Scientically unfounded precaution drives European Commissions
recommendations on EDC regulation, while defying common sense, well-established science and risk assessment principles We, the undersigned editors of prominent journals of pharma- cology and toxicology, are drawing your attention to the imminent decisions by the European Commission to enforce a regulatory framework for so-called endocrine disrupting chemicals (EDCs). The currently drafted framework is based on virtually complete ignorance of all well-established and taught principles of pharma- cology and toxicology, of opinions raised by the European Commis- sions own competent expert authority [4], and of critical statements made by member countries, while avoiding asking for support from the European Commissions own scientic expert committees. As a statement, and as emphasized by others before, endocrine disruption is not a toxicologically dened endpoint but a mode- of-action that may or may not result in adverse effects. In itself, the mode-of-action concept implies the necessary existence of a threshold as experimentally proven for numerous other non-geno- toxic agents including EDCs. Moreover, endocrine systems play a fundamental role in the physiological response to changes in the environment with the aim of keeping an organisms biology within the homeostatic space. It is the task of toxicologists to make the distinction between those effects that are within this adaptive range and effects that go beyond the boundaries of this space and thus can be called adverse. Such adverse effects can be observed in adequately designed and performed toxicity studies. While we agree that a concern for possible EDCs is sensible and important, we also think that the identication and regulation of such substances should depend on (a) the denition of adverse ef- fects that are relevant to whole human or animal organisms and not to isolated test systems of unknown homeostatic signicance, and (b) on a characterization of real-life potency and therefore of thresholds of concern. In contrast, the currently drafted EU framework for EDCs fore- sees a priori regulation of agents that may show presumably endo- crine-mediated effects in some experimental system (in vitro, in silico, in vivo. . .), and under the a priori default assumption of no thresholds. This approach is based on a very small number of pub- lications [1,810] that lack the required scientic robustness needed for such an important piece of legislation that is sweeping in nature, will set an unforeseen precedence, and nally will have profound ramications for everyones livelihood. Furthermore, the regulatory draft specically states that the identication of an endocrine disruptor relies on the demonstration of an adverse effect for which there is convincing evidence of a biologically plausible causal link to an endocrine disrupting mode of action and for which disruption of the endocrine system is not a secondary consequence of other non endocrine-mediated systemic toxicity. Rele- vance of the data to humans should be assumed in the absence of appropriate data demonstrating non-relevance. As all scientists should know, it is biologically and statistically impossible to demonstrate absence of effect and thus absence of relevance. The mere statement demonstrates the lack of atten- tion paid by the European Commission to the weight of scientic evidence that clearly demonstrates the presence of a threshold for non-genotoxic compounds including EDCs [2,3,57], as well as to the scientic detail with regard to the physiological and sta- tistical implausibility of the approach taken. In fact, any scientist familiar with the overwhelming biochemical complexity of life understands that the healthy homeostasis of an organism results from an orchestrated network of myriad thresholds for every com- ponent substance. On this account, a nucleus of scientists sent an open letter on June 18 2013 1 to Prof. Anne Glover, Chief Scientic Advisor to the President of the European Commission Manuel Barroso, 2 pointing out the major deciencies of the drafted EU framework, and the wor- risome ramications this draft could have for science, the economy, and human welfare the world over. Although some readers may shrug and think this is not impor- tant and not their problem, it soon could be. Regulations that pro- foundly affect human activities, that legally impose signicant nes and even detention, should not be based on irrelevant tests forced to be regarded as relevant by administrative dictates, and on arbitrary default assumptions of no thresholds. Such standards would be contrary not only to science, but to the very principles of an enlightened governance and social contract. Not only scientists but society itself would pay dearly if unscientic approaches were to undermine our everyday practice of science, and the stringency of data analysis and evaluation developed by scientic thinking over the past centuries. In the present instance, the very credibility of thorough and robust teaching, research, and scientic analysis is questioned. This calls for action, and as beneciaries of public sup- port it is the utmost responsibility of us scientists to resist and counteract any efforts that undermine the core of science and its continuing promise for the betterment of the human condition and of the planet. 0009-2797/$ - see front matter 2013 Published by Elsevier Ireland Ltd. http://dx.doi.org/10.1016/j.cbi.2013.07.001 1 Open Letter to Prof. Anne Glover (to be included in each Journals own format) of June 18, 2013. 