8/7/12

John Dalli
Commissioner
Directorate-General for Health and Consumers
European Commission
Brussels, Belgium
Transmitted by electronic mail

Dear Commissioner Dalli,

I have carefully considered the position of the Directorate-General
for Health and Consumers (DGHC) on the matter of persistent organic
pollutants (POPs) contamination of the global environment and
governmental actions necessary to protect public health.  I  have
concluded that the DGHC is failing to fully utilize scientific
knowledge on the subject of POPs exposure and disease outcome.  I have
formed this conclusion based upon the position of the DGHC on
government’s role in this matter as stated at point number 4 in a
letter signed by Mr. Michael Fluh, Head of the Safety of the Food
Chain Unit dated December 8th, 2011.

4) “The Commission is of the opinion that the setting of action and
maximum levels for dioxins and PCBs and the adequate enforcement of
these levels provide a high level of human health protection and that
there is no need for specific dietary advice at EU level for the
consumption of animal fat as regards dioxins and PCBs.”

This statement would be valid if the background levels of dioxins,
PCBs and the other POPs were of such low magnitude as to impose no
risk of adverse health effects.  However, this is not the case.
Background levels of POPs contamination of the EU food supply are
similar to those in most other industrialized parts of the world.
Background global levels of POPs contamination are of sufficiently
high magnitude to impose significant risk of serious disease outcome,
including:  cancer, type 2 diabetes, cardiovascular disease,
autoimmune diseases, cognitive deficits, developmental abnormalities,
and reproductive impairments.  In 2010 the World Health Organization
(WHO) published, “Persistent Organic Pollutants:  Impact on Child
Health”.  This report provides guidance on public health protection
policy relating to POPs contamination of the food supply.  WHO calls
for a worldwide effort to minimize the exposures that children receive
to POPs.

Limiting DGHC action on POPs to those items set forth in point 4 shown
above is far less than an effort to minimize POPs exposure.  The most
important strategy for POPs exposure minimization is providing the
general public with a warning of the POPs exposure health hazard.
This can best be accomplished by publication of a POPs exposure health
hazard advisory.  The purpose of publishing and widely disseminating
the health hazard advisory is to raise public awareness of the POPs
exposure health hazard thereby empowering individuals to decide for
themselves whether or not to take the risk of eating animal fats at
current levels of food supply contamination.

The measures set forth in point 4 only serve to protect against
accidental excess contamination of foods.  These measures do not
address background levels of contamination.

I have previously requested a dialogue on collaborating to accomplish
POPs exposure minimization in the EU.  Our organization is moving
steadily forward with POPs exposure minimization in the United States.
We are working closely with the National Center for Environmental
Health and the Agency for Toxic Substances and Disease Registry,
sister agencies of the Centers for Disease Control and Prevention.
These agencies are currently proceeding with the creation of a
document on dioxins and another document on PCBs.  These documents are
intended for use in the education of physicians on the subject of the
significant disease risks associated with current levels of POPs
exposure.  Educating physicians is an integral part of POPs exposure
minimization education.  Once these documents have been completed, the
next step will be to create documents designed for education of the
general public.

POPs exposure minimization is the only sound policy goal for
minimizing the damages to health that result from the POPs
contamination of the global environment.  The only reason for
hesitating to take up the work of POPs exposure minimization is fear
of corporate displeasure.  I encourage the DGHC to overcome that fear
and join into the worldwide effort to minimize the POPs exposure of
children.

joyous in Nature,

Donald L. Hassig

—
Donald L. Hassig, Director
Cancer Action NY
Cancer Action News Network
P O Box 340
Colton, NY USA 13625
315.262.2456
www.canceractionny.org