The Hidden Chemistry of Piramal Pharma’s “Tri-Activ”: A DHFL Victim Writes to Ajay Piramal

Posted on 13th November, 2025 (GMT 03:35 hrs)

ABSTRACT

This letter addresses Piramal Pharma’s Tri-Activ line of disinfectants, critically examining the disparity between the products’ marketed claims of “triple protection” and the documented human health and ecological risks posed by their chemical constituents, notably ethanol and benzalkonium chloride (BAC). Written from the perspective of a survivor of systemic corporate harm, it combines lived experience with peer-reviewed evidence to demand transparency, full disclosure of toxicological and environmental data, and remedial measures including independent environmental monitoring, responsible labeling, and extended producer responsibility initiatives. Beyond consumer safety, the letter interrogates regulatory ambiguities, corporate ethics, and the broader social and ecological consequences of commodified cleanliness, framing the correspondence as a civic appeal for accountability and moral stewardship in the pharmaco-industrial sector.

Introduction

The following letter is addressed to Mr. Ajay Piramal, Chairman of Piramal Pharma, concerning the company’s widely sold Tri-Activ line of disinfectants and cleaning products. It is written from the perspective of a citizen and survivor of systemic financial and corporate harm, blending lived experience with evidence-based scrutiny. The correspondence interrogates the gap between the marketing claims of “triple protection” and the documented environmental and health risks associated with the chemicals in these products. While technical in parts, the letter is intended for public reading, highlighting questions of corporate accountability, regulatory oversight, and ecological responsibility. Readers are invited to consider both the social and chemical consequences of everyday disinfectants that promise protection but may propagate hidden harms.

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To

Mr. Ajay Piramal,

The Chairperson,

Piramal Pharma

Subject: An offering you did not ask for — and an urgent demand for truth about Tri-Activ

Dear Mr. Piramal,

I write to you not as a lawyer or a journalist, but as one among lakhs who survived a financial collapse engineered elsewhere (DHFL), carrying scars that are both economic and corporeal. We learned, the hard way, that promises — of safety, of profit, of “care” — can be sold as absolutes while their costs are outsourced: to victims, to rivers, to bodies that cannot pay for their own cleanup.

I am sending you a Pseudo/Quasi-Pharmaco-Philosophical Reflection that we recently published: 

The Fallen Sceptre(s) Of Your Justice: Dirty My-Self and Piramal Pharma’s Tri-Activ⤡.

Read it, or do not. But if Piramal Pharma intends to keep marketing Tri-Activ as “triple protection,” you — its steward and public face — owe the people more than slogans, sanitizers, and invisible residues.

Below, I summarize — with clinical brevity and lived mistrust — the issues that demand your pharma company’s public response. The tone is one of grief as much as civic interrogation; the evidence is public, verifiable, and duly reviewed.

1. What you sell vs what it does — the rhetoric–reality mismatch

Tri-Activ SKUs (sprays, liquids, wipes, handwash, floor cleaners) circulate two principal chemistries:

• Ethanol (~70%) in sprays (listed as “Ethanol 95% v/v” on product panels). The choice of ethanol as the flagship active is not merely chemical but political: the ethanol supply chain in India has become enmeshed with the E20 biofuel policy promoted by Minister Nitin Gadkari and two of his sons⤡, which has blurred the line between green transition and greenwashed cronyism. Your well-documented proximity to the ruling dispensation led by the BJP intensifies public concern that pharma-corporate ventures and biofuel-industrial policies may be converging through shared political patronage rather than transparent environmental optics.
• Benzalkonium Chloride (BAC) in liquids, wipes, and handwash (disclosed as “Benzalkonium Chloride Solution 8% w/w,” equivalent to ~4% BAC in product).
  These are supplemented by propellants (butane/propane), surfactants, fragrances, and unspecified “Excipients Q.S.”

The marketing vocabulary emphasises “Triple Protection” and “Kills 99.9% germs.” What it omits is the downstream reality: BAC is environmentally persistent; ethanol aerosols contribute volatile organic compounds (VOCs); and propellants add to air pollution. The marketing language embodies the corporate-green transition, while the downstream chemical reality remains invisible.

(See PeerJ and PMC ecotoxicity studies; Particle & Fibre Toxicology inhalation data; recent PubMed reviews identifying BAC as an emerging contaminant.)

