Letter
Letter to EPA From USCCB General Counsel on Final Rule on Testing Pesticides on Humans, December 12, 2005
Letter to EPA From USCCB General Counsel on Final Rule on Testing Pesticides on Humans, December 12, 2005
"On behalf of the United States Conference of Catholic Bishops ("Conference") we are submitting the following comments in response to the notice of proposed rulemaking (RIN 2070-AD57) regarding a ban on intentional dosing human testing for pesticides when the subjects are pregnant women or children that was published in the Federal Register on September 12, 2005. 70 Fed. Reg. 53838. The Catholic Church is one of the major providers of health care in the world and we are particularly concerned with how the testing of pesticides on humans and the laws and regulations governing it will affect human beings, especially the very young, the very old and those with disabilities. 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.
We urge the Agency to adopt a policy that truly reflects the highest standards of respect for the dignity of persons who might participate in human testing. The final rule should reflect a special concern for the interests of vulnerable populations, such as children from before birth through adolescence, pregnant women, the elderly and those with fragile health due to compromised respiratory functions or other conditions. In no case should developing humans (i.e., children in utero, infants, young children or adolescents) be deliberately exposed to toxic chemicals. It is important that vulnerable persons, including the poor, not be offered financial incentives to participate in studies that may harm their health."