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When reports surfaced last month that nearly two dozen scientists had gathered in Berlin to reach an “expert consensus” on how to identify endocrine disrupting chemicals (EDCs), it wasn’t immediately clear who attended, how they were selected, or how – or even if – the European Commission would use some of the outcomes to help steer its efforts toward developing criteria for defining EDCs.
As it turns out, the final consensus statement published on May 4 by the Germany-based Federal Institute for Risk Assessment (BfR) reinforces several key principles that would underpin a risk-based approach to regulating EDCs, such as those used in the U.S., Canada and Japan. (You can find more information on the BfR consensus paper on EDCs here.)
That such a diverse group of experts could come together to recognize the validity of risk-based scientific principles speaks volumes about the value it brings to protecting human health and the environment from potential exposure to EDCs.
By the look of some initial comments made in the press, a few European-based NGOs are now scrambling to draw attention away from the risk-based principles the statement endorses. How? By focusing the media’s attention on the only potential area where they believe risk-based principles for regulating EDCs can’t win under the current EU law – and that’s with potency.
First, a quick primer: potency in chemical risk assessment refers to the amount of a substance required to produce a given effect. A chemical that can produce a biological effect at low doses is said to be more potent than one which produces effects only at higher doses.
In the EU, some have considered potency to be optional for inclusion in the first step in chemical risk assessment, hazard identification. Instead, according to the BfR statement, potency becomes relevant in the second step of risk assessment – hazard characterization. Either way, of course, potency is important.
The problem here isn’t with the statement, but with the fact that, under the current EU law, if a pesticide or biocide is identified as an EDC (a hazard) – step one – no further steps in a risk assessment are taken. It doesn’t even make it to step two, or three or four or five. So, even though potency does matter, there’s no consideration of potency, or real-world exposure scenarios, or probability of real-world effects.
According to the logic driving this “hazard-only” approach to regulation, water and much of the natural food we eat would be banned. Does that sound like sensible regulation to you? Of course not.
The BfR scientists didn’t seem to think so either. Instead, they get it – the risk-based approach is the most comprehensive, practical and protective approach to protecting human health and the environment to date.
And the fact that they effectively called out the EU on their “hazard-only approach” only reiterates the concerns the U.S. and other countries have expressed to the Commission about their potential next steps.
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