Analysis of measures geared to the sustainable use of biocidal products

Transcription

1 Analysis of measures geared to the sustainable use of biocidal products 57 th meeting of representatives of Member States Competent Authorities for the implementation of Regulation 528/ September 2014 Presented by Josephine Armstrong

2 Task 1: Provide an overview of the promotion of best practices as a means of reducing the use of biocidal products to a minimum ; Task 2: Identify whether need for additional provisions regulating professional users; Task 3: Investigate and make recommendations for the most effective approaches for monitoring the use of biocidal products ; Task 4: Specify the risks posed by the use of biocidal products in specific areas and whether addition measures are required to address those risks; and Task 5: Examine the relevance of integrated pest management principles for biocidal products; Task 6: Investigate the possibility to attribute an eco-label to biocidal products; Task 7: Provide an overview of voluntary schemes that are used to highlight those products and uses that have a better environmental and human health profile, and suggest other approaches or tools; and Task 8: Analyse whether it is appropriate to revise Article 72 of the BPR.

3 Interim update Work to date has focused on desk-based research, questionnaires to Member States, industry and NGOs, and an initial analysis of responses; All tasks running in parallel throughout study; Interim report to Commission submitted during Summer 2014 presented initial analysis of responses received; Next stage - follow-up interviews, further information gathering and legal and technical analysis; Final report due March 2015.

4 Best practices in reducing the use of biocidal products to a minimum Categories of information: - Guidance & other best practice documents, e.g. A.I.S.E Tips for Sustainable Use of Biocides by professionals; - Industry standards, e.g. CEN FprEN 16636, Pest management services Requirements and competences ; - Economic incentives (fee-based approaches), e.g. lower fees for simplified authorisation procedure or calculation of annual fee based on hazard categories; - Regulatory mechanisms, e.g. prohibition of use by non-professionals or placing conditions on use; - Information mechanisms (for public & for professionals and businesses), e.g. Danish Think campaign. Best practice documents specific to PT8, PT 18 & PT19 How to promote best practices?

5 Additional measures regulating professional use 16/21 MS apply a definition of professional user general definition / definition based on general scheme of certification or training / definition according to specific product type; 15/21 MS and 83% of industry respondents not aware of any exposure risks for professional users that are not adequately covered by existing risk mitigation measures under health & safety and chemicals legislation; Majority of respondents felt that any exposure risk results from poor application of existing risk mitigation measures; 72% of industry respondents did not consider that additional measures are required to reduce risks to professional users; Considerations: Key issue identified by industry & NGO s was training and provision of information.

6 Monitoring the use of biocidal products 8/21 MS collect data on biocidal products; In each case, monitoring covers data at the stage of placing on the market of biocidal products, and in some cases only for professional users; Only 4/21 MS collect data on actual use of biocidal products or plan to do so in near future; In some cases, specific IT tools used to support monitoring, e.g., SIMMBAD in France. Considerations: Whether any of MS approaches could be used as basis for EU system? Whether R4BP3 could be used to promote a harmonised approach to monitoring use, and if so, what information could be collected? Whether industry initiatives, e.g. smart tag, could be linked to monitoring?

7 Risks posed by use of biocidal products in specific areas 6/21 MS referred to specific prohibitions or restrictions in place covering the use of biocides in certain areas, e.g. prohibition on use of anti-fouling products in freshwater; MS responses split half and half between those that felt that additional measures were required and those that did not; All NGO s felt that additional measures were required. Considerations: What uses in each product group pose risks to specific areas? Whether existing control measures, e.g. under health & safety and water legislation, address these risks? Links with training, information, use of IPM principles etc.

8 IPM principles Could IPM principles apply to biocidal products, either generally or to specific PT? - Industry: 44% /18% considered they could/could not; - Most MS considered they could. IPM principles would need to be product-specific, most suitable ones identified at this stage being PT14 and PT18; Considerations: variety of PT, applications and users; adaptation of principles to biocidal products, not all suitable; development of codes of best practice for specific uses; enforcement.

9 IPM principles

10 Tools to promote sustainable use Eco-label - NGO s consider an eco-label could only ever be used to promote biocide-free alternatives; little support from MS & industry; A number of accreditation, ecological standards or other voluntary labelling schemes exist; Art.72 BPR 17/21 MS and all NGO s felt present restrictions are necessary & should remain; 43% of industry respondents felt advertising restrictions too strict; Main concerns related to terms natural & low-risk biocidal product. Considerations: Review of existing eco-labels; analysis of legal criteria for EU ecolabel; and whether criteria could be developed for specific PTs? Identify through case studies what voluntary schemes and key criteria could be developed & used EU-wide; Need to revise Art.72 BPR

11 Questions? Thank you Josephine Armstrong