Document 93qkE03D9Op9rxrzeY74YL5Qp

organisation for economic COOPERATION AND DEVELOPMENT ' - RESTRICTED Paris, 29th November 1972 ENV(72)27 Scale 2 Or. Eng./Fr. ENVIRONMENT CO' PIITTEE POLYCHLORINATED BIPHENYLS: KIOPOSAIS FOR CONCERTED ACTICil 1. At its meeting on 24th-26th November 1972, the Sector Group on Unintended Occurrence of Chemicals in the Environment considered draft proposals for concerted action regarding ` PCBs, as outlined in* ITR/ENV/72.51- The Group agreed the text in the attached document, paragraph 14 of which contains a proposal for action by the Environment Committee and Council. ' 2. It should be noted that these proposals are in conformity with the conclusions of the Consultation meeting on PCBs held on 3rd October 1972, where it was unanimously agreed that PCBs should not be used in circumstances which could result in their escape to the environment. Consequently . it was desirable to establish a common policy framework throughout the OECD membership regarding the acceptable uses of PCBs under specified conditions. 3. When examining the conclusions of the Consultation meeting the OECD Council requested the Environment Committee to take appropriate measures in order that the Sector'Groupfs proposals be submitted to the Council for consideration before the end of 1972 if possible. At its !3th session on 8th-10th November 1972, the Environment Committee noted " the Council's recuest and agreed that once the proposals had been finalised by the Sector Group they should bo sent to the Environment Committee for comment within 15 Gays after which, should no major criticisms be made thereon, the proposals would be submitted to the OECD Council. ACTION REQUIRED: "Members of the Environment Committee . are invited to comment in v/riting on . the attached document before . 13 th .December, after which date the . proposals therein will be submitted ' in an appropriate form to the OECD Council. osiv 197225 Miff I STLCOPCB4051895 3 - ENV(72)27 SECTOR GROUP Oil UMIITTBMDDD OCCURRENCE CF CHEI ilCALS III THE ElTVIRQ!ETENT Polychlorinated Bi-phenyls Proposals for Concerted Action INTRODUCTION 1. Polychlorinated biphenyls (PC3s) are a group of stable substances comprising theoretically more than 200 individual' compounds, many of which are widely used particularly because of their dielectric properties and non-flammability. At present ' they are obtained through chlorination of diphenyl, resulting in mixtures that arc characterised by their average content of chlorine. Due to the persistence and toxicity of some of these compounds, effects have been observed in the environment end accid.ents reported over the last few years, which have given rise to serious concern in Ilenber countries. In view of this concern, the Sector Group on Unintended Occurrence . of Chemicals in the Environment has investigated, on a priority basis, the need for, and feasibility of, concerted action to control the use and emissions of PCEs. The results ox- this enquiry, which have been presented in document MR/EMV/72.49, lead to the following conclusions : a) Because ox unacceptable levels of PCEs found in the environment and because of a number of incidents involving human health, some countries have taken, or are conside ring tailing action to control the use of PCEs; .' fc) There arc (1972) only six companies in OECD Ilenber countries that manufacture PCEs; four of them have alrecfy taken steps to reduce production to the supply for a few approved uses; c) PCEs can bo replaced except for some uses where their dielectric properties and non-flammability are essential; d) The technology for destruction of PCEs exists; e) Because of the many applications of PCBs in the wide range of consumer products moving in international trade, the situation will almost certainly become complicated unless international agreement is reached on allowable uses; DSVM 191226 STLCOPCB4051896 :rr/(72)27 -4- f) A rough estimate* indicates that consumption of FCEs in OECD countries is matched by production. Considering in addition that import of chemicals from- non-OECD to OECD countries is still restricted to basic chemicals, import of bulk PCEs is unlikely. It is';, therefore, reasonable to suggest that the major part of the problem of unin tended occurrence of PCBs can be solved through concerted action between OECD Member countries. USES OF PCBs 2. The applications of .PCBs fall mainly into two categories : - uses in closed systems - dissipative uses. Closed Systems 3. The use of PCBs in closed systems can be defined as application from which the PCBs are recoverable. PCBs in transformers, capacitors, heat transfer systems, hydraulic equipment, and vacuum pumps are in principle recoverable, since during use, the PCBs are not generally dispersed into the environment. 4. It is, hov.rever, important to distinguish between closed system uses that are controllable in practice and those whore control ennnot be guaranteed either < - because frequent replacement of relatively small quantitief will lead to disposal rather than recovery, or - because a large number of snail units widely dispersed will make collection extremely difficult, or - because accidental leakage will cause imminent danger to human health. 