A Comprehensive Look at Toxic Chemicals in the Body

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A COMPREHENSIVE LOOK AT TOXIC
CHEMICALS IN THE BODY…
SCIENTIFICALLY VALIDATED.
In a study led by Mount Sinai School of Medicine in
New York, in collaboration with the EWG and
Commonweal, researchers at two major laboratories
found an average of 91 industrial compounds,
pollutants, and other chemicals in the blood and
urine of nine volunteers, with a total of 167
chemicals found in the group. Like most of us, the
people tested do not work with chemicals on the job
and do not live near an industrial facility.
Scientists refer to this contamination as a person’s
body burden. Of the 167 chemicals found, 76 cause
cancer in humans or animals, 94 are toxic to the
brain and nervous system, and 79 cause birth
defects or abnormal development. The danger of
exposure to these chemicals in combination has
never been studied before.
These results represent the most comprehensive
assessment of chemical contamination in individuals
ever performed.
Even so, many chemicals were not included in the analysis that are
known to contaminate virtually the entire U.S. population. Two
examples are Scotchgard and the related family of perfluorinated

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chemicals, and a group of compounds known collectively as
brominated flame retardants.
A more precise picture of human contamination with industrial
chemicals, pollutants and pesticides is not possible because chemical
companies are not required to tell EPA how their compounds are
used or monitor where their products end up in the environment.
Neither does U.S. law require chemical companies to conduct basic
health and safety testing of their products either before or after they
are commercialized. Eighty percent of all applications to produce a
new chemical are approved by the U.S. EPA with no health and
safety data. Eighty percent of these are approved in three weeks.
Only the chemical companies know whether their products are
dangerous and whether they are likely to contaminate people. As a
first step toward a public understanding of the extent of the
problem, the chemical industry must submit to the EPA and make
public on the web, all information on human exposure to commercial
chemicals, any and all studies relating to potential health risks, and
comprehensive information on products that contain their chemicals.
GLOSSARY OF CONTAMINANTS
PCBs —
Industrial insulators and lubricants. Banned in the U.S. in 1976.
Persist for decades in the environment. Accumulate up the food
chain, to man. Cause cancer and nervous system problems.
Dioxins —
Pollutants, by-products of PVC production, industrial bleaching, and
incineration. Cause cancer in man. Persist for decades in the
environment. Very toxic to developing endocrine (hormone) system.

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Furans —
Pollutants, by-products of plastics production, industrial bleaching
and incineration. Expected to cause cancer in man. Persist for
decades in the environment. Very toxic to developing endocrine
(hormone) system.
Metals —
Lead, mercury, arsenic and cadmium — Cause lowered IQ,
developmental delays, behavioral disorders and cancer at doses
found in the environment. For lead, most exposures are from lead
paint. For mercury, most exposures are from canned tuna. For
arsenic, most exposures are from arsenic (CCA) treated lumber and
contaminated drinking water. For cadmium, sources of exposure
include pigments and bakeware.
Organochlorine insecticides.
DDT, chlordane and other pesticides. Largely banned in the U.S.
Persist for decades in the environment. Accumulate up the food
chain, to man. Cause cancer and numerous reproductive effects.
Organophosphate insecticide metabolites —
Breakdown products of chlorpyrifos, malathion and others. Potent
nervous system toxicants. Most common source of exposure is
residues in food. Recently banned for indoor uses.
Phthalates —
Plasticizers. Cause birth defects of male reproductive organs. Found
in a wide range of cosmetic and personal care products. Some
phthalates recently banned in Europe.

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Volatile and Semi-volatile organic chemicals. —
Industrial solvents and gasoline ingredients like xylene and ethyl
benzene. Toxic to nervous system, some heavily used SVOCs
(benzene) cause cancer.
CHEMICALS FOUND IN THE HUMAN BODY
LINKED TO SERIOUS HEALTH PROBLEMS ..
9 PEOPLE TESTED.
Number of chemicals found in
9 people and the health
impact thereto.
HEALTH EFFECT OR
BODY SYSTEMS
AFFECTED
Average
number
found in
9 people
Total
found
in all
9
Range
(lowest
and
highest
number
found
in all 9)
Cancer Causing [1] 53
76
[2]
36 to
65
Birth defects /
developmental delays
55
79
[3]
37 to
68
Vision 5
11
[4]
4 to 7
Hormone system 58
86
[5]
40 to
71
Stomach or intestines 59
84
[6]
41 to
72

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Kidney 54
80
[7]
37 to
67
Brain, nervous system 62
94
[8]
46 to
73
Reproductive system 55
77
[9]
37 to
68
Lungs/breathing 55
82
[10]
38 to
67
Skin 56
84
[11]
37 to
70
Liver 42
69
[12]
26 to
54
Cardiovascular system
or blood
55
82
[13]
37 to
68
Hearing 34
50
[14]
16 to
47
Immune system 53
77
[15]
35 to
65
Male reproductive
system
47
70
[16]
28 to
60
Female Reproductive
System
42
61
[17]
24 to
56
[1] Chemicals listed as linked to cancer are those classified by
the National Toxicology Program as "known" human carcinogens, or
"reasonably anticipated" to be human carcinogens; or those
classified by the Environmental Protection Agency as "known" or
"probable" human carcinogens.

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[2] Cancer: 3 heavy metals, 1 phthalate, 9 organochlorine
pesticides, 8 furans, 7 dioxins and 48 PCBs
[3] Birth defects / developmental delays: 4 heavy metals, 2
phthalates, 7 organochlorine pesticides, 8 furans, 7 dioxins, 48
PCBs and 3 other semivolatile or volatile organic compounds
[4] Vision: 1 heavy metal, 1 phthalate, 2 organochlorine pesticides
and 7 other semivolatile or volatile organic compounds
[5] Hormone system: 4 heavy metals, 5 phthalates, 3
organophosphate pesticides and metabolites, 9 organochlorine
pesticides, 8 furans, 7 dioxins, 48 PCBs and 2 other semivolatile or
volatile organic compounds
[6] Stomach or intestines: 3 heavy metals, 3 phthalates, 2
[7] Kidney: 4 heavy metals, 5 phthalates, 3 organochlorine
[8] Brain, nervous system: 4 heavy metals, 4 phthalates, 7
[9] Reproductive system: 4 heavy metals, 2 phthalates, 8
organochlorine pesticides, 8 furans, 7 dioxins and 48 PCBs

