Policy: From Reactive Regulation to Proactive Incentives

Rotation Opportunity

Incentivize preventive and pre-clinical interventions to "engineer resilience" against chronic disease.

The Challenge

Key Insight: Regulatory frameworks incentivize treating disease, not preventing it—leaving prophylactic interventions without clear pathways.

The FDA focuses on established disease, offering no fast tracks for prophylactic meds or early biomarker trials. Companion diagnostic markets face high costs, complex regulations, and low reimbursements. Biomarkers rarely gain traction without approved treatments.

The Legacy

Key Insight: 20th century environmental policies delivered 30:1 returns, but regulatory momentum has stalled since the 1990s.

Despite the mounting evidence of environmental factors contributing to disease in the past decades, there has been fairly little regulatory action against industrial chemicals in the U.S. In the triumphs of eliminating lead in gasoline or banning flame retardants, the phase-outs took years to fully implement. With 70,000+ chemicals already in circulation, we would require centuries of chemical testing to convince regulators with enough irrefutable evidence to act and enforce regulations. Meanwhile today's global population is vulnerable to environmental exposures that can increase risk of disease and adverse outcomes.

For much of the twentieth century, exposure science was tethered to policy, delivering enormous health and economic returns. The phase-out of leaded gasoline yielded a return of $17–$200 for every dollar invested [1]. The Clean Air Act amendments of 1970 and 1990 reduced pollutants and prevented hundreds of thousands of premature deaths each year, yielding a benefit–cost ratio above 30:1 [2]. The Montreal Protocol has averted hundreds of millions of skin cancer and cataract cases by repairing the ozone layer [3]. Environmental health research objectives motivated new regulations at more stringent threshold doses. With these post-industrial revolution policy measures and enforcements in place, industry began to slowly self-regulate to minimize risks of crippling lawsuits.

Impacts of Policy on Human Health

Intervention / Policy Key Outcome Health Impact Economic Return
Phaseout of PCBs & DDT (1970s) Reduced body burdens of persistent organic pollutants Human dietary intake of DDT declined from 13.8 mg/day in 1970 to 1.88 mg/day in 1973 Broad societal gains through improved neurodevelopment; long-term healthcare cost savings
Phaseout of Leaded Gasoline Dramatic drop in child blood lead levels BLL decreased from 17.1 µg/dL (1970s) to 2.7 µg/dL (1990s) ROI of $17–$200 per $1 invested; annual benefits of $192–$270 billion per year
Clean Air Act (1970 & 1990) Dramatic reduction of PM, SO₂, NOₓ, ozone, and lead 2.4M asthma exacerbations prevented, 135K hospital admissions avoided, 230K+ premature deaths prevented Benefit–cost ratio exceeding 30:1; benefits of $22 trillion vs $523B cost
Montreal Protocol Ozone layer protection and recovery Prevention of ~443M U.S. skin cancer cases and 63M cataracts Avoidance of over $1.1 trillion in skin cancer costs; ~2M lives saved annually by 2030

However, the past decades have shown an increasingly deregulatory domestic policy environment. Since the 1990s, fewer environmental laws have been passed, political polarization has deepened, and tens of thousands of untested chemicals remain in circulation.

EPA Regulatory Actions by Decade

Color = Expansion vs Rollback; Opacity = Durability (higher = more stable)

Expansions
Rollbacks
High opacity = stable
Low opacity = fragile

Hover over bars for details on each regulatory action

Moreover, recent regulations on environmental chemicals have had limited success. Phthalate regulation rode on the coattails of other enactments (lead) for consumer product safety almost 20 years ago, and then further regulations have stalled in FDA for food, despite mounting evidence of the hormone disrupting effects.

Given the current timeline for most policy overhauls, piecemeal bans cannot keep pace with the tens of thousands of chemicals in circulation and new product manufacturing, nor can they address the bioaccumulative pollutants already burdening ecosystems and humans.

  • Environmental policy (CERCLA/Superfund) addresses cleanup, not population health effects
  • Value-based care frameworks have failed to reduce costs or improve outcomes at scale

Future-Looking Policies

Key Insight: Place-based investments, tort settlement reinvestment, and TERP translation pathways can create sustainable funding for prevention R&D.

Strategic policy measures can realign biotech innovation with the study of environmental health:

Place-Based Investments

Targeting areas of high disease incidence and elevated exposure rates would accelerate causal discovery of mechanisms of action and improve risk stratification. This approach has been shown to reduce downstream healthcare costs and productivity losses associated with environmentally mediated chronic disease clusters.

Toxic-Tort Settlement Reinvestment

Redirecting a portion of toxic-tort settlements and environmental fines into a dedicated research and development fund, modeled on the Tobacco Master Settlement Agreement and the Deepwater Horizon Natural Resource Damage Assessment, would sustain long-term research capital toward identifying health effects and developing treatments for exposure-based diseases. In addition, Superfund-style requirements could mandate responsible parties to fund longitudinal health research and early intervention efforts in exposed populations.

Public-Private Partnerships

At the federal level, new public–private partnerships could subsidize biotechnology firms' translational research aimed at treating early risk factors or prodromal states in exposed populations. Pharmaceutical firms could integrate existing longitudinal exposure cohorts and biobanks (e.g., NIH Environmental Influences on Child Health Outcomes Program) into discovery pipelines, uncovering upstream disease mechanisms and prevention targets.

TERP Translation Pathways

Incentives are needed to carry forward the outputs of the NIH Toxic Exposure Research Program (TERP) housed within the Congressionally Directed Medical Research Program, which has generated foundational data with over $100M in funding towards exposure–disease mechanisms. Deliberate pathways for translation could include:

  • Matched funding and milestone-based subsidies that enable biotech companies to integrate TERP findings into drug discovery
  • Structured data-access partnerships providing biotech firms with streamlined access to exposure-disease datasets
  • Integration of biobanks/cohort data into discovery pipelines connecting existing longitudinal studies (ECHO, Children's Health and Development Studies) with commercial R&D
  • Biomarker development incentives to translate exposure markers into clinically actionable diagnostics
  • Exposure-mitigation technology subsidies for companies developing remediation and clearance solutions

Benchmarks to Hit

Roadmap: A seven-year plan to create regulatory pathways and funding mechanisms for prevention therapeutics.

  1. Year 1: Establish working group on preventive biomarker regulatory pathways
  2. Year 3: Achieve first cumulative exposure health impact assessment adopted by EPA
  3. Year 5: Create pilot "Resilience Fast Track" designation at FDA for exposure-prevention therapeutics
  4. Year 7: Implement first health impact fee program with dedicated prevention R&D funding

References

  1. Grosse SD, Matte TD, Schwartz J, Jackson RJ. Economic gains resulting from the reduction in children's exposure to lead in the United States. Environ Health Perspect. 2002;110(6):563-9.
  2. U.S. Environmental Protection Agency. Benefits and costs of the Clean Air Act 1990-2020. EPA; 2020.
  3. U.S. Environmental Protection Agency. Atmospheric and Health Effects Framework: Benefits of the Montreal Protocol. EPA; 2020.
  4. Agency for Toxic Substances and Disease Registry. Toxicological profile for DDT, DDE, and DDD. Atlanta: ATSDR; 2002.
  5. Centers for Disease Control and Prevention. Blood lead levels in children aged 1-5 years — United States, 1999-2010. MMWR Morb Mortal Wkly Rep. 2013;62(13):245-8.
  6. National Academy of Sciences. A framework for assessing health risks of environmental exposures to children. Washington, DC: National Academies Press; 1993.