UNITED NATIONS ENVIRONMENT PROGRAMME Chemicals Branch, DTIE COMPILATION OF AN INVENTORY OF EXISTING RISK MANAGEMENT MEASURES LEAD AND CADMIUM Companion document to the Draft final reviews of scientific information on lead and cadmium Version of November 2008 Table of Contents 1. INTRODUCTION .............................................................................................................. 1 1.1 Background and mandate ............................................................................................. 1 1.2 Scope and coverage in this compilation ....................................................................... 1 1.3 Process for call for information .................................................................................... 2 2. SUBMISSION FROM GOVERNMENTS ....................................................................... 4 2.1 Sweden ......................................................................................................................... 4 2.2 Togo .............................................................................................................................. 9 2.3 United States of America ............................................................................................ 10 2.3.1 Some existing risk management measures for lead ............................................ 10 2.3.2 Some existing risk management measures for cadmium.................................... 10 3. INFORMATION SUBMITTED FROM OR RELEVANT TO INTERGOVERNMENTAL ORGANIZATIONS OR TO REGIONAL ECONOMIC INTEGRATION ORGANIZATIONS .................................................................................... 12 3.1 European Commission................................................................................................ 12 3.2 United Nations Economic Commission for Europe (UNECE) .................................. 15 3.3 World Bank ................................................................................................................ 26 4. INFORMATION SUBMITTED FROM OR RELEVANT TO NONGOVERNMENTAL ORGANIZATIONS.............................................................................. 27 4.1 International Lead Association ................................................................................... 27 4.2 International Lead Management Centre (ILMC) ....................................................... 28 4.3 Scientific Committee on Problems of the Environment (SCOPE) ............................. 29 1. INTRODUCTION 1.1 Background and mandate 1. In February 2005, the UNEP Governing Council, by decision 23/9 III, requested UNEP to undertake the development of reviews of scientific information on lead and cadmium, focusing especially on long-range environmental transport, in order to inform future discussions of the Governing Council on the need for global action in relation to lead and cadmium. 2. UNEP established a Working Group to assist it in developing the reviews of scientific information. The Working Group on lead and cadmium consisted of members nominated by Governments, intergovernmental organisations and non-governmental organisations. Working Group members provided a first round of comments on the draft reviews by mail. A first meeting of the Working Group was convened 18 to 22 September 2006 in Geneva, Switzerland. During that meeting the members of the Working Group considered the revised drafts of the reviews of scientific information on lead and cadmium circulated in advance of the meeting and finalized the reviews. Technical summaries of the key findings of each of the reviews were also prepared. 3. The Working Group recognised that, as there was ongoing work underway on the issues in other forums, it was not possible to finalise the reviews. The version finalised by the secretariat after the Working Group meeting was therefore to be considered ‘interim’. 4. The interim reviews of scientific information on lead and cadmium were updated following the working group meeting in September 2006 and additional information was sought to fill the remaining data gaps. Information provided by Governments, intergovernmental organizations and nongovernmental organizations was included in the updated interim reviews finalized in March 2008. 5. By its decision 24/3 III of 9 February 2007 on lead and cadmium, the Governing Council of UNEP “Acknowledges the data and information gaps identified in the United Nations Environment Programme Interim Scientific Reviews on Lead and Cadmium and that further action is needed to fill those data and information gaps, taking into account the specific situation of developing countries and countries with economies in transition; Encourages efforts by Governments and others to reduce risks to human health and the environment of lead and cadmium throughout the whole life cycle of those substances; Requests the Executive Director to provide available information on lead and cadmium to address the data and information gaps identified in the Interim Reviews and to compile an inventory of existing risk management measures”. 1.2 Scope and coverage in this compilation 6. This document responds to Governing Council Decision 24/3 III. It compiles submitted information from Governments, Intergovernmental Organizations and Non-governmental Organizations with regard to the inventory of existing risk management measures which are organized into three main sections accordingly. 7. Submissions of specific relevance to risk management measures were received from the following: Canada, Germany, Sweden, Togo, the United States of America, the European Union, the International Cadmium Association –which information has been included under the European Union Compilation of an inventory of existing risk management measures: Lead and Cadmium 2 _______________________ entry-, the International Lead Zinc Research Organization (ILZRO) and the Scientific Committee on Problems of the Environment (SCOPE) from which the following sections have been drawn. Additional information, where easily available, has either been included or referenced by hyperlinks. 1.3 Process for call for information 8. In response to Governing Council decision 24/3 III in relation t, UNEP sought technical input and information submissions from Governments and other stakeholders with regard to the interim scientific reviews on lead and cadmium and the compilation of an inventory of existing risk management measures between April and September 2007. 9. As of 27 August 2008, a total of 16 Governments, 1 Intergovernmental Organization and 5 Non-governmental Organizations submitted information with regard to the interim scientific reviews on lead and cadmium and the compilation of an inventory of existing risk management measures. All information received by the Chemicals Branch has been made available on the Lead and Cadmium Activities website (http://www.chem.unep.ch/Pb_and_Cd/default.htm ). 10. The current compilation of an inventory of existing risk management measures can be found at the Lead and Cadmium Activities website. It is noted that the compilation was not formally circulated for comments, as it is a compilation of received information; however, UNEP welcomes any comments or additional information. 11. Throughout the different submissions, it was reiterated several times that information contained in the interim review of scientific information on lead and cadmium chapters 8 (prevention and control technologies and practices) and chapter 9 (initiatives for preventing or controlling releases and limiting exposures) could usefully be examined to identify risk reduction measures. 12. Chapter 8 summarizes information about prevention and control technologies and practices, and their associated costs and effectiveness, which could reduce and/or eliminate releases of lead and cadmium, including the use of suitable substitutes, where applicable. It notes that the specific methods for controlling lead and cadmium releases from these sources generally fall under the following four groups: • • • • Reducing consumption of raw materials and products that include lead and cadmium as impurity or use of low-lead and cadmium raw materials; Substitution (or elimination) of products, processes and practices containing or using lead and cadmium with non-lead and cadmium alternatives; Controlling lead and cadmium releases through low-emission process technologies and cleaning of off-gases and wastewater; Management of lead and cadmium-containing waste. 13. Chapter 9 contains information on initiatives and actions for management and control of releases and exposures of lead and cadmium and indicates which adverse effects on human health and the environment various countries and international organisations have considered to be significant enough to merit restriction measures. The global coverage of these organisations shows how important such adverse effects have been. Initiatives for preventing or controlling releases and limiting exposures take place at different levels. The chapter briefly describes initiatives specifically addressing cadmium at four levels: • • • • National initiatives; International conventions and treaties; Programmes of international organisations; Sub-regional and regional initiatives. 14. In addition, the appendices to the reviews provide an overview of existing and future national actions relevant to lead and cadmium that could provide information on risk management measures. To Compilation of an inventory of existing risk management measures: Lead and Cadmium 3 _______________________ avoid duplication, readers are requested to look at those documents for information supplementary to that contained in the current document. 15. The scientific reviews on lead and cadmium and the compilation of an inventory of existing risk management measures will be presented for the twenty-fifth session of the Governing Council/Global Ministerial Environment Forum in February 2009. Compilation of an inventory of existing risk management measures: Lead and Cadmium 4 _______________________ 2. SUBMISSION FROM GOVERNMENTS 2.1 Sweden 16. KEMI, the Swedish Chemicals Agency indicated that risk management measures had been included in their recently updated version of the report “Lead in Articles”. The report is an account of the assignment given by the Swedish Government to the Swedish Chemicals Agency and the Swedish Environmental Protection Agency in June 2005 to investigate the consequences of the forthcoming prohibitions of ammunition containing lead in hunting and target shooting and to conduct a review of the use of lead in articles and products. The Swedish Chemicals Agency and the Swedish Environmental Protection Agency were each given identical assignments. The first part of the assignment was to investigate the consequences of the prohibitions of lead in ammunition. The results of the investigation were presented to the Swedish Government on 10 November 2006 (Swedish EPA report 5627). In a second part of the assignment the Swedish Chemicals Agency and the Swedish Environmental Protection Agency review the use of lead in articles and products as a whole and submit proposals for the regulations they consider to be most urgently needed to attain the environmental quality objective of A Non-Toxic Environment. 17. The following summary on lead in articles is reproduced here-below for ease of consultation. The whole report can be viewed at: http://kemi.se/upload/Trycksaker/Pdf/Rapporter/Report5_07_Lead_in_articles.pdf . Further background reports are available on the Swedish Environmental Protection Agency website ( www.naturvardsverket.se ) and can be downloaded free of charge in electronic form. LEAD IN ARTICLES - SUMMARY Lead is an element commonly present in soil at low concentrations. Lead, zinc and silver to a large extent occur together in nature. In the majority of mines around the world where zinc is extracted, large quantities of lead are also extracted. Lead is a non-essential metal. The harmfulness of the lead ion has long been known and is fairly well documented. The lead ion is classified as toxic to reproduction, category 1, i.e. it affects fertility and can be harmful to fetal development. Lead compounds, for example lead acetate, are suspected of being carcinogenic (cancer, category 3) because of the lead ion. Substances that can release lead ions to the environment are also classified as very toxic to aquatic organisms and can cause harmful long-term effects in the aquatic environment, that is to say they pose an environmental hazard. The Swedish Parliament has adopted environmental quality objectives in 16 areas. One of these objectives is “A Non-Toxic Environment”. This means that “the concentrations of substances that naturally occur in the environment are close to background levels”. According to the wording of interim target 3 for A Non-Toxic Environment, newly manufactured finished products are as far as possible to be free from lead by 2010. The commission In June 2005 the Swedish Government commissioned the Swedish Chemicals Agency and the Swedish Environmental Protection Agency jointly to investigate the consequences of the ban on lead in ammunition that comes into force in 2008 and to review the use of lead in articles and products. A report on the first part of this commission, concerning the consequences of the ban on lead in ammunition, was presented to the Government on 10 November 2006. Compilation of an inventory of existing risk management measures: Lead and Cadmium 5 _______________________ In the second part of the commission the Swedish Chemicals Agency and the Swedish Environmental Protection Agency are to review the use of lead in articles and products as a whole and submit proposals for regulations they consider to be most urgently needed to attain the environmental quality objective of A Non-Toxic Environment. The two government agencies are also to consider the cost-effectiveness of the regulations proposed. Part two of the commission is the subject of this report. Environmental risks Lead in petrol in the past was the most significant source for the dispersal of lead to the environment and gave rise to the effects on microorganisms suspected of occurring in forest soil in parts of Sweden. As the use of leaded petrol continues to decrease in Europe and the rest of the world, fallout of lead will decline further and levels in forest soil