For the past three decades, the rate of innovation among the world’s leading chemical manufacturers has accelerated at a globally competitive pace. Consumers often reap the benefits of this innovation firsthand: we see a larger number and greater variety of products appearing on store shelves; upgraded products that outperform their predecessors; and new technologies that often satisfy a need we never knew we had. For many, this kind of innovation is something to celebrate.
Not everyone seems to feel that way.
Indeed, why does it seem like some individuals and organizations only feel like celebrating when innovation (and consequently, job and economic growth) takes a step backward, rather than progressing forward? Why do some seem to welcome consumer products disappearing from store shelves, applaud the introduction of substitute products that do not perform as well as their predecessors and for which the health risks may be less understood, and laud the creation of an overly restrictive regulatory path that hinders rather than helps companies bring new, potentially game-changing technologies to market?
It’s possible that one such celebration will take place next week when the National Institute of Environmental Health Sciences (NIEHS) hosts a three-day conference to “celebrate” (their word) 25 years of research into substances that can interact with the endocrine system – so-called endocrine disrupting chemicals (EDCs).
It’s an odd choice of words, celebrate.
Today, misinformation and public confusion over EDCs runs rampant, and a slew of products ranging from sunscreen to plastic food containers are potentially at risk of disappearing from store shelves based on that misinformation. On top of that, serious consideration is actually being paid to regulatory approaches that are based on weak science at the expense of overlooking very solid, science-based initiatives that have been around for nearly 20 years.
So, we ask – what is there to celebrate?
Rampant confusion over endocrine active and endocrine disrupting chemicals
Over the last three decades, the NIEHS has missed one critical opportunity after another to help the public recognize the important difference between substances that can interact with the endocrine system safely (“endocrine active chemicals“) and substances that can cause harm (“endocrine disrupting chemicals”).
Here’s what people need to know: endocrine active substances can interact with the endocrine system but, like caffeine, do not illicit harmful effects. By definition, an endocrine disruptor must cause an adverse effect via alteration of the endocrine system. If a chemical alters the functioning of the endocrine system, but this does not result in an adverse effect, by definition, it cannot be identified as an EDC. And yet, time and again, you will see individuals and even some global organizations attempt to categorize, label and list them as such.
Activists coined the term “endocrine disrupting chemicals” at least as far back as the 1980s when it was still unclear whether chemicals could even cause harm through an endocrine mode of action. The wording was strategic. It implied harm. It gave a sense of urgency to an issue that all but guaranteed its placement in the media and public policy spotlight.
As a result, substances with no proven endocrine-related adverse health effects have been unfairly mischaracterized and stigmatized, putting several products at risk of disappearing from store shelves without scientific justification.
For consumers and businesses alike, this unnecessary loss of innovation and consumer choice isn’t something to celebrate.
Serious consideration being paid to unscientific, hazard-based lists
Today, there are typically two sides to the debate on EDCs – those who see chemical safety across all three dimensions of risk assessment – hazard, dose and exposure – and those who can see only one: hazard. The fact that a one-dimensional, hazard-based approach to regulating EDCs is actually being considered by governments around the globe isn’t something to applaud.
First, it’s important to understand what hazard is and what it is not. Hazard refers to the inherent properties of a substance that make it capable of causing harm to a person or the environment. Everything around us, including the entire human body and everything we eat and drink, is entirely made of up chemicals. And all chemicals have inherent properties that can be described by hazard – even water and oxygen (it’s possible to drink too much water, and oxygen can explode).
Even though all chemicals can be described by inherent hazard, the mere presence of a chemical ingredient does not automatically mean it will cause harm. The actual chance of harm from exposure to a chemical ingredient depends on a variety of factors – including how much of the chemical ingredient is in a product; how the product is used; and what kind of exposure to the chemical typically occurs from using a product that contains the chemical.
Here’s the problem: the hazard-based approach often leads to the creation of arbitrary ‘lists’ of chemicals which carry a veneer of authority that masks the capricious and unscientific process by which they are created and which allows organizations to parade them around as science. These lists, which the public and value chain often take at face value, can in turn result in even more products disappearing from store shelves with no scientific justification.
In fact, the hazard-based approach to regulation only worsens the confusion between endocrine active and endocrine disrupting chemicals by giving consumers the false impression that no substance can interact with the endocrine system safely.
When the public doesn’t fundamentally understand the science, you work to fix it – not celebrate it.
Downplaying the accomplishments and scientific progress that has been made to date
There’s a better way to protect public health than confusing the public or arbitrarily limiting consumer choice: thoroughly assessing chemicals for health risks and, if present, adopting appropriate management measures. We believe NIEHS and others should do more to call attention to this scientifically validated process.
Risk assessment, as practiced in countries like the U.S., Canada and Japan, draws a more complete picture of chemical safety by incorporating real-world factors like dose and exposure. It is the more sensible way to protect human health and the environment while encouraging innovation. It’s easy to understand why.
Common substances like water, caffeine and soy can be toxic or “endocrine disrupting” at sufficient doses and exposures, but we have learned to manage those risks while continuing to enjoy the benefits the substances bring to our health and our daily lives.
While the NIEHS is the federal agency sponsoring this week’s conference, one could argue that it is the Institute’s sister organization, the U.S. Environmental Protection Agency (EPA), that has been doing the bulk of the work in screening and testing endocrine active chemicals for safety.
By the time its Endocrine Disruptor Screening Program (EDSP) launched in 1998, the EPA had already been using standardized test methods to assess chemicals for endocrine disruption. The EDSP simply marked a new direction for how the Agency would assess certain chemicals for safety in the future.
The complexity of the science required that EPA scientists follow a methodical process to make sure they got it right. By helping to pioneer the practice of risk assessment, EPA created the foundation for the EDSP as we know it today – credible, validated, and protective.
On Monday, EPA Senior Scientist Amy Blankinship is scheduled to provide a summary of the EDSP program to NIEHS conference attendees. This is a step in the right direction, because if there’s something that deserves special recognition this week, it’s the strong commitment to safety that industry and leading government agencies such as the EPA share through initiatives like the EDSP.
The NIEHS also has an opportunity this week to bring more balance and scientific rigor back into the debate on endocrine active and endocrine disrupting chemicals.
If the NIEHS were successful, that would truly be something to celebrate.