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		Don't believe the label. Look in the box! Thursday 17th November 2005 We know we can't judge a book by its cover. We know that fine feathers don't make fine birds. So why is it that when we come to European laws, so many of us accept the objectives at face value, and never think about the actual proposal, and whether it will work? In eighteenth century London, the South Sea Company offered "an enterprise of great advantage, but no one to know what it is". Punters poured money into it, the share price headed off for the stratosphere, and then in 1720 it crashed, leaving many investors ruined. These days we're all too familiar with scams on the internet, and e-mails offering $22 million from Nigeria, and we look back to those simpler times three hundred years ago with patronising pity for the gullibility of the poor punters. Yet we do just the same thing today with EU directives. In November, the European parliament voted on a proposal called REACH: Registration, Evaluation and Approval of CHemicals. Its objectives are just fine. There are many thousands of chemicals out there in common use in products in the home and the workplace. Many of these have never been tested for toxicity, and there are grounds for believing some may be dangerous, so the proposal is to test them, approve them, and replace any dangerous ones. Put like that, who could disagree? The problem, as always, is in the small print. You need a cold compress on your head, and several hours to read dense pages of print, and even then you won't understand the full implications unless you also go out and consult with industry and find what the real effects will be. And when you find out the effects, they are not good. The measure prioritises by volume, not by known risk. It will take years to complete. The costs will be huge -- a further blow to European competitiveness. Millions of laboratory animals will be destroyed unnecessarily to test substances which have been in use for years and are known to be safe. Many perfectly safe products will in effect be banned because the testing costs exceed the commercial value. Jobs will be lost and companies forced into bankruptcy, with small and medium sized companies bearing the brunt. In many cases production, business and jobs will be forced off-shore to third countries with far lower environmental standards. Just one example: a company on my patch in Market Harborough will have to spend the equivalent of a year's profits -- money which could have gone on investment or jobs or marketing -- to test ferrous oxide. That's rust, and no one imagines it is hazardous, especially when set in architectural cement as a colorant, which is how they use it. Yet so many people see no further than "We want a clean environment", and back the project sight unseen. Lobby groups like the World Wildlife Fund have got at other organisations, like the Women's Institute, and persuaded them to lobby MEPs in large numbers. I have a lot of time for the WI, and it saddens me to see them used in this way. But I knew things were really out of hand when God himself, or at least the World Council of Churches, weighed in. I had an e-mail from a John Smith of WCC, citing the objectives of REACH (but not the methodology) and calling on me to support it. It is worth quoting my reply in full: Dear John, You are making the classic mistake of approving the declared objectives of REACH, but not giving a moment's consideration to the vital question whether the proposed policy and methodology will deliver the desired results, or whether it is the best way to do so. The answers to these questions are, respectively, maybe, and definitely not. The REACH process is slow, cumbersome, expensive, damaging to industry and jobs, and to the extent that it will drive activity to third countries with lower environmental standards, quite possibly counter-productive. I daresay you have not read the proposal, nor considered any alternatives. You should, before you seek to give divine authority to a profoundly flawed piece of EU legislation. Best regards. ROGER HELMER MEP www.rogerhelmer.com So is the answer to do nothing? Certainly not. There is a better way, and it was proposed some time ago by the British Royal Commission on the Environment. Prioritise by risk, not volume. Categorise by class of substance. Use available test results from around the world. Make greater use of modern techniques like molecular computer modelling (and minimise animal testing). The objectives of REACH are fine, but the methodology stinks. There is a better way, to deliver the results we want more quickly, and without the economic damage. We can leave our grandchildren both a clean environment and a viable economy.