Thomas Hartung and Constanza Rovida recently published an opinion piece in Nature (“Chemical regulators have overreached,” Aug. 27, p. 1080-1081) arguing that the compliance with EU REACH legislation is likely to use 20 times more animals and cost 6 times as much as previous estimates. They argue, based on a more comprehensive analysis published elsewhere (http://altweb.jhsph.edu
), that the primary culprit is the two-generation reproductive toxicity test, which is likely to account for 70% of the costs and 90% of the animal use for REACH compliance.
They argue for multi-pronged solution, calling for use of the extended one-generation reproductive toxicity test (the near term), a well-funded alternatives program targeting reproductive toxicity (medium term), and investment in “21st century toxicology” (long term). They recommend a “moratorium on reproductive-toxicity testing, or at least limiting testing to the most suspicious substances, until the OECD guidelines [on the one-generation version] are completed and alternatives strategies for screening lots of chemicals are available” (p. 1081).
Two rebuttals to Hartung and Rovida’s analysis were issued rapidly: a testy blog by Environmental Defense’s Richard Denison (http://blogs.edf.org/nanotechnology/2009/08/26/talk-about-over-reaching-anti-reach-screed-gets-nearly-everything-wrong/
) and a less combative press release by the European Chemicals Agency (http://echa.europa.eu/doc/press/pr_09_11_animal_testing_20090828.pdf