Study contract on “Support related to the international work on
Persistent Organic Pollutants (POPs)”
Draft Management Option Dossier for
Short Chain Chlorinated Paraffins (SCCPs)
25 May 2007
Service Contract ENV.D.1/SER/2006/0123r
DG Environment, European Commission
The views expressed in this report are those of the consultants alone and do
not represent the official views of the Commission.
BiPRO
Beratungsgesellschaft für integrierte Problemlösungen
Table of Content
1
Introduction ....................................................................................................... 1
2
Chemical identity .............................................................................................. 3
3
Current sources of emissions ......................................................................... 4
4
5
3.1
Levels and trends of production, use and disposal/elimination .............. 4
3.1.1
3.1.2
Production ....................................................................................................... 4
Use ................................................................................................................. 6
3.2
3.3
3.4
3.5
3.6
3.7
3.8
Global demand in the future ................................................................. 11
Emissions from production ................................................................... 11
Emissions from handling and transport ................................................ 16
Emissions from the use of products containing SCCP ......................... 16
Emissions from waste containing SCCPs ............................................ 18
Emissions from recycling and dismantling ........................................... 20
Conclusion on current sources of emissions: ....................................... 20
Management options ...................................................................................... 22
4.1
4.2
4.3
Substitution .......................................................................................... 22
Measures to reduce emissions............................................................. 26
Legislative controls............................................................................... 27
4.3.1
4.3.2
4.3.3
Legislative control in the European Union ..................................................... 27
Legislative control in other countries ............................................................. 29
Measures/control by international institutions ................................................ 30
4.4
Cost implications .................................................................................. 32
4.4.1
4.4.2
4.4.3
Cost implications for industry ......................................................................... 32
Cost implications for consumers .................................................................... 39
Cost implications for state budgets ................................................................ 40
Identification and discussion of possible management options under
the UNECE POPs protocol ............................................................................. 41
5.1
5.2
6
Possible management options under the UNECE POPs protocol........ 41
Discussion of options ........................................................................... 43
References ...................................................................................................... 48
1 Introduction
This dossier concerns management options to reduce risks related to short chain chlorinated
paraffins (SCCPs).
At its 23rd session in December 2005 the Executive Body requested the Task Force on
POPs to prepare the technical elements for the track A review of proposed substances
(ECE/EB.AIR.87). The Task Force on Persistant Organic Pollutants (TFPOP) reviewed the
proposal on SCCPs in its 5th meeting in May 2006 and agreed that according to the risk
profile (Track A review) SCCPs should be considered as POP and a management option
dossier (Track B review) should be developed.
The Task Force generally concluded that the dossier contained sufficient information for
screening in relation to the requirements of Executive Body Decision 1998/2 and supported
the dossier’s conclusion that SCCP be considered a POP in the context of the Protocol.
The Task Force concluded that SCCPs are bioaccumulating, toxic and are generally
persistent and have potential for long-range environmental transport. Relating to
persistence, one expert noted that there was insufficient information on the persistence
of SCCPs in sediment (ECE/EB.AIR.5/2006/10). At its 24th session in December 2006, the
Executive Body noted the progress made on the track B review of SCCPs and invited the
TFPOP to continue its work on this substance and to complete the review (ECE/EB.AIR.89).
Recently reported results (in April 2007) demonstrate that SCCPs are persistent and that
SCCPs may therefore be confirmed as meeting the definitve criteria for persistence,
bioaccumulation and toxicity (ECB 2007).
The management options dossier is based on the risk profile for SCCPs (European
Commission 2005a) and is complemented with new data from several literature and
information sources. Up-to-date information was extracted from a questionnaire on
management options for reducing production, use and emissions under the UNECE Protocol
on POPs (UNECE survey 2007). Information has been provided by Belgium, Czech
Republic, Cyprus, Germany, the Netherlands, Italy, France, the United Kingdom,
Switzerland, Canada and the USA. Industry contributions were provided by ORICA and Euro
Chlor. The working draft risk profile on SCCPs prepared by Canada for the Stockholm
convention (POPRC 2007) and the responses to request for information on Annex E
requirements for the proposed POPs substances which have been submitted to the
Persistent Organic Pollutants Review Committee (POPRC) under the Stockholm Convention
have also been used as sources of up-to-date information.
SCCPs are n-paraffins with a carbon chain length of between 10 and 13 carbon atoms and a
degree of chlorination of more than 48% by weigth. These synthetic compounds are mainly
used in metal working fluids, sealants, as flame retardants in rubbers and textiles, in leather
processing and in paints and coatings. The marketing and use of these substances has
been restricted in the European Union1 due to the risks caused by the substance to the
health and environment. Due to Directive 2002/45/EC, the use of SCCP in EU countries
1
Restriction of marketing and use of SCCPs according to Directive 2002/45/EC
1
in metal-working fluids and for fat liquoring of leather had been rapidly decreasing
(UNECE EB 26 July 2006) and ceased. In Canada SCCPs are not produced any more.
The European production volume ranges from 1,500 to 2,500 tonnes per year. The
estimated figure for the USA ranges from 6000 to 8,800 tonnes per year.
Within the UNECE region viable substitutes appear to be available for all major use types.
The evaluation of the best substitute has to be done on a case by case basis in the light of
economic, technical, environmental, health and security aspects.
2
2 Chemical identity
This dossier considers short chain (C10-13) chlorinated paraffins.
IUPAC Name: Alkanes, C10-13, chloro
CAS No: 85535-84-8
EINECS No: 287-476-5
Synonyms: alkanes, chlorinated; alkanes (C10-13), chloro-(50-70%); alkanes (C10-13), chloro(60%); chlorinated alkanes (C10-13), chlorinated paraffins (C10-13); chloroalkanes (C10-13);
chlorocarbons (C10-13); polychlorinated alkanes (C10-13); paraffins chlorinated (C10-13).
Molecular formula: CxH(2x-y+2)Cly, where x=10-13 and y=1-13
Molecular weight: 320-500
SCCPs are viscous, colorless or yellowish, dense oils. They are practically insoluble in
water. The structure of two exemplary SCCP compounds (C10H17Cl5 and C13H22Cl6) is
illustrated in Figure 2-1.
Figure 2-1:
Molecular structure of two examplary SCCP compounds (C10H17Cl5 and C13H22Cl6)
There is a range of commercially available C10-13 chlorinated paraffins and they are usually
mixtures of different carbon chain lengths and different degrees of chlorination although all
have a common structure in that no secondary carbon atom carries more than one chlorine.
Owing to the many possible positions for the chlorine atoms, standard analytical methods do
not permit their separation and identification.
In the working draft risk profile prepared by Canada for the Stockholm Convention the
commercial mixture is proposed as identity for SCCPs under the Stockholm convention
(POPRC 2007).
Two other groups of chlorinated paraffins are produced commercially. These are known as
“mid, medium or intermediate chain length” (“MCCPs”, typically C14-17) and “long chain
length” (“LCCPs”, typically C20-30).
3
3 Current sources of emissions
3.1
3.1.1
Levels and trends of production, use and disposal/elimination
Production
According to the Chlorinated Paraffin Industry Association (CPIA2) SCCPs are currently
produced in the USA, Europe, India, and China. According to the working draft risk profile
2007-04-01 on SCCPs provided by Canada for the Stockholm convention (POPRC 2007)
chlorinated paraffin (CP) producers are also located in Russia, Taiwan, Japan and Brazil.
CPIA recently distributed a survey to the global CP producers in an effort to determine the
quantity of SCCPs produced. If sufficient responses are received, the information will be
submitted to UNEP (Annex E response 2007, CPIA).
According to the EU Risk Assessment Report, in 1994 SCCPs were manufactured within the
EU by two producers, at a total quantity of < 15,000 tonnes/year (European Commission
2000). According to the updated draft Risk Assessment Report from August 2005 (European
Commission 2005) SCCPs were produced by INEOS Chlor Ltd, UK (trade name:
CERECLOR) and Caffaro Chimica S.r.l., Italy (trade name: Cloparin). These were the only
EU producers of SCCPs in 2006.
SCCPs are also currently produced in Slovakia. For 2007 a dramatic decrease of production
in Slovakia is anticipated. Production figures for the preceeding years show a significant
decline from 560 tonnes in 2004 to 354 tonnes in 2005 and 380 tonnes in 2006 (Annex E
response 2007, Slovakia). According to national answers to the UNECE questionaire
production in Germany (1995) and in Belgium has stopped (UNECE survey 2007, BE, DE).
According to industry information, current production in Europe ranges between 1,500-2,500
tonnes (UNECE Survey 2007, Euro Chlor).
Currently a very limited number of companies supplies SCCPs in the EU. In Germany the
small amount of current imports originates from the USA and Asia (Annex E response 2007,
Germany referring to information from Euro Chlor). It is not indicated whether the imports
concern C10-13 chlorinated paraffins or other commercial mixtures.
SCCPs have never been produced in Switzerland (UNECE survey 2007).
It is not clear, if SCCPs have ever been produced in Canada. However there is no current
production. The only known Canadian producer of CPs produced MCCPs and LCCPs with a
chlorine content of up to 56%. This plant was recently sold and is not currently producing
any CPs (UNECE survey 2007, Canada).
With respect to production amounts in the USA clarification is needed on what substances
are included within the scope of the proposal for SCCPs. No substance designated by CAS
No. 85535-84-8 is listed on the Toxic Substances Control Act (TSCA) Inventory. Generally,
2
See www.regnet.com/cpia
4
chemical substances manufactured or imported in the USA for commercial purposes must
be listed on the TSCA Inventory. The CAS numbers currently listed on the TSCA Inventory
and used in the USA to cover SCCPs and other chlorinated paraffins are given in Table 3-1.
CAS No.
Substance
Production and import
volume 2002 and 1998*
63449-39-8
paraffin waxes and hydrocarbon waxes, chloro
23,069 metric tons
61788-76-9
alkanes, chloro; chloroparaffins
7,842 metric tons
68920-70-7
alkanes, C6-18, chloro
70.2 metric tons*
Table 3-1:
Production and import volumes reported for chlorinated paraffins for the USA for 2002 and 1998
(UNECE Survey 2007, USA)
* last reported for the 1998 reporting year
Additional information is available at http://www.epa.gov/opptintr/iur/tools/data/2002-vol.htm
Taking these figures as a basis, the total amount of produced and imported chlorinated
paraffins of the above listed CAS numbers was approximately 30,000 tonnes per year.
According to POPPRC 2007 about 20 % of the North American total sales of chlorinated
paraffins is estimated to be C10-133. Assuming a similar share in the present production in
North America would result in an estimated production amount of SCCPs C10-13 of
approximately 6,000 tonnes per year (on the basis of 30,000 tonnes).
In 2002, The Innovation Group projected that 44,000 metric tonnes (97 million pounds) of
chlorinated paraffins would be produced in 2005. This was based on production of 43,500
metric tonnes (96 million pounds) of chlorinated paraffins in 2001 and a projection that the
2002-2005 growth outlook for chlorinated paraffins would be stagnant. Assuming that 20% of
the production of chlorinated paraffins could be attributed to SCCPs, the 2005 projection for
SCCPs would be 8,800 metric tonnes. Actual data was not available to confirm this
projection.
For comparison, the total production of SCCPs, MCCPs and LCCPs in China in 1997 was
about 100,000 tonnes (OSPAR 2001).
Conclusions on production:
Based on available data from the EU, Switzerland, Canada and USA, production of SCCPs
in the UNECE region is estimated to range from 7,500 to 11,300 tonnes per year (see Table
3-2). The volume of SCCP produced in Russia, Taiwan, Japan and Brazil is unknown.
Taking into account estimated uses of 67,727 t/y in metal working in eastern European
UNECE countries (TNO 2006), however indicates that there might be additional production
in the UNECE region.
3
Sales pattern from 1998; Information from POPRC 2007 according to CPIA 2000
5
Region
Production
Year
EU (25)
1,500 to 2,500 tonnes per year
2006
USA
6,000 to 8,800 tonnes per year
2002/1998 and 2005
Canada
0 tonnes per year
2006
Total
7,500 to 11,300
Table 3-2:
3.1.2
Ranges of production amounts in Europe, the USA and Canada
Use
Main uses of SCCPs have been in metal working fluids, as plasticiser in paints, coatings and
sealants, as flame retardant in rubbers, textiles and plastics, and in leather processing (fat
liquoring).
The use of SCCPs in metal working and for fat liquoring of leather has been banned in the
EU by Directive 2002/45/EC since January 2004. In the EU SCCPs may currently be used
as flame retardant in textiles and rubber, in paints and sealants and as adhesives. In
addition a number of EU Member States, Norway and Switzerland accepted PARCOM
decision 95/1 which required complete phase out of all major uses including paints, coatings,
sealants, rubber and textiles (see chapter 4.3.3).
Due to these measures the use of SCCPs in Europe has rapidly ceased. It is assumed that
at present there is no longer any use of SCCPs in metal working fluids and in leather
industry in the EU. The EU consumption in textiles and rubber had decreased by a factor of
three in 2003 compared to the 2001 level. The consumption in paints and
sealants/adhesives decreased by a factor of two over the same time period (European
Commission 2005a). There is no current use of SCCPs in PVC in the EU4 since at least
1994, although it appears that SCCPs have been used in PVC historically (European
Commission 2005b).
4
Caffaro chimica S.r.l. produces MCCPs for use in PVC and has confirmed that SCCPs are not currently sold by
this company for use in PVC (personal communication from Caffaro, 04.05.2007).
6
The overall amount of SCCPs used in the remaining applications in 2003 was less than
1,000 tonnes (European Commission 2005a). Table 3-3 provides the use distribution within
the EU in 1998 and an estimation of the consumption in 2003 and 2004.
Application
Tonnes/year in 1998
tonnes/year in 2003/4
(estimation)
Metal working fluids
2,018 (49,5%)
0
Paints, coatings and sealants
726 (17,8%)
< 370
Rubber/flame retardants/
638 (15,7%)
< 115
Leather fat liquors
45 (1,1%)
0
Other
648 (15,9%)
?
Total
4,075
< 1000
Table 3-3:
Use of SCCPs in Europe in 1998 (OSPAR 2001) and estimation of current uses based on
information contained in the Risk Profile and Summary Report Short-chained Chlorinated
Paraffins (European Commission 2005a)
Updated data for 2005 provided by Euro Chlor are indicated in Table 3-4. The data is taken
from producer sales statistics and information from distributors selling SCCPs on behalf of
producers (UNECE Survey 2007, Euro Chlor).
Use
Range in 2005
In paints and coatings
Share
50 to 75 tonnes
~ 8%
75 to 100 tonnes
~12%
As flame retardant
250 to 350 tonnes
~40%
In paints, waterproofing textile, other, unknown
250 to 350 tonnes
~40%
Total
625 to 875 tonnes
100%
In sealants and adhesives
Table 3-4:
Use of SCCPs in EU 25 in 2005 (UNECE Survey 2007, Euro Chlor)
In Sweden total marketed amounts of chlorinated paraffins (short, medium and long CPs;
production + import - export) were reduced from 1.500 to 300 tonnes per year from 19932001 (OSPAR 2006). This figure has further decreased to below 200 tonnes per year in
20045 (KEMI 2007).
In Lithuania there is no official data that SCCPs have been imported and used (Annex E
response 2007, Lithuania).
It is estimated that the current use of SCCPs in Switzerland has decreased from an amount
of 70 tonnes/year in 1994 by approximately 80%. (Annex E response 2007, Switzerland).
Quantities in imported goods are largely unknown with the exception of rubber products (2
tonnes SCCP/year) and lava lamps (0.3 tonnes/year) (UNECE survey 2007, CH). Since
Import in products + import as raw material – export in products; not taking into account exports as raw material
due to confidentiality reasons
5
7
2005 it is prohibited in Switzerland to place specific product types on the market if they
contain more than 1% of SCCPs by mass (paint and varnishes, sealants, plastics and
rubbers, textiles, leather processing products and metal working products).
The use of short-chain chlorinated paraffins in Norway has been reduced from 16
tonnes/year in 1998 to 4 tonnes/year in 2001 (75% reduction). The current (2001) uses were
reported to be in metal working fluids/lubricants and paints and rust inhibitors (European
Commission 2005b). Since 2002 the use of SCCPs is prohibited in Norway (exemptions
were possible until 2005).
The results of the UNECE questionnaire (UNECE 2003) indicate historical uses of SCCPs in
Belgium, Canada, Czech Republic, Denmark, Finland, Georgia, Germany, Netherlands,
Norway, Spain, Sweden, Switzerland, UK and USA. Except for Norway and Spain, SCCPs
were also reported to be in use in the same countries at that time. In addition, Georgia
reported minor uses for laboratory purposes or other non-commercial small scale uses,
Belgium reported use in softener for PVC and Finland in dye additives. According to UNECE
2003 annual quantities used ranged from 10 tonnes per year to the USA’s 25,500 metric
tones/year which assumed that all domestically manufactured and imported quantities were
used in the USA. In Canada, 1995 surveys indicated that SCCPs were used primarily as
lubricants in the metal working industry, with other uses including rubber, sealants and flame
retardants for rubber and soft plastics (UNECE 2003).
The responses to the UNECE survey in 2007 indicate current use in the following countries:
In the EU uses have been reported for the following Member States:

