# Who built the SSD — corporate or EPA? (affiliations from the primary papers)

*Question posed 2026-06-11: are the people behind the Species Sensitivity Distribution corporate or government?
Answered here from the **title-page affiliations of the actual papers** now held in `papers/` (not from memory).
Companion to [`SSD_GENEALOGY.md`](SSD_GENEALOGY.md) and [`SSD_DE-MINIMIS_LINEAGE.md`](SSD_DE-MINIMIS_LINEAGE.md).*

## Short answer

**The SSD's origins are government and academic — specifically the U.S. federal water agency that became the
EPA, and the Dutch public-health/environment institutes. Not corporate.** That is the opposite of Frawley's de
minimis, which an industry trade campaign pushed onto a reluctant FDA. **But industry moved in as the method
matured into a regulatory tool — and the human-side relative of the SSD, the TTC, was corporate from the
root.**

## The evidence (verbatim from the papers' title pages)

### The origins — government / academic
| Paper | Affiliation (as printed) | Type |
|---|---|---|
| **Mount & Stephan 1967** (application factor) | "Fish Toxicology Activities, **Federal Water Pollution Control Administration, U.S. Department of the Interior**, Cincinnati" — the agency folded into the **EPA** in 1970 | **US gov't → EPA** |
| **Kooijman 1987** (statistical SSD) | "**TNO**… Delft, The Netherlands"; funded by the "**Ministry of Housing, Physical Planning and Environment**" | Dutch public research / gov't |
| **Slooff, Canton & Hermens 1983** (foundational data) | "**National Institute for Water Supply**"; "**National Institute of Public Health**, Bilthoven" (→ **RIVM**); "University of Utrecht" | Dutch gov't + academic |
| **Van Straalen & Denneman 1989** (95% rule) | "Department of Ecology and Ecotoxicology, **Free University** [VU Amsterdam]"; to implement the "**Soil Protection Act of 1986**… Dutch Ministry of Housing, Physical Planning, and Environment" | academic + Dutch gov't |
| **Wagner & Løkke 1991** | "Technical University of Denmark"; "**Ministry of the Environment, National Environmental Research Institute**" | academic + Danish gov't |
| **Aldenberg & Slob 1993** (HC5 CIs) | "**National Institute of Public Health and Environmental Protection (RIVM)**" | Dutch gov't |

The foundation is unambiguous: a U.S. federal pollution agency (the direct ancestor of the EPA) and the Dutch
RIVM / VU Amsterdam / Danish NERI. The statisticians who built the HC5 were government scientists.

### Industry arrives as the method becomes regulation
| Paper | Affiliation | Note |
|---|---|---|
| **Aldenberg & Jaworska 2000** (HC5 uncertainty) | RIVM **+ Procter & Gamble** (Eurocor, Belgium) | a foundational statistics paper now co-authored with a consumer-goods corporation |
| **ECETOC WR28** (assessment factor of 2) | **European Centre for Ecotoxicology and Toxicology of Chemicals** — the chemical industry's research body | sets the leniency dial (AF = 2 vs 5) |
| **Belanger et al. 2017** (SETAC "future needs" consensus) | **Procter & Gamble** (lead) · U.S. EPA · Durham Univ. · **ECETOC** · **Unilever** | the consensus on SSD's future is **industry-plurality**: two consumer-goods firms + the chemical-industry body, alongside one EPA lab and one university |

So by the 2000s the people steering the *application* of SSDs include the EPA and academia **and** Procter &
Gamble, Unilever, and ECETOC — the tripartite SETAC world, with industry the largest single bloc on the key
consensus paper.

### The critics are academic
Forbes & Forbes (1993, Danish NERI), Hickey & Craig (2012, Durham), Fox (2010/2021, Univ. Melbourne /
Environmetrics Australia) — the people writing the *critiques* of SSD's statistics are universities and
government research institutes, not industry.

### The human-side relative (TTC) is corporate from the root
The cross-branch our genealogy ties to the SSD is, by affiliation, far more corporate:
| Paper | Affiliation | Type |
|---|---|---|
| **Cramer, Ford & Hall 1978** (the decision tree / Cramer classes) | "**McCormick and Co., Inc.**" (the spice company) + "**Research Institute for Fragrance Materials, Inc.**" | **food / fragrance industry** |
| **Munro et al. 1996** (the TTC) | "**CanTox Inc.**" (toxicology consultancy) + "**Research Institute for Fragrance Materials, Inc.**" | **industry consultancy + fragrance industry** |
| **Kroes et al. 2004** (structure-based TTC) | Utrecht / Southampton / Fraunhofer / RIVM / Swiss FOPH — convened under **ILSI Europe** (industry-funded) | academic/gov't under an **industry umbrella** |

## What this means for the series

The contrast sharpens the thesis. The same threshold-of-acceptable-harm logic appears on two tracks with
opposite sponsors:

- **Human / de minimis:** **industry-born and industry-pushed** — Frawley (Hercules), the SPI/MCA campaign,
  Keller & Heckman; and the TTC that descends from it was written at McCormick, RIFM, CanTox, and under ILSI.
- **Ecological / SSD:** **government-and-academic-born** — the U.S. federal water agency (→ EPA), RIVM, VU
  Amsterdam, Danish NERI — then **progressively industry-shaped** (P&G and ECETOC co-authoring the statistics
  and the consensus; ECETOC tuning the assessment factor down).

The lesson is the one the genealogy already drew, now backed by names on title pages: the de minimis idea does
not need a corporate sponsor to spread — regulators reach for it themselves — but **once it is the regulatory
machinery, industry takes a seat at the table and works the one lever that remains, the size of the safety
factor.** On the ecological side that lever is the assessment factor on the HC5; on the human side it was
Frawley's complaint that the factor of 100 was "overly conservative." Different sponsors, same lever.

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## Open / next
- **[open]** Confirm Posthuma 2019's full author affiliations (page-1 extraction returned blank — it is RIVM +
  US EPA per the metadata; verify from the PDF).
- **[open]** The **funding/acknowledgements** lines (not just author affiliations) — e.g., Kooijman's Dutch
  Ministry funding, and any industry funding of the "consensus" papers — would sharpen the sponsorship picture.
- **[open]** Trace **Scott Belanger (P&G)** and **ECETOC**'s role across the SSD-guidance literature: are the
  same industry actors repeatedly on the methodology-setting bodies (SETAC Pellston, ECETOC task forces, the EU
  TGD revisions)? A recurring-names map would be the ecological counterpart to our SPI/Keller-&-Heckman
  campaign reconstruction.
- **[wishlist]** The two most important missing critiques (Forbes & Calow 2002; Newman et al. 2000) and the
  test-species-selection paper (Maltby et al. 2005) — see `papers/_WISHLIST.md`.