A critique of the European Commission Document, “State of the Art Assessment of Endocrine Disrupters”

In this commentary, we critique a recently finalized document titled "State of the Art Assessment of Endocrine Disrupters" (SOA Assessment). The SOA Assessment was commissioned by the European Union Directorate-General for the Environment to provide a basis for developing scientific criteria for identifying endocrine disruptors and reviewing and possibly revising the European Community Strategy on Endocrine Disrupters. In our view, the SOA Assessment takes an anecdotal approach rather than attempting a comprehensive assessment of the state of the art or synthesis of current knowledge. To do the latter, the document would have had to (i) distinguish between apparent associations of outcomes with exposure and the inference of an endocrine-disruption (ED) basis for those outcomes; (ii) constitute a complete and unbiased survey of new literature since 2002 (when the WHO/IPCS document, "Global Assessment of the State-of-the-Science of Endocrine Disruptors" was published); (iii) consider strengths and weaknesses and issues in interpretation of the cited literature; (iv) follow a weight-of-evidence methodology to evaluate evidence of ED; (v) document the evidence for its conclusions or the reasoning behind them; and (vi) present the evidence for or reasoning behind why conclusions that differ from those drawn in the 2002 WHO/IPCS document need to be changed. In its present form, the SOA Assessment fails to provide a balanced and critical assessment or synthesis of literature relevant to ED. We urge further evidence-based evaluations to develop the needed scientific basis to support future policy decisions.