Endocrine disruptors, European Commission consultation on rules. (1) The National Institute of Health and Scandinavian organizations are fighting to apply uniform scientific criteria and the precautionary principle. While the chemical industry and conniving agricultural confederations complain about the what they say is excessive stringency of the albeit mild measures in place in Europe.
Endocrine disruptors, the shame of Europe
‘An endocrine disruptor‘ is an exogenous substance or mixture that alters endocrine system functions and consequently causes adverse health effects in an intact organism, or in its progeny or (sub)populations. […] Critical effect, severity, (ir)reversibility, and power aspects are part of the hazard characterization of EDs [Endocrine Disruptors].‘ (2)
Endocrine interference is accepted by verification that three preconditions are met:
1) an adverse effect in an intact organism or (sub)population,
2) An endocrine activity,
3) a plausible causal relationship between the two.
Hazardous chemicals and their mixtures can be found anywhere from everyday products. Food contact materials and articles(MOCA), cosmetics, toys, plastics for various uses, textiles and clothing, electronics, etc. As well as products for cleaning and various professional activities, including agriculture (e.g., pesticides, herbicides). Some of them increase the risk of serious diseases, including damage to the reproductive system, malformations, genetic mutations, and cancers. Others harm the environment.
The EU General Court had condemned the European Commission in 2015 for failing to consider the risks of endocrine disruption in agrotoxin approval procedures. The European Parliament subsequently challenged in 2017 the mild measures taken to prevent the aforementioned risks in EC Regulation 1107/09, ‘concerning the placing of plant protection products on the market.’
On 7.11.18, the European Commission adopted its communication ‘Towards a comprehensive EU framework on endocrine disruptors‘ to update, better late than never, the 1999 strategy. (3) Acknowledging the need for ‘a systematic analysis of the consistency of relevant provisions on endocrine disruptors within EU legal measures.’ (4) Just another way to stall and postpone the necessary policy initiative to protect public health. EU executive reconfirms itself as serving toxic lobbies. In the chemical sector, as in the food sector.
On 4/18/19, the European Parliament adopted a spirited resolution, once again trying to remind the Commission of its duties to protect public health as a priority. (5) But once again it was too late, at the end of the term, to get a change in the situation. Brussels has thus initiated the Fitness Check, which is a phase of checking the adequacy of the overall system of standards under consideration. (6) Following are the most lucid positions gathered so far in the consultation process.
International Chemical Secretariat, NGO (Sweden)
ChemSec
, is a Swedish association at the forefront of protecting European citizens from chemical hazards. He spoke to emphasize-in line with the positions expressed by the European Parliament, the Council (7), other NGOs and stakeholders-how the Fitness Check represents an unnecessary waste of time and resources. Instead, the available scientific and legal data dictate that we move from analysis to action.
The European Parliament’s recent study ‘Endocrine Disruptors, from Scientific Evidence to Human Health Protection‘ provides a comprehensive overview of the global threat posed by some 800 substances suspected of being ED. But to date, the European Commission has not taken the horizontal measures it was supposed to take by 2015 to ensure exposure to endocrine disruptors is minimized. In spite of the serious and overt human and animal health risks involved. This overview should be sufficient to guide more concrete actions.
‘Repairing is twenty times harder than preventing.’ (Henri-Frédéric Amiel (1821-1881).
Brussels must therefore act now to supplement the various regulations with definitions, guidelines, and criteria for risk analysis and management. In order for different regulations to meet the basic goal of protecting human health and the environment. Minimizing exposure to endocrine disruptors from all sources, dietary and environmental.
Superior Institute of Health (ISS)
Professor Alberto Mantovani, an internationally renowned toxicologist with extensive research experience on the health impact of endocrine disruptors, in turn spoke in the consultation on behalf of ISS. EDs must be addressed consistently, on a scientific basis, with a holistic approach oriented toward the long term. However, this should not delay the adoption of reforms that can already be made on sector regulations (e.g., biocides, pesticides).
The cornerstone is the ‘one substance, one toxicology’ principle. That is, the same scientific criteria should always be adopted, to assess the risks associated with a given substance. When even assessments are functional in different regulatory domains. If substance X, for example, is identified as an endocrine disruptor (ED) in the review of a food additive, the same evaluation should also be used for the purpose of its authorization as a cosmetic ingredient, feed additive, etc.