can be expected to diminish. The general level of exposure to lead in urban environments is also falling sharply with the decreasing use of leaded petrol. Lead-containing articles that end up in waste may contribute to atmosphere fallout of lead when the waste is incinerated, or potentially be dispersed to the environment in some other way. The use of articles containing lead, such as shot and fishing weights, can result in general dispersal of metallic lead in some areas, similar to that from atmospheric fallout. It has not been possible to quantify what effects this will have on aquatic and soil organisms. The environmental impact of lead from the use of other types of articles will be more concentrated, and risks may possibly arise locally in soil and water. The greatest environmental risk identified in the use of articles is the poisoning of birds and other animals that can ingest lead objects (shot, fishing weights) directly or through the food chain. Health risks Measures to reduce the dispersal of lead in Sweden have been successful. They have resulted in reduced blood levels of lead over the last 20 years. The mean value of lead in the blood of Swedish men at present is approximately 0.2 μmol/l. The mean value is lower in women, adolescents and children. The average level of lead in the blood of children in areas without activities that result in major emissions is approximately 0.1 μmol/l. However, it is difficult to establish a safe level for lead exposure as lead can damage the nervous system even at low levels of exposure. Sensitivity is particularly great during brain development in fetuses and small children. In studies on children, delayed development, lower IQ and behavioural disorders have been observed at blood lead levels of around 0.5 μmol/l. Suppressed erythropoiesis (blood formation) and hearing impairment are other effects observed at relatively low lead exposure. The neuropsychological effects on children are severe, and lead levels in the blood of children and women of childbearing age should therefore be lower than 0.5 μmol lead per litre of blood. However, there are indications that these effects do not have a threshold, which means that it is not possible to establish a “safe” level of lead in the blood of children and fetuses. Today the general population is exposed to lead principally through food, but based on calculations of weekly intake of lead through food this exposure generally appears to be low in Sweden. Certain at-risk groups which may be exposed to harmful quantities of lead through consumer products have, however, been identified. Examples of such at-risk groups are anglers who make their own fishing weights, people who use solder and those who cast tin soldiers and make lead Compilation of an inventory of existing risk management measures: Lead and Cadmium 6 _______________________ bullets for black powder shooting. These activities can lead to high “uncontrolled” exposure to lead vapour. Lead vapour is formed when lead melts at high temperatures. This “vapour” contains small inhalable lead particles, and uptake in the lung is assumed to be 100 per cent. Another example of at-risk groups is people who spend time in rooms in which scented candles/gel candles with a lead-containing wick are lit. When these candles are lit lead vapour is released, which might give rise to high concentrations of lead in air. Rules on lead in articles Lead is found in a large number of applications, and regulations on lead can therefore be found in a number of different European directives. The report presents a broad description of regulations in the EU that explicitly relate to lead, either as a substance or in articles. Certain other products that are of great significance in limiting the use of lead, e.g. cars, petrol and batteries, have been regulated. Another example of the regulation of the level of lead in articles is a new directive which imposes limits on lead in electrical and electronic products. New product directives concerned with lead will probably also be added. The new chemicals legislation REACH may signify further restrictions on lead. Use of lead in articles The use of lead has decreased in most of the groups of articles considered in the report over the last decade. It is principally in paint pigments, plastics, crystal, lead-jacketed cable, electronics and shot that quantities of lead have fallen. The forces driving this positive development have been tightened legislation for certain uses of lead in products but also customer requirements and other voluntary initiatives in industry. Product areas where the use of lead has not diminished are batteries, boat keels, fishing tackle, alloys, weights and radiation protection. A reduction in the quantity of lead is, however, expected shortly, with regard to balance weights, as the previous exemption from the limitation of lead in end-of-life vehicles has ceased to apply (ELV Directive, 2000/53/EC, see Annex 3). Prioritised groups of articles The risks associated with lead vary between different product groups. This principally depends on the form in which the lead occurs, what volumes of lead are used in the product group, the dispersal of the products in society and how they are disposed of at the end of their life. In addition, it is significant to the risks whether use of the product may mean that people or the environment are exposed to lead, particularly in the case of sensitive groups such as children. Lead can emit and be dispersed during various phases of the life cycle of products. Emissions in production are principally a working-environment issue, but in some cases also have an impact on the natural environment. The release of lead during the use of products may pose a risk to humans and the environment, as may emissions from end-of-life articles. Dispersal of lead and the risk of harm must be taken into account in prioritising products for proposed measures. In addition, account must be taken of whether there are already rules limiting lead in the product group. On the basis of these criteria the following product groups have been prioritised for further measures: • Fishing tackle in angling and commercial fishing – because of substantial dispersal to the environment. Seabirds are poisoned by ingesting lead fishing weights. Fishing tackle is not separated from other waste and lead therefore ends up in domestic waste. Lost lead fishing tackle corrodes which may lead to exposure of organisms in the aquatic environment. The private casting of lead for fishing tackle also implies health risks. Compilation of an inventory of existing risk management measures: Lead and Cadmium 7 _______________________ • Consumer products – as they can pose a risk of serious health effects. Certain products lead to exposure by inhalation, such as leaded wicks and tin solder. Other articles such as chalks and jewellery could imply a health risk since children might swallow parts of the article. • Aviation spirit – as lead in the aviation spirit is dispersed to the environment. Lead in petrol is the most dangerous form of lead from the toxicological point of view. • Batteries – due to the large quantities of lead they contain. • Residual products, e.g. iron sand – as waste and residual products may contain a large amount of lead, from the quantitative point of view. The exposure scenario is often unclear with regard to both health and the environment. Swedish Environmental Protection Agency and Swedish Chemicals Agency proposals Rules on limitation in fishing products On the basis of the risk scenario that exists for products in angling and commercial fishing and for certain consumer products that contain lead, these products appear to represent the most pressing need for further regulation. Taking account of the consequences possible regulation may have for the parties concerned and for society in general, the Swedish Chemicals Agency and the Swedish Environmental Protection Agency propose that a ban be introduced on fishing tackle. The limitation should at first hand be introduced at EU level. However, the timetable for limitations under the Limitations Directive (see section 14.1) is, highly uncertain and it is therefore proposed that a national ban be introduced. A national ban is proposed for all fishing tackle, i.e. tackle for angling and for household requirements as well as commercial fishing tackle. The tackle must not contain lead in an amount exceeding 0.1 per cent by weight. Under this proposal, the sale and use of tackle would be banned, according to the proposal. Some transitional provisions are also proposed, adjusted for the availability of alternatives. Tackle which was in use prior to the ban coming into force may continue to be used. Rules on limitations in consumer products The Swedish Chemicals Agency and the Swedish Environmental Protection Agency propose that Sweden should press for a limitation under the Products Safety Directive (2001/95/EC) in the case of certain consumer products since the risk pattern for these products makes them suitable for regulation. Other product groups considered in the report could also be regarded as consumer products, but this proposal only concerns the kind of consumer products known to the Swedish Chemicals Agency to be capable of causing a health risk. In the opinion of the Swedish Chemicals Agency, consumer products to be regulated are jewellery and accessories that have been soldered and cast, chalks, plus candles and alloys containing lead, which are available to consumers for casting. Authorization to the Swedish Chemicals Agency concerning lead in consumer products There may be a need to regulate further consumer products of which we are not currently aware and which are not regulated by other rules on limitations. This need is reinforced by the argument that zinc production controls lead availability on the market and that if the use of lead in batteries decreases new applications may become relevant. An alternative option to a ban at government level may be to authorize the Swedish Chemicals Agency to decide on bans on certain consumer products at the level of agency regulations, if there are serious environmental and health reasons for doing so. Therefore, it is proposed that the Swedish Chemicals Agency be given an authorization in Section 14 of the Chemical Products (Handling, Import, and Export Prohibitions) Ordinance (1998:944). A general authorization could also send a signal to the market that lead must not be present in consumer articles. Compilation of an inventory of existing risk management measures: Lead and Cadmium 8 _______________________ Aviation spirit Sweden has to date had a derogation from EU provisions that fuels for private recreational flying have to be taxed. This derogation came to an end on 31 December 2006 and Sweden will probably need to introduce taxation of aviation spirit in the near future. In conjunction with investigation of the formulation of this tax, the Swedish Environmental Protection Agency and the Swedish Chemicals Agency consider this to be an appropriate time to also investigate ways of making it advantageous to use the alternative unleaded aviation spirit through differentiation. Batteries With regard to batteries, the Swedish Chemicals Agency and the Swedish Environmental Protection Agency consider it important to follow developments both in Sweden and the EU closely. If the interim target of newly manufactured finished products being free of lead is to be attained, there is a need for extensive technical development of lead-free battery alternatives. Residual products A discussion is under way in the EU on the interpretation of what is waste, and the Commission has recently published a communication concerning waste and residual products. Iron sand is an example of problems concerned with residual products containing lead. In view of this ongoing discussion it is difficult at present to propose limitations for iron sand or other waste and residual products as the options depend on whether these are products (raw materials, substances, preparations) or waste. REACH covers raw materials, substances and preparations, but not waste. When all titles in REACH comes into force, the requirements for registration and risk assessment will gradually also come to apply to iron sand, provided iron sand has ceased to be waste. If iron sand is still to be regarded as waste, it is the rules under the Framework Directive on Waste and its national implementation in Sweden that are applicable. In view of the fact that many activities are in progress both nationally and in the EU with regard to increased requirements for risk assessment of both products and waste, the Swedish Chemicals Agency and the Swedish Environmental Protection Agency do not consider there to be reason within the framework of this commission to propose further measures for iron sand or other wastes and residual products. The example of iron sand makes it clear, however, that the aim of the strict policy in relation to lead in articles (phasing out lead in newly manufactured articles as far as possible and handling existing articles that contain lead in such a way that nothing leaks into the environment) will not be successfully met unless the rules on waste also have the same orientation and level of ambition. Crystal Directive With regard to the Crystal Directive (69/493/EEC), the Swedish Chemicals Agency and the Swedish Environmental Protection Agency consider it essential to press for this directive to be amended in the EU. 18. Swedish measures related to cadmium were provided in extenso as a result of the call for information for the interim reviews on cadmium and lead and their respective appendices. The information provided is available at the UNEP Lead and Cadmium Activities website at http://www.chem.unep.ch/Pb_and_Cd/default.htm Compilation of an inventory of existing risk management measures: Lead and Cadmium 9 _______________________ 2.2 Togo 19. The following is an excerpt from the submission by the Republic of Togo for the lead and cadmium reviews in which national measures and strategies for the prevention and management of lead and cadmium wastes are described (in French). The whole text can be downloaded at http://www.chem.unep.ch/Pb_and_Cd/SR/GOV/Subm2007_TGO.pdf VI- MESURES ET STRATEGIES DE PREVENTION ET DE MAITRISE DES REJETS Parallèlement aux études d’impact de ces rejets, des