5. A truly controllable use may therefore be defined as an application where - the PCBs are contained in a sealed circuit in large, long life units, - the quantities involved are such that there is an incenti\ for regeneration,. ,___ _______ , * Production in. 1971 amounted to about 48,400 metric tons and consumption in the 13 countries that provided numerical infor mation to about 35,300 tons; assuming that, consumption of PCBs . is likely to be in some measure proportional to GMP, consumpti . in the other ten countries (Austria, Denmark, Greece, Iceland, Ireland, Italy, Japan, Luxemburg, Soain, Turkey) would be in .. : ~ ">' ''On . `' STLCOPCB4051897 5 J-.1N v v / a J c. ( 6. Following what has been said above, the only truly controllable uses of PCBs are in dielectrics'for transformers and for large_car)Citors for power factor correction. Preventing . escape~ox~PCIs Iron these applications is mainly a problem of engineering design and of collection and destruction ox used liquids, or, in the case of capacitors, of removal and destruction of PCB-inpregnated material. These uses also being essential for safety reasons, it would be unreasonable to suggest that they be discontinued at the present time. 7. In all other closed systems, recovery of PCBs, although _ theoretically possible, would not be practical. Such appli cations should, therefore, be discontinued, unless safety requirements prevent the use of substitute products : (i) Heat_transfer_systems ' There may be some installations where the risk of explosion or fire must be avoided at all cost, and the danger of some escape of PCBs therefore is of less importance. Eecause of the risk of leakage, which can never be totally guarded against, the use of PCBs as heat transfer media in the food, drugs and feed industries should, however, be prohibited. . (ii) Hydraulic equipment, vacuum_pumps Although the quantities involved in the individual case are relatively small, they will, unless recovered, add significantly to the environmental burden of PCBs. Theoretically, used fmids could be recovered, but in view of the difficulty of establishing a system to collect small quantities from many users, these appli cations should be discontinued.. Furthermore, PCBs are generally not essential in hydraulic and pumping fluids, with the possible exception of hydraulic equipment in underground mining. , (iii) Snail capacitors These are typical examples of an application of PCBs in sealed units that are almost completely non-recove- rable. Considering, for example, the many domestic electrical appliances in which capacitors are used, the cost of recovery would probably be prohibitive. A warning label showing that the equipment must not be disposed of as ordinary waste has been suggested; it is . - however, not likely to be sufficient, unless manufactu rers and. retailers would accept return of appliances that are out of use. The problem remains unresolved at the present time, but it has to be noted that one country has already banned the use of PCBs in the manufacture of - small capacitors. --____ Svv 191228 STLCOPCB4051898 EUV(72)27 -6- Dissipative Uses .' The dissipative uses are those where recovery of used PCBs is not possible, since they are not contained in closed systems but in direct contact with the environment , (i) The conditions under which these oils are used are suchthat there is continuous emission of small quantities into the environment. These applications, not being essential, should be discontinued; (ii) Pesticide Use . ' This use has fortunately been abandoned in most countries already; if not, it should be banned with immediate effect. Since all OECD countries require registration of pesticides, such a measure can easily be taken under existing legislation; (iii) Plasticizers 1 . The most important category, by volume, of dissipative use is in the field of plasticizers. They are or have been used in most countries in a wide variety of consumer products including paints, inks, copying paper, adhesives, sealants, plastic products, etc.., many of which are traded internationally. The major applications seem to be in the printing and paint industries. The_Printing Industry : Because of the risk ox contamination oi~paper,which alter recycling may be used in food packaging, the use of PCBs in the printing industry shoula be banned. In view of the fact that printing inks can be produced 'without PCBs and that in any case the production represents a total value of only about 8 30 million in OECD countries, such a measure should not cause serious economic damage. Assuming that copying paper is usually provided by the copying machine manufacturers (relatively few and big companies), .any economic effects should be small. Industry poses a somewhat different problem. Over the last decaSe7 production has increased by 3.5?3 - 5% annually and the trend is rising in the OECD area. The over 2,000 million dollar West- European paint industry alone accounts for some 40^j of the world output. Production is assured by a few large and a great many small companies (U.K. = ^80, Italy and France = 350 etc.). This picture suggests that an overall ban on PCBs in paints could have some economic consequences. ' DSW 191229 STLCOPCB4051899 ':'S; / . . -7 - -r ir. 'r \ , . , .' : . I1NV(72)27 * . - -p It appears, however, that where used, (e.g. in stoving r.ppli- cations) PCBs constitute something like 5 - 1055 of the paint. / Few details arc available in respect of the amounts used in /- paints, but taking one example (France) where 250 tons were . ; used (1971) in a paint industry that produced something like ; 700,000 tons of paint, presumably only 2500-5000 tons would . . contain PCEs. Considering in addition that snail paint nanufac- turc-rs are generally highly specialized, and that the manufac turing process v;ould not have to undergo a major change to . replace the use of PCEs, a ban on PCBs should not cause any . . serious disturbance. The use of PCBs in paints has, in fact, been discontinued in some countries already. Figures for production (8,65^,200 tons in 1969) end consumption ' ; (8,517, 500 tons) in OECD countries again suggest that inport of paints iron non-OECD producers nay be of minor significance. 