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Endocrine disruptors: a denial of the state of the science

The European Commission relies on studies financed by industry.

HEAL has translated this article which originally ran in French on 29 November 2016 in LeMonde. It is Part 2 of a 3 part series, accompanied by a commentary signed by nearly 100 scientists:

Open Letter: Let’s stop the manipulation of the science.

Endocrine Disruptors: The manufacture of a lie (Part 1)

Endocrine Disruptors: The interference of the United States (Part 3)

By Stéphane Horel

The current scientific knowledge”: It is this that the European Commission assures it is using to justify its much criticised choices in the regulation of endocrine disruptors. Yet, the Endocrine Society, a major scholarly society, believes that the Commission “ignores [the] state of science”. How can such a hiatus be explained?

To document its considerations, the Directorate-General for Health and Food Safety, responsible for the file at the Commission, carried out an impact assessment of more than 400 pages, which was published in June after having been under lock and key as a state secret (Le Monde, 20-21 May). To what specific “scientific knowledge” does it refer?

Above all, the Commission cites the opinion issued by one of its official agencies, the European Food Safety Authority, in 2013. This opinion is indeed the basis of its regulatory proposal. But the decision-making process began in 2009 and the “scientific knowledge” on endocrine disruptors has evolved considerably since then. The Endocrine Society produced a review of the science in 2015.

It examined 1,322 publications that had been published since its last review, which was actually in 2009. Conclusion? They do not leave “any doubt that EDCs [endocrine disruptors] are contributing to increased chronic disease burdens related to obesity, diabetes mellitus, reproduction, thyroid, cancers, and neuroendocrine and neurodevelopmental functions.” In 2013, some 20 researchers working for nearly two years under the auspices of the World Health Organization (WHO) and the United Nations Environment Program (UNEP) had reached similar conclusions. Their report sounded the alarm bell on a “global threat that needs to be resolved”.

“Controversial interpretation”

These recent additions to “scientific knowledge” are indeed mentioned in the Commission’s impact assessment but to disqualify them on the basis that they do not deserve to be taken into consideration. “Evidence is scattered and its interpretation controversial,” the assessment report says, “so that a causal link or even a possible association between ED [endocrine disruptors] exposure at environmental levels and the diseases is not agreed among experts.” In the wake of this damning reception, it reduces the Endocrine Society to a “stakeholder” who has issued a “statement”. As for the WHO/UNEP report, “scientific criticism to the general methodology used … was raised”, it indicates, citing a number of publications which it says show that the controversy “seems not resolved”. But what publications would be sufficiently authoritative as to be able to knock down the work carried out by the most respected specialists in the field?

Notably, the Commission’s negative comments are based on “critical comments“, published in 2014, challenging the methods and conclusions of the WHO/UNEP report. Among the ten authors of the comments, seven are working for two consulting companies, Exponent and Gradient Corp, which specialise in scientific issues and are known as “product-defense firms”.

But, most importantly, it was industry that sponsored the article through its lobbying organizations:  the chemical sector with the European Chemical Industry Council (Cefic) and the American Chemistry Council and the pesticides sector with CropLife America, CropLife Canada, CropLife International and the European Crop Protection Association.

“Urban legend”

None of this can be unknown to the Commission services. Not only do these sponsors appear clearly in the declaration of interests at the end of the article, but industry itself sent it to them. Cefic sent it by e-mail to about thirty European officials involved in the case on 17 March 2014. In a message consulted by Le Monde, the industrialists explain that they have “commissioned a consortium of scientific experts to independently review the WHO-UNEP report “, fearing, in particular, that “despite its serious shortcomings it was being used to call for more precautionary chemicals policy.”

Other publications cited in the impact study include a two-page article, one of whose signatories is a person better known for his role as a consultant to the tobacco industry than for his competence on this topic. Among its co-authors are toxicologists paid by the chemical, pesticides and plastic industries. Another article has again two consultants out of the three authors and talks about endocrine disruptors as an “urban legend” posing “imaginary health risks”. Making fun of the “hypothetical” effects of endocrine disruptors, such as the “reduced penis length and size”, they pose the question of “whether the whole issue of EDC is more within the competence of Dr. Sigmund Freud than that of toxicology”.

