European commission strategy
At its meeting of June 25th 1999, the European Council of Ministers asked the European Commission to propose a new strategy with regard to chemical substances policy, no later than end 2000. This decision follows on from a 1998 report by the EEA-UNEP and a working document of the same year that criticised the Commission with respect to the functioning of the European Union's four main policy-making instruments in terms of chemical substances.
To quote a memorandum issued by the chemicals industry (which has felt obliged to emit weak protests so as not to have to dig too deep into its own pocket!), the Commission's proposal would require the testing of the 70,000 existing chemical substances, meaning 7 to 10 million animals would have to be sacrificed, i.e. 350,000 to 500,000 animals each year for twenty years. The number of chemical substances on the market, and that would therefore actually need testing, can be estimated at a low 20,000. This would correspond to 2 to 3 million animals.
A great many industrial chemical substances exist within the EU (Directive 67/548/EEC). There are 100,106 so-called "existing" substances, i.e. prior to 1981, listed on the European INventory of Existing Chemical Substances (EINECS). Add to this some 2,000 "new" substances, recorded on the European LIst of Notified Chemical Substances (ELINCS).
Directive 79/831 of 1981 obliges manufacturers and importers of chemicals to "notify" chemical products, i.e. to provide detailed information on the production, use and intrinsic properties of a substance in a technical dossier. This means testing the substances on animals.
Since 1993, notification of a new chemical substance also means evaluating the danger that exposure to that substance entails for public health and the environment (seventh amendment to Directive 67/548/EEC - Directive 92/32/EC). If the risk is too high, the substance can be banned. Up until 1998, of the 2,000 new chemical substances, only 400 risk evaluations had been carried out.
Regulation 793/93/EC seeks to identify and reduce the risks associated with existing chemical substances. The number of chemicals currently on the market is generally estimated at between 20,000 and 70,000: such imprecision clearly illustrates the lack of data in this field. Little is known of the toxicity of some 75% of these 20,000 to 70,000 substances (EEA-UNEP 1998). According to another source (Allanou et al, 1999), nothing or little is known of the toxicity of over 85% of the 2,500 most heavily-produced substances (over 10,000 metric tons per year).The manufacturers and importers of existing chemical substances (some 98% of all chemicals) are currently under no obligation to provide new data, despite the fact that existing data is not enough to classify these products as dangerous or not. Risk evaluation as it stands is a long and unwieldy process. The European Commission implicitly recognises that almost all these chemical products have been introduced on the EU market and are still being sold today without any form knowledge of their impact on public health and the environment.
How many pesticides, colorants and additives, even among the most commonly used, are in reality harmful? How many can cause cancer in the medium- and long-term ? This question can be extended to all the artificial substances that form part of our daily lives, as the corresponding "notification dossiers", of which there are few, have only proven their "partial toxicity" or alleged innocuousness on animal species whose metabolism is totally different to ours.
Let us not forget the doubts that exist concerning the validity of results obtained using animals when applied to humans. Still today we continue to use outdated tests, such as the LD-50 (lethal dose) toxicity test which is already half a century old and has been heavily criticised by the WHO for more than ten years now. And yet, in an attempt to cast some light on the situation, we are seriously envisaging spending at least € 3 billion a year for twenty years (estimation by Dr. C. Reiss of the French national scientific research centre, CNRS).What is the true motive behind this decision? To genuinely identify and outlaw dangerous substances? Or simply to reassure 350 million Europeans without upsetting the powerful chemical industry, a source of employment and profit?
Quite clearly, continuing in the same vein will not solve the problem of insufficient data for existing substances, be this in terms of quantity (too slow in coming) or quality (unreliable).
Just as some would have us believe that nuclear power is the answer to global warming and the greenhouse effect, others seem to want to convince us that more animal experimentation will solve the problem of pollution and the other harmful consequences of chemical substances.
Faced with what would be the biggest ever "massacre" organised by the European authorities (despite a decision by the European Commission some years ago to halve the number of animals used in experimentation by 2000), we have decided to react. We must rapidly develop the use of alternative methods, which are less costly, more reliable and less cruel. Let us not forget that, following a similar case in the United States, a compromise was found and that, thanks to Al Gore's orders, many lives and dollars were saved by implementing alternative solutions.
Is Europe lagging behind again? One Voice, like everyone else, wants only safe chemical products to be allowed on the market. We also believe that there are better - and more humane - ways of reaching this goal
Translation: Sandra Petch