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[10] Lungs/breathing: 4 heavy metals, 3 phthalates, 2
[11] Skin: 3 heavy metals, 5 phthalates, 2 organophosphate
pesticides and metabolites, 4 organochlorine pesticides, 8 furans, 7
dioxins, 48 PCBs and 7 other semivolatile or volatile organic
compounds
[12] Liver: 4 heavy metals, 6 phthalates, 3 organochlorine
pesticides, 48 PCBs and 8 other semivolatile or volatile organic
compounds
[13] Cardiovascular system or blood: 4 heavy metals, 2
phthalates, 2 organophosphate pesticides and metabolites, 7
organochlorine pesticides, 8 furans, 7 dioxins, 48 PCBs and 4 other
semivolatile or volatile organic compounds
[14] Hearing: 1 heavy metal, 48 PCBs and 1 other semivolatile or
volatile organic compound
[15] Immune system: 4 heavy metals, 1 phthalate, 6
organochlorine pesticides, 8 furans, 7 dioxins, 48 PCBs and 3 other
[16] Male reproductive system: 4 heavy metals, 5 phthalates, 2
organochlorine pesticides, 7 dioxins, 48 PCBs and 4 other
[17] Female reproductive system: 2 heavy metals, 2 phthalates,
1 organochlorine pesticide, 7 dioxins, 48 PCBs and 1 other
semivolatile or volatile organic compound

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SOME CHEMICALS ARE ASSOCIATED WITH MULTIPLE HEALTH
IMPACTS, AND APPEAR IN MULTIPLE CATEGORIES IN THE
TABLE ABOVE.
HOW DO TOXIC CHEMICALS END UP IN
PEOPLE?
Scientists refer to the chemical exposure documented here as an
individual’s “body burden” — the consequence of lifelong exposure
to industrial chemicals that are used in thousands of consumer
products and linger as contaminants in air, water, food, and soil.
There are hundreds of chemicals in drinking water, household air,
dust, treated tap water and food. They come from household
products like detergent, insulation, fabric treatments, cosmetics,
paints, upholstery, computers and TVs, and they accumulate in fat,
blood and organs, or are passed through the body in breast milk,
urine, feces, sweat, semen, hair and nails.
(Easton, et al. 2002, EPA 2002d, OECD 2002, Rudel, et al. 2001,
Thornton, et al. 2000, USGS 2002).
We know that:
• U.S. chemical companies hold licenses to make 75,000
chemicals for commercial use. The federal government
registers an average of 2,000 newly synthesized
chemicals each year.
• The government has tallied 5,000 chemical ingredients
in cosmetics; more than 3,200 chemicals added to food;
1,010 chemicals used in 11,700 consumer products; and
500 chemicals used as active ingredients in pesticides
(EPA 1997c, EPA 2002b, EPA 2002c, FDA 2002a, FDA
2002b, FDA 2002c).

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• In 1998 U.S. industries reported manufacturing 6.5
trillion pounds of 9,000 different chemicals
(EPA 2001), and in 2000 major U.S. industries reported
dumping 7.1 billion pounds of 650 industrial chemicals into
our air and water (EPA 2002a).
HOW MANY TOXIC CHEMICALS ARE IN US?
Not known (even this study defines only a fraction of the chemicals
in the nine people tested).
The reason: beyond chemicals that are added to food or used as
drugs, there is no requirement for chemical manufacturers to:
disclose how their chemicals are used or the routes through which
people are exposed; understand the fate of their chemicals in the
environment; measure concentrations of their products in the
environment or in people; or develop and make public analytical
methods that would allow other scientists to gather information.
Companies sometimes develop methods to test for chemicals in the
blood or urine of their workers, but they do not routinely disclose
the methods or results to the government or the public. The
government has spearheaded most of the limited testing that has
been performed for the general population in studies funded by
taxpayers. The government’s studies have not kept pace with the
ever-expanding array of new toxic chemicals. The country’s most
comprehensive program for detecting industrial chemicals in the
human body is run by a government program that reported on 27
chemicals in 2001 (CDC 2001). The chemical industry provided
direct funding for none of this multi-million dollar effort, but instead
paid their trade association’s press office to educate the national
media on the safety of industrial chemicals in the days following the
government’s report release. In their upcoming report on chemical
exposures, CDC is expected to release information on 116
chemicals, or about 70 percent of the number identified in this
study.

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A few types of consumer products, such as cosmetics and home
pesticides, must carry partial ingredient labels so consumers can
make informed choices. Federal law, however, does not require the
chemical industry to disclose ingredients in most household
consumer products, including cleaners, paints and varnishes, and
chemical coatings on clothing and furniture, or the so-called “inert”
ingredients in pesticides, which are typically more than 95 percent of
the retail product. The EPA has compiled a database of more than
1,000 chemicals they believe might be present in 11,700 consumer
products, using data the Agency gathered from chemical
encyclopedias, air sampling studies in the open scientific literature,
and manufacturers. But the companies have classified the chemical
recipes for 9,300 of these products as “confidential business
information.”
The EPA attempts to track local exposures to chemical pollutants
through two testing programs, one for tap water and another for
ambient air. But testing captures only a small fraction of the
chemicals a person is exposed to over the course of a day. At least
165 companies have manufactured the 167 chemicals found in the
test subjects, marketing them under at least 265 trade and
consumer products names (Table 3). By contrast, some local and
state air monitoring programs track only five chemical contaminants,
most of them linked to automobile exhaust. Water suppliers test tap
water for 70 contaminants, but the list excludes hundreds of
chemicals known to contaminate public water supplies [e.g., (USGS
2002)].
RESEARCHERS WARN CONSUMERS ABOUT
HAZARDOUS INGREDIENT IN NAIL POLISH
Growing Scientific Concern About Dibutyl Phthalate (DBP),
Reproductive Age Women and Links to Birth Defects

