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Woodruff TJ, Rayasam SDG, Axelrad DA, Koman PD, Chartres N, Bennett DH, Birnbaum LS, Brown P, Carignan CC, Cooper C, Cranor CF, Diamond ML, Franjevic S, Gartner EC, Hattis D, Hauser R, Heiger-Bernays W, Joglekar R, Lam J, Levy JI, MacRoy PM, Maffini MV, Marquez EC, Morello-Frosch R, Nachman KE, Nielsen GH, Oksas C, Abrahamsson DP, Patisaul HB, Patton S, Robinson JF, Rodgers KM, Rossi MS, Rudel RA, Sass JB, Sathyanarayana S, Schettler T, Shaffer RM, Shamasunder B, Shepard PM, Shrader-Frechette K, Solomon GM, Subra WA, Vandenberg LN, Varshavsky JR, White RF, Zarker K, Zeise L. A science-based agenda for health-protective chemical assessments and decisions: overview and consensus statement. Environ Health 2023; 21:132. [PMID: 36635734 PMCID: PMC9835243 DOI: 10.1186/s12940-022-00930-3] [Citation(s) in RCA: 10] [Impact Index Per Article: 5.0] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Grants] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Accepted: 10/27/2022] [Indexed: 06/17/2023]
Abstract
The manufacture and production of industrial chemicals continues to increase, with hundreds of thousands of chemicals and chemical mixtures used worldwide, leading to widespread population exposures and resultant health impacts. Low-wealth communities and communities of color often bear disproportionate burdens of exposure and impact; all compounded by regulatory delays to the detriment of public health. Multiple authoritative bodies and scientific consensus groups have called for actions to prevent harmful exposures via improved policy approaches. We worked across multiple disciplines to develop consensus recommendations for health-protective, scientific approaches to reduce harmful chemical exposures, which can be applied to current US policies governing industrial chemicals and environmental pollutants. This consensus identifies five principles and scientific recommendations for improving how agencies like the US Environmental Protection Agency (EPA) approach and conduct hazard and risk assessment and risk management analyses: (1) the financial burden of data generation for any given chemical on (or to be introduced to) the market should be on the chemical producers that benefit from their production and use; (2) lack of data does not equate to lack of hazard, exposure, or risk; (3) populations at greater risk, including those that are more susceptible or more highly exposed, must be better identified and protected to account for their real-world risks; (4) hazard and risk assessments should not assume existence of a "safe" or "no-risk" level of chemical exposure in the diverse general population; and (5) hazard and risk assessments must evaluate and account for financial conflicts of interest in the body of evidence. While many of these recommendations focus specifically on the EPA, they are general principles for environmental health that could be adopted by any agency or entity engaged in exposure, hazard, and risk assessment. We also detail recommendations for four priority areas in companion papers (exposure assessment methods, human variability assessment, methods for quantifying non-cancer health outcomes, and a framework for defining chemical classes). These recommendations constitute key steps for improved evidence-based environmental health decision-making and public health protection.
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Affiliation(s)
- Tracey J Woodruff
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA.