2 http://ec.europa.eu/commission_2010-2014/president/chief-scientic-adviser/ Chemico-Biological Interactions 205 (2013) A1A5 Contents lists available at SciVerse ScienceDirect Chemico-Biological Interactions j our nal homepage: www. el sevi er . com/ l ocat e/ chembi oi nt Authors Daniel R. Dietrich, Editor-in-Chief, Chemico Biological Interactions Sonja von Aulock, Editor-in-Chief, ALTEX Hans Marquardt, Editor-in-Chief, Toxicology Bas Blaauboer, Editor-Europe, Toxicology in Vitro Wolfgang Dekant, Editor-in-Chief, Toxicology Letters James Kehrer, Editor-in-Chief, Toxicology Letters Jan Hengstler, Editor-in-Chief, Archives of Toxicology Abby Collier, Section Editor, Chemico Biological Interactions Gio Batta Gori, Editor-in-Chief, Regulatory Pharmacology and Toxicology Olavi Pelkonen, Editor-in-Chief, Frontiers in Predictive Toxicology Florian Lang, Editor-in-Chief, Toxins Frank A. Barile, Editor-in-Chief, Toxicology in Vitro Frans P. Nijkamp, Editor-in-Chief, European Journal of Pharmacology Kerstin Stemmer, Assoc. Editor, Toxicology in Vitro Albert Li, Section Editor, Chemico Biological Interactions Kai Savolainen, Editor for Europe and rest of the World, Human and Experimental Toxicology A. Wallace Hayes, Editor for the Americas, Human and Experi- mental Toxicology and Editor-in-Chief, Food and Chemical Toxicology Nigel Gooderham, Editor-in-Chief, Toxicology Research Alan Harvey, Editor-in-Chief, Toxicon References [1] L.S. Birnbaum, When environmental chemicals act like uncontrolled medicine, Trends Endocrinol. Metab. 24 (2013) 321323. [2] A.R. Boobis, G.P. Daston, R.J. Preston, S.S. Olin, Application of key events analysis to chemical carcinogens and noncarcinogens, Crit. Rev. Food Sci. Nutr. 49 (2009) 690707. [3] C.J. Borgert, E.V. Sargent, G. Casella, D.R. Dietrich, L.S. McCarty, R.J. Golden, The human relevant potency threshold: reducing uncertainty by human calibration of cumulative risk assessments, Regul. Toxicol. Pharmacol. 62 (2012) 313328. [4] E.F.S.A.S. Committee, Scientic opinion on the hazard assessment of endocrine disruptors: scientic criteria for identication of endocrine disruptors and appropriateness of existing test methods for assessing effects mediated by these substances on human health and the environment, EFSA J. 11 (2013) 31323216. [5] A.H. Piersma, L.G. Hernandez, J. van Benthem, J.J. Muller, F.X. van Leeuwen, T.G. Vermeire, M.T. van Raaij, Reproductive toxicants have a threshold of adversity, Crit. Rev. Toxicol. 41 (2011) 545554. [6] L.R. Rhomberg, J.E. Goodman, Low-dose effects and nonmonotonic dose- responses of endocrine disrupting chemicals: has the case been made?, Regul Toxicol. Pharmacol. 64 (2012) 130133. [7] L.R. Rhomberg, J.E. Goodman, L.T. Haber, M. Dourson, M.E. Andersen, J.E. Klaunig, B. Meek, P.S. Price, R.O. McClellan, S.M. Cohen, Linear low-dose extrapolation for noncancer heath effects is the exception, not the rule, Crit. Rev. Toxicol. 41 (2011) 119. [8] D.M. Sheehan, No-threshold dose-response curves for nongenotoxic chemicals: ndings and applications for risk assessment, Environ. Res. 100 (2006) 9399. [9] L.N. Vandenberg, T. Colborn, T.B. Hayes, J.J. Heindel, D.R. Jacobs Jr., D.H. Lee, T. Shioda, A.M. Soto, F.S. vom Saal, W.V. Welshons, R.T. Zoeller, J.P. Myers, Hormones and endocrine-disrupting chemicals: low-dose effects and nonmonotonic dose responses, Endocr. Rev. 33 (2012) 378455. [10] R.T. Zoeller, T.R. Brown, L.L. Doan, A.C. Gore, N.E. Skakkebaek, A.M. Soto, T.J. Woodruff, F.S. Vom Saal, Endocrine-disrupting chemicals and public health protection: a statement of principles from the endocrine society, Endocrinology 153 (2012) 40974110. A2 Editorial / Chemico-Biological Interactions 205 (2013) A1A5 RE: Draft regulation on endocrine active chemicals June 18, 2013 Dear Prof. Glover, We, the undersigned are writing to draw your attention to imminent decisions by the European Commission to set a regula- tory framework for so-called endocrine disrupting chemicals. We are concerned that the approach proposed could rewrite well- accepted scientic and regulatory principles in the areas of toxicol- ogy and ecotoxicology without adequate scientic evidence justifying such a departure from existing practices. First of all, we want to emphasize that endocrine disruption is not a toxicological endpoint, but one of many mechanisms which may cause adverse effects. In addition, we recognize that such a policy initiative is highly technical and complex and requires an understanding of the modes of action for endocrine disruption and their signicance. It also implies the in-depth involvement not only of toxicological disciplines but also of environmental sci- ences and thus requires scientic input from experts in this area. The undersigned are concerned that the Commissions scientic committees have so far not been consulted by the Commission when drafting such regulations. What is even more disturbing is that, where a scientic advisory body such as EFSA has been con- sulted, critical elements of this bodys opinion are ignored. For example, in assessment of chemicals with endocrine activity, EFSA supported a substance specic risk assessment approach integrat- ing exposure and adverse effects instead of developing horizontal criteria for dening whether a substance is an endocrine disrup- tor. Development of horizontal lists ignores the long-standing principle that an assessment of a substance should be based on data obtained from toxicity testing on this specic substance and derived information on potency. If the Commission