Speciality Chemicals Magazine NOV / DEC 2022 | Page 23

BIOCIDES
Figure 2 - Use matrix
containing all or at least most of their products , thus saving resources .
Possible challenges
Many companies have exploited this opportunity in creative ways . In some cases , the families ended up in being extremely wide and rather complicated for the authorities to evaluate . This led to a new and stricter guidance , which set a number of new limits on which products can belong to the same family . 1 The previous guidance 2 stated that in order to belong to the same family , the products should have : 1 . The same active substance 2 . Similar compositions 3 . Similar uses 4 . Similar levels of efficacy 5 . Similar levels of risk
These requests are preserved in new guidance , but the similarity concept has been detailed in order to reduce the complexity of the families . An example of a very simple quat BPF gives us an idea of what it is allowed and what is not . The family contains four products apparently quite similar to one another ( Table 1 ). They all contain BKC as the active ingredient , satisfying condition 1 . Condition 2 is about the similarity of the composition . The new guidance introduces a new concept of a backbone composition , which is a basic set of ingredients essential for formulating all products within the BPF . Individual products may still contain additional ingredients to comply with the need for some envisaged individual uses , but they all need to contain the basic set identified by the backbone composition .
Therefore , it is crucial to understand which ingredients are essential for the formulations and which are not . The pre-requisite of ‘ essential to formulate ’ refers to co-formulants such as complexing agents , binders and pH-regulators , or a specific solvent needed to formulate any individual product in the BPF , and which are essential for the physical state and the stability to be preserved . It may seem as an easy task , but practices proves otherwise , as formulators can be quite creative in the diversification of their products portfolio . Condition 3 is that the uses among the different products are similar . A traffic light matrix approach tool 3 can help in understanding if the different uses of the four products are similar enough for the products to be grouped in a single family ( Figure 2 ).
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