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- Pre-submission strongly advised for biocides Union authorisation
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- Life in the Board of Appeal – a personal view
- New partners service for authorisation applicants
- Building consumer awareness on safety
- A challenging supporter who expects REACH to deliver a safer future
- A global response to a global challenge
- Animal welfare organisations – ECHA's critical friends
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Animal welfare organisations – ECHA's critical friends
The European Coalition to End Animal Testing, ECEAE, has been representing animal welfare organisations as one of ECHA's accredited stakeholders since the very beginning. During these years, they have been actively involved in commenting on testing proposals and have observed the impact that REACH has had on animal welfare. The ECEAE's Chief scientific advisor, Katy Taylor, tells the ECHA Newsletter about her experience of working with ECHA.
"We have found ECHA to be very welcoming to its stakeholders, including us. Initially, we were pleased to see how the Agency recognised our concerns about animal welfare. However, as processes evolved we have become more critical while we have gained more experience of how REACH works in practice," Katy Taylor says. "Whilst the ECEAE has always been a supporter of the principles of REACH, we would like to see REACH without animal testing. Until this happens, we want to work with regulators to help them keep animal testing as a last resort. We are pleased to have stakeholder status and like to view our relationship as a 'critical friend'. If we think that the Agency has done something inappropriate or wrong then we reserve the right to say so," Ms Taylor explains.
| Katy Taylor and Agatha. |
Trust in stakeholders
The ECEAE works closely not only with ECHA but with many European regulatory authorities. Ms Taylor appreciates the efforts that ECHA makes in engaging with its stakeholders and believes that ECHA is the most transparent agency that they have cooperated with. "I am quite positive about the Agency in terms of its transparency. I feel that ECHA takes its stakeholders very seriously. We are invited to most of the main official meetings as observers and our attendance there is paid for by ECHA. There is a huge amount of information on the website that is useful for stakeholders too. Not just about REACH and how it works but also about the outcomes of the Agency's work and its decisions," she says.
However, there are still areas where ECHA can improve. For example, observers are not allowed to participate in closed sessions of Committee meetings. "We have asked ECHA to seriously look into the issue of the closed sessions where Member States make their decisions. We do not have access to documents that they are discussing in the closed sessions either. This is quite a big issue for us," Ms Taylor states.
She admits that the situation is not easy for ECHA but for the stakeholders to be able to follow all the discussions, there is need for greater mutual trust. "Accredited stakeholders that are allowed to attend the meetings are afforded a special kind of trust – we are not allowed to talk about what happens in the meetings. We sign confidentiality agreements, so in my opinion we should be allowed access to the documents which are discussed during these meetings," she explains.
Importance of the work done on testing proposals
The ECEAE has been very active in providing expert support to comment on the testing proposals from the very start. This is an important task for them. She would, however, like to see more time given for public commenting. "We are concerned about the number of testing proposals that are published in every batch. There is obviously a lot for ECHA to process but we believe that they should publish smaller batches and extend the period that they have to publish testing proposals," she insists.
In public consultations, ECHA asks third parties to submit scientifically valid information and studies. To Ms Taylor, this is problematic because the information that they can provide does not always consist of test results that have previously been conducted. "We think that it is useful to provide ECHA with information, for example, about a QSAR model that a registrant could very easily run, but they believe it is the registrant's responsibility to take it up or not," she clarifies.
"We have succeeded in a few cases in showing a registrant that the information they need is there and they have therefore withdrawn a testing proposal. We put a lot of effort and time into this process and our member organisations have all contributed. We would like to be even more successful. To us, any animal saved is a worthwhile outcome but we think we have already directly saved 18 000 animals," she says.
More concern for animal welfare needed
One of the topics that the animal welfare NGOs have recently discussed is ECHA's report on alternatives to animal testing which was published in the beginning of June. Ms Taylor understands why the report raised some criticism. She explains that by looking at the number of new animal tests done, it does not look like there has been a significant change by industry.
"I think it is far too early to come with a positive response from the animal groups. I do not think that anyone, the Agency or industry, can rest easy. We want to keep pressure on ECHA and industry to make sure that animal testing is the last resort," she emphasises.
Ms Taylor encourages ECHA to do more to show how industry could do better. "There is also really good information in the report explaining to industry how to use alternatives, but it is buried," she says and continues, "whilst we appreciate ECHA's role in implementing the legislation, the Agency could in our opinion take a very different stance. There is nothing stopping ECHA from, for example, doing press releases encouraging industry to avoid using animal tests and promoting the guidance that is on the website already. This would help reassure industry that ECHA will accept a well presented approach that does not involve animals".
For the last six years she has coordinated the organisation's response to REACH; managing a team of consultants who provide scientific comments on proposals to test on animals, as well as monitoring decisions made by ECHA.
Interview and text by Adam Elwan and Mikko Väänänen
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