Rebutting Industry Science with Knowledge Consultancy
R.I.S.K. Consultancy
I work with chemical policy NGOs to make chemical risk assessment more stringent.
ID: 182729722658-84
Lobbying Activity
Response to Changes to greening rules and clarifications of certain other direct payments' rules
11 Jan 2017
Farming is obviously crucial, but not just in simple economics: no other sector is so involved and dependant on ecology. So it is only logical for humans to live by sustaining, not destroying or treating, the eco system that keeps us alive.
Massive scientific literature documents the harm that petrochemical pesticides (which life did not evolve in the presence of) have. This all is reflected in EU's greening agric. policy. Therefore, strengthen, do not weaken or let slide, the ban of pesticides in EFAs. Similarly, require N-fixing crops be part of crop rotation in all farming areas.
Read full responseResponse to Criteria to identify endocrine disruptors for biocidal products
23 Jul 2016
I have no expertise on whether the Commission has gone beyond what the EU Treaties and related law allow it to do in changing settled laws that the three main bodies have agreed on. Nevertheless it feels obvious that it has. Namely:
1) You claim that POTENCY will not be a criteria to identify EDC. But destroying the limits on the one derogation that required there to be no exposure (adding 'risk' to the determination) causes every determination to consider potency. Also eliminate the proposed change, "which aim to [exclude contact]".
2) Obviously, requiring an agent to be a 'known' EDC is a radical change in the law you are supposed to enforce. How many decades, and how tentatively did the smoking = non-small cell lung cancer causation link take to be established? This is as far from your mandate to be precautionary as I can actually imagine. I ask you critically think about industry's specific comments (Bayer, ECPA, ...) that:
A) the CMR CATEGORIES are not scientific. This was not substantiated, and a lot of scientific bodies and regulators would be surprised to hear it (IARC, USEPA, etc.)
B) applying CMR-like categories would not support EDC decisions or provide legal clarity.
If you wanted to conform to the law's previous paragraphs, you would add 'suspected EDC' or 'that may be EDC' to the EDC criteria (and this latter claim by industry might logically evaporate).
3) The proposal to 'primarily' base the EDC determination on 'international guideline' toxicity studies is 100% incompatible with the following requirement, that systematic review be used to decide EDC. This in entirely illogical--one cannot do systematic review, which begins with the assumption that all data is equal and must be evaluated, if the OECD Test Guidelines and their equivalents are privileged. You will not find a single definition or method for performing systematic review for either chemicals or in medicine that fails to say all evidence must be objectively evaluated).
If you choose to solve this illogic by deleting the systematic review requirement, you would be changing this legal paragraph to make it radically different than the preceding identical paragraphs (one each for determining C,M and R); which say those properties may be determined using either the guideline studies or the academic (published) literature.
Aside from being less precautionary, I cannot imagine the intent of the EU bodies was to have such a radically different evidentiary base for EDCs (even thugh EDCs were given no categories). The reason for this being so radical a change is that only industry uses the guideline methods, and they are very insensitive to detect any chronic toxicities (see Buonsante et al. 2014 for both those claims).
IN SUMMARY, hewing to the existing settled law (having the EDC criteria survive the legal challenges) would seem to require making the above changes.
Read full responseResponse to Criteria to identify endocrine disruptors for plant protection products
23 Jul 2016
I have no expertise on whether the Commission has gone beyond what the EU Treaties and related law allow it to do in changing settled laws that the three main bodies have agreed on. Nevertheless it feels obvious that it has. Namely:
1) You claim that POTENCY will not be a criteria to identify EDC. But destroying the limits on the one derogation that required there to be no exposure (adding 'risk' to the determination) causes every determination to consider potency. Also eliminate the proposed change, "which aim to [exclude contact]".
2) Obviously, requiring an agent to be a 'known' EDC is a radical change in the law you are supposed to enforce. How many decades, and how tentatively did the smoking = non-small cell lung cancer causation link take to be established? This is as far from your mandate to be precautionary as I can actually imagine. I ask you critically think about industry's specific comments (Bayer, ECPA, ...) that:
A) the CMR CATEGORIES are not scientific. This was not substantiated, and a lot of scientific bodies and regulators would be surprised to hear it (IARC, USEPA, etc.)
B) applying CMR-like categories would not support EDC decisions or provide legal clarity.
If you wanted to conform to the law's previous paragraphs, you would add 'suspected EDC' or 'that may be EDC' to the EDC criteria (and this latter claim by industrymight logically evaporate).
3) The proposal to 'primarily' base the EDC determination on 'international guideline' toxicity studies is 100% incompatible with the following requirement, that systematic review be used to decide EDC. This in entirely illogical--one cannot do systematic review, which begins with the assumption that all data is equal and must be evaluated, if the OECD Test Guidelines and their equivalents are privileged. You will not find a single definition or method for performing systematic review for either chemicals or in medicine that fails to say all evidence must be objectively evaluated).
If you choose to solve this illogic by deleting the systematic review requirement, you would be changing this legal paragraph to make it radically different than the preceding identical paragraphs (one each for determining C,M and R); which say those properties may be determined using either the guideline studies or the academic (published) literature.
Aside from being less precautionary, I cannot imagine the intent of the EU bodies was to have such a radically different evidentiary base for EDCs (even thugh EDCs were given no categories). The reason for this being so radical a change is that only industry uses the guideline methods, and they are very insensitive to detect any chronic toxicities (see Buonsante et al. 2014 for both those claims).
IN SUMMARY, hewing to the existing settled law (having the EDC criteria survive the legal challenges) would seem to require making the above changes.
Read full response