaining to educating
the public about environmental exposure and risks to children's health also peaked in
1998.
Evaluation of Children's Health Protection
28
September 19, 2003
-------
0 The Agency continues to initiate and maintain programs aimed ateducatinghealthcare
professionals mchildren's environmental healthissues. While metrics are not available
for all the programs, available data indicate that these programs are well-focused and
meet their stated objective.
D EPAhasdevelopedspecialinitiativesonramniuni^'right-to-know, suchasVCCEP,
and RSEI, which aim to expand information available to the public so that families can
make informed choices regarding environmental exposures of their children.
It should be noted that these measures do not reflect all outreach activities performed by EPA
Information on distribution and efficacy of these measures, as well as information on other outreach
activities, would be necessary for a more complete assessment
Evaluation of Children's Health Protection 29 September 19,2003
-------
BUDGETARY ANALYSIS
FUNDING
Background and Methods
The National Agenda specifies that funding be allocated as is necessary to "address children's
environmentalhealthas a top priority amongrelative environmentalrisks." This analysis uses the proportion
of EPA's total budget devoted to children's health across years as a quantitative measure of the priority
of children's health issues. The analysis focused on the funding dedicated specifically to children's health
issues and did not include other components ofthe Agency's budget that impact children, such as research.
The data used contain dollar amounts dedicated to children's health funding for fiscal years 1999-2003
(amounts for 2003 are projected). While funds were dedicated to children's health before 1999, funding
for children's health was not reported separately until 1999.
Results
The data for fiscalyears 1999-2003 in Exhibit 17 show an approximately two-fold increase inthe
total dollar amount and proportion of EPA's total budget dedicated to children's health between 1999 and
2000. After 2000, the amount and proportion ofthe total budget dedicated to children's health remains
relatively steady.
Evaluation of Children's Health Protection 30 September 19,2003
-------
0.00%
1999
EXHIBIT 17
CHILDREN'S HEALTH BUDGET AS A
PERCENTAGE OF EPA'S BUDGET
2003
Year
1999
2000
2001
2002
2003
Children's Health Spending
$32,419,900
$67,580,100
$71,176,2000
$67,634,100
$62,390,100
Total EPA Budget
$7,600,000,000
$7,600,000,000
$7,900,000,000
$8,000,000,000
$7,700,000,000
Evaluation of Children's Health Protection
31
September 19, 2003
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TRACKING CHILDREN'S ENVIRONMENTAL HEALTH
The measures described in previous sections of 1his report help illustrate EPA's progress on
regulations, basic research and science policy, and outreach programs in support of EPA's mission to
improve children's environmental health. To complement these measures, the analysis also examined
measures of the desired outcome of these programs; that is, changes in children's exposures and health
status over time. While it is extremely difficult, ifnot impossible, to attribute specific changes in children's
exposures and health status to particular EPA efforts, analysis of children's health status can help
policymakers and other stakeholders identify and prioritize further EPA children's health initiatives.
EPA's Office of Policy, Economics and Innovation and OCHP have published two reports on
trends in environmental factors related to the health and well-being of children in the United States.
America's Children and the Environment: A First View of Available Measures was published in
December 2000, and America's Children and the Environment: Measures of Contaminants, Body
Burdens, and Illnesses was publishedinFebruary 2003 (available at www.epagov/envirohealthAMdren).
These reports bring together, in one place, the most current quantitative information available from
a variety of sources to show trends over time in levels of environmental contaminants in air, water, food,
and soil; concentrations of contaminants measured in the bodies of children and women; and childhood
illnesses that may be influenced by exposure to environmental contaminants. These measures help EPA
track and understand the potential impacts of environmental contaminants on children's health and,
ultimately, to identify and evaluate ways to minimize environmental impacts on children The measures will
also inform discussions among policymakers and the public about howto improve federal data on children
and the environment
The 2003 edition of the report finds that there is a continued decline in the number of children with
elevated blood lead levels, a reduction in children's exposure to second hand smoke, and decreases in
exposures to air pollution and contaminants in drinking water. However, the report also finds that there is
still much work to be done, as asthma rates are increasing, many children continue to have elevated blood
lead levels, the potential for mercury exposure in the womb is of growing concern, and there is a
disproportionate impact of childhood diseases on low-income and minority children.
Highlights of the findings of the 2003 report include:
Outdoor Air Pollutants
D In 1990, approximately 23 percent of childrenlived in counties in which the one-hour
ozone standard was exceeded on at least one day per year. In 2001, approximately
15 percent of children lived in such counties. This value fluctuated during the
intervening years, ranging from 13 to 28 percent
D In 1996-2001, significantly more children lived in counties that exceeded the eight-
hour ozone standard than in counties that exceeded the one-hour standard. In2001,
Evaluation of Children's Health Protection 32 September 19,2003
-------
nearly 40 percent of diildrenlivedin counties that exceeded the eight-hour standard.