Can these texts really be incorporated into “scientific knowledge”? Why does the Commission give so much credit to documents that resemble lobbying material? In a momentous editorial published today [29 November 2016] in Le Monde, independent scientists express concerns about a “distortion of the evidence by industrially sponsored actors”. Signed by a hundred experts from two very different fields – endocrine disruption and climate change – their text notes the “dangerous consequences for the health of people and the environment” of this strategy of “manufacturing of doubt”.

This article has been translated by the Health and Environment Alliance from the original French version here:

This article ran on 29 November 2016 in LeMonde, France, alongside 3 other articles :

  • Let’s stop the manipulation of the science.
    A commentary by nearly one hundred scientists, asking the European Union and the international community to act against endocrine disruptors. They condemn the use of strategies for manufacturing doubt employed by industries in the climate change battle.


Endocrine disrupters: the manufacture of a lie

The European Commission has developed its own evidence to avoid what it considers to be an overly stringent regulation of these hazardous substances.

HEAL has translated this article which originally ran in French on 29 November 2016 in LeMonde. It is Part 1 of a 3 part series, accompanied by a commentary signed by nearly 100 scientists:

Open Letter: Let’s stop the manipulation of the science

Endocrine Disruptors: A denial of the state of the science (Part 2)

Endocrine Disruptors: The interference of the United States (Part 3)

By Stéphane Horel

Everything, or almost everything, is contained in a few words: “(Endocrine disruptors) can … be treated like most other substances of concern for human health and the environment.” It is on this simple phrase, which comes from the conclusion of an Opinion from The European Food Safety Authority’s (EFSA) in 2013, that Brussels bases its plan to regulate endocrine disruptors, these ubiquitous substances capable of interfering with the hormonal system, often at low doses.

The proposal, which is due be voted on by the Member States soon, has not only France, Denmark and Sweden united against it but also all the non-governmental organizations (NGOs) who consider that it does not protect public health and the environment.

The expert scientific community, embodied by the Endocrine Society – a scholarly society that brings together some 18,000 researchers and clinicians specialising in the hormonal system – is also battling against the proposal. This opposition is surprising given that the European Commission insists that it relies on science, in the form of the scientific expertise of EFSA.

The explanation for this singular hiatus is found in a series of internal documents of the European administration obtained by Le Monde. They show, without ambiguity, that the key phrase on which the regulatory edifice proposed by the Commission is built had been drafted even before any scientific expertise had really begun.

Written conclusions in advance

In December 2012, EFSA was already presenting “conclusions/recommendations” in an e-mail to the experts it had assembled to carry out this work. It said: “…endocrine disruptors and their adverse effects should be treated just like any other chemical of concern for human health or the environment “. The key phrase is already there. Yet, the very first meeting to set up work was held only a few days before. At the end of March 2013, three months later, the phrase figures in the conclusions of the opinion published by the agency.

“For sure, the conclusions were written beforehand, if not on paper, but in the heads of some of the participants,” a source close to the file at the time told Le Monde. The Commission itself did not respond to our questions. EFSA reacted with an assurance that it had properly fulfilled its mandate. EFSA’s “Scientific Committee took stock of the various views from a number of experts and forums”, the European agency said when questioned.

The “EFSA phrase”, harmless for the uninitiated, has in fact a considerable weight. Because if endocrine disruptors were actually substances that are just like any others, then there would be no need for strict regulation.

The pesticide industry, which is most affected by the issue, has clearly understood the point. Its main lobbying organisations – the European Crop Protection Association (ECPA), CropLife International, CropLife America – or the German agrochemical groups BASF or Bayer repeat ad libitum the “EFSA phrase” in arguments and correspondence with the European institutions that Le Monde has seen.

In fact, the famous phrase is of major importance for European regulation on plant protection products. It was in 2009 that the European Parliament voted a new “pesticides regulation”. According to this legislation, pesticides a priori identified as “endocrine disruptors” would no longer be allowed to enter or remain on the market except when the exposure is considered negligible.

This provision only needs one thing if it is to be applied: the adoption of scientific criteria to define endocrine disruptors – that is, what Brussels is proposing today. But since endocrine disruptors are chemical substances like any others – it’s the “EFSA phrase” that prompts the question: why prohibit them a priori?

“Major breach” in health protection 

The Commission has therefore made an amendment to the text. Now, it is sufficient to assess the risk that they present on a case-by-case basis if problems arise after they have been placed on the market – and therefore a posteriori. Is this change at the cost of the spirit of the 2009 regulation?

