In an article published on January 31, 2018, the non-governmental organization (NGO) Health and Environmental Alliance (HEAL) summarized its response to the public consultation on the draft guidance for the identification of endocrine disrupting chemicals (EDCs) (FPF reported) based on the EDC identification criteria recently adopted in the EU (FPF reported).
HEAL criticized “the narrow scope of the document” which focused only on a limited number of EDC properties, namely only on those mediated by the most studied EATS (estrogen, androgen, thyroid, and steroidogenesis) actions. HEAL argued that “this narrow focus will likely results in the classification of chemicals as ‘non EDCs’ by default,” while a bigger focus may be more relevant, particularly in the context of chronic diseases. Further, HEAL noticed that “the unprecedented level of evidence required to proceed with identification” likely contradicts “the precautionary principle, which should allow decision-makers to take action in the face of scientific gaps or uncertainties.” Finally, HEAL highlighted “the contradiction between the acknowledgement of several scientific limitations and the lack of practical guidelines for how to deal with these,” specifically emphasizing the fact that “the document does not foresee a clear timeline and process for inclusion of new scientific knowledge or test methods as they are being developed to support EDC identification.”
The Endocrine Society (ES) also responded to this consultation, as summarized in an article published on February 1, 2018. Similarly to HEAL, the ES “called for broadening the scope of the guidance to incorporate all potential toxicity effects that are relevant to endocrine disruption,” highlighting that, apart from EATS-mediated pathways, “chemicals can also disrupt other endocrine pathways that depend on proper hormone function, such as metabolism,” what may lead to such widespread conditions as insulin resistance and obesity. The ES also emphasized that the guidance should ensure that EDCs can be defined “based on a realistic standard of scientific information, minimizing the potential for mischaracterization of harmful chemicals,” and asked “for more clarity on situations where agencies may not have sufficient information to evaluate a chemical.”
Endocrine Society (February 1, 2018). “Endocrine Society calls for improved guidance to identify endocrine-disrupting chemicals.”
PAN Europe (February 2018). “Comments on Guidance Document on identification of EDCs.”
Vanessa Zainzinger (February 7, 2018). “EDC criteria guidance consultation ends with criticism from industry, NGOs.” Chemical Watch
Ninja Reineke (February 7, 2018). “Will the EU finally start identifying endocrine disrupting biocides and pesticides or will exposure continue?” CHEMTrust