Category: Uncategorized

 

A US government agency intended to assist small businesses is instead operating as an unquestioning promoter of a deadly business lobby wishlist. A report from the independent Center for Effective Government says the Small Business Administration’s Office of Advocacy is supposed to ensure that federal agencies evaluate the small business impacts of the rules they adopt. Instead it has been weighing in on issues including scientific assessments of the cancer risks of formaldehyde, styrene, and chromium.

But instead of scrutinising the evidence, it has just regurgitated industry briefings. The Centre says by the Office of Advocacy’s own admission, it lacks the scientific expertise to evaluate the merits of these scientific assessments. “We found that the Office of Advocacy’s comments on these assessments raised no issues of specific concern to small business and relied almost exclusively on talking points provided by trade associations dominated by big chemical companies.

Between 2005 and 2012, the American Chemistry Council (ACC) and its members spent over $333 million lobbying Congress and federal agencies on, among other things, a protracted campaign to prevent government agencies from designating formaldehyde, styrene, and chromium as carcinogens.The Formaldehyde Council, Styrene Industry Research Council, and Chrome Coalition spent millions more.

These groups asked the Office of Advocacy for assistance, and the Office became their willing partner.” According to the Center: “We conclude that the Office of Advocacy’s decision to comment on scientific assessments of the cancer risks of certain chemicals constitutes a significant and unwarranted expansion of its role and reach beyond its statutory responsibilities. We recommend that Congress ask the Government Accountability Office (GAO) to investigate the Office of Advocacy and exert more rigorous oversight of its activities to ensure its work does not undermine the efforts of other federal agencies to fulfil the goals Congress has assigned them.” (by Rory O’Neill www.hazards.org)

 Center for Effective Government news release and report: Small businesses, public health, and scientific integrity: Whose interests does the Office of Advocacy at the Small Business Administration serve?

Alliance for Cancer Prevention

Press release
Embargo until 00.01 Friday 7^th December 2012

Occupational breast cancer, a much neglected gender issue

London, UK (December 7th 2012)

New research has serious implications for elevated rates of breast cancer and reproductive disorders among women working in the plastics industry in the UK. (1) The paper published in the journal New Solutions supports recent findings by the Canadian researchers, Dr Jim Brophy and Dr Margaret Keith. Their epidemiological study found a five-fold elevated breast cancer risk for pre-menopausal women working in the plastics industry in Canada. (2)

The New Solutions study, carried out in association with the University of Stirling, Occupational Health Clinics for Ontario Workers and the National Network on Environments and Women’s Health, did a review of the toxicology, epidemiology, industrial hygiene literatures in conjunction with qualitative research looking at occupational exposures for the plastics industry’s largely female workforce.

The review revealed the body burdens of women working in the industry have much higher levels of hormone disrupting chemicals such as BPA, phthalates, styrene and acrylonitrile than the general population.  These chemicals are all used in plastics production and some can leach out of the products over time, further affecting women and children’s health.

But the real impact on women workers in the UK is harder to assess.  For the 200,000 workers reported by Professor Andrew Watterson to be working in the UK plastics industry, there is no available data break down by gender. (3) Given the serious implications for women workers highlighted in this research, this further illustrates the serious lack of attention and consideration paid to women’s occupational health in the UK.  There is also obvious significance for other sectors where women work with BPA and other endocrine disrupting chemicals.

Breast cancer rates in the UK have risen by 90% over the thirty year period 1971 – 2010 according to the ONS. (4) Yet occupational and environmental exposures are continually left out of the picture when risk factors are addressed.

The alliance believes a tipping point has been reached with the growing and compelling body of evidence linking breast cancer to life-time and pre-birth exposure to endocrine disrupting chemicals. Failure to act now is to consign women to face elevated breast risk by working in environments where they are exposed daily to a cocktail of carcinogenic, mutagenic and endocrine disrupting chemicals manufacturing products for consumption. This is just not acceptable.

