EuroWindoor feedback to the public consultation on derogation to the exclusion criteria for Propiconazole (July 2022)

EuroWindoor represents the interest of window and door manufacturers all over Europe, including wooden products. In this regard, we have a comprehensive view of production processes and of the technologies available to protect wooden frames from biological attacks (blue stains, white rot, brown rot, insects).

Propiconazole is currently used as the main active substance in biocidal products for wood preservation of window and door frames due to its high efficacy spectrum, even at low concentration. Its unique efficacy against all main fungi makes it an essential component in the long lifespan of wooden windows and doors. Further evidence of the role of Propiconazole for the window and door industry can be found in the CEI-Bois – EuroWindoor – SBS joint position [1].

EuroWindoor believes Propiconazole meets the 3 derogation criteria simultaneously, as explained in the below statements.

1. Feedback on derogation of Article 5 2. (a), (b) and (c) of the BPR

(a) Risk from human, animal and environmental exposure to the active substance

Regarding the risk for human exposure

Risks for human health essentially occur at 3 different levels: risk for industrial workers (e.g. within impregnation plants), risk for professional workers/craftsmen (in workshops or on construction sites) and risk for end-users (during the lifetime of the treated product). Regarding the exposure risk for industrial workers, the industry already has in place a series of risk management measures: 1. All industrial impregnation processes used by the window and door industry are performed in closed loop systems (e.g. spray tunnels) or in dipping tanks where excess liquid is recycled. By design, these systems do not allow the spread of biocidal product containing Propiconazole into the rest of the plant, therefore protecting workers from direct exposure.  Any direct contact for workers is prevented by avoiding any spillover or splashing into other surfaces of the plant. 2. In order to ensure the use of proper Personal Protective Equipment (PPEs), the CLP regulation (Classification, Labelling and Packaging) sets requirements for all workers in charge of handling and maintenance operations. These are required to use PPEs as soon as they need to handle treated articles or to proceed to maintenance operations on the impregnation lines (especially hand and skin protection).  Workers in charge of maintenance and cleaning processes of wood impregnation installations must use adequate PPEs to limit the risk of skin or inhaling exposure. In addition, and as stated in the Biocidal Product Committee’s (BPC) opinion [2] on Propiconazole, “with regard to human health exposure, the risk related to primary exposure is considered acceptable with a conventional risk assessment (excluding ED properties) for industrial and professional users when appropriate personal protection equipment (PPE) are worn”. Regarding the exposure risk for professional workers and craftsmen: As for industrial use, the CLP regulation – via the mandatory publication of Safety Data Sheets (SDS) – requires producers of biocidal products to inform professional users about the appropriate equipment to wear while using a specific product. The use of PPEs therefore becomes mandatory for wood treatment applications (e.g. brushing) in accordance with relevant material safety data sheet.

EuroWindoor feedback to Consultation on derogation to the exclusion criteria for Propiconazole CZ

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