This amendment would open a “major loophole” in the protection of health and the environment, says EDC-Free Europe. This coalition of NGOs accuses the Commission of wanting to distort the intention of European law.

But above all, this amendment to the 2009 Regulation poses a democratic problem: it is much as if the officials have taken the initiative to draft an implementing decree that had nothing to do with the intention of the elected representatives. The European Parliament is also of this opinion. In a copy of a letter seen by Le Monde and dated 15 September, the chairman of the Parliament’s Environment Committee wrote to the Health Commissioner, Vytenis Andriukaitis, who is responsible for the file, saying that the project: “exceeds the implementing powers of the Commission” by amending “essential elements” of the law. Similarly, in their note of 10 October, France, Denmark and Sweden do not say anything different, judging that that the Commission has no right to change “a policy choice by the legislator”.

This rebuke is all the more unfortunate because it comes when the Commission is already in a state of illegality on this issue. The European Court of Justice actually condemned the Commission in December 2015 for violating EU law: the Commission had been required to settle the question of the criteria to identify endocrine disrupters before the end of 2013.

However, the Commission remains unfazed by the shower of criticism. It offers an assurance that it has fulfilled the condition which authorizes it to “update” the regulation: to take into account the evolution of “scientific knowledge”, namely the famous little phrase of EFSA. It is that phrase on which its justification rests.

But why should EFSA have written, in advance, a conclusion in breach of the scientific consensus? An internal Commission document obtained by Le Monde sheds some light on the intentions of the Directorate General for Health and Food Safety (DG Health), which is now responsible for the matter at the Commission.

A meeting report records in black and white that, as of September 2012, DG Health intends to disregard the will of elected representatives in Europe. The health directorate said then that it “did not oppose even the idea to go back to regulating based on risk assessment” and was “ready to change entirely” the part of the regulation concerned.

The same document states further on that DG Health will have to “talk with EFSA to try and accelerate the preparation” of its opinion. At this point, EFSA’s opinion did not exist … The agency had only just been asked to set up a working group on endocrine disruptors.

A “mortified” message

The very special conditions in which this working group operated can be read in e-mails exchanged by EFSA experts and officials. One month before the release of the EFSA report, the World Health Organization (WHO) and the United Nations Environment Program (UNEP) published a joint report on endocrine disruptors.

A mortified EFSA expert sent a message to the whole group: “It is almost embarrassing to compare the current draft report with the WHO-UNEP report … when WHO-UNEP comes to the conclusion that traditional risk assessment of chemicals is not fit for purpose to assess (endocrine disruptors), we are exactly coming to the opposite conclusion.”

This scientist considered it essential that the conclusions be radically changed. The EFSA official overseeing the work of the expert group agreed. The “current conclusions where we explain that [endocrine disruptors] should be considered like most other chemicals [...] puts us in isolation compared to the rest of the world, and may be hard to defend,” he writes. However, when EFSA’s opinion is published on 20 March 2013, it continued to include, unperturbed, the little phrase.

“This should be a science-based procedure – so evidence-based policy-making,” says Axel Singhofen, an adviser to the Greens-European Free Alliance in the European Parliament. “But what we see here is policy-based evidence-making.”

This article has been translated by the Health and Environment Alliance from the original French version here:


EDC-Free Europe letter to EU Ministers on revised EDC criteria

Monday 14th of November 2016
To: Health, Environment and Agriculture Ministers

Dear Minister,

Ahead of the discussions on the criteria for endocrine disrupting chemicals in the Standing Committee of Food Animals Food and Feed on 18.11.2016 under the Pesticides 1107/2009 and Biocides 528/2012 Regulations, we would to like to share our concerns regarding the revised draft Commission proposal.

The EDC-Free Europe coalition opposes this revised proposal because the text still demands too high a burden of proof, fails to address the requirements of the Pesticide and Biocide Laws and is hence also unfit to apply to other EU regulations. The criteria will still fail to protect EU citizens and the environment the way the law intends.

