Children's health, susceptibility, and regulatory approaches to reducing risks from chemical carcinogens

Risk-based regulation of chemical exposures from the environment generally relies on assumptions about the extent of people's susceptibility to chemically induced diseases. Those assumptions are intended to be health-protective; that is, they err on the side of overstating susceptibility. Recent concern about children's special susceptibilities has led to proposals that would make risk-based regulations one-tenth more stringent, unless data are available to refute the assumption that children are more susceptible than adults. In this paper we highlight some of the questions that should be addressed in the context of risk assessment to determine whether such increased stringency would accomplish the desired result of improving children's health. In particular, characterizing benefits of greater stringency requires more information about dose-response relationships than is currently available. Lowering regulatory levels has attendant costs but may not achieve benefits, for example, if the previous level were already below an actual or practical threshold. Without an ability to understand the potential benefit (or lack thereof) of the additional stringency, an appropriate consideration of benefits and costs is not possible.