travaux de recherches sur les voies et moyens de réduction des risques ont été entrepris. Ces travaux portent essentiellement sur de nouvelles méthodes de gestion des déchets industriels en général et miniers en particulier. C’est ainsi que des essais de traitement des boues phosphatées en vue de récupérer la fraction solide contenant la matière phosphatée source de cadmium et de plomb ont été réalisés en utilisant la méthode de coagulation –floculation. Ces essais ont donné des résultats satisfaisants car on est parvenu à ramener la plupart des paramètres de l’eau (turbidité, dureté, concentration en ions métalliques etc.) à des valeurs conformes aux normes admises. Toujours dans le souci de freiner la dissémination du cadmium et du plomb dans l’environnement, une autre étude a consisté en des essais de réduction de la teneur en cadmium du minerai marchand exporté par le Togo. Là aussi les résultats sont très encourageants. Dans le même ordre d’idée, le Togo vient d’introduire la commercialisation sur toute l’étendue du territoire national la vente du carburant sans plomb (en réalité carburant à très faible teneur de plomb) en vue de réduire le rejet du plomb dans l’environnement. La mesure a pris effet à partir du 1er juillet 2005. Toutes ces actions ne seront bénéfiques que si elles sont coordonnées sur le plan régional. C’est pourquoi le Togo, dans le cadre de la lutte contre la dégradation des zones côtières et la réduction des ressources vivantes dans le grand écosystème marin du courant de Guinée, par des actions régionales, a souscrit au projet grand écosystème marin du Courant de Guinée qui démarre pour l’heure sur le volet lutte contre la pollution de la mer par des boues de phosphates par l’application de la méthode de décantation et d’identification d’une stratégie de gestion durable. Aussi, des programmes visant à éliminer certains produits chimiques sont-ils mis en place notamment le programme d’élimination des substances altérant la couche d’ozone, le programme d’élimination de certains polluants organiques persistants et le projet d’élaboration du profil national sur les produits chimiques. Toujours dans ce même objectif, une étude de faisabilité du projet de développement d’outils de planification et de suivi de la gestion du littoral a été réalisée. Les textes législatifs et réglementaires en matière d’étude d’impact sur l’environnement sont également mis à jour au Togo. Cela permettra d’envisager désormais les mesures d’atténuation et de minimiser autant que possible les dégâts sur l’environnement lors de l’installation des projets industriels pouvant porté préjudice à la santé humaine et l’environnement. Encore faut-il rappeler que le manque de structures adéquates de gestion écologiquement rationnelle des déchets qu’ils soient industriels ou ménagers contribue énormément à l’accentuation de cette menace sur la santé et l’environnement de ces éléments traces nocifs. Notons également que les campagnes de sensibilisation et d’éducation des populations et des industriels constituent une des priorités actuelles du Ministère de l’Environnement et des Ressources Forestières pour combattre cette pollution des produits chimiques. Compilation of an inventory of existing risk management measures: Lead and Cadmium 10 _______________________ 2.3 United States of America 2.3.1 Some existing risk management measures for lead 20. Measures to address emissions. Under the Clean Air Act Amendments of 1990, the U.S. EPA regulates Hazardous Air Pollutant Emissions (including lead emissions) by industrial source categories using Maximum Achievable Control Technology (MACT) standards for each "major source" in any source category. A MACT standard is defined based on an analysis of existing control technologies among the best-controlled sources in a given source category (U.S. EPA, 2006a). U.S. EPA has promulgated MACT standards for various industries including, inter alia: Primary Lead Production, Secondary Lead Production, Industrial/Commercial/Institutional Boilers (i.e., facilities that burn coal, oil, gas, or wood for heat and/or power), Cement Production, and Waste Incineration. U.S. EPA also develops emissions standards under the Clean Air Act for smaller sources (called area sources) based on generally available control technologies (GACT) or management practices. More information on these regulations are available at: http://www.epa.gov/ttn/atw/mactfnlalph.html 21. The U.S. EPA established a National Ambient Air Quality Standard for lead of 1.5 ug/m3 (as a quarterly maximum average) in year 1978. Any area in the U.S. found to be exceeding this level must implement actions to reduce emissions to achieve attainment of the standard. The U.S. EPA is currently reviewing this standard and reviewing possible options for revising this standard. More information is available at: http://www.epa.gov/ttn/naaqs/standards/pb/s_pb_index.html. 22. Measures to address waste management (disposal, recycling, etc). Under the Resource Conservation and Recovery Act (RCRA) standards have been developed for the management of lead in solid and hazardous waste (see http://www.epa.gov/osw/hazwaste.htm). 23. Measures to address lead use in products. The Consumer Products Safety Commission has banned lead in paint (both household paint and paint used on consumer products), lead in venetian blinds, and lead cored-wicks. 24. Risk Communication and Education/Outreach to reduce exposures/risks, etc. The U.S. EPA and other Federal agencies and departments (such as the Centers for Disease Control and Prevention, National Institute for Occupational Health and Safety, Occupation Safety and Health Administration, the U.S. Consumer Product Safety Commission, and others) as well as State and local health departments, have conducted extensive outreach on lead to reduce exposures and risks. These include, outreach campaigns and educational materials to help parents, health care professionals, home owners, and other professionals learn what they can do to protect their families, patients, communities, and themselves, from the dangers of lead. These materials can be found at www.epa.gov/lead, http://www.cdc.gov/nceh/lead/, http://www.osha.gov/SLTC/lead/index.html, http://www.cdc.gov/niosh/topics/lead/, http://www.cpsc.gov/ and other related websites. 2.3.2 Some existing risk management measures for cadmium 25. Measures to address emissions. Under the Clean Air Act Amendments of 1990, the U.S. EPA regulates Hazardous Air Pollutant Emissions (including cadmium emissions) by industrial source categories using Maximum Achievable Control Technology (MACT) standards for each "major source" in any source category. A MACT standard is defined based on an analysis of existing control technologies among the best-controlled sources in a given source category (U.S. EPA, 2006a). U.S. EPA has promulgated MACT standards for various industries including, inter alia: Primary Copper Production, Primary Steel Production, Industrial/Commercial/Institutional Boilers (i.e., facilities that burn coal, oil, gas, or wood for heat and/or power), Cement Production, and Waste Incineration. U.S. EPA also develops emissions standards under the Clean Air Act for smaller sources (called area Compilation of an inventory of existing risk management measures: Lead and Cadmium 11 _______________________ sources) based on generally available control technologies (GACT) or management practices. More information on these regulations is available at: http://www.epa.gov/ttn/atw/mactfnlalph.html. 26. Measures to address waste management (disposal, recycling, etc). Under the Resource Conservation and Recovery Act (RCRA) standards have been developed for the management of lead in solid and hazardous waste (see http://www.epa.gov/osw/hazwaste.htm). 27. Risk Communication and Education/Outreach to reduce exposures/risks, etc. The Occupation Safety and Health Administration, U.S. EPA, National Institute for Occupational Health and Safety, and other agencies have conducted some outreach on cadmium to reduce exposures and risks. Some of this information is available at the following websites: http://www.osha.gov/SLTC/cadmium/, http://www.epa.gov/ttn/atw/hlthef/cadmium.html, http://thecommunityguide.org/niosh/topics/Cadmium/. Compilation of an inventory of existing risk management measures: Lead and Cadmium 12 _______________________ 3. INFORMATION SUBMITTED FROM OR RELEVANT TO INTERGOVERNMENTAL ORGANIZATIONS OR TO REGIONAL ECONOMIC INTEGRATION ORGANIZATIONS 3.1 European Commission 28. The following paragraphs have been submitted by the European Commission and include a short compilation of European regulation on lead and cadmium, providing a description of the various regulations and directives addressing those substances. 29. European Union Risk Assessment Report- Cadmium (1). The Institute for Health and Consumer Protection of the European Chemicals Bureau has produced in 2007 a European Union Risk Assessment Report on cadmium oxide and cadmium metal (Part 1 environment) – (3rd Priority List, Volume 72). Section 2.3 of the report covers Legislative control measures including European Union legislation and national legislation. 30. European Union Risk Assessment Report- Cadmium (2). There exists a Risk Assessment Report (RAR) for cadmium prepared within the Existing Substance Assessment Programme of the European Union. The Draft Report has been prepared by Belgium and is available on the homepage of the European Chemicals Bureau: http://ecb.jrc.it/ (under "ESIS" with CAS-No. 7440-43-9 or substance name “Cadmium”. 31. European Union legislation. The following is an overview of the main provisions of European Community Legislation with a relevance to lead and cadmium: Council Directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators. Explicitly addresses the question of cadmium and lead. Council Directive 2000/76/EC on Incineration of waste. To prevent and limit negative environmental effects by emissions into air, soil, surface and ground-water, and the resulting risks to human health, from the incineration and co-incineration of waste. Council Directive 2001/80/EC Large Combustion Plants. On the limitation of emissions of certain pollutants into the air from Large Combustion Plants Council Directive 96/61/EC on Integrated Pollution Prevention and Control Council Directive 76/116/EEC on the approximation of the laws of the Member States relating to fertilizers. Treaty concerning the maximum admissible content of cadmium in fertilisers Council Directive 304/2003 on the export and import of dangerous chemicals Council Directive 91/338/EC (amending Directive 76/769/EC) restricts the use of cadmium (1) as pigment, (2) as stabilizer in plastics and (3) as plating of metallic products or components of products. Restricts the levels of cadmium in certain consumer goods. Council Directive 67/548/EEC on the classification, packaging and labelling of dangerous substances. Lead metal, as the powder or in bulk form, is not (yet) classified. However, lead compounds not otherwise specified in Annex 1 of Directive 67/548/EEC are classified as follows: Repr. Cat. 1; R61 (risk to unborn child) Compilation of an inventory of existing risk management measures: Lead and Cadmium 13 _______________________ Repr. Cat. 3; R62 (risk of impaired fertility Xn; R20/22 (harmful by inhalation and ingestion) R33 (danger of cumulative effects) N; R50-53 Very toxic to aquatic organisms; may cause long-term adverse effects in the aquatic environment Council Directive 1999/45/EC on the classification, packaging and labelling of dangerous preparations. All preparations containing dangerous substances classified under Directive 67/548/EEC above a certain threshold have to be classified accordingly Commission Directive 2001/58/EC amending Directive 91/155/EEC defining and laying down detailed arrangements for the system of specific information relating to dangerous preparations and substances (safety data sheets). For dangerous substances and dangerous preparations, professional users are entitled to receive a safety data sheet which contains information on the intrinsic properties of the substance / components of the preparations, their classification and labelling requirements, and information on for example storage, waste disposal, emergency measures etc. Council Directive 76/769/EEC on restrictions on the marketing and use of certain dangerous substances and preparations. Bans the marketing and use of certain dangerous substances and preparations. With regard to lead and lead compounds, the following are restricted: Lead-based Paint The use of lead-based paint in residential applications was officially banned under EU Council Directive 89/677/EEC amending Council Directive 76/769/EEC (prohibits the use of lead carbonates and lead sulphates in paints except for the restoration of works of art and historic buildings) Council Directive 98/24/EC on the protection of the health and safety of workers from the risks related to chemical agents at work (Fourteenth individual Directive within the meaning of Article 16 (1) of Directive 89/391/EEC). Sets binding occupational exposure limits for lead and its ionic compounds in blood. Council Directive 92/85/EEC on the introduction of measures to encourage improvements in the safety and health of pregnant workers and workers who have recently given birth or are breast-feeding (Tenth individual Directive within the meaning of Article 16(1) of Directive 89/391/EEC). Sets out measures to protect pregnant workers and workers who have recently given birth or are breast-feeding, including the requirement to assess exposure to health risks including lead compounds due to their reprotoxic effects. Council Directive 94/33/EC on the protection of young people at work. Prohibits the use of certain chemical agents, including lead compounds as a reprotoxic agent, by young workers. Council Directive 88/378/EEC on the safety of toys. Established extraction limits for the bioavailability any lead contained in children’s toys. Council Directive 76/768/EEC on cosmetic products. Bans the use of lead and lead compounds in cosmetics, with an exemption for the use of lead acetate in hair treatments. Council Directive 91/689/EEC on hazardous waste. Sets out the requirements for the management of hazardous wastes, such as wastes containing lead compounds above a certain threshold. Compilation of an inventory of existing risk