Tunnel vision: The regulation of endocrine disruptors

Abstract

Abstract. This study examines the failure of a small but significant element of U.S. chemical regulatory policy: the Endocrine Disruptor Screening Program (EDSP). A range of conditions are implicated in the failure of this program, but one condition, the scientific testing and regulation paradigm (STRP), seems particularly important and ties the failure of EDSP to the failure of other U.S. chemical regulatory programs. This paradigm is a group of assumptions that have driven pesticide (and other chemical) regulatory policy since World War II. This study investigates the relationship between STRP and the failure of EDSP, the potential efficacy of alternatives to this program, and one alternative that broke from this paradigm. Ultimately, this study suggests that we must revise the role of science in regulation in order to find effective alternatives to modern chemical regulatory policy.

Addressing the temporal fit of institutions: the regulation of endocrine-disrupting chemicals in Europe

“…Although the EU's REACH has reversed the burden of proof from government to producers, the basic assumptions of the paradigm nevertheless remain (Hansen et al 2007). This poses significant problems for the regulation of EDCs because the influence of these chemicals can be acutely and directly toxic, but more often they have indirect, hormonal effects with significant time lags between exposure and observed adverse outcome (Adam 1998, Vogel 2004. Furthermore, such hormonally active chemicals can interact and give rise to so-called mixture effects, or combination effects (e.g., Council of the European Union 2009).…”

“…Nevertheless, new generation risks are at the same time often characterized by a considerable amount of experiential evidence collected and articulated by experts, commonly expressed as alternative scenarios describing the pathways and management of the uncertainties. Even in the absence of exact evidence of impacts, some analysts believe the situation justifies reasonable concern over public safety and warrants precautionary policy action (Vogel 2004, Hukkinen 2008.…”

“…The question of sequence becomes central, as the imperative that scientific determination of harm must precede regulatory action (Vogel 2004) is central in the regulation of EDCs in REACH. This sequence has historical roots and corresponds to a modern linear conceptualization of science and its relationship to policy making (e.g., Jasanoff 1990).…”

“…Endocrine-disrupting chemicals (EDCs), or substances that adversely interfere with the hormonal systems of living beings, have been on the political agenda in most industrialized countries since the early 1990s (Krimsky 2000, Vogel 2004, Hecker and Hollert 2011. The use of EDCs is widespread and can be found in numerous consumer goods, such as cosmetic and pharmaceutical products.…”

“…The use of EDCs is widespread and can be found in numerous consumer goods, such as cosmetic and pharmaceutical products. However, despite a deeply felt concern and massive efforts by the scientific community and nongovernmental organizations to evaluate the effects of EDCs (see e.g., Kortenkamp et al 2011), regulatory communities worldwide have been slow to incorporate the chemicals posing endocrine concerns into existing legislations (Vogel 2004, Hecker and Hollert 2011, Honkela et al 2014. Although some argue that the slow detection of EDCs stems from the novel nature of the chemicals (e.g., Scheffer et al 2003), others argue that because EDCs embody a wide range of temporalities, such as vast time frames as well as nonlinear dose and effect relationships, governing EDCs within the current risk assessment paradigm focusing on quantitative data and methods is highly challenging (Adam 1998, Held 2001).…”