BIOCIDES a whole has had various names over the years , most very long . Currently the substance marketed as Citrepel 75 is named ‘ Cymbopogon winterianus oil ’. The CAS number was also an issue at the outset , because the oil containing at least 40 % PMD has been on the same number as pure PMD . Chemian itself was too small to make the original submission and instead joined forces with the dossier submitter . As the firm grew , it became an independent supplier . In 2016 , it purchased a Letter of Access ( LoA ) to the complete substance dossier and became listed as an alternate supplier under Article 95 of the BPR . It continued to pay its share of the ongoing costs for evaluation . The HSE was aware of the alternate botanical sources of PMDRBO within the submission . This was discussed at meetings with Chemian but considered irrelevant ; the increased PMD content of Citrepel 75 was considered a positive . “ Chemian assumed that the working title ‘ PMDRBO ’ or the long Article 95 name , minus the trade name , would be the new name of the substance ,” Walker said .
What ’ s in a name ?
PMDRBO itself is a UVCB , a ‘ substance of unknown or variable composition , complex reaction products or biological materials ’. It contains a variety of naturally occurring compounds , including impurities . Chemian initially welcomed this definition , because it treated substance as a whole rather than its individual components , making things simpler in terms of evaluation and identity : the oil would be used for biodegradability and toxicity tests in its entirety ; and one PNEC , one LD50 and one AEL could be derived for the whole substance . “ However , although toxicity is assessed as a whole , the emissions are still assessed on every individual component at their inclusion levels ,” Walker said . This significantly increases the environmental risk assessment needed because each element must be assessed individually – and some of them lack data . In addition , “ a bizarre situation occurs ” where the fate of an individual component has to be assessed against the toxicity of the oil as a whole . Combined with “ extremely hypothetical ” emission scenarios under Product Type ( PT )' 19 , it does nothing to simplify approvals , which are disproportionate to the requirements for cosmetic uses of essential oils . Another initially perceived benefit of the UVCB classification was having a single registration covering multiple substances with the same constituents and the same hazard profile under both REACH and the BPR . Guidelines developed by ECHA and the European Federation of Essential Oils seemed to make this clear . “ What happened next came as quite an unpleasant surprise ,” Walker said . In October 2016 , after PMDRBO had already been discussed by a BPR working group , the listing for the active ’ s name changed to ‘ Eucalyptus citriadora oil hydrated cyclised ’ ( EC Oil H / C ) and the listing as ‘ Mixture of cis and trans PMD ’ was removed from Article 95 . As a non-participant in the active review programme , Chemian was not consulted but it experienced the repercussions . Firstly , as Citrepel 75 is not produced from Eucalyptus ‣
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