Underneath the Labels

Written by Thomas Roiss


Thomas Roiss, a master’s student of the MA STS program at the MCTS, shares an essay written for the course, “Evidence Practices in Environmental Health.” BPA, a chemical from which many plastic products are made, is discussed for its omnipresent role in society today as well as how its toxicity is managed through evidence practices. Labeling and substituting are presented as strategies utilized by industry in order to strengthen a shift of responsibility from governmental to scientific authorities in charge of presenting information to individual responsible consumers.

Keywords: toxicity, chemical pollution, endocrine disruptors, BPA, consumerism, evidence practices, epidemiology


It was not long ago, when plastic seemed to be the greatest invention ever made, and the hopes and promises it held were never-ending. We started using those materials for all kinds of things, from floors to bulletproof vests, from clothing to baby bottles. When asked about potential toxicities of the chemicals used to produce these materials, we were reassured that it would not matter, because they are bound in those long molecular chains called polymers, and no individual molecules could possibly migrate. And even if they did, the concentrations would be so low, that in the classic toxicological model of dose-response relationships it would be absolutely safe. Trusting the narratives of its safety, we used particular types of plastic, ones that contain Bisphenol A (BPA), for almost everything – food packaging, receipts, toys. Only decades later do we realize that BPA does migrate (Vandenberg, Maffini, Sonnenschein, Rubin, & Soto, 2009; Vogel, 2009). And that it did so for years and years, until it became ubiquitous in our environment, as well as in our bodies – it has now reached detectable levels in more than 90 % of different sample populations (Vandenberg, Hauser, Marcus, Olea, & Welshons, 2007). And what is more, we are realizing that it is a so called endocrine disruptor, a chemical that can act similarly to a hormone, and is therefore dangerous even in minute quantities (Vogel, 2009). As a consequence, we now have substitute chemicals and we have labels, telling us when a product is “BPA free”. Finally, the world is alright again. Or is it?

And who is this “we” that I am constantly referring to? Who knows all those things, and how? Well, I would call this “we” the society, made up of citizens, informing themselves, choosing their sources and making up their own opinion – ideally. But what we really see is a different story. I want to argue that today our society, this diffuse “we”, is being framed as not consisting of citizens, but of consumers. Consumers that, even before they can inform themselves, are readily being informed by evidence provided by the market players. Consumers that are assumed – and expected – to have completely free choice based on this information. Welcome to the age of responsible consumerism.

How do these narratives influence regulations on potentially harmful chemicals? How are evidence practices enacted via the labelling of products, and what does this say about regulatory practices in a consumer driven world? In this essay, I argue that BPA presents a special exemplary case of the emergence of new evidence practices, such as labelling, in a world which is ever more perceived as purely economically driven. The concept of the consumer replaces the concept of the citizen with the significant consequence that individual free choice is assumed and expected. I further argue, that thereby responsibilities are shifted from governmental and scientific authorities providing information to individuals, expected to inform themselves. The essay shows how, in anticipation of these changes, the industry´s strategy of substituting and labelling (and thereby providing information themselves as well as borrowing trust from other, established labels) is likely to be highly effective. I will conclude with a brief outlook, showing what these changes mean for our society and that in the end it is all of us who are suffering from it, one way or another.

A short history of BPA
Allow me to give a bit of background information on the chemical BPA itself, its history, the debate about its safety, and its current regulatory status. While I will keep this as brief as possible, I believe it is absolutely vital in order to be able to follow the story in the next section.

Bisphenol A has a longer history than one might think. After it was first synthesized in 1891, the molecule received some attention about 40 years later, when British biochemist Charles Dodds discovered the estrogenic activity of BPA in his search for a “therapeutic treatment of numerous female “problems” related to menstruation” (Vogel, 2009, p. 559). While he ended up using diethylstilbestrol (DES) (a drug that too caused much harm and was later banned) BPA found its renaissance in the 1950s, when the first epoxy resins and polycarbonates were made with it as one of the two starting chemicals. Its history as synthetic estrogen seemed forgotten when the pure practicality of these materials was discovered and subsequently unfolded in a number of applications. The most relevant of these applications for our story (for there are many others, where human exposure is much less likely) are the inner coatings of aluminium food cans, where epoxy resins are used, and various food containers and toys that are made out of polycarbonates (Vandenberg et al., 2007; Von Goetz, Wormuth, Scheringer, & Hungerbühler, 2010). BPA is furthermore a part of the coating of thermal paper, commonly used for receipts (Vandenberg et al., 2007).

