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Gori GB, Aschner M, Borgert CJ, Cohen SM, Dietrich DR, Galli CL, Greim H, Heslop-Harrison JS, Kacew S, Kaminski NE, Klaunig JE, Marquardt HWJ, Pelkonen O, Roberts R, Savolainen KM, Tsatsakis A, Yamazaki H. US regulations to curb alleged cancer causes are ineffectual and compromised by scientific, constitutional and ethical violations. Arch Toxicol 2023; 97:1813-1822. [PMID: 37029818 PMCID: PMC10182921 DOI: 10.1007/s00204-022-03429-5] [Citation(s) in RCA: 0] [Impact Index Per Article: 0] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Journal Information] [Subscribe] [Scholar Register] [Received: 11/11/2022] [Accepted: 11/17/2022] [Indexed: 04/09/2023]
Abstract
The 1958 Delaney amendment to the Federal Food Drug and Cosmetics Act prohibited food additives causing cancer in animals by appropriate tests. Regulators responded by adopting chronic lifetime cancer tests in rodents, soon challenged as inappropriate, for they led to very inconsistent results depending on the subjective choice of animals, test design and conduct, and interpretive assumptions. Presently, decades of discussions and trials have come to conclude it is impossible to translate chronic animal data into verifiable prospects of cancer hazards and risks in humans. Such conclusion poses an existential crisis for official agencies in the US and abroad, which for some 65 years have used animal tests to justify massive regulations of alleged human cancer hazards, with aggregated costs of $trillions and without provable evidence of public health advantages. This article addresses suitable remedies for the US and potentially worldwide, by critically exploring the practices of regulatory agencies vis-á-vis essential criteria for validating scientific evidence. According to this analysis, regulations of alleged cancer hazards and risks have been and continue to be structured around arbitrary default assumptions at odds with basic scientific and legal tests of reliable evidence. Such practices raise a manifold ethical predicament for being incompatible with basic premises of the US Constitution, and with the ensuing public expectations of testable truth and transparency from government agencies. Potential remedies in the US include amendments to the US Administrative Procedures Act, preferably requiring agencies to justify regulations compliant with the Daubert opinion of the Daubert ruling of the US Supreme Court, which codifies the criteria defining reliable scientific evidence. International reverberations are bound to follow what remedial actions may be taken in the US, the origin of current world regulatory procedures to control alleged cancer causing agents.
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Affiliation(s)
- Gio B Gori
- Emeritus Director, The Health Policy Center, Bethesda, Maryland, USA.
- Formerly Deputy Director, Division of Cancer Cause and Prevention, National Cancer Institute, Bethesda, Maryland, USA.
| | - Michael Aschner
- Professor of Molecular Pharmacology, Albert Einstein College of Medicine, Bronx, NY, 10461, USA
| | - Christopher J Borgert
- Applied Pharmacology and Toxicology, Inc., Department of Physiological Sciences, University of Florida College of Veterinary Medicine, Gainesville, FL, USA
| | - Samuel M Cohen
- Havlik Wall Professor of Oncology, Department of Pathology and Microbiology and Buffett Cancer Center, University of Nebraska Medical Center, Omaha, NE, 68198-3135, USA
| | - Daniel R Dietrich
- Professor of Human and Environmental Toxicology, Dean of Studies, Faculty of Biology, Konstanz University, Konstanz, Germany
| | - Corrado L Galli
- Professor of Toxicology and Risk Assessment, Department of Pharmacological and Biomolecular Sciences, University of Milan, 20133, Milan, Italy
| | - Helmut Greim
- Professor emeritus of Toxicology and Environmental Health Technical, University of Munich, Munich, Germany
| | | | - Sam Kacew
- McLauglin Centre for Population Health Risk Assessment, University of Ottawa, Ottawa, Ontario, K1N6N5, Canada
| | - Norbert E Kaminski
- Pharmacology & Toxicology, Director, Institute for Integrative Toxicology, Michigan State University, East Lansing, Michigan, USA
| | - James E Klaunig
- Professor of Environmental Health, Indiana University, Bloomington, Indiana, 47408, USA
| | - Hans W J Marquardt
- Department of Experimental & Clinical Toxicology, University Hamburg Medical School (Retired), Hamburg, Germany
| | - Olavi Pelkonen
- Professor of Pharmacology (Retired), Research Unit of Biomedical Sciences/Pharmacology and Toxicology, University of Oulu, Oulu, Finland
| | - Ruth Roberts
- Apconix Ltd. Chair and Director of Drug Discovery, University of Birmingham, Birmingham, UK
| | | | - Aristidis Tsatsakis
- Chairman of Toxicology and Forensics Departments, University of Crete Medical School, Heraklion, Crete, Greece
| | - Hiroshi Yamazaki
- Drug Metabolism and Pharmacokinetics, Showa Pharmaceutical University, Machida, Tokyo, 194-8543, Japan
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Aschner M, Autrup HN, Berry SCL, Boobis AR, Cohen SM, Creppy EE, Dekant W, Doull J, Galli CL, Goodman JI, Gori GB, Greim HA, Joudrier P, Kaminski NE, Klaassen CD, Klaunig JE, Lotti M, Marquardt HWJ, Pelkonen O, Sipes IG, Wallace KB, Yamazaki H. Upholding science in health, safety and environmental risk assessments and regulations. Toxicology 2016; 371:12-16. [PMID: 27639665 DOI: 10.1016/j.tox.2016.09.005] [Citation(s) in RCA: 6] [Impact Index Per Article: 0.8] [Reference Citation Analysis] [What about the content of this article? (0)] [Affiliation(s)] [Abstract] [Key Words] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Indexed: 10/21/2022]
Abstract
A public appeal has been advanced by a large group of scientists, concerned that science has been misused in attempting to quantify and regulate unmeasurable hazards and risks.1 The appeal recalls that science is unable to evaluate hazards that cannot be measured, and that science in such cases should not be invoked to justify risk assessments in health, safety and environmental regulations. The appeal also notes that most national and international statutes delineating the discretion of regulators are ambiguous about what rules of evidence ought to apply. Those statutes should be revised to ensure that the evidence for regulatory action is grounded on the standards of the scientific method, whenever feasible. When independent scientific evidence is not possible, policies and regulations should be informed by publicly debated trade-offs between socially desirable uses and social perceptions of affordable precaution. This article explores the premises, implications and actions supporting the appeal and its objectives.
