COMMENT BY: GAIL CHARNLEY, Ph.D., HealthRisk Strategies
SUBJECT: Theory on Hormonally Active Agents is Like Creationism -- A Conclusion Looking for Data
DATE: August 22, 1999

Charles J. Fromm
Executive Director
Center for Regulatory Effectiveness
11 Dupont Circle NW #700
Washington, DC 20036

Dear Mr. Fromm:

Recently the National Academy of Sciences issued a long-anticipated report assessing whether chemicals in the environment that resemble endocrine hormones pose a threat to our health. According to the "endocrine disruption" theory, these chemicals are supposed to interfere with the body's normal hormone biology by mimicking the action of hormones and causing problems with fertility and development -- and even cancer -- in both humans and wildlife. In a way, the endocrine disruption debate resembles the evolution versus creationism controversy that was recently thrust back into the spotlight courtesy of the State of Kansas' Board of Education. In both cases, the debates boil down to a question of science versus faith.

In the case of evolution versus creationism, the argument is that because evolution can't be proven, creation is just as valid an explanation of human origin and both should be taught in the science classroom. Of course, this argument ignores the whole basis for the scientific method. If scientists were presented with data consistent with the conclusion that the earth is only 10,000 years old, they would alter the theory of evolution to explain the data. By contrast, creationists do not alter their "theory" to explain the body of data consistent with evolution and a much older planet. Creationism is a conclusion looking for data.

Similarly, in the case of hormonally active agents (the politically correct term adopted by the National Academy of Sciences committee that wrote the report), instead of using the scientific method, people started with a theory based on anecdotes and then tried to find supporting data that were consistent with that theory. The National Academy of Sciences committee was convened to try to determine what the science could tell us about the theory and what it could not -- in essence, applying the scientific method late in the game to see what conclusions were possible given the data.

What the committee found was that the available science does not support an association between exposure to the normally low levels of hormonally active agents in the environment and cancer, problems with development, or male reproductive disorders such as declines in sperm count. The committee did agree that at unusually high levels of exposure, such as following an accidental spill, humans and wildlife could experience reproductive and developmental effects and possibly immunotoxicity. The committee did not agree that any of those effects could be attributed to interference with the body's normal hormone activities, however.

Meanwhile, instead of waiting for the scientific process to take place and understandably reacting to public fears, Congress acted at the first sign of a theory. And because that theory was sufficiently alarming, many tax dollars and much emotional energy have been spent on a proposed testing program that is far ahead of the science. The Environmental Protection Agency has developed a complex new tiered testing protocol and redirected its entire health research budget to create a focus on endocrine disruption -- an impressive response to a dubious premise.

Carrying out the testing currently required by law to identify hormone mimics would require some $1.4 billion. Extending those testing requirements to all industrial chemicals could cost ten times that. But where are the risks to justify the investment? How will we be able to learn anything meaningful about human risks from the data generated by all that testing?

Our public health and environmental protection priorities are confused. Government shouldn't regulate first and ask questions about the science later. There are too many real risks that require its attention. Instead of using the poorly supported theories of a few people and media scare tactics to decide how to spend our financial and emotional resources, let's start with what we know and what the science tells us. Lots of things are worth worrying about. Let's not waste our time and money on science fiction.