To understand the figures surrounding REACH, we need to go back to two historical events. The first of these was an industrial accident that took place in 1976 in the town of Seveso in northern Italy, involving the massive release of the chemical dioxin. This chemical disaster persuaded the EU to take action. As a result, in 1981 the decision was taken by the European authorities to submit all new chemical products to toxicity tests, at the expense of the manufacturer, and REACH was born (1).

The second historical event relating to the figure of 54 million animals was the discovery in 1938 of the powerful synthetic oestrogen, diethylstilbestrol (DES). DES resulted in cervical cancer in daughters and grand daughters born to some of the women who were prescribed this drug. This drug tragedy is cited as the justification for “second-generation” toxicity tests in animals, which (according to Dr Hartung) constitute about 70% of the 54 million. The European authorities surely knew about the DES tragedy when REACH was launched in 2007, and yet presented the public with a figure of 12.8 million. There are two possible reasons for this “discrepancy”.

The first is that the European authorities preferred to wait as long as possible before announcing the bad news, so as present the public and animal welfare organisations with a fait accompli. The second scenario is to “play the numbers game” by initially announcing a massive increase in the number of animals to be used and then gradually reducing the figures so as to appear to use fewer animals. Indeed, the European Chemicals Agency (ECHA) has already suggested that it may be possible to spare 4.5 million animals of the 54 million (2).

While the public watches and waits to see where this numbers game will end, we need to remind ourselves that the current REACH program relies on the same bad science (animal tests) that was used to study chemicals prior to 1981. Given the fact that REACH will not be completed before 2018, our regulatory authorities have in effect, granted the chemical industry 37 extra years of animal testing to “protect” public health and the environment against toxic chemicals. But how effective is this plan? A 2004 survey conducted in the US of newborn babies discovered a cocktail of more than 200 toxic chemicals in their umbilical cord blood (3). What more proof do we require to show that the current testing system is hopelessly inadequate?

What lessons can we learn from the above, in order to better protect public health and the environment? It often requires a tragedy or a disaster of massive proportions before the authorities will act (Dioxin and DES); Even then, the authorities are usually slow to respond (37 years to complete REACH ); Animal tests do not protect human health; It is no secret that politicians respond to pressure. The question is whether we can create sufficient public outcry to override the pressure exerted by industry. We can protect public health and the environment, and it does not require the use of animal tests. The solution lies in the use of intelligent testing strategies, based on a tiered testing system, beginning with human cell lines. In the case of reproductive toxicity (also referred to as reprotoxicity) and second-generation toxic effects, the human cell lines chosen would be those corresponding to the male and female reproductive system in various stages of development (4,5).

*(REACH = Registration, Evaluation, Authorisation and restriction of Chemicals)