John Peterson Myers, Ph.D.
Director, W. Alton Jones Foundation
International Symposium on Environmental Endocrine Disruptors í98
Kyoto International Conference Hall, Japan
11-13 December 1998Send us your comments!
This has been a fascinating and exceedingly important meeting, and I want to thank the Environment Agency of Japan, the Japan Society of Endocrine Disruption Research and especially our distinguished chairs, Dr Mori and Dr. Iguchi, for their hard work and insightful collaboration to make this meeting such a success.
I visited Kyoto last year for the historic United Nations meetings on climate, and was just in Buenos Aires for the next round of climate negotiations. I hope the people of Kyoto, and indeed of Japan, understand how vital and constructive a role their city has played in finding solutions for the very real threat of climate disruption.
And I hope that the effort we have participated in here these last 3 days plays a similarly important role in developing solutions for endocrine disruption.
Climate change represents a threat to the outer world that has provided an environment for millennia in which the human race has prospered. In contrast, endocrine disruption represents a threat to the inner world within ourselves, the intricacies of the biological processes from whence our human nature arises. So it is fitting that if Kyoto has been important to international progress on climate, it should also help lead to solutions on endocrine disruption. Many of us around the world thank the city of Kyoto for its leadership.
We have learned from the scientific presentations of the scale of potential risks posed by endocrine disruption and the difficulties in fully understanding the impacts, and also of the uncertainties that surround many details.
For me, the most urgent aspect of these uncertainties are that¾ even if we don't have absolute scientific proof of widespread human harm¾ we have many indications from wildlife and from laboratory studies that widespread harm to humans is plausible, indeed likely.
We also know that there are many human health problems, growing in frequency and intensity, that are plausibly linked to endocrine disruption.
And we know that human exposure to both classic contaminants like PCBs and DDT and Dieldrin, as well as common use contaminants like atrazine, chlorpyrifos, bisphenol A, phthalates and nonyl phenols is not just widespread, exposure is ubiquitous. That ubiquity means that it is highly unlikely that a human fetus has been born anywhere on earth for the last two generations without at least some exposure to endocrine disrupting chemicals in the womb.
So for me the most urgent aspect of the uncertainties is that we are engaged in a vast global experiment, not in the lab, but in our bodies and in our childrenís bodies and in our mother's wombs. And given what we know about the effect of endocrine disruptors on development, we know that the health impacts of this experiment may not become evident for a generation after each new chemical is released. I believe that means it is morally and scientifically wrong to wait for absolute scientific proof before taking action.
Some people criticize me and my co-authors in Our Stolen Future for acting too quickly, that the science demands we be more cautious. I think they have this backward: it is the cautious scientist who wants to make sure we understand the risks before exposing the public.
Fortunately, even in this state of uncertainty, there are many things that we can and should do... as scientists, as citizens, as regulators and as industries involved in the production, distribution and use of endocrine disruptors
Our book, Our Stolen Future, published last year in Japan, contains a number of suggestions that individual people can take to minimize their risks and the risks to their children, born or those yet unborn. There is a chapter in the book titled "Defending Ourselves." Let me refer you to that chapter and encourage anyone interested to look at the recommendations therein.
I would like to focus here on two perhaps more controversial but concrete and constructive solutions: two for industry, two for government.
With respect to industry, my first recommendation is prompted in part by our experience in the United States with conflicts between science and vested economic interests. It is also prompted by the debate we saw in the meeting yesterday over whose science to believe... that from independent academic research laboratories or from industry.
We all agree that we need scientific research to help resolve the uncertainties, to reveal new problems, and to find solutions. Industry needs it as much as do public health experts. And recognizing this, industry has committed significant funding to research. In the US, however, the problem has been that because of the public's experience with tobacco science and climate science, the public very often doesn't believe the results when they come from an industry whose economic profits depend upon a particular finding being true. There is an inherent conflict of interest. In fact I have been told by a scientist involved in the process that a US trade association involved in this very issue of endocrine disruption stopped funding research because they knew that no one would believe it.
Let me give you an example. It is now widely accepted that lead causes developmental problems in children at low exposure levels, problems including reduced intelligence, learning disabilities, and attention deficit disorder. But as this scientific understanding was developing, there was a curious pattern in the literature reported by an eminent health research scientist, Dr. Herbert Needleman (Lancet, March 29, 1975, p. 751). He analyzed some 40 papers published during the 60s and 70s on the health impact of lead and found a very clear pattern. Roughly half showed health effects while the other half showed no effects. Without exception, those studies reporting detrimental health effects of lead were funded by government or non-industry sources. With only one apparent exception, those studies reporting no health effects acknowledged industry funding. Upon further study, the one exception to the pattern was found to have been supported by industry, but hadn't acknowledged the support.(1)
That isn't to say that all scientists working in industry labs are bad. I personally know many who are very good. But the incentives for how their experiments are conducted and especially how their results are used are often profoundly shaped by the strong incentives of where they work. And that's before the lawyers get hold of the data.