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WASHINGTON — The EWG today released Beauty Secrets, the
first-ever consumer alert on beauty products that contain dibutyl
phthalate (DBP), a chemical coming under growing scientific
scrutiny because of high levels found in reproductive age women
and possible risks of birth defects.
Scientific concerns about DBP's risks increased recently after a
Centers for Disease Control (CDC) study this fall unexpectedly
found DBP in the bodies of every single person they tested, with
the highest levels in reproductive-age women, the group most at
risk. Scientists are concerned about DBP and reproductive age
women because the chemical causes severe birth defects in lab
animals. According to lab animal studies, DBP can harm nearly
every physical structure in the developing male reproductive
system. The effects include testicular atrophy, absent testes and
reduced sperm count.
Major loopholes in federal law allow cosmetics manufacturers to put
unlimited amounts of industrial chemicals like DBP into personal
care products with no required testing of monitoring for adverse
effects. EWG's initial investigation suggests that DBP is found in
about a third of the nail polishes currently on the market, as well as
a variety of other cosmetic products.
"It's buyer beware when it comes to cosmetics," said Jane
Houlihan, Senior Analyst for EWG and principal author of Beauty
Secrets. "Women who are considering becoming pregnant, or who
are pregnant or nursing, should avoid using any products
containing DBP."
To better identify consumer sources of DBP, the EWG shopped at a
local Rite-Aid, surfed the on-line store Drugstore.com, and
searched the U.S. patent office records for products that contain
DBP in the patent application. EWG found:
• DBP in 37 popular nail polishes, topcoats, and
hardeners, including products by L’Oréal, Maybelline, Oil
of Olay, and Cover Girl (Table 1).

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• Patents proposing to use DBP in a broad range of beauty
and personal care products, including shampoos and
conditioners, lotions, hair growth formulations,
antiperspirants, and sunscreen. Even patents relating to
gum, candy, and pharmaceuticals taken orally propose
DBP as an ingredient.
• Many major manufacturers who propose to use DBP in
cosmetics and related products. Of more than 100
patents analyzed by EWG, Procter & Gamble holds the
most (37) that propose to use DBP in personal care
products. Other major companies with multiple patents
are L’Oréal (10), Lever Brothers (4), and Maybelline (3).
The CDC has postulated that one of the routes of DPB exposure in
young women would be cosmetics and personal care items. DBP is
used to help nail polish form an even film as it dries, as a
consistency enhancer to keep products blended, and as an
ingredient to help cosmetics penetrate the skin. It can be absorbed
through the skin or inhaled as a product is applied.
EWG is a nonprofit environmental research organization with offices
in Washington DC , Seattle WA, and Oakland CA.
ARE YOUR BEAUTY PRODUCTS KILLING YOU?
A new report linking birth defects and health risks with a chemical
used in trendy cosmetics, gives a long overdue wake-up call to the
FDA, consumers and the beauty industry.
If you got out of the shower this morning, blow-dried your hair and
gave your 'do a spritz of VO5 hairspray, you've just poisoned
yourself. If you do this every morning as your regular routine, you
are accumulating these poisons by the bucketful.
But it's not just VO5 that could make you sick. Try Secret Sheer Dry
deodorant, or the suitably named Poison, a perfume by Christian

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Dior. In fact, 52 popular cosmetics are now proven to have toxic
components in varying concentrations -- and they're all over the
place.
A report released jointly July 10 by Coming Clean, the EWG and
Health Care Without Harm details the extent to which a toxic family
of chemicals known as phthalates (THAY-lates) are used in everyday
household products, especially beauty products like nail polish,
lipstick and perfumes.
The report, titled "Not Too Pretty: Pthalates, Beauty Products and the
FDA," has its basis in a 1999 FDA study of toxins in the general
population of the U.S. From a sample of 1,029 people, every one of
them tested positive for phthalates in their blood or urine. Scientists
at the Centers for Disease Control singled out a subgroup of 289
people with a particularly high incidence of phthalates: women of
childbearing age. These women were found to have daily exposures
of phthalates ranging from 2.5 to 22 times the normal for the rest of
the general population, with 5 percent showing levels of 75 percent or
higher of the acceptable daily amounts.
Judging from the 5 percent of women with dangerously high test
results, it can be assumed that every day, as many as 2,000,000
women of childbearing age are exposed to toxic levels of phthalates.
Phthalates have been shown to cause a wide array of health
problems, from liver and kidney failure to heart, lung and blood
pressure problems. The most worrisome aspect by far is the
phthalates' effect on the reproductive development of fetuses and
infants, particularly the reproductive tracts of males.
Phthalates are metabolized in humans once ingested or absorbed
through the skin. In pregnant women, phthalates pass through the
placenta to be absorbed by the fetus. In nursing women, phthalates
are found in breast milk, which means infants are ingesting these
chemicals as they develop. In male fetuses -- and infants especially -
- the phthalates have been shown to cause testicular atrophy and a
reduced sperm count, among other serious health problems.

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Dr. Stephen Safe of Texas A&M University notes that some in the
medical community have expressed concerns about phthalate
exposure and human health. "It's hard to be specific until more
medical data is available," Dr. Safe says, "but if people have
concerns, they should limit their use of these products."
The HCWH report is the first to document and link the deleterious
effects of phthalates to male reproductive development. Women of
childbearing age were shown to be the most at-risk demographic, and
it is reasonable to attribute this in large part to one fact: the beauty
industry. According to Charlotte Brody, executive director of HCWH,
"With all the variables involved, the only one that doesn't apply on a
large scale to both men and women is the use of cosmetics."
Global Pollutants
Phthalates are plasticizers. In cosmetics, they are used to add texture
and luster to the product. Ninety percent of the world's plasticizers
are used to soften PVC (vinyl) and make it pliable. The other 10
percent have been used in many kinds of manufacturing for 30 years,
beginning with medical products like IV bags, gloves and blood bags,
but also paints, lubricants, adhesives, toys, food containers, and, of
course, cosmetics.
The use of phthalates in manufacturing is widespread, and has such a
long history that phthalates have wormed their way into every corner
of the globe. Traces are present in virtually every person on the
planet. The phthalate DEHP has been found in Antarctica and in deep-
sea jellyfish 3,000 feet below the ocean's surface.
Different phthalates can be found in consumer products like shower
curtains, umbrellas, adhesives, children's toys, and countless other
manufactured goods. PVC, being incredibly cheap to produce, is the
preferred product for the world's manufacturers. With phthalates, you
can easily turn PVC into any number of products.

