Critical comments on the WHO-UNEP State of the Science of Endocrine Disrupting Chemicals - 2012

- We critically review the WHO-UNEP 2012 report on endocrine disruptors.
- WHO-UNEP report is not an update of the WHO-IPCS 2002 state-of-the-science review.
- WHO-UNEP report should not guide evidence-based decisions on endocrine disruption.
- A balanced and objective review of all available literature is needed.
- An update must note controversies, data gaps, and provide supported conclusions.

Early in 2013, the World Health Organization (WHO) released a 2012 update to the 2002 State of the Science of Endocrine Disrupting Chemicals. Several significant concerns have been identified that raise questions about conclusions reached in this report regarding endocrine disruption. First, the report is not a state-of-the-science review and does not follow the 2002 WHO recommended weight-of-evidence approach. Second, endocrine disruption is often presumed to occur based on exposure or a potential mechanism despite a lack of evidence to show that chemicals are causally established as endocrine disruptors. Additionally, causation is often inferred by the presentation of a series of unrelated facts, which collectively do not demonstrate causation. Third, trends in disease incidence or prevalence are discussed without regard to known causes or risk factors; endocrine disruption is implicated as the reason for such trends in the absence of evidence. Fourth, dose and potency are ignored for most chemicals discussed. Finally, controversial topics (i.e., low dose effects, non-monotonic dose response) are presented in a one-sided manner and these topics are important to understanding endocrine disruption. Overall, the 2012 report does not provide a balanced perspective, nor does it accurately reflect the state of the science on endocrine disruption.