Alright, I couldn’t find that, so I’ve just speed-read the bloody paper. I need a stiff drink now.
The paper argues that the EPA’s standard assumption that children are ten times more sensitive than adults to known toxins is sufficient, and the EPA’s stance that animal models are sufficiently representative of human toxicology to drive policy is correct. It says data provided by the National Academy of Sciences shows actual toxicity response is not linear with age, and that children under six months of age seem to be more resistant to some carcinogens than older children, and more sensitive to many other categories of poison, but says that data is insufficient to warrant any change of EPA behavior.
If any one else wants to check sources, just read the opening remarks and then skip down to the part entitled “DIFFERENTIAL RISK BETWEEN CHILDREN AND ADULTS” to save yourself some tedium.
Lerner (and Cory, by proxy) are somewhat sensationalizing what the paper says. Prima facie, it argues that data do not support increase in the number of EPA categories (no establishment of an under-six-months separate exposure limit, for example) and that limiting children’s exposure to newly identified toxins to one-tenth the limit for adults is valid enough to ensure public safety. Not a stance I agree with, but also not controversial in 21st century USA.
Here’s the conclusion:
“Taken together, information on the relative sensitivities of children and adults, on the sensitivity and specificity of toxicity testing protocols, and on the extent to which current uncertainty factors compensate for increased sensitivities and limited data suggests that the use of additional uncertainty factors to limit environmental chemical exposures is unlikely to provide significantly greater protection to children over 6 months of age. The same conclusion might not always hold true for children younger than 6 months of age in the absence of adequate developmental or systemic toxicity testing. However, while younger children are often more sensitive to toxicity than older children or adults, so are younger laboratory animals. Thus, appropriate in utero and early neonatal toxicity testing will compensate for any additional early sensitivity. Developmental and reproductive toxicity testing protocols such as those recommended by the EPA, FDA, and OECD are useful for characterizing toxicity in developing animals and for assessing risks to children that might arise from in utero and postnatal exposures.”
Dourson’s record indicates he’s a “Merchant of Doubt” and his writing has all the hallmarks - he is superficially agreeing with the EPA and with NAS, and makes no outright false statements of data, but he extensively references himself and publications of his house, and his phrasing makes his writing a goldmine for anyone willing to take portions out of context. So to some extent it is fitting that Lerner does this, although I would not, personally.
