CHEM Trust was among the many participants in yesterday’s European Commission conference on hormone (or endocrine) disrupting chemicals (EDCs). The Commission’s Health Department (DG Santé) had organised the conference to discuss the next steps of an impact assessment on the potential socio-economic impacts of draft criteria to identify EDCs. Once finalised, these criteria will be applied in several EU laws, including laws on the regulation of pesticides and biocides.
The large interest in the topic was reflected by there being nearly 300 participants in the room, including representatives from industry associations, health and environment groups, consumer organisations, EU Member States, medical professionals, and scientists from universities & research institutes.
From our perspective we took away 3 key things at the end of the day:
- It is unclear what the impact assessment will be able to deliver
- The question is not about scientific controversy but the consequences of regulatory control
- There’s a need to focus on the benefits for human health and savings in health costs
1. It is unclear what the impact assessment will be able to deliver
EU Health Commissioner Andriukaitis emphasized in his opening speech that the impact assessment will have to answer many questions, health being the first one. However, it will be interesting to see how the impact assessment, which was described as a tool for decision making, will actually be able to inform decision makers on science-based criteria for the identification of EDCs.
Sharon Munn from the EU’s Joint Research Centre emphasized that in many cases adequate data on endocrine disrupting (ED) activity would not be available for the impact assessment, so definitive comparisons of which chemicals would be caught by each of the options under consideration would not be possible. Yet such data will be a prerequisite for trying to make accurate comparison of the impacts of the different options proposed in the Commission’s EDC roadmap. The food industry stated they cannot provide data on impacts on their sector before the EDC criteria are actually in place. The pesticide industry also remained rather vague in describing the potential impacts of criteria on their industry.
The programme also included speakers from Canada and Argentina. While it was of course interesting to listen to opinions from non-EU countries on EU legislation, it was not clear how these contributions helped the Commission in its task of coming up with science-based EDC criteria. These criteria are an implementing measure for existing EU pesticides and biocides legislation, which prohibit EDCs on the EU market (unless a derogation or specific authorization is given).
CHEM Trust considers that the EU should not heed warnings from non-EU countries who suggest that the EU would be in breach of trade laws if it implemented tough regulation of EDCs. Implementing controls on EDCs in order to protect EU citizens would not be an unjustified barrier to trade, and arguments to the contrary must not be allowed to drag down our legislation to the lowest common denominator.
2. The question is not about scientific controversy but the consequences of regulatory control
Many scientists in the room pointed to the evidence that had accumulated over the last decade that EDCs present a global health threat (see also the Endocrine Society’s press release).
In the course of the conference the Commission was criticised by several scientists for overemphasising the scientific controversy. Professor Ake Bergman, coordinator of the WHO/UNEP report on EDCs said that there is a consensus among the leading EDC researchers in the world.
Gwynne Lyons, participating on behalf of CHEM Trust, raised the issue of whether EDCs require a special approach in risk assessment:
“People and wildlife are exposed to multiple chemicals by various sources. How can a single substance risk assessment, focusing on the exposure to just one chemical at a time, be the right tool to address the rising incidences of hormonal illnesses?
After the conference, she further noted that she did not consider there were significant controversies on the science as such, which would prevent a way forward:
“Rather some speakers seemed to be ignorant of the fact that current EU laws do now require regulation of substances based on their endocrine disrupting properties. This makes perfect sense as people and wildlife will certainly be exposed due to the way pesticides and biocides are used.
The current dispute is clearly related to the consequences of the legislation and the remaining gaps in science are taken as a pretext for the delay. There are still many open questions in cancer research, but still we have a system regulating carcinogens”
3. There’s a need to focus on the benefits for human health and savings in health costs
Several stakeholders called on the Commission to proceed as quickly as possible, and to include a thorough investigation of the benefits for health and the environment in their assessment. A number of studies have been published recently looking at these costs, including by HEAL, the Nordic Council and by Trasande et al.
Genon Jensen from HEAL underlined in her talk that properly identifying and regulating EDCs:
“is one of the biggest opportunities to improve public health in our time, and it will also help turn the tide on preventing chronic diseases.”
Gwynne Lyons added:
“The Commission has a moral obligation to act on chemicals with endocrine disrupting properties, given the hormone-related diseases in the population. Reducing and mimimisation of exposures is what the current law requires.”
All the presentations from the conference are now available on the European Commission’s page on the conference.
- The CHEM Trust FAQ on EDCs addresses many of the issues discussed during the conference, including on potency, phytoestrogens and thresholds.
Update, January 2016
- In December 2015 the European Court of Justice ruled that the European Commission had broken EU law by not setting criteria to identify EDCs by 13th December 2013. CHEM Trust joined with other NGOs to write to President Juncker, calling for the Commission to rapidly set such criteria.