Document zQLbExYOLZO9D2qeRw95movr6

organisation i^ort economic COOPERATION iUil) BEVELOEISHT restricted - Pexts, 29th Uovember 1972 ENV(72)27 Scale 2 Or. Eng./Fr. ENVIRONMENT CO' jilTTBE POLYCHLORINATED BIPHENYLS: FROPOSAIS FOR CONCERTED ACTION 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* NR/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 ?C3s should not be used in circumstances which could result in their escape to the environment. Consequently it vjs.3 desirable to establish a common policy framework throughout the OECD membership regarding the acceptable uses of PC3s 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 Group's proposals be submitted to the Council for consideration before the end of 1972 if possible. At its 5 th session on Oth-lOth 'November 1972, the Environment Committee noted the Council's request and agreed that once tho proposals had boon finalised by tho Sector Group they should bo sent to tho Environment Co:.imittec for comment within 15 days after which, should no major criticises bo made thereon, tho proposals would be submitted to the OECD Council. ACTION REQUIRED: 'Members of the Environment Committee . are invited to comment in writing on the attached document before . 13th.December, after which date the . proposals therein will be submitted in an appropriate fora to the OECD Council. MONS 039067 -3- ENV(72)27 ' SkCTOR GROUP OH UMIMTEUDDD OCCUniiP.RCE OF CHEMICALS II? TIC.-1 niiViaOiJISNT Polychlorinated Biphenyls Proposals for Concerted Action ITlTilODUCTIOH Polychlorinated biphenyls (PCBs) are q Group of stablo substances comprising theoretically more than 200 individual compounds, many of which ere widely used particularly because of their dielectric properties and non-flammability. At present they are obtained through chlorination of diphenyl, resulting in mixtures that are characterised by their average content of chlorine. Due to the persistence and toxicity of some of these compounds, effects have boon observed in the environment and accidents reported over the last few years, which have given rise to serious concern in Member countries. In viev; 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 PCBs. The results of- this enquiry, which have- been presented In document NR/ENV/72,49, lead to the following conclusions : o) Becau.se of unacceptable levols of PCBs found in the environment and because of a number of incidents involving human health, some countries have taken, or are conside ring taking action- to control the use of PCBs; b) There arc (1972) only si;: companies in OECD Member countries that manufacture PCBs; four of them have already taken stops to reduce production to the supply for a feu approved uses; c) PCBs can bo replaced except for some uses where their dielectric properties and non-flammability are essential; d) The technology for destruction of PCBs exists; g) 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; MONS 039068 :NV(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, l-easonablc to suggest that the major part of the problem of 'unin tended occurrence of PCBs can be solved through concerted notion between O^CD fiomber countries. USES OF PCEs 2. The applications of PCEs fall mainly into two categories : - uses in closed systems - dissipative uses. Closed Systems 3. The use of PCBs in closed systems can bo defined as application from which the PCBs are recoverable. PCBs in transformers, capacitors, heat transfer systems, hydraulic equipment, and vacuum pumps ~re in principle recoverable, since during use, the PCEs are not generally dispersed into the environment. 4. It is, hov.'c-vor, important to distinguish between closed system uses that are controllcble in practice and those where control ennnot bo guaranteed either - because frequent replacement of relatively small quantities 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 v/horo - the PCEs are contained in a soaled circuit in large, long . life units, - the quantities involved are such that there is an incenti\ for regeneration. ~ HONS 039069 * Production in 1971 amounted to about 48,400 metric tons and consumption in the 13 countries that provided numerical infor- ma.tion to about 35,300 tons; assuming that consumption of PCEs . is likely to bo in some measure proportional to CMP, consur.pti ' in the other ton countries (Austria, Denmark, Greece, Iceland, Ireland, Italy, Japan, Luxemburg, Spain, Turkey) would be in - * 17 l> , -5- ENV(72)27 6. Following what has been said above, the only truly controllable uses of PCBs are in dielectrics for transformers and for large capacitors for power factor corrocxIonT'Prcvonting escapc-oi~FCSs Iron these applications is