Belgium (manufacturing of rubber and plastic products and of metal products;
amounts unknown)

Czech Republic (sectors and amounts unknown; environmental levels in sediments
and soils confirm that SCCPs are still used, but there is no actual inventory)

Cyprus (SCCPs are not imported in Cyprus; no data on SCCPs in imported products)

France (estimated amounts used in 2002 are 147 tonnes in metalworking fluids, 57
tonnes in paints and coatings and 17 tonnes as flame retardant; it is unknown
whether since 2002 the use has decreased du to the new regulations and in
accordance with a general decreasing trend in SCCP use)

The United Kingdom (currently main use as flame retardant; use in metalworking
stopped in 2003; use in leather processing stopped in 2000; (reference was made to
the National Atmospheric Emmissions Inventory: NAEI, 2006, UK Emmisions of Air
Pollutants 1970 - 20046)
In Canada nearly all reported usage of SCCPs is for metalworking applications. Minor uses
included use as a flame retardant in plastics and rubber. Information on amounts used in
Canada has not been provided. (UNECE survey 2007, Canada).
6
See www.naei.org.uk
8
In the USA SCCPs have been reported to be currently used as additives in extreme
pressure lubricants, as flame retardants in plastics and textiles; as plasticizers for polyvinyl
chloride (PVC) and other plastics, paints and rubber. Information on amounts used in the
USA has not been provided. (UNECE Survey 2007, USA). It is referred to the Chlorinated
Paraffins Industry Association (CPIA) website7. According to this website, the use shares of
Chlorinated paraffins in general can be estimated for lubricating additives (~50%), plastics
(~20%), rubber (~12%) and paints (~9%), adhesives (~6%), miscellaneous (~3%)8.
In Australia the annual use of SCCPs in metal working fluids has decreased from about 125
tonnes in 1998 to about 25 tonnes in 2002 (NICNAS 2004).
Current uses for eastern European UNECE countries have been estimated in TNO 2006.
According to these estimates 67,727 t of SCCPs are used annually. Estimated comsumption
occurs particularly in Russia and the Ukraine and is focused on metal working. However,
there is no confirmation of these data from national authorities in these countries.
Conclusions on current uses:
Current uses of SCCPs within the UNECE region cover metal working fluids, plasticisers in
paints, coatings and sealants, flame retardant in rubbers and textiles. Use in metalworking
and leather processing has been recently phased out in the European Union, Norway and
Switzerland. In addition in Norway and Switzerland and 11 EU Member States all other
major uses were phased out following OSPAR decision requirements. Amounts used in the
EU in 2005 range from 625 to 875 tonnes per year. Amounts used in other UNECE regions
are not known. Production estimates for North America range from 6,000 to 8,800
tonnes/year. Use estimates for eastern European UNECE countries have been reported as
67,727 t/y.
Disposal and Elimination
Euro Chlor provides information/recommendations on CP (including SCCP) waste
management by waste types and sources (Euro Chlor 2005). According to this, generally
three management options are possible:
7
8

