In a press release published on November 15, 2016 the Endocrine Society commented on the revised proposals for the identification of endocrine disrupting chemicals  (EDCs) which were released by the European Commission on the same day (FPF reported). The Endocrine Society expressed its disappointment, pointing out that the revised drafts still outline the “unnecessarily narrow criteria for identifying EDCs that will make it nearly impossible for scientists to meet the unrealistically high burden of proof and protect the public from dangerous chemicals.”

Similar views were expressed in an open letter to the EC sent on November 16, 2016 by a group of fifteen scientists working in the field of endocrine disrupting chemicals. In his article published on the web-site of Policy From Science Project, Paul Whaley summarized the open letter, pointing out that the revised EDC criteria drafts did attempt to address a number of concerns raised by the same group of scientists in their first open letter sent in response to the original proposals released in June 2016 (FPF reported). However, the changes undertaken are still insufficient, and the proposed criteria remain “not fit for purpose.”

The scientists outline the following five issues that are still of concern:

“(1) An unclear fit between the requirement that a substance “may cause adverse effects” and the implication throughout the document that only chemical substances which are known to cause adverse outcomes via alteration of the function of the endocrine system will be classified as EDCs;

(2) That the new draft has replaced what was unequivocally a too-high burden of proof with an ambiguous burden of proof;

(3) The addition of new detail which explains the regulatory implementation of weight-of-evidence assessment and systematic review as it pertains to EDCs is welcome, but it does not capture best practice in evidence synthesis and integration, and is not an operable approach to making full and fair use of the existing evidence to identify endocrine disruptors;

(4) The retention of a two-tier hierarchy of evidence, of “internationally agreed study protocols” as against “other relevant scientific data”, further prevents implementation of a fair and operable evidence integration methodology;

(5) That the move from “negligible exposure” to “negligible risk” is being justified as a scientific matter when in fact it seems a political one, the implementation of which requiring a different regulatory process than the one currently being followed.”

Read more

Endocrine Society (November 15, 2016). “European Commission proposal on endocrine-disrupting chemicals fails to protect public.

Paul Whaley (November 16, 2016). “Another open letter to the EU Commission about the EDC

Whaley, P., et al. (November 16, 2016). “Open letter in response to the redrafted criteria for identification and regulation of endocrine disrupting chemicals, under the PPP and Biocides Regulation.Policy From Science (pdf)

Chemical Watch (November 24, 2016). “Endocrine scientists voice concerns over revised EDC criteria.