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Since the FDA does not regulate the use of pthalates in cosmetics and
beauty aids, manufacturers are not required to disclose them as
ingredients.
Says the report: "Taken as a whole, the lab results indicate that a
substantial fraction of cosmetics companies may be hiding phthalates
on store shelves within the containers of their products, with no
warning for pregnant women who might want to avoid purchasing
products that contain chemicals linked to birth defects."
DEHP, the primary phthalate found in medical supplies, has been
found toxic in studies of patients who spend considerable amounts of
time in hospitals, mainly newborns and the elderly. But other
phthalates, including DEP, DBP, BBP, DCP, DOP and DINP, were last
studied nearly 20 years ago.
According to FDA spokesperson Kimberly Rawlings, "Phthalates were
shown to be safe for topical use in 1984, and there have been no
further studies by the FDA on this subject since then."
In a recent Dallas Morning News story on phthalates and the
cosmetics industry, Rod Irvin, a spokesman for the American
Chemistry Council's Phthalate Esters Panel, said that "[p]hthalates
are among the most-studied products out there. They have a long
record of safe use, with no reports or evidence of harm to human
health." Additionally, the industry group has spent "millions" studying
the compounds and has found no reason for concern.
In November 2000, the Environmental Working Group released a
report that stated, "Phthalates are recognized as toxic substances
under environmental law, but companies are free to use unlimited
amounts in cosmetics."
The FDA in the past has considered each of these phthalates
separately when studying their toxicity. If you're a dialysis patient,
then you're at risk for poisoning because you're getting twice the
amount of DEHP recommended with each visit. That's bad. But if
you're a dialysis patient and you wear a lot of makeup and spend a

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lot of time playing with your grandchildren and their toys, your
exposure could be deadly.
Not in the many-faceted eyes of the FDA, though. Its consideration of
disparate exposure to phthalates is the main loophole manufacturers
use to claim that phthalates are safe. Without recognizing that all
members of the phthalate family accumulate to cause the same
health problems, phthalate manufacturers are able to claim that each
individual chemical is not harmful at the documented levels.
HCWH tested 72 of the following kinds of cosmetics: Nail polish,
fragrances (perfumes, body oils, etc.), hairsprays, deodorants and
lotions. Fifty-two of these contained phthalates as ingredients, though
none were listed on the labels. Most of the pthalate-containing
products are household names: Aqua Net Professional Hair Spray;
Degree Original Solid Deodorant; Nivea Créme lotion; Elizabeth
Arden's Red Door fragrance; Calvin Klein's Eternity perfume.
As Brody of HCWH points out, this is just the beginning: "It's
impossible to know without testing which products contain
phthalates. Just because some of the lotions we tried tested negative
doesn't mean [all lotions are] clean." Until the manufacturers are
required to label phthalates, there's no way to know for sure.
Early Warnings
This is only the latest in a long series of warnings about the dangers
of phthalates, which have been used extensively since the early
1970s. The biggest commotion over phthalates came in 1998, when
the Danish government issued a well-publicized ban on toys
containing phthalates because of concern that children were being
exposed to toxic chemicals when they put toys in their mouths. Lego,
the Danish toymaker, quickly responded by reformulating its toy
factories to phase out the use of phthalates in production of its toys.
Since then, there has been steadily growing awareness of the
dangers of phthalates. Network news programs have discussed the
dangers in toys, cosmetics and beauty products, and even in fish that
live in polluted waters. Despite all this, the battle against phthalates

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has been a stalemate: The EU continues to extend its temporary ban
on toys for children aged 3 and under, but European manufacturers
are lobbying to institute a voluntary reporting system for all other
products similar to what is in place in the U.S.
Stacy Malkan of HCWH is urging people to distribute the lists of
phthalate-containing products far and wide, to discuss the topic of
phthalates in cosmetics and medical supplies with their health care
provider, and to contact the FDA to demand an industry-wide ban on
phthalates in cosmetic products. In addition, the groups releasing the
report are preparing to launch a national ad campaign.
As the report makes clear, non-toxic alternatives are readily
available: "The limited testing done for Not Too Pretty reveals that
the same big companies that produce phthalate-laced beauty
products, also make similar products without phthalates ... L'Oreal
markets Jet Set nail polish without DBP but puts the phthalate in its
Maybelline brand."
Without public pressure, however, there will be no incentive for the
$20 billion-a-year cosmetics industry to phase out all phthalates. And
women who continue to douse themselves in Christian Dior's Poison
may be helping the perfume live up to its name.
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Roe D, Pease W, Florini K, and. Silbergeld E. 1997. Toxic
Ignorance. Environmental Defense. Washington DC. Summer 1997.
Sainio EL, Engstrom K, Henriks-Eckerman ML, Kanerva L. 1997.
Allergenic ingredients in nail polishes. Contact Dermatitis
Oct;37(4):155-62.
Swan SH, Elkin EP, Fenster L. 2000. The question of declining
sperm density revisited: An analysis of 101 studies published 1934-
1996. Environmental Health Perspectives. 108(10). October 2000.
Toppari, J, Larsen JC, Christiansen P, Giwercman A, Grandjean P,
Guillette Lj Jr, Jegou B, Jensen, TK, Jouannet P, Keiding N, Leffers
H, McLachlan JA, Meyer O, Muller J, Meyts, E R-D, Scheike T,
Sharpe R, Sumpter J, Skakkebaek NE. August 1996. Male
reproductive health and environmental xenoestrogens.
Environmental Health Perspectives. 104. Supplement 4.
Wine R, Li L_H, Barnes LH, Gulati DK, Chapin RE. 1997.
Reproductive toxicity of di-n-butyl phthalate in a continuous
breeding protocol in Sprague-Dawley rats. Environ Health Perspect
105:102-107 91997).
CCAANN LLOOWW DDOOSSEESS OOFF SSYYSSTTEEMMIICC,, TTOOXXIICC
CCHHEEMMIICCAALLSS HHUURRTT MMEE??
Hundreds of studies in the peer-reviewed literature show that
adverse health effects from low dose exposures are occurring in the
population, caused by unavoidable contamination with PCBs, DDT,
dioxin, mercury, lead, toxic air pollutants, and other chemicals. The
health effects scientists have linked to chemical exposures in the
general population include premature death, asthma, cancer, chronic
bronchitis, permanent decrements in IQ and declines in other
measures of brain function, premature birth, respiratory tract
infection, heart disease, and permanent decrements in lung capacity
(EPA 1996, EPA 2000, Gauderman, et al. 2002, Jacobson and
Jacobson 2002, Jacobson, et al. 2002, Kopp, et al. 2000,

