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Breast Cancer UK

BCUK

Breast Cancer UK's vision is a world without breast cancer.

Lobbying Activity

Response to Towards a more comprehensive EU framework on endocrine disruptors

18 Jul 2018

Breast Cancer UK welcomes publication of the roadmap “Towards a more comprehensive framework on endocrine disruptors” and appreciates the opportunity to provide feedback to the European Commission. Please see the attached file for our comments.
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Response to Criteria to identify endocrine disruptors for biocidal products

27 Jul 2016

Breast Cancer UK welcomes the opportunity to respond to the proposed criteria for identifying endocrine disrupting chemicals (EDCs). We call on the EU Commission to make significant changes, as we believe that the current proposal requires such a high burden of proof that it will only identify a very small proportion of EDCs. Currently, over 800 chemicals are listed as endocrine disruptors. Over 1300 scientific studies link EDC exposures to increasing rates of hormone-related cancers, fertility problems, diabetes, obesity & behavioural problems in children. Breast Cancer UK is especially concerned that routine exposures to combinations of EDCs (including certain pesticides) are leading to an increased risk of breast cancer. Breast Cancer rates in the UK and elsewhere continue to increase and EDC exposures may be partly responsible. The World Health Organization has called EDCs a “global threat”. The health costs of diseases associated with EDC exposures are estimated at €158 billion yearly in the EU. In the 7th Environmental Action program, the EU made a commitment to minimise exposure to EDCs. The proposed criteria are inconsistent with this aim. The Commission proposes to identify EDCs only if they are “known" to cause an adverse effect relevant to human (or animal) health. Demanding such a high burden of proof weakens the current law, which includes regulation of substances that may cause harm. It also undermines expert opinion about the likelihood of a detrimental effect and is likely to result in damage to humans and the environment before action is taken. This is inconsistent with the precautionary principle enshrined in the EU Treaty and part of the biocide and pesticides law. Furthermore, it is inconsistent with the identification of carcinogens, mutagens and reproductive toxicants, which is based on known or presumed adverse effects. Only this approach is consistent and coherent with the EU biocides law which says biocides should not be allowed on the market if they “are considered as having endocrine-disrupting properties that may cause adverse effects in humans”. The Commission should act on the existing scientific evidence and the best option for health is an approach with 3 categories (confirmed; suspected and potential EDC).Substances should be identified as EDCs on a similar basis to these harmful chemicals. Breast Cancer UK welcomes the use of the WHO/IPCS definition of EDCs, but believes the best option for EDC identification is to include 3 categories (known, suspected, potential) according to the level of evidence available (option 3 of the Commission’s roadmap). The proposal is an adaptation of option 2 of the Commission’s roadmap. It is disappointing this revised option was not presented in the roadmap for consideration by the public. Furthermore, by proposing this option the Commission has ignored the majority of respondents to its 2015 public consultation. We believe the proposed criteria should be changed to ensure a high level of protection for health and the environment, preventing endocrine-related diseases and averting damage to ecosystems. France, Sweden and Denmark have expressed their disagreement to the proposal (http://goo.gl/oU3QDS). The Endocrine Society (https://goo.gl/MNE4c7) and other scientists (http://goo.gl/u0LtIl) have strongly criticised the proposal, as has the construction company Skanska, who believe the criteria should be stronger to identify and phase out potentially harmful materials (http://goo.gl/pmYHkh). EDCs are a threat to our society’s public health and prosperity. Europe should take a leading role in regulating EDCs; this will stimulate innovation so that industries can develop and use better and safer alternatives. Breast Cancer UK calls on the Commission to change the proposed criteria for identifying EDCs from “known” to cause an adverse health effect to “may” cause an adverse health effect, and to include three EDC categories (known, suspected, potential).
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Response to Criteria to identify endocrine disruptors for plant protection products

27 Jul 2016

Breast Cancer UK welcomes the opportunity to respond to the proposed criteria for identifying endocrine disrupting chemicals (EDCs). We call on the EU Commission to make significant changes, as we believe that the current proposal requires such a high burden of proof that it will only identify a very small proportion of EDCs. Currently, over 800 chemicals are listed as endocrine disruptors. Over 1300 scientific studies link EDC exposures to increasing rates of hormone-related cancers, fertility problems, diabetes, obesity and behavioural problems in children. Breast Cancer UK is especially concerned that routine exposures to combinations of EDCs (including certain pesticides) are leading to an increased risk of breast cancer. Breast Cancer rates in the UK and elsewhere continue to increase and EDC exposures may be partly responsible. The World Health Organization has called EDCs a “global threat”. The health costs of diseases associated with EDC exposures are estimated at €158 billion yearly in the EU. In the 7th Environmental Action program, the EU made a commitment to minimise exposure to EDCs. The proposed criteria are inconsistent with this aim. The Commission proposes to identify EDCs only if they are “known to cause an adverse effect" relevant to human health or non-target organisms. Demanding such high burden of proof weakens the current law, which includes regulation of substances that "may" cause harm. It also undermines expert opinion about the likelihood of a detrimental effect and is likely to result in damage to humans and the environment before action is taken. This is inconsistent with the precautionary principle enshrined in the EU Treaty and part of the biocide and pesticides law. Furthermore, it is inconsistent with the identification of carcinogens, mutagens and reproductive toxicants, which is based on known or presumed adverse effects. Substances should be identified as EDCs on a similar basis to these harmful chemicals. Breast Cancer UK welcomes the use of the WHO/IPCS definition of EDCs, but believes the best option for EDC identification is to include 3 categories (known, suspected, potential) according to the level of evidence available (option 3 of the Commission’s roadmap). The Commission also proposes widening the current exemption for those pesticides identified as EDCs, introducing a major loophole. The proposal to change `negligible exposure’ to ‘negligible risk´ would mean continued exposure to these EDCs. The Commission has gone beyond their identification task and weakened the law by reintroducing specific risk assessments for pesticides identified as EDCs. The proposal is a revision of option 2 of the Commission’s roadmap. It is disappointing this revised option was not presented in the roadmap, for consideration by the public. Furthermore, by proposing this option the Commission has ignored the majority of respondents to its 2015 public consultation. We believe the proposed criteria should be changed to ensure a high level of protection for health and the environment, preventing endocrine-related diseases and averting damage to ecosystems. France, Sweden and Denmark have expressed their disagreement to the proposal (http://goo.gl/oU3QDS). The Endocrine Society (https://goo.gl/MNE4c7) and other scientists (http://goo.gl/u0LtIl) have strongly criticised the proposal, as has the construction company Skanska, who support stronger criteria in order to identify and phase out potentially harmful materials (http://goo.gl/pmYHkh). EDCs are a threat to our society’s public health and prosperity. Europe should take a leading role in regulating EDCs; this will stimulate innovation so that industries can develop and use better and safer alternatives. Breast Cancer UK calls on the Commission to change the proposed criteria for identifying EDCs, to include three categories (known, suspected, potential) and specify a substance can only be approved if exposure (not risk) is negligible.
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Meeting with Vytenis Andriukaitis (Commissioner) and

2 May 2016 · Endocrine disruptors