The scientific committee at the European Food Safety Authority (EFSA) recently published a draft opinion that the limit value for Bisphenol A (BPA) should be lowered by 100 000 times.
The committee thereby concludes that every EU citizen is at health risk from exposure to BPA through their diet.
Interestingly, it´s been only seven years since the same committee concluded that there was no risk from BPA.
This is a perfect example of why we at ChemSec sound like a broken record when we keep saying that chemicals must be regulated based on if they are toxic or not, also known as a hazard-based approach. It’s also an example of how traditional risk assessments have failed to protect us yet another time, putting citizens and the environment at unnecessary risk. We would even go so far as to call this a scandal!
The hormone disruptor BPA has been used to produce transparent plastic, including baby bottles, and a million other products. It is one of the most used and well-studied chemicals in the world. It has been proven to cause a diversity of health problems from reproductive disorders to obesity and cancer. Scientists have warned about this for decades. Still regulation has lagged behind considerably.
And while BPA finally received EU official classification for being toxic to reproduction and was placed on the REACH Candidate List a few years ago – it is stilled allowed in most products.
Why? Because risk has not yet been proved. Or it had not until now, except for use in cash receipts and baby bottles where there are restrictions in place. In case you didn’t know, instead of outright banning BPA, different EU committees and panels are going through every use, one at a time. This obviously takes time as BPA has about 50 000 different uses. And this is not unique for just BPA, this is how most regulation of toxic chemicals works. One by one, instead of banning all uses in consumer products at a time, which would obviously be more effective.
We have so many times, too many times, seen warnings from scientists and NGOs about a certain problematic chemical being ignored. There is even a report series gathering such examples.
Hazardous chemicals in diapers
A very recent example is the attempt to ban several really nasty chemicals, including formaldehyde, dioxins, and PCBs in baby diapers. When the European Chemicals Agency did its analysis of the restriction proposal it could not establish that there was a risk and therefore did not support this restriction. In other words: exposing babies to extremely hazardous chemicals in contact with the most sensitive part of the skin is not seen as a risk.
The diaper issue is now with the Commission who will make the final decision if these nasty chemicals should be banned in these products or not.
Salt can kill you too!
The problem is that the conclusion of risk assessments tends to change over time following new scientific knowledge. The examples of where these new assessments have proven a lower risk than the previous ones are unheard of.
Still, some very influential and industry-friendly people keep patting our heads whenever this is brought up. Are we not aware of the foundations of toxicology? Paracelsus? Don’t we know that the dose makes the poison? That salt can kill you too?
Well, we do, and we have tried to illustrate this over and again, we even faked a consultancy website and printed a “Salt can kill you too” T-shirt!
We do not reject the fact, that for several hazardous endpoints (effects), the bigger the dose the bigger the effects are. The problem is that for other endpoints for example Endocrine Disruption (EDCs) like BPA, this is not the case. And for most chemicals, not all endpoints (if any) are studied.
“Risk assessments tends to change over time following new scientific knowledge”
And even if we would know everything about the hazardous properties of a chemical, there are simply too many uncertainties as to where and how it will be used.
Another recent example of a failed risk assessment was when the limit value for the most studied PFAS chemicals PFOA and PFOS was proposed to be lowered by 99,9% in 2019.
So we’ve learned that only a few years of new knowledge can change a “Tolerable Daily Intake Value” by 100 000 times and the conclusion from “no risk” to “everyone is at risk”.
Seven years may seem long, but in the regulatory world, we can assure you it is not.
On the bright side – we are in a unique moment in time when all of EUs chemicals regulation is up for discussion and hopefully improvement, as the EU Chemicals Strategy promises less reliance on risk assessments.
This is obviously making risk assessment fans nervous, and already we are experiencing an onslaught of “even water can be dangerous in large amounts”-arguments at various meetings around Europe. The next step in this diversion campaign will most likely be a new wave of ridiculous industry cartoons explaining in kids’ voices why risk assessments are really swell.
One can only hope that the Commission will take past failures into account and resist the appealing idea that industry can responsibly control the most hazardous chemicals because they cannot. Not when they are used in consumer products.