An assessment of endocrine disrupting pesticides by PAN Europe
PAN Europe completed an impact assessment study showing which pesticides are endocrine disrupting chemicals. We used all available data, both industry's dossiers and independent scientific literature and assessed which pesticides should be banned according to the Pesticide Regulation (chemicals with endocrine properties that may cause adverse effects) and which ones are likely to be banned according to the commission's options (as explained in the EDCs-Roadmap and PAN Europe's position on roadmap). The detailed analysis of the results is given in Annex Ia and Ib.
Unlike the exaggerated claims by the industry and farmers- for example that up to 100 pesticides will be banned by the EU resulting in a massive economic impact on agriculture- our report reveals that only seven, four or zero pesticides are likely to be regulated according to the Commission's proposal. Further, we carried out an in-depth analysis on alternatives to these pesticides (Annex II) and we also evaluated the flaws of the industry-reports that claim huge costs and yield losses if such pesticides were to be banned (Annex III). Finally, we analysed the inadequacy of an "economic" impact assessment for decisions that aim to protect human and environmental health and we have given suggestions on what extra elements must be considered by the Commission, that are repeatedly neglected because they don't have a market value (Annex IV).
EDCs-training organized by PAN Europe
We also motivated the participants to respond to the Public Consultation launched at that time by the Commission on the different criteria options for EDCs and the regulatory decision-making. Moreover, we presented a platform tool for a quick response to the public consultation, created by the EDC-free coalition that PAN Europe is also a member. More than 20,000 people used the tool to respond to the consultation, which was a great success.
The event was very fruitful, reinforced collaboration among NGOs and we found the common grounds for action in 2015.
Invitation to the EDC meeting by PAN Europe
“Dear members and colleagues,
There is some heat going on in the Brussels arena in relation to Endocrine Disrupting Chemicals (EDCs). The Public Consultation has been launched (which is so technical that it can hardly be called "public") that will be crucial to determine the next steps: how these chemicals are going to be regulated in Europe.
We don't want EDCs in our food, we don't want them near our houses, children's playgrounds, residential areas, not even near our pets. These chemicals are active in tiny amounts and all scientific evidence suggests that EDCs are bad news. Reproductive anomalies, cognitive difficulties, obesity, diabetes, autism, Parkinson disease are some of the diseases/dysfunctions that may derive from exposure to EDCs- especially when exposure takes place during the early life stages, when the organism is still under development.
The public consultation ends in January. PAN-Europe wants to use this opportunity and organize a training session/seminar among all our members and collaborators about EDC pesticides. Some of the experts on the field including research scientists, MEP advisers, Chemical experts and pioneer NGOs will present the different angles of EDCs and how they affect society and the environment. Furthermore, our members and NGOs active in Netherlands and Brussels will have the chance to present their national activities and discuss further opportunities.
Below is a very preliminary agenda of issues that we would like to include in the seminar (click here for the final agenda).
Thank you in advance for your contribution and collaboration.
1. With the financial support of the European Commission, DG Environment (LIFE2012ENVNL /0008833).
Tell the european commission that you want to remove hormone disrupting chemicals from our lives to protect our health!
PAN Europe and all members of the EDC-free coalition invite you to take action!
The European Commission has launched a public consultation, which is very technical and seems uninterested in the public opinion on hormone disrupting chemicals. But we have made it easy for you to make your voice heard! Just fill in the information below and with four simple steps, your submission will be sent directly to the European Commission.
The prepared answers to the consultation are available via the Questions and answers link below to the right so you can read these before taking action below.
The public consultation is open until 16 January 2015 and it is available in 7 languages. You can find more about the consultation on the European Commission website.
Thank you for your participation!
(PAN Europe is an active member of the EDC-free coalition: A coalition of more than 50 organizations across Europe that have come together through a concern about endocrine disrupting chemicals – EDCs - and aim to raise public awareness and urge quicker governmental action. Our campaign partners include trade unions, consumers, public health and healthcare professionals, advocates for cancer prevention, environmentalists and women’s groups.)
To find more about the EDC-free coalition go to www.edc-free-europe.org.
What are EDCs
Endocrine Disrupting Chemicals (EDCs) are biologically active chemicals of a diverse origin and use (industrial chemicals, plastic components, components of cosmetics, pharmaceuticals, pesticides, biocides etc) that interfere with the hormonal system of animal species, including humans, leading to poor health and the development of disease. They are also called “hormone disruptors”.
The hormonal system can be seen as a network of chemical messengers (hormones) that circulate across the body and transfer the necessary “information” to specific organs to regulate their function and development. These continuous coordinated interactions have the key role to maintain our bodies in equilibrium. During the development of a male foetus, for example, hormones released from the brain stimulate the production of the male hormone testosterone, which passes information to the reproductive system in order to initiate the development of male reproductive organs, together with other male characteristics. When too much testosterone is produced, the brain ceases stimulating its production and testosterone levels are reduced.
