I asked the head of the REACH program, Derek Knight, that question when he was presenting at an EPA symposium in North Carolina. I got up in the discussion period and I said, “Derek, I get the sense that the REACH program is a little more hazard based, a little more precautionary, than the approach that's used by the U.S. Environmental Protection Agency”, and he said, “Yes”.
The idea, I think, relates a little bit to guilty until proven innocent; show me safety before you can use an agent. I think we need to find the right balance between those two. I don't have a simple solution to your question, but I think it's a very important one, and one that you need to give some guidance on within the new statute.