This is the final week of the European Commission’s public consultation on Endocrine Disrupting Chemicals, which closes on January 16, 2015.
HEAL has made its official submission to the Commission’s public consultation on the criteria to identify hormone disrupting chemicals (known as EDCs), and on possible regulatory approaches.
Leading EDC scientists around the world have raised the alarm on EDCs because of rising rates of serious hormone related chronic diseases, including cancer, diabetes, learning disabilities, and reproductive problems.
HEAL wants the EU Commission to use the best science to identify these harmful chemicals, so that already existing laws designed to protect public health by reducing people’s exposure can be properly implemented.
Below are some of the key elements of HEAL’s submission:
1. Use categories to rank EDCs
HEAL supports the proposal to use three different categories of EDCs depending on the evidence of strength, using WHO/IPCS definition (OPTION 3). This approach follows the established approach for other hazardous chemicals (carcinogens, reproductive toxicants, mutagens).
“HEAL believes this would best capture and enable the optimal use of the existing state of the art science in a way that will best serve protection of public health.”
These categories (e.g., definite, suspected, potential) allow the substances to be distinguished according to the evidence, and to be dealt with differently according to the provisions of the laws.
“HEAL views the correct interpretation of those laws [Pesticides and Biocides] as including both category 1 [definite] and 2 [suspected] EDCs in the cut off criteria [not to be placed on the market].”
“Humanity faces rising levels of hormone related illnesses, so what the European Commission must do is to establish a system that leads to reducing our exposures to hormone disruptors, to help prevent these illnesses. Using categories is a sophisticated, powerful & necessary part of such as system.”
2. Oppose potency as part of EDC identification
HEAL does not support the proposal that would have potency being used in the identification of EDCs (OPTION 4)
“This proposal is scientifically flawed and is contrary to the policy advice the Commission received in reports by the Joint Research Centre (JRC) + the European Food Safety Agency (EFSA).”
“Potency is not used to identify chemicals which cause cancer (C) or are toxic to reproduction (R); some of these C or R chemicals are so classified because they exert these toxic effects via an Endocrine [disrupting] mode of action. Therefore it is scientifically illogical to use potency in identifying whether a chemical is an endocrine disruptor or not.”
“The potency of a chemical that can be measured depends on what the endpoint is that is being observed and during what phase the exposure is occurring (prenatal versus adult middle age, for example). EDCs vary in how strongly they affect different parts of the body & different hormone systems [at different times], so relying on certain tests for potency may wrongly leave some chemicals unidentified. For example, an EDC may be weak in disrupting female hormonal signalling but strong in disrupting some aspect of brain development.”
“During the most vulnerable periods, such as growth and development in the womb, even extremely small amounts of ‘weak’ EDCs may contribute to ill health, particularly later in life.”
3. Oppose creating a new escape route for hazardous pesticides
HEAL does not support proposals to change existing pesticides and biocides laws.
“HEAL found that regulatory option A (adhering to the existing provisions of the Pesticides and Biocides regulations which prohibit EDCs) is the best way forward [to reduce exposures to endocrine disrupting pesticides and biocides].
“HEAL opposes the EU Commission’s proposed regulatory options B and C. These are unacceptable because they would undermine the democratically agreed rules in the EU pesticides law adopted by the elected European parliamentarians and national governments in 2009 and the Biocides law in 2011.”
“The EU pesticides and biocides laws already contain provisions for exemptions if certain ED pesticides and biocides are found to be absolutely necessary.”
4. Look at environmental and health benefits, not just industry losses
“HEAL calls upon the EU Commission, and especially the Health and Consumers Directorate General, to ensure that the Impact Assessment, of which this consultation is just one part, fully analyse and reflect the benefits from identification criteria Option 3 together with regulatory Option A – that is, the health, societal, and environmental benefits of reduced exposure to EDCs, and the costs of inaction and lack of innovation in the industries if these options are not used.”
“Because of the inherent difficulties involved in costing such long term benefits Impact Assessment is limited, particularly in quantitative terms. Careful consideration of qualitative evidence must be made, especially for combination and cumulative exposures.”
Individuals can give easy and fast responses to the consultation
The EDC-Free coalition has developed a swift simple online tool for individuals to give answers directly to the European Commission. The platform is available in English, Danish, Dutch, French, German, Spanish and Swedish. www.no2hormonedisruptingchemicals.org. It has already been used by over 17,000 individuals who want the health and environmental threat of EDCs stopped.
The official questionnaire is here: http://ec.europa.eu/dgs/health_consumer/dgs_consultations/food/consultation_20150116_endocrine-disruptors_en.htm
HEALs response to the Commission’s public consultation here
CHEM Trust response to the Commission’s public consultation here
Swedish KEMi’s response to the Commission’s public consultation here