Life Cycle Thinking Blog

Rebuttal to presumed EDCs by presumed scientists

Only 18 of 52 chemicals will move on to Tier 2 endocrine disruption testing as potential risks.

EPA released its “Universe of Chemicals” of 10,000 chemicals that might be targeted for screening tests to determine whether they are endocrine disruptors over the next 5 years (it could have been 87,000). From the report:

“It is important to emphasize that the identification of this universe of chemicals for potential EDSP screening should neither be interpreted as a list of chemicals that will automatically be screened, nor as a list of chemicals with potential to interfere with endocrine systems of humans or other species.”

As follow on to its Chemical Action Plan on Bisphenol A (BPA), EPA published an Advance Notice of Proposed Rulemaking July 26, 2011, to develop environmental effects and exposure testing. EPA is not addressing human health effects in this notice as there is ongoing testing work already with other agencies. (See a pointed Trevor Butterworth blog about that work here.)

Kind of ironic:
Industry has submitted a petition to EPA to hold off on getting data on List 2 for the Endocrine Disruptor Screening Program (EDSP) until the Agency reviews and issues final guidance on how they are going to deal with the results they get on the first list of chemicals – especially if the agency is going to change the rules of the game in the middle of testing. Allegedly, one issue of controversy is around Good Laboratory Practices (GLP) – a careful set of documentation, review and recordkeeping requirements to ensure data quality every step of the way for any given written protocol. By following GLP, it should be possible to verify the protocol was followed and any deviations noted so that the test could be replicated (or challenged) by others. Failure to follow GLP leaves open the possibility of biased short-cuts or modifications (or ignoring uncomfortable data points) that make the results unreliable.