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Home My WebLink AboutCOM 0771.270 2020-2022 PtCoun.ci pillf�1 coMM,77( From: Denis Dudley Sent: Thursday, May 26, 2022 4:16 PM To: Council Testimony o Subject: Petrochemical UV Filters are Hazardous to Humans and the Environment ^ b , Attachments: Towards_a_paradigm_shift_in_environmental_health_d.pdf; 10 ESTABLISHED CTS;Jr4 UT SOLUBLE ORGANIC UV FILTERS.docx; SUBMISSION in Support of BILL 167 N Y 20,? cx; Hawaii Testimony Executive Summary 2022.docx ro 1,46 To the attention of:Chair Maile David,Co-Chair Aaron Chung, and the Members of the County Council. Re: Bill 167. ca • Petrochemical UV Filters otherwise called Soluble Organic UV Filters (SOUVF)consist of 12 chemicals or benzene compounds still categorized by the FDA as "Marketed Unapproved Drugs". In FEB 2019 12 of these agents were Categorized by the FDA as failing to meet minimum criteria for acceptable safety and efficacy.The FDA declared oxybenzone,octinoxate,avobenzone, homosalate,octisalate,octocrylene, and 6 others as NOT Generally Regarded As Safe and Effective(GRASE). ONLY zinc oxide and titanium dioxide are categorized as GRASE by your FDA.They asked industry to produce the data required to justify a GRASE designation for petrochemical UV filters. 3 years has passed. NO SAFETY or EFFICACY data has been provided.The silence is deafening.The data will NEVER materialise for a simple reason-SOUVF are neither safe nor effective. • In 1990, I found oxybenzone and avobenzone in fetal blood at 30-36 weeks of pregnancy. In 1995 Hayden published data on oxybenzone in human blood from sunscreen application. Since then 25 years of published literature prove their presence in 98%of humans tested. Oxybenzone, homosalate,octocrylene,octinoxate are among the most ubiquitous environmental pollutants routinely detected in mammals,fish, birds, mussels, shrimp,turtles,sea grass, lettuce and other plants and microorganisms They now pollute the unborn- measured in blood, amniotic fluid, cord blood,semen and breast milk.Several of the petrochemical UV filters are now found in every component of the global water reservoir:tap water in many cities, every lake, river,the subterranean aquifer,ocean, reefs,glaciers, and even the Arctic. Councillors, please ask yourself: Do you know of another OTC or prescription drug, industrial chemical or pesticide that has polluted all of the planet, humanity,the unborn, land and marine wildlife,and now the food chain?SOUVF have!! Would you knowingly apply a pesticide-like chemical to your child's skin?Would you deliberately add 10W30 engine oil to your dinnertime salad for your family?Applying oxybenzone, homosalate, or octocrylene to your child's skin is similar- both routes end up with petrochemical contamination of your child's tissues and brain. The paper attached is from the Department of Environmental Health Sciences,School of Public Health and Health Sciences, University of Massachusetts.The senior author is Professor Laura Vandenberg who is a luminary in Public Health. She has published extensively on hormone disruption, confirming my position that even an undetectable dose of estrogen mimics like the SOUVF can have profound effects on the developing fetus,young or adolescent children, and even adults. Remember the FDA data that in 2019 dealt with very short term exposure: 4 petrochemical UV filters exceeded the FDA threshold of 0.5ng/ml for toxicity testing by Day 1 and 6 did so after 4 days of application. Oxybenzone achieved a blood level over 500 times,avobenzone and octocrylene about 15 X the established FDA threshold where safety data is usually mandated. Imagine the pollution of your body when used day in day out for years of sun protection. This signature public health paper is recommended reading for every lawmaker and regulator looking at the issue of sunscreen safety and efficacy. It uses oxybenzone as a case study. Remember under the endocrine principle of isoform function all 12 of the SOUVF are likely to act in a similar manner and many studies already confirm the Endocrine Nervous Disruption (END) and DNA damage effects of homosalate, octisalate, octocrylene, and octinoxate. Here are some excerpts that prove that all the fundamental principles and ethics in environmental and human health are being violated by the ongoing use of SOUVF, particularly since the latest studies support the cancer statistics from 1970-2015 that SOUVF (90%of global sunscreens) do not prevent cancer: �(1'.