Project TENDR: Targeting Environmental Neuro-Developmental Risks The TENDR Consensus Statement

1The TENDR Consensus Statement is a call to action to reduce exposures to toxic chemicals that can contribute to the prevalence of neurodevelopmental disabilities in America’s children. The TENDR authors agree that widespread exposures to toxic chemicals in our air, water, food, soil, and consumer products can increase the risks for cognitive, behavioral, or social impairment, as well as specific neurodevelopmental disorders such as autism and attention deficit hyperactivity disorder (ADHD). This preventable threat results from a failure of our industrial and consumer markets and regulatory systems to protect the developing brain from toxic chemicals. To lower children’s risks for developing neurodevelopmental disorders, policies and actions are urgently needed to eliminate or significantly reduce exposures to these chemicals. Further, if we are to protect children, we must overhaul how government agencies and business assess risks to human health from chemical exposures, how chemicals in commerce are regulated, and how scientific evidence informs decision making by government and the private sector.

2We are witnessing an alarming increase in learning and behavioral problems in children. Parents report that 1 in 6 children in the United States, 17% more than a decade ago, have a developmental disability, including learning disabilities, ADHD, autism, and other developmental delays. As of 2012, 1 in 10 (> 5.9 million) children in the United States are estimated to have ADHD. As of 2014, 1 in 68 children in the United States has an autism spectrum disorder (based on 2010 reporting data).

3The economic costs associated with neurodevelopmental disorders are staggering. On average, it costs twice as much in the United States to educate a child who has a learning or developmental disability as it costs for a child who does not. A recent study in the European Union found that costs associated with lost IQ points and intellectual disability arising from two categories of chemicals—polybrominated diphenyl ether flame retardants (PBDEs) and organophosphate (OP) pesticides—are estimated at 155.44 billion euros ($169.43 billion dollars) annually. A 2009 analysis in the United States found that for every $1 spent to reduce exposures to lead, a potent neurotoxicant, society would benefit by $17–$221.

4Many toxic chemicals can interfere with healthy brain development, some at extremely low levels of exposure. Research in the neurosciences has identified “critical windows of vulnerability” during embryonic and fetal development, infancy, early childhood and adolescence. During these windows of development, toxic chemical exposures may cause lasting harm to the brain that interferes with a child’s ability to reach his or her full potential.

5The developing fetus is continuously exposed to a mixture of environmental chemicals. A 2011 analysis of the U.S. Centers for Disease Control and Prevention’s (CDC) biomonitoring data found that 90% of pregnant women in the United States have detectable levels of 62 chemicals in their bodies, out of 163 chemicals for which the women were screened. Among the chemicals found in the vast majority of pregnant women are PBDEs, polycyclic aromatic hydrocarbons (PAHS), phthalates, perfluorinated compounds, polychlorinated biphenyls (PCBs), perchlorate, lead and mercury. Many of these chemicals can cross the placenta during pregnancy and are routinely detected in cord blood or other fetal tissues.

6The following list provides prime examples of toxic chemicals that can contribute to learning, behavioral, or intellectual impairment, as well as specific neurodevelopmental disorders such as ADHD or autism spectrum disorder:

7Organophosphate (OP) pesticides.

8PBDE flame retardants.

9Combustion-related air pollutants, which generally include PAHs, nitrogen dioxide and particulate matter, and other air pollutants for which nitrogen dioxide and particulate matter are markers.

10Lead.

11Mercury.

12PCBs.

13The United States has restricted some of the production, use and environmental releases of these particular chemicals, but those measures have tended to be too little and too late. We face a crisis from both legacy and ongoing exposures to toxic chemicals. For lead, OP pesticides, PBDEs and air pollution, communities of color and socioeconomically stressed communities face disproportionately high exposures and health impacts.

14Policies to ban lead from gasoline, paints and other products have been successful in lowering blood lead levels in the American population, yet lead exposure continues to be a preventable cause of intellectual impairment, ADHD and maladaptive behaviors for millions of children. Scientists agree that there is no safe level of lead exposure for fetal or early childhood development, and studies have documented the potential for cumulative and synergistic health effects from combined exposure to lead and social stressors. Thus, taking further preventive actions is imperative.