21
Longnecker, et al. 2001, NAS 2000, NTP 2002, Pope, et al. 2002,
Salonen, et al. 1995, Sydbom, et al. 2001).
A growing body of literature links low dose chemical exposures in
animal studies to a broad range of health effects previously
unexplored in high dose studies. In low dose testing, scientists are
using sophisticated techniques to measure subtle but important
changes in the functioning of apparently undamaged organ systems,
including alterations in immune function (such as antibody
response), enzyme activity, hormone levels, cellular changes in
tissues, neurobehavioral parameters, organ growth, and hormone
and neurotransmitter receptor levels. Importantly, many low dose
effects are detected following developmental exposure. These tests
focus on the effects of chemical exposures comparable to those that
occur in the general population, and far below the levels that have
traditionally been considered safe based on the results of studies
that feed lab animals high doses of a given compound. Using these
protocols, scientists are finding that low doses of chemicals can be
far more harmful than previously believed.
Low dose studies often identify toxic effects at levels far below those
identified as the “no effect” level in high dose studies. For instance,
through low dose studies of bisphenol A (BPA), a plasticizer chemical
commonly used in dental sealants and plastic water bottles,
scientists have revealed health effects at levels 2,500 times lower
than EPA’s “lowest observed effect” dose, with adverse outcomes
ranging from altered male reproductive organs and aggressive
behavior, to abnormal mammary gland growth, early puberty, and
reduced breast feeding.
In the face of a powerful and growing body of literature linking low
dose chemical exposures and health harms in the general
population, the chemical industry continues to claim that low dose
exposures to hundreds of chemicals simultaneously is safe. These
claims, however, are nearly always based on a lack of scientific
information on the toxicity of low-dose exposures, not on a
definitive, scientific proof of safety.
High dose animal studies provide the foundation for federal exposure
limits for contaminants in consumer products, drinking water, food,

22
and air. Indeed, the nation’s regulatory system for chemical
exposures is dependent on the notion that high dose studies will
reveal completely, the toxic properties of a chemical being tested.
We now know that this is not true. A number of factors, each of
which can be as important as the exposure dose, determine a
compound's toxicity:
• Timing. The timing of a dose can often determine the
toxicity of the chemical. Low dose chemical exposures
during fetal development or infancy are known to
produce more serious toxic effects than similar
exposures during adulthood for many chemicals. Lead
and mercury are the classic examples, where low dose
exposures in utero and during infancy cause permanent
brain and nerve damage, while the same doses cause no
observable effects in adults. Few high dose studies, with
the exception of those required for food use pesticides,
target vulnerable periods of development. Most high
dose studies include only adult animals. Low dose
studies almost always involve exposures in utero,
through multiple generations, and into old age.
• Genetic vulnerability. Some people are more
susceptible to environmental contaminants because of
genetic factors. For example, EPA-funded research has
documented a 10,000-fold variability in human
respiratory response to airborne particles (including
allergens and pharmaceuticals) (Hattis, et al. 2001).
This variability explains, in part, why we all breathe the
same air, but not all of us have asthma attacks.
Laboratory animal studies, often conducted with
genetically uniform animals, cannot reveal genetically
induced adverse effects that may occur in a small but
significant percentage of a highly diverse human
population.

23
• Mechanisms and unexpected results. Chemicals
produce a spectrum of health effects that can both vary
with dose, and affect the target organ in different ways
depending on dose. For instance, some chemicals
produce opposite effects at high and low doses – a
phenomenon called biphasic dose response. Some
produce different effects at high and low doses. Some
produce adverse effects at low doses, but not at higher
doses. DES, a potent synthetic estrogen, has been
shown to stimulate prostate growth at 0.02, 0.2, and 2
mg/kg-day, but inhibit prostate growth at doses of 100
and 200 mg/kg-day (vom Saal, et al. 1997).
Perchlorate, a component of rocket fuel that
contaminates drinking water, causes changes in the size
of certain parts of the brain at 0.01 – 1 mg/kg-day, but
not at 30 mg/kg-day (Argus 1998). Current government
testing regimes do not require tests to define different
effects of chemicals across a wide range of doses.
WWHHAATT AARREE TTHHEE PPOOSSSSIIBBLLEE HHEEAALLTTHH EEFFFFEECCTTSS
OOFF LLOOWW DDOOSSEE EEXXPPOOSSUURREESS TTOO TTOOXXIICC
CCHHEEMMIICCAALLSS??
Health professionals are not trained to link health problems to an
individual’s chemical exposure, but it is increasingly evident that
background exposures to industrial chemicals and pesticides are
contributing to a portion of the steady increase in some health
problems in the population.
Cancer.
Between 1992 and 1999, cancer incidence increased for many forms
of the disease, including breast, thyroid, kidney, liver, abdominal
cavity connective tissue, skin and some forms of leukemia. The
incidence of childhood cancer increased by 26 percent between 1975
and 1999, with the sharpest rise estimated for brain and other
nervous system cancers (50 percent increase) and acute

24
lymphocytic leukemia (62 percent increase). The incidence of
testicular cancer also rose between 1973 and 1999 (NCI 2002). The
probability that a US resident will develop cancer at some point in
his or her lifetime is 1 in 2 for men and 1 in 3 for women (ACS
2001). Just 5 to 10 percent of all cancers are linked to inherited,
genetic factors (ACS 2001). For the remainder, a broad array of
environmental factors play a pivotal role.
• This study found 79 carcinogens in nine people. On
average, each study participant contained 53 chemical
carcinogens.
Major nervous system disorders.
Several recent studies have determined that the reported incidence
of autism is increasing, and is now almost 10 times higher than in
the mid-1980’s (Byrd 2002, Chakrabarti and Fombonne 2001, Yang,
et al. 2000). The number of children being diagnosed and treated for
attention deficit disorder (ADD) and attention deficit hyperactivity
disorder (ADHD) has also increased dramatically in the past decade
(Robison, et al. 1999, Robison, et al. 2002, Zito, et al. 2000). The
causes are largely unexplained, but environmental factors, including
chemical exposures, are considered a potential cause or contributor.
Environmental factors have also been increasingly linked with
Parkinson’s disease (Checkoway and Nelson 1999, Engel, et al.
2001).
• This study found 94 nervous system toxins in nine
people. On average, each study participant contained 62
nervous system toxins.
Defects of the reproductive system.
Studies show that sperm counts in certain parts of the world are
decreasing (Swan, et al. 2000, Toppari, et al. 1996). Scientists have
measured significant regional differences in sperm count that cannot
be explained by differences in genetic factors (Swan, et al. in press).
Girls may be reaching puberty earlier, based on comparing current

