NCHR Statement on U.S. Consumer Product Safety Commission Priorities for Fiscal Year 2017 and 2018

Stephanie Fox-Rawlings PhD, National Center for Health Research: June 15, 2016

The National Center for Health Research is a nonprofit research center staffed by scientists, medical professionals, and health experts who analyze and review research on a range of health issues. Thank you for the opportunity to share our views concerning the Consumer Product Safety Commission’s (CPSC) priorities for fiscal year 2017 and 2018. We respect the essential role of the CPSC, as well as the challenges you face in selecting the most important priorities

Phthalates and flame retardants need to be among your top priorities because they are in all our homes and they migrate from products into the our daily environment. Multiple phthalate metabolites and flame retardants are detectable in nearly all people in the U.S.[1] and scientists agree that their impact on health can be dangerous and long-lasting.

Additional Bans on Phthalates in Children’s Toys and Care Products

We applaud the current permanent and temporary bans on six phthalates in children’s toys and child care articles.[2] However, these bans need to be expanded. The rule “Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates” proposed in spring 2015 following the Chronic Hazard Advisory Panel (CHAP) would provide essential additional protections for children.[2] [3]

We support the permanent bans on four additional phthalates (DIBP, DPENP, DHEXP, and DCHP) and making permanent the interim ban on DINP.[2] However, the CHAP report also recommended an intern ban on DIOP, which should also be included in the rule. We strongly disagree with the proposal to lift the interim bans on DNOP and DIDP. While they may not be associated with antiandrogenicity, they are associated with organ toxicity and altered development.

The CHAP report also recommended additional studies on three other phthalates (DMP, DPHP, and DEP) and six phthalate alternatives.[3] The final rule should include a timeline for the completion of these studies.

In summary, we strongly urge the CPSC to finalize the proposed rule on phthalates in children’s toys and child care articles, including consideration of our safety concerns.

It is also important for CPSC to expand its work on phthalates to include safeguards for older children. There is increasing evidence of the impact of these chemicals on early puberty,which itself is associated with drug abuse, sexual exploitation, and suicide.[4][5][6][7][8][9]

Bans on Flame Retardants

The CPSC has the responsibility and ability to protect consumers from toxic flame retardants under the Federal Hazardous Substances Act.

We agree with others groups commenting today that the CPSC should propose and finalize regulations that would ban additive, non-polymeric organohalogen flame retardants in four categories of household products as proposed in Petition No. HP 15-1.[10] Like phthalates, these chemicals move from products to our daily environment and from there into consumers’ bodies where they can cause irreparable harm. All of the organohalogen flame retardants studied have been associated with chronic health effects.

The most well-studied organohalogen flame retardants are the polybrominated diphenyl ethers (PBDEs), which have been phased out in part due to their effects on human health.[11] The alternatives in the same class are proving to have similar problems. These alternatives found in a large percentage of people tested in various communities.[12] They have been linked to cancer, reproductive problems, neurotoxicity, developmental toxicity, endocrine disruption, and behavioral changes in models and/or humans.[10]

We strongly urge the CPSC to develop and finalize a ban on these chemicals in the proposed residential products to protect consumers from their toxic effects.

In conclusion, we urge the CPSC to prioritize the research and rulemaking to limit exposure of consumers, and especially children, from the phthalates and flame retardants that have been found to have negatively impact health and development.

Thank you for your time and consideration of our views.

References

  1. National Health and Nutrition Examination Survey (NHANES) (October 2014). Phthalates and Plasticizers Metabolites- Urine (PHTHTE_G); years of content 2011-2012. http://wwwn.cdc.gov/Nchs/Nhanes/2011-2012/PHTHTE_G.htm
  2. Federal Register (December 30, 2014). Consumer Product Safety Commission. Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates. Docket No. CPSC-2014-0033. http://www.gpo.gov/fdsys/pkg/FR-2014-12-30/pdf/2014-29967.pdf
  3. Consumer Product Safety Commission (July 2014). Chronic Hazard Advisory Panel On Phthalates and Phthalate Alternatives. https://www.cpsc.gov/PageFiles/169876/CHAP-REPORT-FINAL.pdf
  4. Bourguignon JP, Juul A, Franssen D, Fudvoye J, Pinson A, Parent AS (2016) Contribution of the Endocrine Perspective in the Evaluation of Endocrine Disrupting Chemical Effects: The Case Study of Pubertal Timing. Horm Res Paediatr. In Press.
  5. Zhang Y, Cao Y Shi H Jiang X Zhao Y Fang X Xie C (2015) Could Exposure to Phthalates Speedup or Delay Pubertal Onset and Development? A 1.5-year Follow-up of a School-based Population. Environ Int 83:41-49.
  6. Fisher MM Eugster EA (2014) What is in our Environment that Effects Puberty? Reprod Toxicol 44:7-14.
  7. Hedges K Korchmaros JD (2016) Pubertal Timing and Substance Abuse Treatment Outcomes: An Analysis of Early Menarche on Substance Use Patterns. J Child Adolesc Subst Abuse. In Press.
  8. Golub MS, Collman GW, Foster PM, Kimmel CA, Rajpert-De Meyts E, Reiter EO, Sharpe RM, Skakkebaek NE, Toppari J (2008) Public Health Implications of Altered Puberty Timing. Pediatrics. Suppl 3:S218-230.
  9. Mendle J, turkheimer E, Emery RE (2007) Detrimental Psychological Outcomes Associated with Early Pubertal Timing in Adolescent Girls. Dev Rev 27(2):151-171.
  10. Earthjustice and Consumer Federation. (July 2015) Petitiion HP 15-1 Requesting Rulemaking on Products Containing Organohalogen flame Retardants. https://www.cpsc.gov/Global/Regulations-Laws-and-Standards/Petitions/PetitionHP151RequestingRulemakingProductsContainingOrganohalogenFlameRetardents.pdf
  11. US EPA. Polybrominated Diphenyl Ethers (PBDEs). https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/polybrominated-diphenyl-ethers-pbdes.
  12. Centers for Disease Control and Prevention (2009). Fourth National Report on Human Exposure to Environmental Chemicals, at 311-13. http://www.cdc.gov/exposurereport/.