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Standing Committee on Biocidal Products 17 March 2017: vote on approval of three active substances

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[Deleted] Garry Wiles 1 year ago  
Dear Biocides active substances web community member The EU Commission is convening a meeting of the Standing Committee on Biocidal Products (SCBP) on 17 March to vote on the approval of three active substances, as follows: Silicon dioxide Kieselguhr; Pyrogenic, synthetic amorphous silicon dioxide, nano, surface treated; Dichlofluanid. More details of these active substances and the product types uses applying to these votes are in the recently uploaded document ''Table of active substances for approval at 17 March 2017 Standing Committee on Bioicidal Products'', which you can access via the 'What's New' page. If you wish to comment on any of these proposals, please reply to this discussion thread by Thursday 9 March. If you would like to let HSE have any information that is commercially confidential, you can send your comments to the email account at chemicalsconsultation@«hidden» Kind regards Garry Wiles Biocides active substances web community manager
Modified by [Deleted] Garry Wiles (1 year ago)
will douglas 1 year ago  

Diatomaceous earth / Kieselguhr:                                                                                                                                                  Is available in many forms for many uses varying by particle size/distribution,shape/sharpness,treatment, acid washing etc. This material should not be included under BPR actives and I cannot understand why the HSE or the relevant ECHA biocides committee has not contested the ruling made by the European court that so decided.   Killing by purely mechanical means was specifically excluded from the original BPD for good reason and many similar sharpness material would probably have a similar effect. I cannot see how art 95 suppliers can control such variables to 'achieve a specified efficacy. Such decision on inclusion in the BPR should be determined by the specialists with the biocidal field rather than learned amateurs /lawyers. 

This reflects my personal view and not that of the company I work for.

Will Douglas

will douglas 1 year ago  

Diatomaceous earth / Kieselguhr:                                                                                                                                                  Is available in many forms for many uses varying by particle size/distribution,shape/sharpness,treatment, acid washing etc. This material should not be included under BPR actives and I cannot understand why the HSE or the relevant ECHA biocides committee has not contested the ruling made by the European court that so decided.   Killing by purely mechanical means was specifically excluded from the original BPD for good reason and many similar sharpness material would probably have a similar effect. I cannot see how art 95 suppliers can control such variables to 'achieve a specified efficacy. Such decision on inclusion in the BPR should be determined by the specialists with the biocidal field rather than learned amateurs /lawyers. 

This reflects my personal view and not that of the company I work for.

Will Douglas