11. In practice, none of the products where PCBs have boon used as plasticizers can be recovered. Unless the use is totally eliminated, there will be continuous emissions into the envi- .rpnnent due to evaporation, insufficient incineration etc. Judging by the action already taken in several countries, substitutes can readily be found for the whole category of plasticizer use of PCBs, which should, therefore, be banned. _ I '12. It follov;s from what has been said above that for adequate . protection of health and environment, but also to avoid undue competition in international trade, agreement is necessary on allowed uses of PCEs. In order to ensure that home production ' is not substituted by import, control action by governments . through licencing or other means, is essential. 13. Measures are further necessary to ensure collection of used material, safety in transport of raw PCBs, and assessment of substitute materials : a) -In order to ensure collection of PCBs from all installations vhere their use must continue, manufacturers and/or importers should be required to keep inventory of all amounts supplied, recovered, regenerated and destroyed. Such inventories must be open to government inspection. b) A uniform labelling 53'stem, internationally recognisable, should be developed fbr use on containers of rav; PCBs as well as cn any equipment or product containing PCBs. c) Suppliers (i.e. manufacturers and importers) should further provide containers for the transport of PCB- . containing liquids : such containers must meet the appro '' priate specifications that have been laid down to ensure safety in transport of dangerous chemicals. ' ' DSW191230 STLCOPCB4051900 im (72) 27 --o-- 2 d) Development of substitutes that are loss hazardous than PCBs** Should be encouraged, but in viev; of the fact that no system for pre-market control of new chemicals has . been introduced, testing for environmental effects is so far entirely the responsibility of the manufacturers. Information on replacement products should, therefore, be collected and reviewed. . ACTIO;! PROPOSED ' The Sector Group on Unintended Occurrence of Chemicals in the Environment - in pursuit of the objective of elimination of all escape * of PCBs to the environment, , .. - whilst recognising tha.t all Ilember countries may not presently have adequate legislation and may have to seek other means of compliance, proposes that the Council of the OECD seek the strongest possible agreement betv.reon Member governments ; ^ a) that PCBs be limited, except as provided in para.c)hereof, to the following categories of use, hov.'ever only in those applications where requirements for non-flanmability supercede those of environmental protection and where sufficient control is possible : Dielectric fluids for * transformers large power factor correction capacitors, lieat_transfor_fluid5 ' other than in installations for the processing of foods, drugs, foods and veterinary products, in mining equipment; . . b) that for all PCB-uses the following procedures be established : (i) control of the manufacture, import and export of bulk PCBs, including also PCD-containing products as far as useful and practicable; (ii) the institution of adequate arrangements for the recovery, regeneration,adequate incineration or other safe disposal of surplus end waste materials;------------------------- ;^ i ^___ _________ DSW - As of the time of the preparation of this report, limited research studies with certain selected PCB-ccmpo'unds may indicate that some of these compounds could eventually safely be used as replacements for certain applications. . STLCOPCB4051901 -9- Fir; (72) 27 (iii)'the institution of a' special, uniform labelling system for both raw PCBs end PCB-containing manufac tured products; (iv) safety specifications for containers and transport; that Member countries v.'ork towards the elimination of PCBs from small capacitors. It is however recognised that at pre sent this is unattainable. while their use continues, it is understood that it would be impracticable for them to be ^ subject to the recommendations dealing with labelling and disposal. The problem should be kept under review by the Sector Group on Unintended Occurrence of Chemicals in the Environment; that all other applications of PCBs be eliminated, giving priority attention to : - heat transfer fluids in the food, pharmaceuticals, feed and veterinary industries, - plasticizers for paints, inks, copying paper, adhesives, sealants, - hydraulic liquids (other than in mining) and lubricating oils, - vacuum pump fluids and cutting oils, - pesticide uses; . ..that Member countries request their industries to use as PCB replacements materials which pose a lover hazard to human health and the environment than do the FCBs; that information be exchanged at the beginning of 197^, 1975 and 1976 on * (i) amounts ox PCBs, including : amounts manufactured by PCB type amounts imported "" amounts exported " *' amounts incinerated n" amounts consumed "" and by country and by country and by use; (ii) details of PCB replacements including : identification, total amounts for each chemical type and . for each use, known toxiGity and environmental hazard of each chemical type; DSW 191232 STLCOPCB4051902 ENV(7?-)27 - 10 - (iii) details of disposal of surplus PCBs,(by incineration or by other moans), including cvalua tion of incinerator efficiency; g) that implementation of measures adopted be reported regularly to Council. ` 15. Finally, attention is called to the desirability that appropriate steps be taken to eventually open any agreement between CCCD Member countries for adherence by non-OECD nations. , DSW191233 STLCOPCB4051903