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Derogations under the Detergents Regulation

Derogations under the Detergents Regulation. Stephen Pickering. Biodegradability requirements. Ultimate biodegradability Ultimate biodegradatation = breakdown to CO 2 , H 2 O, mineral salts and increased biomass (Primary biodegradatation = loss of surfactant characteristics)

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Derogations under the Detergents Regulation

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  1. Derogations under the Detergents Regulation Stephen Pickering

  2. Biodegradabilityrequirements • Ultimate biodegradability • Ultimate biodegradatation = breakdown to CO2, H2O, mineral salts and increased biomass • (Primary biodegradatation = loss of surfactant characteristics) • Criterion for ultimate biodegradability: 60% in 28 days • Same criterion applies to all types of surfactant i.e. ionic, anionic, cationic and amphoteric

  3. Derogation decision tree

  4. Granting of derogations Derogations may be granted if: • Used in low-dispersive applications • Used in specific I&I applications only • Risk to environment is small compared to socio-economic benefits (the availability of alternatives is no reason to refuse a derogation) - Derogations may allow, limit, or severely restrict use. - Restrictions may include a phase-out period.

  5. Derogation granted: Dehypon G 2084 • Alcohols, Guerbet, C16-20, ethoxylated, n-butyl ether (7-8EO) [Dehypon G 2084] for: • Bottle washing (160t/year) • Cleaning-in-place (40t/year) • Metal cleaning (40t/year) Commission Regulation (EC) No 551/2009

  6. Characteristics of Dehypon G 2084 • Primary biodegradability 95% in 19 days the metabolites are: • n-butanol • ethoxylates • guerbet alcohol • Ultimate biodegradability of 42% in 28 days

  7. Tiered approach to testing Tier 1: worst-case assumptions. No specific knowledge of metabolites needed. Tier 2: basic understanding of metabolites. Assessment of mixture of data + interpolation. Tier 3: full knowledge of metabolites. Full risk assessment.

  8. Toxicity testing of Dehypon G 2084 • Toxicity testing • algae • Daphnia acute • Daphnia chronic (most sensitive: NOEC 0.1 mg/l) • fish • PEC/PNEC <1 with safety factor 100

  9. Reasons for derogation • Request for three named uses evaluated by German competent authority which found: • Uses are low dispersive • The uses are industrial • No risk to the environment as the surfactant poses no risk (lack of toxicity) and its metabolites are not persistent

  10. Opinion of the Committee • Committee agrees with German evaluation but notes that only partial information is available on the toxicity of the metabolites • Committee notes that no suitable alternatives are available • Committee decides to limit the duration of the derogation to 10 years to encourage development of alternatives

  11. Other applications for derogation A small number of other applications for derogation were made (in France and Sweden) but those were subsequently abandoned: • one use was found to fall outside the scope of the Regulation (fuel additive) • for the others only incomplete dossiers were submitted before the deadline and the application automatically lapsed

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