Greenpeace Ignores Their Own Advice to
Look at the Evidence:
Setting the Record Straight on Bisphenol A
May 12, 2006
Development of a comprehensive, single regulatory system for chemicals management within the European Union, known as REACH, is now nearing completion. In a recent report titled “Fragile: Our Reproductive Health and Chemical Exposure,” bisphenol A was used as an example to support Greenpeace’s advocacy for the adoption of a precautionary approach in REACH through mandatory substitution requirements. But Greenpeace failed to take their own advice and ignored most of the scientific evidence on bisphenol A. Contrary to the view presented by Greenpeace, the weight of scientific evidence, as reviewed by scientific and government bodies worldwide, supports the conclusion that bisphenol A is not a risk to human health.
The Evidence Cannot Be Ignored
New legislation to reform the current regulatory system for chemicals is under discussion by the European Parliament and the Council of the European Union. As indicated by the name – Registration, Evaluation, and Authorization of Chemicals (REACH) – this legislation will establish a comprehensive, single regulatory system with extensive requirements for the management of both new and existing chemicals in the European market. Registration and evaluation will be required for chemicals produced or imported above specified volume thresholds, and further requirements for use-by-use authorization will apply to chemicals in designated hazard categories.
Along with other stakeholders, non-governmental organizations have actively advocated their views on the structure and requirements of the legislation. To support their desire for adoption of a precautionary approach in REACH with mandatory substitution requirements, Greenpeace recently released a report(1) that refers to a “growing body of evidence” of a possible link between the incidence of human reproductive disorders and exposure to chemicals, and states “the evidence to date cannot be ignored.”
Ignoring the Evidence
Surprisingly then, in their discussion on bisphenol A Greenpeace completely ignores their own advice by selectively citing only the very limited evidence that supports their opinion that bisphenol A causes adverse reproductive effects at low doses. Not a single citation is provided to studies that conflict with their view, in particular to the most comprehensive studies that were designed to determine whether bisphenol A has the potential to cause reproductive effects. Nor is there any indication that their view of bisphenol A is not supported by any of the government or scientific bodies worldwide that have comprehensively reviewed the evidence.
Greenpeace further notes that “decision makers should ensure that sufficient data about the properties of chemicals are provided by the producers and importers to establish the full range of hazards posed.” But by then ignoring most of the evidence on bisphenol A, Greenpeace undermines their own advocacy.
Setting the Record Straight on Bisphenol A
Bisphenol A is one of the best studied substances, with a large database of toxicological and exposure information that is relevant for human reproductive health. Greenpeace is right that the evidence cannot be ignored, and it has not been. Government and scientific bodies worldwide have comprehensively examined the evidence and, in every case, these assessments support the conclusion that bisphenol A is not a risk to human health at the extremely low levels to which people might be exposed. Key examples include:
- In January 2006, the German Federal Institute for Risk Assessment (BfR, Bundesinstitut für Risikobewertung) released a statement with their views on the safety of polycarbonate baby bottles.(2) They noted “The BfR does not recognize any health risk for babies that are fed from baby bottles made of polycarbonate.”
- A November 2005 statement from the US Food and Drug Administration on the safety of food contact products made from polycarbonate concluded “based on all the evidence available at this time, FDA sees no reason to change its long-held position that current uses with food are safe.”(3)
- In November 2005, a comprehensive risk assessment on bisphenol A conducted by scientists at the Japanese National Institute of Advanced Industrial Science and Technology concluded that “current exposure levels of BPA will not pose any unacceptable risk to human health.”(4)
- In March 2005, the Japanese Ministry of Environment reported the results of their own tests on bisphenol A, including a comprehensive reproductive test in laboratory animals. MOE concluded that there were no clear endocrine disrupting effects at low doses and that no regulatory action is required to manage risks.(5)
- In 2004, a weight-of-the-evidence evaluation of low-dose reproductive and developmental effects of bisphenol A conducted by a panel of scientific experts organized by the Harvard Center for Risk Analysis “found no consistent affirmative evidence of low-dose BPA effects for any endpoint.”(6) An updated evaluation that considered studies published through February 2006 concluded “the weight of evidence does not support the hypothesis that low oral doses of BPA adversely affect human reproductive and developmental health.”
- In 2003, a comprehensive European Union risk assessment(8) was published along with a critical review by the Scientific Committee on Toxicity, Ecotoxicity and the Environment(9) that stated “The CSTEE agrees with the conclusion of the RAR [Risk Assessment Report] that there is no convincing evidence that low doses of bisphenol A have effects on developmental parameters in offspring.”
The weight of scientific evidence, as reviewed by scientific and government bodies worldwide, supports the conclusion that bisphenol A is not a risk to human health at the extremely low levels to which people might be exposed.
1. Fragile: Our reproductive health and chemical exposure. 2006. Greenpeace International. Available on the internet at http://www.greenpeace.org/international/campaigns/toxics.
2. Selected questions and answers relating to bisphenol A in baby bottles. Bundesinstitut für Risikobewertung. January 18, 2006. http://www.bfr.bund.de/cd/7294 (English), http://www.bfr.bund.de/cd/7195 (German).
3. Letter from Dr. George H. Pauli of the Food and Drug Administration to Greg Aghazarian, California State Assemblymember, November 28, 2005.
4. An abstract and detailed summary of the bisphenol A risk assessment are available at http://unit.aist.go.jp/riss/crm/mainmenu/e_1-10.html. For further discussion on the assessment, see http://www.bisphenol-a.org/whatsNew/20060320.html.
5. Japanese Ministry of Environment. 2005. MOE’s perspectives on endocrine disrupting effects of substances. March 2005. Available on the internet at http://www.env.go.jp/en/chemi/ed/extend2005_full.pdf.
6. Gray, G. M., Cohen, J. T., Cunha, G., Hughes, C., McConnell, E. E., Rhomberg, L., Sipes, I. G., and Mattison, D. 2004. Weight of the evidence evaluation of low-dose reproductive and developmental effects of bisphenol A. Human and Ecological Risk Assessment. 10:875-921.
For a description of this study and a link to the full paper, see http://www.bisphenol-a.org/whatsNew/20040903Harvard.html.
7. Goodman, J. E., McConnell, E. E., Sipes, I. G., Witorsch, R. J., Slayton, T. M., Yu, C. J., Lewis, A. S., and Rhomberg, L. R. 2006. An Updated Weight of the Evidence Evaluation of Reproductive and Developmental Effects of Low Doses of Bisphenol A. Critical Reviews in Toxicology. In Press.
8. Available on the internet at http://ecb.jrc.it/DOCUMENTS/Existing-Chemicals/RISK_ASSESSMENT/SUMMARY/bisphenolasum325.pdf (summary) and http://ecb.jrc.it/DOCUMENTS/Existing-Chemicals/RISK_ASSESSMENT/REPORT/bisphenolareport325.pdf (full report).
9. Available on the internet at http://ec.europa.eu/health/ph_risk/committees/sct/documents/out156_en.pdf.