Children's health continues to be an EPA priority. On April 21, 1997, President Clinton signed Executive Order 13045, entitled "Protection of Children From Environmental Health Risks and Safety Risks." The Order requires federal agencies to assign a "high priority" to addressing health and safety risks to children, to coordinate research priorities on children's health issues, and to ensure that regulatory standards reflect special risks to children. To implement the Order, then EPA Administrator Browner established the Office of Children's Health Protection (OCHP) in May 1997 to facilitate EPA's efforts to protect children from environmental health threats.

In his April 1998 Earth Day remarks, Vice President Gore gave further expression to the Administration's commitment to children's health issues, announcing a new testing initiative focusing on chemicals children are most likely to encounter. EPA announced its intent to promulgate a Children's Health Test Rule under TSCA Section 4 sometime this year or next. Of concern to chemical manufacturers is the fact that if the tests EPA now proposes are required to be completed, testing costs could exceed $3 million per test chemical. The planned rule announced in April 1998 would require the testing of approximately 100 chemicals to which children have a high likelihood of exposure, but about which EPA believes it lacks sufficient toxicity data to assess the risk of human exposure.

In December 2000, EPA began a pilot study of the voluntary Children's Chemical Evaluation Program (VCCEP). The goal of this program is to provide data enabling a better public understanding of the potential health risks to children associated with certain chemical exposures. EPA has begun a pilot study of the VCCEP by asking companies that manufacture or import 23 chemicals found in human tissues and the environment to Sponsor an evaluation of these chemicals. Industry Sponsors have volunteered for 20 of the 23 chemicals. Sponsorship requires the companies to collect or develop health effects and exposure information on their chemical(s) and then to integrate that information in a risk assessment and a "data needs" assessment. More information about the VCCEP is available on the EPA's VCCEP website. The chemicals on the list for Tier 1 testing and exposure assessment are listed on the chart below.

Many of these chemicals have been sponsored and are undergoing testing or are under review by a peer consultation group. EPA will announce if additional information is needed to assess a chemical's risk to children and will indicate what information in Tier 2 should be provided. Companies will then be given an opportunity to sponsor chemicals in Tier 2. EPA plans to use the same process to review Tier 2 information to determine if Tier 3 information is needed and companies will then be given an opportunity to sponsor chemicals in Tier 3.

The signed notice is available on the Internet on the Bergeson & Campbell, P.C. web site at http://www.lawbc.com/other_pdfs/VCCEPFR-Notice.pdf. Lynn L. Bergeson's November 2000 article on the VCCEP, "The VCCEP: Big Issues, High Stakes," is available on the site at http://www.lawbc.com/other_pdfs/bergeson2.pdf.

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