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The meeting notes detail industry concerns about the text of a proposed rule that the Bush administration first unveiled a month later on September 12th. For example, the Crop Life America attendees urged:
• “Re kids—never say never” (emphasis in original);
• “Pesticides have benefits. Rule should say so. Testing, too, has benefits”; and
• “We want a rule quickly—[therefore] narrow [is] better. Don’t like being singled out but, speed is most imp.”
“These meeting notes make it clear that the pesticide industry’s top objective is access to children for experiments. After reading these ghoulish notes one has the urge to take a shower,” commented PEER Executive Director Jeff Ruch, whose organization works with EPA scientists who have been prevented from voicing ethical and scientific concerns about human subject testing. “For an administration which trumpets its concern for the ‘value and dignity of life,’ it is disconcerting that no ethicists, children advocates or scientists were invited to this meeting to counterbalance the pesticide pushers.”
The upcoming August 3rd deadline for EPA final approval for a controversial class of pesticides derived from nerve agents called organophosphates appeared to be a top industry priority. Jim Aidala, the industry lobbyist, stated, “Won’t be able to meet the FQPA [Food Quality Protection Act] deadline. Wouldn’t anyway. Just do the rule first, then proceed ASAP.”
Aidala also suggested how the rules could make subtle exceptions for chemicals testing on children:
• “Distinguish testing kids from using data on kids who were tested”; and
• “Some workers may legally be children, albeit old enough for DOL” [Department of Labor coverage].
The human testing rule adopted by EPA earlier this year contains the loopholes advocated at the OMB meeting for exposing children to pesticides, such as testing on workers and exposures unconnected with the approval process for new pesticides or new uses for existing agents. In addition, the rule broadly allows dosing experiments on infants and pregnant women using non-pesticide chemicals.
“Unfortunately, using human beings as guinea pigs to test the toxic strength of commercial poisons has become a central regulatory strategy under the Bush administration,” Ruch added.