D In 2000, approximately 27 percent of children lived in counties that exceeded the
PM-2.5 particulate matter standard. In 2001, approximately 25 percent of children
lived in such counties.
D The percentage of days that were designated as having "unhealthy" air quality
(including days that were unhealthy for everyone as well as those that were unhealthy
for sensitive groups) decreased between 1990 and 1999, dropping from 3 percent
in 1990 to less than 1 percent in 1999. The percentage of days with "moderate" air
quality remained around 20 percent between 1990 and 1999, although an upward
trend is suggested by the fact that the percentage of moderate air quality days was
higher in 1999 than for any other year in this analysis.
i
D In 2000, about 1 million children experienced an average PM-10 concentration
above the annual standard, down from about 2 million in 1990.
Indoor Air Pollutants
The percentage of homes with children under 7 in which someone smokes on a
regular basis decreased from 29 percent in 1994 to 19 percent inl 999.
Drinking Water Contaminants
The percentage of children served by public water systems that reported exceeding
a Maximum Contaminant Level or violated a treatment standard decreased from 20
percent in 1993 to 8 percent in 1999. Every category of violation decreased
between 1993 and 1999 except for nitrates and nitrites, which remained steady.
Pesticide Residues
From 1994 to 2001, the percentage of food samples with detectable
organophosphate pesticide residues ranged between 19 percent and 29 percent The
highest detection rates were observed during 1996 and 1997,while the lowest
detection rate was observed in 2001.
Concentrations of Lead in Blood
The median (5 0th percentile) concentration oflead in the blood of children 5 years old
and under dropped from 15 micrograms per deciliter (ng/dL) in 1976-1980 to 2.2
Hg/dL in 1999-2000, a decline of 85 percent.
Evaluation of Children's Health Protection 3 3 September 19, 2003
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D Concentrations of lead in children's blood differ by race/ethnicity and family income.
In 1999-2000, tire medianblood lead level in children ages 1-5 was 2.2 ng/dL. The
median blood lead level for childrenliving in families with incomes below Ihe poverty
level was 2.8 pg/dL and for children living in families above the poverty level it was
1.9 |ig/dL. For all income levels, Black non-Hispanic children had a median blood
lead level of 2.8 ng/dL. White non-Hispanic children had a median blood lead level
of 2.1 |ig/dL and Hispanic children had a median blood level of 2.0 |ig/dL.
D Approximately 430,000 children ages 1-5 (about 2 percent) had a blood lead level
of 10 ng/dL or greater in 1999-2000.
Concentrations of Mercury in Blood
EPA has determined that children bom to women with blood concentrations above
5.8 parts per billion are at some increased risk of adverse health effects. About 8
percent of women of child-bearing age had at least 5.8 parts per billion of mercury
in 1heir blood in 1999-2000.
Concentrations of Cotinine in Blood
Cotinine is a marker of exposure to environmental tobacco smoke. In 1999-2000,
median^O* percentile) levels of cotininemeasuredinchildrenwere56 percent lower
than they were in 1988-1991. Cotinine values at the 90th percentile, representing Ihe
mosthighly exposed 10 percent of children, declined by 18 percent between 1988-
91 and 1999-2000.
Respiratory Diseases
Between 1980 and 1995, the percentage of children withaslhma doubled, risingfrom
3.6 percent in 1980 to 7.5 percent in 1995. A decrease in tire percentage of children
with asthma occurred between 1995 and 1996, but interpreting single-year changes
is difficult
In 2001,8.7 percent (6.3 million) of all children had asthma.
The percentage of children wilh asthma differs by race/ethnicity and family income.
In 1997-2000, more than 8 percent of Black non-Hispanic children living in families
withincomes belowtiie poverty levelhad an asthma attack in the previous 12months.
Approximately 6 percent of White non-Hispanic children and 5 percent of Hispanic
children living in families wilh incomes below the poverty levelhad an asthma attack
in the previous 12 months.
Evaluation of Children's Health Protection 34 September 19,2003
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Emergency room visits for asthma and other respiratory causes were 369 per 10,000
children in 1992 and 379 per 10,000 children in 1999. Hospital admissions for
aslhma and other respiratory causes were 55 per 10,000 children in 1980 and 66 per
10,000 children in 1999.
Childhood Cancer
The frequency of new childhood cancer cases has been fairly stable since 1990. The
age-adjusted annual incidence of cancer in childrenincreased from 128 to 161 cases
per million children between 1975 and 1998. Cancer mortality decreased fromSl to
28 deaths per million children during the 1975-1998 period.
