ECHA Launches Consultation on 22-Dibromo-2 Cyanoacetamide DBNPA

On September 18, 2024, the European Chemicals Agency (ECHA) launched a public consultation on 2,2-dibromo-2-cyanoacetamide [DBNPA]. European authorities have determined that DBNPA has endocrine disrupting properties, which means that it meets the exclusion criteria present in Article 5(1)(d) of the Biocidal Products Regulation (EU) No 528/2012.  

Risk Assessment and Approval Considerations for Product Type 12 

Despite its classification, the risk associated with the use of DBNPA in Product Type (PT) 12 applications has been assessed as negligible and manageable. Consequently, in the absence of technically feasible, economically viable, and less hazardous alternatives, approval of DBNPA for PT 12 may be considered under Article 5(2). A key factor in this decision is the availability of suitable alternatives. A confidential Analysis of Alternatives (AoA) was carried out to evaluate potential substitutes for the main uses of DBNPA in PT 12, a summary of which was provided for ECHA's Public Consultation, while the complete AoA remains confidential. 

DBNPA for Product Type 12 

Product Type 12 (PT 12) encompasses biocidal products specifically designed as slimicides, which prevent or control the growth of slime on materials, equipment, and structures in industrial processes. Consequently, the use and handling of DBNPA within this category is limited to industrial settings and trained professionals. 

Applications and Alternatives Assessed in the AoA 

The AoA evaluated specific applications of DBNPA in PT 12, including its use for biofouling and biofilm control in Reverse Osmosis (RO) and Nanofiltration (NF) membrane systems for industrial water production, as well as for microbial control in pulp and paper additives, mixtures, and coating systems. 

Although the technical requirements for these applications are similar, the AoA separately identified and assessed potential alternatives for DBNPA in RO/NF systems and in paper production. This evaluation considered the required technical and functional properties, performance, hazards and risks, as well as the availability and economic viability of the alternatives. 

Health and Environmental Risks of DBNPA 

According to the information provided by ECHA, DBNPA is fatal if inhaled and toxic if ingested. It poses a risk of organ damage with prolonged or repeated exposure and is highly toxic to aquatic life, with long-lasting effects. Additionally, it can cause severe eye damage, skin irritation, and may trigger allergic skin reactions. 

Consultation Deadline  

The consultation on DBNPA will close on November 17, 2024.