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Affiliation(s)
- Michael Aschner
- Professor, Molecular Pharmacology, Albert Einstein College of Medicine, 1300 Morris Park Avenue, Bronx, NY 10461, United States.
| | - Herman N Autrup
- Emeritus Professor, Institute of Public Health, University of Aarhus, Aarhus, Denmark.
| | | | - Alan R Boobis
- Professor of Biochemical Pharmacology,Department of Medicine, Imperial College, London, UK.
| | - Samuel M Cohen
- Professor, Department of Pathology and Microbiology, University of Nebraska Medical Center, Omaha, NE, USA.
| | - Edmond E Creppy
- Head of Toxicology Department, Faculty of Pharmaceutical Sciences, Université Bordeaux Segalen, Bordeaux, France.
| | - Wolfgang Dekant
- Professor of Toxicology, Department of Toxicology, University of Wuerzburg, Wuerzburg, Germany.
| | - John Doull
- Emeritus Professor, Pharmacology, Toxicology and Therapeutics, University of Kansas Medical Center, Kansas City, KS, USA.
| | - Corrado L Galli
- Professor, Toxicology and Risk Assessment, Pharmacological and Biomolecular Sciences, University of Milan, Milan, Italy.
| | - Jay I Goodman
- Professor of Pharmacology and Toxicology, Michigan State University, East Lansing, USA.
| | - Gio B Gori
- Emeritus, The Health Policy Center, Editor, Regulatory Toxicology and Pharmacology, Bethesda, MD, USA.
| | - Helmut A Greim
- Emeritus Professor, Technical University of Munich, Munich, Germany.
| | | | - Norbert E Kaminski
- Professor, Pharmacology & Toxicology, Director, Institute for Integrative Toxicology, Michigan State University, East Lansing, MI, USA.
| | - Curtis D Klaassen
- Affiliate Professor, Dept. of Environmental and Occupational Health, University of Washington, Seattle, WA, USA.
| | - James E Klaunig
- Professor, Department of Environmental Health, University of Indiana, Ellettsville, IN, USA.
| | - Marcello Lotti
- Professor, Department of Cardiology, Thoracic and Vascular Sciences, School of Medicine, University of Padua, Padua, Italy.
| | - Hans W J Marquardt
- Professor Emeritus, Experimental and Clinical Toxicology, University of Hamburg Medical School, Hambug, Germany.
| | - Olavi Pelkonen
- Professor and Chair Emeritus, Department of Pharmacology and Toxicology, Faculty of Medicine, University of Oulu, Oulu, Finland.
| | - I Glenn Sipes
- Professor Emeritus, University of Arizona, Tucson, AZ, USA.
| | - Kendall B Wallace
- Professor & Associate Dean for Faculty Affairs, University of Minnesota Medical School Duluth, Duluth, MN, USA.
| | - Hiroshi Yamazaki
- Dean of Graduate School & Professor, Drug Metabolism and Pharmacokinetics, Showa Pharmaceutical University, Machida, Tokyo, Japan.
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Dietrich D, von Aulock S, Marquardt HWJ, Blaauboer BJ, Dekant W, Kehrer J, Hengstler JG, Collier AC, Gori GB, Pelkonen O, Lang F, Nijkamp FP, Stemmer K, Li A, Savolainen K, Hayes AW, Gooderham N, Harvey A. Open letter to the European Commission: scientifically unfounded precaution drives European Commission's recommendations on EDC regulation, while defying common sense, well-established science, and risk assessment principles. Arch Toxicol 2013; 87:1739-41. [PMID: 23979651 DOI: 10.1007/s00204-013-1117-2] [Citation(s) in RCA: 23] [Impact Index Per Article: 2.1] [Reference Citation Analysis] [What about the content of this article? (0)] [MESH Headings] [Track Full Text] [Journal Information] [Subscribe] [Scholar Register] [Received: 08/06/2013] [Accepted: 08/06/2013] [Indexed: 11/25/2022]
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