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Jennifer Garfinkel
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WASHINGTON (January 14, 2020) – The American Chemistry Council’s North American Flame Retardant Alliance (NAFRA) issued the following comments in response to a study published today in Molecular and Cellular Endocrinology titled, “Trends in Neurodevelopmental Disability Burden Due to Early Life Chemical Exposure in the USA from 2001 to 2016: A Population-based Disease Burden and Cost Analysis”.

“Neurodevelopmental disability is a critical issue, and better understanding factors that could contribute to it is an important area of research. However, the inaccurate and misleading claims made in this study are not supported by the very science and data cited within the research paper.

“According to the U.S. Center for Disease Control (CDC), ‘most developmental disabilities are thought to be caused by a complex mix of factors. These factors include genetics; parental health and behaviors (such as smoking and drinking) during pregnancy; complications during birth; infections the mother might have during pregnancy or the baby might have very early in life; and exposure of the mother or child to high levels of environmental toxins, such as lead. For some developmental disabilities—such as fetal alcohol syndrome, which is caused by drinking alcohol during pregnancy—we know the cause. But for most, we don’t’.

“High-quality research is essential to guide health professionals, policy-makers and the average person in making well-informed, evidence-based decisions. Unfortunately, the conclusions noted in the study published today in Molecular and Cellular Endocrinology are not based on good science for the following reasons:

  • The authors rely on numerous unverified assumptions in performing their work.
  • The authors of this specific study confuse statistical correlation with causation. A correlation may suggest a relationship between two variables, but it does not prove that one variable causes a change in another variable. Studies like this one, which are designed to find a correlation, cannot lead us to a conclusion about cause.
  • The authors utilized biomonitoring data for only one type of polybrominated diphenyl ether (PBDE) flame retardant as a proxy for all types of (PBDEs) flame retardants. The class of PBDE flame retardants represent a diverse set of chemicals that are not all the same. This is further compounded by the fact that this class of chemistry has not been produced in the US for years and is being phased-out globally, so relying on this time-limited data as a proxy vastly overestimates the underlying exposure assumptions and hence reduces the accuracy of the conclusions.
  • The authors relied on National Health and Nutrition Examination Surveys (NHANES) for the biomonitoring data, which represents a one-time sample, and used it to represent a much longer exposure period.
  • The researchers acknowledge that there are limitations to their analysis. Most importantly, they acknowledge that their assumptions that these chemicals cause IQ loss and intellectual disability may NOT be true.

“Therefore, it is not possible to conclude that chemicals—and in particular, flame retardants—are the cause of neurodevelopmental health disorders in children.

“Flame retardants help save lives and reduce the devastating impacts of fire. They are an important tool in the overall fire safety toolbox that help make thousands of products safer, including consumer goods, electronics, building materials and transportation.

“Product safety should be a shared objective of all stakeholders. ACC and NAFRA strongly support efforts to ensure that appropriate chemicals are responsibly and safely used. Like all chemicals, flame retardants are subject to rigorous review by national regulatory agencies around the world to help ensure they are safe for their intended uses.”

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