I was at a conference about cosmetic regulations yesterday. As is often the case, some of the most interesting things I picked up in random conversations with people I might not otherwise ever meet. For example I was chatting to someone in passing mentioned that the people enforcing the REACH regulations were resorting to automated methods to clear their backlog of unapproved data.
If you are like the vast majority of people who don’t work with chemicals, you won’t have the first idea what I am talking about.
I dare say most people in the cosmetics business have heard of REACH, but it doesn’t directly affect us very much so even we have only the vaguest notion of what it is all about. What I have heard has always sounded fairly reasonable, and I have been generally in favour of it in the way I am generally in favour of other people doing stuff that makes my life easier with no effort on my part.
REACH – ‘No Data, No Market’
The idea behind REACH is that no chemical manufacturer can put a chemical on the market without generating a package of data on it. I like chemicals and I like data, so that sounds okay. Somebody at some point coined the phrase ‘no data, no market’. This sounds admirably tough and it gets trotted out regularly whenever the subject gets debated.
But with regulations, the devil is in the detail. And in the case of this particular regulation there is a great deal of detail for the devil to play with. The REACH regulations are the longest and most complex piece of legislation passed by any elected body in history. Complying with them and enforcing them has consumed whole lifetimes of effort on the parts of some highly educated and intelligent people. Huge quantities of data have been generated.
It turns out that, if what I heard is right, the backlog of assessing and approving all this data is now so great that it is literally beyond the ability of humans to cope with it. We are having to programme computers to do it.
REACH – A Failure with the Public?
And nobody has ever heard of it. If the motive was to reassure the public, then this truly huge project has to be judged a failure. You mind is not going to be put at rest by something you have never heard of. Presumably at least some of the MEPs who passed this remarkable document into law had some notion of what they were doing at the time. Certainly the MEP who currently represents my area in the European parliament seems a very serious minded woman who takes the trouble to blog about her activities in plain language. I don’t know if she was around when this bill went through, but I imagine she’d have checked it out. But what can a politician do with something this specialist anyway? Surely they’d have had to follow what their experts told them.
As I say, I think the basic aim of REACH is a sound one. But does it really have to be so complex and prescriptive? It seems to me that it has already failed on the test of making people less worried about chemicals. Has it led to any improvement in public health? Surely all this work must have had some benefits to people’s well being, even if they don’t realise it?
If it has, I am not aware of it. And I can find no reference on the EU’s web pages to any study being carried out to find out what good it has done.