LEGISLATION
WHAT’S THE DEAL WITH: BIOCIDAL
O
PRODUCT REGULATIONS
The industry is at the mercy of various regulatory bodies as to what ingredients can or can’t be used in the manufacture of building chemicals which is becoming a challenge as Dr Kayliegh Cox-Novak, technical manager at Bond It tells BMJ.
ver the past 20 years the industry has been moving to a new European Regulation,
the Biocidal Product Regulations (BPR), previously the Biocidal Products Directive (BPD). The process has involved reviewing and assessing the available data on active substances such as efficacy, safety, and environmental characteristics. This is now being followed up by a re-assessment program as active substances require assessment every 5-10 years.
As this second phase commences many of the active substances our industry uses are not being supported for re-assessment. This is because, under REACH, many substances are being re-classified making re-assessment virtually impossible due to the constraints of the BPR or due to the huge expense of carrying out the support programs.
Throughout the review there
has been a maximum of 45 active substances which could be used as timber preservatives. Of the first 21 active substances to be re-assessed only 9 are supported for re-assessment - a reduction of more than 50% in the number of biocides available for timber. We all agree we should not be using chemicals which are dangerous to humans or the environment but hazard should be balanced against risk: a chemical may be hazardous but when correctly used the risk maybe low. This should also be balanced against the effects not having such products.
All biocides have unwanted effects on the environment but we should also consider the impact of not having a wide range of biocides for the preservation of timber. Lack of preservatives is likely to lead to timber rotting which will lead to an increased demand for new timber.
On the face of it this might
seem positive, growing trees is an effective way of removing and storing carbon (Carbon Dioxide) from our atmosphere. However, the process has knock on effects. Forests or plantations require the huge use of, usually arable, land, thereby reducing the availability of land for commercial farming. With an ever-growing population pressure is mounting considerably on food supplies.
Alternatively, trees could be planted in difficult to farm areas, but this increases the difficulty of logging and transportation which is likely to lead to further emissions of Carbon Dioxide from machinery and transportation. It can also result in the destruction of natural habitats.
We must also consider the impact of a smaller pool of timber preservatives. The outcome of this is likely to be an increased resistance to actives or products that are used today. The resilience of biological organisms is well documented and biocidal products can be rendered ineffective. The irony of increased resistance is it could force authorities to revert to actives or products which have previously been deemed too high risk for users and the environment. Another factor is a lack of choice. It is likely that more preservation work will need to be carried out by professional operators, assuming products can even be deemed safe for professional use. This raises the question as to whether there are sufficiently trained people or companies capable of carrying out such work.
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As the regulations are so tight it is likely that such works would be deemed highly specialised and command excessive prices for what is effectively a simple process. In many cases properties in poor state of repair are owned by those on lower or restricted incomes. The lack of availability of products in the DIY market could preclude those in such circumstances from affording the necessary works.
The timber treatment market, like all free markets, is based on supply and demand. Reducing the availability of alternatives results in less competition and increased prices, further putting pressure on those on lower or restricted incomes who require the use of timber treatments.
Properties falling into states of disrepair are known to cause respiratory health issues, leading to people needing medical care and increasing pressure on health services. Further to this, serious injuries could result from structurally unsafe buildings which owners cannot afford to repair. Biocides can be an important way of preserving historical buildings for their historical and educational value and enabling continued use. These buildings could be maintained or made good using modern materials but that would ruin the idea of “preservation”.
Finally, if company incomes are restricted due to lack of sales or business then they are inevitably going to look to reduce their single biggest overhead: employees. The loss of employees means a loss of knowledge, leading to more problems in the future. The BPR will impact on companies of all sizes, from the very small to the very large. BMJ
www.buildersmerchantsjournal.net September 2020
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