Comments on: Commission must take action against endocrine disruptors EU news and policy debates across languages Wed, 29 Aug 2018 04:15:38 +0000 hourly 1 By: GregBond Tue, 14 Feb 2017 03:22:45 +0000 As an epidemiologist with 35 years of experience leading research in environmental health, I feel compelled to raise attention to a number of factual errors and unsupported claims within AIM’s “Declaration” and, consequently, several portions of this op-ed.

Given the importance of open and transparent scientific debate, I would welcome a response from Mr. Zahn and the authors of the AIM declaration to the concerns shared below, or an acknowledgment of the errors I have cited, and for them to significantly revise their declaration to reflect the actual state of the science on EDCs.

Claim #1: “Endocrine disruptors are thought to cause two diseases responsible for 70% of infertility cases.”

My Response: AIM neither provides a scientific reference to substantiate this claim, nor does it make it clear which two diseases it references, or which chemicals it alleges are EDCs and are acting as causal factors. Infertility affects approximately 10 percent of heterosexual couples who wish to conceive, and the causes are complex. Several recent literature reviews of the evidence linking exposure to EDCs and male and female reproductive disorders have been published. None has concluded that there is sufficient evidence of a causal link, and they have instead highlighted significant research data gaps.

Claim #2: Endocrine disrupting chemicals (EDCs) are everywhere nowadays. They are probably linked to many diseases whose incidence is rising. That trend can no longer be ignored – it involves reduced fertility, adverse pregnancy outcomes, obesity and type 2 diabetes, and childhood leukemia.

My Response: . “Everywhere nowadays” is hardly a factual statement, and no definition is provided for EDCs in this context. A precise definition is important because the majority of the substances that may interact with the endocrine system result in activity that is benign, or in some cases, even essential to our well-being. From a regulatory policy and scientific perspective, it is important to distinguish and focus on those substances that have a real potential to cause harm to people or the environment, versus those that merely interact with the endocrine system in a benign or beneficial way.

AIM also says EDCs are “probably linked to many diseases whose incidence is rising”. Such a casual statement is highly speculative and is not supported by a robust review of the available scientific evidence. Firstly, AIM concludes that because the increase in disease trends has occurred primarily over the last few decades, these trends cannot be entirely attributable to genetic causes. It is implied that if these trends are not the result of genetic heritability, then the only other explanation is environmental exposure to chemicals. However, environmental factors go well beyond chemicals, and cover a multitude of characteristics in human populations including: diet, exercise, lifestyle factors, infectious agents, and even drug use – factors which can be completely unrelated to environmental chemical exposures.

Claim#3: “Worse still, global rates of endocrine-related cancers have dramatically increased over the past decades.”

My Response: Contrary to the assertion in the AIM declaration, over the past decade rates for endocrine related cancers have not been increasing. Nor is there scientific consensus that EDCs play a causal role in the etiology of cancers of the breast, testis, prostate and ovary.

With the exception of lung cancer among women and pancreatic cancer among both sexes, overall cancer mortality has been steadily declining in Europe since its peak in 1988, translating to an overall 26% fall in men and 21% in women, and the avoidance of over 325 000 deaths in 2015 compared with the peak rate. Since 2009, breast cancer rates in women fell 10.2% and prostate cancer rates among men fell 12.2%.

In the U.S., during the last decade, breast cancer incidence has been level, prostate cancer has been falling on average 5.1% each year, and ovarian cancer has been declining 1.9% each year. Although testicular cancer incidence has been rising 0.8% per year, this appears completely attributable to earlier detection as mortality rates have been stable and five year survival rates have been increasing.

Claim #4: “Of the over 1300 chemicals known or suspected to be capable of interfering with endocrine systems, only a small fraction has been properly investigated and the great majority of the chemicals which are currently commercially used have not been tested at all for endocrine disruption effects.”

My Response: the figure of 1300 chemicals alleged by AIM as known or suspected to be capable of interfering with endocrine systems derives from work done by the NGO TEDX. Their list of alleged EDCs has been roundly criticized for not employing the widely accepted WHO/IPCS definition of an EDC; for failing to consider the quality of the underlying research evidence; for failing to use a state-of-the-art systematic review and weight-of-the-evidence evaluation; and for employing reviewers that lack sufficient scientific qualifications to undertake a robust evaluation of the science – among other issues. Under the TEDX scheme, a single un-replicated study reporting any interaction between a chemical and any component of the endocrine system is sufficient to list a chemical, and no amount of new evidence, no matter how scientifically compelling, can reverse the decision.

Again, I would welcome the authors to respond to the concerns I have shared here.

Gregory G. Bond, Ph.D., M.P.H., F.A.C.E.
Manitou View Consulting, LLC
Northport, Michigan USA