That which must not, can not be... A reply to the EChA and EDF responses to the REACH analysis of animal use and costs.

We appreciate the interest and discussion our study reassessing animal use and costs of ReACH (Rovida and Hartung, 2009, Hartung and Rovida, 2009) has initiated. the issue has received serious press coverage in several countries. This reflects the extent of the ReACH investment into consumer product safety, and it should stimulate further discussion regarding a revision of safety testing approaches, i.e. the transition toward a “toxicology for the 21st Century.” We believe that this continuing dialogue is essential to maximizing the public health protection that ReACH can offer today and for future generations. Major disagreement came, however, from the european Chemical Agency (its statement was published back-to-back with our study in the last issue of ALTEX, eChA, 2009) and from the US environmental Defense Fund blog (Denison, 2009). Unfortunately, both responses followed the reasoning process outlined in the Christian Morgenstern quote above, offering very little in the way of specific indications of errors in our estimates. Neither response addressed the key questions, i.e. the impact of the larger eU and a continuously growing chemical industry, which was not reflected in previous estimates based on more than 15 year old figures, and where the testing facilities and toxicologists for the acknowledged or the even increased demand should come from. Going forward, however, we believe it makes most sense to look for areas of agreement and continue to discuss those topics upon which we do not yet agree. As a first step in that direction, we want to clarify several important points that we believe were not clear to some of the readers of our article. 1 We support REACH and want to make it feasible