From Mr Drieu Godefridiand Ms Angela Logomasini.

Sir, Industry has long been fighting a losing battle to "fix" the EU's proposed Reach programme as indicated in your article "Setback for industry as tougher regulation on chemicals moves closer" (October 11).

They were destined to fail from the start because the concepts behind Reach are fundamentally flawed and thus the proposal cannot be fixed. It should be rejected outright. The programme's "substitution principle", which prevailed in the environment committee draft, is one example. It is based on the idea that regulation can prompt industry to find products that are superior to "dangerous products".

If the substitutes were really superior, they would prevail in the marketplace. Mandated substitutes are usually not used voluntarily because they carry trade-offs - higher prices, reduced product quality and increased level of product failures. In some cases, mandated substitutes are actually more dangerous.

The banning of DDT offers an example of why we should not trust regulators to mandate substitution. This pesticide was banned in many places based on faulty information about its health risks and because people assumed that substitute controls like bed nets could do as well to fight malaria. After DDT use halted, malaria rates skyrocketed and millions of people have died from the disease every year since. Some nations are returning to DDT use for malaria control, but it is tragic that so many people have to die first. The Reach programme, unfortunately, shows that policymakers still have not learnt from that tragic mistake.

Drieu Godefridi,

Hayek Institute,

Brussels, Belgium

Angela Logomasini,

Competitive Enterprise Institute,

Washington, DC 20036, US