Leukemia was the most common cancer diagnosis for children from 1973-1998,
representing about 20 percent ofthe total childhood cancer cases. Incidence of acute
lymphoblastic leukemia was 24 cases per million in 1974-1978 and approximately
28 cases per million in 1994-1998. Incidence of acute myeloid leukemia was
approximately 5 cases per million in 1974-98 and about the same in 1994-98.
Neurodevelopmental Disorders
In 1997-2000, about 6 children out of every 1,000 (0.6 percent) were reported to
have been diagnosed with mental retardation.
Anolher measure of children's environmental exposures is information available from {be Toxics Release
Inventory (TRI). Exhibit 18 shows total pounds of chemicals released for the years 1988-199912, for the
lists of chemicals of special concern for children, in the VCCEP program as well as the Toxicity and
Exposure Assessment for Children's Health (TEACH) program, a Region 5 initiative. The list of chemicals
in the TEACH project were chosen through a literature search of childhood exposures to key
environmental contaminants and through consensus among risk assessors in various EPA Region 5 offices.
The VCCEP chemicals were chosen by EPA and industry as previously described. The RSEI model
provides a unitless metric that reflects the relative risk of each chemical based upon a weighted composite
of chemical toxicily, the fate and transport of the chemical in the environment after it is released, the
pathway ofhuman exposure, and the number of people (in this case, children) exposed. Exhibit 19 shows
the total RSEI risk index for TEACH/VCCEP chemicals combined, showing separate data for two age
groups of children. It is important to note that the RSEI risk indexforthe TEACH chemicals is significantly
greater (more than 20 times) than the index for the VCEEP chemicals.
12TRI reporting began in 1988
Evaluation of Children's Health Protection 35 September 19,2003
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Overall, whiletotal pounds ofTEACHchonicals emitted over the period increased, the risk-related
impacts to children, as estimated by RSEI, generally decreased over the time period of this analysis.
1000-
5 800-
i
| 600-
- Pounds
1 s
n~i
*
f
-
1966
TOTAL POt
a TEACH
"VCCEP
1969 199
EXHIBIT 18
JNDS OF TEACH AND VCEEP CHEMICALS RELEASED
) 1991 1992 1993 1994 1995 1996 1997 1996 1999
Ynr
Evaluation of Children's Health Protection
36
September 19, 2003
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8000.00
1000.00
0.00
EXHIBIT 19
RISK-RELATED RESULTS TO CHILDREN FROM
TEACH AND VCEEP CHEMICALS
B Children under 10 years
13 CNkfeit between 10 and 17 years old
1988 1989
1999
Evaluation ofCMdren 's Health Protection
37
September 19, 2003
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
CONCLUSIONS
Hie goal of this analysis was to characterize progress that EPA is making in considering and
addressing the environmental risks posed to children's health. As set out in the National Agenda to
Protect Children's Health, EPA works to specifically consider and respond to these threats in its
rulemaking activities. EPA also encourages research, education, and outreach activities to educate the
public about these risks and about appropriate steps to reduce them.
REGULATORY PROGRAM REVIEW
Hie results of the regulatory program review showed that onry a negligible number of rules (<1 %)
actually met all the criteria and triggered the provisions of EO 13045. The analysis found that
approximately 20 percent of all rules were health- and safety-based, about 1.2 percent were deemed to
have a disproportionate effect on children, and less than one percent were economically significant Based
on Hie informationincludedinlhe Federal Register, there were no cases where an evaluation of the special
impact on children should have been conducted, but was not. Sixty-three percent of the rules contained
a discussion of the relevance of EO 13045, although EO 13045 rarely applied. While the analysis found
that all regulations that were required to adhere to EO 13045 did so, this finding was based on Ihe
rulewriters own judgement that their regulations had a disproportionate impact on children. However, a
number of other regulations met three of the four criteria for EO13045 but asserted there was no
disproportionate impact on children.
Although EO 13045 rarely applied, nonetheless, EPA rulewriters conducted children's health
evaluations in nearly 12 percent of the health- or safety-based proposals. Rules that address pesticide
issues or relate to Ihe setting of air quality standards for criteria air pollutants are already required to include
a children's health evaluation.
In-depth evaluation of rules that triggered EO 13045, as well as interviews with key EPA contacts
involved in drafting these rules, confirmed that EPA rulewriters considered the impacts of their actions on
children, and incorporated results of Iheir analyses into the regulatory proposals. However, the review
team did not conduct a detailed analysis of the quality ofthe consideration gjvento children's healthissues.
