This one's about integrity, oversight, and endocrine disruption and how the tangled web grows bigger by the day. It's a guest post by Jody Roberts, of the Chemical Heritage Foundation.
Two news stories in last week's edition of Chemical and Engineering News perfectly demonstrate the complex interweaving of technical, social, and political processes in attempting to grapple with emerging sciences and environmental health. In the article, "Debating Science," we see once again the hot button issue of science and politics, science in politics, and politics in science. In "Test of Endocrine Disruptors Delayed," we see how these issues have stalled a program that according to Congressional mandate should have been in effect for nearly a decade - and yet it languishes as it tries to understand what it is supposed to do - and how.
Last week the House Energy and Commerce Subcommittee on Oversight and Investigations held a hearing on "integrity in science" at the EPA - or, is there any integrity in science at the EPA? The hearing provided a forum for Deborah Rice, who chaired an external review panel on the toxicological effects of brominated flame retardants in 2007, and Sharon Kneiss, vice president in the products division at the American Chemistry Council. At issue was a request from last year by the ACC to remove Rice's testimony because she had, according to the ACC, forfeited her objectivity by providing expert testimony to a state panel in Maine on the chemicals under investigation. The issue is confusing: Rice was asked to offer expert testimony because she's an expert. Isn't this the same capacity she was asked to serve in for the EPA? If she's not an expert, and she's not willing to offer her expert opinion, then what good is it having her chair a review panel? The ACC contended that she had made up her mind before all of the science was accounted for in this case. So when is the right time to offer expert testimony?
The case of the endocrine disruptor screening program is a perfect case in point of this tactic taken to its extreme. Twelve years ago, in the wake of an increasing number of scientific reports, a BBC documentary, and the publishing of Our Stolen Future, Congress called upon the EPA to establish a screening program for potential endocrine disruptors. Details were to be developed by the end of the 1990s with implementation begin by 2000. Last year, the EPA finally released its first draft list of chemicals to be screened - a list that included chemicals long since known to be involved in endocrine disruption. And, notably, the EPA still had failed to deliver on the means by which they would screen these chemicals. The program has been such a debacle that many of its early and ardent supports have given up on it, including Theo Colborn. The program is an ongoing example of the "integrity in science" issue - but it's also much more than that. Unfortunately, because the politics have become so vitriolic, it's been difficult to see what exactly has gone wrong (a case that easily extends into the story of flame retardants as well).
The nascent screening program suffers quite visibly from a tangled web of politics. For that reason, it's a great example of how industry, academe, NGO, and government continue their long stalemate in regulation - especially when it comes to dealing with new scientific information. But this political struggle has made it more difficult to see the other problems that plague this program. First, it has been almost impossible to develop a good screening method for endocrine disruption because endocrine disruption (ED) is not one thing. The very reason that ED requires new action is the same reason that it has been so difficult to work into practice: the complexity with which chemicals interact with the signaling mechanisms of an organism are vastly more complex than simply working a dose response curve that looks almost exclusively at mortality. Add to this problem the complexity of synergistic effects and suddenly you need not just one assay to test for potential ED effects for each chemical, but an exponential number of assays will have to be run to understand the real world scenario that accurately characterizes our life experiences. We're all carrying hundreds of known synthetic chemicals in our bodies according to CDC human biomonitoring data. (Likely, that number is in the thousands, which would more accurately reflect the chemicals currently in production and use - but current biomarker and biomonitoring research is only offering a limited view at this point.)
Second, that screening method, if it develops, will likely involve unheard of quantities of animal testing. That's one reason (as the article points out) that PETA has gotten so worked up about this. But they aren't the only ones. In the EU, the new cosmetics directive that eliminates animal testing in a broad swath of chemical products is running headlong into REACH, which like the ED program here will require a drastic increase in the number of animals used in these studies. What isn't being discussed is the number of new in vitro options available for testing. Unfortunately, like other tests, most of these have not yet been developed to screen for ED effects and so animal tests are still being relied upon for these new initiatives. Tied to this issue, though, is the legal and regulatory aspect of testing. For a method to be of any use it has to carry weight in each of those arenas. Unfortunately, most of the tests are not seen as valid, and therefore lack this sort of evidentiary weight. But in the meantime, most animal models, too, are not considered valid in courts. So what is considered valid? Clear cause and effect harm done to human persons is considered valid. But in the case of ED, this is nearly impossible. And is that really what we ought to be waiting for, the proverbial bodies in the streets?
Perhaps this is one reason that you can get a quote from Theo Colborn saying that the whole system is broken and that we should just scrap this and start over again. But start over with what? In the case of Colborn, she's looking for the experts to be involved from the outset. And now we find ourselves back at the first story: who counts as an expert and when do they forfeit those credentials? It is indeed a tangled mess. And while many are taking hope in REACH, we should be cautious in thinking about just how much REACH will fix the problem. A general overhaul is long overdo, but we also need the moral (not just political) will to act when the evidence suggests things aren't looking good.