The Make America Healthy Again Commission, established by Executive Order 14212[1], on May 22, 2025 issued its initial report entitled “The MAHA Report: Making Our Children Healthy Again”. The Report asserts that children in the US are experiencing a chronic disease crisis. Four influences are alleged to be key drivers of adverse childhood health impacts: ultra processed foods; chemicals in the environment, impacts of digital life and social media; and overmedicalization.
The Reports alleges that children are suffering from exposure to a plethora of toxins, including pesticides, heavy metals, air pollutants, endocrine disruptors, water borne contaminants such as PFAS, and persistent organics such as PCBs. There is widespread recognition that these are subjects of concern, although attitudes differ widely as to what remedial actions are warranted. There is less consensus regarding other cited topics of concern, including fluoride, cosmetics and exposure to 5G WiFi.
Pesticides are the subject of the most extensive discussion regarding chemical exposures. The two primary points of attack on current regulatory approaches are the failure to evaluate pesticides on a multiple ingredient, cumulative basis and the reliance on allegedly biased industry conducted scientific studies. Data on the adverse health effects of glyphosate and atrazine are cited, but so is EPA’s conclusion that data does not identify any connection between glyphosate use and adverse health impacts.
The proposed approach is a direct attack on existing law and EPA’s current process for evaluating the risks of harm from pesticides. FIFRA requires that data be generated by applicants for pesticide registration. The Report cites the legal reality that “a significant portion of environmental toxicology and epidemiology studies are conducted by private corporations.” The Report asserts that this circumstance is evidence of undue influence. The implication is that data supporting pesticide registrations, which the Report acknowledges run in the tens of millions of dollars, should be generated by government agencies. This position contradicts the Administration’s general policy position that private enterprise is more efficient than the government.
The Report contends that the administration will implement “gold standard” science and “radical” transparency. Executive Order 14303[2], entitled “Restoring Gold Standard Science” also bears on issues related to data supporting pesticide registrations and takes positions in conflict with existing law. The Executive Order asserts that all data relied upon by the Federal government must be peer reviewed and available for public review. This approach arguable presents a challenge to the current system supporting pesticide registrations, as data submitted in support of pesticide registrations is not peer reviewed nor is it available for public review. While criticizing the U.S. approach, the report flatly rules out modeling the practices of the European Union and its reliance on a “precautionary principle” which the Report alleges stifles growth.
The Report has been attacked from multiple directions. Major agricultural trade associations, including the American Farm Bureau Federation, the National Corn Growers Association and the American Soybean Association have all issued critiques of the Report. On the other hand childhood advocacy organizations have criticized the fact that the Report makes no mention of firearms and automobile accidents, which are the two leading causes of childhood deaths. In recent years those two causes have been responsible for approximately 35% of annual childhood deaths. While the Report alleges that fluoride doses well beyond levels used in public water systems cause harm, it neglects to point out that tooth decay is the most widespread chronic health issue facing children.
Further undermining the credibility of the Report has been the discovery that a number of citations in it do not exists or are incorrect. The inaccuracies include multiple instances where citations have been found to not exist, including instances where the citation included an obvious reference to having been generated by artificial intelligence. The Administration has issued two revised versions of the Report correcting and revising at least fifteen citations.
Executive Order 14212 requires the Commission to issue a Strategy by mid-August. The Strategy will have to confront the explicit policy contradictions between the Report’s allegations of regulatory shortcomings and existing law and administration policy. The interests of the chemical and agricultural industries are likely to play a significant role in the shaping of the Strategy. The policy conflicts expressed in the Report will be playing out behind the scenes between now and the issuance of the Strategy.
[1] Published at 90 Fed Reg 9833 [May 29, 2025].
[2] Published at 90 Fed Reg 22601 [May 9, 2025].