The Scientific Committees of DG SANCO (SCCS on TTC ) and EFSA (EFSA opinion on TTC ) this week adopted their opinions on the controversial risk management tool TTC, the threshold of toxicological concern.
The EFSA-Committee working group for a long time pushed very hard to get TTC adopted, while the SANCO Committee had several doubts. The percentage of industry-linked people being part of both Committee wg.’s (EFSA, 77%, SANCO, 57%) might explain this difference. After many meetings and discussions, the final opinions are more or less similar, a support for the use of TTC, while some differences remain (SANCO questions the genotox database, and stresses the extra uncertainty created by TTC). PAN-Europe is urging EU Commission to reject SANCO and EFSA opinions because TTC will not guarantee the high level of protection required in the EU for humans and the environment, while the cost reduction of industry will be paid by society in terms of higher health costs and lower quality of life.
TTC allows industry to bypass safety testing and make use of a fixed threshold to qualify a chemical as safe, claiming that the probability of harmful effects is low. But,
- this threshold is not protective for 5% of the chemicals toxic at the lowest doses
- the database of toxicological data (for non-genotoxic substances) from which the thresholds are derived is questionable, based mainly on industry-sponsored studies using old, unreliable protocols of little relevance to modern toxicological practice
- the TTCs are based on the assumption that low-dose, endocrine disrupting effects do not exist
- the thresholds make no allowance for the unique susceptibility of the developing foetus, infant or young child to chemical exposures
- the thresholds allow exposure to genotoxic substances, when the overall EU policy objective is to prevent exposure
- there is substantial post-hoc juggling in TTC calculation, where chemicals (such as organophosphates) which would forced a lower threshold are instead removed from the TTC databases and given their own unique threshold
This places TTCs on scientific quicksand. NGO’s have already easily identified chemicals which are harmful below the TTC level [Fenarimol, Deltamethrin, Hexachlorobenzene].
TTC is misleadingly claimed to be a tool for prioritisation and screening but in practice it is already used by EFSA (groundwater metabolites, flavouring substances) and will be used for metabolites, impurities and other chemicals for which industry is reluctant to do safety testing. Use of TTC’s is likely to filter across to other regulation, as TTCs are also being heavily promoted by industry for use in cosmetics and REACH.
Industry advocacy club ILSI (International Life Sciences Institute) has been lobbying European institutions for over 10 years to get a risk assessment tool for chemicals adopted which reduces costs for industry on a large scale. People linked to ILSI and industry even infiltrated EFSA-panels, resulting in an EFSA working group on TTC with 10 out of 13 members linked to ILSI or industry (PAN report on TTC ) while several of them worked for ILSI to develop TTC. The SANCO wg. is also contaminated with industry-linked people (8 out of 14, mostly via cosmetics-industry umbrella COLIPA), a just-published analysis of RISK consultancy  (commissioned by PAN-Europe) reveals.
Remarkably EFSA also recently refused PAN-Europe access to their stakeholder forum which has already an industry-dominance of 10:1 to NGO’s.
For further information please contact:
Hans Muilerman, Pesticide Action Network, tel: 0031 6 55807255