will adopt a policy stating that it is impossi- ble to dene a safe limit or threshold for a substance with classied as endocrine disruptor, this would reverse current scientic and regulatory practices and, more importantly, ignore broadly devel- oped and accepted scientic development and accepted knowledge regarding thresholds of adversity. Moreover, the latter approach may not only apply to potential EDCs but rather would apply to all chemical substances and thus nullify decades of experience and repeatable observations in exposureresponse relationships in pharmacology and toxicology and well-established and widely proven procedures in hazard and risk assessment. It also appears that the Commission will propose that identica- tion of an in vitro effect without a causal relationship to adversity in an intact organism may be sufcient to classify a substance as an endocrine disruptor. This would not only represent a rewriting of the rules and accepted practices of toxicology, which rely on well- dened adverse effects observed in adequately performed studies, but also would be contrary to all accumulated physiological understanding. This leaves us concerned that there is neither a scientic basis nor broad support by scientists established in risk assessment be- hind the approach of setting horizontal criteria and the lists of con- rmed and suspected endocrine disruptors. We have noted your important interventions on the need for scientic evidence to be at the heart of EU policy and are therefore writing to urge your review of the emerging policy to ensure that the opinion of relevant scientic committees and member states authorities are taken into account. The following individuals are supporting this initiative: Antero Aitio, Dr. Med. Sc., Professor h.c., former scientist/medi- cal ofcer at the International Programme on Chemical Safety, World Health Organization; former team leader, Finnish Institute of Occupational Health; former Unit Chief of the Monographs Pro- gramme, International Agency for Research on Cancer Herman Autrup, Professor, PhD ATS, President International Un- ion of Toxicologists, former member SCHER, AFC-Panel of EFSA, Institute of Public Health, University of Aarhus, Denmark Susan, Barlow, Ph.D., former member of EFSA Scientic Com- mittee (20032012), Brighton, UK Diane Benford, Dr., member, chair CONTAM Panel of EFSA, Head of Chemical Risk Assessment Unit, Food Standards Agency, London, UK Ole J. Bjerrum, DMSc, Professor of Pharmacology, University of Copenhagen, Denmark Sir Colin Berry, Prof. Emeritus of Pathology, Queen Mary, Uni- versity of London, UK Bas J. Blaauboer, Prof. Dr., Doerenkamp-Zbinden Chair on Alter- natives to Toxicity Testing, Institute for Risk Assessment Sciences, Division of Toxicology, Utrecht University, The Netherlands Hermann M. Bolt, Prof. Dr. med., Dr. rer. nat., Chair of the Scien- tic Committee for Occupational Exposure Limits, SCOEL (DG Employment), Leibniz Research centre for Working Environment and Human Factors (IfADo) at the TU Dortmund, Germany Alan Boobis, Prof., OBE, PhD, FSB, FBTS, member CONTAM Panel of EFSA, centre for Pharmacology & Therapeutics, Department of Medicine, Imperial College London, UK Christopher J. Borgert, Ph.D., President & Principal Scientist, Applied Pharmacology and Toxicology, Inc., Research Assistant Sci- entist, Department of Physiological Sciences, College of Veterinary Medicine, Gainesville, FL, USA Alexander Brkle, Prof. Dr., Chair of Molecular Toxicology Department of Biology, University of Konstanz, Germany Michle Bouchard, Ph.D., Associate Professor, Head of the Chair in Toxicological Risk Assessment and Management and Head of the Biomarker Unit of the Xenobiotics and Nanoparticles Platform, Department of Environmental and Occupational Health, Faculty of Medicine, University of Montreal, Canada Thomas Colnot, Ph.D., ERT, CiS Toxicology, Castro, Chile Brian Cummings, Ph.D., Assistant Professor, Department of Pharmaceutical and Biomedical Sciences, University of Georgia, Athens, GA, USA Slawomir Czerczak, Prof. Dr., Chair for Group of Experts for Chemical Agents of Polish Intersectoral Commission for MAC and MAI Values, Head of Department of Chemical Safety, Nofer Insti- tute of Occupational Medicine Lodz, Poland Gisela H. Degen, Prof. Dr., member SCCS, Leibniz Research cen- tre for Working Environment and Human Factors (IfADo) at the TU Dortmund, Germany Wolfgang Dekant, PhD, Professor of Toxicology, former member SCHER, CSTEE, member SCHENIHR, Department of Toxicology, Uni- versity of Wrzburg, Germany Lennart Dencker, Prof. Dr., Department of Pharmaceutical Bio- sciences, Uppsala University, Uppsala, Sweden Daniel Dietrich, Prof. Dr., Ph.D., Professor of Human and Envi- ronmental Toxicology, Member of SCENIHR, Former Chair of the OECD Endocrine Disruption and Ecotoxicology EDTA-VMG Non- Animal of the OECD, Member Presidential Expert Group AOAC, Fac- ulty of Biology, University of Konstanz, Germany Daniel R. Doerge, Ph.D., National Center for Toxicological Research, Jefferson, AR, USA (afliation is given for identication purposes only) Eugenia Dogliotti, Dr., Member CONTAM Panel of EFSA, Istituto Superiore di Sanit, Environment & Primary Prevention Dept., Unit of Molecular Epidemiology, Roma, Italy Editorial / Chemico-Biological Interactions 205 (2013) A1A5 A3 Jose L. Domingo, Professor and Director, Laboratory of Toxicol- ogy and Environmental Health, School of Medicine, Universitat Rovira i Virgili, Reus, Spain Johanna Fink-Gremmels, Prof. Dr., Utrecht University, Faculty of