BUILDING A GREEN ONTARIO THROUGH TOXICS REDUCTION

May 23, 2008 Memorandum to Environment Minister John Gerretsen from the Toxics Reduction Expert Panel

Memorandum

To: The Honourable John Gerretsen, Minister of the Environment
From: Toxics Reduction Scientific Expert Panel
Re: Bisphenol A Advice
Date: May 23, 2008

Introduction & Summary

The Toxics Reduction Scientific Expert Panel (“the Panel”) has now evaluated available evidence on Bisphenol A (“BPA”).  The limited human studies do not indicate that current exposures are harmful to adults, although this assessment could change as more studies are published.  Conversely, animal studies suggest that there is some concern for potential adverse effects of BPA on the fetus and young children.  Accordingly, the Panel supports a precautionary regulatory approach by recommending the prohibition of BPA-containing baby bottles and strongly recommends that the Ministry assess whether other products containing BPA such as “sippy cups”, polycarbonate kettles, and BPA-can linings merit control actions.  In addition, the Panel recommends that the Ministry cooperate with the Federal Government and others for conducting and/or funding of studies to clarify major routes of human exposure (particularly for women of child-bearing age as well as for infants and toddlers), identify major sources of BPA to the environment, Ontario citizens’ body burdens, and, importantly, potential alternatives (along with their potential environmental and health impacts) to BPA in products that contact food or drink. 

Recommendations re: Bisphenol A

Having reviewed the comprehensive assessments undertaken by Health Canada, Environment Canada, the US National Toxicology Program, and others, the Panel supports the adoption of a ‘toxics use reduction and safer alternatives’ approach to BPA. This would include a precautionary approach to the regulation of BPA in consumer products, particularly those used by women of child-bearing age, infants, and young children.  Accordingly, the Panel recommends that the Province:

• Prohibit the manufacture, distribution and sale (in Ontario) of baby bottles containing BPA, unless the federal government acts within two years.

Given the remaining substantial uncertainty regarding toxicity, exposure routes, and alternatives associated with BPA, the Panel further recommends that the Province:

• Cooperate with the Federal Government and other organizations to gather data on BPA exposure from products that contact food and drink, such as children’s “sippy cups”, polycarbonate kettles, and BPA-epoxy can coatings, particularly those used for infant formula.  This exposure assessment should include vulnerable populations that rely on canned goods to a greater extent than the general public; such populations could include those in remote communities, children’s camps, those who rely on food banks and the military.
• Gather data regarding BPA on the major routes of exposure to, and concentrations in, the Ontario population (bio-monitoring); there currently are no Ontario data demonstrating the extent to which Ontarians have been and are being exposed to BPA, and the pathways by which such exposure is occurring.  Such data are crucial in shaping the Province’s overall management strategy with respect to BPA.
• Cooperate with the Federal Government and other agencies to gather data regarding the hazards (if any) associated with, and environmental and health implications of, alternatives to BPA.  It is crucial that before BPA alternatives are widely marketed, adequate safety and environmental impact data are gathered and evaluated.  Although the properties of glass and stainless steel are well understood, those of many non-BPA-containing plastics are less well understood and should be regarded with caution.
• Depending on the outcome of the alternatives assessment, consider phasing in regulation, within two years, of BPA content in other products that come into contact with food or drink, as noted above.
• Explore options to provide “one stop” public access to information, including the data gathered above, regarding BPA and other chemicals in Ontario as well as options to improve capacity for public health units and healthcare professionals to provide consistent advice to the public.

Conclusion

The Panel recommends that the Province work with the Federal government and other agencies to take measures that will limit human exposure (particularly to the fetus and young children) to, and releases to the environment of BPA.  The Panel also recommends that further information be gathered and shared with the public so that well informed decisions can be made regarding the best ways to limit BPA exposure and releases, which are potentially deleterious to health.