IMHO, stay away from BPA. I have been following this for a while. What originally caused concern was a while back a janitor at a research facility cleaned rat cages with a scrub brush. This cages contained BPA. The end result was a huge drop in fertility within a matter of weeks. I couldn't find my link to this. But, I do have this letter below. Anyway, BPA is in so many things it is hard to stay totally away from it. Cans, juice and milk containers, disposible cups, microwave oven dishes and popcorn bags, some childrens dental sealants, water supply pipes to name a few. And because it leaches, it is getting into our water supply! It is pretty scary. And if this is a worry for you, check out this. Plague of Plastic Chokes the Seas http://www.latimes.com/news/printedition/la-me-ocean2aug02,0,5274274,full.story
Ms. Cynthia (her last name was objectionable) LOL
Office of Environmental Health Hazard Assessment
Proposition 65 Implementation
P.O. Box 401
1001 I Street, 19th Floor
Sacramento, CA 95812-4010
Dear Ms. O:
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
Each of these points is detailed further below:
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
OEHHA had also outlined in the 1993 document that “effects should occur
in multiple studies or multiple species for a substance to be recommended for
listing”; the 63 studies that OEHHA reviewed confirms the reproducibility of
findings that illustrate the low dose toxicity of this chemical.
Widespread Exposure: We want to call your attention to a very recent
publication in Environmental Health Perspectives in which the national Centers
for Disease Control and Prevention (CDC) detected BPA in 93% of people age 6 and
older. CDC tested the urine of 2,517 people who are representative of the US
population for BPA and found children ages 6 and older had higher concentrations
than adolescents, who in turn had higher concentrations than adults. Women,
non-Hispanic blacks, and lower income adults were also sub-groups with higher
concentrations (Calafat et al 2007). Because BPA has a short half-life in the
body, this study confirms daily, sustained exposures among the general public.
In addition, BPA has also been found in breast milk, amniotic fluid, and cord
blood, indicating exposure to the developing fetus and neonates (CERHR 2006).
The widespread exposure demonstrated by these studies is consistent with the
many sources of exposure to BPA from a variety of consumer products. BPA ranks
in the top two percent of high production volume chemicals in the US, with
annual production exceeding a billion pounds per year. It is used as plasticizer
in a variety of commonly used consumer products and is so ubiquitous that it
pollutes not only people but also rivers, estuaries, sediment, and house dust.
Earlier this year, EWG spearheaded a study in which an independent laboratory
tested 97 cans of name-brand fruit, vegetables, soda, and other commonly eaten
canned foods for the presence of BPA (EWG 2007a).
Canned foods represent a major source of exposure to BPA for the general
public and Japanese manufacturers voluntarily decreased the use of the chemical
in their products beginning in 1997 for the benefit of their customers
(Matsumoto 2003).
EWG’s tests found the following:
* 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)
EWG also included tests of liquid infant formula in this study and combined
this information with FDA tests of liquid infant formula in 1996 (EWG 2007b).
EWG analysis of these results revealed the following:
* 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)
This EWG study provides the most comprehensive U.S. based examination of BPA in
canned food available and confirms widespread contamination of these foods by
BPA. Because of its ubiquity in foods that are commonly eaten by the public,
this study provides strong evidence that significant numbers of pregnant women,
formula fed infants, and young children may be exposed to BPA on a daily basis
at levels that have been found to be harmful in lab animals.
The current reference dose for BPA of 50 ug/kg/day was derived from traditional
toxicological studies and does not take into account the large body of work from
the last ten years that shows that BPA is biologically active at much lower
doses (vom Saal and Hughes 2005). In fact, there are many studies that show harm
to lab animals at BPA doses that are well below the reference dose (Nagel et al
1997, Kawai et al 2003, Howdeshell et al 1999, Honma et al 2002). The low doses
that have been found to be harmful to animals are similar to levels that are
found in people.
BPA and Human Health Trends: BPA has been linked to a variety of medical
conditions that are prevalent and taking a major toll on our collective health.
