An SME ’ s 15-year journey with the BPR
Chemian Technology has undergone a long and tortuous path to compliance with EU biocides regulation . We report from Chemical Watch ’ s Biocides Symposium
Founded just over 25 years ago , Chemian Technology originally sought to provide business development services to chemical companies . However , said founder and managing director Ian Dell , while presenting at Chemical Watch ’ s latest Biocides Symposium , it always intended to develop a technology in its own right . “ A vague , curious enquiry ” from a company wanting to source a natural insect repellent active called p-Menthane-3,8-diol ( PMD ) led over time to the firm ’ s main business . It now makes two natural insect repellent products : Citrepel 65 , derived from Eucalyptus citriodora leaves , and Citrepel 75 , from the Java citronella plant . Chemian is still very small , employing only two others , and still works with some of the same contractors it worked with 20 years ago . Naturally , there is no regulatory department . Indeed , Dell still sometimes has to do emergency deliveries himself . For 15 years , Chemian has been trying to comply with the requirements of European biocides legislation in respect of these products . “ From the outset of the project , the spectre of the BPD loomed ahead of us ,” says Dell . “ But in our typical optimistic fashion , we thought we would find a way to comply .” Dell first met up with a company with a consumer brand of PMD , which had already generated the data for a US EPA registration . They worked together with them on early submissions to the UK Competent Authority , the Health & Safety Executive ( HSE ), subsequent completeness checks and a dossier submission for PMD .
Approval process
For the last three years , Dell ’ s co-presenter Samantha Walker of regulatory consultancy TSG has worked with Chemian to get Citrepel approved . With no little understatement , she said that Chemian ’ s experience “ does not wholly reflect ” the ideals of the BPR , of harmonising regulation , protecting human health and the environment “ Over 15 years on , their actives are not yet approved ,” Walker said . “ It is incredibly expensive and they have yet to turn a profit as a company as so much money is ploughed into the BPR and other regulatory requirements . It is unbelievably complicated and constantly changing . It is not a level playing field .” Ever since the original submission under the BPD in 2006 , the title of the substance has been an issue . The main constituent is PMD Rich Botanical Oil ( PMDRBO ) but the oil as
46 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981