ChemCon Europe 2014, extended interview: Elizabeth Ruffinengo
Why we need better regulation of biocides
Biocidal products are under the spotlight as never before as part of the global movement to modernise chemicals regulation in order to catch up with the pace of chemicals products being introduced. A new regulation in Europe is posing compliance challenges for companies, but NGOs welcome what they hope will be a more effective regime to reduce the risks of biocides. Elisabeth Ruffinengo of Women in Europe for a Common Future (WECF) tells Mamta Patel why this is so important to NGOs.
Advocacy and awareness raising are the twin areas of activity for WECF, Ms Ruffinengo says. WECF is an international network of over 100 women’s, environmental and health organisations implementing projects in 40 countries and advocating globally for a healthy environment for all. It is one of the European Chemicals Agency’s accredited stakeholder organization, giving it a role in shaping some of the decisions concerning approval and assessment of chemical products.
One of WECF’s campaigns is “Safe Chemicals for a Healthy Environment for All”. Under this heading, the group is very interested in the widespread use of biocides in everyday products, which may expose vulnerable populations such as pregnant women, infants, children, etc. to chemicals of concern. Citizens in Europe and elsewhere have a “deep lack of awareness” about the use of biocides in products, Ms Ruffinengo says, including what they are used for and how they may be exposed to them, as well as potential harmful effects on their health and that of ecosystems. She attributes this to a “lack of transparency of biocides use at a global scale”.
At the same time, the approval and use of biocides for the professional sector should not be neglected because “professional exposures have historically proven to be key to discover and understand the toxicity of chemicals of concern…Testing hazardous properties of biocidal products before they are even placed on the market and not allow those which are proven or suspected to be harmful is the best way to avoid such a situation in the future”, she adds.
She also stresses that control of biocidal products should be seen in the perspective of global regulatory efforts to manage the risks of chemical products on a much wider scale. Therefore, the same issues and unknowns apply to biocidal products including emerging knowledge about the behaviour of chemicals including endocrine disruptors and nanomaterials, impacts on vulnerable groups and on ecosystems. “Just like other chemicals, the more expertise and knowledge on their properties progresses, the more we become aware of their harmful effects on both human and environmental health. This is highly worrying from a public health perspective”. She points to the impacts of biocides in marine antifouling paints and emerging studies on the impacts of nano-silver in the environment as examples.
The former EU Biocidal Products Directive (BPD), adopted in 1998, had a very difficult task to achieve, she feels. “It came in at a time when biocidal products were not regulated at all in the EU. This means that the Directive has tried very hard to fill a knowledge gap on the use of biocidal products, but could not do more given the scale of the data to be collected, analysed and assessed by the public authorities in charge before envisaging to move towards responsible management.
Ms Ruffinengo has higher hopes for the EU Biocidal Products Regulation (BPR), which was adopted in 2012 as a newer, sleeker replacement for the BPD. Asked about her hopes and fears for the BPR, she says: “Indeed, the new BPR can make a significant difference: the precautionary principle underpins the new regulation, and most of its provisions, if interpreted in that sense at the time of implementation, can be effective tools to protect public health and the environment from potential threats caused by biocidal products.
“My hopes are for more transparency of data on biocidal products along the supply chain, sufficient resources on the side of the public authorities in charge of dealing with the new BPR obligations, improved access to information of the general public on biocides use, and globally more coherence at EU level. My fears are that given the economic context, health and environment issues are not given the priority they should receive compared to economic and commercial considerations.”
Specifically on nano-biocides, WECF is part of NGO coalitions working on nanomaterials and nanotechnologies use. “We consider that nano-biocides have to be assessed with appropriate toxicological approaches, adapted to their very nature, properties, specific fate in the environment and in human tissues, which are different from their bulk counterparts. The fact that nanomaterials are excluded from the simplified authorisation regime of the EU BPR, together with the obligation to mention “nano” into brackets where nanomaterials are used in biocidal products are encouraging. We are especially concerned about the wide use of nano-biocides such as nano-silver for example, since they have been placed on the market without sufficient impact assessment, and there is a huge gap to fill still in terms of knowledge of their impacts. We do support a precautionary approach when it comes to nano-biocides.”
Given its concerns about the risks of biocides, what does WECF consider to be responsible management of these? Ms Ruffinengo answers that this would mean firstly only to use biocidal products that have proven to be effective and which are necessary, and then only when non chemical or safer alternatives do not exist (for example, the effectiveness of biocidal treatments of textiles has been questioned). NGOs want assurance that the BPR’s rules for data requirements and exclusion criteria will not be undermined by derogations and that the substitution principle will be firmly applied for the most hazardous substances. In general, exhaustive risk assessment and research on new biocidal products should be concluded before they are placed on the market. “This would also make it possible to reverse the situation we have had for many years now, of putting regulations in place far too long after certain hazardous chemicals – including biocides - have been widely disseminated in the environment and in human populations.”
Looking more widely, she says: “At a time when the challenge of toxic chemicals/compounds and their impacts of human health and ecosystems goes beyond borders, as expressed by reports like the UNEP Global Chemical Outlook (2013), it is clear that regulatory change can be efficient only if taking place at global level. The populations and ecosystems of the US and other parts of the world face the same risks as those in Europe, but, undoubtedly, most at risk are the populations of developing countries which often face greater exposure to hazardous chemicals but with far less protection.”