Author: Maureen Swanson

August 10, 2026

Shelley Moore Capito
Chair
Committee on Environment and Public Works
U.S. Senate
Washington, DC 20510

Sheldon Whitehouse
Ranking Member
Committee on Environment and Public Works
U.S. Senate
Washington, DC 20510

Dear Chair Capito and Ranking Member Whitehouse,

We are members of Project TENDR (Targeting Environmental Neuro-Development Risks), a collaborative of scientists, health professionals, and public health advocates focused on preventing exposures to chemicals and pollutants that harm child brain development. Some of us have decades of collective experience and expertise in understanding the health impacts of toxic chemicals and have served on panels convened by the National Academies of Sciences, Engineering, and Medicine and other Federal peer review panels to evaluate the safety of chemicals that have the potential to harm children.

We are concerned that the Environment & Public Works Committee soon plans to mark up legislation to re-open and potentially weaken EPA’s ability to protect public health under the Toxic Substances Control Act (TSCA).

The Lautenberg Chemical Safety Act of 2016 added important protections to TSCA, including requiring an affirmative safety determination before new chemicals can be commercialized. Reopening TSCA will lead to a weakening of these protections, allowing highly toxic chemicals to enter the market with minimal restrictions, if any, adversely impacting the health of children.

We ask that the Committee hold a hearing before any markup on this proposal. It is critical that the committee hear from stakeholders on the range of harmful impacts, particularly on children’s development, of any potential TSCA amendments. Until now, Members have heard primarily from industry lobbyists and their trade associations whose focus has been on weakening TSCA. Members would benefit greatly from hearing testimony on the impacts of toxic chemicals on those most vulnerable before advancing legislation.

For an issue that has the potential to significantly impact children, we hope that you provide the opportunity for testimony that will be crucial for evaluating the impact of changes to TSCA.

Sincerely,

Jerry P. Abraham, MD MPH CMQ *
Director of Public Health, Integration, Street Medicine & Workforce Development,
Kedren Community Health Center
Professor, Charles R. Drew University of Medicine & Science
Past President, Los Angeles County Medical Association LACMA

John R. Balmes, MD*
Prof. of Medicine, UCSF; Prof. Environmental Health Sciences, UC Berkeley
Director, Northern Calif Center for Occupational & Environmental Health
UC Berkeley-UC Davis-UCSF

Deborah H. Bennett, PhD*
Professor, Dept. of Public Health Sciences, School of Medicine
University of California, Davis

Linda S. Birnbaum, PhD, DABT, ATS*
Scientist Emeritus and Former Director,
National Institute of Environmental Health Sciences and National Toxicology Program
Scholar in Residence, Nicholas School of the Environment, Duke University

Joseph Braun, PhD, RN*
Professor, Department of Epidemiology
Director, Center for Climate, Environment, & Health
Brown University School of Public Health

Charlotte Brody, RN
National Director
Healthy Babies, Bright Futures

Carla Campbell, MD, MS, FAAP*
Dornsife School of Public Health
Drexel University

Aimin Chen, MD, PhD*
Professor of Biostatistics and Epidemiology
Perelman School of Medicine, University of Pennsylvania

Jeanne A Conry, MD, PhD
President, The Environmental Health Leadership Foundation

Stephanie M. Engel, PhD*
Professor of Epidemiology
Director, UNC Center for Early Life Exposures and Neurotoxicity
Deputy Director, Center for Environmental Health and Susceptibility
Associate Director for Population Science, Biomedical Research Imaging Center
Gillings School of Global Public Health, University of North Carolina at Chapel Hill

Brenda Eskenazi, PhD*
Professor Emeritus
Director, Center for Environmental Research and Children’s Health (CERCH)
School of Public Health, University of California, Berkeley

Robert M. Gould, MD*
Associate Adjunct Professor, Program on Reproductive Health and the Environment
UCSF School of Medicine
President, San Francisco Bay Physicians for Social Responsibility

Russ Hauser, MD, ScD, MPH*
Frederick Lee Hisaw Professor of Reproductive Physiology
Professor of Environmental and Occupational Epidemiology
Harvard T.H. Chan School of Public Health
Professor of Obstetrics, Gynecology and Reproductive Biology, Harvard Medical School

Irva Hertz-Picciotto, PhD, MPH*
Director, UC Davis Environmental Health Sciences Center
Professor, Dept. of Public Health Sciences & Medical Investigations of Neurodevelopmental Disorders (MIND) Institute, University of California, Davis