Veterinary Medicine, Institute for Risk Assessment Sciences, Division Toxicology, Veterinary Pharmacology, Pharmacotherapy and Toxicology, Utrecht, The Netherlands Hermann Fromme, Prof. Dr., Department of Chemical Safety and Toxicology, Bavarian Health and Food Safety Authority, Munich Corrado Galli, Pof. Dr., Dean, Faculty of Pharmaceutical Sciences, Lab. Toxicology, Department of Pharmacological and Biomolecular Sciences, University of Milan, Italy David Gott, Dr., member ANS Panel of EFSA, Head of Toxicology Team, Chemical Risk Assessment Unit, Food Standards Agency, London, UK Gio Batta Gori, DSc, MPH, ATS, Editor, Regulatory Toxicology and Pharmacology Bettina Grasl-Kraupp, Prof. Dr., ERT, Institute for Cancer Re- search - Medical University of Vienna, Austria Helmut Greim, Prof. Dr., member RAC ECHA, former chair MAK Commission, former chair SCHER, former member CSTEE, member SCHER, Technische Universitt Mnchen, Senatskommission der DFG zur Prfung gesundheitsschdlicher Arbeitsstoff, Freising, Germany Heidrun Greim, Dr., Wissenschaftliches Kommissionssekretariat der Stndigen Senatskommission der DFG zur Prfung ges- undheitsschdlicher Arbeitsstoffe, Karlsruher Institut fr Technol- ogie (KIT), Abteilung Lebensmittelchemie und Toxikologie, Institut fr Angewandte Biowissenschaften, Freising- Weihenste- phan, Germany G.M.M. Groothuis, Prof. Dr., Professor in Drug Metabolism and Toxicology, Department of Pharmacy, Groningen Research Institute of Pharmacy, Division Pharmacokinetics, Toxicology and Targeting, University of Groningen, The Netherlands Helen Hkansson, Professor, Head of Unit, Karolinska Institutet, Institute of Environmental Medicine, Environmental Health Risk Assessment Unit, Stockholm, Sweden Steen Honor Hansen, Prof. D.Sc., Analytical Biosciences, Department of Pharmacy, Faculty of Health and Medical Sciences, University of Copenhagen, Denmark Wolfgang Heger, Dr., Umweltbundesamt, Berlin, Germany Bjrn Hellman, Ph.D., Professor of Toxicology, Department of Pharmaceutical Biosciences, University of Uppsala, Sweden (aflia- tion is given for identication purposes only) Jan G. Hengstler, Prof. Dr., Leibniz Research Centre for Working Environment and Human Factors, IfADo, Dortmund, Germany Magnus Ingelman-Sundberg, PhD, BSc.Med, Professor and Section Head, Vice Dean (Recruitment), Karolinska Institutet, Sec- tion of Pharmacogenetics, Department of Physiology and Pharma- cology, Stockholm, Sweden Colin Janssen, Prof. Dr., former member CSTEE, member SCHER, Ghent University, Department Applied Ecology and Environmental Biology, Laboratory of Environmental Toxicology and Aquatic Ecol- ogy, Ghent, Belgium Risto Juvonen, PhD, School of Pharmacy Faculty of Health Sci- ences University of Eastern Finland, Kuopio, Finland James Kehrer, Professor and Dean, Faculty of Pharmacy & Phar- maceutical Sciences, Katz Centre for Pharmacy & Health Research, University of Alberta, Edmonton, AB, Canada Hannu Kiviranta, Ph.D., Unit head, National Institute for Health and Welfare/Department of Environmental Health/Chemical Expo- sure, Kuopio, Finland Hannu Komulainen, Research professor, former member SCHER, National Institute for Health and Welfare, Department of Environ- mental Health, Kuopio, Finland Hans Lepper, Dr., Bayerisches Landesamt fr Gesundheit und Lebensmittelsicherheit, SG K3: Forschungskoordination/Zentrals- telle Risikoanalyse, Erlangen, Germany Beatriz Silva Lima, Prof. Dr., Lisbon University, Faculty of Phar- macy, Lisbon, Portugal Jan Linders, Dr., member SCHER, formerly National Institute for Public Health and the Environment (RIVM), The Netherlands Marcello Lotti, MD, Professor, University of Padua, Medical School, Padua, Italy Marina Marinovich, Prof. Dr., Faculty of Pharmaceutical Sci- ences, Lab. Toxicology, Department of Pharmacological and Biomo- lecular Sciences, University of Milan, Italy Angelo Moretto, Prof. Dr., Department of Biomedical and Clini- cal Sciences, Universit degli Studi di Milano, Milano, Italy Paquale Mosesso, Associate Professor of Genetics, member ANS Panel of EFSA, Department of Ecological and Biological Sciences, University of Tuscia, Viterbo, Italy Mikko Nikinmaa, Prof. Dr., Department of Biology, University of Turku, Finland Marc Pallardy, Prof. Dr., INSERM UMR 996, University Paris-Sud, Faculty of Pharmacy, Chatenay-Malabry, France Markku Pasanen, Prof. Dr., University of Eastern Finland, Faculty of Health Sciences, School of Pharmacy, Kuopio, Finland Olavi Pelkonen, Professor of Pharmacology, Department of Pharmacology and Toxicology, University of Oulu, Oulu, Finland Hannu Raunio, Prof. Dr., University of Eastern Finland, Faculty of Health Sciences, School of Pharmacy, Kuopio, Finland Ivonne M.C.M. Rietjens, Prof. dr. ir., Professor in Toxicology, member ANS Panel of EFSA, Wageningen University AFSG/Division of Toxicology, Wageningen, The Netherlands Konrad Rydzynski, Prof. Dr. med., Coordinator of the European Network of Excellence ECNIS (Environmental Cancer Risks, Nutri- tion and the Individual Susceptibility), member SCENIHR, Director of the Nofer Institute of Occupational Medicine, Lodz, Poland Edward V. Sargent, Dr., MPH, PhD DABT, Adjunct Full Professor, School of Public Health, Rutgers University, NJ, USA Tinaa Santonen, MD, PhD, MSc in Applied Toxicology TeamLeader, Chemical Safety, Finnish Institute of Occupational Health, Finland Josef Schlatter, Dr., member of EFSA Scientic Committee, Zrich, Switzerland Dieter Schrenk, MD PhD, Professor of Toxicology, member CON- TAM Panel of EFSA, Food Chemistry and Toxicology University of