Recovery (reuse/recycling or energy recovery by incineration)

Destructive incineration

Landfill
See http://www.regnet.com/cpia/benefits.htm
Ratios estimated on the basis of the graphic on uses of CPs on the CPIA website, update September 2003
9
Table 3-5 shows the management options recommended by Euro Chlor.
Type of waste
Preparation for
recovery
Management recommendation
Solids
Liquids adsorbed onto
solids
hazardous landfill or incineration
Metal swarf with CPs
Incineration/re-smelting or degreasing/separation from
solvent or incineration
Oil based liquids
Used oil from metal
working operations
Recovery (restrictions in Germany) or Incineration
Mixed
plasticiser
condensates
Recovery/deodorisation/re-use when feasible or
Incineration
Unusable liquid CPs
Incineration
Water based liquids
Emulsions
and
mixtures (should first
be split into oil and
water phases; three
techniques can be
utilised in the splitting
process producing split
waste
of
differing
quality)
1. Chemical
splitting
This gives split water with high salt contents and
imperfect oil separation so that further treatment is
required.
The oil phase also is contaminated with chemicals,
water, etc. and is consequently treated as "hazardous
waste". Mineral oils can also be carcinogenic Oil phase
should be disposed of by incineration
2. Aqueous
evaporation
The water is evaporated and when condensed often
requires no additional treatment (unless contaminated
by volatile substances).
The oil phase can be disposed of by normal
incineration/energy generation (according to calorific
value).
3. Ultrafiltration
The separated water may need some additional
treatment e.g., to reduce Chemical Oxygen Demand
(COD).
The oil phase can be disposed of by normal
incineration/energy generation (according to calorific
value).
Sludges
Three phase mixtures
(oil, water and solids)
Table 3-5:
Best disposed of as hazardous waste by a specialist
contractor. Alternatively a combination of the above
separation processes may be employed by large
companies with their own facilities.
Waste management options for chlorinated paraffins (Euro Chlor 2005)
Limited information is available on Australian industry practices, particularly those for small
and medium enterprises, relating to disposal of waste fluids. Of the 28 companies that used
metal cutting fluids, 11 companies (40%) indicated that no or little waste was generated by
using metal cutting fluids, due to recycled use. Seven companies (25%) indicated that the
waste generated was collected by licensed waste disposal contractors. Guidance on
disposal practices in general appears scarce (NICNAS 2004).
10
3.2
Global demand in the future
Specific data on global demand in future are not available. In principal future global demand
could relate to all current and potential future uses. In the European Union, Norway,
Switzerland and the USA significant decrease in use and demand has been reported. For
eastern European UNECE countries corresponding information is missing. Future demand
for SCCP containing metal working fluids could be regarded as a decisive factor due to the
important share of this sector in current use. As concerns availability and feasibility of
substitutes problems with replacement of SCCP do not seem to occur in general. Only for
the use as flame retardant in e.g. conveyor belts substitution seems to be problematic (see
chapter 4.1).
The European Scientific Committee CSTEE has noted that future restriction on the use of
brominated flame retardants may increase the use of chlorinated paraffins for this purpose
(CSTEE 2002). However a corresponding development can not be observed from recent
European consumption figures.
3.3
Emissions from production
The Environmental Health Criteria report (WHO 1996) contains a general description of
environmental losses of chlorinated paraffins. These substances are not known to occur
naturally in the environment. Since chlorinated paraffins are produced without contact with
water, the possibility of leakage into the environment by direct water discharge is low. After
chlorination the solvent is removed and residual amounts of chlorine gas and hydrogen
chloride are removed by blowing air or other gases through the product. This could possibly
lead to some loss into the air, but since the chlorine gas and hydrochloric acid are recovered
and the volatility of chlorinated paraffins is very low, the loss is likely to be very low.
The EU risk assessment report (European Commission 2000) contains a number of release
estimates on the basis of SCCP uses in Europe by using various models and assumptions.
Table 3-6 shows a summary of the release estimates for the assessed period.
Table 3-6:
Summary of release estimates for the EU (European Commission 2000).
11
According to this assessment 45 tonnes of SCCPs were annually release to water from
production in the EU. 1,739 tonnes were annually released from different uses namely metal
working (>90%). The estimated annual release to air of 393.9 kg was almost completely
related to leather formulation and use.
The EU updated risk assessment (European Commission 2005b) provides data on
emissions from production and uses in the EU after the implementation of the Directive
2002/45/EC of the European Parliament and of the Council. The assessment considers
emissions from the production of SCCPs and formulation and from use in rubber (and
polymers), paints, sealants and adhesives and textiles including to an important part
releases during service life and on disposal. Releases from metal working and fat liquoring
do not occur any more and are therefore considered zero. The total worst case EU
emissions of SCCPs based on 2001 consumption data are estimated to be around

