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For a strong REACH
For many years, a large number of scientists have been trying to alert the authorities and public opinion to the worrying health trend, a trend stemming from the increasing diversity of chemical substances with which we may be in contact. Whether through what we eat (pesticide and fertiliser residues), in the air around us (automobile or industrial pollution) or in the air in our homes (molecules flaking off the many objects that we bring into our homes or work-places), we are in contact with hundreds (at least!) of chemical substances, and inquiries carried out by Greenpeace or the WWF show that many of these substances are to be found in our blood: on average, some forty substances are to be found in the blood samples donated by Europeans. Some forty among those which were sought, which means that our blood certainly contains many more.
The initiative launched by the European Commission in 2001, which proposed to evaluate the toxicity of all these substances, was therefore very welcome. A White Paper gave rise to the REACH (Regulation, Evaluation and Authorisation of CHemicals) project, future European legislation in this field.
Unfortunately, the REACH project was very soon watered down: while it was to have concerned the 100,000 products marketed before 1981 which were not the subject of evaluations that have been compulsory since that date, it was, later, to have applied to the 30,000 of those products marketed in quantities of more than a ton per year, whereas the regulations drawn up in 1981 had required the evaluation of products marketed in quantities of more than 10 kg. Finally, only 12,000 products would be tested.
Numerous associations demand that it be made compulsory for manufacturers to communicate information on the toxicity of their products, that dangerous products be replaced by less toxic equivalents and that the most dangerous, persistent and bioaccumulable products in any event be banned.
Antidote Europe approves all of these requirements but we think one fundamental one is missing: that reliable methods be used for evaluating the toxicity of products. In effect, what would be the use of a law that banned a dangerous product if the maufacturer may choose the methods to be used to evaluate this danger and if he takes as a reference methods that are only slightly or not at all reliable? Evaluation is thus the central point of REACH, the point that conditions authorisation or banning mesures.
REACH will therefore be strong solely if the methods accepted for the evaluation of toxicity are reliable. But nowadays these methods are nearly always based on animal experiments. We show that no animal species is the biological model of man. Consequently, to continue to accept toxicology based on animal experiments opens the way to erroneous evaluations and removes all meaning from REACH.
Antidote Europe therefore informed the authorities of this problem and proposed a reliable methoed: the Scientific Toxicology Programme, drawn up by researchers from the French National Center for Scientific Research with very many years' experience as research directors and who organised to European Workshops on Molecular and Cellular Toxicology (in Sophia Antipolis in 1996 and in Paris in 1999). This Programme is a specific approach using toxicogenomics, a method that emerged early in the nineties and is widely used in the United States and Japan.
In collaboration with its European partners, Antidote Europe managed to have an amendment mentioning toxicogenomics approved by the European Parliament during the first reading of REACH (17th November 2005), then reintroduced with a view to the second reading and approved by the Environment Committee (10th October 2006). We deplore the fact that the final version of REACH (18th December 2006) omitted this amendment, although, in its preamble, it proposed to encourage toxicogenomics. While this is a step in the right direction, it is most inadequate. Indeed, while the European authorities say they wish to "develop" toxicogenomics, whereas in fact the method has already been perfected, animal tests, which give little prediction of the toxic effects for humans, will continue...