Our two main concerns we would urge you to address:

1) The revised proposal continues to impose an unreasonably high burden of proof to identify EDCs. Although there have been some useful clarifications, the criteria are very difficult to fulfil because of the requirement to prove a consequential link between the adverse effect and the endocrine mode of action. In addition, the draft does not include categories in order to reflect the different levels of scientific evidence available, in spite of the fact that both EU Biocides and Pesticides Laws require the identification of EDCs that `may` cause adverse effects (i.e. suspected/potential EDCs).

2) The revised proposal still keeps the amendments to the Annex of the Plant Protection Product Regulation that alter in a fundamental way the risk management choice agreed by Council, Parliament and Commission in the co-decision procedure. The change in the derogation from `negligible exposure` to `negligible risk` introduces new risk elements to the legislation. By this change, the Commission widens an existing limited exemption into a major loophole that can easily be exploited to enable continued use of identified EDCs. This would allow endocrine disrupting pesticides to be authorised for widespread use. Europeans and the environment will remain unprotected for the harmful effects of EDCs.

The EDC criteria are expected to have wide ranging implications for all EU chemicals laws and therefore the proposal needs to be changed to ensure coherence and to protect human health and the environment. We therefore call on you to oppose the revised Commission proposal and ensure the EDC criteria will provide a high level of protection, are in line with the European law and can be applied across all Regulations pertaining to chemicals.

Your decision will be a critical contribution in the urgent efforts to prevent endocrine-related diseases for Europeans and averting damage from our ecosystems.

With kind regards on behalf of EDC-Free Europe coalition,

Francois Veillerette
President of Pesticide Action Network (PAN) Europe 

Genon Jensen
Executive Director, Health & Environment Alliance (HEAL)

Letter available to download here

NGOs’ verdict to Commission’s revised proposal on EDC criteria: not right again!

Brussels, 8 November 2016 – EDC-Free Europe has reacted strongly to the European Commission’s revised proposal on EDC criteria because it will fail to protect health and environment.

“Despite some clarifications, the proposed criteria will not protect citizen’s health or the environment the way the law intends.  The burden of proof to identify EDCs is still too high. But even worse, the Commission kept in the massive and illegal loophole to the EDC ban on pesticides, against the spirit and intention of the law,” says EDC Free Europe spokesperson Genon K. Jensen.

The NGOs criticise:

  • the unreasonably high burden of proof to identify EDCs
  • the exemption that allows widespread use of endocrine disrupting pesticides
  • the absence of multiple categories to rank chemicals according to scientific evidence
  • the discrimination against independent studies.

The Commission has retained its proposed change to the exemption from “negligible exposure” to “negligible risk” using a flawed justification of adaptation to scientific progress.  This change allows endocrine disrupting pesticides to be authorised for widespread use.  But this change touches the essential balance in the law, something the Commission is not allowed to change in a committee procedure.  Such changes must be done via Parliament and Council in a fully transparent and democratic ‘co-decision’ process.


This postcard is available in EnglishFrench, Dutch and Danish.

Photo opportunity


EDC-Free Europe campaign partners will meet with MEPs outside the European Parliament on Wednesday 9 November to highlight a citizen’s call on endocrine disruptors. A petition from SumOfUs calls on European leaders to protect the public and environment from endocrine disrupting chemicals (EDCs). (1)

EDC-Free campaign partners will hand over a postcard to MEPs highlighting recommendations on how to achieve an EDC-Free future, how to get EDCs properly identified, and how to reduce people’s exposure to these chemicals.

   # # #


Lisette van Vliet, Mobile: +32 484 614 528
Vito A. Buonsante,, Mobile: +32 475 239 402
Francois Veillerette,, Mobile: +33 681 64 65 58
Hans Muilerman,, Tel: +31 6 55 80 72 55


1. View the petition: Reject the EU Commission’s disastrous draft proposal on endocrine disruptors to protect public health and the environment at
The petition is available in English, French, Spanish, German.

2. EDC Free Europe reaction to EU Commission proposal (released 15 June 2016)

EDC Free Europe is a coalition of more than 70 environmental, health, women’s and consumer groups across Europe who share a concern about endocrine disrupting chemicals (EDCs) and their impact on our health and wildlife. The coalition aims to raise awareness and urge faster governmental action on these chemicals. Over 11,000 individuals support the campaign, communicating in seven languages.

SumOfUs is a global consumer watchdog group that campaigns to hold big corporations accountable. Over 10 million people have taken over 50 million actions worldwide with SumOfUs since it launched.

