September 7, 2018

Dr. Kurt Straif
Section Head
Monographs Group
International Agency for Research on Cancer (IARC)
150 Cours Albert Thomas
69372 Lyon CEDEX 08
France

Dr. Straif:

On behalf of citizens of more than one hundred countries around the globe, International Governmental Organization (IGO) Watch urges IARC to make sensible changes to the Monographs Preamble. Problems in the wording of the Preamble have led to faulty evaluation procedures by IARC, resulting in unnecessary product restrictions and undue concerns by governments and consumer groups.

Substances such as aloe vera, d-limonene, and aniline are all considered at least “possibly carcinogenic” by the organization, despite insufficient evidence and a presumption of danger. Additionally, IARC refused to drop coffee’s “possible carcinogen” status for more than two decades, even after the weight of evidence suggested that coffee had important protective effects against heart disease and various cancers.

Even after retracting the “possible carcinogen” status, IARC refused to reclassify to “unlikely to cause cancer in humans.” Despite sharing ample empirical evidence that there are inverse relationships between coffee and different types of cancers, IARC concluded simply that coffee is “unclassifiable as to its carcinogenicity in humans.”

Undergirding these harmful decisions is vague determination criteria found in the Preamble, which IGO Watch describes in greater detail in the enclosed public comments form. Studies deemed to be “inadequate” are not considered by IARC, despite little clarification on what constitutes an adequate or high-quality study. While IARC does list some legitimate criteria for included studies, the agency fails to explain their thresholds for statistical significance and consideration of variable inclusion.

These shortcomings are concerning, given the real-world consequences of IARC classifications. IARC classifications lie at the center of some American states’ consumer protection laws, with rulings triggering regulatory actions by governments and growing costs for taxpayers. In California, for instance, IARC designations trigger warning labels, which add additional costs onto products that are often passed onto consumers. For farm production, warning labels on the end product often force farmers to inefficiently keep different produce far apart for liability purposes.

IARC should use these comments and other submissions to change course and consider all evidence from all perspectives when evaluating different substances.

Regards,

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David Williams
President