Presentation by Andre Menache on behalf of the petitioners

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laws requiring animal testing are now 70 years out of date compared to today’s scientific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