Question: What is REACH?

Jan Creamer: REACH stands for Registration, Evaluation, Authorisation of Chemicals. It is a new regulation proposed by the European Commission for the control of chemicals in the European market.

There are about 100,000 chemicals on the market in the EU for which the authorities do not have full safety testing and risk assessment data. About 30,000 of those chemicals are produced in high production volumes and these are the ones that the European commission wants to target.

These chemicals are of concern because some of them are toxic, bioaccumulative, and persistent; some of them are toxic to the reproductive system. Some, called endocrine disruptors, disrupt the hormone system.

Many of these chemicals are in the products that we use on a daily basis; household cleansers, detergents, air fresheners, household furnishings, cosmetics, toiletries, products used at work, in the garden, for the car, and so forth.

Question: Why is Animal Defenders concerned about REACH?

Jan Creamer: We fully support removing dangerous chemicals from the market, but the REACH proposal contains animal testing protocols in the testing strategy.

We believe that it is wrong to use animals for this kind of testing. If you think about the reality of toxicity in the environment; on a daily basis we are exposed to very small amounts of a mixture of different chemicals that we touch or breathe in when we are using our computers, or watching our television.

But what happens in animal testing is that vast quantities of a substance are given to animals over a relatively short period of time. These animal tests in REACH have been criticised by ecotoxicity experts and by other scientists who are saying that they are simply the wrong model for these kinds of tests.

Question: But are there effective alternatives that would ensure public and environmental safety?

Jan Creamer: There certainly are, for example fast-screening computer and in vitro (cell culture) techniques; databases of chemical substances, and others, some of which are already employed by authorities elsewhere.

These techniques have been looked at by the royal commission on environmental pollution, in their report on chemicals in the environment. The royal commission has said that the animal tests in REACH should be replaced by more modern computer technology and non animal alternatives, such as tissue culture.

The problem that we have with the animal tests in REACH are that they are not going to produce the answer that is required so they are not going to achieve the aims of REACH and in addition to this they are going to take too long. The royal commission on environmental pollution pointed out that the animal tests specified in REACH are cumbersome and unsound and they have recommended that the REACH proposals must exploit the new technology that is now available to replace animals in research.

Question: You are currently urging MPs and MEPs to "keep animals out of REACH"?

Jan Creamer: We have devised an alternative testing strategy. We have looked the kind of information that is needed about the chemicals at the centre of the REACH proposals and devised a strategy of non- animal research methods.

We have instead suggested in vitro and computer methods which can produce results in a few weeks rather than months. This means that we can achieve the aims of REACH – protection of humans and the environment - and we can remove dangerous chemicals from the environment - but we don’t have to kill millions of animals in the process.

Question: Isn't there a risk that your proposals will simply delay REACH, and therefore delay removing dangerous chemicals from the environment?

Jan Creamer: No, in fact the proposals we have put forward would speed up the answers that are required about these chemicals in REACH. The animal tests currently described in the REACH document will take years to complete, leaving dangerous chemicals on the market while animal tests are being carried out; whereas the fast computer pre-screening strategy we have suggested will identify the most dangerous chemicals immediately, so that they can be removed from the market.

This is followed by other computational and in vitro methods, to produce risk assessment data on other chemicals. It is much faster and cheaper than animal tests. REACH is already underway and being discussed now. The UK government hopes to bring REACH to a conclusion in Europe by the end of 2005.

Question: Environmentalists and consumer groups have pressed hard for REACH, are your proposals at odds with their views?

Jan Creamer: We are not at odds with their views, it is simply a different perspective.

We do agree with that these dangerous chemicals need to be removed from the environment, they harm animals and people; but we have brought in our expertise to say, yes we need safety and we need to protect the environment, but this isn’t the way to do it, in fact this is a prime example where non-animal test methods are better – we should employ alternatives now. Many environmentalists agree with this strategy.

Question: What can MPs and MEPs do to change the current REACH proposals?

Jan Creamer: They can certainly lobby the UK government, and the European Commission.

I think that we have to get MPs and MEPs involved in this because it is something that effects all of us everyday of our lives and they need to lobby for a better method of testing other than use of animals.

The conclusions and recommendations of the royal commission on environmental pollution are very important.

The royal commission has said that the current testing protocols and risk assessment strategy are cumbersome and unsound and that they won’t achieve the aims of REACH, which is to protect humans and the environment. It is really important for everyone to get these testing protocols changed to the modern computer technology and in-vitro techniques that we have suggested.

Question: You are very concerned about duplication of tests and failure to share data, but aren't there some safeguards within REACH?

Jan Creamer: No, currently within REACH companies can avoid sharing data. So one of the points that we have made about REACH is that it must be mandatory that companies should share data that they hold on chemicals and that there should be an incentive for companies to encourage them to share data – a carrot and stick approach is needed.

We do also support the proposal put forward by the UK and Hungarian governments for ‘one substance one registration’ - that should avoid a lot of duplication of animal tests.

Question: In your proposals you state that the validation and implementation of modern non-animal testing methods must be accelerated. Where is the money going to come from to do this?

Jan Creamer: Some of the money can come from the money that has been allocated to REACH.

The UK government has apparently estimated the cost of REACH to the UK at something like £1.2bn and that is considered to be a conservative estimate.

REACH is set to cost billions of euros and what we are saying is that some of this money that is allocated to animal testing, which is expensive, should be reallocated to the European Centre for the Validation of Alternative Methods (ECVAM) in order to speed up validation of in vitro techniques.

Question: What do you consider are the key steps for getting REACH right?

Jan Creamer: I think first of all setting up a comprehensive database of all known chemicals in products in the EU market, with data contributed by industry, from government departments, from environmental and monitoring agencies, academia and other stakeholders.

At the same time, a fast throughput computer pre-screening should take place, to highlight chemicals of concern. The most toxic, persistent, bioaccumulative and those disrupting the hormone system should be removed from the market immediately and replace with greener alternatives.

Third, a system of compulsory data sharing for companies who wish to register substances. ‘One substance, one registration’ as suggested by the UK government.

"But also, a system of incentives for companies to share data – including data on substances they do not plan to register. For example they could charge a fee for anyone wanting to use their data.

"Finally, there needs to be a massive increase in funding for new in vitro techniques – more money for ECVAM. Industry should contribute to ECVAM.

Question: So you're not opposing REACH, you're saying that this is a chance for safety testing to take a leap forward?

Jan Creamer: Absolutely yes.