The Endocrine Society has been engaged in reform of the Toxic Substances Control Act and is closely following implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act. On August 22, the Endocrine Society submitted comments to the EPA with recommendations to address deficiencies in the existing regulatory approach.
Our recommendations included the following:
- EPA should develop a consistent approach and criteria that is applied in the same way to all studies in the risk assessment and chemical prioritization processes. This includes peer-reviewed academic literature.
- The term “Weight of Evidence” (WOE) should explicitly refer to a systematic review method that uses a pre-established protocol to comprehensively, objectively, transparently, and consistently, identify and evaluate each stream of evidence, including strengths, limitations, and relevance of each study and to integrate evidence as necessary and appropriate based on strengths, limitations, and relevance.
- WOE approaches should also ensure that the EPA consider academic studies fully along with any other category of evidence.
- The default approach for evaluating risks from chemicals should be that there are risks at low doses and that a dose at which there is no effect must be proven.
Implementing these recommendations will ensure that EPA is able to consider the latest scientific studies when making regulatory decisions to protect the public from harms due to EDC exposures. For more information on the Society’s comments, please see the full letter here. The Endocrine Society will continue to engage with EPA as it continues the development of guidance documents towards the full implementation of the new law.
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