Recommendations for making the European Commission's Safe and Sustainable by Design framework practicable for biocides

Abstract

The European Commission has published a framework on Safe and Sustainable by Design (SSbD) to minimize the adverse impacts of chemicals and materials. Biocides are an important group of active substances with an intended effect on organisms that are widely used, both professionally and by the general public. With their intended effects on organisms, biocides represent a group of chemicals for which the SSbD framework presents particular challenges. As they intentionally feature harmful properties to provide a societal benefit, a special approach is needed for biocides to assess their safety and sustainability. Thus, we propose biocide-specific amendments to the SSbD framework to address these challenges, allowing a more balanced assessment. First of all, we suggest the inclusion of specific questions within the scoping analysis. In addition, a circular approach with central aspects is recommended for the assessment to facilitate an iterative improvement of safety and sustainability considerations for biocides. The central aspects include purpose, functionality and efficacy. Additionally, specific recommendations are provided for safety and sustainability individually, including the first proposals for biocide-specific aspects in the social impact assessment step; encompassing both societal needs and impacts (positive and negative aspects) and a socio-economic life cycle assessment. It is advisable to establish a feedback loop between societal needs and impacts and the intrinsic hazard assessment, which involves balancing the hazard with the functionality of the investigated biocide. Some suggestions from this study may also apply to other active substances, chemicals and materials, serving as general recommendations for the SSbD framework.