Bisphenol-A (BPA) is a ubiquitous industrial chemical found in everything from baby bottles to cash register receipts. From its inauspicious creation in the laboratory by a group of scientists trying to synthesize an estrogenic compound for the pharmaceutical industry, it has become a fundamental building block of the multi-billion dollar plastics industry. Unfortunately, ever since anomalous results appeared in two research labs using BPA containing plastic equipment in the 1980s, evidence of the chemical’s toxicological risks has continued to mount. The chemical is an endocrine disruptor, meaning that it interferes with the body’s hormone system, and BPA’s health risks include, but are not limited to, increased susceptibility to prostate and breast cancers, reproductive system defects and abnormalities, hormonal imbalances, brain development abnormalities,5 gender confusion, heart disease, and diabetes. Particularly alarming is the evidence that the populations most in danger of suffering from BPA’s health risks are fetuses, infants, and children. New scientific evidence about BPA also indicates that the familiar concept of “the dose makes the poison” – an idea that underlies most of our federal laws for managing toxic risks – may not apply to BPA. Ordinarily, decreasing exposure to a toxic chemical decreases adverse effects. Thus we manage toxic risks by reducing exposures to a point where health effects do not occur or where the risks are sufficiently low that we consider the exposures “safe.” With BPA, however, low doses could cause significant harm, and for certain health effects it appears that low dose exposures to BPA could actually be more harmful than some high dose exposures.
Mounting health and safety concerns over BPA have not only raised consumer anxieties over the prolific chemical’s presence, but also given rise to a deceptive consumer environment, in which seemingly reassuring labels of “BPA-Free” offer little meaningful information, protection, or indication of regulatory progress. For one thing, substitutes for the chemical, such as Bisphenol-S (BPS), may be just as risky. For another, federal agencies have not taken effective steps to control BPA exposures. To assist the federal agencies in moving forward with BPA regulation and to provide the public with a more informative and safer consumer environment, this white paper outlines various short-term and long-term regulatory options for protecting the public from the health risks posed by BPA.
The Food and Drug Administration (FDA), the Environmental Protection Agency (EPA), and the Occupational Safety and Health Administration (OSHA) are the federal agencies best situated to tackle BPA risk assessment and risk management, given the present state of scientific information on the endocrine-disrupting chemical, the agencies’ regulatory authority, and their resources. This white paper urges a two-phase approach to BPA regulation. The first phase should produce immediate information collection and dissemination, including early warnings for the public and stricter guidance for industry. The second phase should include long-term regulatory controls, standards, and protections, to be promulgated as soon as missing information becomes available.
Noah M. Sachs et al, Protecting the Public from BPA: An Action Plan for Federal Agencies (2012) (Center for Progressive Reform White Paper #1202.)