Biocides – Risks and Alternatives Challenges and Perspectives Regarding the Handling of Biocides in the EU
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Biocides – risks and alternatives Challenges and perspectives regarding the handling of biocides in the EU A healthy world for all. Protect humanity and the enviroment from pesticides. Promote alternatives. © Pestizid Aktions-Netzwerk (PAN) e. V. Nernstweg 32, 22765 Hamburg Tel. +49 (0)40 - 3991910 - 0 E-mail: [email protected] www.pan-germany.org Hamburg, February 2010 Author: Christian Schweer Layout: Ulrike Sommer, grafik:sommer, Hamburg IS Photos front page: sale of insecticides/Valentina Lukova, kindergarten/Lubka/picasa.com, Ant/Viele/Derek/Lilly/morguefile.com, fly swatter/PAN Germany e.V., Hoges/Fotolia.com This project is supported by: The supporting institutions accept no responsibility for the correctness, accuracy or completeness of the information, or for the observance of the private rights of third parties. The views and opinions expressed herein do not necessarily reflect those of the supporting institutions. Biocides – risks and alternatives Challenges and perspectives regarding the handling of biocides in the EU 5 ................................. Executive Summary 6 ................................. Biocides – profile and challenges 9 ................................. Current legal framework 10 ................................. Implementation – well done? 19 ................................. The draft for a biocide regulation – a critical comment 21 ................................. Conclusions – five key demands 22 ................................. References Executive Summary The EU biocide policy is currently under revision. The European Parliament and the Council are considering the Commission’s draft biocide regulation, which is intended to replace the current EU Biocidal Products Directive from 1998. Why should we draw attention to these activities? Biocides are widely and sometimes casually applied in everyday life, such as disinfection or the eli- mination of household-insects. They can have toxic, carcinogenic or endocrine disrupting properties. So far, there is a huge gap in the relevant data. Preliminary investigations indicate a large and expanding market for all kinds of biocides, alt- hough their necessity is often unproven. Serious incidents for health and the en- vironment (e.g. poisoning, pollution) have also come to light (Photo 1). The current EU biocide legislation has failed in its purpose of establishing effective risk ma- nagement also due to shortcomings in the enforcement phase. Highly hazardous substances which are banned for other purposes can still be sold as biocides- for-everyone. When analysing the Commission’s draft for a biocide regulation we have even identified noticeable roll-backs from achieving current environmental and health standards. Hence, one of the key demands of PAN Germany and other NGOs is the establishment of an innovative biocide legislation that ensures the consistent phase-out of hazardous substances, as well as providing an effective framework for the development and use of sound alternatives. (Photo 1) Between 2003 and 2005, almost 15,600 consumers, workers and professional users suffered acute poisoning or were affected by the application of biocides in the EU. Though, as a consequence of significant data gaps the real situation remains unclear. Data Source: European Commission, 20061; Photo: Michael Bührke, pixelio.de Pesticid Action Network – Germany 5 Biocides – profile and challenges Biocides are intended to combat harmful and unwanted organisms outside the agricultural context. In many cases, they are not necessary for our sa- fety. However, they are widely used and can pose adverse effects to human health and biodiversity. According to Article 2 (1) of the Directive 98/8/EC (Biocidal Products Directive – BPD) biocidal products are defined as:»Active substances and preparations containing one or more active substances, put up in the form in which they are supplied to the user, intended to destroy, deter, render harmless, prevent the action of, or otherwise exert a controlling effect on any harmful organism by chemical or biological means.