management measures: Lead and Cadmium 14 _______________________ European Parliament and Council Directive 94/62/EC on packaging and packaging waste as amended by Directive 2005/20/EC. The Directive eliminated this application of lead by reducing the sum of the amount of lead, cadmium, mercury and hexavalent chromium present in packaging or packaging components to 100 ppm by the year 2001 Council Directive 2002/95/EC of the European Parliament and of the Council on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). Bans the use of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs) in new electrical and electronic equipment put on the market from 1 July 2006. There are exemptions for certain uses such as lead as an alloying element in steel, aluminium and copper. Directive 2002/96/EC of the European Parliament and of the Council on waste electrical and electronic equipment (WEEE) as amended by Directive 2003/108/EC. Sets criteria for the collection, treatment, recycling and recovery of waste electrical and electronic equipment and makes producers responsible for financing most of these activities. Council Directive 2000/53/EC of the European Parliament and of the Council on end-of-life vehicles. Bans the use of lead, mercury, cadmium and hexavalent chromium in new vehicles put on the market from 1 July 2003. There are exemptions for certain uses such as lead as an alloying element in steel and copper, and lead in batteries and vibration dampers. Council Directive 91/157/EEC on batteries and accumulators containing certain dangerous substances as amended by Directive 98/101/EC. Sets out measures relating to the recovery and disposal of spent batteries and accumulators containing certain dangerous substances, such as batteries containing greater than 0.4% lead by weight. Council 85/210/EEC on the approximation of the laws of the Member States concerning the lead content of petrol – repealed by Directive 98/70/EC as amended. Restricts the content lead in petrol to 0,005 g/ltr. Council Directive 96/62/EC on ambient air quality assessment and management. The Framework Directive 96/62/EC set-out a common strategy to define and set objectives for ambient air quality. Lead concentrations in the ambient air were addressed by the 1st Daughter Directive (1999/30/EC), and a limit value (expressed as an average over a calendar year) of 0.5 ng/m3 was specified based upon WHO guidelines. Commission Decision 2000/479/EC on the implementation of a European pollutant emission register (EPER). According to the EPER Decision, Member States have to produce a triennial report on the emissions of industrial facilities regulated under Council Directive 96/61/EC on integrated pollution prevention and control (IPPC) into the air and waters. The report covers 50 pollutants including lead. Council Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy. Sets out objectives in the field of water policy including priority status and quality standard requirements for lead. Lead and its compounds are classed as ‘priority substances under review’ under the Water Framework Directive; this classification means that the substances so listed may be proposed as priority hazardous substances if justified by further investigation. Council Directive 86/278/EEC on the protection of the environment, and in particular of the soil, when sewage sludge is used in agriculture. This Directive prohibits the sludge from sewage treatment plants from being used in agriculture unless specified requirements are fulfilled, including the testing of the sludge and the soil. Parameters subject to the provisions of the Directive include amongst others the content of lead and cadmium. Compilation of an inventory of existing risk management measures: Lead and Cadmium 15 _______________________ Council Directive 84/500/EEC October 1984 on the approximation of the laws of the Member States relating to ceramic articles intended to come into contact with foodstuffs as amended by Directive 2005/31/EC. The Directive lays down maximum limits for the cadmium and lead transferred by ceramic objects to the foodstuffs with which they enter into contact. Council Directive 98/83/EC on the quality of water intended for human consumption. In the Directive the guideline for Pb in drinking water is reduced from 50 µg Pb L-1 to 10 µg Pb L-1, with a 15 year transition period to allow for replacing lead distribution pipes. 3.2 United Nations Economic Commission for Europe (UNECE) 32. Several countries, in particular Canada and Germany, referred to the valuable information available from the work of the Task Force on Heavy Metals of the UNECE Convention on Long-range Transboundary Air Pollution. 33. The Executive Body (representatives of the Parties to the Convention) adopted the Protocol on Heavy Metals on 24 June 1998 in Aarhus, Denmark. It targets three metals: cadmium, lead and mercury. According to one of the basic obligations, Parties will have to reduce their emissions for these three metals below their levels in 1990 (or an alternative year between 1985 and 1995). The Protocol aims to cut emissions from industrial sources (iron and steel industry, non-ferrous metal industry), combustion processes (power generation, road transport) and waste incineration. It lays down stringent limit values for emissions from stationary sources and suggests best available techniques (BAT) for these sources, such as special filters or scrubbers for combustion sources or mercury-free processes. The Protocol requires Parties to phase out leaded petrol. It also introduces measures to lower heavy metal emissions from other products, such as mercury in batteries, and proposes the introduction of management measures for other mercury-containing products, such as electrical components (thermostats, switches) measuring devices (thermometers, manometers, barometers), fluorescent lamps, dental amalgam, pesticides and paints. The Protocol can be seen at http://www.unece.org/env/lrtap/full%20text/1998.Heavy.Metals.e.pdf 34. The Executive Body for the Convention established the Task Force on Heavy Metals in 2004. Led by Germany, the Task Force: i) addresses the technical needs of the reviews and assessments required by the 1998 Aarhus Protocol on Heavy Metals, ii) schedules evaluations of limit values, the review of sufficiency and effectiveness and the review of additional heavy metals, product control measures or products/product groups ; among others activities. The work takes into account activities of relevant bodies under the Convention and synergies with the abatement of particulate matter. Documents and papers prepared for the different meetings of the task force can be found in full on the convention website at http://www.unece.org/env/lrtap/TaskForce/tfhm/welcome.htm 35. The review of the sufficiency and effectiveness of the 1998 Heavy Metals Protocol to the Convention on Long-Range Transboundary Air Pollution has been completed. An assessment of technological developments and improved product control and product management measures (prepared by the Task Force on Heavy Metals by experts from Canada, Netherlands, Sweden, United States, International Cadmium Association and Lead Development Association International) was published in June 2006. 36. The following two documents prepared by The Netherlands which may be useful as sources of additional information for this compilation were presented at the fourth meeting of the Task Force on Heavy Metals, held in Vienna, Austria from 6-8 June 2007. Additional relevant information can be found at http://www.unece.org/env/lrtap/TaskForce/tfhm/4thmeeting.htm The report on “Heavy Metal Emissions, Depositions, Critical Loads and Exceedances in Europe”, which summarizes knowledge of – and comparison between – heavy metal emission Compilation of an inventory of existing risk management measures: Lead and Cadmium 16 _______________________ reduction scenario´s and resulting depositions and critical exceedances. The focus of this report is on the relative assessment of the effect on mercury, cadmium and lead and – more tentatively – of other heavy metals on human health and the environment. The report is available under: http://www.unece.org/env/lrtap/TaskForce/tfhm/COMBINED%20HM%20REPORT.pdf The report on “Study to the effectiveness of the UNECE Heavy Metals (HM) protocol and cost of additional measures”. The report is available under: http://www.tno.nl/downloads%5C2006A-R0087-B_rapport_AV_hdg_V04_1-8.pdf 37. Recently, the Task Force on Heavy Metals held its fifth meeting from 4 - 6 June 2008 in London, United Kingdom. Further information on the work of the task force can be found on the UNECE website, and meeting documents for the fifth meeting can be found at http://www.unece.org/env/lrtap/TaskForce/tfhm/5thmeeting.htm 38. Annex VI of the Heavy Metals Protocol contains binding product control measures and Annex VII contains guidance to Parties on a range of possible product management measures. The abovementioned document describes how measures and technological developments have improved relative to the measures given in the two annexes of the Heavy Metals Protocol. It includes information on how many Parties have undertaken measures, what kinds of management measures have been introduced, changes in the consumption of heavy metals and estimates of the products contributions to air emissions where available. In 10 Annex E of the document, regulatory measures, non-regulatory measures, technological developments, use and emissions and a summary are, where possible, provided for cadmium containing batteries, cadmium as surface treatment, stabiliser and colouring agent, cadmium in electrical and electronic equipment, lead in electrical and electronic equipment, lead containing batteries, lead-containing paint, lead stabilisers in PVC products and heavy metals in packaging, sewage sludge and vehicles. Annex 10 E addresses the issue of products with potential for indirect air emission of lead and cadmium. The report provides a good example of a clear structure and disposition presenting both regulatory measures and non- regulatory measures for each concerned product group or use.The chapters on Best Available Techniques and Products may contain information relevant to the current inventory of existing risk management measures, especially in terms of emerging techniques and is reproduced here below. 39. Technological developments in best available techniques (BATs). The following overview of the most recent technological BAT developments in relation to annex III of the Protocol covers both new and existing stationary sources and is given for each source category as indicated in annex III (See table 1 below). Additional information is given for emerging technologies. Techniques already described in annex III are not taken into account for this summary. For further information on techniques with regard to application, environmental performance etc., reference is made to the background information. Table 1. Overview on Most Recent Developments with BAT and other Emissions Control Techniques1 Sector Combustion of fossil fuels in utility and industrial boilers 1 BAT Stable combustion conditions (reduce peak emissions) Wet FGD plus particulate control device (ESP or FF) (plus high dust SCR) Injection of sorbent prior to FGD Carbon filter bed filtration of flue gas For low sulfur fuels (e.g. biomass): FF Emerging Techniques New designs of ESPs Improving the liquid-to-gas ratio Wet FGD Tower Design Injection of activated carbon impregnated with additives Low-NOx technologies Reburning Simultaneous control of sulfur dioxide, nitrogen oxides and Hg (Source: http://www.unece.org/env/lrtap/TaskForce/tfhm/third%20meetingdocs/PostOttawa/Background_BATELV_14.06.06.FINAL.doc ) Compilation of an inventory of existing risk management measures: Lead and Cadmium Primary iron and steel industry Direct reduction/smelting reduction (alternatives to the coke oven/BF route) Efficient capture and exhaust of emissions Processing of ferrous metal ores Increase the mercury rejection to the tailing Sinter plants Fine wet scrubbers or FF with lime addition Exclusion of PM from last ESP field from recycling to the sinter strand Recirculation of waste gas Pelletisation plants Scrubbing Semi-dry desulfurization and subsequent PM removal Blast furnaces Hot stoves Cast house PM removal Secondary Minimize the presence of mercury in the scrap by iron and steel removing mercury-bearing components industry Electric arc furnace Direct off gas extraction (4th or 2nd hole) Iron foundries Minimizing fugitive emissions Cupola furnace melting of cast iron Improve the thermal efficiency Divided blast operation (2 rows of tuyères) for cold blast cupolas Oxygen enrichment of the blast air Minimize the blast-off periods for hot blast cupolas Induction furnace melting of cast iron and steel Increase furnace efficiency Dry flue-gas cleaning Rotary furnace melting of cast iron Increase the melting efficiency Post combustion Dry PM removal Primary and Minimize emissions from materials handling, storage and secondary transfer non-ferrous Sealed reactors and furnaces metal industry Processes connected to a sulfuric acid plant: Wet scrubber or wet ESP Removal of mercury from off-gas Activated carbon filter Spray dry systems with downstream FF Removal of mercury from sulfuric acid Superlig Ion Exchange process Potassium iodide process Primary and secondary production of copper Various processes depending on raw materials FF (with lime injection) Scrubbing (if necessary) Secondary production of aluminium Various processes depending on raw materials FF or ceramic filter Primary and secondary production of lead and zinc Various processes depending on raw materials FF /wet ESP /wet scrubbing (depending on process) Production of gold FF / wet ESP / scrubbing (depending on process) Production of mercury Phase out primary production of mercury 17 _______________________ Fuel cells Biomass-fired IGCC Blast furnaces Continuous steelmaking Basic oxygen steelmaking and casting New reagents in the desulfurisation process Foaming techniques at pig iron pretreatment and steel refining Electric arc furnace Comelt EAF / Contiarc furnace / Direct reduction / Liquid iron Selenium filter Odda chloride process Primary and secondary production of copper Bath smelting ISA Smelt hydro-metallurgical processes (e.g. leach-solvent extraction-electro-win (L:SX:EW) process) Secondary