15Epidemiological, toxicological, and mechanistic studies have together provided evidence that clearly demonstrates or strongly suggests neurodevelopmental toxicity for lead, mercury, OP pesticides, air pollution, PBDEs, and PCBs. The level and type of available evidence linking exposures to toxic chemicals with neurodevelopmental disorders, including the examples in this statement, vary both within and among chemical classes. In light of this extensive evidence and continued widespread exposure, the risks for learning and developmental disorders can likely be lowered through targeted exposure reduction, starting with these example chemicals.

16The examples of developmental neurotoxic chemicals that we list here likely represent the tip of the iceberg. Of the tens of thousands of chemicals on the U.S. Environmental Protection Agency (EPA) chemical inventory, nearly 7,700 are manufactured or imported into the United States at ≥ 25,000 pounds per year. The U.S. EPA has identified nearly 3,000 chemicals that are produced or imported at > 1 million pounds per year.

17Only a minority of chemicals has been evaluated for neurotoxic effects in adults. Even fewer have been evaluated for potential effects on brain development in children. Further, toxicological studies and regulatory evaluation seldom address combined effects of chemical mixtures, despite evidence that all people are exposed to dozens of chemicals at any given time.

18Our failures to protect children from harm underscore the urgent need for a better approach to developing and assessing scientific evidence and using it to make decisions. We as a society should be able to take protective action when scientific evidence indicates a chemical is of concern, and not wait for unequivocal proof that a chemical is causing harm to our children.

19Evidence of neurodevelopmental toxicity of any type—epidemiological or toxicological or mechanistic—by itself should constitute a signal sufficient to trigger prioritization and some level of action. Such an approach would enable policy makers and regulators to proactively test and identify chemicals that are emerging concerns for brain development and prevent widespread human exposures.

20Some chemicals, like those that disrupt the endocrine system, present a concern because they interfere with the activity of endogenous hormones that are essential for healthy brain development. Endocrine-disrupting chemicals (EDCs) include many pesticides, flame retardants, fuels, and plasticizers. One class of EDCs that is ubiquitous in consumer products are the phthalates. These are an emerging concern for interference with brain development and therefore demand attention.

21Under our current system, when a toxic chemical or category of chemicals is finally removed from the market, chemical manufacturers often substitute similar chemicals that may pose similar concerns or be virtually untested for toxicity. This practice can result in “regrettable substitution” whereby the cycle of exposures and adverse effects starts all over again. The following list provides examples of this cycle:

22When the federal government banned some uses of OP pesticides, manufacturers responded by expanding the use of neonicotinoid and pyrethroid pesticides. Evidence is emerging that these widely used classes of pesticides pose a threat to the developing brain.

23When the U.S. Government reached a voluntary agreement with flame retardant manufacturers to stop making PBDEs, the manufacturers substituted other halogenated and organophosphate flame retardant chemicals. Many of these replacement flame retardants are similar in structure to other neurotoxic chemicals but have not undergone adequate assessment of their effects on developing brains.

24When the federal government banned some phthalates in children’s products, the chemical industry responded by replacing the banned chemicals with structurally similar new phthalates. These replacements are now under investigation for disrupting the endocrine system.

25Our system for evaluating scientific evidence and making decisions about environmental chemicals is broken. We cannot continue to gamble with our children’s health. We call for action now to prevent exposures to chemicals and pollutants that can contribute to the prevalence of neurodevelopmental disabilities in America’s children.

26We need to overhaul our approach to developing and assessing evidence on chemicals of concern for brain development. Toward this end, we call on regulators to follow scientific guidance for assessing how chemicals affect brain development, such as taking into account the special vulnerabilities of the developing fetus and children, cumulative effects resulting from combined exposures to multiple toxic chemicals and stressors, and the lack of a safety threshold for many of these chemicals. We call on businesses to eliminate neurodevelopmental toxicants from their supply chains and products, and on health professionals to integrate knowledge about environmental toxicants into patient care and public health practice.

27Finally, we call on policy makers to take seriously the need to reduce exposures of all children to lead—by accelerating the clean up from our past uses of lead such as in paint and water pipes, by halting the current uses of lead, and by better regulating the industrial processes that cause new lead contamination.

28We are confident that reducing exposures to chemicals that can interfere with healthy brain development will help to lower the prevalence of neurodevelopmental disabilities, and thus enable many more children to reach their full potential.