Non agricultural biocide directive. Practical proposals of implementation in the case where biocides are wood preservatives
This project of non-agricultural biocide directive has currently an extremely wide scope of pre-marketing authorization of substances and preparations used in numerous applications, other than agricultural. Elaborated on the 86/414/EEC model of the phytopharmaceutical product directive, the "NAB" draft directive aims to cover situations as different as plant or wood protection: in the case of plants, there is a need of no residue on the support; in the case of wood, there is an aim of 100% active residue on the support to achieve a 10-50 year service life; for the wood preservation sector, where the regulatory and normative background is already strongly documented, there is an evident need of sectorial adaptation. If it seems widely agreed to homologate substances at the EC level, this is not the case for preparations which represent potentially infinite combinations of substances, to take into account the geographical, climatic and biological discrepancies. The proposals made herewith are to start from a european shopping list of sufficiently known substances, classified in terms of dangers, and move for wood preservatives to the new approach EC system requiring compliance with harmonized standards of risk assessment methodology showing a severity equivalent to that of homologation and checking compliance with health and environment quality criteria. In this model, marketing is initiated under the manufacturer's responsability by using the CE marking. The attestation of conformity for safety uses the same scheme as for quality; the non-conformity with the essential requirements proposed involves withdrawal from the market of the biocidal product involved.
Keywords: BIOCIDES; NON AGRICULTURAL BIOCIDES; IMPLEMENTATION; NEW APPROACH; CE MARKING; HOMOLOGATION ESSENTIAL REQUIREMENTS; OPTIONS; REGULATIONS