Our science advisor, Dr Andre Menache was given the opportunity to present a petition to the European Parliament.
The reason for this petition is that the current REACH regulation is failing to protect the health of EU citizens for two main reasons: the continued reliance on animal tests; and not enough collection of human data.
Animal testing is not evidence-based, nor predictive for humans. We listened earlier to
information on bisphenol A (BPA). The manufacturers of BPA succeeded in bringing this
product to market by choosing the species of animal that suits them best. In the case of BPA,
the Sprague-Dawley rat is several thousand times more resistant to the hormonal effects of
this endocrine disruptor than the CF1 mouse. The industry has obviously chosen the rat rather
than the mouse to get BPA to be accepted by regulatory authorities. A rat cannot predict what
will happen in a mouse and, nor what will happen in a human.
BPA is also capable of causing a biological effect on our cells at very low doses (a few parts
per trillion). We are still relying on regulatory requirements adopted in 1946 or 1947. These
laws requiring animal testing are now 70 years out of date compared to today’s scientific
knowledge. It is time to update the laws.
There is also a serious lack of human data collection. Since 2003 we have known of the
presence of 300 industrial chemicals in the bodies of the newborn. At present, the REACH list
of substances of very high concern (SVHC) amounts to 174. It would have been more logical
to launch the list of SVHC at the beginning of the REACH program (in June 2007) using the
300 substances already present in the body of the newborn. We should all be shocked that
cancer is now the leading cause of death in children under 14 years in many countries in
The lack of epidemiological data collection of people exposed to chemicals, particularly of
millions of workers employed in various industries, represents a huge waste of a precious
resource. Some would consider that this is due to bureaucratic incompetence. Others would
call it criminal negligence. I rather agree with the latter, given the importance attributed to
epidemiology already in the 1950s and 1960s, which demonstrated the link between smoking
and lung cancer in people. Yet those responsible nowadays still focus mainly on animal
testing to the detriment of widely available human data collection. The European Commission
has finally woken up to launch a bio-monitoring project as part of the Horizon 2020 program,
announced in December 2016.
The REACH program in its current format does not work. It must be adapted to the science of
the 21st century. We have several powerful technologies such as molecular epidemiology,
human PBPK modeling, toxicogenomics, Adverse Outcome Pathway (PDO), and a range of
other methods focusing solely on humans. Thank you for your attention