Current EU work on reviewing the strategy and criteria for identifying ED chemicals and substances needs to be informed by this research and take into account women’s workplace exposures. (5)

The Alliance for Cancer Prevention thinks that this is not just an occupational issue, it is a social issue and a public health issue but predominantly it should be a gender issue. We need to get better at making the connections between environmental, occupational and social issues.

While there has been considerable progress in eliminating chemicals like BPA from baby products, the fact remains that women are still being exposed to EDCs in the workplace.  When it comes to EDCs, risk regulation does not protect women workers or future generations. Many women work in the early stages of pregnancy and while breast feeding, unfortunately a women’s body burden can be passed on to the develop foetus and unwittingly through breast milk.

Maybe the issue needs reframing in terms of exposure at work being an unwarranted and preventable assault on women’s bodies that prevents them from reaching the highest attainable standard of health. Through CEDAW, women as workers have an enshrined legal right to protection of their health and safety in working conditions, including the safeguarding of the function of reproduction. (6)

The take home message for women as workers, citizens and consumers is, there are no safe levels of EDCs.

Alliance for Cancer Prevention

Facilitator Helen Lynn m: 07960 033 687

email: info@allianceforcancerprevention.org.uk
www.allianceforcancerprevention.org.uk

@Cancer_Alliance

Notes to editor

(1)     DeMatteo R, et al. “Chemical Exposures of Women Workers in the Plastics Industry with Particular Reference to Breast Cancer and Reproductive Hazards”. New Solutions, Vol. 22(4) 427-448, 2012

(2)     J. T. Brophy et al., “Breast Cancer Risk in Relation to Occupations with Exposure to Carcinogens and Endocrine Disruptors: A Canadian Case-Control Study,” Environmental Health 11(87) (2012): 1-17, doi: 10.1186/1476-069X-11-87.

(3)     Chemical exposure at work is putting Scottish plastic workers at risk of breast cancer. Stirling University Press Release.

(4)     Office for National Statistics. Breast Cancer: Incidence, Mortality and Survival, 2010.

(5)     How the European Commission addresses challenges posed by endocrine disruptors. 

(6)     Convention on the Elimination of all forms of Discrimination Against women. (Article 11)  UK ratified the convention in 1986.

(7)     Endocrine disrupting chemicals are substances that alter one or more functions of the endocrine system (the bodies messenger system) and consequently cause adverse health effects in an intact organism, or its progeny, or (sub) populations. (WHO definition).

(8)     Environmental and occupational risk factors are exposures (either occupational or environmental) through air, soil, or water or direct contact with chemicals or substances which contribute to a cancer outcome by nature of their carcinogenicity, mutagenicity or endocrine disrupting abilities and properties.

2nd October 2012

Dear Commissioner Dalli,

Dear Commissioner Potočnik,

We, the undersigned environment, occupation/workers, and health organisations are writing to you today as we would like to request clarification on yesterday’s news that EFSA has been asked by the European Commission to prepare a scientific opinion on the human health and environmental risks of endocrine disruptors.

For at least one year, there has been an ongoing process under the auspices of DG Environment, , on the science and policy issues relating to the Community Strategy for Endocrine Disruptors and the requirements of the Pesticides and Biocides legislation to establish the criteria for the identification and assessment of Endocrine Disruptors. The process includes DG Health and Consumers (Sanco), DG Employment, Joint Research Centre, European Chemicals Agency, Member States, industry and public interest stakeholders, and involves the Ad Hoc meetings and the ED Expert Advisory Sub Group meetings.

In particular, the Expert Advisor Sub Group meeting has been providing advice to and is developing a report for the Commission and for the Member States Ad hoc Group on scientific aspects related to identification of endocrine disruptors. In these groups, discussions include the work of the OECD, the 2012 report on the “State of the Art Assessment of Endocrine Disruptors”, and other relevant scientific materials. These meetings have taken up considerable resources and time from all participants. Although the news article on the EFSA website and mandate text indicate it derives from the ‘European Commission’, we find it hard to believe that the Commission as a whole would initiate an entirely new process, which will lead to significant duplication and overlap with the existing process already underway under the auspices of DG Environment. Moreover, the letter makes clear that the mandate comes specifically from DG Sanco.