EU member states have chance to decide on the future of our health

On the 15 June, the European Commission finally released its proposal for criteria to identify hormone disrupting chemicals (also known as endocrine disrupting chemicals or EDCs) for the EU biocides and pesticides laws. It then held meetings with member states and with stakeholders to explain the proposals, and conducted 2 parallel public consultations on these proposed EDC Criteria in July. 

Draft general message 2_opt

Experts and official representatives of the 28 member states met on 21 September (separately a biocides expert group and the Pesticides Standing Committee) in Brussels to discuss the proposed criteria. The country representatives in the Pesticides Standing Committee will vote on the proposals in a future Committee meeting. Under the biocides law, no vote is required on the biocides proposal.

To date, the proposals have been widely criticised by scientific and medical professionals. The Endocrine Society noted that the overly strict [draft] criteria would result in very few EDCs being identified and regulated, at a high cost to the public’s health [1]. Leading EDC researchers have criticised both the high burden of proof required to identify an EDC, and the «confused set of processes for identifying, evaluating and integrating scientific evidence which unnecessarily privilege certain types of data, and cannot be adequately operationalised for regulatory identification of EDCs» [2].

If the Pesticides Committee approves the final proposal, which the Commission may still change as a result of the discussions before the vote, the approved proposal then proceeds to Parliament and Council, who have 3 months to decide if they want to reject the proposal.

Our verdict on Commission proposal

Despite a delay of nearly three years, the Commission’s June proposal still fails to satisfy, both in terms of the scientific content and parameters, and in terms of protecting the health of humans, wildlife and the environment. When the criteria proposal was released in June, the EDC-Free Europe Coalition expressed its astonishment, strongly condemning the proposal.

For these reasons, the EDC-Free Europe Coalition urges all national governments to reject the proposal as it currently stands and insists on major changes to ensure that the EDCs to which we are exposed will be identified as such and therefore be prohibited from use as the laws intended, in order protect our health.

Want to know what you can do?

Use our infographics and tell your governments to demand better criteria for better health protection!

Draft general message 1

Copy of EDCFree September template (positive) (7)

Draft general message 3



European Commission launches two public consultations on hormone disrupting chemicals in midst of summer

18 July 2016, Brussels – Following the Commission`s proposed criteria for identifying hormone disrupting chemicals, also known as endocrine disrupting chemicals (EDCs) on 15 June, it has now launched two more public consultations, which close on 28 July.

After a delay of nearly three years, the Commission’s proposal still fails to protect the health of humans, wildlife and the environment. On the day of the announced criteria in June, the EDC-Free Europe Coalition expressed its astonishment, strongly condemning the proposal.

The current proposal fails to address the pressing public health threat from EDCs and fulfill the legal mandate to protect health, wildlife and the environment from exposure to these chemicals. The Commission has ignored the majority of respondents to its 2015 public consultation who supported the most effective use of science to protect humans and wildlife, especially vulnerable groups such as pregnant women, babies and children. At that time over 20,000 citizens made their voice heard in this first European Commission public consultation. Despite this public demand to protect our health and the environment, the Commission has ignored these concerns.

Over 1,300 scientific studies link exposure to EDCs to spiraling rates of hormone-related cancers, diabetes, obesity and behavioral problems in children. In addition, the health costs of diseases associated with exposure to these chemicals are estimated at 158 billion EUR per year.

The proposal must be rectified to ensure a high level of protection for health and the environment, preventing endocrine- related diseases for Europeans and averting damage from our ecosystems. Our everyday exposure must stop to protect current and future generations.

EDC-Free campaign partners have started providing feedback to the EU Commission. You can join them by following these links:


For any questions, please contact the EDC-Free Secretariat

EDC-Free Coalition asks Environment Ministers to say NO to hormone disruptors

Dear Environment Minister,

Ahead of the June Environment Council, we are writing to you on behalf of EDC-Free Europe, a coalition representing over 70 organisations who have come together because of our concern about endocrine disrupting chemicals (EDCs).

The EDC-Free Europe coalition strongly condemns the Commission proposal for criteria to identify endocrine disrupting chemicals (EDCs) presented on June 15th. It will fail to protect wildlife and to address this urgent public health threat. We have reason for concern – over 1,300 studies have linked EDC exposure to serious health problems including infertility, diabetes, obesity, hormone-related cancers and neurological disorders.