nainly a problcn of engineering design and of collection and destruction of used liquids, or, in the case of capacitors, of removal ncd destruction of PCE-inpregnated material. These uses also being essential for safety reasons, it would be unreasonable to suggest that they bo discontinued at the present tine. 7. In all other closed eystens, recovery of PCBs, although theoretically possible, would not be practical. Such appli cations should, therefore, bo discontinued, unless safety requirements prevent the use of substitute products : (1) Htt_transfer_systems There nay be some installations where the risk of explosion or fire oust be avoided at all cost, and the danger of sone escape of PCBs therefore is of less importance. Because of the risk of leakage, which can never be totally guarded against, the use of PCEs as heat transfer media in the food, drugs and feed industries should, however, bo prohibited. (ii) Hydraulic eculpnent, vacuum pumps Although the quantities involved in the individual case arc relatively snail, they will, unless recovered, add significantly to the environmental burden of PCBs. Theoretically, used 3uids could be recovered, but in viov: of the difficulty of establishing a systen to collect small quantities from many users, these appli cations should be discontinued. Furthermore, PCBs arc generally not essential in hydraulic and pumping fluids, with the possible exception of hydraulic equipment in underground mining. " (ill) Snail capacitors These are typical examples of an application of PCBs in sealed units that are aluost completely non-rccovorcble. Considering, for example, the many domestic electrical appliances in which capacitors are used, the cost of recovery would probably be prohibitive. A wa.rning label showing that the equipment must not bo disposed of as ordinary waste has been suggested; it is . however, not likely to be sufficient, unless manufactu rers md 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 PCEs in the manufacture of small capacitors. MONS 039070 EHV(72)27 -6- * Dissipative Uses 8. 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 . (1) Rubricating_and_cuttlng_oils The conditions under which these oils aro used are suchthat there is continuous emission of small quantities , into the environment. These applications, not being ' essential, should be discontinued; (li) Pesticide_Use . This use has fortunately been abandoned in most countries already; if not, it should bo banned with immediate offset. Since all OECD countries require registration of pesticides, such a measure can easily be taken under existing legislation; (Hi) Plasticizers ' 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. 9. The Printing_Industrjr : Beca.use of the risk of contamination or-paper7whloh-cTer recycling may be used in food packaging, the use of PCBs in the printing industry should 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 (s 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 feu and big companies), any economic effects should bo small. 10. The_Paint Industry poses a somewhat different problem. Over Ifie~Ias-c!ecF.3o7~production has increased by 3.5?S - 5% annually and the trend is rising in the OECD area. The over 2,000 million dollar West-European paint industry alone eccounts for some 40;j of the world output. Production is assured by a few largo and a great many small companies (U.K. = *i60, Italy and France ** 350 etc.). This picture suggests that an overall ban on PCBs in paints could have some , economic consequences. ' MQNS 039071 -7 - DNV(72)27 It eppea.rs, However, that where used, (o.g. In stoving a.ppllcations) PCEs constitute something llko 5 - 1055 of the paint. / Fow details arc available in respect of the amounts used in ' points, but taking one excmple (France) v.-here 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 manufac turers are generally highly specialized, and that the manufac turing process would not have to undergo a major change to replace the use of PCBs, a ban on PCBs should not cause any serious disturbance. The use of PCEs in paints has, in fact, been discontinued in some countries already. Figures for production (G,65A,200 tons in 1969) and consumption (8,517,500 tons) in OECD countries again suggest that import of paints from non-OECD producers may be of minor significance. 11. In practice, none of the products whore PCBs have been used as plasticizers can be recovered. Unless the use is totally eliminated, there will be continuous emissions into the onvironner.t due to evaporation, insufficient incineration etc. Judging by the action alrcc.dy taken in several countries, substitutes can readily be found for the whole category of plcsticizer use of PCBs, which should, therefore, be banned. 