2. Human health risks you must acknowledge publicly

• Ethanol sprays are flammable and emit aerosols that irritate mucosa and respiratory tissue, especially in enclosed or poorly ventilated areas.
• Benzalkonium Chloride (BAC) has demonstrated pulmonary toxicity in animal inhalation models (intratracheal LD₅₀ in mice ~8.5 mg/kg) and severe outcomes in accidental human ingestion, particularly among children.
• Chronic dermal exposure to surfactants and fragrance additives can cause contact dermatitis and sensitisation.

Your labels and product pages describe some Tri-Activ variants as “household safe” and “dermatologically tested.” If so, please publish — in full — the toxicological dossiers that substantiate these claims: raw study data, peer-reviewed assessments, and not mere retail-level summaries.

3. Environmental and ecological accountability — rivers are not inert bins

BAC compounds adsorb to sludge, resist biodegradation, and enter aquatic systems where microgram-level concentrations can kill algae and disrupt food webs. QACs, including BAC, are also known to co-select antibiotic resistance genes — a public health risk beyond consumer perception. Every wipe flushed and every rinse drained contributes to this invisible but measurable ecological burden.

If Tri-Activ is sold as “protection,” who measures the protection’s “collateral damage” — to ecosystems, to rivers, to microbial balance?

4. Regulatory and ethical opacity

Your publicly available product sheets reveal major actives (ethanol %, BAC %) but obscure minor additives under “Excipients Q.S.” Safety Data Sheets (SDS) are referenced but not accessible from your consumer pages, and no independent verification of “kills 99.9%” claims is available.

In India, many disinfectants exist in the grey zone between consumer goods and regulated chemical hazards — a loophole that allows corporations (such as yours) to profit from fear while escaping accountability for environmental fate or long-term toxicity.

5. Concrete requests

I do not ask for theatre. I ask for facts — and for remedial measures proportional to the harms your products may reportedly cause.

Please, within one month of receiving this letter:
a) Publish full, unredacted Safety Data Sheets (SDS/MSDS) and the complete compositions (including excipients and their concentrations) for all Tri-Activ SKUs sold in India.
b) Release all internal toxicology, inhalation, dermal sensitisation, and environmental fate studies used to substantiate your marketing claims. If conducted externally, disclose raw data and lab reports, or confirm that independent peer-reviewed studies will be commissioned.
c) Commission and fund an independent, third-party environmental monitoring study (with oversight from the CPCB/State Pollution Control Boards and qualified university ecotoxicologists). This must not replicate the shortcomings of the Digwal Environmental Impact Assessment (EIA)—which, being prepared by Piramal Enterprises Ltd. in collaboration with M/s Pridhvi Envirotech Pvt. Ltd., amounted to a self-assessment devoid of independent scrutiny. That EIA merely echoed your corporate “green transition” rhetoric while omitting critical pollution data, exemplifying the corporate capture of environmental regulation. ⤡ ⤡) on BAC/QAC residues in at least three river basins downstream from high-sales urban zones, publishing results within six-seven months.
d) Institute an Extended Producer Responsibility (EPR) pilot for Tri-Activ packaging and residual product — including take-back systems for aerosols and refill stations — and report feasibility outcomes in your next CSR update.
e) Amend product labels and marketing to include clear acute risk warnings (inhalation, aquatic toxicity) and responsible disposal instructions.
f) Issue a public statement detailing what Piramal Pharma knew about BAC persistence and what measures it will take to reduce ecological dissemination.

Moreover, most of Piramal Pharma’s products are available over the counter (OTC) — requiring no doctor’s prescription. They exist in a grey zone of regulatory ambiguity and ethical indifference, more aligned with marketing theatrics than pharmacological legitimacy. These are formulations sold as science but driven by salesmanship, substituting data with design and ethics with advertising. One cannot help but ask: how can such an enterprise still call itself a “pharma company”? Is your real business simply producing raw materials or APIs, claiming pharmaceutical identity merely because you supply intermediates to companies that do the actual drug development? And then there is your “sourcing office” in Shanghai, China — an arrangement that, under the Sangh Parivar’s own ideological lens, would make you “anti-national.” Why are you ignoring your beloved Hon’ble Prime Minister’s “Boycott China” campaign, the same rhetoric used to police ordinary citizens and small traders? While nationalism is preached to the masses, your corporation continues to import, outsource, and profit across Chinese supply chains, revealing the hollowness of your Atmanirbhar Bharat posturing — a flag waved for optics, not principle.⤡

I recall that in September 2018, India’s Health Ministry banned 328 fixed-dose combination (FDC) drugs⤡ lacking therapeutic justification, including your Piramal Pharma’s popular Saridon⤡. The decision, based on safety and efficacy concerns, was soon challenged in court. The Supreme Court of India initially stayed the ban on Saridon and two other formulations, and in February 2019 formally exempted Saridon from the prohibited list, citing that its formulation predated the 1988 regulatory cutoff outlined in Union of India & Ors v. Pfizer Ltd & Ors. This exemption effectively allowed you to resume marketing Saridon despite the nationwide ban on hundreds of similar FDCs, underscoring the company’s regulatory leverage and proximity to state power in navigating pharmaceutical restrictions. This again proves you are more equal than others when it comes to getting “instant justice” (like instant noodles) for yourself.