We see two major problems with the proposals which we ask you to rectify:

1)      The Commission proposes to identify EDCs only if they have been proven to cause adverse effects in humans or non-target organisms. Requiring this unprecedentedly high level of proof means that humans and the environment will most likely have to be harmed before action is taken. This level of proof is incoherent with the usual approach taken in the EU for e.g. identifying carcinogens which uses both the wording `known` (CLP cat 1 A) and `presumed` (CLP cat 1B). The proposal will have wide ranging implications for all EU chemicals laws and therefore needs to be changed in order to ensure coherence, and to protect wildlife and people.

2)      The Commission proposes amendments to the Plant Protection Product Regulation that alter the agreement taken between Council, European Parliament and Commission in the co-decision procedure. They propose changing the legal text from endocrine disruptors that “may cause adverse effect” to endocrine disruptors “known to cause an adverse effect”.  Furthermore, the Commission goes beyond their task on identification criteria and actually reintroduces new specific risk assessments for all EDC pesticides, which changes the balance and approach agreed between Council and Parliament. They propose widening an existing exemption into a major loophole for those cases where chemicals have been identified as EDCs (changing `negligible exposure’ to ‘negligible risk´). This would allow continued uncontrolled exposure to these chemicals of high concern.

We therefore call on you to use the opportunity at the Environment Council meeting on Monday, 20th of June, to insist on major changes. Thank you very much for ensuring a high level of protection for human health and the environment, preventing endocrine-related diseases for Europeans and averting damage from our ecosystems.

In the view of the public interest in this matter we will make this letter available more widely.

Translations of this letter are available in English, Spanish, and French.

EDC-Free Europe reaction on Commission’s EDC criteria proposal

Commission’s EDC criteria proposal:  More humans will have to be harmed before action is taken

The EDC-Free Europe coalition is astounded at and strongly condemns today`s Commission proposal for criteria to identify endocrine disrupting chemicals (EDCs).

EDCFree reaction

The Commission proposed to identify EDCs based on an unprecedentedly high level of proof.  This proposal requires such a high amount of evidence that it will be nearly impossible to identify more than a small fraction of substances posing a threat to human health and the environment from hormone disruption. The health costs of diseases associated with exposure to endocrine disrupting chemicals, including infertility and male reproductive dysfunctions, female reproductive problems (endometriosis and uterine fibroids), birth defects, obesity, diabetes, cardiovascular disease, and neurobehavioral and learning disorders, have been estimated at 158.4 billion Euros per year in the EU.

Moreover, the Commission ignored that:

  • This approach is inconsistent and incoherent with the current, well established, and successful approach to identifying and ranking carcinogens, mutagens and chemicals toxic to reproduction according to the level of evidence;
  • The majority of respondents to the Commission`s public consultation supported to use multiple ranking categories (option 3) to effectively use the science to protect human health; 
  • The leading scientists recommended option 3 as the right option because it
    • takes up the latest science and new emerging research, and;
    • enables the regulation to protect pregnant women, babies and children.

Potential EDCs will not be captured – “MAY” cause adverse effects deleted
The proposal further undermines the current biocides and pesticide legislation by ignoring a key aspect – “potential” EDCs. The current law covers hormone disrupters which ` may cause adverse effects [in humans or animals]´. This shows the clear intention of the entire EU Parliament and Council to regulate not only definite but also strongly suspected EDCs. However, the Commission proposal gets rid of this wording in the proposed changes to the pesticide law.  Furthermore, the Commission proposes only one category, and sets restrictive conditions on the evidence which means that humans will most likely (continue to) be harmed before action is taken.  This is not only a glaring departure from the EU precautionary approach both enshrined in the EU Treaties and carefully and intentionally built into the biocide and pesticides laws, it is simply not an acceptable level of protection.

Sneaky: Changing negligible EXPOSURE to negligible RISK
Moreover, in a move that is potentially illegal the Commission goes beyond identification criteria to propose widening an existing exemption in the Pesticides law into a major loophole for those cases where chemicals have been identified as EDCs (changing `negligible exposure’ to ‘negligible risk´).

We urgently call on the Member States to insist on major changes because these proposals will do nothing to protect human health and environment from further harm but instead allows the pesticide and chemical industries to continue using harmful substances to which we are all daily exposed.