Statement in support of listing BPA as a Reproductive Health Toxiciant under California’s Prop 65

Presented to the Developmental and Reproductive Toxicant Identification Committee of California EPA OEHHA’s Science Advisory Board July 15, 2009 Oakland, California Good morning. My name is Rivka Gordon. I am a Physician Assistant, a Women’s …

Presented to the Developmental and Reproductive Toxicant Identification Committee of
California EPA OEHHA’s Science Advisory Board

July 15, 2009
Oakland, California

Good morning. My name is Rivka Gordon. I am a Physician Assistant, a Women’s Health Care Specialist and the director of strategic initiatives with the Association of Reproductive Health Professionals based in Washington, DC and Oakland, California. ARHP serves as the leading source of trusted medical education and information on reproductive and sexual health. ARHP was founded in 1963 and is a multidisciplinary professional association with over 11,000 members, including physicians, nurse practitioners, physician assistants, nurse midwives, pharmacists, researchers, and educators, all with expertise in reproductive health research or practice. ARHP and its members provide reproductive health services and education, and conduct reproductive health research. ARHP fosters research and advocacy to improve reproductive health.

ARHP is accredited by the Accreditation Council for Continuing Medical Education to provide continuing medical education to health care providers through a variety of educational programs, meetings, and publications. ARHP advocates for evidence-based research and supports the availability of, and education about, a wide range of safe, effective, and appropriate new technologies to enhance the health of all women.


On behalf of ARHP and its members, it is my pleasure to provide comment before the California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) in support of including Bisphenol A in the Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65.) ARHP is offering comments today because we value evidence-based science and serve as the translating interface between cutting edge science and reproductive aged consumers. We are responsible for educating healthcare providers with expert information so that they can provide excellent care to their patients, safeguarding not only their health, but the health of their current and future families.

History and science make clear that substances once considered safe have later been shown to cause harm to pregnant women and their future children—thalidomide, alcohol and tobacco, mercury, DES, for example. Research informs us that a critical window of exposure may have much to do with what effect a harmful agent may later play on in the woman’s health or that of her child.

As a reproductive health issue, it is crucial for health care providers to learn more about potential risks that may adversely affect their patient’s reproductive health and pregnancy outcomes. It is important for women and families to have state-of-the-art recommendations so they can plan their pregnancies appropriately and assume the healthiest lifestyle –before they even know they are pregnant.


While the science is still emerging, what’s presently known about BPA is worrisome:

Human exposure to BPA is widespread: it is in the seemingly inconsequential plastics and lining of metal cans that women of reproductive age, babies and children come frequently into contact with- especially in the form of food and beverage storage and heating containers, water bottles, baby bottles.

Emerging research indicates that low-levels of BPA that were previously thought not to be harmful may now be associated with negative health outcomes.

Research indicates that BPA may be related to increased trends in humans regarding: abnormal penile/urethral development in males and early puberty in females, increase childhood and adult obesity and Type 2 Diabetes Mellitus, regional decreases in sperm count, and increased hormonally-mediated cancers such as prostate and breast cancers.

Informed by research from the environmental sciences and confirmatory research in laboratory animals who are exposed to levels of Bisphenol A that are relevant to human exposures, there is a growing concern about BPA’s adverse effects upon humans. We are concerned that all BPA scientific studies are not created equal and that the preponderance of studies relied upon by policy makers are those supported by industry when rigorously designed independently funded studies show results that are at odds with some industry funded studies’ results.


ARHP supports first rate science informing clinical decision making. Unfortunately we do not always have all the data we want to make definitive recommendations to our patients. But absence of a certain kind of evidence does not necessarily mean evidence of absence of harm. Ethical concerns prevent us from ever being able to conduct randomized double-blinded placebo controlled studies on pregnant women exposing them to various levels of BPA, or other endocrine disrupting chemicals. Scientific uncertainty will therefore continue to exist. In the face of scientific uncertainty and credible threats of harm, ARHP supports Precautionary Action in the form of governmental recommendations to decrease overall BPA exposure.

ARHP recommends that the California EPA under Prop 65 enact measures that decrease exposure and educate the public about possible harm from BPA. ARHP and its members, many pof whom are California’s leading reproductive health clinicians and scientists, believe that it is the responsibility of our state regulatory agencies to protect people, especially women of childbearing age, children and adolescents from the risk of exposure to BPA by adding BPA to the list of restricted chemicals under Prop 65.

I would like to thank the panel for the opportunity to present this statement.

Rivka Gordon, PA-C, MHS
Director of Strategic Initiatives
Association of Reproductive Health Professionals
1330 Broadway Suite 1100
Oakland, CA. 94618

Drug Integrity Associate Audrey Amos is a pharmacist with experience in health communication and has a passion for making health information accessible. She received her Doctor of Pharmacy degree from Butler University. As a Drug Integrity Associate, she audits drug content, addresses drug-related queries

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