It is recognised that microbial cleaners represent a novel type of product which does not smoothly fit into EU chemical, detergent or biocide legislation. The same may be true for other EU legislations, too. The applicability of either of these legislations might well depend on the particular product use and claims, thus, the adaptability of all three legislations should be further clarified. Alternatively, a specific regulation should be established tailored for these products to provide for regulatory oversight of environmental and health risks. In the absence of such a regulation, the observed differences in terms of quality assurance, hygiene and risk assessment might continue, which could potentially lead to products which differ markedly in terms of efficacy, hygiene and even safety. Regulatory oversight would require developers to provide safety-relevant information in a harmonised and systematic way. Regulatory oversight would also be in the interest of producers, as approved products or notifications also represent a reassurance for new clients or users. It will be important to carefully balance the risk assessment requirements, otherwise this might be detrimental for the many SME-type developers.
Prospects for genetically modified micro-organisms in cleaning products
This survey revealed no indication that producers of microbial cleaners are developing genetically modified (GM) micro-organisms tailored for the use in cleaning products. Almost all producers of microbial cleaners are of SME type and it can be assumed that the development and market approval of genetically modified micro-organisms is too costly and the time to market - if successful at all - could easily take a decade. Moreover, the deliberate release of living GM micro-organisms is still lacking consumer/regulatory acceptance. In the related field of bioremediation, there is quite some research ongoing to enhance “cleaning” properties of micro-organisms by using GM techniques (oil spills, etc.) (see Chapter 8). A spill-over to microbes used in cleaning products can be expected once GM micro-organisms are considered more acceptable to be used in the environment.