In mid December 2014 when the European Food Safety Authority (EFSA) flagged that they had finalised the bisphenol A (BPA) opinion and only some editorial work remained, I predicted in a blog that the EFSA Panel would once again clear the use of BPA in food contact materials. On 21 January 2015 EFSA published the new opinion, and surprise, surprise, BPA is considered harmless at current exposure levels. This is the summary wording of EFSA:
EFSA’s comprehensive re-evaluation of bisphenol A (BPA) exposure and toxicity concludes that BPA poses no health risk to consumers of any age group (including unborn children, infants and adolescents) at current exposure levels. Exposure from the diet or from a combination of sources (diet, dust, cosmetics and thermal paper) is considerably under the safe level (the “tolerable daily intake” or TDI).
This conclusion comes despite the fact that EFSA further firmed up the TDI to 4 µg/kg of body weight per day, more than 12 times lower than the previously recommended TDI of 50 µg/kg of body weight per day. The highest estimates for exposure from a combination of dietary, inhalation and dermal routes (called “aggregated exposure” in EFSA’s opinion) are three to five times lower than the new TDI when using a deterministic method (see comparison with probabilistic method further down). All clear then?
Not so fast, there are still uncertainties as EFSA points out. Effects on the reproductive, nervous, immune, metabolic and cardiovascular systems, as well as in the development of cancer are not considered likely at present, but they could not be excluded on the available evidence the Panel concluded. The new TDI is thus temporary pending the outcome of a long-term study in rats by the US National Toxicology Program, which will help to reduce these uncertainties.
So what to believe?
EFSA and the French Agency for Food, Environmental and Occupational Health & Safety (ANSES) have divergent views on the safety of BPA in food contact and other materials. If there are different views on the safety of a compound between a national food safety organisation and EFSA, it is compulsory to discuss and if possible reconcile their respective assessments. Such a discussion took place in December 2014. From the minutes of the meeting it is possible to deduce that the differences relate to:
- results from two key toxicological studies selected by ANSES on the effects of BPA on brain and behaviour, and on the mammary gland;
- on an extra safety factor of 3 added by ANSES to the normal safety factor of 100, while EFSA applied an extra safety factor of 1.5 to address uncertainties; and
- on the use of a probabilistic method to determine exposure used by ANSES as opposed to the deterministic method used by EFSA.
Looking first at the selected toxicological studies it seems as if ANSES trusted the negative results from the two studies more than EFSA. EFSA on the other hand balanced the negative findings against similar studies showing no negative effects in the two areas in question. To be fair EFSA also included a study that was published after the ANSES opinion that showed no negative effects on the mammary gland, but still the opinions of the two organisations differed in relation to the validity of several of the studies.
Adding an extra safety factor of 3 makes sense in light of the remaining uncertainties and could have been adopted also by EFSA. EFSA instead selected to use a weight of evidence approach to cater for the remaining uncertainties, but such an approach relies solely on subjective expert judgement. You might be interested to know that EFSA involved an unprecedented 26 experts in the working group that developed the initial draft BPA opinion to arrive at the best possible balanced view, but still the extra safety factor used by ANSES might provide greater certainty.
Finally, the differences in exposure methodology used between the two organisations might also cause some differences in the final result. ANSES has long used probabilistic methods to calculate exposure, while EFSA has stubbornly stuck to the simpler deterministic methods. To EFSA’s advantage is access to extensive Europe wide data for the input parameters for the calculations, BPA occurrence and food consumption. However, the use of probabilistic techniques will better cater for unusual occurrence and consumption patterns and thus cover a larger range of the population.
Considering the two latter points, combined they would probably take the highest estimates of exposure closer to the temporary TDI since the EFSA margin was three to five times lower than the new TDI. Adding the toxicological results that ANSES used we could have a problem. On the other hand, the might of EFSA’s scientific expertise very clearly concluded that there is no problem of any kind that they could identify using the present scientific knowledge.
More research results on BPA
However, already new toxicological results are piling up. In a first multispecies study combining human association and animal causal studies assessing the risk posed by prenatal BPA exposure to metabolic health, evidence was provided of the induction of nitrosative stress by prenatal BPA in both the mother and foetus at time of birth. The researchers concluded that:
Whether or not BPA is harmful to human health has been vigorously debated. These findings demonstrate that more studies like this one are needed to determine the disease risk of exposure to BPA. In the interim, these results indicate that pregnant women should minimize their exposure to BPA to safeguard their babies and themselves from oxidant injury.
I can safely predict that the EFSA opinion will not be the last word on potential human harm caused by BPA.