Preliminary conclusions suggest that the evaluations of children's health rely upon a range of data and that
guidance written for EO 13045 has not been a major source of guidance for the children's health
evaluations. In addition, interviewees have generally noted that the same evaluation of children's health
would have been conducted even in the absence of EO 13045.
RESEARCH AND SCIENCE POLICY
EPA achieved a significant milestone in responding to the National Agenda through the publication
of the 1999 Strategy for Research on Environmental Risks to Children. Because the Strategy was
published as a final document in 2000, it may take some time to see how research funding responds to the
specific needs identified in Ihe Strategy. Nevertheless, ihis analysis found that EPA had already devoted
significant resources to funding scientific research on children's health, prior to the publication ofthe formal
Evaluation of Children's Health Protection
38
September 19, 2003
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44 Strategy, witha particularly large influx of resources whenlhe Centers for Excellence were initially funded
45 in 1998. TheanalysisalsofomdthatwWlethemulti-yearprojectsfuM
46 continued, 1he funding of new proj ects dropped off in 1999, 2000 and 2001. Nowthatthe Strategy has
47 been finalized, it wifl be worthtracking whetherthis pattern of punctuated, long-term funding continues, or
48 if funding accelerates, with more new projects funded each year.
49
5 0 Clearly, funding of extramural research does not capture the full breadth of research and analysis
51 that EPAhas undertaken to support the analysis of risks to children's health The projects summarized by
52 this report, including major achievements on methods for evaluating cumulative exposures in children, the
53 Children's Exposure Factors Handbook, and others, represent only a few of any number of efforts by
54 program offices to develop scientific approaches, performresearch and develop science policy to evaluate
55 children's health. A centralized and regularly updated database of intramural research would facilitate
56 future evaluations of EPA efforts to fill research gaps related to children's health.
57
58 OUTREACH
59
60 A sharp rise in the number of children's health related publications in NEPIS and a rise in the
61 proportion of NEPIS publications related to children's health occurred in 1998 with a gradual decrease
62 thereafter. One explanation could be that local communities may be taking on more of the responsibility for
63 publishing children's health-related outreach documents. EPA recognizes that local agencies may be more
64 effective in reaching members of a community; thus grants are often given to organizations that can provide
65 comnmty-specific outreach. The analysis ofNEPIS would not capture publications produced under these
66 grants.
67
68 Screening children's health publications in the NEPIS database is just one measure of EPA's
69 activities in outreach to the public regarding children's healthissues. The publications contained in NEPIS
70 contain only printed publications that have been scanned and converted into full-text electronic documents.
71 It is not a comprehensive database containing all of EPA's publications, nor does it contain materials
72 presented in media other than print such as videos, CDs, posters, or fliers. Information contained on EPA
73 webpages designed to provide outreach to the public is also not contained in the NEPIS database. In fact,
74 another possible explanation for the gradual decrease in children's health-related publications in NEPIS
75 could be the rise of the Internet as an increasingly available and efficient medium for information
76 dissemination to the public. Many of EPA's outreach activities to Hie public now include publishing
77 information and documents on the Internet, which would not be captured in the NEPIS database.
78
79 The use of environmental educational grants was another quantitative measure of EPA's activities
80 in outreach to the public regarding children's health issues. Environmental education grants are awarded
81 to projects that enhance the public's awareness, knowledge, and skills to make informed decisions that
82 affect environmental quality. Although not explicit in the focus and mission, health issues are often
83 addressed in these projects. The analysis revealed the grant amounts awarded to projects dealing with
84 children's health (and the proportion) peaked in 1998.
85
86 EPA has been successful in providing information to health care professionals regarding
Evaluation of Children's Health Protection 39 September 19,2003
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87
88
89
90
91
92
93
94
95
96
environmentalhealththreats to children. Further, the VCCEP special initiative demonstrates a collaborative
effort between EPA and private industry to provide 1he public more information regarding potential
environmental exposures, to children.
BUDGETARY ANALYSIS
EPA's budget shows an approximately two-fold increase in funding dedicated to children's health
between fiscal years 1999 and 2000, bolhin terms of total dollar value and as a proportion of EPA's total
budget. Since 2000, the proportion of the total budget dedicated to children's health has remained
relatively steady.
Evaluation of Children's Health Protection
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September 19, 2003
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97 NEXT STEPS
98
99 This analysis has demonstrated that EPA is making strong progress in integrating children's health
100 concerns into Iheir ongoing activities. To improve future evaluations and provide a more quantitative
101 assessment of progress, the review has identified a number of actions EPA could take. For example, EPA
102 could consider developing more sophisticated baselines and measures to more closely track additional
103 outputs and outcomes not addressed in this analysis.
