Open Letter to the EU Ministers of Environment, Health and Agriculture and to the EU Health Commissioner regarding the identification of Endocrine Disruptors in the EU

Subject: Open Letter to the EU Ministers of Environment, Health and Agriculture and to the EU Health Commissioner regarding the identification of Endocrine Disruptors in the EU
From: Independent scientists working in the field of Endocrinology and Environmental Health
Date: 6 Apr 2017

“History is the sum total of things that could have been avoided”. These words of Konrad Adenauer, a founding father of the European Union, are especially pertinent today. For the last four years the European Union has been wrangling over the definition of endocrine disruptors, thereby blocking the application of long-standing European legislation on these chemicals, including the Pesticides (Plant Protection Product) and Biocides regulations, designed to limit their health and environmental impacts. However, as early as 2002 the World Health Organization (WHO) proposed a definition of endocrine disruptors. Here we call on the EU's Environment, Health and Agriculture Ministers and on the Health Commissioner to heed the scientific community not to attempt bending scientific definitions for political or economic purposes. In practice this implies to abandon the derogation that would not allow pesticides and biocides developed in order to affect target organisms via their endocrine systems to be recognized as endocrine disruptors.

Managing health and environmental problems relies on two distinct steps: identifying the problem (the scientific stage) and then managing it (the political stage). The political stage has been decided by the European Parliament and the Council in the Pesticides and Biocides Regulations, which stipulate that endocrine-disrupting substances should not be authorized, and the current discussions only concern scientific criteria identifying endocrine disruptors.

The text for the identification of endocrine disruptors currently debated contains a clause failing to recognize as endocrine disruptors biocides or pesticides that have been specifically developed to act by disrupting the endocrine system of target species, even if they also affect a non-target species by the same mechanism. If this text were to be accepted, the EU would have to apply a senseless definition of endocrine disruptors, whereby substances invented as endocrine disruptors would be excluded from the endocrine disruptor definition!

The principle of restricting the definition of EDs to "accidental" endocrine disruptors and ignoring endocrine disruptors “by design” is in direct contradiction with the internationally accepted definition of endocrine disruptors given by the World Health Organization in 2002. Given the high degree of conservation of the endocrine system across species, substances altering the endocrine system of an insect species targeted by a pesticide could also affect the endocrine system of beneficial species of insects, such as bees or other pollinating insects. It is unreasonable to make the assumption that chemicals designed to interfere with hormones in one species will not have widespread and unintended effects.

If decision-makers believe that certain pesticides or biocides should be maintained, including those acting on the endocrine system of insects or rodents, then derogations could be granted after they are identified as endocrine disruptors. If they believe that certain endocrine-disrupting pesticides should be authorized to avoid losses in market share by companies producing them, then we encourage them to do so only once all economic and societal impacts of such a decision, including those on health and the environment, have been considered. However, creating a definition with purposefully designed "loop-holes" that would avoid clear identification of a number of endocrine disruptors would represent a manipulation of the science and abolish the boundaries between identification of health problems and their management.

Thanks to the effort of the Member States and those of the European Parliament, Europe has taken on the role of international leadership in terms of protecting human health and the environment from endocrine disruptors. This leadership must not be based on a scientifically unfounded definition. We therefore urge you to ensure that science prevails in this preliminary, but essential, step of identifying endocrine disruptors and to defer to the risk management stage those exceptions which might be required. In practice, this means abandoning the derogation that would not allow pesticides developed in order to affect target organisms via their endocrine systems to be recognized as endocrine disruptors using evidence based on phylogenetically-related species.

First signatories:

Rémy Slama (Environmental Epidemiologist, Inserm, France), Barbara Demeneix (Endocrinologist, Museum National d’Histoire Naturelle, France), Jean-Pierre Bourguignon (Pediatric Endocrinologist, Belgium), Andreas Kortenkamp (Toxicologist, Brunel University, UK), Andrea Lenzi (President of the Italian Society of Endocrinology, Sapienza University of Rome, Italy), Giancarlo Panzica (Neuro-endocrinologist, University of Turin, Italy), R. Thomas Zoeller (Endocrinologist, Amherst University, USA), Leonardo Trasande (Environmental Epidemiologist, New-York University, USA), Russ Hauser (Environmental and reproductive epidemiologist, Harvard University, USA), Richard Ivell (Endocrinologist, Nottingham University, UK), Ezio Ghigo (Past president of the Italian Society of Endocrinology, University of Turin, Italy), Martine Vrijheid (Environmental Epidemiologist, ISGlobal, Spain), Cécile Chevrier (Environmental Epidemiologist, Inserm, France), Merete Eggesbø (Environmental Epidemiologist, NIPH, Norway), Joseph Braun (Environmental epidemiologist, Brown University, USA), Ana Soto (Endocrinologist, Tufts University, USA), Carlos Sonnenschein (Tufts University, USA).