UK newspaper The Guardian recently published an article, Sperm counts among western men have halved in last 40 years in which a recent study was reviewed and the findings were alarming. According to the latest findings of this study “between 1973 and 2011, the concentration of sperm in the ejaculate of men in western countries has fallen by an average of 1.4% a year, leading to an overall drop of just over 52%”. Interestingly, the researchers said they were still unclear about the causes of such a drop.
Whilst appropriately cautious in identifying the causes of this decline in fertility, it is worth consulting the work conducted by the Endocrine Society on the effects of endocrine disruptors. The society has been looking into this issue over the years and commented that “since human reproductive processes are similar to those of other species, many pest-control chemicals designed to harm pest reproductive systems also damage people’s reproductive systems” (See: Impact of EDCs of reproductive systems), explicitly linking lower fertility rates to the effects of chemicals with endocrine disrupting properties; such as those used in pesticides and other products.
HCWH Europe has been active in tackling the health issues linked to endocrine disrupting chemicals (EDCs), specifically focussing on medical devices. For this reason we have been engaged in the debate on the definition of criteria for EDCs. The European Commission was under a legal obligation to come up with scientific criteria for EDCs by December 2013 so as to regulate these harmful chemicals more effectively. The legal obligations came from two sources, two different Regulations: Article 5 (3) of the Biocidal Products Regulation (528/2012), and Article 80 (7) of the Pesticides Regulation (1107/2009).
After half a decade of procrastination, the European Commission (EC) finally met its legal obligations. At their meeting on 12th of July 2017, EU competent authorities for biocides voted to adopt a regulation that would incorporate the EC’s proposed scientific criteria for identifying EDCs into the biocidal products Regulation. They followed the decision taken a week earlier by a separate committee of member state officials considering pesticides regulation, voting to include the EDC criteria in the Regulation on plant protection products.
A recent letter, from the Endocrine Society to the competent EU Member State ministers, is critical of the final criteria.
“The criteria, as currently constructed, will likely fail to identify EDCs that are currently causing human harm, and will not secure a high level of health and environment protection as required per the Treaty on the European Union (EU). Furthermore, the criteria contain arbitrary exemptions for chemicals specifically designed to disrupt target insect endocrine systems that have similarities to systems in wildlife and humans. Consequently, the criteria cannot be called science‐based, nor can they be considered as “fit for purpose” according to the better regulation strategy, as they lack coherence and will not be effective or efficient. We strenuously object to the addition of loopholes in the criteria. This creates divergent frameworks wherein certain chemicals that are designed to be EDs cannot be defined as EDs in the context of applicable laws.”
HCWH Europe is also critical of the criteria as adopted: there will be no obligation to replace EDCs that do not meet the exacting level of proof contained in medical devices on the market. This will undoubtedly lower protection for EU citizens; sadly, those most affected by the adverse effects of EDCs are the vulnerable: medical patients, foetuses, small children, and pregnant women.
Both sets of criteria will be submitted to the European Parliament for scrutiny as part of the regulatory procedure with scrutiny applicable to delegated acts. The EP still has a chance to reject these two sets of criteria in the coming two months.
Preview image: Grace Herbert via Flickr cc