Dear Members of the EFSA Scientific Committee,
“The Endocrine Society takes this opportunity to provide detailed comments addressing important issues regarding the draft EFSA Scientific Committee Opinion on biological plausibility of non-monotonic dose responses and their impact on risk assessment. In its current construction, the document is an inaccurate assessment of non-monotonic dose responses (NMDRs); without substantial revision, adoption of the opinion will result in the use of restrictive criteria that will limit the ability of regulatory agencies to make health protective decisions. We hope that these comments will help EFSA re-evaluate the scientific basis of the opinion’s conclusions. Additional improvements would be possible through collaboration with other stakeholders, including endocrine scientists, to ensure that the final draft accurately reflects the state of the science of NMDRs and their relevance to regulatory assessments, including for endocrine-disrupting chemicals (EDCs)."
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