Q: Because children are known to be more vulnerable to chemical exposures, shouldn’t we automatically impose higher levels of safety to protect them?

A: Dow supports the accumulation of information to support risk-based decision making to protect the health and safety of all populations, including children and others considered to be more sensitive sub-populations. That is why Dow is participating in the US EPA Voluntary Children’s Chemical Evaluation Program (VCCEP). This tier-based risk assessment program is focused specifically on ensuring adequate protection for children from certain substances to which children may be exposed.

Current risk assessment practice incorporates precautionary (or safety) factors to accommodate scientific uncertainties. Typically, a 10-fold safety factor is applied to accommodate the uncertainty of extrapolating findings from studies conducted in laboratory animals to humans. An additional 10-fold safety factor is then applied to allow for variability or unique sensitivities among humans.

Scientists have examined the question of unique or greater vulnerability of children and have concluded that, while there are some examples of chemicals and exposure scenarios where children are more vulnerable, there are many more examples where they are not. Their conclusion is that because we cannot automatically conclude that children are more vulnerable to the effects of chemicals, decisions to impose additional safety factors, beyond the two ten-fold safety factors discussed above, should be made on a case-by-case basis, taking into account the inherent hazards of the chemical and the exposure scenarios. If any credible risk assessment shows that children would be expected to be more vulnerable, then appropriate action should be taken to protect them.

Dow supports efforts to strengthen and standardize health and environmental data collection efforts internationally so that children’s disease trend data can be analyzed and used for further scientific investigation. We support continued research into the causes of childhood morbidity and mortality using rigorous scientific methods, such as those outlined in the US National Children's Study. We caution against drawing “cause and effect” conclusions from studies that are intended to merely link health and environmental databases.