«2 One can differentiate between 23 product types (Figure 1) which are subsumed under four main categories of usage (disinfectants, preservatives, pest control and other biocidal products). Biocides have become part of our everyday life: Almost 400,000 tons of active substances are estimated to be sold in the EU each year. These are used in a variety of applications in households, public buildings and industrial plants (e.g. in the cooling systems of energy power plants). They can even be found in textiles like odourless anti-sweat socks or carpets treated with biocides. An accurate insight into this battle against unwanted or harmful organisms, as well as the necessity of biocides and their impact is still impossible. So far, there has been a huge gap in market and use data, in information on the effects of exposure or environmental and health impacts, as well as regarding sound or better alterna- tives.3 For this reason, it is essential to generate significant data and to ensure trans- parency. As many biocides can easily be bought in stores and supermarkets (e.g. household pesticides, wood preservatives or disinfectants which are not subject to strict sales controls) one should draw more attention to the fact that such man-made products can have an impact on our health and the environment. Biocidal products can often contain substances of concern with allergic, ecotoxic, carcinogenic, de- velopmental neurotoxic or endocrine disrupting properties (Table 1). We generally become aware of this (again) when we hear about scandalous cases in the media. One well-known incident involved the widescale sale of wood preservatives for indoor use which included pentachlorophenol (PCP), an active substance with car- cinogenic and endocrine disrupting properties. Although its application has been strongly restricted since 1989, it is still present in our environment today. PCP can also be released from treated goods imported from non-EU-countries.4 Another problematic incident is associated with the application of dimethylfumarate (DMF) which is used to kill moulds that may cause furniture or shoe leather to deteriorate during storage and transportation.5 Hundreds of consumers in countries including France, Poland and the UK suffered severe allergic reactions from contact with DMF-treated products before DMF has been banned in products which are sold in the EU. However, this seems to be just the tip of the iceberg. The application of numerous biocides can be problematic or harmful for professional users or con- 6 Pesticid Action Network – Germany sumers. They pose a particular risk to pregnant women, unborn life, small children (Figure 1) Biocidal Product-Types or citizens with serious chronic illness (e.g. linkages between childhood cancer and the use of household pesticides have been already detected).6 However, cu- MAIN GROUP 1 – Disinfectants and mulative exposures or combination effects are still not taken into account when general biocidal products 1 ► Human hygiene biocidal products evaluating biocides. Active substances and their metabolites can endanger our 2 ► Private area and public health area biodiversity and vulnerable ecosystems. For example, it has been demonstrated disinfectants and other biocidal that the use of the antifouling agent tributyltin (TBT) has a serious impact on the products 3 ► Veterinary hygiene biocidal products marine environment (e.g. masculinisation of female common whelks, accumula- 4 ► Food and feed area disinfectants tion in pot whales).7, 8 Furthermore, the application of brodifacoum which is very 5 ► Drinking water disinfectants toxic for rodents and freely available on the market, has resulted in the secondary MAIN GROUP 2 9 – Preservatives poisoning of non-targeted birds of prey like barn owls. A Scottish study has de- 6 ► In-can preservatives monstrated the vulnerability of red kites and foxes to similar rodenticides: Traces 7 ► Film preservatives of rodenticides were found in more than 50% of the tested individuals, while almost 8 ► Wood preservatives 9 ► Fibre, leather, rubber and polyme- 30% of them showed concentrations that would be regarded as being at the level rised materials preservatives of causing a health risk.10 10 ► Masonry preservatives In addition, 50% of active substances applied in biocidal products have already been 11 ► Preservatives for liquid-cooling and processing systems prohibited or strongly restricted for agricultural or horticultural purposes in accor- 12 ► Slimicides dance with the plant protection products legislation (Directive 91/414/ EEC)11, 12 or 13 ► Metalworking-fluid preservatives identified as priority substances pursuant to the provisions of the Directive2008/105/ MAIN GROUP 3 13 – Pest control EC on environmental quality standards in the field of water policy. This is, for exa- 14 ► Rodenticides mple, the case with the herbicide diuron which is a relevant water contaminant.14, 15 15 ► Avicides It can still be used as a biocide like for in-can and masonry preservation. 16 ► Molluscicides 17 ► Piscicides A new challenge is the growing use and sale of nano-biocides (e.g. nano-silver). 18 ► Insecticides, acaricides and pro- Such products can have different properties and impacts from „normal biocides“. ducts to control other arthropods So far, there have been no sufficient test methods to identify the real risks of 19 ► Repellents and attractants nano-biocides. Some studies indicate health and environmental risks (e.g. toxic MAIN GROUP