July 12, 2005
We understand that House and Senate Conferees will meet soon to take up the Interior, Environment and Related Agencies Appropriations bill for FY 2006. I write as Chairman of the Domestic Policy Committee of the United States Conference of Catholic Bishops (USCCB) to express our support for efforts by Congress to ensure that there are adequate and effective safeguards in laws or regulations governing the testing of pesticides on human beings. We believe that the morally responsible course for U.S. Environmental Protection Agency (EPA) to take is to not accept human toxicity studies until the Agency takes the care and time necessary to go through the formal regulatory process (including an ample period for public comments) for establishing a definitive policy on safeguards consistent with the comments the USCCB provided and criteria recommended by the National Academy of Sciences (NAS).
The Catholic Church is one of the major providers of health care in the world and therefore we are particularly concerned with how this testing and the laws and regulations governing it will affect human beings, especially the very young, very old or disabled. It is often the powerless and vulnerable in our society, including children, born and unborn, and low-income families, who face the greatest risk from harmful exposures and unethical testing.
While we recognize that appropriate human testing has legitimate uses and is often necessary, it needs to serve the common good and safeguard the most vulnerable among us. We approach this issue from our perspective as pastors and teachers concerned about the protection of human life, not from any particular scientific expertise. As our Conference noted in its statement Faithful Citizenship, “We believe that every human life is sacred from conception to natural death, that people are more important than things, and that the measure of every institution is whether it protects the life and dignity of the human person."
We have attached a copy of the comments we submitted to the EPA in September 2003 on its proposed rulemaking on human testing of pesticides. In those comments, we opposed any attempts to undermine or weaken the health protections set forth by the Food Quality Protection Act of 1996 (FQPA). This Act was intended to reform pesticide regulation in response to a 1993 NAS report which found that the pesticide regulatory framework did not provide adequate health protection, especially for children.
We urge you to see that the EPA puts in place a comprehensive policy that reflects its mission of protecting public health and the environment, before the EPA continues authorizing tests on human beings.
We thank you for your consideration of our views and for your support of measures that protect those most vulnerable from harmful pesticides.
Most Rev. Nicholas DiMarzio, PhD, DD
Bishop of Brooklyn
Domestic Policy Committee