Deborah Hirtz, MD*
Pediatric Neurologist
Volunteer Professor, University of Vermont
Retired Program Director for Pediatric Neurological Research, NINDS, NIH

Jane Houlihan, MSCE
Research Director
Healthy Babies Bright Futures

Katie Huffling, RN, MS, CNM
Executive Director
Alliance of Nurses for Healthy Environments

Rashmi Joglekar, PhD*
Science Policy Director, Health and Toxics Policy Lab
Department of Epidemiology and Population Health
Stanford University

Arthur Lavin, MD, FAAP
Pediatrician
Cleveland, Ohio

Carmen Marsit, PhD*
Rollins Distinguished Professor of Environmental Health
Emory University Rollins School of Public Health

Pamela Miller, MS
Executive Director
Alaska Community Action on Toxics

Mark Miller MD, MPH*
Director (retired), Children’s Environmental Health Center
California Environmental Protection Agency

Mark A. Mitchell MD, MPH*
Emeritus Professor of Climate Change, Energy, & Environmental Health Equity
George Mason University
Co-chair, Council on Environmental Health and Climate Change, National Medical Association

Rachel Morello-Frosch, PhD, MPH*
Professor, School of Public Health and
Dept of Environmental Science, Policy, and Management
University of California, Berkeley

Beate Ritz, MD, PhD*
Professor of Epidemiology, Environmental Health, and Neurology
Fielding School of Public Health and School of Medicine
University of California Los Angeles

Leslie Rubin, MD*
Assoc. Prof., Dept. of Pediatrics, Morehouse School of Medicine
Co-director, Southeast Pediatric Environmental Health Specialty Unit, Emory University
Founder, Break the Cycle of Health Disparities, Inc.

Susan L. Schantz, PhD*
Professor Emeritus of Toxicology and Neuroscience
Beckman Institute for Advanced Science and Technology
University of Illinois, Urbana-Champaign

Veena Singla, PhD*
Affiliate, Program on Reproductive Health and Environment
University of California San Francisco

Maureen Swanson, MPA
Executive Director, Project TENDR

Julia Varshavsky, PhD*
Assistant Professor, Dept. of Health Sciences, Dept. of Civil Engineering
Northeastern University

R. Thomas Zoeller, PhD*
Professor Emeritus, Biology Department
University of Massachusetts Amherst

Ami Zota, ScD, MS*
Professor, Dept. of Environmental Health Sciences
Mailman School of Public Health, Columbia University

*Affiliations are provided for identification purposes only and do not imply institutional endorsement or support.

Download PDF Letter

https://projecttendr.org/wp-content/uploads/2024/04/Project-TENDR_Plastics-Briefing-Paper_April-2024.pdf

Landmark research review is the first to examine disparities in neurotoxic exposures and the harmful effects of those exposures on children by race, ethnicity, and economic status

WASHINGTON, D.C., September 27, 2023—Children from families with low incomes and families of color are exposed to more neurotoxic chemicals and experience greater harm that impacts brain development and contributes to developmental delays according to a review of more than 200 studies published today in the peer-reviewed journal, Environmental Health Perspectives (EHP). The study is titled “Disparities in Toxic Chemical Exposures and Associated Neurodevelopmental Outcomes: A Scoping Review and Systematic Evidence Map of the Epidemiological Literature.”

Neurotoxic chemicals include but are not limited to lead, particulate matter, organophosphate pesticides, PBDE flame retardants, PCBs, and phthalates in air, water, soil, food, food packaging, and plastics.

“As a result of discriminatory practices and policies, families with low incomes and families of color are currently and historically disproportionately exposed to chemicals without their knowledge or consent where they live, work, play, pray, and learn,” says co-Lead Author Devon C. Payne-Sturges, Project TENDR member and associate professor, University of Maryland School of Public Health. “Their neighborhoods are more likely to be located near factories, chemical plants, superfund sites, highways and more vehicle traffic, or by agricultural fields where pesticides are applied. Our study demonstrates children from families experiencing higher exposures are also experiencing greater health and developmental challenges and that when these exposures are reduced, the neurological health of children of color improves.”

Additional findings confirmed by the author’s analysis of studies that measured neurotoxic exposures by sociodemographic and socioeconomic factors include:
● Low-income and Black children had higher exposures to lead.
● Children in communities of color and low-income communities were more highly exposed to air pollution.
● Black and Hispanic children were exposed to higher levels of organophosphate pesticides.
● Black and Hispanic mothers had higher levels of phthalates — neurotoxic chemicals in everyday plastics such as food and drink packaging, and in personal care products like shampoos and body washes.