104
105 To more thoroughly evaluate compliance with EO 13045, OCHP should conduct a more formal
106 assessment of the quality of children's health evaluations being completed by Agency rulemakers to
107 determine if children's health was throughly considered. It would be useful to conduct further analysis to
108 better understand how rulewriters determine whether the rule will have a disproportionate impact on
109 children. By looking at both cases where children were and were not thought to be disproportionately
110 affected, OCHP might be able to develop criteria that could be used by future rulewriters to make such
111 a determination.
112
113 OCHP could work with OPEI to explore incorporating a review of children's health risks as part
114 of the regulatory review process that is being implemented throughout EPA OCHP could periodically
115 review the Regulatory Agenda to identify upcoming regulations EPA will be promulgating that may impact
116 children's heallh. With this information, OCHP can work with the program offices to ensure that children's
117 health risks are more explicitly examined. OCHP could also make recommendations to the Assistant
118 Administrators to allocate resources in program office budgets specifically set aside to more adequately
119 address children's health risk in upcoming rulemakings.
Non-regulatory analysis categories have, by necessity, focused on programmatic outputs more than
on the effects of these efforts. For example, Ads study identified changes inlhe number of research studies
affecting children and Hie number of outreach documents published by EPA However, the analysis did
not examine the quality of these efforts or how successful they have been. These data are more difficult
and time consuming to collect, but EPA could consider beginning the long-term effort to gauge the quality
of the outcomes itis achieving as well as the steps it is taking to reach them. For example, directly tracking
the outputs and outcomes described in the 1999 EPA Strategy for Research on Environmental Risks
to Children may help assess implementation of the Strategy.
In order to obtain a more accurate picture of EPA's public outreach efforts regarding children's
health issues, one needs to look at additional measures that are quantifiable and can be tracked. A helpful
first step would be to track children's health outreach activities undertaken by different offices and compile
the informationinto a central database. This would not only provide better quantitative measures to more
accurately portray the full picture and scope of EPA's children's health outreach but could also increase
interoffice collaboration and sharing of various outreach approaches and successes. However, the true
impact and significance of certain activities cannot be adequately reflected quantitatively. In many instances,
qualitative descriptions of these activities can provide a more accurate reflection of the magnitude and
significance of EPA's efforts. The continuation and updating of the Children's Health Yearbooks would
be valuable in this regard. Additionally, giventhe migration of outreach efforts to Ihe Internet, OCHP could
Evaluation of Children's Health Protection 41 September 19,2003
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explore howto develop measures for Internet-based outreach where no apparent means of measurement
is currently available.
Evaluation of'Children's Health Protection 42
September 19, 2003
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Attachment 2
Summary of OCHP Accomplishments
Response to IG Report
Since its creation in 1997, the Office of Children's Health Protection (OCHP) has
been instrumental in coordinating the implementation of the National Agenda to Protect
Children's Health from Environmental Threats. OCHP has been very effective in
leveraging resources within the Agency and with external stakeholders to ensure that the
directives of the National Agenda are met. In addition, in 2002 OCHP was directed to
lead the EPA's Aging Initiative to protect the health of older adults. Since the official
launch of the Aging Initiative in October 2002, OCHP has drawn on ongoing efforts
throughout EPA to develop collaborative relationships with regional and program offices,
as well as external stakeholders.
OCHP's work falls into four areas: 1) regulations and standards, 2) science and
risk assessment, 3) outreach, public awareness, community based programs, and
education, and 4) Aging Initiative. OCHP has been instrumental in bringing children's
environmental health to the forefront within EPA and outside of the Agency. Some
highlights of OCHP's efforts include:
National Academy of Sciences (NAS) Study of the Future of Toxicity Testing.
Supplemental Guidance for Assessing Cancer Susceptibility from Early-Life
Exposure to Carcinogens (External Review Draft).
First Time Ever Collaboration of State Environmental and Health Officials to
Implement a National Action Agenda to Reduce Childhood Asthma: Environmental
Council of the States (ECOS) and Association of State and Territorial Health
Officials (ASTHO).
Publication of outreach tools including the Children's Environmental Health
Yearbook; Tips to Protect Children from Environmental Health Threats; a new
general brochure, "Protect Our Children, Protect Our Future"; and an award winning
website
American Nurses Foundation/University of Maryland School of Nurses Collaboration
to develop a continuing education program for nurses in environmental health.
Interagency group to coordinate the Children's Environmental Health program at the
Commission for Environmental Cooperation (CEC).