production of aluminium Reuse of filter PM Catalytic filter bags Primary and secondary production of lead and zinc Leaching processes based on chloride Injection of fine material EZINEX process (direct treatment of EAF dusts) Direct smelting Lead sulfide process BSN process using PM from EAF Production of gold 'J' process Gold production from pyrite Compilation of an inventory of existing risk management measures: Lead and Cadmium Cement industry Stop surpluses re-entering the market Production of mercury from secondary raw materials Mercury scrubber (Boliden, thiosulphate etc). concentrate Production of mercury Process with abatement of fine mercury particles Dry process kiln with multi-stage preheating and precalcination Fluidised bed cement manufacturing Lower exhaust temperature Adsorption on activated carbon Plasma melter Glass industry ESP or FF (with dry or semi-dry acid gas scrubbing) Dry Injection FF/ Dry Lime Scrubber combination, or wet scrubber Minimize downstream emissions Chlor-alkali PARCOM decision 90/3 of 14 June 1990 (phase-out of the industry mercury process) was reviewed in 1999-2001 without any changes Conversion to membrane cell technology Non-asbestos diaphragm technology Stop surplus of Hg from decommissioning re-entering the market Minimizing emissions from handling, storage, treatment and disposal of mercury-contaminated wastes Gas stream cooling to remove mercury from hydrogen stream Mist eliminators Scrubbers Adsorption on activated carbon and molecular sieves Complete enclosure of the cell room Municipal, In some countries, no differentiation between municipal, medical and hazardous and medical waste in terms of applied hazardous techniques or achievable emission limits. waste Separate collection and treatment of mercury-containing incineration wastes Substitution of mercury in products Sorbent injection FGD Carbon filter beds Wet scrubber with additives Selenium filters Activated carbon injection prior to the ESP or FF Activated carbon or coke filters Selective catalytic reduction (SCR) Co-incineration of waste and recovered fuel in cement kilns BAT for cement kilns Co- incineration of waste and recovered fuel in combustion installations Avoid Hg entering as an elevated component of the secondary fuel Gasification of the secondary fuel Injection of activated carbon BAT for combustion installations Definition of Acronyms used in Table 1: BAT BF BOF BREF CFA 18 _______________________ Best available techniques Blast furnace Basic oxygen furnace Best available technique reference document Circulating fluidized-bed absorber Heavy metal evaporation process Hydro-metallurgical treatment + vitrification Municipal waste incineration PECK combination process Compilation of an inventory of existing risk management measures: Lead and Cadmium EAF ESP FF FGD IGCC PM SCR 19 _______________________ Electric arc furnace Electrostatic precipitator Fabric filter Flue gas desulfurization Integrated gasification combined-cycle Particulate matter Selective Catalytic Reduction 40. Elements from the report entitled “Exploration of possible options for the reduction of heavy metals from a technical point of view, including costs and benefits” (by Maarten van het Bolscher, Johan Sliggers and Jean-Paul Hettelingh) are reproduced here-below. The report summarized knowledge of – and comparison between – heavy metal emission reduction scenarios and resulting depositions and critical exceedences. The focus of the report is on the relative assessment of the effect on mercury, cadmium and lead – and more tentatively of other heavy metals – on human health and the environment. Exploration of possible options for the reduction of heavy metals from a technical point of view, including costs and benefits (Maarten van het Bolscher, Johan Sliggers and Jean-Paul Hettelingh) Introduction. At the 24th Executive Body meeting in December 2006 Parties to the Heavy Metals (HM) Protocol agreed that the first review of the Protocol had been completed. Also, the EB endorsed the work plan of the Task Force for 2007. Main items in this work plan are: (a) Explore from a technical point of view options for further reducing the emissions of the heavy metals listed in Annex I. Advantages and disadvantages of the options will be compiled; and (b) Assess quantitative and, where this is not possible, qualitative information on health and ecosystem benefits of further measures to reduce emissions of heavy metals listed in Annex I. Parties to the Protocol at the EB felt that more insight was necessary on the various options to reduce emissions of heavy metals further including their costs and (qualitative) benefits before they conclude on a possible revision of the Protocol. This paper addresses possible options for the further emission reduction of heavy metals. For a number of options the emission reduction, the costs involved with those options and their effects, expressed as exceedances of critical loads, have been compiled. The basis of the compilation is formed by two studies and reports: • Study to the effectiveness of the UNECE Heavy Metals (HM) Protocol and cost of possible measures, Phase II: Estimated emission reduction and cost of options for a possible revision of the HM Protocol (Visschedijk et al., 2006) • Heavy Metal Emissions, Depositions, Critical Loads and Exceedances in Europe (Hettelingh et al., 2006). Both reports have been presented at the Working Group on Strategies and Review in September 2006 and will be presented at the Task Force on HM in Vienna in June 2007. The reports can also be found on the home page of the Task Force on HM. In this paper, which deals with the European case only, you will find the description of the options for the further reduction of heavy metals in chapter 2. The compilation on the emission (reduction)s, costs and exceedances per option is given in chapter 3. This chapter also presents and discusses results. The paper concludes with a more general discussion on a possible revision of the HM Protocol in chapter 4. Compilation of an inventory of existing risk management measures: Lead and Cadmium 20 _______________________ Options for the further reduction of heavy metals. Seven options have been explored starting from the full implementation of the current 1998 HM Protocol. The option that all countries fully implement the current HM Protocol is to be seen as a baseline and forms the minimum case. The maximum case is when additional measures for all three priority metals at new and existing sources are taken. Figures on emission (reductions), costs and exceedances have been compiled for all European countries in the EMEP domain. In the various options distinctions are made between EU+ (EU25 countries plus Norway and Switzerland. Note: When the underlying studies, that have been used for this paper, were performed Bulgaria and Romania were not part of the EU yet) and non-EU countries. Two main sets of measures are explored, one for dust related mesures that reduce emissions of Cd and Pb and one for measures that reduce emissions of Hg. Other distinctions between scenarios are whether measures are taken for new stationary sources only or for both new and existing stationary sources. Product measures on Hg as foreseen in the EU have not been taken into account. For the following seven options figures have been compiled: 1. Full implementation HM Protocol. In this first option all European countries ratify and implement the 1998 HM Protocol. 2. Additional measures Cd and Pb new. In this option all countries fully implement the HM Protocol and take additional measures at new stationary sources for Cd and Pb. This means in effect that they take dust related measures at all relevant significant sources. 3. Additional measures Cd and Pb new. The EU(25)+ also existing. All countries take dust related measures at new stationary sources. The EU+ countries also take these measures at existing stationary sources. 4. Additional measures Cd and Pb new and existing.All countries take dust related measures at new and existing stationary sources. 5. Additional measures Cd and Pb new and existing. The EU(25)+ also additional measures Hg new. All countries take dust related measures at new and existing stationary sources. The EU(25)+ countries also take Hg measures at new stationary sources. 6. Additional measures Cd and Pb new and existing. Additional measures Hg new and the EU(25)+ also for existing. All countries take dust related measures at new and existing stationary sources. All countries take measures for Hg at new sources and the EU(25)+ countries also take measures at existing stationary sources. 7. Additional measures Cd and Pb new and existing plus additional measures Hg new and existing. All countries take measures to reduce emissions of dust and Hg at new and existing stationary sources. 1. Emission, costs and exceedances of the options to reduce HM emissions Options The starting point for the identification of possible options for the reduction of HM emissions is the selection of sources based on the contribution to the 2020 HM emissions. For 2020 full implementation is assumed (all European UNECE countries) of the current HM Protocol and implementation of all foreseen autonomous developments. The reduction will be discussed via a possible strengthening of the Protocol and subsequent quantification of emission reductions and costs. As described in chapter 2, we have identified seven different possible options for strengthening of the Protocol on HM. Option 1 can be seen as the baseline scenario, where no additional Compilation of an inventory of existing risk management measures: Lead and Cadmium 21 _______________________ measures have been included. Step-wise, additional measures are shown for two country groups, EU(25)+ and non-EU(25)+. Finally Option 7 includes all additional measures. The possibility for further reductions of HM emissions has been explored by selecting new emission limit values (ELVs) based on information submitted by IFARE to the Task Force on Heavy Metals for updating the Annex V of the Protocol. These more strict ELVs could replace those that are currently in the Protocol upon a possible revision. Emissions The projected emissions of Cd, Hg and Pb in 2020 and the reduction percentage in relation to the ‘baseline’ Option 1 are shown in Table 2. Within the analysis a distinction has been made between the EU 25 member states plus Norway and Switzerland (EU(25)+) and the other European UNECE countries (non-EU(25)+). The projected emissions for 2020 for the EU(25)+ assume implementation of the IPPC Directive as autonomous policy. This implies that in 2020 all major industrial sources of air pollution will use technologies equal or equivalent to BAT as described in the IPPC BREF Documents. Costs Besides the emissions and emission reduction for Cd, Hg and Pb in 2020 as a result of the different options, Table 2 shows the costs. The costs of the options are shown as incremental costs, calculated as additional costs on top of the costs of a full implementation of the present HM Protocol. This implies that the differences between the costs of the present ELVs and the adjusted ELVs will be calculated. Within the TNO study, costs have been described as the modification costs of an installation without distinguishing new and old installations. Since measures for only new installations could be an option we have made a rough estimation of the emissions, costs and exceedances when taking this into account. The estimation is based on the assumptions that installations have a life expectancy of 30 years, that the installations will be renewed gradually, and that this option will be applied starting from 2010. This implies that costs will increase slowly and emissions reduces slowly. For new installations measures have to be taken. In 2020 we estimate that 1/3 of the installations will be renewed making total annual costs in 2020 1/3 of the costs necessary to apply the measure to all installations at that time This estimation is of course a rough one and has its limitations. When building a new installation for example, new technologies will be used and costs and emissions could be much lower as described here. On the other hand the additional costs will be relatively small regarding the total costs of new installations. The cost figures and emissions within the grey rows of Table 2 must therefore be seen as a conservative estimation. It should be mentioned that ex-post evaluations of costs made show that these costs are a factor of 2 to 10 lower compared to the ex ante calculated costs. Exceedances Exceedances are computed by comparing critical loads with atmospheric depositions. Depending on the endpoint, exceedances can be computed to identify the risk for human health or the risk for ecotoxicological effects (see Hettelingh et al., 2006). However, the results described in this report focus on the most sensitive endpoint. Thus, the lowest critical load has been chosen if critical loads have been computed for both endpoints for any single ecosystem point in the European database. In this paper the risk of impacts caused by the deposition of Cd, Pb and Hg has been expressed as (a) the Area at risk, and (b) the Average Accumulated Exceedance (AAE). Table 2 (last column) shows the percentages of areas at risk of health or environmental effects caused by deposition of the heavy metals for the year 2020.The area at risk is computed as the percentage Compilation of an inventory of existing risk management measures: Lead and Cadmium 22 _______________________ of the European ecosystem areas (forest soils, grassland, arable land or freshwaters) as submitted by National Focal Centres (forest soils otherwise) of which the critical load of a metal is exceeded by the deposition of this metal. The AAE is the ecosystem area-weighted sum (in g ha-1 yr-1) of the individual exceedances (deposition minus critical load, with zero for non-exceedance) of all ecosystems in a region (see Hettelingh et al., 2006, pp.38). As any other statistic, an AAE can be computed for Europe, a country, a (sub-) region, an EMEP grid cell, or ecosystems within and EMEP grid cell. In this paper both the Area at risk and the AAE are computed for EU25 Member States plus Switzerland and Norway, the nonEU(25)+ countries under the LRTAP Convention and for the whole of Europe (EMEP domain). Results Table 2 gives an overview of the