The studies that looked further found greater impacts to brain development for those children experiencing high exposures. For example:
● Babies living in economically disinvested neighborhoods in their first year of life and exposed to air pollution were more likely to be diagnosed with autism.
● Low socioeconomic status magnified the harmful effects of lead exposure on children’s cognitive function.
● Air pollution exposures were associated with more adverse Performance IQ scores among children from lower-income families.
● Air pollution exposures were associated with worse memory functioning scores among Hispanic and Black boys with exposure to high prenatal stress.

“We need more stringent environmental standards to address pollution that is disproportionately impacting low-income communities and communities of color,” says co- Lead Author Tanya Khemet Taiwo, Project TENDR member and Bastyr University Midwifery Department assistant professor. “But, it’s just as important that we find a way to improve the unjust systems and social policies that create harmful conditions in the first place. As researchers, we can contribute by better documenting how and why children living in poverty and children of color are suffering the greatest harms. And, researchers and policymakers need to collaborate with communities to learn from their experience and expertise, and support locally-driven solutions.”

Project TENDR, a program of The Arc, is an alliance of more than 50 leading scientists, health professionals, and advocates focused on protecting children from toxic chemicals and pollutants harmful to brain development, and on eliminating disproportionate exposures to children of color and children from low-wealth communities.

The authors of the paper found that despite decades of evidence that families with low incomes and families of color are more highly exposed to neurotoxic chemicals, most researchers failed to examine how race, ethnicity, and economic hardship interact with those exposures to produce differing outcomes. When scientists do investigate those interactions, they find toxic chemical exposures are more strongly associated with learning, attention, and behavior problems for children in families that are also exposed to social and economic adversities. Additionally, the research review yielded a conspicuous lack of studies that examined the exposures and neurodevelopmental outcomes among American Indian, Alaska Native, and Asian American communities.

Numerous environmental justice groups such as the Alaska Community Action on Toxics, Alianza Nacional de Campesinas, and Farmworker Association of Florida, Inc have been collaborating with communities to address the impacts of exposure to toxins. They partner with diverse groups around the country, including Black and Hispanic communities, tribes and Indigenous populations, and farmworker families, to better protect children’s health through shared research and education and collaborative organizing and advocacy.

To complement grassroots initiatives, the authors of the review call on all levels of government to limit, lower, and eliminate existing pollution levels and toxic chemical use (including pesticides); halt locating and permitting new chemical and plastics manufacturing plants in or near communities of color and low-income communities; and enact stronger workplace protections.

“FDA and EPA can act now — not later — to protect families from neurotoxic chemicals by banning phthalates from food contact materials; eliminating lead from residential environments, aviation gas, and children’s foods; ending the use of organophosphate pesticides and setting air pollution standards to protect child brain development,” said Dr. Payne-Sturges, who was a policy specialist at EPA for 12 years.

The study’s authors, all of whom are Project TENDR researchers, reviewed 212 studies spanning five decades from 1974 to 2022. The review included studies that examined children ages 0-18, seven neurotoxic chemicals, and a wide array of neurodevelopmental outcomes.

In addition to the study, EHP published an Invited Perspective, to offer context on the review, from Aisha Dickerson, PhD, MSPH, an assistant professor at Johns Hopkins and researcher who studies environmental exposures and their disproportionate impact on autism and dementia risks in underserved communities across the lifespan.

Project TENDR’s Letter to the Editor, “Lead in Baby Foods,” published in Sunday New York Times, Feb. 5, 2023. Authored by Project TENDR expert on lead and children’s health, Dr. Mark Mitchell, using his National Medical Association affiliation.

Project TENDR’s press release on FDA’s decision in May 2022 to leave 9 phthalates approved for food contact materials, including those with long-standing evidence of neurodevelopmental and reproductive harm, resulted in an article in The Hill quoting Project TENDR expert Dr. Ami Zota.

https://projecttendr.org/wp-content/uploads/2021/10/Project-TENDR-letter_CDC_BLRL-8.2.21.pdf

In a peer-reviewed article published today in the American Journal of Public Health, leading scientists and health professionals of Project TENDR identify ortho-phthalates as neurotoxic chemicals that increase children’s risks for learning, attention, and behavioral disorders. In particular, prenatal exposures to phthalates can contribute to attention problems in children.

The TENDR experts call for swift government and corporate action to eliminate the use of the entire class of ortho-phthalates to protect child brain development. Phthalates are widely used in personal care products and cosmetics, in food packaging and processing equipment, flooring and other building materials. Black and Latina women have higher exposure to phthalates than White women, independent of income level.