National Agenda for the Environment and the Aging
A detailed summary of OCHP's accomplishments follows.
n
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Regulations and Standards
OCHP works closely with all program offices to promote the consideration of children's
health risks in regulatory actions and to assist in complying with Executive Order 13045,
"Protection of Children from Environmental Health Risks and Safety Risks." Selected
OCHP's regulatory activities include the following:
Rule Writer's Guide to E.G. 13045. EPA and other federal agencies and
departments are required to evaluate the health and safety effects of planned
regulations on children under Executive Order 13045, "Protection of Children from
Environmental Health Risks and Safety Risks." In addition, an Agency policy
requires all EPA standards and regulations to explicitly consider risks to fetuses,
infants, and children. To help its rule writers comply with the Executive Order and
the Agency's policy on children's health, OCHP worked with the Regulatory Policy
Council and the Regulatory Steering group to issue this guidance in November 1998.
Children's Health Valuation Handbook OCHP and OPEI developed the
Handbook as a reference tool for analysts conducting economic analyses of EPA
regulations and policies that may affect risks to children's health. This handbook
focuses on valuing changes in risks to children's health caused by environmental
improvement or degradation. It addresses incorporating children's health
considerations in efficiency assessments and distributional analyses. All program
offices contributed to the development of this handbook.
America's Children and the Environment. OCHP and OPEI developed the first
children's environmental health indicators report anywhere. The America's Children
and the Environment brings together, in one place, quantitative information from a
variety of sources to show trends in levels of environmental contaminants in air,
water, food, and soil; concentrations of contaminants measured in the bodies of
mothers and children; and childhood diseases that may be influenced by
environmental factors.
Children's Health Valuation Research Grants (STAR Grants). EPA needs
accurate environmental economics research on which to base and evaluate its
policies. OCHP worked closely with ORD and other program offices to develop a
research program under the Science to Achieve Results (STAR) program.
Science and Risk Assessment
OCHP has been a leader in the Agency's work on science and risk assessment related to
children's environmental health protection. For example:
National Academy of Sciences (NAS) Study of the Future of Tozicity Testing.
OCHP recently initiated and co-chaired an EPA effort to establish and implement the
NAS study. The 3.5 year study emphasizes generating toxicity data relevant to early
life stages and the aging population.
fi
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Supplemental Guidance for Assessing Cancer Susceptibility from Early-Life
Exposure to Carcinogens (External Review Draft). OCHP was heavily involved
through the Science Policy Council in developing and approving the guidance.
In 2000, OCHP hosted the National Workshop to Identify Critical Windows of
Exposure for Children's Health, which considered the importance of the tuning of
exposure to toxic chemicals and the affect on respiratory, immune, reproductive, nervous,
cardiovascular, and endocrine systems, as well as general growth and cancer. The
workshop's conclusions were published in peer reviewed scientific literature .
(http://ehp.niehs.mh. go v/docs/2000/suppl -3/loc.hrml'i.
National Children's Study: OCHP co-chairs the Senior Staff Planning Committee of
the President's Task Force on Environmental Health Risks and Safety Risks to
Children. The Task Force initiated the National Children's Study, a longitudinal
cohort study to investigate basic mechanisms of developmental disorders and
environmental factors that influence health and developmental processes.
(vvww.nati
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Breath: Strategies to Reduce Environmental Factors that Contribute to Asthma in
Children. Five states are currently conducting pilot projects to implement the
national action agenda. In addition to these pilots, OCHP will soon announce the
award of approximately $360,000 in grants to about seven additional states to support
the joint efforts of state environment and health agencies to minimize the
environmental triggers of childhood asthma. To date, the process has involved more
than 250 people from 41 states, the federal government, and other stakeholder groups.
National Conference of State Legislatures (NCSL) State Legislatures are
beginning to consider children's environmental health in state legislation, policy
initiatives, and funding. NCSL represents state legislators and staff in all 50 states.
With OCHP support, NCSL is helping state legislatures address the issue of children's
environmental health. NCSL has produced a video designed specifically for state
legislatures on children's environmental health, developed an on-line tracking system
of pending state legislation and enacted statutes on various children's environmental
health topics, provided technical assistance to state legislatures, and is developing a
legislative options guide on children's environmental health.
OUTREACH
Child Health Champion Pilot Program Eleven communities participated in the
Child Health Champion Campaign pilot program that was designed to empower local
citizens and communities to take voluntary steps toward protecting their children
from environmental health threats, such as lead, asthma triggers, and unsafe drinking
water. OCHP initiated the Child Health Champion Campaign to meet specific goals
of Executive Order 13045 and EPA's National Agenda to Protect Children's Health
from Environmental Threats. A Child Health Champion Community Team was
established in each pilot community and:
1. Identified local children's environment health issues, such as a high incidence
of hospital admissions and school absences due to asthma;
2. Set community-specific goals to protect children; and
3. Developed and implemented action plans to achieve those goals.
The pilot program has ended and an evaluation is available. It is hoped that the
many valuable lessons learned from the Child Health Champion pilot program
will be useful for future community-based projects. OCHP convened an Agency-
wide work group to develop the pilot program. Each region was responsible for
managing its pilot project.