options and the related emissions, costs and areas at risk. Besides grey marked rows, the options show a step by step increase in emission reduction. The reason for the decrease in emission reduction (grey rows), instead of an increase, is due to the fact that by implementing the specific Hg measures a few dust measures become redundant. Those dust sources (Cd and Pb emisions) will also be covered for only 1/3 within this scenario by the Hg measure, because the dust measure has become redundant compare to a full implemented Hg measures. Since only 1/3 of these Hg measures will be applied in these ‘grey rows’, there will be more emission from the dust sources (Cd and Pb emission). Those installations that aren’t renewed yet within this scenario, but are subject to be renewed within the future will therefore have a higher emission for Cd and/or Pb for some sources. As can be seen the emission of Hg is poorly mitigated by generic dust emission reduction measures (Option 1 to 4). In general, measures under the HM Protocol focus on dust removal, thereby reducing the emissions of HM. For Hg this is less efficient as most of the Hg emissions occur in the gaseous phase. Therefore, Hg measures are shown separately from the measures taken to reduce Cd and Pb. Starting from Option 5 the Hg measures are included, first only for new installations in the EU(25)+, up to a full implementation for all countries for Option 7. While analysing Table 2 its good to know that in the non-EU(25)+ countries all costs are included. For EU(25)+ countries, where the IPPC Directive has been implemented, this is regarded as autonomous development. Therefore the costs in the EU(25)+ will often appear lower than for other countries because the EU(25)+ countries have to comply with EC Directives, such as the IPPC Directive, and may already made (a part of) the costs. So, lower costs for the EU(25)+ does not imply that they take less measures or that they have lower costs. It is just showing the incremental costs for additional measures as a result of extra measures in a revised HM Protocol. The costs will be presented as total annual costs (the sum of amortization and operational costs) and are expressed in Euro (€) as of year 2000. End-of-pipe removal of Hg is in most cases not regarded as BAT by the IPPC, and costs are usually relatively high. Therefore, Options 6 and 7 show a relative high increase in incremental costs. The costs of emission reductions give, due to the limitation of cost data underlying the results, an order of magnitude of the costs range. Table 3 shows that overall in Europe the area at risk for Cd deposition reduces from 0.10 % for Option 1 to about nihil for Option 7. The area at risk in non-EU(25)+ diminishes from 0.16 % under Option 1 to 0,02% under Option 7. Also the exceedance magnitudes are very low. However, it should be noted that the deposition calculations of Cd are likely to be underestimated. Additional loads from manure and/or fertiliser will extend the area and magnitude of exceedance in central Europe. The risk of Pb deposition expressed as AAE is highest in the EU(25)+ (5 and 3 g/ha yr in options 1 and 7 respectively), while the area at risk is highest in non-EU(25)+ (35% and 14% in options 1 and 7 respectively). Compilation of an inventory of existing risk management measures: Lead and Cadmium 23 _______________________ Finally, the risk of mercury turns out to cover a broad area in Europe. 80% of the area is at risk under Option 1 which is reduced by 6% to 74% under option 7. The risk is highest in nonEU(25)+ countries covering 97% of the area (with an AAE of 0,14 g ha-1 yr-1) under option 1. Peak Average Accumulated Exceedances that are higher than 0,4 g ha-1 yr-1 occur in most of the Parties under the Convention (see Hettelingh et al., 2006, pp. 53) Under Option 7 the risk of Hg in the non-EU(25)+ diminishes to an area at risk of still 91% (with an AAE of 0,069 g ha1yr-1). Areas with AAE peaks exceeding 0,4 g ha-1yr-1 are reduced to a limited set of scattered grid cells in the whole of Europe. The southern part of Greece remains highly exposed. In the end it should be noted that the risk of Options 2 to 6 lie between those described for Options 1 and 7. Other It is important to note that many measures that target a specific HM have substantial co-benefits as ultimately a whole group of substances (e.g. other heavy metals, particulate matter and/or dioxins) will be reduced. So thus, the injection of activated carbon, as a Hg emission reduction measure has, a co-benefit due to the removal of specific other gaseous compounds, such as dioxins. The relative decrease of emissions by metal as a result of tightening the ELVs is shown in Figure 1. 100% Percentage 90% 80% Cd 70% 60% Hg 50% Cr 40% 30% Cu 20% 10% Ni Pb As Se 0% EU(25) plus Norway and Switzerland Other European UNECE Members Total UNECE Europe Zn Country Group Figure 1 Emission reduction potential of a possible revision of the HM Protocol following the tightening of the ELVs Compilation of an inventory of existing risk management measures: Lead and Cadmium Emissions, costs and area at risk for the different options in 2020 New source Existing source Hg measures New source 2. Additional measures Cd and Pb new. X X 3. Additional measures Cd and Pb new. The EU+ also existing. 4. Additional measures Cd and Pb new and existing. X X X X X X X 5. Additional measures Cd and Pb new and existing. The EU+ also additional measures Hg new. 6. Additional measures Cd and Pb new and existing. Additional measures Hg new and the EU+ also for existing. X X X X X X X X X X X 7. Additional measures Cd and Pb new and existing plus additional measures Hg new and existing. X X X X X X Cd Existing source 1. Full Implementation HM Protocol. X X X Emissions (tonnes) Pb Hg Costs (M€) Reduction (%) Countries Dust measures Reduction (%) Option Reduction (%) Table 2 24 ________________________________________________________________________________________ All 149 31% 2813 51% 307 3% EU(25)+ 83 13% 1551 41% 124 12% 0 0 0 448 2 546 2 994 1 344 2 546 3 890 1 344 7 637 8 981 4 848 non-EU(25)+ 68 44% 1265 60% 166 5% 7 637 EU(25)+ 95 0% 2622 0% 141 0% non-EU(25)+ 121 0% 3139 0% 175 0% All 217 0% 5761 0% 316 0% EU(25)+ 90 5% 2264 14% 141 0% non-EU(25)+ 103 4778 20% 17% 172 194 15% 11% 2514 All 313 2% 1% EU(25)+ 81 15% 1548 41% 141 0% non-EU(25)+ 103 15% 2514 20% 172 2% All 184 1548 29% 41% 313 81 15% 15% 4062 EU(25)+ 141 1% 0% non-EU(25)+ 68 44% 1265 60% 166 5% Area at risk (%)* Cd Pb Hg 0,03 38 66 0.1 33 80 <0.10 <33 <80 66 <0.10 <33 <80 66 <0.10 <33 <80 All 151 31% 2816 51% 290 8% 12 485 >0.02 >19 >74 EU(25)+ 77 19% 1540 41% 89 37% 11 936 0.02 27 61 non-EU(25)+ 74 39% 1276 59% 148 16% 10 187 All 151 30% 2816 51% 237 25% 22 123 >0.02 >19 >74 EU(25)+ 77 19% 1540 41% 89 37% 27 61 60 50% 1250 60% 94 46% 11 936 15 454 0.02 non-EU(25)+ All 137 37% 2790 52% 183 42% 27 390 0.02 19 74 Emission and Cost data have been obtained from Visschedijk et al. (2006) (See text for an explanation on the grey marked rows ). Area at risks data have been obtained from Hettelingh et al. (2006) *Please be aware that the countries covered within the two studies is not exactly the same. Due to rounding off the numbers, there migth be a small difference between the numbers in the TNO study and the numbers in the table Compilation of an inventory of existing risk management measures: Lead and Cadmium Table 3 Ecosystem areas in1: The area at risk (%) and Average Accumulated Exceedance (g ha-1yr-1) of areas within the EMEP domain of Europe, in the EU25 Member States plus Norway and Switzerland (EU(25)+), and other Parties under the Convention (non-EU(25)+) for the Options 1 and 7. Option 1 Cd Area at risk Pb Average Accumulated Exceedance Area at risk (g/ha yr) EU(25)+ non-EU(25)+ All 25 (%) 0,03 0,16 0,1 nil nil nil Hg Average Accumulated Exceedance Area at risk Average Accumulated Exceedance (g/ha yr) (%) 30 35 33 5 2 3 (g/ha yr) (%) 64 97 80 0,11 0,14 0,12 Option 7 Cd Pb Hg 0,02 nil 25 3 57 0,06 EU(25)+ non-EU(25)+ 0,02 nil 14 1 91 0,069 0,02 nil 19 2 74 0,064 All 1 EU25+: EU countries before 31 december 2006 excl. Malta for the risk assessments of all metals and Finland for the assessment of the risk of mercury, due to lack of data. General discussion on a possible revision of the HM Protocol In this paper seven options to reduce HM further have been investigated. Although more options could have been undertaken they give a good overview of what can be done to abate HM emissions further. Variants to the options in this paper are different time frames for the implementation of measures for Western countries (the EU+ and North America) and European non-EU countries. Other possibilities are e.g. a difference in obligations, binding measures or non-binding measures. The options are independent of where the further reduction land in a protocol. One could revise the current HM Protocol or draft a new ‘Second HM Protocol’. Another possibility is that since the HM Protocol is to a very large extent a dust related protocol that the HM Protocol is extended to a protocol on primary particulate matter (PM) and heavy metals (a Protocol on PM/HM). It could be a technology-based protocol with obligations on BAT and ELVs and not on mandatory emission ceilings. This possibility might be attractive for emission inventories of HM and PM are not as accurate as are the substances now addressed in the Gothenburg Protocol. Such a technology-based protocol can be drafted fairly quickly. Such a protocol on PM/HM would also have the advantage of not increasing the complexity of the Gothenburg Protocol with PM. The current idea is to add PM to the possibly revised Gothenburg Protocol. Since HM and primary PM are largely overlapping one could also include HM into the revised Compilation of an inventory of existing risk management measures: Lead and Cadmium 26 Gothenburg Protocol. A distinct disadvantage would be that it would become even more difficult to implement and ratify such an all-encompassing protocol. This paper explores options to reduce HM emissions from stationary sources. For Hg the EU has many product regulations on Hg containing products. These regulations go beyond the measures in the HM Protocol in Annex VI (mandatory measures) and Annex VII (voluntary measures). For a new HM protocol one could opt for the EU+ and North America to have more mandatory Hg product measures in Annex VI. Other European non-EU countries could possibly have time exemptions on these additional Hg measures. For Cd and Pb containing products the situation is more complex. It is only after combustion that these metals are released into the atmosphere. One could place measures on the limitation of Cd and Pb in products into a non-mandatory annex (e.g. Annex VII). References Visschedijk, A.J.H., H.A.C. Denier van der Gon, M. van het Bolscher, P.Y.J. Zanveld (2006), Study to the effectiveness of the UNECE Heavy Metals (HM) Protocol and costs of additional measures, Phase II: estimated emission reduction and costs of options for a possible revision of the HM Protocol, TNO-report 2006-A-R0087/B. Hettelingh, J.-P., J. Sliggers (eds.), M. van het Bolscher, B.J.Groenenberg, I. Ilyin, G.J.Reinds, J.Slootweg, O.Travnikov, A.Visschendijk, W.de Vries (2006), Emissions, depositions, critical loads and exceedances in Europe, Report of the Directorate for Climate Change and Industry, Dutch ministry of VROM (also available at the CCE from www.mnp.nl/cce ). 3.3 World Bank 41. Environmental, Health and Safety Guidelines. In April of 2007 new versions of the World Bank Group Environmental, Health and Safety (EHS) Guidelines were published. These guidelines consist of general guidelines that address performance levels and measures related to Environmental, Occupational Health and Safety, Community Health and Safety and Construction and Decommissioning as well as industry specific guidelines including ones for Base Metal Smelting and Refining. A copy of the general EHS guidelines is available at: http://www.ifc.org/ifcext/enviro.nsf/Content/EnvironmentalGuidelines . Compilation of an inventory of existing risk management measures: Lead and Cadmium 27 4. INFORMATION SUBMITTED FROM OR RELEVANT TO NON-GOVERNMENTAL ORGANIZATIONS 4.1 International Lead Association 42. Voluntary Risk Assessment on Lead (prepared by the Lead Industry). The Voluntary Risk Assessment on Lead and Lead Compounds (VRAL) has been produced by consultants appointed by the Lead Development Association International (LDAI). The VRAL reports have been reviewed by independent scientific review panels. The Netherlands has acted in the role of Sponsor Country. The reports were submitted in May 2005 to the Technical Committee on New and Existing Chemicals (an European Commission working group) of Council Regulation (EEC) 793/93, Directive 67/548/EEC (TC NES). The first in-depth discussion on the environment assessment took place at TC NES III ’06 (2006). 43. The following is a descriptive pamphlet on the document from the International Lead Association website http://www.ila-lead.org/documents/FS_VRAL.pdf Throughout the world, legislation is under constant review to ensure that both man and the environment are adequately protected from lead’s hazardous properties. Towards the end of the 1990s it became clear that, despite the huge body of information available on lead, some data gaps still existed. As a result industry volunteered to conduct a comprehensive assessment of lead risks in the European Union (EU). In the EU at the time, an official procedure already existed for governments to conduct such assessments. However no assessment had ever been conducted on lead. The lead industry was the first industry to volunteer to perform such an assessment according to this procedure. As a result the industry spent many years working with the European Commission and EU governments to agree on a process by which industry could carry out a risk assessment in an open and transparent way, and ultimately for the assessment to be reviewed by EU governments. To avoid any accusation of bias, independent consultants were appointed to conduct the assessment and leading international experts in the field of lead were appointed to two independent scientific review panels which periodically reviewed the work output. Both the consultants and the review panel members were approved by the European Commission and a Reviewing Country. The Netherlands government agreed to participate as the Reviewing Country to monitor progress. The risk assessment is extremely comprehensive, covering lead metal and the major lead compounds throughout the life cycle (i.e. from production through to use, recycling and, where recycling is not possible, disposal). The process of conducting the risk assessment took four years, after which draft reports on environment, health and waste were submitted to the European Chemicals Bureau in Compilation of an inventory of existing risk management measures: Lead and Cadmium 28 2005. Since then the reports have been extensively reviewed by EU government and will also be reviewed by the EU’s independent Scientific Committee on Health and Environmental Risks (SCHER). The project is already providing valuable information on how risks from lead can be effectively managed, for example in the case of worker health, and industry is committed to implementing these measures. The report is also helping to identify areas where further research is needed and again industry is committed to delivering this. The €4 million cost of the risk assessment has been met in its entirety by the lead industry. The work has helped the industry improve its knowledge of the impact of lead on health and the environment. The information has also been useful to regulators of national and local issues. 