3 to 11 tonnes/year to air

37 to 97.3 tonnes/year to waste water treatment plants

20.1 to 45.9 tonnes/year direct to surface water

32.8 to 64.9 tonnes/year to urban/industrial soil
The contribution of different emission sources and stages of service life is specified in Table
3-10. The use of short-chain chlorinated paraffins in the EU in 2003 was around three times
lower than in 2001 (European Commission, 2005a). This reduction and possible further
reduction in use will lead to a reduction in the regional and continental emissions. Thus, the
current release estimates are subject to a considerable uncertainty and may be over
estimated.
POPRC 2007 provides an estimation of fractional losses of SCCPs to wastewater and
surface waters based on EU data as summarized in Table 3-7. Behaviour similar to that of
MCCPs (U.K. Environment Agency 2003b) is assumed. Overall most releases of SCCPs are
expected to be associated with metal working operations, however there is potential for
widespread release in small amounts associated with uses in products such as paints,
textiles or rubber (see chapter 3.5).
Application
Metalworking lubricants
Paints and sealants
Rubber/flame retardants/
textiles/polymers (other than
PVC)
1
2
3
Wastewater
18%
0.1%
1
0.1%
Release to each compartment
Surface water2
Terrestrial3
1.4%
17.8%
0.015%
Unknown —
Landfilling of used material
0.05–0.4%
Unknown —
Landfilling of used material
Wastewater during use (metalworking fluids) or product formulation (paints/polymers).
For metalworking fluids, surface water = 0.08 × wastewater. For PVC and paints/adhesives/sealants,
direct losses to surface water are included.
Terrestrial = soil + landfilling/burial, assuming landfilling or sludge spreading, except for PVC and
paints/adhesives/sealants, where direct losses to urban/industrial soils need to be considered.
Table 3-7:
Estimated fractional losses of SCCPs in the EU to wastewaters, surface waters and the terrestrial
environment
12
The tables below show the aggregated releases for the EU of SCCPs reported for EPER
activities for the reporting years 2001 (Table 3-8) and 2004 (Table 3-9) grouped by activities
for which releases are reported. It has to be noted that only releases from specific activities
and facilities are obliged to be reported under EPER9.
Activity
To air (per
year)
Direct to
water (per
year)
Indirect to water
(transfer to an off-site
waste water treatment)
Combustion installations > 50 MW
-
-
0.0022 t
Basic organic chemicals
-
-
0.01584 t
Basic inorganic chemicals or
fertilisers
-
0.01 t
-
Total
-
0.01 t
0.01804 t
Table 3-8: Aggregated releases for the EU of SCCPs reported under EPER for the reporting year 2001
Activity
To air (per
year)
Direct to water
(per year)
Indirect to water
(transfer to an offsite waste water
treatment)
Combustion installations > 50 MW
-
-
0.0014 t
Basic organic chemicals
-
-
0.013 t
Installations for the disposal or
recovery of hazardous waste (>10t/d)
or municipal waste (>3t/h)
-
0.0078 t
-
Installations for surface treatment or
products using organic solvents
(>200t/y)
-
-
0.00207 t
Total
-
0.0078 t
0.01647 t
Table 3-9: Aggregated releases for the EU of SCCPs reported under EPER for the reporting year 2004
9
More information available at http://www.eper.ec.europa.eu/eper/
13
Table 3-10
Summary of environmental release estimates for short-chain chlorinated paraffins (European Commission 2005b)
Use
Comment
Estimated local release
Estimated regional release
(kg/year)
Estimated continental releasea
(kg/year)
Production sites
Site specific information
<0.089 kg/day to waste water over 300 days
Confidential
Confidential
Use in rubberb
Compounding site
(formulation)
7.5 kg/year (0.038-0.063 kg/day) to waste water;
2.5 kg/year (0.0125-0.021 kg/day ) to air, over 118-200 days
Confidential
Confidential
Conversion site (processing)
2.5-12.5 kg/year (0.0125-0.106 kg/day) to waste water;
2.5-12.5 kg/year (0.0125-0.106 kg/day) to air, over 118-200 days
Combined compounding and
conversion site
10-20 kg/year (0.050-0.169 kg/day) to waste water;
5-15 kg/year (0.025-0.127 kg/day) to air, over 118-200 days
Formulation (compounding)
165 kg/year (0.55 kg/day) to waste water, over 300 days
Confidential
Confidential
Processing (backcoating)
49.5-88.0 kg/year (0.75-1 kg/day) to waste water, over 66-88
days
Confidential
Confidential
Sealants/
adhesives
Formulation/use
Negligible
Confidential
Confidential
Paints and
coatings
Formulation
Negligible
Confidential
Confidential
Industrial application of
paints (Processing)
6.48-13.0 kg/year (0.022-0.075) kg/day to waste water, over 300
days
Confidential
Confidential
Application by general public
(private use)
Negligible
Use in textiles
Table 3-10 continued overleaf.
14
Table 3-10 continued
Use
Comment
Volatile and
leaching loss from
products
containing shortchain chlorinated
paraffins over lifetime
Estimated local release
Estimated regional release
(kg/year)
Estimated continental releasea
(kg/year)
Volatile loss over life-time
286-1,057 kg/year to air
2,576-9,516 kg/year to air
Leaching loss over life-time
4,363-11,878 kg/year to waste water
39,269-106,903 kg/year to waste
water
3,276-6,492 kg/year to
urban/industrial soil
29,484-58,429 kg/year to
urban/industrial soil
1,088-2,155 kg/year to surface water
9,788-19,398 kg/year to surface
water
“Waste remaining
in environment”
over life-time and
disposal
4.4-8.7 kg/year to air
39.2-77.9 kg/year to air
Total
299-1,092 kg/year to air
2,695-9,832 kg/year to air
3,732-9,789 kg/year to wwtpc
33,213-87,486 kg/year to wwtpc
2,021-4,602 kg/year to surface waterc
18,091-41,270 kg/year to surface
waterc
3,276-6,492 kg/year to
urban/industrial soil
Notes:
a)
b)
c)
29,484-58,429 kg/year to
urban/industrial soil
Continental release = total EU release-regional release .
Estimates based on a worst case approach assuming release from rubber processing is similar to that from plastic processing. Other information is available which indicates that the total
release from the processes may be much lower at <0.0042 kg/day over 118 days, probably to waste water. This figure will also be considered in the risk assessment.
Releases to waste water assume a 80% connection rate to wwtp, with 20% going directly to surface water, as recommended in the Technical Guidance Document.
15
Environmental concentration data show that CPs are being released as a result of human
activity into air and water in Canada. The release of CPs into the environment may occur
during production, storage, transportation, industrial and consumer usage of CP-containing
products, disposal and burning of waste, and landfilling of products such as PVC, textiles,
painted materials, paint cans and cutting oils. The two major sources of release of CPs into
the Canadian environment are likely use in metalworking applications and manufacturing of
products containing CPs. The possible sources of releases to water from manufacturing
include spills, facility wash-down and stormwater runoff. CPs in metalworking/metal cutting
fluids may also be released into aquatic environments from drum disposal, carry-off and spent
bath use. These releases are collected in sewer systems and ultimately end up in the
effluents of sewage treatment plants (Environment Canada 2004).
Data since 1999 reported to Canada’s National Pollutant Release Inventory (NPRI) found that
very small amounts of CPs (short, medium and long chain) are being released to the
Canadian environment by companies that meet the NPRI reporting requirements
(Environment Canada, 2004). In 2001-2002, the NPRI found 1.45 tonnes CPs for disposal to
landfill and 1.94 tonnes recycling by recovery of organics from two companies in Ontario.
Both of these companies use SCCPs as a formulation component in the manufacture of wires
and cables and of paints and coatings, respectively. In 2005, NPRI found that one company
in Ontario disposed 0.023 tonnes of Alkanes 10-13, chloro (CAS 85535-84-8) off-site and
2.967 tonnes were recycled off-site (POPRC 2007).
SCCPs are subject to the USA Toxic Release Inventory reporting as part of a broader
category of polychlorinated alkanes, C10-13. For 2004, a total of 28,1 tonnes was reported for
on-and off-site disposal. For other releases 1,91 tonnes was reported, of which were releases
to air and water (TRI, 2004, data for all USA industries for the polychlorinated alkanes
category, data release April 12, 200610).
3.4
Emissions from handling and transport
Some loss into the environment could be expected during transport and storage. If the drums
which are used for the transport of chlorinated paraffins are cleaned for further use
environmental release might occur. Soil could be contaminated if empty drums are dumped at
landfills. Spills may occur, but clean-up using an adsorbent material is easy. The adsorbent
material would probably be deposited in a landfill, which in turn could lead to possible
environmental contamination.
3.5
Emissions from the use of products containing SCCP
WHO (1996) concludes that the uses of chlorinated paraffins probably provide the major
source of environmental contamination. When chlorinated paraffins are used as plasticizers
or additives in coatings, they are effectively dissolved in the polymers and will therefore leak
10
additional data is available at www.epa.gov/triexplorer
16
into the environment only very slowly. However, polymers containing chlorinated paraffins will
act as sources of chlorinated paraffins for centuries after disposal. A more likely route of
leakage of chlorinated paraffins into the environment would be the improper disposal of oils
containing chlorinated paraffins. Loss of chlorinated paraffins by removal from paints and
coatings may also contribute to environmental contamination.
According to the EU risk assessment (European Commission 2000) 1,739 tonnes of SCCPs
were annually released to water and 393.9 kg were released to air in the European Union in
the nineties being mainly related to the use of SCCPs in metal working and leather
formulation (see Table 3-6). At present, the use of SCCPs in metal working and leather
formulation is no longer of concern at EU level (European Commission 2005b).
There are no figures on amounts of imported SCCPs and hence, no estimates of releases
from such uses. These could, however, contribute considerably to emissions to the
environment. An example is given by CSTEE (1998) on estimated emissions of 9 tonnes on a
yearly European scale from surfaces with paint containing SCCPs. Other sources, which
could contribute to emissions mentioned, are articles, containing SCCPs like rubber, textiles,
sealants and polymers. This can be the case during production and use, and when the
articles become waste and are sent to landfill.
In the EU risk assessment report, emissions from articles are discussed very briefly.
Elaborated methods to estimate this are lacking in the EC Technical Guidance Document
(TGD) on Risk Assessment of New and Existing Substances (1996). However, reported data
on emissions from surfaces with a paint containing SCCPs could indicate that such emissions
can be significant (CSTEE 1998).
In the updated EU risk assessment report (European Commission 2005b) a release estimate
from articles over their service life has been performed and is discussed as follows:
Although short-chain chlorinated paraffins are of low vapour pressure at ambient
temperatures, the vapour pressure is not so low as to preclude the possibility of volatilisation
from plastics, paints, rubber, textiles and sealants during their service life. Losses have also
been estimated for leaching and for “waste” from the products themselves during their useful
lifetime and disposal (e.g. erosion/particulate losses).
Releases from the use over lifetime and at disposal of products containing SCCPs are
considered to be a major source of environmental contamination. Relevant are volatile,
leaching and particulate losses. Particulate losses over lifetime, at disposal and at
recovery/reclamation are designated as “waste remaining in the environment”.
As indicated in Table 3-10 it has been estimated that over the product lifetime around 39 to
107 tonnes per year were leaching to waste water and approximately 3 to 10 tonnes would
volatilised into air in the EU. The losses as “waste remaining in the environment” over lifetime
and disposal was estimated at around 29 to 58 tonnes per year to urban/industrial soil, 10 to
19 tonnes per year to surface water and 0.039 to 0.08 tonnes per year to air (European
17
Commission 2005b).
The method used to estimate these emissions follows the approach taken in the draft ESR 11
risk assessments of various phthalate plasticisers. The accuracy of the estimates is uncertain.
The estimates depend to some extent on the vapour pressure of the substance in question. A
vapour pressure at room temperature of around 0.021 Pa has been assumed in the
calculations for short-chain chlorinated paraffins in general where several different types of
short-chain chlorinated paraffins could be used. However, for rubber and textiles a single type
of short-chain chlorinated paraffin dominates each use, and a vapour pressure appropriate to
the main type of chlorinated paraffin used has been assumed (i.e. 5.4x10-3 Pa for the 55-61%
wt. Cl types used in textiles and 1.3x10-5 Pa for the 70-71% wt. Cl types used in rubber).
The details of the updated EU release estimates are considered confidential.
Releases into water from historic use in metal processing via sewers show a decreasing
trend. The releases in the UK decreased from 13 (in 1997) to 8 (in 1998) to 6 (in 1999) to 3
(in 2000) to 1 (in 2001 and 2002) tonnes/year (UNECE survey 2007, UK).
3.6
Emissions from waste containing SCCPs
Estimates for releases from waste containing SCCP are contained in the updated EU risk
assessment report (European Commission 2005b) as “waste remaining in environment” over
life-time and disposal (see chapter 3.5). A further differentiation however, is not provided.
Based on the estimated figures it might be possible that releases at disposal represent a
significant share of releases at least in case that use of SCCP in metal working has ceased.
Mechanical processes in disposal operations may cause dust relases. Such losses are
allocated to particulate losses during the service life of products (“waste remaining in the
environment”).
Disposal of wastes containing chlorinated paraffins comprises treatment options such as
material and energy recovery, incineration or landfill, usually at landfills for hazardous waste
and in compliance with local regulations. Owing to their thermal instability, chlorinated
paraffins are degraded by incineration at relatively low temperatures and thus are not
expected to occur in exhaust gases from an incinerator. Chlorinated paraffins are not
expected to be formed de novo. The disposal of chlorinated paraffins in landfills may give rise
to leaching into water, but owing to the low water solubility and strong adsorption onto solids
the amounts reaching water are likely to be low.
Similar to chlorinated compounds in general, chlorinated paraffins can act as a source of
chlorine radicals during disposal using incineration processes. This chlorine can then lead to
the formation of polychlorinated dioxins and furans, and is a well known problem with
incineration.
18
In most cases, controls are already in place on incinerators to minimise the formation of these
dioxins and furans, and so the presence of chlorinated paraffins should not lead to increased
emissions. However, other processes involving chlorinated paraffins may not be so well
controlled (e.g. accidental fires).
In addition, CSTEE (2002b) indicates that other unsaturated hydrocarbon products, including