Tools: OCHP provides information and tools to help people protect children from
environmental risks. OCHP worked with program and regions to develop the EPA
Children's Environmental Health Yearbook and its Supplement, the agency's
early inventory of its activities to protect children from environmental hazards;
a set of tips - easy steps parents and other caregivers could take to protect children
from environmental risks; and a new general brochure "Protect Children, Protect
Our Future". The brochure's purpose is to raise awareness about children's
environmental health issues among citizens, government, and other organizations and
to enable them to take action to protect children. Finally, OCHP worked with
program offices and regions in the development of its award-winning web site.
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Children's Health Month: October is Children's Health Month and OCHP works
with program offices and regions to promote their messages and highlight their many
efforts to protect children from environmental risks during the entire month. OCHP
has developed a Children's Health Month calendar with daily tips to protect children
from environmental risks. OCHP works with program offices and regions to provide
opportunities for the Administrator and other high-ranking EPA officials to
participate in events highlighting children's health protection.
HEALTHCARE PRO AIDERS
OCHP supports efforts to expand the integration of environmental health into health care
provider education and practice.
American Nurses Foundation/University of Maryland School of Nurses
Collaboration As the largest group of health care providers (2.6 million in the United
States), nurses can play an important role in protecting children from environmental
health risks. With OCHP support, the American Nurses Foundation in collaboration
with the University of Maryland School of Nursing developed a continuing education
program for nurses in environmental health. Three on-line and in-print continuing
education modules related to children's environmental health focus on pediatric
environmental health in the home and community, in the school setting, and in the
health care setting. MEDSCAPE is currently offering the module on home and
community on its web site.
» American Academy of Pediatrics: With EPA support, the American Academy of
Pediatrics (AAP) published the second edition of the Handbook of Pediatric
Environmental Health, a comprehensive reference manual for pediatric clinicians to
help identify, prevent and treat environmental health problems in children.
Pediatricians are often not trained to recognize environmental hazards yet they are '
among parents' top health concerns for their children. This handbook will allow
pediatricians to answer parent questions and address environmental health issues with
the most up-to-date information. OCHP worked with program staff to gain
support for this effort and many program offices contributed toward the $92,000
grant to AAP including: Office of Water; Office of Prevention, Pesticides, and
Toxic Substances; Office of Air and Radiation and Office of Children's Health
Protection.
OCHP also supported an AAP project to help pediatricians understand how to use
the Handbook. Each year for the past four years AAP sponsored a workshop for
incoming chief pediatric residents to heighten awareness of pediatric environmental
health issues. The goal was for the residents to incorporate their new knowledge into
their residency education program. More than 160 incoming chief pediatric residents
participated in these workshops and an evaluation of its effectiveness is ongoing.
Ambulatory Pediatrics Association: The field of pediatric environmental health
needs champions and experts to make sure that children are protected from
environmental risks. OCHP supported the Ambulatory Pediatric Association's
development of competencies as well as ongoing education for a new Pediatric
Environmental Health Fellowship program supported primarily through private
funding.
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National Strategies for Health Care Providers: Pesticide Initiative: EPA and the
National Environmental Education and Training Foundation, in partnership with the
U.S. Departments of Health and Human Services, Agriculture and Labor, and health
professionals nationwide, are supporting a national initiative to integrate health
information related to pesticides into the education and practice of health care
providers. OCHP is a member of die federal planning committee for this
initiative and provided partial funding for a national forum held in June 2004. It is
hoped that the pesticides initiative may be applied to other environmental health
issues.
JSI Research and Training Institute, Center for Environmental Studies: OCHP
supported an effort by the JSI Research and Training Institute in partnership with
Greater Boston Physicians for Social Responsibility to develop model training
materials and programs for health care providers based on the publication In Harms
Way. The Training Program for Health Professionals - hi Harm's Way: Toxic Threats
to Child Development - has been translated into Spanish and was distributed to
pediatricians attending the First International Training on Children's Environmental
Health organized as pre-congress activity of the Triennial Congress of Pediatrics for
the south cone of Latin America. While the grant ended in 2002, the training
program has been incorporated into numerous training sessions and workshops since
that time. Just this past fall the training program was presented to 350 health
professionals in two cities.
