Response to European Consultation on the Beating Cancer Roadmap

The European Commission launched an EU-wide public consultation on Europe’s Beating Cancer Plan on the 4/2/20. The consultation on the roadmap closed on the 4th Feb 2020.The Alliance’s response is below.

There is a a new public consultation running until the 7th May.  The EU Commission plans to cover the entire life-cycle of the disease from prevention to early detection and better treatment and care, with patients and survivors at the centre of this plan. They are inviting interested individuals or organisations to share their views and experiences to feed into a European cancer plan putting European citizens at the centre.

Of specific relevance is the Commissions inclusion of environmental risk factors alongside targeting ways to reduce exposure to toxic chemicals. We hope this is also in relation to occupational cancers.

More information on EU-actions on cancer:

The response from the Alliance for Cancer Prevention.

The Alliance welcomes the European Beat Cancer Plan. We have been campaigning for the inclusion of environmental and occupational risk factors into all cancer plans and strategies for the last 2 decades. Along with From Pink to Prevention campaign and the Lincolnshire Cancer Project we hope this European plan and the Cancer Code will provide a template which will be reproduced in all European cancer plans and beyond. To ensure inclusion, there should be a mandatory agreement to include and address occupational and environmental risk factors.

The Alliance views this plan as a vehicle to bring cancer policy into the 21st century, by embracing new and emerging science and adopting a primary prevention approach. Equal consideration needs to be given to precautionary and preventive approaches to cancer alongside better treatment and care, as the foundation stones of the Beating Cancer Plan.

In 2011 the World Health Organisation (WHO) issued a call for action:
Many cancers caused by environmental and occupational exposures can be prevented. Primary prevention – prevention of the exposures that cause cancer – is the single most effective means of prevention. Prevention of the environmental and occupational exposures that cause cancer must be an integral component of cancer control worldwide. The Asturias Declaration WHO 2011.

Yet, 9 years later, we still do not see this call replicated in the English cancer plan.

Our current cancer strategies are failing us, they are inadequate, fragmented and outdated. Not only do they ignore social, economic and gender inequalities but also the interwoven and intrinsically linked environmental and occupational risk factors for cancer. By not addressing these confounding risk factors, strategies to tackle cancer seek to place the onus at the feet of the individual cancer patient for their cancer, instead of at the feet of governments and the cancer establishment.

A lack of political will to address prevention is supported by a lack of acknowledgement by the medical and cancer establishments that cancer can be prevented through reducing exposures to cancer causing chemicals, or that exposure to certain chemicals and substances is even linked to increasing cancer rates.

While nobody is questioning the potential links between cancer and tobacco, poor diet, lack of exercise and overindulgence in alcohol. These modifiable risk factors are also compounded by factors like workplaces exposures, indoor and outdoor air pollution, and socioeconomic factors.

Cancer strategies are supposedly aimed at reducing the burden of cancer. Yet the vast majority of cancer plans only focus on the 30 – 50% of cancers perceived as preventable through various lifestyle interventions.

  • Environmental and occupational risk factors (determinants) need to be addressed as risk factors for cancer in all cancer plans and ,with definitive targets for action and appropriate allocated funding.

Research has shown that cancer organisations cite lack of time, knowledge, concern about social and economic influences, and the downplaying of risks by industry interests, as barriers to including and addressing environmental and occupational risks factors in their work. If this is the case:

  • Cancer organisations should be supported with clear repeatable messages from the European Beating cancer plan which they can easily incorporate into their work along with a requirement for this to be mandatory.

There is an urgent need to step outside the endless catch 22 situation where the call on cancer never varies from ‘more research’, yet more research never leads to conclusive action. Meanwhile we continue to watch people suffer and die from preventable cancers. For many chemicals and substances such as Carcinogenic, Mutagenic and toxic for Reproductive  (CMRs) and Endocrine Disrupting Chemicals (EDCs) there are no safe levels. Gaps in knowledge can be filled alongside action on the knowledge we have already.

  • The Alliance would like to see the inclusion of the precautionary principle as one of the foundation stones in the Beat Cancer Plan, alongside a greater emphasis on acting on what we already know.
  • Phase out of all International Agency for Research on Cancer (IARC) classified Group 1 carcinogens and Group 2A potential carcinogens.
  • Elimination of the future use of all types of asbestos and ensure proper management of the asbestos currently in place to protect workers from asbestos exposure.
  • Take a more human rights-based approach to cancer factoring in environmental justice principles and the right to a clean and safe environment in all cancer plans.
  • Harmonisation of the language in relation to cancer ensuring that references to the environment and primary prevention are universal and defined in terms of stopping cancer before it starts.

Occupational cancers rates are vastly underestimated which is a massive oversight given many occupational cancers are eminently preventable. The lack of gender disaggregated data means many female cancers get overlooked.

  • All doctors and health professional should take a full work history for patients.
  • Education provided to all doctors and cancer specialists on environmental and occupational exposures.

The Alliance acknowledges there will be better protection for workers with the establishment of binding occupational exposure limit values. But the aim should be for zero occupational cancer rates. We need to go further and include all EDCs and carcinogens to truly reduce exposures. Occupational cancer exposures can happen in the womb before current health and safety measures are implemented.  These need to be specifically mentioned in the roadmap with targeted toxic reduction across all environments, the lived, worked and the first environment, the womb.



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