| | - Swati D G Rayasam
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
| | | | - Patricia D Koman
- Department of Environmental Health Sciences, School of Public Health, University of Michigan, Ann Arbor, MI, USA
| | - Nicholas Chartres
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
| | - Deborah H Bennett
- Department of Public Health Sciences, University of California, Davis, Davis, CA, USA
| | - Linda S Birnbaum
- National Institutes of Environmental Health Sciences and National Toxicology Program, Research Triangle Park, NC, USA
- Duke University, Durham, NC, USA
| | - Phil Brown
- Social Science Environmental Health Research Institute, Northeastern University, Boston, MA, USA
| | - Courtney C Carignan
- Department of Food Science and Human Nutrition, Department of Pharmacology and Toxicology, Michigan State University, East Lansing, MI, USA
| | - Courtney Cooper
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
| | - Carl F Cranor
- Department of Philosophy, University of California, Riverside, Riverside, CA, USA
- Environmental Toxicology Graduate Program, College of Natural and Agricultural Sciences, University of California, Riverside, Riverside, CA, USA
| | - Miriam L Diamond
- Department of Earth Sciences, University of Toronto, Toronto, ON, Canada
- School of the Environment, University of Toronto, Toronto, ON, Canada
| | | | | | - Dale Hattis
- The George Perkins Marsh Institute, Clark University, Worcester, MA, USA
| | - Russ Hauser
- Department of Environmental Health, T.H. Chan School of Public Health, Harvard University, Boston, MA, USA
| | - Wendy Heiger-Bernays
- Department of Environmental Health, School of Public Health, Boston University, Boston, MA, USA
| | | | - Juleen Lam
- Department of Public Health, California State University, East Bay, Hayward, CA, USA
| | - Jonathan I Levy
- Department of Environmental Health, School of Public Health, Boston University, Boston, MA, USA
| | | | | | | | - Rachel Morello-Frosch
- School of Public Health, University of California, Berkeley, Berkeley, CA, USA
- Department of Environmental Science, Policy and Management, University of California, Berkeley, Berkeley, CA, USA
| | - Keeve E Nachman
- Department of Environmental Health and Engineering, Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD, USA
- Johns Hopkins Risk Sciences and Public Policy Institute, Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD, USA
| | - Greylin H Nielsen
- Department of Environmental Health, School of Public Health, Boston University, Boston, MA, USA
| | - Catherine Oksas
- School of Medicine, University of California, San Francisco, CA, USA
| | - Dimitri Panagopoulos Abrahamsson
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
| | - Heather B Patisaul
- Department of Biological Sciences, Center for Human Health and the Environment, North Carolina State University, Raleigh, NC, USA
| | | | - Joshua F Robinson
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology and Reproductive Sciences, University of California, San Francisco, 490 Illinois Street, Floor 10, Box 0132, San Francisco, CA, 94143, USA
- Center for Reproductive Sciences, Department of Obstetrics, Gynecology & Reproductive Sciences, University of California, San Francisco, San Francisco, CA, USA
| | | | | | | | | | - Sheela Sathyanarayana
- Department of Pediatrics, University of Washington, Seattle, WA, USA
- Department of Child Health, Behavior, and Development, Seattle Children's Research Institute, Seattle, WA, USA
| | - Ted Schettler
- Science and Environmental Health Network, Ames, IA, USA
| | - Rachel M Shaffer
- Department of Environmental and Occupational Health Sciences, University of Washington School of Public Health, Seattle, USA
| | - Bhavna Shamasunder
- Department of Urban & Environmental Policy and Public Health, Occidental College, Los Angeles, CA, USA
| | | | - Kristin Shrader-Frechette
- Department of Biological Sciences, University of Notre Dame, Notre Dame, IN, USA
- Department of Philosophy, University of Notre Dame, Notre Dame, IN, USA
| | - Gina M Solomon
- School of Medicine, University of California, San Francisco, CA, USA
- Public Health Institute, Oakland, CA, USA
| | - Wilma A Subra
- Louisiana Environmental Action Network, Baton Rouge, LA, USA
| | - Laura N Vandenberg
- Department of Environmental Health Sciences, School of Public Health & Health Sciences, University of Massachusetts, Amherst, Amherst, MA, USA
| | - Julia R Varshavsky
- Department of Health Sciences, Northeastern University, Boston, MA, USA
- Department of Civil and Environmental Engineering, Northeastern University, Boston, MA, USA
