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Endocrine disruptors: Let’s avoid another ”late lessons from early warnings”.

Debatindlæg bragt i Chemical Watch i september 2016.

Publiceret 30. september 2016

25 years ago, a multidisciplinary group of experts was gathered in Wingspread, US, to assess what was known at the time about the consequences of introducing chemicals capable of disrupting endocrine systems into the environment. They were pioneers in a new scientific field and they laid the foundation for science-based policy decisions on substances known as endocrine disruptors. Now, 25 years down the line, we need to act on years of scientific advances and establish appropriate regulatory measures to sufficiently protect human health and the environment from the risk of endocrine disruptors.

For more than five years several EU-Member States, stakeholders and the European Commission have put tremendous effort into establishing the right criteria for identification of endocrine disruptors. And finally, on 15th June 2016, after an unsightly process that included a court case, the Commission tabled draft acts for pesticides and biocides, with the legally required and long awaited criteria for endocrine disruptors. This, in itself, was really good news.

But when it comes to the substance, the proposal is unfortunately quite disappointing. Mainly for three reasons: 1) it requires an unprecedented and scientifically unjustified level of evidence for identification of endocrine disrupting properties, 2) it is inconsistent with corresponding legislation and 3) it lacks a precautionary aspect. Rather than being the intended supplement to the existing regulation, which excludes substances giving rise to cancer, mutations or adversely harming our reproduction and unborn children, the proposed criteria for endocrine disrupters not only require much more evidence but at the same time less rigorous rules are proposed for their use.

The Commission proposals are neither in line with the globally accepted approach for identification of substances of high concern, nor fully in line with the WHO-definition for an endocrine disruptor. I am particularly worried about the fact that the criteria only apply to substances that are known to cause an adverse effect relevant for human health, and that evidence has to be extensively documented. This goes far beyond the requirements that we apply to other substances of high concern.

By changing the regulations on biocidal products and plant protection products and limiting the identification of ED's to those that are known to cause adverse effects, the Commission's proposal disregards one of the fundamental principles of the Treaty and environment legislation: The precautionary principle. Endocrine disruptors disturb the balance of the endogenous hormones, towards which the foetus and children are most vulnerable during certain sensitive windows of development. Therefore, exposure can - in contrast to many other chemicals - lead to severe effects that may first become evident later in life or even in the next generations.

The bottom line is that the Commission’s approach will not deliver adequate protection of human health and the environment.  Even well-known endocrine disruptors, are unlikely to be identified using the proposed criteria. The approach will also create legal uncertainty regarding the evidence required for a substance to be identified as an endocrine disruptor.

Ignoring current knowledge on suspected endocrine disrupting substances will not only make it difficult for industry to prepare and facilitate substitution of problematic substances, but also delay regulation.  These shortcomings and lack of progress may also lead to creation of unauthorized lists of suspected and potential endocrine disruptors.  

And even if identification of suspected endocrine disrupters is not required by the regulations on biocidal products and plant protection products, it would be much more efficient, and ensure better consistency to have a two -category approach which would allow us to identify confirmed endocrine disruptors as well as those substances suspected for ED properties, for which there is substantial evidence. This would also improve our ability to address the urgent problem of combination effects.

As a global frontrunner, the EU can make a difference by setting scientifically well founded criteria for identification of endocrine disruptors that will be protective for human health and the environment.

So let’s join forces and work for a solution that is in line with the globally accepted approach for identification of other substances of high concern, fully respects the WHO-definition, and clearly states which evidence would qualify for identification.  Such criteria could apply to all relevant EU-legislation, and appropriate risk management should be established according to the needs of the different sectors. If it is considered necessary, legislation must be adapted through the correct formal procedures.

As policy makers, we cannot allow ourselves to ignore the state of the science and the European citizen's concern with endocrine disruptors.

It is in the long term interest of industry and agriculture to ensure that products are trusted by the consumers. And enormously costly for society to pay the bill needed for increased health care and remedial actions that may be needed if we do not take appropriate action now.

If we miss this obvious opportunity to act responsibly today, our descendants may rightly in 25 years of time blame us for having let down the next generation, and, a new sad chapter can be added to the “Late lessons, early warnings”.