PUBLIC AFFAIRS AND ADVOCACY
Biocides and the
Biocidal Products Regulation
2017 proved to be a challenging year for BCF members who manufacture waterbased products. The Biocidal
Products Regulation (BPR), coupled with proposals for harmonised classifications under CLP, continued to cause
significant concerns, with no apparent recognition from the authorities that this could lead to loss of products
from the market, reduced choice for consumers and the potential for product failures due to insufficiently
preserved products. Along with BCF’s European sister trade association CEPE, a total of ten papers have been
published over the past three years in an effort to raise the awareness and propose an alternative holistic
approach.
One key issue that developed in the past 12 months was the
CLP proposal to set a Specific Concentration Limit (SCL)
for Methylisothiazolinone (MIT) of 15ppm, due to concerns
over skin sensitisation. There were several good arguments to
contest this proposal, based on the published supplier studies
and the weak arguments provided by the Risk Assessment
Commitee (RAC - the ECHA committee responsible for the
proposal). The BCF fought hard to deliver the messages to the
UK Competent Authority (the HSE), especially emphasising
that, due to the precedent set up by previous BPR evaluations,
this could ultimately lead to a ban on the sale of any products
containing more than 15ppm of MIT to consumers. As MIT is the
most important biocide for preserving waterbased paints, used
typically at levels between 50 and 100ppm, this would have a
major impact, requiring them not only to reformulate their paints
but also for resin reformulation.
Despite a significant delay and extended discussions on the
subject, the 15ppm decision was finally approved in February
2018. The industry now awaits the next step, the BPR
authorisation of MIT for product type 6, which is due to take
place towards the latter part of 2019.
A second key issue that required BCF action was with regard
to antifouling paints, and the BPR evaluation approach that was
proposed by the authorities. After several years of discussion,
the authorities finally published a new model to use for running
Environmental Risk Assessments of antifouling paints (Product
Type 21). This model is very highly conservative and would
effectively lead to virtually all of the copper-based antifouling
paints to fail under the BPR product approval process. The
HSE appeared unaware of this, until the BCF met with them in
September. Fortunately, the model was introduced too late to
be legally applicable to the evaluations of dossiers submitted at
the end of 2017, however it is still seen as a major threat to the
antifouling paint industry, and the BCF continues to question its
validity.
Other biocides that fell under the spotlight recently were Zinc
Pyrithione (ZnPT - proposed reclassification of Reprotoxic
1B), DCOIT (proposed SCL of 10ppm) and Propiconazole (a
major preservative for wood treatments, now confirmed as
a Reprotoxin 1B). The BC F continues to fight each of these
proposals through comments during public consultation and
direct approaches to the HSE.
For more information on biocides
activities please see the BCF’s Biocides
Hub webpage (member login required)
at: www.coatings.org.uk/biocides
BCF ANNUAL HANDBOOK 2018/19
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