Very small amounts of EDCs are capable to interfere with or “disrupt” the natural action of hormones, pass the wrong “messages” to specific organs and result in alterations in morphology, physiology, growth, reproduction, development and behavior. Such changes have been linked to endocrine-related disorders such as reproductive failure, reproductive organ deformities and cancer, diminished fertility, altered sex differentiation, metabolic disorders (e.g. obesity and diabetes in mammals), immune dysfunction and cognitive impairment among other effects.
Why EDCs are different from other toxic chemicals?
What makes these chemicals particular is that they mimic/disrupt the role of hormones that are naturally present in very small concentrations. Thus, a very tiny amount of an EDC is sufficient to trigger an effect. When the wrong hormonal signals are sent during the early-life stages of development, a whole erroneous cascade of events is triggered and the “wrong programming” is set, which will inevitably result in disease and dysfunction later in life. This means that unborn babies (exposed through their mothers), infants and children, are the most vulnerable to EDCs exposure.
When juveniles and adults are exposed to small amounts of EDCs effects may be different because the biological system of the adults can compensate small alterations without resulting in disease. In the classical risk assessment of toxic chemicals the tests are done mainly in adults and therefore they fail to detect the effects of small doses of EDCs in juveniles. Furthermore, these tests assume a safety level, below which exposure can be considered safe. However, scientists are warning us that for EDCs there is no safe level exposure during the early-life stages of development and growth. All these observations, together with the fact that currently there are very few tests in the assessment of toxic chemicals that detect endocrine disruption specifically, point out that several EDCs are being erroneously classified as safe.
The State-of-the-Science for EDCs
There are still great uncertainties regarding the diseases triggered by these chemicals and what are exactly the first biochemical reactions in this long cascade of events that lead to disease. In laboratory studies, scientists have proven that exposure to EDCs during early-life leads to endocrine-related diseases and although several suggestions have been given on how this occurs, in many cases the exact mode of action is an ongoing investigation. For example, one of the most cases of endocrine disruption in wildlife is the development of “imposex” in marine snails, a “masculizination” condition where female snails develop a penis that blocks their reproduction following exposure to the paint biocide agent Tributyltin (TBT). TBT-paints were used widely until the 80s on the hulls of the boats to avoid the attachment of marine organisms that reduce the speed of the boat and cause metal corrosion. A tiny drop of TBT in twenty 50x25 meters swimming pools is enough to cause “imposex” but why this phenomenon occurs is a more than 40-years ongoing investigation. TBT was finally totally banned in 2008 due to the continuous evidence of the adverse impacts on aquatic life.
In such circumstances, where dangers to human, wildlife and environmental health have been detected but scientific data is insufficient to permit the full evaluation of the risk and employ safety measures, EU has to apply the “precautionary principle” and regulate the production and distribution of, in this case, EDCs to avoid further potential damage.
EDCs enter the European Regulations and create a “political disruption”.
Due to their extraordinary effects, EDCs have been in the agenda of the European Union since 1999, when the 'Community strategy for endocrine disruptors' (COM(1999)706) was adopted, foreseeing more research on EDCs to understand their action, identify them and gradually remove them from Europe’s market. Step by step EDCs were incorporated in the legislations related to chemicals (Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals-REACH; Water Framework Directive-WFD; Medical Devices; Cosmetics) but it was the Plant Protection Products Regulation EC 1107/2009 (PPPR), put into force in 2011 to regulate pesticides, the first legislation to apply the precautionary principle on EDCs and introduce “hazard-based cut-off” criteria, as it is applied for mutagenic compounds i.e. any pesticide with EDCs properties is regarded as a hazard and must be banned (hence the wording “cut-off”). Since pesticide residues are found in our food, deciding against the use of such pesticides was certainly a wise move. EDCs “cut-off” criteria were also incorporated later in the Biocide Product Regulation EU 528/2012 (BPR), which was put into force in 2013.
Ironically the Pesticide and Biocide Regulations were put into force before defining the criteria to identify EDCs. This task was first given to the Environment Directory (DG ENVI) of the European Commission that worked together with endocrine disruption experts to elaborate the criteria to identify EDCs. Although a first draft on the EDC criteria was ready in 2013, which was supporting the precautionary approach, DG ENVI did not present the criteria by December 2013, on the proposed deadline. So what happened?