aromatic products such as polychlorinated biphenyls and polychlorinated naphthalenes can
also be formed from chlorinated paraffins under certain circumstances, such as under heat or
in contact with alkaline substances. The basis for these comments is unknown.
There is insufficient information available on these issues to make an assessment of the
significance of these processes in terms of a risk for the environment. These issues are
therefore not considered further in the draft updated EU risk assessment.
Historical use of SCCP was also as PCB-substitute, in gaskets, e.g. of splices, in buildings.
This will be a further source of SCCPs-containing waste when those buildings are renovated
or teared down. (Annex E Response UNECE 2007, Germany).
The Czech Republic reports on transfer of SCCPs into wastes (0.035 tonnes/year originating
from two power plants). An official inventory does not exist. (UNECE survey 2007, CZ)
Landfilling is a major disposal route for polymeric products in Canada (POPRC 2007). CPs
would be expected to remain stabilized in these products, with minor losses to washoff from
percolating water. Leaching from landfill sites is likely to be negligible owing to strong binding
of CPs to soils. Minor emissions of these products, which are effectively dissolved in
polymers, could occur for centuries after disposal (IPCS 1996). The releases and
bioavailability of CPs from polymers that are landfilled or from losses of polymeric material as
particles during wear and abrasion of flooring, rubber products, etc., are unknown. These
releases could be significant sources of input of CPs to air and soils in urban and industrial
areas (U.K. Environment Agency 2001, 2003a,b).
Euro Chlor 2005 provides information of impacts of chlorinated paraffins in recovery and
disposal processes:
Oil recovery:
Oil recovery and secondary refining are encouraged in the EU (Directives such as
75/442/EEC and 87/101/EEC) and in the USA via the Resource Conservation Recovery Act
(US-EPA RCRA 1987). According to Euro Chlor oils containing chlorinated paraffins do not
present problems in these processes and undesirable by-products are not present in or
formed from chlorinated paraffins either in metal working operations or recovery.
Incineration
11
ESR = Existing Substances Regulation (Council Regulation (EEC) no 793/93)
19
According to Euro Chlor studies of combustion of chlorinated paraffins mixed with either
waste solids or as liquids have shown that in full-scale industrial installations it is entirely
possible to operate without forming or emitting any dioxins. Excessively high operating
temperatures are not required. In vapour phase studies dioxins were not detected above
700°C.
A major product of combustion is hydrogen chloride and incineration facilities are designed so
that condensation does not occur on metallic surfaces that may otherwise corrode. Large
modern incineration facilities are often fitted with acid scrubbing facilities which remove HCl.
Where scrubbing is not available the incinerator gaseous effluent may be limited to its
allowable halogen and other gas contents.
CPs containing waste oils are used in energy generation (cement kilns, direct power etc). In
this case, for calorific value purposes and minimisation of HCl formation Euro Chlor suggests
that the chlorine content of the waste oil be limited to 1%.
Landfill
According to Euro Chlor chlorinated paraffins are not normally disposed of to landfills as
liquids, nor are liquids containing chlorinated paraffins put in landfills. Solid wastes containing
chlorinated paraffins C10-13 should be treated as hazardous waste in a landfill context in
view of their toxicity to aquatic organisms.
3.7
Emissions from recycling and dismantling
Polymer-incorporated CPs could also be released during recycling of plastics, which may
involve processes such as chopping, grinding and washing. If released as dust from these
operations, the CPs would be adsorbed to particles because of high sorption and octanol–air
partition coefficients (POPRC 2007). Such losses are allocated to the category of “particulate
losses during the service life” of products (“waste remaining in the environment”).
3.8
Conclusion on current sources of emissions:
Releases of SCCPs in the UNECE region arise from production, use, handling and transport,
use of products containing SCCPs and disposal of waste containing SCCPs. It can be
assumed that the most relevant sources for releases are the different use sectors (in
particular metalworking), production and the life-time releases from products containing
SCCPs including disposal.
As in Canada SCCPs are not produced, releases from production are considered zero. In
Europe and in particular in the USA production as a relevant source of releases is still
ongoing.
According to production and use patterns, some releases are expected due to handling and
transport activities. These releases are considered irrelevant.
20
Release from the use of SCCPs are most relevant for formulation and in particular for the use
of metalworking fluids (the most relevant source of emissions), formulation and use of leather
processing agents, the use as flame retardant in rubber, textiles and plastics and as
plasticiser in sealant, adhesives paints and coatings. According to different use patterns the
release patterns vary in the different UNECE regions.
No releases are expected from use of SCCPS for metalworking and leather processing in the
European Union, Norway and Switzerland.
No releases from all other major uses of SCCPs are expected in those countries who have
accepted PARCOM decision 95/112.
Significant releases are expected from all major uses in eastern European UNECE countries
(TNO 2006), Canada and the USA where major use of SCCPs is in metalworking fluids. This
appears to be the most relevant emission source in these regions. Minor uses are as flame
retardant in plastic, rubber and textiles and as plasticizer in PVC, other plastics, paints and
rubber whereas leather processing has not been indicated as use in Canada and the USA.
As generally decreasing use trends are expected releases may decline correspondingly.
Releases from the use over lifetime and at disposal of products containing SCCPs are
considered to be another major source of environmental contamination. Relevant are volatile,
leaching and particulate (“waste remaining in the environment”) losses. Such releases occur
in relevant quantities in the whole UNECE region.
Releases from disposal or recovery may occur if dust is relased during these operations.
Such losses can be allocated to particulate losses during the service life of products (waste
remaining in the environment). Releases from incineration and landfill operations are
expected to be negligible.
Data from the European Union suggest releases from use of metal working fluids in a
dimension of 1,700 t/y prior to the legal ban of use for this sector, as well as losses of 115 t/y
during services life and about 70 t/y as waste remaining in the environment over service life
and during disposal according to the up-dated risk assessment report (European Commission
2005b). Other releases appear to be less important.
12
BE, DE, DK, FI, FR, IE, NL, PO, ES, SE, EU, NO, CH, LUX, ICE
21
4 Management options
4.1
Substitution
Among the countries that responded to the UNECE survey 2007 Belgium, Czech Republic,
Cyprus, Germany, the Netherlands, Canada and the USA indicated to have no information on
possible substitutes of SCCPs (France and Italy did not respond to the relevant questions).
According to Switzerland, the analyses of joint sealants have shown that SCCP are being
replaced by MCCP. According to the UK, SCCPs can be substituted in leather processing13
and in paints and coatings14 by MCCPs (or a range of animal, vegetable and mineral oils).
Euro Chlor understands from discussions with end-users that it would be difficult to substitute
SCCPs, particularly in those applications where they are used as a flame retardant additive.
In some cases transition to MCCPs from SCCPs has already been possible, however in some
applications (e.g. as a flame retardant additive for rubber formulations) SCCPs enable the
optimisation of high levels of chlorine content for maximum fire retardancy combined with
workability of the formulation (as viscosity of the CPs is a function of chain length and chlorine
content) (UNECE survey 2007, Euro Chlor).
A summary of alternatives for SCCPs is provided in a recent HELCOM draft guidance
document on SCCPs (HELCOM 2002).
According to this report the medium-chain chlorinated paraffins (MCCPs) (C14-C17) may
have similar uses as SCCPs and they are used as replacements for SCCP as extreme
pressure additives in metal working fluids, as plasticisers in paint, and as additives in
sealants. Based on a UK draft risk assessment on MCCPs from 1998 the report states that
some risk reduction measures may be required for uses in the production of PVC, in some
process formulations of metal cutting fluids, in emulsifiable metal cutting/working fluids where
the spent fluid is discharged to waste water, in leather fat liquors and in carbonless copy
paper during recycling. The risk from use in oilbased metal cutting fluids may also be of
concern.
The long chain chlorinated paraffins (LCCPs) have, at least in Sweden, been used in some
demanding applications in metal working fluids instead of SCCP. LCCP is also suggested as
replacements to SCCP in the leather industry as well as in paint and coatings, in sealants and
rubber (HELCOM 2002).
Alkyl phosphate esters and sulfonated fatty acid esters may function as replacements for
SCCPs as extreme pressure additives in metal working fluids. Natural animal and vegetable
oils are alternatives to in the leather industry.
13
Reference according to UNECE survey 2007, UK: RPA for Defra [Socio-economic]); Costs and benefits and
conclusions: Approx. 15% more expensive & reduced environmental risks. (Cost <£4m since Directive
2002/45/EC)
14 Reference according to UNECE survey 2007, UK: AEA Technology; Costs and benefits and conclusions:
Unlikely to be a major issue phasing out SCCPs.
22
In paint and coatings, phthalate esters, polyacrylic esters, diisobutyrate as well as phosphate
and boron containing compounds are suggested as replacements. Phthalates esters are
alternatives for use in sealants. Alternatives as flame retardant in rubber, textiles and PVC
are antimony trioxide, aluminium hydroxide, acrylic polymers and phosphate containing
compounds.
These halogen free substances are considered by Sweden as less harmful than chlorinated
paraffins. Still, there might be uses for which these alternatives do not fulfil all technical and
security demands. Neither may cost for substitution be proportional to health and
environmental advantages for all types of applications (HELCOM 2002).
An overview on possible alternatives or substitutes to SCCPs taken from HELCOM and
OSPAR reports has been provided in TNO 2006 and is compiled in Table 4-1.
Use
Possible Alternative to SCCP
Extreme pressure additive in metal working MCCPs, LCCPs, alkyl phosphate ethers,
fluids
sulfonated fatty acid esters
Plastizers in paints
MCCPs
Additives in sealants
MCCPs, LCCPs, phthalate esters
Leather industry
LCCPs, natural animal and vegetable oils
Paints, coatings
LCCPs, phthalate esters, diisobutyrate and
phosphate and boron containing compounds
Flame retardant in rubber, textiles and PVC
Antimony trioxide, aluminium trioxide, acrylic
polymers
and
phosphate
containing
compounds
Rubber
LCCPs
Table 4-1:
Possible alternatives or substitutes to SCCPs taken from HELCOM and OSPAR (source TNO
2006)
A German study (UBA 2003a) contains information on substitutes in metal working fluids and
considerations on related possible adverse effects.
Five typical high pressure additives in metal working fluids are compared with SCCPs:
MCCPs, polysulfides, calcium-sulfonate, phosphor-acid ester and polymere ester.
The comparison takes health (mutagenicity, genotoxic carcinogenicity, reproductive toxicity,
carcinogenicity, and allergic effects) and environmental (persistency, bioaccumulation and
aquatic toxicity) aspects into consideration.
23
According to the study MCCPs are no appropriate substitute due to their persistent,
bioaccumulative and toxic properties (PBT-properties) and related environmental concerns.
Polysulfide seems to be the most appropriate alternative within the compared substances.
However, there is not sufficient information available to exclude certain health risks (with
respect to reproductive toxicity and carcinogenicity). With respect to the remaining three
substances considerable uncertainties for both, healt and environmental risks are stated.
There is no information on the efficacity of these substances given. However, the document
states, that substitution of chlorinated paraffins in metal working fluids has already made good
progress.
With respect to the use as flame retardant in rubbers or flame retardant in textiles alternatives
are usually available but the description and evaluation of substitutes can only be carried out
by assessing specific examples because the technical requirements depend from the specific
material and its intended use (UBA 2003b). The study focuses on substitution of brominated
diphenyl ethers, but the following results are also useful for substitutions of other flame
retardants such as SCCPs.
SCCPs are flame retardants of the additive type, i.e. they are physically combined with the
material being treated rather than chemically combined (as in reactive flame retardants such
as TBBA or specific esters of phosphoric acid). This means that there is the possibility that
the flame retardant may migrate and diffuse out of the treated material to some extent.
Usually additive type flame retardants are used in thermoplastic material (e.g. Polypropylen,
Polyethylen, Ethylen-Vinylacetate, PVC). They can be applied ex post to the raw polymer.
Reactive type flame retardants are usually used in thermosetting material (e.g. polyester
resins, epoxy resins, polyurethanes) (UBA 2003b).
Generally it is considered that a substitution of SCCPs by additive type flame retardants that
exhibit PBT-properties such as PBDEs, MCCPs or additive TBBA compared to reactive type
flame retardants is related to a higher risk of release to the environment during use and
disposal of products – irrelevant whether they contain halogens, nitrogen or phosphorus.
Halogenated flame retardants are in addition related to the risk to generate non-desirable
reaction products in the case of fires (UBA 2003b).
The use of halogenated flame retardants in Europe is significantly decreasing (with the
exception of chlorinated phosphoric esters). Mineral type flame retardants such as aluminumtri-hydroxide or magnesium-hydroxide or nitrogen containing flame retardants (e.g. melamine
derivates) show significant increases. An important driving force for these market adjustments
is the consideration of environmental risks (UBA 2003b).
Halogen free flame retardants are suitable substitutes in many relevant cases. In electric and
electronic equipment an efficient flame retardancy of used plastics is important.
Approximately 25 % of all plastic components in this sector are flame retarded. The main
share thereof is thermoplastic housings, followed by thermosetting printed circuit boards and
electronic small parts. For thermoplastic housings suitable and efficient substitutes are
available. In injection molding for thermoplastic housings the fluidness is a critical parameter.
24
Therefore mineral type flame retardants are not appropriate substitutes. Suitable alternatives
that have to be evaluated in each single case are (according to UBA 2003b) for example:

halogen free systems on phosphorus-organic basis (organic triaryl- und bi-phosphates
such as phenyl-cresyl-phosphate mixtures, tri-phenyl-phosphate, resorcinol-bisdiphenyl-phosphate or bis-phenol-A-di-phenyl-phosphate for PC/ABS und highimpact HIPS housings.

brominated systems with low dioxin/furane formation potential, in particular with
respect to recycling/recovery processes (e.g. 1,2-bis-penta-bromophenyl-ethane or
ethylen-bis-tetra-bromo-phthalate).
It has to be noted that the halogen free systems on organo-phosphorus basis can not
generally be considered the environmentally preferable substitute. However, it can be stated
that ecologic advantages outweigh the disadvantages at least in comparison with decaBDE or
additive TBBP-A if

toxicologically sufficiently tested substances with proven degradability and low
volatility are used as additive type flame retardant in these systems or

toxicologically sufficiently tested organophosphates are used as reactive type flame
retardant.
In the UBA guidance document the technical practicability of substitution is demonstrated by
means of several examples (UBA 2003b).
Conclusions on substitution:
The phase out of SCCPs in metalworking and leather processing in the European Union,
Norway and Switzerland, demonstrate the availability of appropriate alternatives for SCCPs.
Alternatives are also available for all other uses as plasticizer and flame retardants in paints
and coatings, sealants, textiles, plastic and rubber as demonstrated by the phase out of other
uses in countries which accepted the PARCOM decision 95/1.
However, according to end-users, in some cases, particular for uses as flame retardants, the
alternatives may not completely fulfil technical requirements.
Available substitutes are generally considered less harmful than SCCPs. However, this does
not implicate that they are completely safe and are not related to risks. Environmental and
health risks need to be considered according to specific uses and substitutes.
Based on current knowledge and available information reactive type flame retardants and
halogen free substitutes appear to be generally preferable under environmental and health
aspects. It has been suggested that MCCPs and LCCPs should not be considered as
possible alternatives to SCCPs, since MCCPs and LCCPs may also show PBT properties.
25
However, currently, there is no conclusive evidence that MCCPs and LCCPs are POPs, as
defined by the UNECE POPs Protocol.
MCCPs meet some of the criteria listed in the Convention (i.e. Toxicity, vapour pressure, lack
of biodegradation, Kow>5), but the BCF was only 1,087 and no evidence was given in the
U.K. draft risk assessment report of MCCPs (U.K. Environment 2002 quoted from UNECE
2003) that MCCPs undergo long-range atmospheric transport. The atmospheric half-life was
estimated to be 2 days using EUSES (U.K 2002 quoted from UNECE 2003).
4.2
Measures to reduce emissions
Among the countries and stakeholders that responded to the UNECE survey 2007 no party
had information on emission control techniques, alternative production processes and
technologies, alternative operating practices and/or other pollution prevention techniques to
reduce the release of SCCPs to the environment, which are already applied or which may be
applied in the near future.
Based on available data major releases of SCCP occur during production or uses in metal
and leather industry. Besides this releases of SCCPs occur in relevant quantities during the
service life of products, disposal and recovery/reclamation operations summarised under the
designation “waste remaining in the environment” (see chapter 3.8).
Thus emission reduction measures could be considered for all sectors in the life-cycle of
SCCPs
During production and use of SCCPs, there are a number of measures that could be taken to
reduce environmental emissions of SCCPs. For example, in relation to losses to waste water
and air via settling out of dust and subsequent release through washing, companies could
collect dust and treat it as controlled waste. In relation to volatile losses, companies could
ensure that all processes are totally closed, preventing losses to the environment, or they
could install abatement technology at the site to ensure that potential emissions are captured.
No specific studies on SCCPs’ emission control techniques are available. General emission
control techniques for the industry sectors involved (metal, leather and textile working etc.)
can be found i.a. from the best available techniques reference documents (BREFs) (see:
http://eippcb.jrc.es/pages/FActivities.htm).
A ban would eliminate emissions from the production, manufacturing and use of SCCPs in
new products. It would not affect the emissions from products already in use nor directly
influence emissions from disposal or recovery.
What concerns particulate losses during the service life of products, emission control is very
difficult. The use of reactive type flame retarding compounds could be recommended as one
potential measure.
As concerns releases at disposal and recovery/reclamation several measures can be taken to
26
reduce possible emissions. This includes specific requirements as concerns collection,
separation, disposal, recovery, permitting of treatment installations and treatment standards.
Examples for measures could be taken from EU Directive 2002/96/EC on waste electrical and
electronical equipment.
In this context it is important to note that according to the requirement of article 3(3) of the
POPs protocol for substances listed in either Annex I or II the “Parties should … take
appropriate measures to ensure that wastes and articles, upon becoming wastes, are
destroyed or disposed of in an environmentally sound manner”.
In general measures identified to reduce environmental emissions at compounders and
processors could principally also be applied to disposal, recycling/recovery and dismantling
facilities. Measures should aim to minimise dust and air emissions and to avoid input to waste
water. Consequently application of BAT/BEP at disposal and recycling/dismantling/reuse
could be an efficient way. A source for possible measures could be the BREF on waste
treatment, even if specific measures for recycling/recovery and dismantling have not been
identified in the BREF (European Commission 2006).
Namely the following measures could be applied:

Separate collection of SCCP containing products at waste stage

techniques applied to waste storage (e.g. controlled run-off from storage places; using
polymer sheeting to cover open solids storage facilities that may generate
particulates)

techniques to reduce water use and prevent water contamination (e.g. vacuuming and
dust collection in preference to hosing down, circulation of washing water)

techniques for dust abatement, collection and treatment

techniques to control diffuse emissions (closed systems)

disposal of shredding residues (light fluff) as hazardous waste (incineration or landfill)

waste water treatment
4.3
4.3.1
Legislative controls
Legislative control in the European Union
In Europe a risk assessment was completed in 2000, leading to a conclusion that the use of
SCCPs in the metalworking and leather processing industries posed a risk to the environment
and there was a need for risk reduction (European Commission 2000).
As a result of the EU risk assessment and risk reduction processes, Directive 2002/45/EC of
27
the European Parliament and of the Council was adopted on 25 June 200215.
This directive came into force in January 2003 and was to be implemented by the Member
States in January 2004 at the latest. According to the Directive, SCCPs may not be marketed
or used in concentrations greater than 1% for metalworking and leather finishing.
Furthermore, the Directive states that all remaining uses of SCCPs were to be reviewed by
the European Commission, in cooperation with the Member States and the OSPAR
Commission, in the light of any relevant new scientific data on risks posed by SCCPs to
health and the environment.
The 25th Adaptation to Technical Progress to the Dangerous Substances Directive
67/548/EEC16 has formally classified C10-13 chlorinated praffins as Category 3 carcinogens
(R40) and as dangerous for the environment (R50/53).
SCCPs have also been identified as priority hazardous substances in the field of water policy
under the Water Framework Directive (Directive 2000/60/EC of 23 October 2000). These
substances will be subject to cessation or phasing out of discharges, emissions and losses
within an appropriate timetable that shall not exceed 20 years.
A number of uses (including some former uses) of SCCPs are covered under the Integrated
Pollution Prevention of Control Directive (Directive 1996/61/EC). These include (depending
on the size of operation) production of short-chain chlorinated paraffins, metal working
(though only large companies in the ferrous and non- ferrous metals sectors), some plastics
compounding/conversion sites and leather processing sites (larger sites only) (Entec, 2004).
Following the PARCOM Decision 95/1 (see chapter 4.3.3), some EU Member States have
implemented national legislation to control the uses of short-chain chlorinated paraffins
identified for phase out by 31st December 1999 (i.e. in metal working; for fat liquoring of
leather; as plasticisers in paints or coatings; and as flame retardants in rubber, plastics or
textiles). Note: The EU risk assessment carried out in accordance with Regulation
793/93/EEC updated the assessment that justified PARCOM Decision 95/1, and did not
identify risks from all of these uses.
Commision Decision 2004/1 authorised the Netherlands and the United Kingdom to partially
maintain their national provisions on SCCPs until 31 December 2006.
In Germany, certain halogen-containing wastes, for example metal working fluids with
>2 g halogen/kg and halogen-containing plasticisers, are classified as potentially hazardous
waste and are incinerated (BUA, 1992). As a consequence oils containing chlorinated
paraffins in concentrations above 0.2% may not be used for material recovery.
15
16
See http://europa.eu.int/eur-lex/pri/en/oj/dat/2002/l_177/l_17720020706en00210022.pdf
Commission Directive 98/98/EC; OJ L355/1 from 30.12.98
28
4.3.2
Legislative control in other countries
4.3.2.1 Legislative control in the USA
According to available information, there have been no specific regulatory actions on SCCPs
in the United States. The only specific federal environmental regulation is an annual
requirement that requires certain facilities to report environmental releases of SCCPs under
the Toxic Release Inventory (TRI).
4.3.2.2 Legislative control in Canada
In Canada, chlorinated paraffins (CPs) were placed on the First Priority Substances List
(PSL1) to determine whether they posed a risk to the health of Canadians or to the
environment. The final PSL1 assessment report was published in 1993 and concluded that
SCCPs were toxic to human health. However, there was insufficient information to conclude
whether short, medium or long chain CPs were harmful to the environment or whether
medium or long chain CPs were considered a danger to human health.
Environment Canada and Health Canada have completed draft scientific assessments of
short chain, medium chain, and long chain CPs, as a follow-up to the PSL1 assessment.
The Draft Follow-up Report prepared by Environment Canada proposes that short, medium,
and certain long chain CPs are toxic to the environment, as defined under Canadian
Environmental Protection Act, 1999 (CEPA 1999), and would be proposed as candidates for
virtual elimination. “Virtual elimination" means, in respect of a toxic substance released into
the environment as a result of human activity, the ultimate reduction of the quantity or
concentration of the substance in the release below the level of quantification specified by the
Ministers in a “Virtual Elimination List” which shall specify the level of quantification for each
substance on the List.
The draft follow-up report is currently being revised in consideration of public comments
received. At present, the Existing Substances Division of Environment Canada does not
expect any changes to the conclusions for SCCPs (Envrionment Canada 2007).
When the level of quantification for a substance has been specified on the Virtual Elimination
List, the Ministers shall prescribe the quantity or concentration of the substance that may be
released into the environment either alone or in combination with any other substance from
any source or type of source, and, in doing so, shall take into account specific information,
including, but not limited to, environmental or health risks and any other relevant social,
economic or technical matters (CEPA 1999)17.
Currently, no level of quantification is specified. This will be done after publication of the final
assessment conclusions. Currently, Environment Canada has not implemented management
options for SCCPs. Management options will be proposed, if warranted by the outcome of the
17
see http://www.ec.gc.ca/ceparegistry/the_act/Part5_a.cfm
29
assessment. The risk management strategy will be available at the time of the publication of
the final assessment decision (Environment Canada 2007). The publication of the final follow
up assessment report for chlorinated paraffins is pending (UNECE survey 2007, Canada).
4.3.2.3 Legislative control in Norway
Regulations governing the use of short-chain chlorinated paraffins in Norway were laid down
on 13th December 2000. According to the regulations, production, import, export, sale and
use of short-chain chlorinated paraffins in pure form, preparations or in finished products is
prohibited. The regulations entered into force on 1st January 2001. According to the
transitional provisions, the prohibition of the sale and use of short-chain chlorinated paraffins
entered into force on 1st January 2002 and will come into force on 1st January 2005 for
conveyor belts in the mining industry and sealing materials (European Commission 2005b).
4.3.2.4 Legislative control in Switzerland
According to Ordinance on Risk Reduction related to Chemical Products of 18 May 2005 (Art.
3 and Annex 1.2), it is prohibited to place the following product types on the market if they
contain more than 1% of SCCPs by mass: paint and varnishes, sealants, plastics and
rubbers, textiles, leather processing products and metal working products. The Swiss
regulation implements Directive 2002/45/EC as well as PARCOM Decision 95/1.
4.3.3
Measures/control by international institutions
Stockholm Convention
The Stockholm Convention, which entered into force on 17 May 2004, is open to all states
and regional economic integration organisations. It is a global instrument that aims to make
sure that the substances it lists are no longer produced, used, imported and exported. It also
seeks to stop or reduce the releases of POPs that are unintentionally produced. SCCPs are
proposed to be listed under the Stockholm convention. The decision process is currently
ongoing. In December 2006, the Parties to the UNECE POPs Protocol agreed that SCCPs
should be considered as a POP as defined under the Protocol.
International Agency for Research on Cancer (IARC)
In 1989, as a result of laboratory testing in animals, SCCPs were classified as a Group 2B
carcinogen (possibly carcinogenic to humans) by the International Agency for Research on
Cancer (IARC).
PARCOM
In 1993, PARCOM published a proposal to phase out the use of SCCPs. However, this was
rejected as it did not raise the necessary support from signatories. Signatories include
Belgium, Denmark, Finland, France, Germany, Iceland, Ireland, Luxembourg, the
Netherlands, Norway, Portugal, Spain, Sweden, Switzerland and the UK, as well as the EU
30
as a whole. In 1995, the proposed ban on the use of SCCPs was accepted by PARCOM and
deadlines were set out for the phase out of SCCPs. This PARCOM Decision lays down the
phasing out of the uses of SCCP within the following time frame: use as plasticiser in paints
and coatings, use in metal working fluids, use as flame retardants in rubber, plastics and
textiles by 31 December 1999; use as plasticiser in sealants by 31 December 2004. It is
noteworthy that leather processing is not covered. Eleven of the EU Member States and
Iceland, Norway and Switzerland had committed themselves to PARCOM Decision 95/1.
Though signatory to PARCOM, the UK did not accept the PARCOM Decision 95/118.
OSPAR Commission
SCCPs are included in the list of substances for priority action within the OSPAR Strategy
with regard to Hazardous Substances. The OSPAR Commission for the Protection of the
Marine Environment of the North-East Atlantic has adopted a decision on SCCPs in 1995
(PARCOM Decision 95/1). This established a ban on the use of SCCPs in all areas of
application: as a fluid additive in the metal working industry; as a fat liquoring agent in the
leather finishing industry; as a plasticiser in paints and coatings; as a plasticiser in sealants;
and as a flame retardant in rubber, textiles and plastics. Under this Decision, the sale and use
of SCCPs should be prohibited by the end of 1999. Exemptions allowed the use of SCCPs in
dam sealants and underground mine conveyor belts until 2004.
Helsinki Commission (HELCOM)
Similarly to OSPAR, also the Baltic Marine Environment Protection Commission (HELCOM)
has included SCCPs on their list of harmful substances. Helcom has also recently completed
a three-year project to identify the most cost-effective ways of eliminating certain hazardous
substances in the region by 2020, which includes short-chain chlorinated paraffins. This
follows a ministerial pledge to phase-out short-chain chlorinated paraffins in a 1998
environmental declaration (along with around 70 other substances). According to available
information no recommendations have yet been taken on SCCPs.
International maritime organisation
SCCPs are categorised by the international maritime organisation as severe marine pollutant
and are, therefore, now placed in UN class 9 for road/rail transport in Europe (Eurochlor
2005). The international maritime organisation furthermore lists specific actions in a report on
maritime protection. In its summary of the “Regional Programme of Action for the
Mediterranean” the report lists as action at national level to make an inventory of the uses
and quantities of chlorinated paraffins and to reduce the use of short-chain chlorinated
paraffins (IMO 2001).
Non-legislative Control at European level
SCCPs are excluded according to the criteria for the voluntary “EU ecolabel” for several types
18
http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!CELEXnumdoc&numdoc=52000PC0260&lg=en
31
of electrical equipment (Annex E response 2007, Germany)19.
Non-legislative Control by the Australian Government
The Australian Government (Department of Health and Ageing) performed an Environmental
Exposure Assessment of Short Chain Chlorinated Paraffins (SCCPs) in Australia (NICNAS
2004). According to the assessment substitution is a potential option in Australia, but it may
not fully address the issue. SCCPs are being replaced with MCCP and LCCPs in Australia.
The main problem with environmental exposure is not just the SCCPs, rather the poorly
controlled use and release of metal working fluids in general, possibly due to their low cost
and hence, a lack of incentive to preserve such chemicals. According to NICNAS 2004 it may
be that a better goal is to increase awareness among users of the need to control release of
these substances, thereby reducing environmental exposure to not only the SCCPs which are
present as extreme pressure additives, but also all other components of metal working fluids
such as emulsifiers, biocides, anti-foaming additives etc. that are present in cutting fluid
formulations. In NICNAS 2004 the following relevant recommendations are listed:

Recommendation 3 (to end users) Voluntary industry phase-out of the use of SCCPs
in metal working fluids is recommended. Substitution of chlorinated paraffins with nonchlorinated extreme pressure additives should be carefully considered and
implemented wherever possible.