So why is BPA bad? In order for any chemical to do harm it takes two things – exposure and actual harmfulness of the chemical (at the level of exposure). Both of these aspects were obscured in different ways as the debate about BPA safety unfolded. The key term in the story of how this was possible is monotonic dose-response relationship. This is the common, simple model in toxicology, describing that the adverse effects of a harmful chemical get worse as the dose increases. Also included in this model are various safety levels; thresholds, where a lower concentration can be considered safe. And if no such monotonic dose-response relationship can be observed, it is also commonly assumed that it is safe at low levels. However, endocrine disruptors do not follow this model, and can indeed be harmful at very low levels of exposure (Welshons, Nagel, & vom Saal, 2006). Such low levels have first been measured in 1993, when BPA leaking from laboratory equipment tainted research of endocrinologists investigating yeast. The discovery, that what they initially thought were high levels of estrogen were actually high levels of BPA, brought attention to the matter and sparked a lot of subsequent research (Vogel, 2009). And yet to this day the debate is not settled. There are still arguments saying animal studies are not sufficient to warrant regulation, that the levels are insignificant compared to our natural hormone levels (and fluctuations thereof), and that BPA is rapidly metabolized anyway, so that in fact in cannot even do harm (Vandenberg et al., 2007).

The body of scientific literature around the safety of BPA is astounding. With this much research having been done, one might (naively) assume that regulation followed swiftly. However, as this is a high production volume chemical, the economic stakes are significant, and the regulatory process accordingly slow. Most often, calls for more research are being made – new studies are being funded, literature reviews commissioned, risks assessed, and of course task forces are being created (Vandenberg et al., 2009). While policy makers wait here for science to present them with an easy solution for the bigger problem, smaller, more limited regulations have been made. BPA has been banned for the use in food containers and materials that are likely to come in contact with young children, like baby bottles, in several places. Outside of this, Canada is currently the only country with broader, non-food related restrictions on BPA (Flint, Markle, Thompson, & Wallace, 2012). Other regions, like the US and the EU are still debating and have thus far neither come up with a bigger regulatory framework for endocrine disrupting chemicals in general, nor BPA specifically.

What makes the BPA case so different?
Of the numerous cases of chemical exposure that are being discussed, and especially of those that are discussed in MCTS and Environmental History literature, the case of BPA seems to stand out. And it does so with a big difference – one that changes the whole story – that it does not start with the discovery of different symptoms in a population, or any other specific signs of exposure. Altman and coauthors (2008) write about “exposure experience” in the context of indoor pollution. They use this concept to describe how the people affected by it describe and experience their exposure to different chemicals, including symptoms, circumstances and more. Take Multiple Chemical Sensitivity for example, a condition where people are hypersensitive to even the smallest amounts of generally harmless chemicals. It is a fascinating case, because there seems to be only the exposure experience, and often times no scientific explanation (Dehart, 1998). However, it is the complete opposite in the case of BPA exposure – there simply is no exposure experience.

With the concept of exposure experience not working in this case, we can also observe another important concept not being able to capture the BPA story, namely that of popular epidemiology. Phil Brown (1993) describes this concept well in the case of toxic waste in Woburn, Massachusetts. It was local citizens who identified and described a local leukemia cluster and uncovered the whole story subsequently in the search for causes. Popular epidemiology is getting more attention these days, and high hopes seem to rest upon it. But it is also important to recognize where such an important concept fails, in order to not overlook those cases that it just cannot explain. Because not only is there no exposure experience for BPA. Due to its ubiquitous nature there is also no locality, no spatial dimension. While some scientists speculate that a multitude of growing diseases concerning modern society, such as cancer, diabetes and infertility, are caused by endocrine disrupting chemicals such as BPA, it is almost impossible to show direct links (WHO & UNEP, 2012). It is almost funny – precisely because it is everywhere, it is also almost completely invisible. Add to that the fact that the observable effects are usually only visible on a population level (e.g. skewed ration of females/males in newborn babies) and always show up with a significant latency (e.g. cancer or infertility).

All of these factors – latency, ubiquity, and lack of exposure experience – render BPA exposure almost invisible. The attention it is getting now started with a few concerned scientists, followed by significant attention from public media later. And yet still, a regime of imperceptibility was created and is sustained by the producing industry, industry-sponsored science, and also regulatory agencies. Michelle Murphy (2006) introduced this concept of imperceptibility as something which can “render claims of chemical exposures uncertain”, either through inevitable limitation in experiment design and equipment, but also through purposeful narratives by industry sponsored science (Murphy, 2006, p. 10). The idea is not to deny the existence, but instead to raise enough uncertainty about the science behind it. That way it is not perceived as a problem and acting upon it and introducing new regulations is difficult at best, impossible at worst. In the case of BPA, one could argue that it is commonly perceived as a problem, and that therefore this strategy was not successful. However, a closer look reveals something different. BPA is now widely being substituted by other bisphenols, likely to be just as harmful (Karrer et al., 2018; Rosenmai et al., 2014). The regime of imperceptibility that was created was and is highly effective in this regard. It prevented broader regulations which might affect the whole class of chemicals instead of just BPA, and the attention that BPA is getting is making the potential risks of its substitutes nearly invisible (Aho, 2017). So, let´s take a closer look at how this is done exactly.