25
appearance of breast development and pubic hair growth with
historical data (Herman-Giddens, et al. 1997). Incidence of
hypospadias, a birth defect of the penis, doubled in the United
States between 1970 and 1993, and is estimated to affect one of
every 125 male babies born (Paulozzi, et al. 1997). The incidence of
undescended testicles (cryptorchidism) and testicular cancer also
appear to be rising in certain parts of the world (Bergstrom, et al.
1996, McKiernan, et al. 1999, Toppari, et al. 1996). Testicular
cancer is now the most common cancer in men age 15 to 35 [NCI
(National Cancer Institute), 2000 #244]. Several studies have
suggested links between developmental exposure to environmental
contaminants and cryptorchidism or testicular cancer (Hardell, et al.
in press, Hosie, et al. 2000, Toppari, et al. 1996, Weidner, et al.
1998).
• This study found 77 chemicals linked to reproductive
damage in nine people. On average the nine subjects
contained 55 reproductive toxins.
AARREENN''TT TTHHEESSEE CCHHEEMMIICCAALLSS TTEESSTTEEDD??
Although most people assume that chemicals in consumer products
are thoroughly tested before they are sold, there is no legal
requirement to test most chemicals for health effects at any stage of
production, marketing, and use.
Under the Toxic Substances Control Act, chemical companies can
continue making chemicals and putting new compounds on the
market without conducting any studies of their effects on people or
the environment. Some companies conduct rudimentary screening
studies prior to production, but fewer than half of all applications to
the EPA for new chemical production include any toxicity data at all.
The government approves 80 percent of these applications with no
restrictions, usually in less than three weeks. When data are
provided, they are typically cursory in nature, because the
government lacks authority to request anything more than that.
Eight of 10 new chemicals win approval in less than three weeks, at

26
an average rate of seven a day. If there are no data, the
government justifies approval with results of computer models that
estimate if a chemical will harm human health or the environment
(EPA 1997a, GAO 1994).
For chemicals that are already on the market, the EPA can request
data only when it can substantiate that the chemical is causing
harm, which it generally cannot do without the toxicity data it is
seeking to request. In practice, this means that studies are required
only after independent scientists have accumulated a body of
evidence demonstrating potential harm, a process that typically
takes decades.
In general, the more recently a chemical has been introduced into
commerce, the less scientists understand its toxicity, and the less
likely it is that scientists will know how to test for it in people and
the environment. The few chemicals or chemical families that have
been well-studied are those for which scientists uncovered, often
accidentally, environmental catastrophes that can include
widespread pollution of the environment or human population.
WWHHAATT MMUUSSTT TTHHEE CCHHEEMMIICCAALL IINNDDUUSSTTRRYY
DDOO??
The chemical industry tightly controls the testing and the
information flow on any issue related to their products. Chemical
companies are not required to prove the safety of their products or
disclose methods that could be used to test for their chemicals in the
environment or the human body.
Typically only after a compound has been on the market for
decades, and has contaminated a significant portion of the
environment, do independent scientists learn how to detect and
quantify it. At that point, the Centers for Disease Control and
Prevention (CDC) may choose to include the chemical in its national
biomonitoring program. Even then there is no guarantee that the
manufacturer will provide CDC with the methodology to detect it, or
that the methods will be reliable. For example, three years after 3M

27
announced that it was removing perfluorinated chemicals in
Scotchgard from the market, chiefly because 3M found that the
human population is widely contaminated with the chemicals, the
CDC has yet to develop a method it considers reliable that would
allow it to add the chemicals to its national biomonitoring program.
At a minimum, people have a right to know what chemicals are in
their bodies and what harm they might cause. The sole source of
this information is the chemical manufacturers themselves, who
historically have not provided it to government officials even as they
have resisted efforts to make the information public.
Without disclosure of information on the environmental fate, human
contamination, and health effects of these chemicals, regulators
cannot effectively prioritize efforts to reduce the health risks from
the current contaminant load in the human population.
Regardless of whether or not Congress revises the nation’s laws or
policies:
• The chemical industry must submit to EPA and make
public on individual company web sites, all internal
studies on the properties, environmental fate, potential
human exposure pathways and exposure levels,
concentrations in workers and the general population,
levels in the environment, worker and community
health, measured effects in wildlife, toxicity,
mechanisms of action and any other information
relevant to human exposures and potential health effects
for all chemicals reasonably likely to be found in people,
drinking water, or indoor air.
WWHHAATT SSHHOOUULLDD TTHHEE GGOOVVEERRNNMMEENNTT DDOO??
This study, combined with work from the Centers for Disease Control
and Prevention, and a thorough review of the scientific literature
reveal a ubiquitous and insidious pollution of the human population
with hundreds of chemicals, pollutants, and pesticides. In large

28
measure this is the result of a regulatory system that leaves the EPA
with few tools to study the health effects or the extent of human
exposure to the thousands of chemicals found in consumer products.
Revisions to the nation’s laws and policies governing chemical
manufacture and use include the following provisions:
• Industry must be required to prove the safety of a
chemical before it is put on the market.
• The EPA must have the unencumbered authority to
request any and all new data on a chemical that is
already on the market.
• The EPA must have the clear authority to suspend a
chemical’s production and sale if the data requested are
not generated, or if they show that the chemical, as
used, is not safe for the most sensitive portion of the
exposed population.
• Chemicals that persist in the environment or bio-
accumulate in the food chain must be banned.
• Chemicals found in humans, in products to which
children might be exposed, in drinking water, food, or
indoor air, must be thoroughly tested for their health
effects in low dose, womb-to-tomb, multi-generational
studies focused on known target organs, that include
sensitive endpoints like organ function and cognitive
development. Studies to define mechanisms of action
(how a chemical harms the body) must be conducted.
• The chemical industry must develop and make public
analytical methods to detect their chemicals in the
human body, and conduct bio-monitoring studies to find
the levels of their chemicals in the general population.

