Analysis of different preferences for the EU's regulatory options for endocrine disruptor identification criteria using argumentation theory

Sander C S Clahsen; Lana Moss; Irene van Kamp; Theo G Vermeire; Bart J Garssen; Aldert H Piersma; Erik Lebret

doi:10.1016/j.scitotenv.2020.140076

Analysis of different preferences for the EU's regulatory options for endocrine disruptor identification criteria using argumentation theory

Sci Total Environ. 2020 Oct 20:740:140076. doi: 10.1016/j.scitotenv.2020.140076. Epub 2020 Jun 15.

Authors

Sander C S Clahsen¹, Lana Moss², Irene van Kamp³, Theo G Vermeire⁴, Bart J Garssen⁵, Aldert H Piersma⁶, Erik Lebret⁷

Affiliations

¹ Centre for Sustainability, Environment and Health, National Institute for Public Health and the Environment - RIVM, P.O. Box 1, 3720 BA Bilthoven, the Netherlands; Institute for Risk Assessment Sciences - IRAS, Utrecht University, Yalelaan 2, 3584 CM, Utrecht, the Netherlands. Electronic address: sander.clahsen@rivm.nl.
² Centre for Sustainability, Environment and Health, National Institute for Public Health and the Environment - RIVM, P.O. Box 1, 3720 BA Bilthoven, the Netherlands; Department of Speech Communication, Argumentation Theory and Rhetoric, University of Amsterdam, 12 Spuistraat 134, 1012 VB Amsterdam, the Netherlands.
³ Centre for Sustainability, Environment and Health, National Institute for Public Health and the Environment - RIVM, P.O. Box 1, 3720 BA Bilthoven, the Netherlands.
⁴ Centre for Safety of Substances and Products, National Institute for Public Health and the Environment - RIVM, P.O. Box 1, 3720 BA, Bilthoven, the Netherlands.
⁵ Department of Speech Communication, Argumentation Theory and Rhetoric, University of Amsterdam, 12 Spuistraat 134, 1012 VB Amsterdam, the Netherlands.
⁶ Institute for Risk Assessment Sciences - IRAS, Utrecht University, Yalelaan 2, 3584 CM, Utrecht, the Netherlands; Centre for Health Protection, National Institute for Public Health and the Environment - RIVM, P.O. Box 1, 3720 BA Bilthoven, the Netherlands.
⁷ Centre for Sustainability, Environment and Health, National Institute for Public Health and the Environment - RIVM, P.O. Box 1, 3720 BA Bilthoven, the Netherlands; Institute for Risk Assessment Sciences - IRAS, Utrecht University, Yalelaan 2, 3584 CM, Utrecht, the Netherlands.

PMID: 32563877
DOI: 10.1016/j.scitotenv.2020.140076

Abstract

What criteria are most suitable to identify endocrine disrupting substances (EDSs) for regulatory purposes in the EU? The results of the European Commission's public consultation, as part of the process to establish identification criteria for EDSs, show that different regulatory options are supported. Some respondents prefer an option including hazard characterization considerations, whereas others prefer an option that avoids these considerations and introduces several hazard-identification based weight-of-evidence categories. In this study, the argumentation underlying the different preferences for identification criteria are analyzed and compared using pragma-dialectical argumentation theory (PDAT). All responses of non-anonymous, national governments that submitted a response in English (n = 17) were included. Responses of other stakeholder organizations were included if a Google News search returned an opinionated presence in the media on the subject (n = 9). Five topical themes and 21 underlying issues were identified. The themes are 1) mechanistic understanding of EDSs, 2) regulatory considerations related to the identification of EDSs, 3) consistency with existing regulatory frameworks, and 4) evaluations of specific issues related to a category approach and 5) related to including potency. We argue that two overarching (implicit) 'advocacy coalitions' can be discerned, that adopted contrasting positions towards the identified themes and issues. Among these 'coalitions', there appears to be consensus about the necessity of having 'science-based' criteria, though different perspectives exist as to what the most accurate mechanistic understanding of EDSs entails. To move the discussion forward, we argue that a societal dialogue would be beneficial, where EDS science and regulation are discussed as interrelated themes.

Keywords: Advocacy coalitions; Argumentation theory; EU regulatory options; Endocrine disruptors; Public consultation.

MeSH terms

Endocrine Disruptors*
European Union
Risk Assessment

Substances

Endocrine Disruptors