March 20, 2013
Today the European Food Safety Authority's (EFSA) Scientific Committee published its opinion on identifying endocrine disrupting chemicals (EDs). ECPA welcomed the EFSA opinion but is concerned how late the input has been requested in a process that has been rushed to meet political deadlines. The process to create new EU rules to identify and regulate EDs, threatens to take action based on
risks, to the detriment of European industry competitiveness and the broader public good.
input but sees its contribution as unfortunately late
when the ED criteria are all but finalised
. It is even more perplexing why the Commission
s own scientific committees have been absent from the d
evelopment of the ED criteria
, Director General of European Crop Protection Association (ECPA). "
Endocrine disruption is a complex scientific issue and the Commission
s own scientific committees could have made an invaluable contribution in providing clear expert advice to European regulators and politicians
Ignoring established scientific principles and rushing the development of the ED criteria risks dealing a crushing blow to European industrial innovation. The criteria as recently drafted would deny EU farmers access to essential and innovative plant protection products which they safely use today. This will deprive EU farmers of important tools at a time when productivity must rise to meet increasing demand for food.
ECPA is clear that protecting human and environmental safety should not be compromised. Satisfying this goal and retaining industry competiveness can co-exist if the ED criteria focus on actual rather than perceived risks. The EFSA opinion raises several important technical considerations which ECPA welcomed and which demand further consideration in this respect:
- risk assessment - EDs can be treated like most other substances and risk assessment is a suitable method to evaluate the level of concern posed by EDs, i.e. consideration of actual or predicted exposure and not only hazard;
- potency and severity - are important and relevant indicators of potential concern, and should be considered; and
- establishing safe dose/concentrations, above which adverse effects occur, is possible.
Further input of EFSA's Scientific Committee on the many complex topics around endocrine disruption is essential. As the scientific debate continues on these topics, robust and independent scientific advice is important to ensure European regulation addresses substantiated concerns rather than fear. A broader return to risk assessment over hazard assessment would meaningfully contribute towards this goal.