29
• Chemical manufacturers must fully disclose the
ingredients of their products to the public.
TTHHEE RREEGGUULLAATTOORRYY PPRREECCEEDDEENNTT OOFF
PPEESSTTIICCIIDDEESS
At first blush these statutory changes appear a radical departure
from current policies, but in fact, the chemical industry already
complies with these standards for pesticide products, proof that the
industry can meet the same safety standards with commercial
chemicals.
Pesticides in food are regulated under section 408 of the Food Drug
and Cosmetic Act, which requires chemical companies to show that
there is a “reasonable certainty of no harm” from exposure to a
pesticide, for all exposed individuals, including explicit consideration
of the fetus, infant and small child. This standard, which is well
defined in case law and regulations, applies to all uses and all routes
of exposure to a pesticide (food, air, and water considered
together). “Reasonable certainty of no harm” is protective of the
public health, particularly where the finding is contingent on fetal
and infant exposure, but is not so protective that it cannot be met,
or that companies can argue that it is onerous.
Section 408 also requires that pesticides with common mechanisms
of toxicity be added together when assessing compliance with the
reasonable certainty of no harm standard. This means that groups of
pesticides, for example, all organophosphates, are added together
when measuring compliance. In contrast, TSCA does not require that
regulators assess the additive risks. Many major chemical classes
commonly used in consumer products are characterized by common
mechanisms of toxicity - phthalates, perfluorinated chemicals, and
polybrominated diphenyl ethers, for example - and none are
assessed in aggregate by EPA.
When data are not available, legal exposures for infants and children
are required to be 10 times lower than for adults, and economic

30
benefits are not allowed as an escape valve, or a means to permit
higher risk.
To ensure that these tough standards can be met, the other
governing statute, FIFRA (the Federal Insecticide Fungicide and
Rodenticide Act), grants the EPA administrator broad (virtually
unlimited) authority to request data, and to suspend the sale of the
product when data are not generated (section 3, particular 3(c)2(B),
and section 6).
The legislative history of FIFRA is instructive. Beginning in the early
1980’s a series of congressional committee investigations and GAO
reports documented that basic health studies had not been
conducted for most pesticides on the market at that time. In
response, Congress amended FIFRA in 1988 to require that all
pesticides be “re-registered,” which meant that they had to be
tested by contemporary standards and re-evaluated for their health
risks.
This forced the EPA to deal with the same problem that they face
today when considering a comprehensive testing program for toxic
chemicals: what to do with all the chemicals already on the market?
EPA’s response, which largely was successful, albeit slow, was to
impose strict timelines for testing and re-evaluation while granting
EPA clear authority to require any test for any pesticide, and the
authority to suspend the sale of a pesticide if the manufacturer
refuses to do the test or fails to submit it on time. Compare this with
TSCA where EPA must go through a rulemaking just to get one test
on one chemical.
As a result of these amendments, EPA now requires about 120 tests
for pesticide registration. These tests range from acute and chronic
toxicity, to metabolism, environmental fate and residue chemistry.
These tests include toxicity tests that will support regulatory decision
making, not the superficial screening tests being conducted under
the HPV testing program. EPA has reevaluated nearly all pesticides
of any significance, starting in the early 1990’s with more than 100

31
pesticide active ingredients in about 20,000 different products
applied to food crops. There is no reason that these same test
requirements could not be applied in a tiered fashion to commercial
chemicals regulated under TSCA.
Testing requirements alone have driven many compounds from the
market. One good example is methoxychlor, a DDT relative, which
was banned with little fanfare in 1999 when the manufacturer simply
refused to conduct required health studies. Another good example is
pesticides used in aircraft cabins. In 1995 EPA asked all
manufacturers of pesticides applied inside commercial airplanes to
do the exposure studies needed to show the use was safe. Not a
single manufacturer of more than 200 products was willing to do the
tests (because they knew that the use was not safe), and all uses of
pesticides inside aircraft were unceremoniously banned in the United
States in 1998.
Another great example of the power of FIFRA’s data generation
authority involves the toxic byproducts of chlorinating tap water. The
Safe Drinking Water Act does not give the EPA authority to require
toxicity tests for drinking water contaminants. As a result, the
agency is forced to negotiate test programs with polluters or the
affected industry, or to pay for the testing from their own research
funds. But because chlorine is a pesticide (it kills microbes in water),
EPA was able to use the data call-in authority of FIFRA to require the
chlorine industry to do a broad range of toxicity tests on chlorination
byproducts that they otherwise had not planned to do.
WWHHAATT CCAANN YYOOUU DDOO??
Some exposures to pesticides and industrial chemicals are
unavoidable. Persistent pollutants, some banned for decades, still
contaminate the environment and end up in the food we eat, the
water we drink, and the air we breathe.
Yet even exposures to persistent pollutants can be reduced through
a varied diet that contains fewer meat and high fat dairy products.

32
Other chemical exposures, like toxic substances in household
cleaners, can be avoided altogether.
SOME SIMPLE TIPS FOR REDUCING EXPOSURES
TO INDUSTRIAL CHEMICALS ARE:
• Eat fewer processed foods, which often contain chemical
additives.
• Eat organic produce. It's free of pesticides and
preservative chemicals.
• Don't microwave food in plastic containers, use glass or
ceramics.
• Run your tap water through a home filter before
drinking. Filters can reduce levels of common tap water
pollutants.
• Eat fewer meat and high fat dairy products, which
contain higher levels of some pollutants.
• Reduce the number of cosmetics and other personal care
products you use, which can contain harmful chemicals
and can be sold with no safety testing.
• Avoid artificial fragrances.
• Don’t use stain repellants on clothing, bedding or
upholstery.
• Reduce the number of household cleaners you use. Try
soap and water first.
• Avoid using gasoline-powered yard tools - use manual or
electric tools instead.

33
• Avoid breathing gasoline fumes when you're filling your
car - sit inside the car, for instance.
• Eat seafood known to be low in PCB and mercury
contamination, including wild Alaska salmon and canned
salmon. Avoid canned tuna - it contains mercury.
• Adopt a diet of cleansing, alkaline foods
• Eat mineral-rich foods
Particularly if you're pregnant, try to follow the tips listed above. Is
there someone in your household who can take over using
household cleaners and pumping gas while you're pregnant? Eat
canned salmon instead of canned tuna. Paint the baby room well
before you conceive. Don't use nail polish, which contains chemicals
linked to birth defects in laboratory studies.
FFIIRRSSTT--TTIIMMEE MMOOMMSS WWIITTHH AA NNEEWW BBAABBYY ……
GGEETT TTEESSTTEEDD!!
If you are a first-time mom, at least six-months pregnant or with a
newborn baby, you can volunteer to participate in an important
scientific study to identify levels of industrial chemicals in breast
milk. Widely considered the very best food for babies, breast milk
also carries traces of industrial pollutants that bind to breast milk
fat. With funding from philanthropic foundations, we have initiated a
study with a major national laboratory to test a limited number of
breast milk samples from first-time moms, for a number of industrial
chemicals that concern scientists, including brominated flame
retardants. Would you be interested in participating in this scientific
study? The cost to you is nothing. Your results would be anonymous,
used in scientific publications, and your participation could advance
science and regulatory policy in ways that could make breast milk an
even better source of nutrition for babies.