So what do we do? The companies, which have the economic resources to carry out research, don't have the moral authority to have their research believed. The academic researchers, like Dr Iguchi and Dr. Mori and Dr. vom Saal and Dr. Soto, whose work is absolutely crucial, struggle to equip their labs with the people and the resources necessary to answer vital questions.
I would suggest that we find mechanisms by which industry resources can be used to fund research, but that industry be kept at arms length... no soccer field length... from the execution and release of the research.
There are several models of how to do this. They are consistent with an important economic and environmental principle: the polluter should pay, not society. (see Tax Waste, Not Work. Hammond et al. 1997. Redefining Progress.) I believe that the most promising approach may involve the creation of a special tax that would be based on the volume of production and use of potential endocrine disrupting chemicals, weighted by the public health risk. This tax would create an earmarked fund to be directed toward important issues in endocrine disruption by government and independent scientific authorities, like the National Institute of Health and the EPA or their counterparts here in Japan. The fund would be used to support research into basic and applied research about the health risks of endocrine disruptors. Given the scale of economic activity in the chemical industry with endocrine disrupters, it would take on a tiny tax to produce a large research fund.
Let me make one other small recommendation to industry. It is my hope that Japanese industry will avoid the pattern followed by industry trade associations in the United States to spend money on public relations designed to discredit scientists whose work is advancing this field and to sow confusion in the public as to the significance of scientific research.
This practice, well developed in the United States in the public debates over smoking and over climate change, has brought short-term gain to the industries that have adopted it, but also brought them long-term harm. The short-term gain has been the result of the fact that by sowing confusion and disinformation, and emphasizing uncertainties about the science, they have been able to slow government action and thus continue business as usual longer than common sense would dictate . The long-term harm has been to their credibility. And there have been huge financial impacts, also, as we are seeing this year with settlements worth hundreds of billions of dollars for the damage tobacco companies have caused public health and as we have seen in bankruptcies for companies producing asbestos.
Sooner or later, the truth will out, and at least in the United States, juries become especially incensed when they see evidence of the abuse of public trust.
I am struck by the fact that one or more US chemical trade associations appear to have paid for public relations specialists to come to the scientific part of this meeting and attempt to sow confusion among journalists about the nature of the scientific findings being reported. I trust that Japanese journalists were quick to note the source of funding for these publicists, and to view their comments with appropriate skepticism.(2) The scientists who have been working hard at this meeting to share their information with colleagues will be interested to learn that the studies that have been reported back to the US press from this meeting would appear to have selectively emphasized those purporting to show no harm.
I would also encourage industry to stop releasing science by press release. Misleading results published by the Society of the Plastics Industry are only the most recent example, but they are especially egregious. These studies were widely promoted a month ago as showing that Dr Fred vom Saal's research could not be replicated. A poster here repeats that claim. The poster and the press releases failed to draw full attention to the fact that the lab that conducted the study could not replicate the positive control using DES. This might seem like a scientific nuance, but it is vital. It means that they could not do the study... basically that their laboratory was incompetent.. not that Dr. vom Saal's research can't be replicated. Indeed, key parts of Dr. vom Saal's research have been replicated by US government scientists, and presented at a large workshop on low-dose testing last spring, at which industry scientists were present. This makes their claims about Dr. vom Saal's work even more disingenuous.
A related pattern we see in the United States I hope does not take root here, although one paper that was presented as a poster gives me concern. In the United States, we sometimes see results released that show no effect in one specific area, and this result is then used to claim there is no effect in general. This is bad logic. The paper I am referring to here was one showing that styrene does not have an estrogenic effect. Apparently the authors have criticized Our Stolen Future for having falsely identified styrene as an endocrine disruptor. Here, too, there is bad logic or perhaps purposeful misrepresentation. We reported in Our Stolen Future that scientists identified styrene as an endocrine disruptor because of its effect on the production of a brain chemical, dopamine, and on the neuroendocrine system. No one had claimed that it was an estrogen. Thus this new paper does little to resolve the health risks of styrene, although I am pleased to learn that it is not an estrogen. But it only makes sense to wait to accept this finding once we see it confirmed by an independent laboratory.
This is also a good moment to remind everyone that the sex steroid hormones are only a small part of the endocrine disruption problem. There are many other hormone systems we must be concerned with, and many other health endpoints than reproduction. I personally am most concerned about the impacts on brain development and on development of the immune system. There should also be a large research investment in the role of endocrine disruption in disturbing the leptin hormone system, now known to be centrally involved in weight regulation. This is especially important given the epidemic in obesity we are now experiencing around the world.
