Advisory Committee on Pesticides Annual Report 2001

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Section E: UK Review Programme outstanding issues concerning data to support the assumptions in the alternative exposure model and practices at UK treatment plants. The <strong>Committee</strong> noted that the main concern was contamination of the ground, from excess treatment solution running off newly treated timber and rain washing solution from newly treated timber. The <strong>Committee</strong> recognised that, although treatment sites were originally built to high standards, some were not maintained and there was cracking of bunds and concrete floors. In addition, a survey conducted on HSE’s behalf had reported that freshly treated and dripping timber was frequently stored outside the contained area. The <strong>Committee</strong> considered approval holders’ proposals to address these concerns. It agreed that the newly proposed exposure scenario for industrial wood preservation products was acceptable for CCA, subject to the submission of specific data to address the inhibition of respiration in sewage sludge micro-organisms, data on the bioavailability of metals in the water column and the issue of sediment toxicity, data to support a reasonable worst-case usage level for CCA at UK installations and UK data to support a reduction of the presumed emission from treatment plants from one percent to 0.2 percent. The <strong>Committee</strong> also agreed that the labels of CCA industrial wood preservation products should include the additional phrase: 55 TREATED WOOD MUST BE HELD FOR LEAST 48 HOURS AFTER TREATMENT AND UNTIL SURFACES ARE DRY WITHIN A BUNDED AREA ON A SITE WHICH IS MAINTAINED TO PREVENT LOSS OF TREATMENT PRODUCT TO THE ENVIRONMENT. The <strong>Committee</strong> welcomed the proposals for an industry-led awareness campaign across the whole industrial wood preservation industry to reduce emissions to the environment. Dichlorophen Dichlorophen and sodium dichlorophen are used in approved herbicide/fungicide products registered with PSD and HSE. In 1998, the ACP had agreed that approval holders for amateur surface biocides containing sodium dichlorophen should consider the feasibility of reformulation to negate the requirement for products containing 40 g/l or more to be labelled ‘Risk of serious damage to eyes’. It also had identified a number of data requirements with respect to the physical chemistry, mammalian toxicology and environmental hazard of dichlorophen/sodium dichlorophen. Two years were allowed for the provision of these data.
<strong>Advisory</strong> <strong>Committee</strong> on Pesticides Annual Report 2001 The <strong>Committee</strong> now considered reports submitted by the manufacturer and one approval holder to address the feasibility of reformulation and/or repackaging of non-agricultural products containing dichlorophen/sodium dichlorophen. It also considered the progress made with the other data requirements it had identified. 56 The <strong>Committee</strong> noted that the company that supplied sodium dichlorophen for use in biocides had provided some data but had not complied fully with the data requirements. One approval holder had expressed concern at the apparent lack of response and indicated that it would be willing to support dichlorophen by generating the missing data itself, if the <strong>Committee</strong> agreed to allow it the time to do so. Subsequently the supplier had made a similar appeal for extra time to generate data. The <strong>Committee</strong> agreed that the supplier’s submission was deficient in a number of aspects and although the company had cited both animal welfare and economic considerations, its response was unacceptable. The <strong>Committee</strong> considered that this company should not be allowed an extension to the deadline for addressing the data requirements and that approval for products reliant on support from it should be revoked. The <strong>Committee</strong> noted that the majority of enquiries and incidents relating to dichlorophen that had been reported to centres of the National Poisons Information Service around the country involved access by young children to veterinary worming tablets. Only two incidents in recent years had involved eye contact with a dichlorophen-containing product and at least one of the adults concerned had suffered no long-term effects. For the other no details were available. As no major toxicological concerns had yet been identified, the <strong>Committee</strong> agreed to allow the specific approval holder extra time to generate the missing data. However, the approval holder would need to provide an early commitment to fulfil the requirements and adhere to a strict timetable. The <strong>Committee</strong> then considered the reports on the feasibility of reformulation of the single product marketed by this approval holder. It appeared that a more dilute concentrate of product was not a viable option due to the large volumes that would then be needed for a single treatment. The <strong>Committee</strong> had previously agreed that, where eye protection was considered necessary, amateur use of a product would not be permitted. However, the apparent lack of incidents related to use of this product reassured the <strong>Committee</strong> that eye protection was not necessary. The company had reported on progress with reformulation and had explored three options, each of which posed some
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Advisory Committee on Pesticides Annual Report 2001

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