4.2 International Lead Management Centre (ILMC) 44. The International Lead Management Center (ILMC) has experience over a decade in management of lead exposure risks through the introduction of specific Environmentally Sound Management (ESM) procedures tailored to the distinct lead exposure issues unique to each country’s cultural, technical, geographic and socio-economic circumstances. 45. The ILMC offers a number of publications containing consensus health materials and detailed lead risk information for the lead mining, refining, manufacturing and recycling sectors. Many of these publications address the data needs are highlighted in this compilation. They include: ILMC Ceramics Handbook ILMC Ceramics Primer for the non-Ceramist ILMC Fact Sheets Risk Management Processes Lead Risk Management at a Lead Recycling Facility ILMC Guidance Documents Sound Management of Solid Waste in the Lead Industry Control and Monitoring of Atmospheric Emissions Control and Monitoring of Liquid Effluent Design of Lead Plant Changing Rooms and Washing Facilities Effective Communication and Public Relations Voluntary Agreements – The ILMC Experience The Various Types of Lead Acid Battery and the Importance of Recycling Battery Design for Cleaner Production Control Strategies and Policies for Recycling ULAB in the “informal” Sector Establishing a Community Care and Outreach Program Strategies for the Remediation of Lead Contaminated Soil Health Issues for Lead Workers and the General Population. 46. All of these publications are available on the ILMC web site at http://www.ilmc.org/pub.html along with other reports on workshops and pilot programs that they Compilation of an inventory of existing risk management measures: Lead and Cadmium 29 have conducted throughout the world. Cooperative interactions between ILMC and the Basel Secretariat have also produced a number of guidance documents directly relevant to waste disposal and recycling issues specific to the needs of developing countries: http://www.basel.int/pub/techguid/tech-wasteacid.pdf http://www.basel.int/stratplan/oewg1/projdocs/elsalvador/issuesrecylcingE.pdf http://www.basel.int/meetings/sbc/workdoc/tm-ulab/techdocs.html http://www.basel.int/stratplan/oewg1/projdocs/elsalvador/final-reg-strategy-e.doc 4.3 Scientific Committee on Problems of the Environment (SCOPE) 47. SCOPE, an interdisciplinary body of natural and social science expertise focused on global environmental issues, operating at the interface between scientific and decision-making processes, consists of a worldwide network of scientists and scientific institutions developing syntheses and reviews of scientific knowledge on current or potential environmental issues. 48. The SCOPE website provides the working group reports and abstracts of the papers presented during the workshops as follows: http://www.icsu-scope.org/ >> menu Scientific Programme >> projects profile >> scroll down to Environment and health >> cadmium in the environment >> scroll down to bottom of the page and click in a respective workshop paragraphs. 49. A workshop on risk assessment and management of environmental cadmium was held at the University of Ghent, in Belgium on 3 to 6 September, 2003. It built on a previous workshop that involved a multidisciplinary evaluation of the environmental and human health dimensions of cadmium in the food chain. The second workshop comprised an interdisciplinary approach to risk assessment and management that involved the setting of standards, the development and implementation of policies, and the balancing of risk for cadmium in relation to meeting global food needs, with special reference to the developing world. It also aimed to identify the research needs and opportunities for risk assessment and management in the context of environmental cadmium. The workshop included one introductory paper on world food security, 20 technical background papers which addressed the diverse issues relating to risk management and assessment, five working group reports, and a meeting to develop a consensus summary report. The report of the first workshop and an extract from a second workshop are reproduced here below: Report from the SCOPE workshop risk assessment and management of environmental cadmium This workshop, held at the University of Ghent, Ghent, Belgium on 3-6 September, 2003, builds on a previous workshop entitled 'Environmental Cadmium in the Food Chain: Sources, Pathways, and Risks' held at the Belgian Academy of Sciences, Brussels, Belgium on 13-16 September, 2000. This first workshop involved a multidisciplinary evaluation of the environmental and human health dimensions of cadmium in the food chain. A Report from the first workshop is available on the SCOPE Website http://www.icsu-scope.org Compilation of an inventory of existing risk management measures: Lead and Cadmium 30 The present workshop comprised an interdisciplinary approach to risk assessment and management that involves the setting of standards, the development and implementation of policies, and the balancing of risk for cadmium in relation to meeting global food needs, with special reference to the developing world. It also aimed to identify the research needs and opportunities for risk assessment and management in the context of environmental cadmium. The workshop included one introductory paper on world food security, 20 technical background papers which addressed the diverse issues relating to risk management and assessment, five working group reports, and a meeting to develop this consensus summary report. ………………………………………………………………………………………………………… Cadmium is a toxic metal. Although studies of occupationally-exposed workers have demonstrated that cadmium is a human carcinogen by inhalation, epidemiologic studies have not confirmed that it is carcinogenic by ingestion. However, some populations have developed significant renal and bone disease from cadmium ingested through the food chain, resulting originally from mine waste and industrial pollution of croplands. The SCOPE Environmental Cadmium project has focused on the transfer of cadmium from sources through the food chain to human and ecologic receptors. Understanding the factors that influence the rates and efficiency of transfer from each of the compartments in the food chain) is essential for a comprehensive risk assessment, and identifies targets and options for risk management interventions. Setting standards to protect soil, plants, animals, and humans from exposure to cadmium is a high-profile policy issue, because, the ability to apply phosphate fertilizer and to reuse sewage sludge (biosolids), may be constrained by current risk assessments for the cadmium that they contain. A major concern arises because phosphate fertilizers, widely used throughout the world and essential for food production, contain varying amounts of cadmium. At the same time, regulations introduced with a view to protecting certain populations may have unforeseen effects involving nutrition, public health, and social and economic factors on other populations. The SCOPE Environmental Cadmium Project has considered these as an integral part of its risk investigation. RISK ASSESSMENT AND RISK MANAGEMENT Risk Assessment Risk assessment is a scientific/statistical process. A risk assessment estimates the probability of an adverse effect occurring under a certain set of circumstances. Risk assessment of a chemical compound in the environment quantifies the hazardous properties, exposure, and dose, and their effects, with special emphasis on critical receptors and significant endpoints. Risk assessments can be multi-chemical, multi-media, and multi-pathway, taking into consideration the additive contribution from different exposures. The SCOPE Environmental Cadmium Project has focused its risk assessment on inputs of cadmium to soil, its transfer through the food chain and effects on humans and ecological receptors. Because cadmium concentrations in soil may increase or decrease over time, a risk assessment should estimate the impact of such changes. Estimating the risk of actual cadmium releases and food chain transfer to humans, requires quantifying a series of steps. The cadmium exposure to humans is mainly driven Compilation of an inventory of existing risk management measures: Lead and Cadmium 31 by cadmium in staple food crops (i.e., cadmium in cereals and tubers) which in turn originates from cadmium in soil. Soil cadmium concentrations are influenced by the natural background and by anthropogenic sources that include phosphate fertilizers, atmospheric deposition (reflecting ongoing emissions from industries and utilities), and applications of sewage sludge in localized areas. These additions will increase the cadmium content of agricultural soils, with the increase being dependent on the cadmium loading from the different inputs and on various removal mechanisms such as leaching. In addition, not all of the cadmium in soil will be available to plants. Risk Management Risk management involves various options for interventions to minimize the input of cadmium and its transfer through the food chain to the target organ (i.e., the kidney in the human body). These can occur at any level in the food chain, (i.e., the soil, plant, animal, and human). However, risk management has to balance potential benefits with actual costs. This is a particularly complex situation for cadmium, as indicated by the beneficial effects of phosphate fertilizer on crop yield and the negative effects on the trade in phosphate fertilizers resulting from regulation based on the cadmium-content. The sequence of transfer of cadmium from soil to crop to the kidney is fixed, but the amounts transferred can vary appreciably between each of these compartments. There are also major areas of uncertainty in the transfer of cadmium from source to receptor. This workshop focused attention particularly on the availability of soil cadmium to plants (phytoavailability) and the absorption and retention (bioavailability) by humans. The ease with which cadmium is transferred from soil to plant is influenced by soil characteristics (pH, chloride, zinc, iron, calcium, and probably other cations) and by plant characteristics; these include the species, variety or cultivar, and the cation status of the plant. Once food (or soil, in certain cases) has been ingested, there is a second major area of variability leading to uncertainty, and this relates to the efficiency with which cadmium is transferred from the matrix to the intestine and into the blood stream, and distributed within the body. The third area of uncertainty which remains is the dose that accumulates in the kidney, which triggers tubular damage manifested mainly by the excretion of a variety of low molecular weight proteins such as beta-2-microglobulin. The process of bioavailability comprises both the transfer of food-cadmium from the gut lumen to the blood (absorption) and the distribution of this cadmium to the vulnerable organ tissues (retention). In the past, the concentration of cadmium in food has been considered the overriding risk factor that determines body burden of this element. However, numerous studies have now revealed other factors that affect intestinal absorption and organ retention of cadmium. These include the composition of the diet itself and the age and sex and nutritional status of the consumer. A very important factor that is often overlooked is the interaction between cadmium and certain other nutrient cations in the diet that compete for transport sites in the intestinal mucosa, which can increase or decrease the absorption rate of dietary cadmium. The most important of these are zinc, iron, and calcium. Several studies have shown that deficient amounts of these cations in the diet enhance the intestinal absorption of cadmium and increase the cadmium content of the vital organs, particularly the kidney. Compilation of an inventory of existing risk management measures: Lead and Cadmium 32 Only recently, however, has it been shown in animal feeding studies that diets with mineral concentrations less than adequate, but not low enough to affect weight gain or general health, also increase absorption and organ accumulation of cadmium by as much as 10-fold. If these findings in animal studies are duplicated in human studies, they could be of particular importance in assessing and managing the risk of food cadmium in certain populations of the world where food is only mildly contaminated with cadmium, but also provides only low to marginal amounts of zinc, iron, or calcium. Thus a food cadmium concentration that is low risk to a well-nourished population may become medium to high risk to a population that is mildly to highly under-nourished with respect to zinc, iron, and calcium. STANDARDS FOR ENVIRONMENT PROTECTING PUBLIC HEALTH AND THE Standards can be set for products, for environmental concentrations, or developed from allowable daily intakes (dose in ug kg-1day-1). Standards are enforceable components of regulatory policy. The process of