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ACC Welcomes Review of EPA Draft "Low Dose" State of the Science Evaluation for Assessing Chemicals


Contact: Scott Jensen (202) 249-6511  
Email: Scott_Jensen@americanchemistry.com

Draft affirms that evidence is, at best, very weak

WASHINGTON (July 23, 2013)The American Chemistry Council (ACC) today provided written and oral comments to the National Academy of Sciences peer review committee regarding the EPA’s June 2013 “Draft State of the Science Evaluation: Nonmonotonic Dose Response as They Apply to Estrogen, Androgen and Thyroid Pathways and EPA Testing Assessment Procedures.” ACC issued the following statement:

“ACC welcomes EPA’s scientific re-evaluation of this important health and public policy issue. Overall, the Agency has done a commendable job in reviewing a large body of data and focusing its efforts on key elements relevant to the process used to assess chemicals. The conclusions of the Agency’s draft report affirm what scientists have expressed for years: the scientific evidence for non-monotonic low dose exposures leading to endocrine disruption and adverse effects is, at best, very weak. When evaluated in the totality, the report indicates that the weight of the scientific evidence does not support changing the way chemical risks are evaluated.

“There are a number of improvements to the draft report that the Agency should consider, including 1) enhancing data evaluation protocols; 2) adopting consistent methods for integrating study results; 3) integrating a discussion of potency and thresholds; and 4) providing a summary of the  EDSP screening and testing program to help contextualize the report. Though these improvements would further strengthen the report, the weight of the evidence is clear and the conclusions reached by the Agency are well supported by the data reviewed.

“ACC is committed to constructively engaging with the scientific community and regulatory agencies and programs to enhance the public understanding of chemicals and how they may interact with the endocrine system. We believe in the importance of exploring new scientific theories and welcome relevant, credible evidence to ensure regulatory decisions are based on high quality science.”

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