Children’s Health: Ten Solutions Offered to the MAHA Commission

    1 You should be part of the solution. I plan to be part of the solution. The following are the actions that I plan to take:

    2 Act fast. President Trump requires the strategy to Make Our Children Healthy Again to be completed this coming August. My proposed solutions for occupational chemical exposures to children (see Section 2 in the report) will be available to the MAHA Commission before that deadline.

    3 Solutions begin with concepts found in the Safety 2013 Session No. 706 paper “Oh Baby – How to Handle OSHA’s Unborn Child and Breastfed Children”². The Commission should be aware about what has not happened in the dozen years since that paper was written. For example, OSHA’s Directorate of Enforcement Programs never responded to a February 2013 request for information (see Interpretation section of the Oh Baby paper). I will suggest that the Commission require OSHA to publicly answer the seven questions listed in the paper.

    4 I will request that the newly formed Administration for a Healthy America (AHA) to survey the number of workplaces that participate in carcinogen, mutagen, and toxic to reproduction (CMR) management programs (CMR-MP). CMR-MP are necessary to fully conform to OSHA 1910.1200 Haz-Com objectives. Low participation is expected. The Commission has many options, such as an OSHA Special Emphasis Program, to increase participation.

    5 I will recommend that the Commission prioritize prevention based on the flow diagram at page 41 of their assessment report. The flow diagram is included with this article for your convenience. CMR-MP must begin at the preconception stage. Workers must be informed preconception of CMRs in the workplace, probable dose from exposure, and the employer developed “special instructions” before CMR use. Employer special instructions for CMRs should be subject to OSHA’s record retention as provided at 29 CFR 1910.1020.

    6 As part of the CMR-MP, employees must be informed of “Risk Decisions” as explained by the carbon monoxide example in the Oh Baby paper. P.S. ACGIH issued a 2025 “Notice of Intended Change” to reduce the CO TLV to 15 ppm.

    7 The MAHA Commission should amend the federal PWFA and PUMP Acts to require employee access to an employer’s CMR-MP. Employee access to a CMR-MP is critical to allow an employee to make an informed decision whether any reasonable accommodations are needed to ensure health of the pregnancy or prevent CMR contamination of breast milk.

    8 An employer’s CMR-MP should be certified as “true and accurate” by an industrial hygienist or other qualified healthcare provider as identified in the PWFA final rules.

    9 The MAHA Commission should authorize the EEOC to establish a “Bounty Hunter” provision, such as found within California Proposition 65, to identify those employers that have not developed and communicated a CMR-MP to their workforce. The Bounty Hunter is needed because an OSHA SEP is likely to be insufficient to accomplish CMR-MP objectives.

    10 The EPA, under its TSCA authority, should accelerate the identification of existing and new CMR’s, along with the chemical’s respective ECEL and NCEL, by using AI to supplement traditional toxicological methods.

    The AHA should give preference to make grants, loans, or other assistance available to employers to create and maintain a CMR-MP based upon business location with marriage or birth rates higher than the national average, as currently established by the U.S. DOT.³

Conclusion
    The above are similar to puzzle pieces that EU nations have put together long ago to protect children’s health. For example, EU’s 1992 Pregnant Workers Directive connects to EU’s 2007 REACH with DNELs that enhances EU’s 2008 implementation of GHS that works to protect the unborn child and breast-fed children that is further supported by EU’s 2022 updated CMR Directive. The MAHA Commission is concerned about electromagnetic radiation and children’s health, then the Commission should consider adoption of the EU’s 2013 EMF Directive that includes a limit for pregnant workers.
    Occupational chemical exposure to children? The MAHA Commission is urged to review the timely article “Risk assessment and management of chemical hazards for pregnant workers: a qualitative review of guidance from EU member states” Claessens et al. published online April 2025 in the Journal of Occupational Medicine and Toxicology.⁴
    Healthcare in the U.S. with its foundations in science and migration into various OHS practices, is undergoing massive change. While massive change may be very uncomfortable for some people it does provide an excellent opportunity to envision and affect a better way for doing things, as you may believe they should be done. Take the chance and get involved.