34
DOCUMENTED REFERRENCES AND PERTINENT
STUDIES LINKING SYSTEMIC TOXINS AND
CHEMICALS TO DEGENERATIVE ILLNESSES:
1. Akhtar, N, SA Kayani, MM Ahmad and M Shahab. 1996.
Insecticide-induced changes in secretory activity of the
thyroid gland in rats. J Appl Toxicol 16(5): 397-400.
2. ATSDR (Agency for Toxic Substances and Disease
Registry). 1992. Toxicological profile for 2-hexanone:
Health effects chapter. Available online at
http://www.atsdr.cdc.gov/toxpro2.html#Final.
Registry). 1994a. Toxicological profile for chlordane:
Registry). 1994b. Toxicological profile for
chlorodibenzofurans (CDFs): Health effects chapter.
Available online at
Registry). 1994c. Toxicological profile for
hexachlorocyclohexanes: Health effects chapter.
Available online at
Registry). 1995a. Toxicological profile for diethyl

35
phthalate (DEP): Health effects chapter. Available online
at http://www.atsdr.cdc.gov/toxpro2.html#Final.
Registry). 1995b. Toxicological profile for mirex and
chlordecone: Health effects chapter. Available online at
Registry). 1995c. Toxicological profile for xylenes:
Registry). 1997. Toxicological profile for di-n-
octylphthalate (DNOP): Health effects chapter. Available
online at http://www.atsdr.cdc.gov/toxpro2.html#Final.
Registry). 1998a. Toxicological profile for chlorinated
dibenzo-o-dioxins (CDDs): Health effects chapter.
Available online at
Registry). 1998b. Toxicological profile for chlorpyrifos:
Registry). 1999a. Toxicological profile for cadmium:
Registry). 1999b. Toxicological profile for ethylbenzene:

36
Registry). 1999c. Toxicological profile for lead: Health
effects chapter. Available online at
Registry). 2000a. Toxicological profile for arsenic: Health
effects chapter. Available online at
Registry). 2000b. Toxicological profile for polychlorinated
biphenyls (PCBs): Health effects chapter. Available
Registry). 2001. Toxicological profile for
pentachlrophenol: Health effects chapter. Available
Registry). 2002a. Toxicological profile for DDT, DDE,
DDD: Health effects chapter. Available online at
hexachlorobenzene: Health effects chapter.
Registry). 2002c. Toxicological profile for methoxychlor:
Health effects chapter. Availble online at

37
21. Bernard AM, de Russis R, Normand JC, Lauwerys RR.
1989. Evaluation of the subacute nephrotoxicity of
cyclohexane and other industrial solvents in the female
Sprague-Dawley rat. Toxicol Lett 45:271-80.
22. BIBRA (The British Industrial Biological Research
Association). 1988. Toxicity profile for cetylpyridinium
chloride (CPC).
23. Blount BC, Silva MJ, Caudill SP, Needham LL, Pirkle
JL, Sampson EJ, Lucier GW, Jackson RJ, Brock JW. 2000.
Levels of seven urinary phthalate metabolites in a
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IC, Rasmussen RK, Schmidt M, Greve T. 2001. Endocrine
disrupting compounds: effect of octylphenol on
reproduction over three generations. Theriogenology
55:131-50.
25. Boockfor FR, Blake CA. 1997. Chronic administration
of 4-tert-octylphenol to adult male rats causes shrinkage
of the testes and male accessory sex organs, disrupts
spermatogenesis, and increases the incidence of sperm
deformities. Biol Reprod 57:267-77.
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toxicological summary. Department of Pesticide
Regulation Medical Toxicology Branch. Available online
at
http://www.cdpr.ca.gov/docs/toxsums/toxsumlist.htm.
27. California Department of Pesticide Regulation. 1997.
Malathion: Summary of toxicology data. Available online

38
at
http://www.cdpr.ca.gov/docs/toxsums/toxsumlist.htm.
28. Cammarota M, Bevilaqua LR, Viola H, Kerr DS,
Reichmann B, Teixeira V, Bulla M, Izquierdo I, Medina
JH. 2002. Participation of CaMKII in neuronal plasticity
and memory formation. Cell Mol Neurobiol 22:259-67.
29. CERHR (Center for the Evaluation of Risks to Human
Reproduction). 2000a. NTP-CERHR expert panel report
on butyl benzyl phthlate (BBP), NTP-CERHR-BBP-00,
National Toxicology Program Center for the Evaluation of
Risks to Human Reproduction. Available online at
http://cerhr.niehs.nih.gov/news/phthalates/report.html.
Reproduction). 2000b. NTP-CERHR expert panel report
on di (2-ethylhexyl) phthalate (DEHP), NTP-CERHR-
DEHP-00, National Toxicology Program Center for the
Evaluation of Risks to Human Reproduction. Available
online at
Reproduction). 2000c. NTP-CERHR expert panel report
on di-n-butyl phthalate (DBP), NTP-CERHR-DBP-00,
Reproduction). 2000d. NTP-CERHR expert panel report
on di-n-octyl phthalate (DnOP), NTP-CERHR-DnOP-00,

39
33. CIR . 2002. 84th Meeting of the CIR expert panel
results. Available online at http://www.cir-
safety.org/staff_files/results.pdf.
34. Cornu MC, Lhuguenot JC, Brady AM, Moore R,
Elcombe CR. 1992. Identification of the proximate
peroxisome proliferator(s) derived from di (2-ethylhexyl)
adipate and species differences in response. Biochem
Pharmacol 43:2129-34.
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2000. Material Safety Data Sheet for ethylcyclohexane.
Available online at
http://www.cpchem.com/specialtychem/products/MSDS/
ETHYLCYCLOHEXANE.pdf.
36. Dewailly E, Ayotte P, Bruneau S, Gingras S, Belles-
Isles M, Roy R. 2000. Susceptibility to infections and
immune status in Inuit infants exposed to
organochlorines. Environ Health Perspect 108:205-11.
37. Duty SM, Singh NP, Silva MJ, Barr D, Brock JW, Ryan
L, Herrick RF, Christiani DC, Hauser R. in press 2003.
The relationship between environmental exposures to
phthalates and DNA damage in human sperm using the
neutral comet assay. Environ Health Perspect
38. EPA (Environmental Protection Agency). 1994.
Chemical Summary for Cyclohexane (EPA 749-F-94-
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