�,'I 0 Comm. No. Ref. To: P(coUYI (i 1 Ref. Date JUN ® 1 2022 • In ignoring the Precautionary Principle to regulate the pervasive application of synthetic compounds-the current flawed practice of cost-benefit analysis be recognized for what it is: a technocratic approach to support corporate interests. • The effects of oxybenzone in vivo are broad: it is toxic to cyanobacteria [14, 15],green algae [14, 16] and coral [17]. In rodents, oxybenzone alters the development of the mammary gland, alters the weight of the liver, kidney, and reproductive organs, decreases the number of spermatocytes in males [18-21] and induces DNA damage in the mammary epithelium [22]. In fish,oxybenzone interferes with reproduction [23, 24]. There is evidence that oxybenzone and its metabolites can affect human health, including effects on reproduction (time to pregnancy, risk of endometriosis,sperm quality, measures of infertility) [68-71]; birth outcomes [72, 73]; neurobehavioral outcomes in the offspring [74]; and health of other organs, e.g.,the thyroid gland [75, 76]. Furthermore, oxybenzone was identified as an allergen in 1-3%of the population [77]and while allergic reactions to sunscreens affect only a small proportion of the population, oxybenzone is a common photoallergic agent. (Comment:zero risk with zinc oxide). • Mammalian toxicological studies similarly point to oxybenzone's effects on the structure and function of tissues including endocrine organs. an increasing number of human studies suggest associations between oxybenzone and harm. These studies examine exposures and health outcomes at the level of individuals,finding "signals" of harm that have unfortunately been dismissed by some in • the dermatology community because the studies do not examine the population in entirety. These findings should not be ignored in a quest for a "perfect" human cohort. With the evidence that is currently available,the principle of"first do no harm"disqualifies oxybenzone due to its maleficence. Comment: Most studies to provide randomized controlled data are unethical and would require observation over a lifetime into the next generation and industry full well knows this. • The Hawaii case study provides an example of a specific population acting meaningfully against environmental pollution. Yet, a situation where governing legislators rule confidently and effectively against a polluting agent is an exception rather than a norm.Typical stories of disproportionate pollution in communities commonly end—if resolved at all—in cumbersome repressive legal actions and public budgets paying for the consequences of the pollution. • Oxybenzone [and other SOUVF] provide one additional angle to the Principle of Justice:this chemical has been detected in the bodies of individuals across the globe, regardless of their personal decisions or reported use of chemical sunscreens [81].Above all, neonates are born having already been exposed to chemical sunscreens [80]. Polluting our descendants raises the question of intergenerational justice. All of the harm for no public benefit is well documented in the other attachments written by a specialist in Maternal Fetal- Medicine/Reproductive Endocrinology and a Dermatologist/Photobiologist. We have said for years that it is malfeasance to expose a fetus to a petrochemical with pesticidal qualities like DDT,that is a xenobiotic with endocrine active effects, now known to have risks for birth defects, and poor pregnancy outcomes, disorders of puberty, infertility and other long term problems. It is arguably a breach in any standard of medical practice to withhold information on the proven bioavailability of SOUVF to all humans, particularly when there is no demonstrable reduction in skin cancer among the general population of sunscreen users. SOUVF lack the UVA protection of zinc oxide, which partly explains their failure to prevent skin cancer. No Benefit Only Risk. Even dermatologists are now admitting this. Professor Grant Kels (Adult & Pediatric Dermatology, UConn) now agrees that sunscreens fail to prevent skin cancer and argues that only mineral products should be used in women of child bearing age and in pregnancy—referenced in attachment 4. We say SOUVF are contraindicated in every human— First Rule in Medicine— Do No HARM. It is likely malpractice when providing a therapy to patients has NO Beneficence, only Maleficence. The 4 attachments codifies 50 years of literature and hundreds of papers, irrefutable by anyone and the SOUVF industry. The evidence and references are all there. Respectfully submitted for your consideration. Yours truly, Dr. Denis K. L. Dudley MD,FRCS(C). Mobile:613-292-8457. 2