The fact that several EDCs would have to be removed from the market brought reactions in the Commission and industry sector and triggered a different kind of “cascade of events”. The agricultural industry composed reports claiming that far too many pesticides would be identified as EDCs causing a “catastrophic” loss in agricultural production and economy. The reports include irrational statements such as Europe will face hunger and will be excluded from international trade due to its strict regulations. Following the industry lobbying, the Commission Directories of human and consumer health (DG SANCO), Enterprise (DG Enterprise), Trade (DG Trade), Employment (DG Employment) and Secretary General together with the European Food and Safety Agency (EFSA) started putting pressure to recognize EDCs as non-hazardous chemicals- this means that exposure to small quantities will be permitted. On June 2013, a group of 18 toxicologists- 17 of which were later proven to have conflict of interest due to their ties to the industry- published a scientific journal editorial accompanied by a letter written to the Chief Scientific Advisor of the European Commission accusing the Commission of being over-precautionary and against well-established science and risk assessment. This letter was immediately strongly criticized by experts in endocrinology including The Endocrine Society, due to the misleading information it provided on endocrine disruption research. Ironically, when the toxicologists that had composed the first letter were invited to the Commission they failed to support their opinion and admitted their mistake. But the damage was already done, and all the extensive research on EDCs was suddenly under questioning. The industry had succeeded to halt the process. Instead of the criteria on EDCs, the Secretary General of the Commission called for an impact assessment, after all if Europe is to be the first to ban these chemicals, the economic impact should be evaluated. This process will delay the definition of EDCs and consequently our exposure to these chemicals will continue for several years.
The impact assessment will be done on different “regulatory” options, but in reality it will decide what definition we will give to these chemicals to fit the regulatory procedures. Instead of having “science-based” politics, we get “politics-based” science! A major evaluation tool will be the economic impact, which will neglect any benefits that are not translated to monetary values, such as the ones of a clean and healthy environment or how we will save money from the diseases that we will not have. Thus, it will be the industry’s economic losses that will determine what are EDCs and whether our new generations will develop endocrine related diseases. This is just another example of the strong industry lobbying deciding on what harmful chemicals we will be exposed.
Updates: Join the Public Consultation on the use of EDCs as pesticides and biocides
What are Endocrine Disrupting Chemicals?
Endocrine Disrupting Chemicals (EDCs) are capable to « disrupt » the hormone system of the human body, which is responsible for the good development and functioning of all vital organs.
More and more top-level scientific studies have shown their dangerous effects on health over the last years, linking them to rising chronic diseases such as diabetes, obesitas, but also hormone-related cancers (breast, prostate...), brain damage and infertility .
A large body of evidence has also warned about the high vulnerability of the unborn and the young children to EDCs, with exposure during key development stages leading to long-term damage like a loss of motility, memory or concentration troubles .
EDCs are all the more dangerous when acting together at the same time because their effects can "add up" (= "cocktail" effects). Eating fruits and vegetables sometimes comes to ingesting on average residues from 20 differents ED pesticides, leading to complex chemical "mixtures".
No "safe" level of exposure
One of the particularities of EDCs is that their effects can be observed at even very low doses , which is why there is no such thing as a "safe" level of exposure.
Some examples of ED pesticides and their health effects:
For the ED pesticides found below, the following health effects have been supported by strong scientific evidence from animal testing :
- Bifenthrin : causing ovulatory dysfunction in females (Liu, 2011).
- Carbendazim and benomyl : causing adverse effects on the male reproductive systems (decreased fertility observed in rats) (Gray, 1990; Lazzary, 2008; Moffit, 2007; Yu, 2009).
- Chlorpyrifos-methyl : blocks the activity of the male sex hormones .(Kang, 2004).
- Mancozeb : a multipotent carcinogen, capable of causing at least 8 different types fo cancer - breast cancer, liver, pancreas, thyroid, etc. (Belpoggi, 2002)
- Prochloraz : causing a feminisation of male offspring and sexual malformations (Blystone and al., 2007).
 For more information, see report by Prof. Kortenkamp appointed by the EU : « State-of-the-art assessment of endocrine disruptors », 2012.
 For information on transgenerational effects, see : “Environmentally Induced Epigenetic Transgenerational Inheritance of Ovarian Disease », Eric Nilsson, Ginger Larsen, Mohan Manikkam, Carlos Guerrero-Bosagna, Marina I. Savenkova, Michael K. Skinner, School of Biological Sciences, Center for Reproductive Biology, Washington State University, Pullman, Washington, United States of America.
 Vandenberg/Soto/Heindel/VomSaal ao. (Endocrine Reviews, June 2012)
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While some progress has been made regarding EDCs in cosmetics, furniture, and baby products, the dangers of exposure through food are still overlooked. Starting with this consumer guide, PAN Europe launches a campaign on EDCs all over Europe. Our next step will be taken this summer with a new action involving all consumers eager to achieve a real policy change.
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