Diseases like breast cancer, prostate cancer, polycystic ovarian syndrome, and
insulin resistance have all been associated with BPA exposure in lab studies
(vom Saal and Hughes 2005, Maffini 2006). In many of these studies, exposure
occurs in utero and these conditions develop in exposed offspring long after
birth. Many of the adverse health effects of BPA arise from its ability to mimic
estrogen. What is most worrisome about these studies is that the doses of BPA
that are being used are extremely low and in the range of the levels that have
been found in people.
A few studies have reported on potential effects of exposure to BPA in humans.
OEHHA’s study summary of BPA included a study in which Japanese scientists
found that women with polycystic ovarian syndrome (PCOS) had higher serum levels
of BPA relative to women with normal ovarian function, and that there were
positive correlations between BPA concentrations and androgen levels (Takeuchi
et al 2006). Polycystic ovarian syndrome is one of the most common causes of
female infertility in the U.S. and affects 5 to 10% of American women.
Another study of women with a history of recurrent miscarriages found they had
higher serum BPA levels when compared with women with normal pregnancies,
leading the authors of the study to conclude that "exposure to bisphenol A is
associated with recurrent miscarriage" (Sugiura-Ogasawara et al. 2005).
Recurrent miscarriages affect one percent of American couples trying to conceive
(Rai 2006).
OEHHA’s study summary did not include a study of men with occupational
exposure to plastics that contain BPA that found that they had decreased
secretion of follicle stimulating hormone (FSH) when compared with men without
occupational exposure to epoxy resins (Hanaoka et al 2002). FSH is critical to
sperm formation. Abnormal secretion of this hormone in men can result in reduced
sperm concentration and infertility.
Federal Review Flawed: The recent review of BPA by the federal CERHR found
“some concern” with respect to neural and behavior effects from in utero
exposure but disregarded the substantial number of studies linking fetal
exposure to BPA to breast and prostate cancers and reproductive problems. This
review had been plagued by many issues, including charges leveled by the House
Oversight and Government Reform Committee of the potential conflict of interest
on the part of the subcontractor that conducted the initial literature search
and prepared the first draft. The subcontractor, Sciences International, was
subsequently fired but the document they prepared continued to be used by the
expert panel. It should also be noted that the CERHR panel lacked BPA experts
and their final draft was found to contain significant numbers of errors of
omission and fact upon review by scientists with BPA expertise (Vandenberg et al
2007).
This failure on the part of the federal panel to make a decision that is fully
protective of public health, in addition to the fundamentally flawed process by
which they reached their decision, underscores the need for a fair and unbiased
reassessment of the public health risks posed by this chemical. OEHHA is in a
position to make just such an assessment.
BPA Experts Release Consensus Statement: In August of this year, a group of 38
independent scientists who research BPA toxicity released a consensus statement
in which they concluded that BPA represents a clear risk to human health (vom
Saal et al 2007). This group of scientists published a series of four articles
in the journal Reproductive Toxicology that outlined their conclusions drawn
from their review of over 700 scientific articles related to BPA. In this
consensus statement, these scientists wrote:
“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.
References
Barrett JR. 2006. Fertile grounds of inquiry: environmental effects on human
reproduction. Environmental Health Perspectives 114(11): A644-49.
Calafat AM, Ye X, Wong L-Y, Reidy JA, Needham LL. 2007. Exposure of the US
population to Bisphenol A and 4-tertiary-octylphenol: 2003-2004. Environmental
Health Perspectives Advance Copy, Online 24 October 2007
http://www.ehponline.org/members/2007/10753/10753.pdf [2] .
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Reproduction, NTP-CERHR. Available at
http://cerhr.niehs.nih.gov/chemicals/bisphenol/Bisphenol_A_Draft_Report [3]
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[1] http://www.ewg.org/files/BPACommentsforOEHHA.pdf
[2] http://www.ehponline.org/members/2007/10753/10753.pdf
[3] http://cerhr.niehs.nih.gov/chemicals/bisphenol/Bisphenol_A_Draft_Report
[4] http://www.ewg.org/reports/bisphenola
[5] http://www.oehha.ca.gov/prop65/policy_procedure/pdf_zip/dartCriteriaNov1993
[6] http://www.oehha.ca.gov/prop65/CRNR_notices/state_listing/prioritizatio
[7] http://cerhr.niehs.nih.gov/chemicals/bisphenol/pubcomm-bisphenol.html
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