| | - Roberta F White
- Department of Environmental Health, School of Public Health, Boston University, Boston, MA, USA
| | - Ken Zarker
- Washington State Department of Ecology, Olympia, WA, USA
| | - Lauren Zeise
- Office of Environmental Health Hazard Assessment, California Environmental Protection Agency, Oakland, CA, USA
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Chartres N, Sass JB, Gee D, Bălan SA, Birnbaum L, Cogliano VJ, Cooper C, Fedinick KP, Harrison RM, Kolossa-Gehring M, Mandrioli D, Mitchell MA, Norris SL, Portier CJ, Straif K, Vermeire T. Conducting evaluations of evidence that are transparent, timely and can lead to health-protective actions. Environ Health 2022; 21:123. [PMID: 36471342 PMCID: PMC9720912 DOI: 10.1186/s12940-022-00926-z] [Citation(s) in RCA: 5] [Impact Index Per Article: 1.7] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Grants] [Track Full Text] [Figures] [Journal Information] [Subscribe] [Scholar Register] [Received: 04/15/2022] [Accepted: 10/20/2022] [Indexed: 06/17/2023]
Abstract
BACKGROUND In February 2021, over one hundred scientists and policy experts participated in a web-based Workshop to discuss the ways that divergent evaluations of evidence and scientific uncertainties are used to delay timely protection of human health and the environment from exposures to hazardous agents. The Workshop arose from a previous workshop organized by the European Environment Agency (EEA) in 2008 and which also drew on case studies from the EEA reports on 'Late Lessons from Early Warnings' (2001, 2013). These reports documented dozens of hazardous agents including many chemicals, for which risk reduction measures were delayed for decades after scientists and others had issued early and later warnings about the harm likely to be caused by those agents. RESULTS Workshop participants used recent case studies including Perfluorooctanoic acid (PFOA), Extremely Low Frequency - Electrical Magnetic Fields (ELF-EMF fields), glyphosate, and Bisphenol A (BPA) to explore myriad reasons for divergent outcomes of evaluations, which has led to delayed and inadequate protection of the public's health. Strategies to overcome these barriers must, therefore, at a minimum include approaches that 1) Make better use of existing data and information, 2) Ensure timeliness, 3) Increase transparency, consistency and minimize bias in evidence evaluations, and 4) Minimize the influence of financial conflicts of interest. CONCLUSION The recommendations should enhance the production of "actionable evidence," that is, reliable evaluations of the scientific evidence to support timely actions to protect health and environments from exposures to hazardous agents. The recommendations are applicable to policy and regulatory settings at the local, state, federal and international levels.
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Affiliation(s)
- Nicholas Chartres
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology, and Reproductive Sciences, University of California at San Francisco, 490 Illinois Street, Floor 10, San Francisco, CA, 94143, USA.
| | - Jennifer B Sass
- Natural Resources Defense Council, Washington, DC, USA
- George Washington University, Washington, DC, USA
| | | | - Simona A Bălan
- California Department of Toxic Substances Control, Berkeley, CA, USA
- University of California at Berkeley, Berkeley, CA, USA
| | - Linda Birnbaum
- Nicholas School of the Environment, Duke University, Durham, NC, USA
| | | | - Courtney Cooper
- Program On Reproductive Health and the Environment, Department of Obstetrics, Gynecology, and Reproductive Sciences, University of California at San Francisco, 490 Illinois Street, Floor 10, San Francisco, CA, 94143, USA
| | | | - Roy M Harrison
- School of Geography, Earth & Environmental Sciences, University of Birmingham, Birmingham, UK
- Department of Environmental Sciences/Centre of Excellence in Environmental Studies, King Abdulaziz University, Jeddah, Saudi Arabia
| | - Marike Kolossa-Gehring
- Department of Environmental Hygiene, Section Toxicology, Health Related Environmental Monitoring, German Federal Environmental Agency, Dessau-Roßlau, Germany
| | - Daniele Mandrioli
- Cesare Maltoni Cancer Research Center, Ramazzini Institute, Bologna, Italy
| | - Mark A Mitchell
- George Mason University, Fairfax, VA, USA
- Connecticut Coalition for Environmental Justice, Hartford, CT, USA
| | - Susan L Norris
- Department of Family Medicine, Oregon Health & Science University, Portland, OR, USA
| | - Christopher J Portier
- Rollins School of Public Health, Emory University, Atlanta, GA, USA