The entire ED evaluation process must come based on suitable and transparent scientific evidence, with due evaluation of uncertainties and precautionary approach. It should be emphasized that the ED evaluation still suffers from important knowledge gaps (e.g., the definition of a ‘threshold’, screening of diabetogenic and obesogenic effects, etc.). feedback from sound and focused research is therefore an essential part of developing an effective regulatory framework.
Attention and resources must then be devoted to the identification of safe alternative substances and environmental remedies, which in the near future may indeed take priority importance. Alberto Mantovani notes among other things how the document does not mention the circular economy action plan or the plastics strategy, which should instead be considered precisely to minimizeexposure to endocrine disruptors.
In order to be effective, the dialogue between the social partners concerned and the European Commission must include a permanent and structured system of information exchange and consultation. The European strategy must then take on an international dimension, in order to effectively protect health and the environment in Europe and promote the European model of food and commodity production in the global market (e.g., BRIC countries, U.S.).
Anonymous
The German chemical industry (read Big 4) and the young Spanish farmers who are members of the ‘confederation of agricultural confederations’ in Europe (Copa-Cogeca) share positions that are disinclined to further risk assessments on pesticides and other substances. Nothing new, recalling the previous alliance on glyphosate in 2016.
Anonymous
Instead, it recalls a crucial aspect, the preservation of bees. Authorization procedures for agrotoxics should no longer disregard the performance of tests on the safety of the substances for the health of pollinating insects. Applying the criteria defined in 2013 by theEuropean Food Safety Authority (EFSA), the review of which is now being organized. (8) The European Union must take drastic measures to stop the decline of bees. First, there is an urgent need to properly test pesticides before they are placed on the market. In line, by the way, with the European consumer initiative ‘Save the Bees!‘ which we urge all our readers to sign and promote.
Cazeau Ronald
, a French microbusiness in the construction and environmental surveying sector, in turn denounces the lack of information about the presence of endocrine disruptors in materials and products that construction workers and other contiguous workers use and handle every day without protection. With direct physical exposure, by contact and inhalation. Workers must be given accurate information about the risks involved in the use of such substances and the personal protective equipment to be used. To this end, it is necessary to define standardized European labels. As well as restrictions and search for alternative substances, we add. In an area, that of materials for professional use, which still eludes uniform rules effectively based on risk analysis.
#Égalité!
Dario Dongo
Notes
(1) European Commission, Fitness Check on Endocrine Disruptors, at https://ec.europa.eu/info/law/better-regulation/initiative/2142/publication/5538010/attachment/090166e5c4d35b44_en
(2) Scientific Committee on Consumer Safety (SCCS). (2014). Memorandum on Endocrine Disruptors. European Union, Dec 16 2014.
doi: 10.2772/52077, https://ec.europa.eu/health/sites/health/files/scientific_committees/consumer_safety/docs/sccs_s_009.pdf
(3) ‘Communication from the European Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Towards a comprehensive EU framework on endocrine disruptors‘, COM/2018/734 final, at%3A2018%
(4) Chemical Safety Regulations (so-called REACH, Registration, Evaluation, Authorisation and Restriction of Chemicals, reg. EC 1907/09), plant protection products (reg. EC 1107/09), cosmetics (reg. EC 1223/09), biocides (reg. EU 528/12), medical devices (dir. 2017/745). In addition to the water framework directive (dir. 2000/60/EC) and the toy directive (dir. 2009/48/EC)
(5) See ‘European Parliament resolution on a comprehensive EU framework on endocrine disruptors‘ (2019/2683 RSP), at http://www.europarl.europa.eu/doceo/document/B-8-2019-0241_EN.html
(6) See footnote 1
(7) European Council, 26.6.19. ‘Towards a Sustainable Chemicals Policy Strategy of the Union, Council conclusions‘. At http://data.consilium.europa.eu/doc/document/ST-10713-2019-INIT/en/pdf
(8) EFSA (2013). Guidance on the risk assessment of plant protection products on bees (Apis mellifera, Bombus spp. and solitary bees). EFSA Journal 2013;11(7):3295. doi: 10.2903/j.efsa.2013.3295. Update 4.7.14 at https://www.efsa.europa.eu/en/efsajournal/pub/3295. For the review process now underway, see https://www.efsa.europa.eu/en/press/news/190508
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
