EPA on the Right Track for Addressing Endocrine-Disrupting Chemicals, but Should be Wary of Potential Detours

A year ago this month, CPR published a white paper that laid out a two-phased action plan for federal agencies to take some critical steps toward protecting the public from Bisphenol-A (BPA). The report provided both short-term and long-term action items for the EPA, FDA, and OSHA that could establish stronger safeguards, risk assessment practices, and warning mechanisms for families and consumers concerning BPA and other endocrine-disrupting chemicals.  We said an underlying requirement for both short-term and long-term action items is for federal agencies to acknowledge the unique low-dose effects and non-monotonic dose response curves (NMDRC) of endocrine-disrupting chemicals and adapt existing scientific protocols to reflect these unique risks.

Shortly before the conclusion of 2012, EPA announced a promising new effort in turning these action items into a reality.  The agency is forming a working group dedicated to investigating and analyzing low-dose effects and NMDRCs for endocrine disrupting chemicals, and intends to release a “state of the science” paper, which will undergo peer review and “help inform how the safety of chemicals are assessed.”  The working group will focus on three critical questions in conducting its work:

• Do NMDRCs capture adverse effects that are not captured using our current chemical testing strategies (i.e. false negatives), and are there adverse effects that we are missing?
• Do NMDRCs exist for chemicals, and if so under what conditions do they occur?
• Do NMDRCs provide key information that would alter EPA’s current weight of evidence conclusions and risk assessment determinations, either qualitatively or quantitatively?

While the mounting evidence concerning BPA and other endocrine-disrupting chemicals (including this thorough scientific review and study released in March of 2012 and credited with spurring EPA’s initiative) would answer each of these questions in the affirmative, this small but meaningful movement toward improving how our federal government determines what chemicals are safe deserves encouragement and support.

Assuming EPA’s working group does answer these questions affirmatively, EPA’s initiative should not stop there, and it should forge ahead with the next steps that can turn the state-of-the-science paper into actual change.  Two potential next steps are developing guidance that instructs risk assessors on how to account for these low-dose effects and NMDRCs, and improving Integrated Risk Information System (IRIS) evaluations.  Additionally, EPA can continue the long-term trudge forward in ultimately drafting new rules and underlying protocols that permanently integrate low-dose effects and NMDRCs into the established risk assessment framework. 

But EPA must also be wary of unnecessary detours and obstacles.  Industry protests and influence at all levels of the process can easily stall EPA’s progress, as was seen with EPA’s report concerning chemical dangers for children.  In the spirit of the New Year, I encourage EPA to keep its resolve to take these important steps forward and change the way we evaluate endocrine-disrupting risks – all with a mind toward protecting the public.