6. Reparative moral asks (not legal claims, but civic duties)

• Fund local wastewater surveillance and cleanup initiatives in at least two river catchments with high consumer runoff.
• Sponsor community health clinics in localities with high occupational and domestic exposure to disinfectants.
• Support open-access research into low-toxicity, refillable, and biodegradable cleaning alternatives for India.

A note on tone:
Sarcasm is my only available disinfectant in a market where “care” has become commodified performance. I was a DHFL victim. I know how institutions transmute human suffering into accounting entries. But this is not an attempt to shame you personally; it is an attempt to compel your corporate machinery to meet the moral standard it advertises as “protection.”

If you wish to respond, have your environmental officer, product safety head, and external toxicology lead address these items publicly in writing. If you do not, silence will be interpreted as corporate evasion. The rivers will not wait for PR cycles.

Finally, I have to say that I offered my essay not as an indictment alone but as an invitation — to reclaim fallen sceptres of justice, to trace the continuity between financial and pharmaco-industrial predation, and to ask: when does cleanliness become complicity?
Cleanliness that poisons is not cleanliness.
Protection that manufactures risk is not protection.
Justice — fallen as your sceptres are — can be reclaimed only if corporations show the courage to tell the whole chemical story.

Hypothetically Yours,

नमस्ते अस्तु मा मा हिंसीः

लड़ेंगे या मरेंगे!

इंक़लाब ज़िंदाबाद!

No Pasaran! 

Debeprasad (sic) Sadhan (patriarchal insertion) Bandopadhyay (sic)

Appendix — Selected evidentiary citations

(Public, peer-reviewed sources substantiating toxicity and ecological claims.)

• Eleršek T. et al. Ecotoxicity of disinfectant benzalkonium chloride and its mixture with 5-FU. PeerJ/PMC. https://pmc.ncbi.nlm.nih.gov/articles/PMC6011824/
• Choi H.Y. et al. Assessment of respiratory and systemic toxicity of Benzalkonium chloride: 14-day inhalation study in rats. Particle & Fibre Toxicology (2020). https://particleandfibretoxicology.biomedcentral.com/articles/10.1186/s12989-020-0339-8
• Liao M. et al. Risks of BAC as emerging contaminants. PubMed (2023). https://pubmed.ncbi.nlm.nih.gov/37862750/
• Pereira B.M.P. et al. Benzalkonium chlorides: Uses, regulatory status, and microbial resistance. PMC (2019). https://pmc.ncbi.nlm.nih.gov/articles/PMC6581159/
• Piramal Pharma — Tri-Activ Homecare Product Listings (Wellify.in, accessed Nov 2025):
  “Ethanol 95% v/v (~70%), Benzalkonium Chloride Solution 8% w/w, Propellant Butane/Propane, Excipients Q.S.; marketed as ‘Triple Protection’ and ‘Kills 99.9% germs.’” 

Copy to:

1. Shri A.H. Laddhad, Hon’ble Prothonotary and Senior Master, Bombay High Court (With reference to Case No. S/42/2025)
2. Hon’ble Secretary, Ministry of Environment, Forest and Climate Change (MoEFCC)
3. Hon’ble Chairman, Central Pollution Control Board (CPCB)
4. Hon’ble Chairman, Telangana State Pollution Control Board (TSPCB)
5. Hon’ble Secretary, Ministry of Health & Family Welfare
6. Hon’ble Drugs Controller General of India (DCGI)
7. Hon’ble Director, National Institute for Research in Environmental Health (NIREH), Bhopal
8. Hon’ble Head, Department of Environmental Science, University of Hyderabad
9. Hon’ble Chief Information Commissioner, Central Information Commission (CIC)
10. Hon’ble Comptroller and Auditor General of India (CAG)
11. Hon’ble Chairperson, National Human Rights Commission (NHRC)
12. Hon’ble Office of the United Nations High Commissioner for Human Rights (OHCHR)
13. Hon’ble Executive Director, United Nations Environment Programme (UNEP)

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