Endocrine Disruptors: Science Should Underpin, not Undermine, EU Decisions by Jean-Charles Bocquet

Jean-Charles Bocquet2 May 2016

The crop protection industry is firmly founded on science and innovation; this allows us to make significant contributions not just to the European economy, but also to solving some of the biggest challenges facing society today, such as food security. Unfortunately, this contribution is often not fully acknowledged. We believe in regulatory decisions being made using the best available science, however, we are concerned by the way that science is increasingly misrepresented at various stages in the decision-making process – both by some inside and outside the European institutions. This can leave consumers uncertain and undermines their confidence in the food they eat and the products they use.

The issue of endocrine disruption continues to garner significant public and scientific interest.  Over the coming months, focus will increasingly turn towards the EU as the European Commission moves closer towards finalizing its criteria for defining substances considered to have “endocrine-disrupting properties.” Once adopted, these criteria will be applied to the regulation of crop protection products (pesticides), biocides and possibly also to general chemicals and cosmetics.

At a time when contemporary scientific thinking is moving towards exposure-driven safety assessment, the EU has unfortunately decided to adopt a hazard-based approval criteria for crop protection products and biocides. This decision was made on the political assumption that hazard-based regulation provides higher levels of protection than risk assessment. The truth is, there have been no demonstrable benefits to the protection of human health or the environment by using hazard-based approval criteria beyond those already provided by the existing risk assessment framework.

Our view is clear. We believe that endocrine disruptors can and should be treated like any other substance of potential concern and be subject to risk assessment, considering both the hazard and exposure of the substance. This was the view of the European Food Safety Authority’s Scientific Committee in its recent scientific opinion[1] and the approach still applied by regulatory authorities globally.

Within the bounds of the legislation we currently have, we believe that regulators should take into account all available and relevant scientific information when evaluating a substance for its potential endocrine-disrupting properties. To do anything else would be unscientific. We also believe that authorities should have the tools at hand to be able to distinguish between substances that have real potential to cause harm from those that present little or no concern and are safe to approve. This is why we believe that the final EU criteria on endocrine disruptors should use the WHO-IPCS (2002) definition as its basis and incorporate all the hazard characterization elements of severity, (ir)reversibility, specificity, potency and lead toxicity. All of these factors along with exposure (dose) are critical determinants as to whether a substance is actually likely to cause harm to humans and/or the environment.

The issue of endocrine disruptors is one that is complex and difficult for the public to understand. We are hopeful, however, that the EU’s final decision on the criteria for endocrine disruptors will not overlook this complexity in favor of a decision that could have significant consequences for consumers, farmers, trade, research and innovation in Europe. The goal we all share is to safeguard human health and the environment and to ensure high levels of protection for both. We trust that the European Commission will carefully consider the different policy options being put forward and ensure that its final decision is based firmly on science.

Jean-Charles Bocquet is director general of the European Crop Protection Association in Brussels, Belgium.

 

[1] EFSA Scientific Committee. 2013. Scientific Opinion on the hazard assessment of endocrine disruptors: scientific criteria for identification of endocrine disruptors and appropriateness of existing test methods for assessing effects mediated by these substances on human health and the environment. EFSA Journal 11(3):3132. [84 pp.] doi: 10.2903/j.efsa.2013.3132.