Kaiserslautern, Germany Richard M Sharpe, Prof. Dr., MRC Centre for Reproductive Health, The Queens Medical Research Institute, University of Edin- burgh, Scotland, UK Andrzej C Skladanowski, PhD, Prof. Dr., Medical University of Gdansk Intercollegiate Faculty of Biotechnology UG-MUG, Depart- ment of Molecular Enzymology, Gdansk, Poland Ralf Stahlmann, Prof. Dr. med., Institut fr Klinische Pharmakol- ogie und Toxikologie, Charit Universittsmedizin Berlin, Germany Frank M. Sullivan, BsC (Hons), FBTS, formerly UK Specialist in Reproductive Toxicology James A. Swenberg, DVM, PhD, DACVP, KenanDistinguishedProfes- sor of Environmental Sciences and Engineering, Gillings School of Glo- bal Public Health, University of North Carolina, Chapel Hill, NC USA Emanuela Testai, Dr., former member SCHER, CSTEE, member SCENIHR, Istituto Superiore di Sanit, Environment & Primary Pre- vention Dept., Mechanisms of Toxicity Unit, Roma, Italy Jouko Tuomisto, MD, PhD, Professor emeritus, Department of Environmental Health, THL (National Institute for Health and Wel- fare), Kuopio, Finland N.P.E. Vermeulen, Prof. Dr., AIMMS/LACDR-Section of Molecular Toxicology, Dept. of Chemistry & Pharmaceutical Sciences, VU Uni- versity, Amsterdam, The Netherlands A4 Editorial / Chemico-Biological Interactions 205 (2013) A1A5 Marco Vighi, Prof. Dr., former member SCHER, Department of Earth and Environmental Sciences, University of Milano Bicocca, Milano, Italy Matti Viluksela, Prof. Dr., former member SCHER, National Insti- tute for Health and Welfare Department of Environmental Health, Kuopio, Finland and University of Eastern Finland Department of Environmental Science Kuopio, Finland Wolfgang Vlkel, PD Dr., ERT, Bayerisches Landesamt fr Gesundheit und Lebensmittelsicherheit, Sachgebiet Chemikaliensi- cherheit und Toxikologie/Biomonitoring, Mnchen, Germany J.C. Vos, Dr., Dept. of Chemistry & Pharmacochemistry, AIMMS- Section of Molecular Toxicology, Vrije Universiteit, Amsterdam, The Netherlands Wojciech Wasowicz, Prof. Dr., President of the Polish Society of Toxicology, Nofer Institute of Occupational Medicine, Lodz, Poland Professor Anne Glover CBE, Chief Scientic Adviser to the President of the European Commission Berlaymont 08/039, Rue de la Loi 200, B-1049 Brussels, Belgium Available online 4 July 2013 Editorial / Chemico-Biological Interactions 205 (2013) A1A5 A5 Policy Decisions on Endocrine Disruptors Should Be Based on Science Across Disciplines: A Response to Dietrich et al. A. C. Gore, J. Balthazart, D. Bikle, D. O. Carpenter, D. Crews, P. Czernichow, E. Diamanti-Kandarakis, R. M. Dores, D. Grattan, P. R. Hof, A. N. Hollenberg, C. Lange, A. V. Lee, J. E. Levine, R. P. Millar, R. J. Nelson, M. Porta, M. Poth, D. M. Power, G. S. Prins, E. C. Ridgway, E. F. Rissman, J. A. Romijn, P. E. Sawchenko, P. D. Sly, O. Sder, H. S. Taylor, M. Tena-Sempere, H. Vaudry, K. Wallen, Z. Wang, L. Wartofsky, and C. S. Watson Division of Pharmacology and Toxicology, The University of Texas, Austin, Texas 78712 (A.C.G.); University of Lige, GIGA Neurosciences, B-4000 Lige, Belgium (J.B.); VA Medical Center and University of California, San Francisco, San Francisco, California 94143 (D.B.); Institute for Health and the Environment, University at Albany, State University of New York, Albany, New York 12222 (D.O.C.); Section of Integrative Biology, The University of Texas, Austin, Texas 78712 (D.C.); Professor Emeritus of Pediatrics, University of Paris, 75006 Paris, France (P.C.); Medical School University of Athens, Sotiria Hospital, Athens 115 27, Greece (E.D.-K.); Department of Biological Sciences, University of Denver, Denver, Colorado 80208 (R.M.D.); Department of Anatomy, University of Otago, North Dunedin 9016, New Zealand (D.G.); Icahn School of Medicine at Mt Sinai, New York, New York 10029 (P.R.H.); Beth Israel Deaconess Medical Center, and Harvard Medical School, Boston, Massachusetts 02115 (A.N.H.); University of Minnesota Masonic Cancer Center, Minneapolis, Minnesota 55455 (C.L.); University of Pittsburgh Cancer Institute and Magee Womens Research Institute, Pittsburgh, Pennsylvania 15213 (A.V.L.); Wisconsin National Primate Research Center, Madison, Wisconsin 53715 (J.E.L.); UCT/MRC Receptor Biology Unit, University of Cape Town, Cape Town, South Africa (R.P.M.); Department of Neuroscience, The Ohio State University Wexner Medical Center, Columbus, Ohio 43210 (R.J.N.); Hospital del Mar Institute of Medical Research and School of Medicine, Universitat Autnoma de Barcelona, 080041 Barcelona, Spain (M.Porta); Uniformed Services University of the Health Sciences, Bethesda, Maryland 20814 (M.Poth); Department of Biosciences, Universidade do Algarve, 8005139 Faro, Portugal (D.M.P.); Department of Physiology and Biophysics, University of Illinois, Chicago, Illinois 60612 (G.S.P.); Department of Medicine, University of Colorado School of Medicine, Denver, Colorado 80208 (E.C.R.); Department of Biochemistry and Molecular Genetics, School of Medicine, University of Virginia, Charlottesville, Virginia 22908 (E.F.R.); Division of Medicine, Academic Medical Center, University of Amsterdam, 1012 WX Amsterdam, The Netherlands (J.A.R.); Laboratory of Neuronal Structure and Function, The Salk Institute, La Jolla, California 92037 (P.E.S.); Queensland Childrens Medical Institute, University of Queensland, Royal Childrens Hospital, Brisbane, Queensland 4000, Australia (P.D.S.); Karolinska Institutet at Karolinska University Hospital Solna, 171 76 Stockholm, Sweden (O.S.); Department of Obstetrics, Gynecology and Reproductive Sciences, Yale School of Medicine, New Haven, Connecticut 06510 (H.S.T.); Department of Cell Biology and Physiology, University of Crdoba, 14071 Crdoba, Spain (M.T.