This is an important article:

Mr. Dennis T. Avery authored it, and it has been published in several publications.

We humans have been testing the theory that dose makes the poison for thousands of years. One can trust that hundreds of generations of people checking, and people trying to prove otherwise, would have succeeded. Accordingly, look for the data. Look for the results that show that there is more to harmful chemicals than just the dose.

You will find that it is not there.

Accordingly, one must conclude that either dose does make the poison, and at some level toxins become innocuous, or there is a huge conspiracy that hides all the information so that everyone will die.

Seeing that we ain’t dead yet, I’ll accept as fact that there is a safe level of lead in my diet.

I’m all for making easy choices in favor of eliminating possible problems. The easiest one is turning the power off of unused devices, like the lights.

That is, if I conserve the power, rather than leaving the light on for the convenience of not having to flip the switch nine hours later when I get home from work, then I will reduce an inefficiency, and I will be doing a small part in reserving the future resources needed to generate that power to provide the much-needed convenience of having light in my house to see by.

The fact is, it is much too easy to turn the light off, save the cost of the power, and turn the light on to justify leaving it on in the interim.

Bisphenol-A is a very useful and efficient plasticizer. While it may seem safe to avoid its use, one must think of the alternatives. Avoiding plasticizers, particularly BPA, has costs. Not using BPA will make plastics more expensive, and it will make the production processes more inefficient, and possibly more unhealthy in some other way. All in all, the costs and harm to society comes out high for banning of BPA, and such a decision is bad compared to the relatively proven case that BPA is not dangerous in any way at the levels encountered in our daily lives, even including our infants and their plastic baby bottles.

Unfortunately, Mr. Avery provided no references. I’m not finding anything recent.

I found this:

Quantitative Assessments of Genotoxicity Data

NCTR scientists are members of the Quantitative Analysis Workgroup of the HESI/ILSI Genetic Toxicology Technical Committee. The committee has developed best practices to analyze genetic toxicology data in a quantitative manner. Several dose-response modeling approaches using genotoxicity databases compiled by the workgroup were the basis for analysis. The workgroup found that a Benchmark Dose (BMD), which produces a 10% increase over the background response (BMD10), has the greatest utility as a Point of Departure (PoD) for establishing risk calculations. These recommendations were published in Environmental and Molecular Mutagenesis.

For additional information, please contact Robert H. Heflich, Ph.D., Division of Genetic and Molecular Toxicology, FDA/NCTR.

I assume that is not what he was referring to. It doesn’t seem to fit, but perhaps he meant this:

February 21
Toxicity Evaluation of Orally Administered BPA

NCTR scientists have published companion papers in Toxicological Sciences presenting data from:

The 90-day, Churchwell et al study provides new data for use to further refine physiologically based pharmacokinetic models used to extrapolate exposures in rodent tests to real world human exposures. The study is a component of the concurrently published subchronic range-finding study Delclos et al.

The second, Delclos et al study was used to determine doses and toxicological direction of the ongoing long-term (two-year) toxicological study currently under way at the FDA. The Delclos et al study results have been publicly available for some time. The results from the FDA’s long-term (two-year) study, which will include data generated by NIEHS-funded academic investigators, are expected to be release in early 2016.

For additional information, please contact Barry Delclos, Ph.D., or Daniel Doerge, Ph.D., Division of Biochemical Toxicology, FDA/NCTR.

Perhaps one of the references here:

March 28
Society for Toxicology Annual Meeting

On March 23-27, 2014, NCTR scientists gave platform presentations in continuing education courses and workshops, as well as poster presentations at the 53rd Annual Meeting and ToxExpo™ of the Society for Toxicology (SOT) in Phoenix, AZ. The presentations covered a wide range of topics including:

  • miRNA biomarkers of toxicity
  • imaging biomarkers
  • pediatric anesthetics
  • drug-induced liver injury
  • nanomaterials
  • results of studies with compounds of high FDA interest such as BPA, triclosan, furan, and melamine/cyanuric acid

Additionally, Dr. Annie Lumen received the “Best Postdoctoral Publication Award” for her paper on modeling effects of iodide and perchlorate exposure during human pregnancy (Toxicological Sciencesdisclaimer icon, 2013, 133: 320-341). The SOT is the premier professional society for toxicologists from academia, industry, and government.

Society for Toxicology Awards

An NCTR research article titled “Ketamine-Induced Neuronal Damage and Altered N-Methyl-D-Aspartate Receptor Function in Rat Primary Forebrain Culture” was one of 2013’s top ten most cited articles inToxicological Sciences. The in vitro study showed that ketamine, a common pediatric anesthetic, induces neuronal cell death through upregulation of the NMDA receptor; and L-carnitine is neuroprotective against ketamine’s adverse effects (Toxicological Sciencesdisclaimer icon, 2013, 131: 548-557). 

For additional information, contact Merle Paule, Ph.D., Director, Division of Neurotoxicology, FDA/NCTR.

Another NCTR research paper titled “Prediction and Ealuation of Route Dependent Dosimetry of BPA in Rats at Different Life Stages Using a Physiologically Based Pharmacokinetic Model” (Toxicol Appl Pharmacol, 270:45) was selected by a committee of the Risk Assessment Specialty Section as one of the Best Papers Published in 2013 Demonstrating Application of Risk Assessment.

A Postdoctoral Fellow in the Division of Biochemical Toxicology, received the SOT Carcinogenesis Specialty Section Postdoctoral Fellowship Award for the abstract entitled “Epigenetic alterations in the livers of Fisher 344 rats exposed to furan. The main focus of this study was to investigate the role of epigenetic alterations in the mechanisms of furan hepatotoxicity and carcinogenicity. The results of the study showed that exposure to furan causes dose-and time-dependent epigenetic aberrations that include alterations of DNA methylation status (global and gene-specific methylation), changes in the expression of chromatin modifying genes, and alterations in histone lysine methylation and acetylation patterns in the livers of male Fisher 344 rats. These findings significantly contribute to our understanding of the mechanisms of furan carcinogenesis and could be helpful for the future development of prevention strategies for early hepatic adverse effects associated with the furan exposure. This award recognizes the best abstract related to the field of carcinogenesis submitted by postdoctoral fellows.

The study of interest wasn’t linked. I found it here,, and they want $36 before I can read this study that our tax dollars paid for in the first place. Oh well. You can read the abstract there. It basically says they’ve finally proven out a mathematical model of how it works in rats. They note it is different in baby rats versus adult rats and monkeys. The abstract seems to admit there are still some assumptions being made. Hopefully they are remembering not to fool themselves.

FDA site on BPA here:

In closing, the fact is that after we get clean enough, safe enough, and low enough concentration, there is more harm done making it more so than just resting in the accomplishment of having done enough. Most of the time, good enough really is as good as it can get.