Critical Analysis of the Consensus Key Characteristics Approach

LD Burgoon, CJ Borgert
The Consensus Key Characteristics Approach (CKCA) applied to carcinogens or endocrine disruptors is either: 1. Unscientific: as it cannot be falsified (all endogenous and biologically relevant chemicals are carcinogens and endocrine disruptors). OR 2. False: CKCA rewards confirmation bias. Evidence of meeting 1 single criterion is sufficient to be labeled a Carcinogen or Endocrine Disruptor. Proponents specifically state the following question should be answered: “Does exposure to the agent induce end points associated with one or more specific key characteristic properties of carcinogens?

This analysis shows that application of the CKCA finds evidence that water, calcium, sodium, glutathione, adenosine triphosphate (ATP) and linoleic acid – which are all natural substances essential for life – are all carcinogens and EDCs, yet, those substances are neither.  An approach that cannot distinguish actual carcinogens and EDCs from the natural chemicals essential for life is not useful or reliable for hazard identification or for evaluating a chemical’s mode of action.