On 23 February 2004, Afsse received a solicited request from the French Ministries of the Environment and Health to prepare proposals for reducing consumer risks that may be adopted at European Union level.
This solicited request was presented to the Committee of Specialised Experts (CSE) on chemical substances which appointed an internal working group to address it. Two external experts (CAP - Centre anti-poison and INRS - Institut National de Recherche et de Sécurité) were included in the working group as they had contributed to the risk assessment report. After three meetings and an encounter with representatives of the manufacturers concerned, the working group presented an opinion to the CSE which was adopted unanimously. It is on the basis of this CSE opinion that the Afsset report was drafted and sent to the ministries concerned in December 2004.
Consumer exposure occurs mainly through the use of anti-moth products, toilet bowl fresheners and air fresheners. Updated information confirms the predominance of anti-moth use (75% of the market) and most cosumption occurring in southern European countries (France, Spain and Italy for the most part). The manufacturers consulted pointed out that the household applications market is losing speed, especially since p-dcb has been classed as a category 3 carcinogenic substance by Community bodies since April 2004. Moreover, it features in the list of active biocidal substances requiring a thorough assessment (Biocides Directive 98/8/EC) to keep its marketing authorisation. Its possible substitutes (such as pyrethrinoids which are already widely sold) will also be assessed.
Diverse categories of measures were examined: modification of packaging, reduced concentration in the preparations, information for consumers, restricted use for certain population groups, etc. These have been discussed by manufacturers and consumer associations.
In conclusion, it is recommended to ban:
p-dcb use in anti-moth products. This prohibition may only come into force once the assessment results of possible substitute products are known, in accordance with the Biocides Directive, i.e. at the end of 2007.
p-dcb in toilet bowl fresheners and air fresheners.
The very high toxicity in aquatic organisms and category 3 carcinogenic classification prompt a recommendation to ban these uses as well.