How credible is REACH regulation without transparency, quality criteria, assurance, and control?

As a result of these shortcomings, ECHA R.14 Guidance for occupational exposure assessment allows the use of non-physical models containing qualitative parameters based on non-accessible calibration databases and statistical evaluations. Because of the lack of transparency, non-physical model construct, and subjective input parameters, model results cannot be associated with real-world operational conditions, and quantitative uncertainty assessment is not feasible. This makes the models qualitative by definition and is not applicable to regulatory exposure modelling. This raises questions about whether ECHA has followed its regulatory mandates in implementing the REACH legislation.