12. It follows from what has boon 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 hone production is not substituted by import, control action by governments through licencing or other means, is essential. 13. Erasures are further necessary to ensure collection of used material, safety in transport of raw PCBs, and assessment of substitute materials : a) `In ordor to ensure collection of PCEs from all installations whore 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 system, internationally recognisable, should be developed for use on containers of raw PCBs as well as cn any equipment or product containing PCBs. c) Suppliers (l.c. manufacturers and importers) should further provide containers'for the transport of PCBcontnining liquids : such containers must meet the eppro- priato specifications that have been laid do\m to ensure safety in transport of dangerous chemicals. HONS 039072 JJNV(72)27 -a- d) Develop:;ont of substitutes that arc lcs3 hazardous than PC2S- Should bo encouraged, but in view of tho fact that no system for pre-market control of new chemicals has been introduced, testing for environmental effects is so for entirely tho responsibility of tho manufacturers. Information on replacement products should, therefore, bo collected end reviewed, . actio:; fhopogsd The Sector Group on Unintended Occurrence of Chemicals in the Environment - in pursuit of the objective of elimination of all escape of PCBs to tho environment, - whilst recognising that all Member countries nay 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 between Member governments : n) that PCHs be limited, except as provided in para.. c)horoof, to the following categories of use, however only in those applications where requirements for non-flammability supersede those of unvii'onnentul protection and where sufficient control is possible : Dielectric fluids for transformers large power factor correction capacitors, U2t_:U:GDSfcr_luid5 ' other than in installations for the processing of foods, drugs, foods and veterinary products, L-XEf:Sli_3:Di3S mining equipment; ' b) that for all PCB-uses tho following procedures bo established : (i) control of the manufacture, import and export of bull: PCi5s, including also PCE-containlng products as far as useful and practicable; (ii) the institution of cdoquata arrangements for tho recovery, regeneration,adequate incineration or other safe disposal of surplus and waste materials;* * MONS 039073 * I.s of the time of tho preparation of this report, limited research studios with certain selected PCS-cc;'pounds may indicate that come of these compounds could eventually safely bo used as replacements for certain applications. -9 - PIP/(72)C7 (Hi) 'tV. institution of s'special, uniform labelling system for both rav; PCBs end PCB-containing manufac tured products; (lv) safety specifications for containers and transport; c) that Member countries work towards the elimination of PCBs from small capacitors. It is however recognised that at pre sent this is unattainable. Uhile their use continues, it is understood that it would be impracticable for them to be subject to the recommendations dealing with labelling and disposal. Tho problem should be kept under review by the Sector Group oh Unintended Occurrence of Chemicals in the Environment; d) that all other applications of PCEs be eliminated, giving priority attention to : - hoat transfer fluids in tho food, pharmaceuticals, feed and veterinary industries, - plasticizers for paints, inks, copying paper, edhesives, sealants, - hydraulic liquids (other than in mining) and lubricating oils, - vacuum pur.p fluids and cutting oils, - pesticide uses; e) 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 tho FCBs; f) that information be exchanged at the beginning of 137!<, 1975 arid 1976 on * (i) amounts of fCBs, including : amounts manufactured by FCE type amounts imported "" amounts exported "" amounts incinerated "" amounts consumed "" ' end by country and by country and by use; (ii) details of PCB replacements including : identification, ` total amounts for each chenlocl type and for each use, known toxicity and environmental hazard of each chemical type; HONS 03907* unv(72)27 - 10 - (ill) details of disposal of surplus PCBs,(by incineration or by other means), including evalua tion of incinerator efficiency; g) that implementation of measures adopted be reported rogulcriy to Council. ' 15. Finally, attention is called to the desirability that appropriate steps be taken to eventually open any agreement between OECD Member countries for adherence by non-OECD nations. MONS 039075