- Department of Toxicogenomics, Maastricht University, Maastricht, Netherlands
- CJP Consulting, Seattle, WA, USA
| | - Kurt Straif
- ISGlobal, Barcelona, Spain
- Boston College, Newton, MA, USA
| | - Theo Vermeire
- Retired, National Institute for Public Health and the Environment (RIVM), Utrecht, The Netherlands
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Soskolne CL, Kramer S, Ramos-Bonilla JP, Mandrioli D, Sass J, Gochfeld M, Cranor CF, Advani S, Bero LA. Toolkit for detecting misused epidemiological methods. Environ Health 2021; 20:90. [PMID: 34412643 PMCID: PMC8375462 DOI: 10.1186/s12940-021-00771-6] [Citation(s) in RCA: 1] [Impact Index Per Article: 0.3] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Received: 03/22/2021] [Accepted: 07/09/2021] [Indexed: 05/08/2023]
Abstract
BACKGROUND Critical knowledge of what we know about health and disease, risk factors, causation, prevention, and treatment, derives from epidemiology. Unfortunately, its methods and language can be misused and improperly applied. A repertoire of methods, techniques, arguments, and tactics are used by some people to manipulate science, usually in the service of powerful interests, and particularly those with a financial stake related to toxic agents. Such interests work to foment uncertainty, cast doubt, and mislead decision makers by seeding confusion about cause-and-effect relating to population health. We have compiled a toolkit of the methods used by those whose interests are not aligned with the public health sciences. Professional epidemiologists, as well as those who rely on their work, will thereby be more readily equipped to detect bias and flaws resulting from financial conflict-of-interest, improper study design, data collection, analysis, or interpretation, bringing greater clarity-not only to the advancement of knowledge, but, more immediately, to policy debates. METHODS The summary of techniques used to manipulate epidemiological findings, compiled as part of the 2020 Position Statement of the International Network for Epidemiology in Policy (INEP) entitled Conflict-of-Interest and Disclosure in Epidemiology, has been expanded and further elucidated in this commentary. RESULTS Some level of uncertainty is inherent in science. However, corrupted and incomplete literature contributes to confuse, foment further uncertainty, and cast doubt about the evidence under consideration. Confusion delays scientific advancement and leads to the inability of policymakers to make changes that, if enacted, would-supported by the body of valid evidence-protect, maintain, and improve public health. An accessible toolkit is provided that brings attention to the misuse of the methods of epidemiology. Its usefulness is as a compendium of what those trained in epidemiology, as well as those reviewing epidemiological studies, should identify methodologically when assessing the transparency and validity of any epidemiological inquiry, evaluation, or argument. The problems resulting from financial conflicting interests and the misuse of scientific methods, in conjunction with the strategies that can be used to safeguard public health against them, apply not only to epidemiologists, but also to other public health professionals. CONCLUSIONS This novel toolkit is for use in protecting the public. It is provided to assist public health professionals as gatekeepers of their respective specialty and subspecialty disciplines whose mission includes protecting, maintaining, and improving the public's health. It is intended to serve our roles as educators, reviewers, and researchers.
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Affiliation(s)
- Colin L Soskolne
- School of Public Health, University of Alberta, Edmonton, AB, Canada.
| | - Shira Kramer
- Epidemiology International, Hunt Valley, MD, USA
| | | | - Daniele Mandrioli
- Cesare Maltoni Cancer Research Centre, Ramazzini Institute, Bologna, Italy
| | - Jennifer Sass
- Natural Resources Defense Council, Washington, DC, USA
- George Washington University, Washington, DC, USA
| | - Michael Gochfeld
- Environmental and Occupational Health Sciences Institute, Rutgers Biomedical and Health Sciences, Newark, NJ, USA
| | - Carl F Cranor
- Departments of Philosophy and Environmental Toxicology, University of California, Riverside, CA, USA
| | - Shailesh Advani
- Terasaki Institute of Biomedical Innovation, Los Angeles, CA, USA
- Georgetown University School of Medicine, Washington, DC, USA
| | - Lisa A Bero
- Center for Bioethics and Humanities, University of Colorado Anschutz Medical Campus, Aurora, CO, USA
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