To Chair and Members of the Scientific Committee on Consumer Safety:
“While recognizing that the SCCS currently looks for a ‘safe dose’ under the existing risk assessment procedure, we believe this approach is outdated since science has clearly demonstrated that in the case of endocrine disruptors a threshold approach is inappropriate and such thresholds may not in fact exist. This has been taken into account for EDs identified under the hazard classification in the PPP and BPR regulations, where once identified as an ED the substance cannot be used in pesticides or biocides. We believe this approach based on identification should be extended to all relevant legislation."
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