Let me now turn to steps government might take to improve relevant public policies. I will comment on two: the consumerís right to know and the precautionary principle. These two concepts lie at the core of constructive and appropriate steps to protect the public from endocrine disruption.
First, a very simple step with wide impacts that government could take would be to require manufacturers to label products being sold in the market that contain endocrine disruptors. This principle has been embodied in legislation in California known as Proposition 65, and there are steps now being taken to move it to the federal level.
Why is this important and how might it work? Take the example of bisphenol A leaching out of plastics into food. I am the first to admit that we donít fully understand the health risks involved here, although I think Dr. Vom Saalís work indicate these risks may be huge given that the illness in prostate gland is such an important public health problem. But in the face of uncertainty, why not let the consumer decide whether or not they want to run the risk for their children?
Right now if I go to the supermarket, I canít readily tell which plastics contain bisphenol A, or phthalates, for that matter, and so we have made a decision in our home that we never microwave in plastic. If there were a label on plastic products stating clearly that these ones here do, and these over here do not, contain endocrine disrupting compounds, then I could make the decision for my own family.
Why should we let industry decide what risks our families should take? Our goals are different. They want profits. I want healthy children. So put in place a labeling systemÖ maybe a bright red EDC for those with endocrine disrupting chemicals in them, and a green EDC with a line through it for those without. Very quickly, I think, the manufacturers would find that their products with EDCs would become less popular, and inventive companies would make a lot of money by producing competing products that were EDC free. Making money is not incompatible with ending endocrine disruption.
The second step government should consider is following the example of the Swedish Governmentís Chemical Policy Committee. This committee has explored what it would mean to implement the precautionary principle in Sweden.
Why is this important? If there is a general message to the emergence of endocrine disruption as a health issue, it isnít just that we havenít been able to catch up with all the chemicals in use and the new ones coming on the market, it is also that we are caught with a scientific and regulatory structure that for decades was ignorant of what questions to ask.
Experience tells us that we do not do very well at anticipating unexpected forms of toxicity, and that commerce proceeds to ramp up production and dispersion of new compounds far more rapidly than the sciences of toxicology and epidemiology can advance. The pace at which these two sciences move forward is not commensurate with the pace of commercialization of new products. The result is that we wind up performing decades long experiments on the public and we do so even lacking adequate monitoring systems to alert us to problems.
The Chemicals Policy Committee of the Swedish government was established in 1996 in Sweden to evaluate approaches to achieving an environmentally sustainable chemical industry.
The CPC begins by observing, as I just mentioned, that we do not do very well at anticipating unexpected forms of toxicity. They go on to observe that substances that are persistent and bioaccumulative create widespread exposure, both through atmospheric and water transport as well as through trade, and that when problems are finally identified the exposures cannot easily be reduced simply by discontinuing production. They conclude that for substances that are persistent and bioaccumulative, we are virtually guaranteed to find that knowledge of adverse impacts will come too late to avoid widespread damage.
The Swedish Chemicals Policy Committee has proposed a series of targets for the governmentís chemical policies:
Specifically with respect to endocrine disrupters, the Chemical Policy Committee has proposed that substances that meet criteria established for endocrine disrupters be phased out, without the need to achieve scientific certainty in demonstrating harm. Period. Even more dramatically, the Committee recommends that polyvinyl chloride plastic materials be phased out from commerce no later than 2007.
This approach is radically different from that being used in the United States, because it begins with the premise that precautionary measures should be taken in the face of significant potential harm even without scientific certainty. They go farther, however, than the most timid applications of precautionary measures, by acknowledging that if our centuryís experience with chemical safety issues has demonstrated anything, it is that we do very poorly at anticipating deleterious effects mediated by unanticipated mechanisms of toxicity.
The SPCís targets are directed toward industry. They are ambitious. They are intended to generate driving forces for change in the choice of chemicals and products and in requirements for products.
They have chosen a long time frame for change, out to the year 2012. They judge that ten to 15 years is a reasonable lead time for targets related to restrictions and phase-outs. Were the timetable longer, then motivation to implement new design criteria would be insufficient. Were it shorter, the targets would be viewed as unrealistic.
The targets focus on sending market signals with enough lead time to allow manufacturers to develop and implement new design criteria. The fact is thatówith the significant exception of pesticidesórarely do products of the modern chemical industry require biological activity, environmental persistence or bioaccumulation as a design objective of products. By being explicit about the need to employ design criteria that explicitly eliminate these characteristics, we are more likely to encourage the development of a sustainable chemical industry which can continue delivering the benefits of modern chemical synthesis with much less risk.