Analysis of the Proposed EU Regulation Concerning Biocide Products and its Opportunities for Alternative Approaches and a Toxicology for the 21 st Century

Abstract

On June 12, 2009, the European Commission adopted a proposal for a Regulation concerning the placement on the market and use of biocidal products, which, when it enters into force on January 1, 2013, will repeal and replace Directive 98/8/EC. The main reason for the revision of the current Directive was to promote best practices for environmental and human health protection, along with implementation of current developments in safety testing in order to create safer biocides. Moreover, the proposed Regulation aims to take into consideration the newest legislation on chemicals.
This article evaluates the proposed Regulation in comparison to Directive 98/8/EC. Although the new proposal requires the sharing of vertebrate animal test data, both for product authorization and for newly developed active substances, it misses – in contrast to REACH – the opportunity to recognize the accelerating development of alternative approaches to animal testing, most recently with new momentum provided by “Toxicity Testing for the 21st Century”, and to support the evolution of toxicology towards a new approach to testing. The new methods promise not only to decrease animal pain and suffering, but also to provide faster results and better prediction for human risk assessment compared to traditional methods. Unfortunately, methods mandated for human risk assessment in the proposal are still mainly based on traditional animal study extrapolation.
We put forward and discuss possible alternative strategies, such as in vitro testing, integrated testing strategies, toxicokinetics, “omics,” systems biology, bioinformatics, and computational modeling, all of which could be more encouraged by the proposal. Current opportunities to improve our tools for biocide risk assessment are discussed, delineating advantages, limitations, and development needs. It is suggested to open the proposed Regulation to alternative approaches that are based on human biology more than on extrapolation from animals to humans.