On May 22, 2025, the U.S. Department of Health and Human Services (HHS) announced the release of a new federal report, Making Our Children Healthy Again (MAHA Assessment) issued by the Make America Healthy Again (MAHA) Commission. The MAHA Commission was established by Executive Order (EO) 14212 to:
(a) study the scope of the childhood chronic disease crisis and any potential contributing causes, including the American diet, absorption of toxic material, medical treatments, lifestyle, environmental factors, Government policies, food production techniques, electromagnetic radiation, and corporate influence or cronyism;
(b) advise and assist the President on informing the American people regarding the childhood chronic disease crisis, using transparent and clear facts; and
(c) provide to the President Government-wide recommendations on policy and strategy related to addressing the identified contributing causes of and ending the childhood chronic disease crisis.
The MAHA Commission was required to submit to the President, within 100 days of the EO’s release on February 13, 2025, this MAHA Assessment. Within 180 days of the date of the EO, or by August 12, 2025, the MAHA Commission is required to submit to the President a “Make Our Children Healthy Again Strategy” based on the findings from the MAHA Assessment.
According to HHS, the MAHA Assessment identifies key drivers behind childhood chronic diseases, including poor diet, accumulation of environmental toxins (such as pesticide exposure), insufficient physical activity, chronic stress, and overmedicalization.
Among other things, the MAHA Assessment examines pesticide use in agriculture and the perceived negative impacts it has on children. It calls for more research and potential shifts in food and farming policies to improve children’s health.
The MAHA Assessment includes a subsection entitled “Why Children Are Uniquely Vulnerable to Environmental Chemicals,” where pesticides are mentioned several times. The MAHA Assessment states that children are at heightened risk when exposed to environmental chemicals, including pesticides. The MAHA Assessment states the following as key factors:
Sensitive Developmental Windows: Even minor exposures during critical periods — in utero, infancy, early childhood, and adolescence — can result in developmental delays or permanent harm.
Developing Immune Systems: Young children have maturing immune systems, making them susceptible to chemical exposures that can disrupt lifelong immune development.
Detoxification Challenges: Babies struggle to detoxify chemicals as effectively as adults, allowing chemicals to accumulate in their smaller bodies.
Accelerated Brain Development: Early childhood is marked by rapid brain development, with up to one million new neural connections forming every second. Toxic exposures during this time can derail neurodevelopment, leading to lifelong learning disabilities and behavioral disorders.
Endocrine Disruption: Multiple developmental stages, from fetal growth to onset of puberty, are regulated via exquisitely sensitive hormonal signaling that can be disrupted by endocrine-disrupting chemicals, impacting growth trajectories and outcomes from conception through early adulthood.
Adolescent Brain Remodeling: The brain undergoes a second phase of remodeling during adolescence, particularly in regions responsible for impulse control and emotion. Neurotoxic substances — such as solvents and heavy metals — can have lasting effects that extend well beyond the teenage years.
With regard to how children are exposed to hazardous substances in different ways, the MAHA Assessment states several factors including:
- Breastmilk: The MAHA Assessment states: “Virtually every breastmilk sample … tested in America contains some level of persistent organic pollutants (POPs), including pesticides, microplastics, and dioxins”;
- Household Dust: Infants and toddlers ingest more household dust than adults, and according to the MAHA Assessment, much of household dust “contains detectable levels of lead, flame retardants, and pesticide residues”;
- Home Environment: The MAHA Assessment cites to a 2009 American Healthy Homes Survey, a collaborative effort by the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Housing and Urban Development (HUD), for demonstrating “the widespread presence of pesticides in U.S. homes, with almost 90% showing measurable levels of at least one insecticide on floors”; and
- Food: The MAHA Assessment states: “More than eight billion pounds of pesticides are used each year in the food systems, around the world, with the U.S. accounting for roughly 11%, or more than one billion pounds.”
The MAHA Assessment states some epidemiological and clinical studies raised concern about possible links between pesticides, herbicides, and insecticides and adverse health outcomes in children. It specifically notes that glyphosate may have a wide range of possible health effects, ranging from reproductive and developmental disorders to cancer, liver inflammation, and metabolic disturbances. Atrazine is also specifically mentioned as causing endocrine disruptions and birth defects. The MAHA Assessment notes that federal government reviews of epidemiologic data for the most common herbicide did not establish a direct link between correct use of the herbicide and adverse health outcomes. In addition, the MAHA Assessment acknowledges that “more recent data from the USDA’s Pesticide Data Program found that 99% of food samples tested in 2023 were compliant with EPA’s safety limit.” HHS states that an updated health assessment by the federal government on common herbicides is expected in 2026.
Commentary
The MAHA Assessment specifically names pesticides chlorpyrifos, atrazine, and glyphosate as examples presenting notable risks from modern agricultural production methods. The MAHA Assessment highlights many of the problems said to be associated with modern food production as a system — processed food ingredients, nutrition, and typical farming practices. The references to pesticides are generally grouped with other categories or substances, including heavy metals, per- and polyfluoroalkyl substances (PFAS), fluoride, and phthalates. The MAHA Assessment acknowledges that EPA has a “robust risk-based approach that considers hazard and exposure for assessing the risks of chemicals, including pesticides, to human health and the environment.”
Throughout the MAHA Assessment, there are footnotes citing studies in an effort to raise concerns about the dangers of the modern food production system, yet the established data about pesticide residues are found to be compliant with the requirements of the Food Quality Protection Act (FQPA). When discussing EPA’s “robust risk-based approach,” the MAHA Assessment does not explicitly note that pesticide residues in food have been found to have a “reasonable certainty of no harm” based on EPA’s robust review of a comprehensive data set. There is no mention of the safety standard in FQPA that there is a “reasonable certainty of no harm” from pesticide residues — perhaps since such notes might sound contrary to the MAHA Assessment’s tone that the food supply and its components are causing widespread harm to the consuming public. Separately, it is curious that in any cross-agency review process, EPA did not insist on such an explanatory note.
It also is interesting to note that in the MAHA Assessment’s “Next Steps” section, where the MAHA Commission sets forth research initiative recommendations that are underway or will begin in the near future, there are no specific recommendations for EPA. There is, however, a recommendation to “fund independent studies evaluating the health impact of self-affirmed GRAS [Generally Recognized As Safe] food ingredients, prioritizing risks to children and informing transparent FDA [U.S. Food and Drug Administration] rulemaking.”
As noted above, the MAHA Commission has until August 12, 2025, to submit the Make Our Children Healthy Again Strategy, based on the findings noted in the MAHA Assessment. While Administrator’s Zeldin’s press release regarding the MAHA Assessment did not respond to or address any statements in the MAHA Assessment regarding pesticide exposures, it will be important to see what recommendations are forthcoming in the Strategy as they relate to pesticides and food.