Re: DEHP again

["Alex J. Sagady & Associates" <asagady@sojourn.com>]

At 07:34 PM 7/15/96 -0400, you (charlie.cray@green2.greenpeace.org)  wrote:

>to:  Dioxin heads
>fr:  Charlie Cray
> 
>A follow-up to my earlier memo and the misinformation given by
>PVC industry representatives in response:
> 
>1)  While it may be true that only two of the phthalate esters
>are currently considered ESTROGENIC, DEHP (the principle
>phthalate in commerce) is considered a known endocrine disruptor
>(estrogenicity is not the only way endocrine disrupting chemicals
>act).  DEHP is listed as an endocrine-disrupting chemical in the
>Wingspread experts statement on chemically-induced alterations in
>sexual development.  
> 
>2)  As far back as the early 1980's researchers at the Research
>Triangle Institute, one of two testing laboratories contracted by
>the National Toxicity Program, found that DEHP, used in the
>production of soft plastics (esp. PVC), causes the testes to
>atrophy and androgen (male sex hormone) levels to decrease.  
>

Your statement neglects to mention whether the RTI data is
for mice or for people....I presume its for lab animals.  Assuming
such, what was the dose that caused this result???    In short term 
animal toxicology testing for carcinogens, isn't there a 
considerable amount of testing at extremely high doses
 over short terms in order to establish the maximum tolerated
 dose??  If the testicular atrophy is at the high doses, why would
this be relevant to current environmental exposures,
 except, perhaps, for  occupational exposures?


>Dr. Ralph Dougherty, a professor of biochemistry at Florida State
>University, who specializes in research about infertility, found
>that "phthalates concentrate in human semen and can lower sperm
>production."

Dr. Dougherty's statement would appear to be at odds with the
statement of the DHHS/ATSDR that you quote below which says
there is no data for humans on human health effects.  If this statement
is correct, and what he is saying is true, what kind of epidemiological
study justified this conclusion and where did he publish this research??

  Dr. Jerry Reel, director for life sciences and
>toxicology at Research Triangle Institute (Research Triangle
>Park,NC) "has shown that phthalates can cause infertility in
>adult laboratory animals and birth defects in offspring."   
>("Probing chemical causes of infertility," Chemical Week, Feb 15,
>1984)

Was this at a dose that was environmentally significant, or
were these doses several orders of magnitude greater than
anything that anyone would ever be exposed to except for
spills and occupational exposures?    By way of comparison, 
for example, DBCP (dibromo-chloropropane) was found to
cause infertility in male employees in a production plant
in California....  is DEHP a more or less potent terratogen
and/or reproductive toxicant than DBCP??? 


> 
>Again, while this has been known for some time, the government
>has done little to protect us.   The PVC industy is growing at a
>pace of about 5-6% annually in the US, becoming the key product
>line of the chlorine (dioxin) industry, despite the fact that it
>is the key source of these ubiquitous pollutants.

If this is so, then what is the most important source of human exposure
to DEHP and what are the sinks in the environment and its
biodegradability????  The original poster on dioxin-l was asking
about DEHP in compost...if memory serves me correct, I think
the inquiry was about DEHP in vinyl compost boxes/enclosures....
...  I can't help but think that this would pose an insignificant potential 
for human exposure and environmental damage, compared to, 
for example, the use of flexible DEHP containing PVC tubing in
a heart/lung machine or for storage of cooking oil, for example....


> 
>3) The U.S. Department of Health and Human Services has
>determined "that DEHP may reasonably be anticipated to be a
>carcinogen.  DEHP causes cancer in rats and mice.  It is also
>known to produce liver damage and male reproductive system
>damage,affect reproduction, and produce birth defects in
>laboratory animals.  Because none of these effects have been
>documented in humans, it is difficult to estimate the kinds of
>health effects and exposure levels that may actually affect
>humans.   However, it is prudent to regard the animal data as
>indicating some degree of concern for harmful hman effects until
>more research can be done." (US Agency for Toxic Substances and
>Disease Registry, Public Health Statement)
> 
>4)  According to the Danish EPA, "Phthalates are the most
>abundant man-made environmental pollutants, and human intake per
>day via various routes, especially via the diet, is measured in
>tens of milligrams," Male Reproductive Health and Envionmental
>Chemicals with Estrogenic Effects, Danish EPA, April 1995)

  There
>is likely not a single person on the planet who is not carrying
>phthalates in their body.

Where was this latter statement published, except by 
Greenpeace???


  Given the additive and synergistic
>nature of endocrine-disrupting chemicals and the fact that all of
>us are now exposed to it (especially those at the most sensitive
>stages of development), it would seem that we'd want to eliminate
>the known source of a known endocrine-disrupting chemical like
>DEHP.

Are you saying that DEHP production and use should be 
banned???    If so, who else besides Greenpeace is taking
this position, and does such a position constitute the mainstream
of thought among toxicologists and environmental scientists???
How can you justify a ban where a group like ATSDR says 
there is no human evidence currently of a problem???

And if there is human evidence of a problem from human
exposures, would you please tell us how many cases of 
DEHP-induced human endocrine disease is presently
being caused by this exposure per year?

> 
>5) To talk about se found
>to be toxic (like organotins for lead, lead for cadmium, adipates
>for phthalates) is to send people on a toxic merry-go-round. 
>It's like discovering that they put a carcinogenic additive in
>cigarettes, and suggesting that cigarettes can be made safe by
>substituting another, "safer" additive.  Of course this is just
>an analogy, but pretty appropriate for an industry which seems to
>be learning its PR from the Tobacco companies.
>----------

At the risk of being labelled "politically incorrect,"
I guess my plea is for some more perspective, and
more quantification of problems....  Nothing in
your post convinces me that DEHP constitutes anything close
to the health and environmental hazards posed, for
example,  by heavy 
metals, dioxins and PCBs in the environment.....  or, for that
matter, ordinary dust (PM10) and ozone exposures in
community air pollution or human sewage in combined sewer
overflows, or pesticide exposures to farm workers.....
In fact, I'd suggest that these hazards pose human health
and environmental risks that are orders of magnitude 
greater in demonstrated human health impact than to
current environmental exposures to DEHP.

In closing, I'd note that I have nothing to do with the PVC
or chlorine industry....  I am just a long time Michigan
environmental activist that cares about the public
and scientific credibility of our modern day 
citizen environmental movement, and the need
for a more accountable, hard-nosed approach to
what our movement does, why it does it and what
we do with our members' and contributors' hard
earned public dollars....... 
  .....and that responsible, environmentally concerned 
citizens need to worry about the biggest and worst
 demonstrable public health, community, natural resource
 and environmental problems  first......