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Critical analysis of the draft National Strategy on Endocrine Disruptors 2 (SNPE2) and proposal of result indicators

France adopted a proactive approach to drafting the first National Strategy on Endocrine Disruptors, and is very active on the subject within the European Union. The second strategy (SNPE2) is currently being drafted under the joint oversight of the Ministries for Solidarity and Health and the Ecological and Inclusive Transition. The HCSP was asked to provide a statement on the draft SNPE2 and the proposals for action being considered and to outline expected result indicators.

The HCSP has performed a critical analysis of the draft which, as a whole, addresses the priorities put forward in the report by the general inspectorates (IGAS, CEGDD, CGAER), published following the evaluation of SNPE1. However, it issues strong recommendations:

  • Combine the measures undertaken in the context of European regulatory procedures with an ambitious risk management approach at national level – not least in terms of information for consumers.
  • Harmonise European regulations on hazardous chemical substances by including endocrine disruptors and categorising these into 3 groups according to the proof of danger.
  • Take greater account of food as a source of exposure to endocrine disruptors.
  • Better integrate the socio-economic dimensions and inequalities of exposure, especially in the professional setting.
  • Raise the profile of the issue of endocrine disruptors in other public policies and plans.
  • Dedicate a national multidisciplinary research programme to endocrine disruptors and enhance knowledge on the impact of endocrine disruptors on ecosystems (wildlife and environments).
  • Identify the operators for each action of the strategy and their role, and announce the resources that will be allocated to each action.

This report has a twofold purpose: facilitate the real-time monitoring of the plan’s effectiveness and provide guidance that will enable judgment to be passed upon its performance. In that regard, the HCSP has appended proposals of specific performance objectives and indicators for the actions of the second National Strategy on Endocrine Disruptors.

Addendum: Taking into consideration the report requested from the HCSP, the Government just issued its SNPE2, whose Action plan has been substantially modified compared to the version based upon which HCSP had devised its recommendations. Among other changes, the ranking and number of actions, sometimes also their content, are different from those cited in the SNPE2 critical analysis that is presented herafter.

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