Thank you for that question.
I would say there are significant differences with regard to the relative role of industry and government in these different proposals. One contrast with the REACH proposal, which is really quite revolutionary in its approach, is to put the burden on the industry of not only developing information but actually assessing that information and deciding what risk management practices are needed. Those latter two are traditionally government functions and are a hallmark of every chemicals program, no matter whether it is pesticides, pharmaceuticals, or what have you.
The government's role in REACH will be largely an oversight role, to check on that information and ensure that it's accurate. One of my concerns about REACH, frankly, is that the process by which those evaluations of the industry submissions take place has no timelines and no particular pace at which it has to happen. I actually think there are a lot of innovative aspects to REACH, but there are elements like that one that are really of significant concern to me. It really is a matter of trying to find the best features of these different systems and bringing them together and making sure they work in the cultural and regulatory context of a country. That is the challenge, and my report is really trying to grapple with that issue.