CEPA #TheGoodPestManager (the association of the professional pest management industry in Europe - see box at end), welcomes the possibility to take part in the consultation on a toxic-free environment in relation to the Chemical Strategy for Sustainability. While this consultation focuses on the REACH Regulation, we believe it is relevant for us to provide our input, as inappropriate precedents could be set that may in future influence the evolution of the Biocidal Products Regulation. The latter regulates products that are a necessary part of an efficacious toolbox used by professional pest management operators for controlling pest infestations that present a threat to public health. Furthermore, certain ingredients used in mixtures for biocidal products are covered under REACH
CEPA strongly advocates the practice of Integrated Pest Management (IPM) as the most effective way to sustainable pest management. In this context, our members always start from the premise that alternative pest management techniques should be adopted, with the use of active substances/biocides as the last resort for solving a pest-related problem. With this spirit, our sector has successfully worked in recent years to carefully control and reduce usage of chemicals in our operations.
Information on critical hazard
The information provided by manufacturers on critical hazard is already very complete. We ensure our staff is trained to understand it. Though additional information is welcomed, it should be provided using a risk-based approach and focus on the information that is essential.
Data collection on usage and exposure to active substances
It is suggested in the consultation that end-users of active substances might be required to provide usage and exposure data to the European Chemicals Agency.
The pest control sector is 90% composed of small- and medium-sized enterprises, many of them being even micro-enterprises with less than 10 employees. Any additional requirement will present a significant and costly administrative burden on them and should, therefore, be avoided.
In relation to data on operator exposure to active substances, products are applied when strictly necessary in accordance with label instructions by trained professionals that are aware of the nature of the products they are using. In consequence, exposure will in practice be null or at safe levels. Therefore, CEPA does not deem it necessary for end-users to collect such data.
Notion of “essential use” in the specific context of active substances and pest management
Professional pest managers make use of a range of preventive measures and treatments adapted to the varying pest management challenges and contexts that are encountered in practice. A combination of solutions is often used to achieve the essential objectives of pest control, which is the protection of public health and private property. However, not all of these solutions can be applied in practice and/or at scale in every situation. When active substances are deployed by trained professionals, this is done in a safe, precise and efficacious manner.
Activities of professionals are already subjected to European and national specific requirements, special risk mitigation measures, prohibitions and use restrictions to ensure that active substances are only administered where necessary and justified. Therefore, any “generic” and/or “automatic” restriction would be disproportionate. We strongly believe that the pertinence of the usage of biocides (i.e. when and where their use is essential) should be left to trained professionals, based on:
- their extensive practical experience in managing (often growing) pest populations in specific local contexts on a daily basis; and,
- their full understanding of – and commitment to – an Integrated Pest Management approach.
Nonetheless, if an “essential use” notion was to come to light and include biocidal products (and/or the ingredients used to produce these products) in the future, it should be based on the following principles:
- “Essentiality” should be based on actual risk presented in practice and not determined uniquely by the hazardous quality of the chemicals.
- The assessment should be made application-per-application and not based on broad (and, possibly, arbitrary) categories.
- A thorough consultation with relevant stakeholders, including the actual end-users of these substances should take place early enough in the decision process to ensure that the practical realities of pest management are taken fully into account.
Conclusion
CEPA recognises that use of active substances must be safe and sustainable, reducing and minimizing risks to human health and the environment from biocidal products, while also ensuring that the parallel risks presented by pest populations are equally reduced or minimized. This association is constantly striving to reach these goals, notably via its CEPA Certified certification scheme for professional pest managers, its Memorandum of Understanding that aims to spread IPM practices across Europe and its various initiatives to promote the professionalization of the sector.
CEPA and its members would be delighted to contribute further with their knowledge and expertise to support the European Commission in putting in place fit-for-purpose legislation.