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Editor-in-chief: Maurizio Roncaccia
Editors: Paul Trouth and Päivi Jokiniemi
Article related to: Biocides
Harmonising biocides enforcement - what to expect?
The Biocidal Products Regulation Subgroup (BPRS) works under the umbrella of ECHA’s Enforcement Forum to improve and harmonise biocides enforcement activities. We met with Francesca Ravaioli, Vice-Chair and the Italian representative in the subgroup, to find out why the group is needed and what future activities are planned.
Harmonisation adjusts inconsistencies in different practices, schedules and procedures to make them mutually compatible. This is what the subgroup aims to do for biocides enforcement throughout Europe.
Francesca Ravaioli. Image: Francesca Ravaioli.
Its members are representatives of national enforcement authorities, who want to develop synergies, share experiences and identify tools to exchange information. The group has also already decided to join some of the enforcement projects established by ECHA’s Enforcement Forum, originally set up to enforce REACH and CLP.
Why harmonised enforcement is needed
Harmonised enforcement of the Biocidal Products Regulation (BPR) helps to make the interpretation of the regulation consistent at national level. This, in turn, leads to increased legal certainty for companies.
“Public health, environmental protection and fair competition between companies have to be guaranteed and, to do this, harmonised enforcement plays a key role. Harmonisation also helps the Member States roll out high-quality enforcement activities,” Ms Ravaioli explains.
Thanks to the subgroup, national enforcement authorities will now be able to rely on the help of enforcement experts, who will debate and share best practice on controlling biocidal products.
“The challenge is that we don’t have a universal interpretation for the term treated article, which makes it very complex and not always easy to apply,” she says.
The term can also be difficult for companies to understand. “I encourage companies to let the subgroup know if they are uncertain whether something is a treated article. The subgroup can help to assess the product’s characteristics,” Ms Ravaioli points out.
Focus on the critical product-types
It is also important to pay attention to critical product-types, such as disinfectants, preservatives and pest control products. The main concerns are related to harmful effects on both human and animal health as well as on the environment.
“The use of such hazardous product-types by children and pregnant women will be in our focus, as prolonged exposure is particularly critical for these vulnerable groups,” she says and continues, “children up to five years old are most likely to be exposed and commonly used products, such as disinfectants, are linked to many of these incidents,” she adds.
Focus on sharing best practice
But, how will the subgroup actually put harmonised enforcement of biocides into action?
“First of all, we will focus on identifying best practice for enforcement in the Member States. We will also prioritise our activities and concentrate on training national coordinators and providing tips and advice for inspectors to improve their competencies,” Ms Ravaioli tells.
The subgroup will organise the ‘Training for enforcement trainers’ on the BPR, which will likely already take place in 2018.
As it is part of ECHA’s Enforcement Forum, it is only natural for the subgroup and the Forum to collaborate on certain projects. One of the joint projects is REACH-EN-FORCE-6, which focuses on the classification and labelling of biocidal products.
“The subgroup will produce the coordinated enforcement project’s manual containing a guidance document, checklist and recommendations on how to execute the project,” Ms Ravaioli explains.
In general, the subgroup encourages more effective interaction between national and European levels. “Issues related to enforcing the requirements for biocidal products at national level can be instantly reported at EU level through the Forum Secretariat, which immediately alerts the subgroup’s members. This also inspires members to communicate with each other between the plenary meetings,” Ms Ravaioli explains.
Implementing the Portal Dashboard, ECHA’s IT tool, is also high on the agenda. The tool would allow national inspectors to access and share inspection data submitted to ECHA. To enable national and European actors to interact more, the subgroup will discuss how to collaborate with stakeholders more in the future. Stay tuned!
Biocidal Products Regulation Subgroup (BPRS)
The Biocidal Products Regulation Subgroup is part of the ECHA Forum for Exchange of Information on Enforcement. In practice, it is a parallel composition of the Forum with members specialising in the Biocidal Products Regulation (BPR).
Each EU Member State has at least one representative in the subgroup – some are the same as in the Forum.
The subgroup has regular meetings in connection to the Forum meetings three times a year.