BPA Comments for OEHHA
BPA Comments for OEHHA
Dear Ms. Oshita:
The Environmental Working Group (EWG) strongly supports the Office of Environmental Health Hazard Assessment’s (OEHHA) request for a priority review of Bisphenol A (BPA). Over the last decade, a growing body of science has provided substantial evidence of the developmental and reproductive toxicity of BPA in lab animals at low, environmentally relevant doses and has demonstrated widespread exposures among the public. In addition, many of the diseases and health conditions linked to BPA in animal studies are common among the US population. This gives us great concern that BPA exposures for pregnant women and children may pose significant health risks.
In particular, the following finding on BPA toxicity and human exposures demonstrate why this priority review of this chemical by OEHHA is so important and relevant:
- Developmental and reproductive toxicity of BPA is demonstrated in multiple animal studies
- Studies demonstrate widespread exposure to BPA among the public at levels that have been shown to cause adverse effects in numerous lab studies
- Health effects linked to BPA in lab studies are common among the public
- A recent federal Center for the Evaluation of Risk to Human Reproduction (CERHR) review of BPA contains fundamental errors that support the need for an independent review by OEHHA; and
- Findings of an independent BPA expert panel, including their concerns about potential adverse effects in humans, support the need for priority review by OEHHA
Developmental and Reproductive Toxicity: In the last decade, numerous animal studies have shown that exposure to BPA results in developmental and reproductive toxicity in exposed animals and their offspring. In 1993, OEHHA published a list of criteria that need to be met in order for a chemical to be listed as a reproductive toxin (OEHHA 1993). Earlier this year, OEHHA compiled a list of 63 studies that meet these established criteria for developmental or reproductive toxicity from BPA exposure (OEHHA 2007). These studies reported toxic effects that included:
- persistent changes to breast tissue that predispose cells to carcinogenesis in the offspring of exposed animals
- neurobehavioral changes in offspring of exposed animals
- germ cell damage in offspring of exposed animals
- persistent changes to prostate tissue that predispose cells to carcinogenesis in the offspring of exposed animals; and
- adverse effects on fertility and reproductive system of exposed animals
- BPA was detected in 56% of samples
- Of all foods tested, chicken soup, infant formula, and ravioli had BPA levels of highest concern. Just one to three servings of foods with these concentrations could expose a pregnant woman or child to BPA at levels that caused serious adverse effects in animal tests (2.0 ug/kg/day linked to permanent damage of the reproductive system and aggressive behavior- Nagel et al 1997, Kawai et al 2003)
- For women of childbearing age who routinely eat canned food, chronic exposure levels throughout pregnancy can exceed safe doses. For example, the BPA dose for one-quarter of all women eating 2 servings of canned food daily would fall within a margin of safety of 10 from levels linked to increases in anogenital distance in both genders and early puberty in studies of in utero exposures (2.4 ug/kg/day- Howdeshell et al 1999, Honma et al 2002)
- One of every 16 infants fed ready-to-eat canned formula would be exposed to BPA at doses exceeding those that altered testosterone levels, affected neurodevelopment, and caused other permanent damage to male and female reproductive systems (2.4 ug/kg/day- Howdeshell et al 1999, Honma et al 2002)
- At the highest BPA levels found in formula (17 parts per billion), nearly two-thirds of all infants fed ready-to-eat formula would be exposed above doses that proved harmful in animal tests (2.4 ug/kg/day- Howdeshell et al 1999, Honma et al 2002)
“The wide range of adverse effects of low doses of BPA in laboratory animals exposed both during development and in adulthood is a great cause for concern with regard to the potential for similar adverse effects in humans. Recent trends in human disease relate to adverse effects observed in experimental animals exposed to low doses of BPA.”Given the flaws in the process that lead to the federal CERHR decision on BPA, OEHHA has an opportunity to reevaluate the reproductive and developmental toxicity of this chemical in a fair and unbiased way that takes into account the substantial body of work that has been published over the last decade. We hope that OEHHA can quickly address the pressing public health issues posed by widespread human exposures to this chemical that has demonstrated extremely low dose toxicity in scores of laboratory studies. Environmental Working Group strongly supports OEHHA’s decision to prioritize a review of BPA under Prop 65 as a reproductive toxicant. Sincerely, Anila Jacob, M.D., M.P.H. Senior Scientist Environmental Working Group.
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