-S.); Institut National de la Sant et de la Recherche Mdicale U982, University of Rouen, 76821 Rouen, France (H.V.); Department of Psychology and Yerkes National Primate Research Center, Emory University, Atlanta, Georgia 30322 (K.W.); Department of Psychology and Neuroscience, Florida State University, Tallahassee, Florida 32306 (Z.W.); Department of Medicine, Washington Hospital Center, Washington, DC 20010; and Department of Biochemistry and Molecular Biology, University of Texas Medical Branch, Galveston, Texas 77555 (C.S.W.) (Endocrinology 154: 39573960, 2013) ISSN Print 0013-7227 ISSN Online 1945-7170 Printed in U.S.A. Copyright 2013 by The Endocrine Society Received September 14, 2013. Accepted September 14, 2013. Abbreviations: EDC, endocrine disrupting chemical; UNEP, United Nations Environment Programme; WHO, World Health Organization. E D I T O R I A L doi: 10.1210/en.2013-1854 Endocrinology, November 2013, 154(11):39573960 endo.endojournals.org 3957 W e are writing as scientists and editors of leading peer-reviewed journals that have published impor- tant contributions in the study of endocrine disrupting chemicals (EDCs). By signing this editorial, we affirmthat regulatory decisions on EDCs should be made based on the best available science and expertise that involves, among others, reproductive biology, endocrinology, med- icine, genetics, behavior, developmental biology, and tox- icology (1). (For a complete list of Signatories and their Disclosures, see Supplemental Table 1 published on The Endocrine Societys Journals Online web site at http://end.endojournals.org.) Thousands of published studies have revealed the health effects of EDCs on wildlife and laboratory animals and, moreover, have shown associations of EDCs with effects in humans. Many of these studies have been reviewed recently by The Endocrine Society, the United Nations Environment Programme (UNEP) and World Health Organization (WHO), andother independent scientists (25). The conclu- sions presented in each of these documents are extraordi- narilyconsistent: like hormones, EDCs are active at very low doses and can induce a range of adverse health outcomes, many of which are not examined in traditional toxicology assays (1). In sum, these reports point to the conclusion that EDCs pose a global health threat. Arecent editorial signed by a number of editors of tox- icology journals argues for the status quo in the regulation of EDCs (6), despite the large volume of evidence indicat- ing that current regulations are ineffective in protecting human populations from these chemicals (47). As the UNEP/WHOreport notes, the incidence of chronic disease is nowgreater thanthat of communicable disease; many of these diseases have an endocrine basis. Both experimental animal and epidemiology studies provide plausible causal links between EDCs and many of these diseases; for some, the data are sufficiently robust (8). The dismissive approach to endocrine disruption sci- ence put forth by Dietrich et al (6) is unfounded, as it is neither based on the fundamental principles of how the endocrine system works and how chemicals can interfere with its normal function, nor does it consider the conse- quences of that interference. Their letter also ignores a growing and rigorous body of literature on both endoge- nous hormonal and exogenous EDC effects. Basic scientists, clinical investigators, and physicians understand that the endocrine systems functions and re- sponses change remarkably across the life cycle. Of par- ticular concern is incontrovertible evidence, published more than a half century ago (9, 10), that there are critical life stages, especially during early development, whenhor- mones dictate the differentiation and development of tis- sues. Any perturbation of the delicate hormonal balance, whether due to the absence of natural hormones or the presence of exogenous hormones, can have irreversible effects on endocrine-sensitive organs. EDCs are known to upset this delicate balance. Dietrich et al (6) also misrepresent the state of science on thresholds, stating that the evidence clearly demon- strates the presence of a threshold for nongenotoxic com- pounds including EDCs. Dietrich et al assert that their position constitutes common sense and that the Euro- pean Commissions approach departs from common sense. Theydonot, however, provide scientific support for this position. Instead, they list several references (1115) that, upon examination, do not contain data supporting their assumption but rather simply assert that the assump- tion is true. They also fail to address the considerable lit- erature that speaks against that assumption (eg, Refs 16 20). Finally, they argue that structuring regulation upon the assumption of no threshold will set an unforeseen precedence [sic]. This is simply and demonstrably not true. The assumption of no threshold has been widely used, for many years, in the regulation of genotoxic car- cinogens, often based on in vitro data. We believe extend- ingthis precedent toEDCs is supportedbythe science (19). Furthermore, we hold that common sense dictates that policies, particularly those in which public health is at stake, should be based on scientific evidence obtained from the worlds leading researchers and should derive from a more evolved, modernunderstandingof thescience, ratherthanon older, outdatedconcepts