INTERNATIONAL
OCHP has been actively involved in international initiatives to protect children
from environmental health risks to children. OCHP and OIA run an interagency group to
coordinate the Children's Environmental Health program at the Commission for
Environmental Cooperation (CEC). This effort has been very successful in pulling
together appropriate EPA program offices and regional representatives, resulting in:
+ Council resolutions to create a CEC work program on children's
environmental health,
* A high level of cooperation and collaboration on CEC children's work,
including on indicators, asthma, and risk assessment issues,
* Cooperation with the Department of Health and Human Services.
The group recently convened to discuss EPA's response to the CEC Taking Stock Report
on Children and Chemicals, so that the Agency is well prepared to respond appropriately
to queries about the report.
OCHP has also played a key role in the following international activities related to
children's environmental health:
Creation and implementation of the CEC Children's Environmental Health
Programa trilateral effort to address children's environmental health in
Canada, Mexico and the United States.
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Launch of a UN partnership at the World Summit on Sustainable
Development to develop global indicators on children's environmental
health. The partnership includes other governments, NGOs and international
organizations, and is currently being implemented.
* Co-sponsored conferences and workshops, prepared and distributed
materials, and briefed key policy makers to create interest and action on
children's environmental health in Europe, South East Asia, Africa, and
Latin America.
Creation of interest and action on children's environmental health in international
and non governmental organizations including OECD, UNEP, UNICEF, WHO,
EU, G8 Health and Environment Ministers of the Americas, CEC;
International Society of Doctors for the Environment (ISDE), International
Children's Health Environment and Safety (INCHES), and various national
organizations.
Creation of interest and action on children's environmental health at key
international forums, including: GS meeting in 1997 and 2002, European
Environment and Health Ministerial in 1999 and 2004, CEC council
meetings 200-2003, Health and Environment Ministers of the Americas,
2002, UN General Assembly Special Session on Children, 2002, and the
World Summit on Sustainable Development, 2002.
Aging Initiative
EPA has taken a leadership role by establishing an Aging Initiative to protect the
health of older adults. The Initiative, led by OCHP, is EPA's first coordinated approach
to address environmental hazards that affect the health of older persons, and will result in
a National Agenda for the Environment and the Aging. The National Agenda will
study the effects of environmental hazards on Hie health of older persons and examine the
impact that a rapidly aging population will have on the environment. OCHP's Aging
Initiative is working with program offices to ensure that the needs and issues of older
adults are included in products and policies. For example:
The Aging Initiative is working closely with the EPA Office of Research and
Development (ORD) to help develop an integrated research strategy to provide a
scientific foundation that supports policies that include the interaction between
aging and environmental exposure that results in adverse health effects on older
adults.
Developing information on Chronic Obstructive Pulmonary Disease and asthma
triggers for older adults: The Aging Initiative is working with ORD, the Office of
Air and Radiation (OAR) and the Office of Pesticides and Poison Prevention
(OPPTS) on this effort.
"National Poison Prevention Week,'' with the Office of Pesticides and Poison
Prevention.
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Outside of EPA, Hie Aging Initiative continues to raise awareness of environmental
hazards and the health of older adults by reaching out to Federal agencies, state, local and
tribal governments, non-governmental organizations, aging and health organizations and
health care professionals:
The Federal Interagency Forum on Aging-Related Statistics, has recently
accepted an indicator on the health effect of air pollution on the health of older
.adults. The Aging Initiative has coordinated an interagency meeting with various
Federal agencies to solicit guidance for the development'of the National Agenda for
the Environment and the Aging.
The Council of State and Territorial Epidemiologists, with an EPA grant, is
developing questions on environmental health hazards and older adults as part of the
Behavioral Risk Factor Surveillance System.
The Aging Initiative outreach strategy also includes:
A comprehensive website (www. epa. aov/aging).
A 750-plus member listserve, and
Information dissemination on the interaction between environmental
exposures and pre-existing diseases which may result in significant health
benefits. For example, the Aging Initiative partnered with the American Lung
Association and the National Council on the Aging to develop a poster on COPD
and asthma which has been distributed to 15,000 senior centers, 655 area agencies
on aging, 57 state offices on aging, and hundreds of individuals and other aging
and health organizations. ,
In 2002 the Aging Initiative sponsored a National Academy of Sciences
workshop on "Differential Susceptibility of Older People to Environmental
Hazards" which brought together experts in the field of aging, health and the
environment to identify research needs to help guide EPA efforts.
EPA held six public listening sessions to obtain input for a National Agenda for
the Environment and the Aging..
The Aging Initiative continues to work with members of the Leadership Council
of Aging Organizations who represent the 50 major national aging organizations
in the U.S., as well as Generations United, which is the nation's foremost
intergenerational organization, and academic institutions, including schools of
public health, medical schools and nursing colleges.
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