We would like to receive clarification as to how this new scientific opinion will fit into the existing process; and in particular, how it will be compatible with the DG Environment lead in the Commission services on producing criteria for Endocrine Disruptors. The Biocides law is the legislation requiring the earliest adoption of delegated acts specifying criteria for the determination of endocrine disrupting properties and for Biocides, DG Environment leads the process. Under the Experts Sub Group mentioned above, DG Environment has already set up a group with expertise on EDCs, comprised of representatives of Member States and stakeholders in order provide expert advice on the criteria. It now seems counter-productive to involve additional groups of scientific experts, particularly as not all have the requisite expertise in the issue of endocrine disruption.

We would also like to receive clarification on how this new scientific opinion will be compatible with the need for horizontal criteria that crosses all relevant legislation including that of for food & feed, industrial chemicals, cosmetics, water, and other areas. This need has been clearly expressed in the 4th report on the implementation of the Community Strategy on Endocrine Disruptors (August 2011), particularly given the special nature of endocrine disrupting chemicals having additive effects.

Controversies have already been provoked by previous EFSA work on Endocrine Disruptors, and their omission of new scientific insights on endocrine disruption. There are ongoing disputes about the validity of EFSA opinions (see Vandenberg et al, Environmental Health Perspectives, May 2010 and other publications), as well as ongoing disagreement views between EFSA and different Member States, for example see the French ANSES on Bisphenol A in food containers “Effets sanitaires du bisphénol A” September 2011). In addition there is significant public concern about the reliability and impartiality of its work on EDCs (as evinced by the recent decision of MEPs to withhold EFSA’s budget).

We would like explanations on how the Commission intends to proceed further with these now overlapping processes, and how Member State and other stakeholder expertise will be involved in the future. Given that the European Parliament is in the midst of its Report on Endocrine Disruptors, it would also be useful to understand how the Commission sees the Parliament’s report in relation to this EFSA undertaking. The credibility and motivation of the Commission Services that initiated this mandate, if not the Commission as a whole, let alone that of EFSA itself, is brought into question by what appears to be a significant duplication and overlap of resources and separate processes. In these times of austerity budgets and EU financial crises, European citizens expect the European Commission to ensure the most efficient and effective use of its resources, as well as those of its participating Member State representatives and experts. Looking at the mandate, we are not sure that this new process serves these ends, and think that this new development merits the fullest explanation.

Finally, we would like to point out that we think it is of the utmost importance that the process on the EDCs Strategy and the EDCs Criteria continues to be transparent and involves all stakeholders. The definition of and criteria for EDCs will mean that some substances will become recognized as EDCs and therefore possibly subject to controls, and others not. Therefore we believe public scrutiny is necessary with respect to the scientific formulations of criteria and definitions, and the scientific opinions, definitions and criteria are part of a wider process which require ongoing democratic participation and decision-making, and embody the precautionary principle.

In view of the public interest in this matter, we intend to make the contents of this letter more widely available. We are requesting a meeting with you about this as a matter of urgency.

Bearing in mind the importance of the issue, we look forward to a swift response.

 

Yours sincerely,

Lisette van Vliet,

Senior Policy Advisor, Chemicals and Chronic Disease Prevention

Health & Environment Alliance (HEAL)

28 Boulevard Charlemagne

B-1000 Brussels, BELGIUM

Tel:             +32 2 234 3645       (direct)

 

on behalf of

• Alliance for Cancer Prevention
• Breast Cancer UK
• BUND /Friends of the Earth Germany
• Cancer Prevention and Education Society
• Center for International Environmental Law
• CHEM Trust
• Client Earth
• Danish Ecological Council
• European Environment Bureau
• Health Care Without Harm Europe
• International Chemical Secretariat (ChemSec)
• Intituto Sindical de Trabajo, Ambiente y Salud (ISTAS)
• Générations Futures
• Greenpeace
• Organización para la Defensa de la Salud (Health Defense Organisation), Vivo Sano Foundation
• Pesticide Action Network Europe
• Réseau Environnement Santé
• Swedish Society for Nature Conservation
• Women in Europe for a Common Future

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