April 17, 2008
Ms. Cynthia Oshita
Office of Environmental Health Hazard Assessment
Proposition 65 Implementation
P.O. Box 401
1001 I Street, 19th Floor
Sacramento, CA 95812-4010
- With regards to exposure, NTP notes “Although biomonitoring data are not available for infants and children less than 6 years of age, blood and urine levels of free bisphenol A are predicted to be higher in these age groups” (NTP 2008).
- NTP notes “there is some concern for neural and behavioral effects in fetuses, infants, and children at current human exposures. The NTP also has some concern for bisphenol A exposure in these populations based on effects in the prostate gland, mammary gland, and an earlier age for puberty in females” (NTP 2008).
- NTP concludes, “the possibility that bisphenol A may alter human development cannot be dismissed” (NTP 2008).
- Infant formula manufacturers do not adequately test for BPA in their products to ensure their safety.
- FDA has based its public assurances of the safety of BPA-containing consumer products on just 2 industry studies, one of which is unpublished.
- Several recent studies that highlight the links between BPA exposure and adverse health effects have been published.
- New research shows that commonly used plastic water bottles leach BPA under typical conditions of use.
- New research confirms the relevance of low-dose BPA studies that use nonoral routes of administration.
- Current body of literature: To date, almost 100 animal studies have been published in peer reviewed journals that show significant adverse health effects related to BPA exposures that fall below the current ‘lowest adverse effect level’ (LOAEL) for BPA of 50 mg/kg/day defined by EPA (EPA 1993). These independent studies originated from scientists and labs at academic institutions and government agencies from all over the world. In many of these studies, exposure occurred in-utero and adverse health effects were observed in offspring. As a whole, these studies illustrate that BPA has adverse effects on diverse systems within the body, ranging from the immune system, to the reproductive, neurological, and endocrine systems.
- Adverse health effects related to BPA exposure mirror US health trends: In animal studies, BPA exposure at low doses has been linked to structural changes in mammary and prostate tissues that result in cancer later in life, in addition to a number of other adverse health effects including impaired fertility, insulin resistance, and recurrent miscarriage. These findings are especially worrisome in light of current US health trends since all of these adverse health effects are either on the rise or common among our population. While we may never have definitive epidemiological evidence showing cause and effect, the fact that the vast majority of Americans are chronically exposed to BPA, coupled with current health trends provides a compelling reason to exercise the precautionary principle.
- NIH sponsored panel finds concern: An NIH sponsored panel consisting of 38 BPA experts has expressed strong concerns about the risks to human health posed by current BPA exposures. In their consensus statement, they note the following “The published scientific literature on human and animal exposure to low doses of BPA in relation to in vitro mechanistic studies reveals that human exposure to BPA is within the range that is predicted to be biologically active in over 95% of people sampled. 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 diseases relate to adverse effects observed in experimental animals exposed to low doses of BPA. Specific examples include: the increase in prostate and breast cancer, uro-genital abnormalities in male babies, a decline in semen quality in men, early onset of puberty in girls, metabolic disorders including insulin resistant (type 2) diabetes and obesity, and neurobehavioral problems such as attention deficit hyperactivity disorder (ADHD)” (vom Saal 2007).
Sincerely, Anila Jacob, M.D., M.P.H.
Environmental Working Group