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The Health and Environment Alliance (HEAL) welcomes the opportunity to provide comments in the context of ECHA’s public consultation on potential derogations to the BPR exclusion criteria regarding the use of creosote as a wood preservative (PT 8). Creosote is classified as a carcinogen category 1B, a reprotoxicant category 1B, as well as PBT/vPvB substance.
As such, it fulfils several of the exclusion criteria laid out in article 5 of the Biocides Product Regulation (BPR), namely (a), (c) and (e). Creosote is also classified under category 1 acute and chronic toxicity to aquatic organisms.
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