We are often asked whether a similar approach can be taken to conducting a risk assessment for a Biocidal product as for a plant protection product.
The first observation we would make is that biocidal product risk assessments have a high variability in approach in contrast to the generally more harmonised and prescribed approach taken to plant protection products risk assessments.
Given that biocidal products are very diverse in nature, it is crucial to identify the correct pathway for the risk assessments before starting. The BPR covers a vast range of Product Types (PTs) and, in turn, these PTs include a selection of application methods/packaging types, use locations (indoor/outdoor) and user categories. The first and most critical step in conducting the risk assessments becomes identifying the exposure scenarios for both the human health and the environmental risk assessments.
Consideration also needs to be given to the possibilities of aggregated/combined exposure, particularly given that non-professional use within living quarters can be of particular interest for biocidal product applications.
While guidance is available on the ECHA website, it is key to identify the correct guidance before starting work on the risk assessments, and even then any assumptions made regarding parameters to be input into the risk assessments need to be clearly justified. There are also some unusual cases/situations that are not fully covered by the guidance and therefore require more creative approaches that may combine information from alternative sources with strong justification.
At Kerona we are very experienced in conducting risk assessments for both biocidal products and plant protection products. For further information or to discuss your requirements contact Kerona Scientific at firstname.lastname@example.org
You may also be interested in the following upcoming webinars hosted by Kerona – Human Health Data Requirements and Risk Assessment under the BPR (3rd June 2020) and Environmental Risk Assessment under the BPR (10th June 2020). See www.kerona.ie/training for further details.