standard setting varies among state, national, and international agencies. The types of methodologies available for setting a standard include: Risk-based endpoints Soil-loading models for sustainability A mass-balance approach Harmonization to existing country or international standards Using existing food standards (e.g., Codex Alimentarius) coupled with a rigorous monitoring program As Low As Reasonably Achievable (ALARA) Maximum Achievable Control Technology (MACT) Best Available Control Technology (MACT) Precautionary approaches Water-quality standards have been set for cadmium based on ecotoxicology studies of aquatic life. Developing human health risk-based standards for cadmium, however, has been thwarted by significant data gaps and uncertainties, even though there is substantial data on some human populations with chronic exposure. The limitations, however, lie in the uncertainties mentioned above. Risk assessments have been completed by several agencies, yielding values to which individuals (including susceptible individuals) could be exposed on a daily basis, throughout their lifetime, without showing the symptoms of cadmium toxicity. These differ by less than an order of magnitude and in two cases they are the same. Compilation of an inventory of existing risk management measures: Lead and Cadmium Agency World Health Organization US Environmental Protection Agency Agency for Toxic Substances and Disease Registry 33 Name of threshold value Provisional Tolerable Weekly Intake (PTWI) Intake level per day 1.0 μg kg-1day-1 Reference Dose (oral) (RfD) 1.0 μg kg-1day-1 Minimal Risk Level (oral chronic) (MRL) 0.2 μg kg-1day-1 There are many uncertainties regarding phytoavailability and plant uptake, and bioavailability and absorption, which make the setting of standards very difficult. Bioavailability, in particular, is a vitally-important issue with respect to scientificallybase standards, supported by a risk assessment. More reliable and realistic assessments of the social and economic costs and benefits are required and these should be done as an integral part of any standard setting process. BALANCING RISK The workshop re-enforced the point that there has been no conclusive evidence of an adverse impact of the cadmium in phosphate fertilizer on human health, even in Australia which has a long history of application of phosphate fertilizer with a high cadmium content. In the case of international trade in phosphate fertilizers, limiting use on the basis of their cadmium content will restrict the export of those fertilizers from certain countries, with serious implications for their national economies. This must be balanced against the possible effects on human health in importing countries that use high cadmiumcontaining fertilizers. In the absence of phosphate fertilizer input, crop yields may be low and crop quality poor, with adverse effects on farm income and human health, resulting from the poor nutritional status of the diet. With high phosphate input, crop yields are larger and nutritional status is better, but if the cadmium content of the crop is also higher, because of the use of high cadmium-containing phosphate sources, there is a potential risk to human health, particularly in developing countries where deficiencies in calcium, zinc, and iron are prevalent. Women of child-bearing age who are iron-depleted and anemic would be at particular risk of cadmium accumulation. Thus benefits in one country may be offset by harm in another. In the context of risk balancing, it is essential that a comprehensive cost-benefit analysis is conducted on cadmium control measures from all sources. SOCIO-ECONOMIC IMPLICATIONS REGULATIONS FOR CADMIUM OF MORE RESTRICTIVE Managing environmental cadmium may, in part, involve the use of more restrictive regulations, for example, the proposed EU-wide Regulation on Cadmium in Fertilizers. The socio-economic evaluation of such regulation includes consideration of the associated benefits and costs, including both the source and destination nations. The Compilation of an inventory of existing risk management measures: Lead and Cadmium 34 decision to regulate cadmium by setting standards for concentration in food and fertilizers, should take into account effectiveness and efficiency. Although data presented at the present and previous (2000) workshops demonstrate the toxicity of cadmium and the relationship of dietary exposure to disease, a number of factors involving bioavailability, suggest that with adequate soil quality management and human nutrition, the risks associated with levels likely to be achieved in diets, can be kept low. Thus non-regulatory approaches or a mixed strategy, may be effective in maintaining cadmium levels as low as reasonably achievable. Other approaches to reducing cadmium exposure include: education (good agricultural practices, awareness of consumers, appropriate selection of fertilizer type and quantity matched to local soils and crops) stimulation of research and development reduction of trade-distorting tariffs ensuring an adequate supply and use of low-cadmium containing fertilizers stimulation of Corporate Responsibility and Product Stewardship programs. There is an urgent need for information on the efficiency of regulations. An accurate evaluation is hampered by the incomplete assessment of the social cost dimensions involved, because the costs may arise in countries remote from where benefits are realized. Currently, there is not a consensus about a number of costs and benefits. For example, the estimated costs of decadmiation vary between 8 Euros and 110 Euros per ton P2O5 . The calculation of these costs depends substantially on the assumptions made for the process being considered. In addition to a need for reliable and realistic benefit and costs figures, there is a need for a consensus among stakeholders as to which costs and benefits need to be considered. However, in general, stakeholders identify the following benefits and costs: Benefits: Increase of health and safety levels due to lower cadmium intake (associated with a high level of uncertainty) Increased perceived faith in the use fertilizers and consumption of food Opportunities for some fertilizers producers Stabilization/reduction of cadmium concentrations in soil Opportunities to develop alternative farming practices Opportunities for other economic sectors (e.g., cadmium waste management/recycling) Development of new (cleaner) technologies Costs: Increase in fertilizer costs: * Decrease in the use of phosphate fertilizers (particularly in developing countries) * Increased reliance on high cadmium fertilizers in some developing countries * Decrease in fertilizer production Nutrient imbalances due to inadequate or inappropriate fertilizer us Higher energy costs Increased public concern or "worry" about cadmium in fertilizer and food, may decrease faith in the use of fertilizers and consumption of food Disruption of established production and trade patterns Compilation of an inventory of existing risk management measures: Lead and Cadmium 35 Threats to other economic sectors Costs of new technologies: * Increase of costs * Increase of cadmium waste Less competition (possible monopolistic profits) Regulatory burdens Currently, a definitive cost-benefit analysis of cadmium regulation is impossible with the information available. There is need for further research on determining the effectiveness and efficiency of various levels of regulation and other adaptations in existing governmental policies. The current existing gaps in scientific evidence bearing on effectiveness and efficiency of different standards need to be filled. Regardless of the standards set or the strategies developed, monitoring programs are required to assess the effectiveness of any intervention and to allow revisions, when required. CONCLUSIONS 1. Cadmium is toxic to humans and organisms, and reduction of exposure to cadmium will be beneficial for human health, soil sustainability, and ecosystems. The need to reduce inputs of cadmium into the environment is widely accepted. 2. Additions of cadmium to the soil are the main inputs of cadmium into the food chain; these additions are mainly in phosphate fertilizers, from atmospheric deposition, and from the application of sewage sludge in localized areas. Further accumulation of soil cadmium should be prevented. 3. Risk assessment at this workshop has focused on inputs of cadmium to the soil, its transfer through the food chain, nd effects on human health. There are substantial data gaps at all stages in the food chain, particularly in assessing the risk to human health from exposure to dietary cadmium. 4. Risk management involves interventions to minimize the input and transfer of cadmium through the food chain to the target organ (i.e., the kidney in the human body). 5. Soil management practices (e.g., avoiding saline soils and saline irrigation water) and correcting zinc deficiency can effectively decrease the plant availability (phytoavailability) of soil cadmium. Although the correction of soil acidity decreases the mobility of cadmium in soils, it can have a varying and unpredictable effect on plant uptake. 6. Breeding plants for low cadmium uptake and a high uptake and storage of bioavailable iron and zinc in the plant, which can decrease the amount of cadmium absorbed in the intestine, offers considerable promise as a risk management strategy. 7. Standards are enforceable components of regulatory policy for protecting human health and the environment. However, there are many uncertainties with regard to phytoavailability and bioavailability (in particular) which make standard setting for environmental cadmium very difficult. Compilation of an inventory of existing risk management measures: Lead and Cadmium 36 8. There are social and economic costs and benefits resulting from the setting of standards. This is particularly relevant to cadmium, for which the impact of any standards set should be reliably and realistically assessed. 9. There is no conclusive evidence for any adverse effects on human health of the cadmium in phosphate fertilizers. Any limitations on the trade in phosphate fertilizers based on their cadmium content will have a major economic impact on certain phosphateexporting countries and this must be balanced against possible risks to human health in phosphate-importing countries. 10. Many soils in lesser-developed countries are deficient in phosphate. The introduction of regulatory measures that lead to a decrease phosphate fertilizer use is likely to have serious negative impacts on crop production, food quality, and human health, resulting from an inadequate diet, in those countries. 11. Managing environmental cadmium may partly involve the use of more restrictive regulations, e.g., the proposed EU-wide Regulations on Cadmium in Fertilizers. Reliable and realistic studies that assess social and economic costs and benefits are required before such regulations are imposed. 12. The effectiveness and efficiency of any regulations for cadmium require evaluation but this is hindered by the incomplete assessment of the social costs involved, in particular. There is a need for further research on the likely impact of various levels of regulation and other modifications to government policies, studies that do not appear to have been conducted. 13. There is an urgent need for further research on the topics identified at this workshop as being of high priority. WORKING GROUP REPORTS Specific details and recommendations provided in the five Working Group Reports are posted on the SCOPE Website (www.icsu-scope.org ): 1. Data gaps for risk assessment of cadmium in the food chain 2. Prioritizing risk reduction and management strategies for cadmium 3. Identifying methodologies for setting standards for cadmium 4. Risk balancing for agricultural production in developing countries 5. Socio-economic implications of more restrictive regulations for cadmium 50. In addition an extract from the report of the SCOPE Workshop – Environmental Cadmium in the Food Chain: sources, pathways and risks held in Brussels, Belgium, September 2000 has been reproduced here covering risk management options. Compilation of an inventory of existing risk management measures: Lead and Cadmium 37 POLICY Risk Management A defining feature of sound risk management is assuring its relevance to stakeholders, who must live with the options and should have input into the risk management process. This requires that the selection of endpoints be relevant to the population, and therefore risk management strategies to prevent a particular hazard, may differ regionally and over time. Risk management must take into account competing risks and must not introduce greater risks. The precautionary principle dictates that, in the absence of data or the presence of uncertainty, risks be managed at low levels until data are available indicating that less protection is warranted or acceptable. Given that cadmium may continue to build up in the environment, and future exposures may be substantially higher than at present, and that it is hazardous to human health and ecosystems, it is prudent to keep cadmium levels and bioavailability at safe levels. Economic Issues Measures and policies to reduce the potential risks to human health from food produced on soils with different levels of accumulated cadmium may be costly. Internationally food standards and requirements will change the patterns of world trade in both food products and fertilizers. Imposing food quality criteria will require fertilizer manufacturers, farmers, marketers, and consumers to modify their behavior. The costs and benefits to each need careful consideration. Controls at the fertilizer input level may be costly to the fertilizer production industry and ultimately to farmers and food consumers, particularly in the developing world where rapidly growing populations create increased energy demand. The removal of cadmium from phosphoric acid (decadmiation) is not cost-effective at present prices. The technical and economic conditions under which decadmiation becomes an economic option need to be established. The costs and benefits of alternative policy measures must be established in order to set socially optimal food safety levels. Their consequences for food security and international trade of less developed countries are particularly important.