On behalf of Environmental Working Group, I am writing to inquire if your company has detected any of the chemicals you produce in the blood of American babies.
EWG's recent review of the open literature indicates, surprisingly, that comparatively few of the thousands of chemicals U.S. companies produce have been tested for in human umbilical cord blood. To our knowledge, the study we released last week ("Body Burden: The Pollution in Newborns") tested for the widest array of toxic chemicals to date in the blood of individual babies.
It is our assumption that any chemical company concerned about the potential health impacts of their products would take the rudimentary step of testing to see if those products end up in people, especially during the period in life when people are most vulnerable to chemical insultÑin the womb, during infancy, and throughout early childhood.
What we want to know is whether or not your company has performed, but not published, laboratory tests to determine if your chemicals end up in babies through transplacental movement.
If your company has performed those tests, we ask that you make public the results. If you have not conducted such tests, we would like to know why not.
Our inquiry touches on important matters not only of public health science, but also of ethics and law. You may be aware of the lawsuit the Environmental Protection Agency filed against DuPont in 2004 for multiple violations of federal laws, including the Toxic Substances Control Act. Figuring prominently in EPA's complaint was the company's failure to report a 1981 finding of the Teflon-related chemical perfluorooctanoic acid (PFOA) in umbilical cord blood in a study that measured the chemical in babies born to female employees. The EPA's complaint puts the matter very clearly:
"DuPont's failure to immediately inform EPA about the information concerning the human blood sampling [Teflon ingredient contaminating human cord blood] constitutes a violation of TSCA Section 8(e)..." (paragraph 46)
"The Agency considers the human blood sampling information confirming transplacental movement of PFOA [the Teflon ingredient] to reasonably support the conclusion of a substantial risk of injury to health or the environment." (paragraph 47)
"DuPont's failure or refusal to submit the human blood sampling information as required under TSCA Section 8(e) is an unlawful act..." (paragraph 52)
We are also curious to know if your company intends to nominate any chemicals, including chemicals you produce, for inclusion in the national exposure assessment conducted by the Centers for Disease Control.
We thank you for your consideration in this matter.
Sincerely yours,
Kenneth A. Cook
President
NOTE: This letter was sent to the following chemical company CEOs:
William S. Stavropoulos, President & CEO
Dow Chemical
John C. Hodgson, Vice President
DuPont
James P. Harris, Senior Vice President
ExxonMobil Chemical Company
Peter Huntsman, President & CEO
Huntsman Corporation
Morris Gelb, COO
Equistar Chemicals, LP
Jim Gallogly, President & CEO
Chevron Phillips
John Krenicki, President & CEO
GE Advanced Materials
William A. Woodburn, President & CEO
GE Infrastructure
Kevin F. Sullivan, Vice President, Chemicals
PPG Industries Incorporated
John Jones, President & CEO
Air Products and Chemicals Incorporated
Dennis H. Reilley, Chairman, President, & CEO
Praxair Incorporated
J. Brian Ferguson, Senior Vice President
Eastman Chemical
Rajiv L. Gupta, Chairman & CEO
Rohm and Haas
Dan F. Smith, President & CEO
Lyondell
David Weidman, President & CEO
Celanese Corporation
Nance Dicciani, CEO
Honeywell
Stephanie A. Burns, President & CEO
Dow Corning Corporation
Hugh Grant, Chairman, President, & CEO
Monsanto
Mike Campbell, President & CEO
Arch Chemicals
Mark P. Bulriss, Chairman, President, & CEO
Great Lakes Chemical
Robert L. Wood, President & CEO
Crompton Corporation
Robert S. Morrison, Chairman of the Board & CEO
3M
www.ewg.org is the website for both Environmental Working Group and EWG Action Fund
Copyright 2008, Environmental Working Group. All Rights Reserved.
Headquarters 1436 U St. N.W., Suite 100 | Washington, DC 20009 || Contact Us California Office 1904 Franklin St. Suite 703 | Oakland, CA 94612 || Contact Us