So far, I tried to set the stage and introduced our main actor and their backstory, and also gave some context of the world this play is set in. With this in mind, I want to talk about the final act now, a story which could be considered an epilogue in the by now quite often told story of BPA. Because this story is far from over. Not only is there still no consensus on the effects of BPA (or endocrine disruptors in general, for that matter), and not only is its regulation half-hearted at best. It is also being substituted now. And while this may sound like a great victory, as if public pressure has indeed for once lead to a great change, it couldn´t be farther from it. Because BPA is being replaced with different bisphenols, such as BPF, BPS, and BPAF. And while not many studies on the toxicology of these chemicals exist, the initial results show that they are not better than BPA and might even be worse (Karrer et al., 2018; Rosenmai et al., 2014). Yet, the focus on BPA masks the potential danger that come from these substitute chemicals. And what is more, it allows the labelling of products as “BPA-free”, suggesting safety when there really is just uncertainty at best, and harm at worst. Yet these labels work as a form of evidence, they readily inform consumers on what they are looking at and establish trust in the harmlessness of a product.

Is labelling the new regulation?
Having established labels for products is incredibly common nowadays, especially in Germany. The most prominent example would be “Stiftung Warentest”, which is an independent institution that gives grades for products, then to be displayed in the form of labels on the products themselves. Another example that comes to mind is the “AMA Gütesiegel”, which labels meat that comes from Austria and proves that the animals have been kept and killed according to Austrian laws. Such labels enjoy a trust that has been established over years. And they speak to the – perhaps stressed, perhaps lazy – consumer, who then does not need to inform themselves, but rather is being informed by a clear sign. Labelling practices are intensively being debated in the context of genetically modified organisms (GMOs) in Europe. With concerns about their safety and a great deal of uncertainty, as well as the precautionary principle that is established in the European Union, the labelling of products containing GMOs is presented as the prime solution. And while most of the debate spins around the details of how to label such products, there are some general arguments for and against labelling per se. Most of these arguments – on both sides – are of economic nature, but there is one that is particularly interesting: ”labelling of novel foods does not make sense as long as the majority of consumers does not know how to interpret the meaning of the labels” (Todt & Luján, 1997, p. 322).

I would argue that this is the same in the case of BPA. A “BPA-free” label cannot be correctly interpreted without knowledge about what is used instead. The general idea is that while consumers could take an extra step and look up more information, or request more information, most of them would not do that. This is because the label is acting as evidence that their biggest concern – BPA – is not to worry about. Providing this information upfront creates a trust in the harmlessness of the product. But what is more, a study has shown that even when people are informed about the uncertainty, ambiguity and potential harmfulness of substitutes, they still prefer to buy the product labelled “BPA-free” (Scherer, Maynard, Dolinoy, Fagerlin, & Zikmund-Fisher, 2014). Another argument against labelling, that has previously not been raised, is that there is risk for progress to just stop there.

Consumers, the new citizens?
Labelling practices are only one part of a larger trend that I am seeing in issues of exposure to toxicants and uncertainty. The people who are exposed are constantly being framed as consumers, almost never as citizens. But what does that mean, and why could it be dangerous? The confluence of the concepts of consumers and citizens can be observed in a number of cases over the last years. Alastair Iles (2004) described it in the context of sustainable seafood, and Robert Doubleday (2004) in the context of a Unilever campaign. Both saw it positively that consumers are given citizen-like powers over producers. Simply by their decisions of what to buy they can create a pressure on companies, possibly leading to changes. However, I want to argue that this positive view has a significant flaw and is especially not applicable in the case of chemical exposure and regulation thereof.

Welcoming that consumers are given citizen-like qualities seems somewhat cynical. It masks the fact that in our democracy it is the citizen who should have the power to make change happen. While it can easily be argued that there is no harm in having both the citizen and the consumer in a position to exert influence, I do not think it is that easy. For the more power the consumer has, the less power the citizen has – it is not an addition, it is a trade-off. We as a society accept that working towards change in the role of a consumer is in times more effective than doing so as a citizen, but by accepting that role we enable and enforce a more and more economically driven world. The case of bisphenols clearly shows the shortcomings of this. Labelling practices satisfies people´s desire for change. The illusion of the free will of the consumer – which in reality is constrained by a number of personal social and economic factors – successfully silences the calls for regulatory agencies and governments to take action.

In this essay I have recited the story of the safety of BPA and offered a glimpse at what could be an epilogue to this story. One which is about uncertainty, substitution, labelling, and consumerism. In it, we realized that identifying a substance as harmful is really only the first step in a long journey. Not only are the economic stakes incredibly high in the case of high production volume chemicals such as BPA, but there is also uncertainty of how to replace it. Substituting harmful chemicals is never easy, and it is almost never clear whether the substitutes are better or worse – at first they are just new (V. J. Brown, 2012). And who should have the responsibility to come up with alternatives, and who should have to prove their safety? None of these questions can be easily answered, and yet I think it is of utmost importance that they are being discussed. For we see what happens when we only go half of the way and then stop – the issue is perceived as being resolved. Something that once got a great deal of attention is being covered once again under a veil of invisibility and imperceptibility. Consumerism is cleverly employed to aid this cause. If we would peel off the “BPA-free” label and take a closer look behind it, we could see that really nothing has changed. I hope that what is now an epilogue will at some point be the beginning of a new story. A story of how we change our approach when it comes to toxic chemicals. How we bid farewell to this kind of consumerism and instead employ proper regulation, finally enacting the precautionary principle properly. Maybe it would not even be that difficult.

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