anddatataught inclassrooms 20or more years ago. The European Commission policy, by that standard, does represent common sense. Further, the US National Academy of Sciences has con- cluded that because of the range of susceptibility to environ- mental chemicals across the population, such as that from age, preexisting conditions, and genetic variation, and be- causetherearedocumentedexposures tomultiplechemicals, including EDCs, in the population, it is more appropriate to consider lack of thresholds at a population level (16). Many toxicologists have developed rigorous research programs on EDCs that incorporate endocrinological principles, including two former presidents of the Society of Toxicology, Cheryl Walker and Linda Birnbaum. They and many other toxicologists do work in this area and report results that have contributed to the breadth and depth of concern about EDCs as a global public health threat. The ad hominem attacks in Dietrich et al (6) do nothing to advance science or opportunities to protect public health; we refer readers totwoadditional responses to their editorial that support this point of view (21, 22). We need the fields of toxicology, endocrinology and other stakeholders to work together to address these issues, not engage in recriminations. 3958 Gore et al Editorial Endocrinology, November 2013, 154(11):39573960 Policymakers in Europe and elsewhere should base their decisions onscience, not onassumptions basedonprinciples that arose out of research on chemicals that are not EDCs. The letter by Dietrich et al does the European Commission, science, including the field of toxicology, and most impor- tantly, public health, a profound disservice. Acknowledgments The following is the list of signatories. The complete list of their affiliations and disclosure information is provided in Supple- mental Table 1. Signatories Journal Editors-in-Chief: 1. Prof. Jacques Balthazart, PhD, Frontiers in Neuroendocrinology 2. David O. Carpenter, MD, Reviews on Environmental Health 3. Paul Czernichow, MD, Hormone Research in Pediatrics 4. Donald B. DeFranco, PhD, Molecular Endocrinology 5. Robert M. Dores, PhD, General and Comparative Endocrinology 6. Andrea C. Gore, PhD, Endocrinology 7. David Grattan, PhD, Journal of Neuroendocrinology 8. Stephen R. Hammes, MD, PhD, Editor-in-Chief elect, Molecular Endocrinology 9. Patrick R. Hof, MD, Journal of Comparative Neurology 10. Carol Lange, PhD, Hormones and Cancer 11. Jon E. Levine, PhD, Frontiers in Neuroendocrinology 12. Deborah M. Power, PhD, General and Comparative Endocrinology 13. Professor Robert P. Millar, PhD, FRSE, Neuroendocrinology 14. E. Chester Ridgway, MD, MACP, Endocrine Reviews 15. Johannes A. Romijn, MD, PhD, European Journal of Endocrinology 16. Peter D. Sly, MBBS, FRACP, MD, DSc, Reviews on En- vironmental Health 17. Hubert Vaudry, PhD, DrSci, Frontiers in Neuroendo- crine Science; also Senior Editor, Journal of Neuroendo- crinology; Associate Editor, Hormone and Metabolic Re- search; Associate Editor, General and Comparative Endocrinology; Associate Editor, Peptides 18. Kim Wallen, PhD, Hormones and Behavior 19. Leonard Wartofsky, MD, MACP, Journal of Clinical En- docrinology and Metabolism 20. Cheryl S. Watson, PhD, Endocrine Disruptors Journal Associate Editors 1. ke Bergman, PhD, Archives of Environmental Contam- ination and Toxicology; Environmental Science and Pol- lution Research 2. Daniel Bikle, MD, PhD, Endocrinology 3. Barbara A. Cohn, PhD, Endocrine Disruptors 4. David Crews, PhD, Endocrine Disruptors; Journal of Experimental Zoology; Ecological Genetics and Physiology; Sexual Development; Epigenetics 5. Peter L. DeFur, PhD, Endocrine Disruptors 6. Evanthia Diamanti-Kandarakis, MD, PhD, European Journal of Endocrinology 7. Anthony N. Hollenberg, MD, Endocrinology 8. Susan Jobling, PhD, Endocrine Disruptors 9. Jun Kanno, MD, PhD, Environmental Health Perspectives 10. Carolyn Klinge, PhD, Endocrine Disruptors 11. B. Paige Lawrence, PhD, Endocrine Disruptors 12. Adrian V. Lee, PhD, Endocrinology 13. J. P. Myers, PhD, Endocrine Disruptors 14. Randy J. Nelson, PhD, Hormones and Behavior 15. Miquel Porta, MD, MPH, PhD, Journal of Epidemiology & Community Health; European Journal of Clinical Investigation; European Journal of Epidemiology 16. Merrily Poth, MD, Journal of Clinical Endocrinology and Metabolism 17. Gail S. Prins, PhD, Endocrinology; Andrology 18. Emilie F. Rissman, PhD, Endocrinology 19. Paul E. Sawchenko, PhD, Journal of Comparative Neurology 20. Olle Sder, MD, PhD, Hormone Research in Pediatrics 21. Ana M. Soto, MD, Progress in Biophysics and Molecular Biology 22. Shanna Swan, PhD, Endocrine Disruptors 23. Hugh S. Taylor, MD, Endocrinology 24. Manuel Tena-Sempere, MD, PhD, Endocrinology 25. Frederick vom Saal, PhD, Endocrine Disruptors 26. Zuoxin Wang, PhD, Hormones and Behavior 27. Wade V. Welshons, PhD, Endocrine Disruptors 28. R. Thomas Zoeller, PhD, Endocrine Disruptors Additional Signatories 1. Benson T. Akingbemi, PhD 2. Koji Arizono, PhD 3. Scott M. Belcher, PhD 4. Fiorella Belpoggi, PhD 5. Carl-Gustaf Bornehag, PhD 6. Jean-Pierre Bourguignon, MD, PhD 7. Terry R. Brown, PhD 8. Ernesto Burgio, MD 9. Terrence J. Collins, PhD 10. D. Andrew Crain, PhD 11. Barbara Demeneix, PhD 12. Rodney R. Dietert, PhD 13. Loretta Doan, PhD 14. Thea M. Edwards, PhD 15. Mariana F. Fernandez, PhD 16. R. William Field, PhD, MS 17. Linda C. Giudice, MD, PhD 18. Louis J. Guillette, PhD 19. Y. Leon Guo, MD, PhD, MPH doi: 10.1210/en.2013-1854 endo.endojournals.org 3959 20. Tyrone Hayes, PhD 21. Andrea