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Universität Konstanz

UKON

Founded in 1966 as a reform university, the University of Konstanz stands for cutting-edge research, excellence in teaching and study, internationality as well as inter- and transdisciplinary collaboration.

Lobbying Activity

Meeting with Katarina Barley (Member of the European Parliament, Shadow rapporteur)

6 Mar 2023 · Austausch zum Vorhaben (staff level)

Response to Towards a more comprehensive EU framework on endocrine disruptors

6 Jul 2018

It is very disturbing to realize that the Comission based their initiative on untenable scientific grounds. Indeed, whiel adverse effects of EDCs in animals can be proven (at high concentrations), all present data published regarding the putative effects of EDCs in humans are untenable und unprovable. Indeed, using the ECs own definition of a rare disease (namely 1 per 2000 persons) one can clearly conclude that the alleged adverse effects of EDCs in humans, e.g. DDE and oncreased obesity or diabetes type 2 in 10 year olds, in the very worst case calculated could detect 1 in 10'000. The latter meaning that these presumed effects could never be detected via any means. Moreover, the 2012 UNEP State of the Science of endocrine disupting chemicals as well as the European Environment Agency's 2012 "impacts of endocrine disrupters on wildlife, people and their environment" have been demosntrated to be severely biased and flawed with regard to their scientific evidence (See Bond and Dietrich, Archives of Toxicology 2017 and Bond and Dietrich J Epidemiol Comm Health 2017, both attached). Similarly the series of published papers and alleged EDC mediated health effects in humans have been demonstrated via scientific analysis to be untenable, i.e. mere speculation without credible scientific basis (see attached). Moreover, in all cases, the issue of exposure to equally or more potent natural EDCs (e.g. Bisphenol F, see Dietrich and Hengstler Arch. Tox 2016) in the alleged human health effects of EDCs are completly ignored. Indeed, an assessment of hazard and risk of specific EDCs by the US National Academy of Sciences "Low-dose Phthalates and PBDE toxicological evaluation 21.7.2017 – I Epidemiology & Animal Data" clearly stated in their conclusions that e.g. the brominated flame retardent "BDE-47 is a "presumed" hazard to humans with respect to effects on intelligence"........However "identifying the potential of a chemical to cause particular forms of toxicity in humans does not indicate whether the substance poses a risk in specific populations." If the Commission is serious about gathering and weighing evidence for a more comprehensive EU framework on endocrine disrupters it must use solid evidence and not rely on obviously untenable assumptions, irrespective of whether these untenable assumptions and findings were published in peer-reviewed journals. It is the responsibility of the Commission to ensure the greatest care in establishing a framework that encompasses the best scientific evidence available while guaranteeing health and socioeconomical stability for European citizens.
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