* National Research Center for Women & Families * U.S. Public Interest Research Group *
The following letter was sent to Chairman Pryor, Chair of the Senate Commerce Subcommittee on Consumer Affairs, Insurance and Automotive Safety on bisphenol-A (BPA) and phthalates.
May 13, 2008
Dear Chairman Pryor:
We are writing to thank you for holding a hearing this week to consider the effects of additives to plastics, including bisphenol-A (BPA) and phthalates. Our groups are deeply concerned about the potentially harmful health effects of both of these chemicals in consumer products. BPA is a common chemical found in many hard plastic products, including baby bottles, and phthalates are a family of chemicals used in toys, cosmetics, food packaging, and medical devices. We believe that the potential health and safety hazard associated with BPA and phthalates have escaped the scrutiny of our federal regulators for far too long.
We know that bisphenol-A can leach from plastic containers and cans and into food and beverages, generating potentially significant human exposures. A recent study released by the U.S. Centers for Disease Control and Prevention (CDC) found that BPA was in the blood of 93 percent of Americans aged 6 and older. BPA raises particularly troubling health questions because it can affect the endocrine system, mimicking the effects of estrogen in the body. Experiments in animals and with human cells strongly suggest exposures typical in the U.S. population may increase susceptibility to breast and prostate cancer, reproductive system abnormalities, and, for exposure in the womb and early childhood, a host of developmental problems. Concerns about early life exposures also extend to early onset of puberty in females, potential prostate problems in males, and obesity.
In May 1999, Consumer Reports magazine reported that BPA from polycarbonate plastic baby bottles leached into infant formula after the bottles were heated during testing. Based on these results, Consumer Reports scientists estimated that babies fed formula sterilized by heating in the bottle could be exposed to a BPA dose of about 4 percent of the amount that has adversely affected test animals in experiments conducted by Professor Frederick vom Saal at the University of Missouri, Columbia. The magazine pointed out that, although those levels may sound very low, safety limits for infant exposure can be set as low as 0.1 percent of the level that has adversely affected animals.
In the decade since Consumer Reports originally published this article, many new studies have substantiated the work of Professor vom Saal, as documented in recent reviews by expert committees at the National Toxicology Program and the Health Ministry of Canada. Unlike the Canadian government, which recently announced plans to ban major sources of BPA exposure, U.S. regulatory agencies have yet to act to protect the public.
The current U.S. Environmental Protection Agency daily upper limit for BPA, 50 micrograms per kilogram of body weight, is based on industry-sponsored experiments conducted in the 1980’s. Some animal studies show adverse health affects from exposure of only 0.025 micrograms per kilogram of body weight, yet a polycarbonate baby bottle with room temperature water can leach 2 micrograms of BPA per liter. A 3-month-old baby drinking from a polycarbonate bottle may be exposed to as much as 11 micrograms per kilogram of body weight daily.
Aside from polycarbonate plastic bottles, BPA is also a food additive approved by the Food and Drug Administration (FDA), commonly used in the coatings for the inside of food cans. But a recent report by the National Toxicology Program (NTP) questioned previous FDA findings that BPA is safe for such applications. Their report, issued on April 15, 2008, expressed “some concern” based on animal studies that BPA might affect the neurological systems and behavior of infants and children. Among its conclusions, the NTP report states that, “the possibility that human development may be altered by bisphenol-A at current exposure levels cannot be dismissed.”
Our organizations recently endorsed a bill introduced by Senator Charles Schumer recently, S.2928, the “BPA-Free Kids Act of 2008.” This bill will prohibit the use of BPA in all children’s products, effective 180 days after its enactment. It will also require the CDC to study the health effects of BPA exposure in all age groups and pregnant women. We support this effort and feel it should focus on the products that have the greatest potential for causing human harm. Particularly due to the possible increased risks to small children and pregnant women, we strongly urge the removal of BPA from all products intended to contact food.
With such high consensus within the independent scientific community on the strength of evidence for adverse health effects associated with BPA exposure, we believe it is prudent – at a minimum – to remove BPA from children’s products, until science can prove its safety.
Phthalates may be linked to developmental and reproductive health risks. The industry says that phthalates are safe, but some companies have removed them from cosmetics, for example, in response to public concern. California has also passed legislation banning phthalates in children’s products.
In 2005, the CDC reported that it had found breakdown chemicals from two of the most common cosmetic phthalates in almost every member of a group of 2,782 people it examined. In rodent studies, phthalates have caused testicular injury, liver injury, and liver cancer. Another report in 2003 found that men with higher concentrations of two phthalate breakdown products in their urine were more likely to have low sperm count or low sperm motility.
With such serious concerns about the impact of phthalates on our health, and because of the ubiquity of these chemicals in our products, we believe federal agencies must also examine and act upon independent, unbiased science about all of the potential harms associated with phthalates in order to protect the public health.
Again, we appreciate your Subcommittee’s work in examining BPA and phthalates. We look forward to continuing to work with you and the members of the Subcommittee in the future.
Donald L. Mays
Senior Director, Product Safety and Technical Public Policy
Nancy A. Cowles
Kids in Danger
Director, Congress Watch
Director, Federal Policy
Director of Product Safety and Senior Counsel
Consumer Federation of America
Public Health Advocate
U.S. Public Interest Research Group
Government Relations Manager
National Research Center for Women & Families