Hinwood, PhD 22. C. Vyvyan Howard, MB, ChB, PhD, FRCPath 23. Eric R. Hugo, PhD 24. Patricia Hunt, PhD 25. Taisen Iguchi, PhD 26. Richard J. Jackson, MD, MPH, AIA(Hon), ASLA(Hon) 27. Patricia Joseph-Bravo, PhD 28. Hans Laufer, PhD 29. Duk-Hee Lee, MD, PhD 30. Rachel Morello-Frosch, PhD, MPH 31. Jane Muncke, PhD 32. Angel Nadal, PhD 33. David O. Norris, PhD 34. Jrg Oehlmann, PhD 35. Nicolas Olea, MD, PhD 36. Edward F. Orlando, PhD 37. Vasantha Padmanabhan, PhD 38. Paola Palanza, PhD 39. Stefano Parmigiani, PhD 40. Donald W. Pfaff, PhD 41. Beverly S. Rubin, PhD 42. Joan V. Ruderman, PhD 43. Arnold Schecter, MD, MPH 44. Toshi Shioda, MD, PhD 45. Martin Scheringer, PhD 46. Niels E. Skakkebaek, MD 47. Howard M. Snyder III, MD 48. Carlos Sonnenschein, MD 49. Richard W. Stahlhut, MD, MPH 50. Laura Vandenberg, PhD 51. Catherine VandeVoort, PhD 52. Martin Wagner, PhD 53. Hong-Sheng Wang, PhD 54. Bernard Weiss, PhD 55. Teresa Woodruff, PhD 56. Tracey Woodruff, PhD Address all correspondence and requests for reprints to: An- drea C. Gore, PhD, Editor-in-Chief, Endocrinology, Gustavus, Louise Pfeiffer Professor of Pharmacology, Toxicology, The Uni- versity of Texas at Austin, Austin, Texas 78712. E-mail: andrea.gore@austin.utexas.edu. References 1. American Society of Human Genetics, American Society for Repro- ductive Medicine, Endocrine Society, Genetics Society of America, Society for Developmental Biology, Society for Pediatric Urology, Society for the Study of Reproduction, Society for Gynecologic In- vestigation. Assessing chemical risk: societies offer expertise. Sci- ence. 2011;331:1136. 2. Diamanti-Kandarakis E, Bourguignon JP, Giudice LC, et al. Endo- crine-disrupting chemicals: an Endocrine Society scientific state- ment. Endocr Rev. 2009;30:293342. 3. Vandenberg LN, Colborn T, Hayes TB, et al. Hormones and en- docrine-disrupting chemicals: low-dose effects and nonmonotonic dose responses. Endocr Rev. 2012;33:378455. 4. Zoeller RT, Brown TR, Doan LL, et al. Endocrine-disrupting chem- icals and public health protection: a statement of principles fromthe Endocrine Society. Endocrinology. 2012;153:40974110. 5. Bergman A, Heindel JJ, Jobling S, Kidd KA, Zoeller RT, eds. State of the Science of Endocrine Disrupting Chemicals2012. An As- sessment of the State of the Science of Endocrine Disruptors Pre- pared by a Group of Experts for the United Nations Environment Programme and World Health Organization. Geneva, Switzerland: United Nations Environment Programme and the World Health Or- ganization; 2013. 6. Dietrich DR, Aulock SV, Marquardt H, et al. Scientifically un- founded precaution drives European Commissions recommenda- tions on EDC regulation, while defying common sense, well-estab- lished science and risk assessment principles. Chem Biol Interact. 2013;205:A1A5. 7. Vandenberg LN, Colborn T, Hayes TB, et al. Regulatory decisions on endocrine disrupting chemicals should be based on the principles of endocrinology. Reprod Toxicol. 2013;38:115. 8. Birnbaum LS. Environmental chemicals: evaluating low-dose ef- fects. Environ Health Perspect. 2012;120:A143A144. 9. Phoenix CH, Goy RW, Gerall AA, Young WC. Organizing action of prenatally administered testosterone propionate on the tissues me- diating mating behavior in the female guinea pig. Endocrinology. 1959;65:369382. 10. Wallen K. The Organizational Hypothesis: reflections on the 50th anniversary of the publication of Phoenix, Goy, Gerall, and Young (1959). Horm Behav. 2009;55:561565. 11. Boobis AR, Daston GP, Preston RJ, Olin SS. Application of key events analysis to chemical carcinogens and noncarcinogens. Crit Rev Food Sci Nutr. 2009;49:690707. 12. Borgert CJ, Sargent EV, Casella G, Dietrich DR, McCarty LS, Golden RJ. The human relevant potency threshold: reducing uncer- tainty by human calibration of cumulative risk assessments. Regul Toxicol Pharmacol. 2012;62:313328. 13. Piersma AH, Hernandez LG, van Benthem J, et al. Reproductive toxicants have a threshold of adversity. Crit Rev Toxicol. 2011;41: 545554. 14. Rhomberg LR, Goodman JE, Haber LT, et al. Linear low-dose ex- trapolation for noncancer health effects is the exception, not the rule. Crit Rev Toxicol. 2011;41:119. 15. Rhomberg LR, Goodman JE. Low-dose effects and nonmonotonic dose-responses of endocrine disrupting chemicals: Has the case been made? Regul Toxicol Pharmacol. 2012;64:130133. 16. vom Saal FS, Sheehan DM. Challenging risk assessment. Forum Appl Res Public Policy. 1998;13:1118. 17. Sheehan DM, WillinghamE, Gaylor D, Bergeron JM, Crews D. No threshold dose for estradiol-induced sex reversal of turtle embryos: how little is too much? Environ Health Perspect. 1999;107:155 159. 18. Sheehan DM, vom Saal FS. Low dose effects of hormones: a chal- lenge for risk assessment. Risk Policy Rep. 1997;4:3139. 19. Sheehan DM. No-threshold dose-response curves for nongenotoxic chemicals: findings and applications for risk assessment. Environ Res. 2006;100:9399. 20. Welshons WV, Thayer KA, Judy BM, Taylor JA, Curran EM, vom Saal FS. Large effects from small exposures. I. Mechanisms for en- docrine-disrupting chemicals with estrogenic activity. Environ Health Perspect. 2003;111:9941006. 21. Grandjean P, Ozonoff D. Transparency and translation of science in a modern world. Environ Health. 2013;12:70. 22. Bergman A, Andersson AM, Becher G, et al. Science and policy on endocrine disrupters must not be mixed: a reply to a common sense intervention by toxicology journal editors. Environ Health. 2013;12:69. 3960 Gore et al Editorial Endocrinology, November 2013, 154(11):39573960