Recommendation 4 (to end users): To reduce the potential environmental exposure
from splashing/spillage, on a day-to-day basis, spills should be cleaned up
immediately. Wastes should not be dumped or swept into sumps or coolant return
trenches. Waste material, including solvent-soaked rags used for clean-up, should be
deposited in airtight metal receptacles prior to disposal to landfill.

Recommendation 7 (to state and territory environment authorities): State and territory
environment authorities should note recommendations 3 and 4 and could work in
partnership with industry to ensure take up of voluntary initiatives. Environment
authorities should explore compliance measures as necessary and may wish to build
into their chemical program a measure to monitor for the poor management and
disposal of metal working fluids.
4.4
4.4.1
Cost implications
Cost implications for industry
The European Commission report (ERM 1999) constitutes a summary of studies carried out
on costs and benefits of control of SCCPs and deals mainly with the advantages and
drawbacks of the bans of some uses. The assessment of cost implications in the ERM study
is based on historical use figures and patterns. As the report is not publicly available, the
19
see http://europa.eu.int/comm/environment/ecolabel/index_en.htm
32
following conclusions are drawn from the summary information contained in the EU risk
profile (European Commission 2005a). Conclusions are based on updated information on
production and uses.
In addition a 2006 study prepared for the Netherlands Ministry of Housing, Spatial Planning
and the Environment (TNO 2006) provides cost estimates for the substitution of SCCP in the
UNECE European region. The estimates from the dutch study (TNO 2006) assume that in
2010 for the EU all uses of SCCPs will have ceased at no additional costs for a revised POP
protocol because of autonomous developments due to European legislation (e.g. Directive
2002/45/EC). For non EU European UNECE countries the cost estimates are based on UK
figures from the end of the nineties (RPA 2001). According to this study additional costs in the
dimension of about 1000 €/ton should be expected for a substitution in sealants and
adhesives, metal working fluids and PVC, whereas substitution in the leather processing
seems to be easy and cheap.
In general it has to be stated that it is difficult to make quantified estimates of the economic
impacts of restrictions at UNECE level due to lack of robust background information.
The use figures have significantly decreased in western Europe within the last years due to
the ban of SCCPs in metalworking and leather processing and due to the fact that all other
major uses have been phased out in those countries who have accepted PARCOM decision
95/1 (see chapter 4.3.3). As a consequence, cost implications are not relevant any more in
these countries for the uses that are already phased out. Cost implications within the UNECE
region are therefore particularly expected in eastern European countries, the USA and
Canada.
4.4.1.1 Cost implications for producers
The market volume of SCCP production within the UNECE region can be estimated as shown
in Table 4-2 assuming a price of 1.5 € per kg SCCPs.
Production range
EU
1,500 to 2,500 tonnes per 2006
year
2,3
3,8
USA
6,000 to 8,800 tonnes per 2002/1998
year
and 2005
9,1
13,3
Canada
0 tonnes per year
0,0
0,0
Total
7,500 to 11,300
11,4
17,1
Table 4-2:
Year
Market volume range (m€)
Region
2006
Estimated market volume of SCCP production in Europe, the USA and Canada
Based on estimated use figures of 67,727 tons/year for SCCP in metal working in eastern
European UNECE countries mainly Russia and Ukraine (TNO 2006), a significant additional
market volume could be expected. However there is no confirmation of these data from
national authorities in these countries.
33
Information on the likely impacts for the producers of a ban on the use of SCCPs include the
following:

due to the fact that production is a batch process, the technical/conversion costs of
the transition from SCCPs to MCCPs (the major alternative) is limited (estimated
<100€/ton);

several producers have been instrumental in moving customers away from SCCPs
since the EU phase out and PARCOM Decision 95/1, and so costs of conversion were
already been borne by the producers;

the unit cost of MCCPs is lower by around 25% per tonne, which will reduce the value
of sales for producers of chlorinated substitutes (but will also reduce the input costs
for users);

as SCCPs will not only be substituted by other chlorinated paraffins but also by nonchlorinated substances, there will be a certain loss of sales for the existing producers;
on the other hand producers of substitutes will have corresponding increases in sales
of more expensive products

it can be expected that there will be no change in the overall employment situation
considering the producing companies of SCCPs and alternatives.

There will be no impact on exports to non UNECE regions
Conclusions for producers:
Producers of SCCPs and chlorinated substitutes will have to face to certain losses that are
difficult to quantify but could be in a dimension of 10-20 m€. On the other hand it can be
expected that these losses will be outweighed by corresponding gains for producers of
MCCP, LCCP and other appropriate substitutes. It can therefore be expected that the overall
impact on the producing chemical industry is characterised by a shift from SCCPs to
substitutes and that the gains for substitutes will outweigh the losses for SCCPs.
4.4.1.2 Cost implications for the metalworking sector
Short-chain chlorinated paraffins are used as extreme pressure additives in metalworking
fluids, particularly for processes involving very high pressure, temperature and /or with high
sheering forces. They perform lubrication, cooling and swarf (metal debris/fragments) clearing
roles, and are used as cutting and drawing liquids (metal forming).
Prior to the phase out of SCCPs in metalworking in western Europe (EU, NO, CH) there
where several concerns if technical requirements can be completely fulfilled by available
alternatives. At present it appears that, less harmful and technically appropriate substitutes
are available for all uses in metalworking.
34
Due to the phase out of SCCPs in this sector in the EU, Norway and Switzerland, cost
implications in the UNECE region may occur in eastern European UNECE countries, Canada
and the USA. For these regions metalworking is the most relevant use of SCCPs.
Based on information from Europe that was collected prior to the phase out in 2003,
transitional costs due to the need for reformulation, e.g. laboratory testing, were expected to
be in the order of 50,000 Euros per formulator. Cost increases around 20% have been
expected for moving to chlorine-free alternatives as their development requires reformulation
of the base-oil. It had been suggested that such costs would be passed onto the customer. At
that time, chlorine-free products cost approximately 25 to 33% more than SCCP-based fluids.
Price increases of no more than 5% were estimated when switching from SCCPs to MCCPs.
Formulators indicated that these costs would most likely be absorbed by themselves, rather
than being passed onto the users.
According to the british study (RPA 2001) substitution costs for metal working fluids depend
on the type of substitute ranging from 100 € per ton for MCCPs to 2,500 € per ton for nonCPs. That means that replacement costs are depending on whether the use of medium or
long chained chlorinated paraffins is acceptable as replacement for SCCPs in metal working
fluids.
Based on current use figures of 67,727 t/y in non-EU European UNECE countries20 the dutch
study (TNO 2006) assumes additional annual costs of 7-169 m€/y (lower figure for
substitution with MCCPs) in the non-EU European UNECE countries. Based on the estimated
production figures in the USA of roughly 8,000 t/y (see chapter 3.1.1; assumed that all
SCCPs produced are used within the country and thereof 50% in metal working) additional
costs of 0.4-10 m€ (lower figure for MCCP) can be expected for substitution in this region.
Against the fact that appropriate and economically viable substitutes are now available for
metal working fluids for all uses and based on the experiences from formulators supplying the
European metal working sector, corresponding increases in eastern European UNECE
countries, the USA and Canada will probably be significantly lower for the move to chlorine
free or chlorinated substitutes. Transitional costs for reformulation of metalworking fluids are
expected to be significantly lower due the exsting experiences of formulators supplying the
western European Market.
Cost increases are expected to be largely absorbed by formulators rather than being passed
onto users. As a consequence there are only low cost implications expected for the
metalworking sector in the UNECE region as a consequence of a phase out of SCCPs for this
specific use.
20
Albania, Armenia, Azerbaijan, Belarus, Bosnia and Herzegovina, Croatia, Federal Republic of Yugoslavia,
Former Yugoslav Republic of Macedonia, Georgia, Kazakhstan, Kyrgyzstan, Republic of Moldova, Russia,
Ukraine, Turkey
35
4.4.1.3 Cost implications for the leather processing sector
SCCPs are used as relatively cheap bulking agents in the leather industry to increase the
product volume of fat- liquors (processing agents). However, SCCPs are reported not to offer
any improved performance as they do not convey any fat-liquoring properties - the
replacement of oils lost during the tanning process - they are merely odour- free and ‘costeffective’ in comparison to current alternatives. SCCPs may comprise around 20% of the fatliquoring mix, with approximately 1-5% of SCCPs used found in the waste washings.
Already prior to the phase out of SCCPs in leather processing in Europe it has been indicated
that SCCPs do not appear to be crucial to leather processing, used only in ‘lower grade’ fatliquoring agents. No calls for derogations by the leather industry had been presented in the
light of the planned phase out of SCCPs for use in leather processing in the EU.
There are no indications that the use of alternatives (any of a range of animal, vegetable or
mineral oils) would alter the quality of the end-products. It has been concluded for the UK that
there are no technical barriers to the substitution of SCCPs in leather processing fluids and
that additional costs for substitutes are not significant. Any cost increases passed on to the
consumer will be minimal (TNO 2006).
Due to the phase out of SCCPs in this sector in the EU, Norway and Switzerland, cost
implications in the UNECE region may occur in eastern European UNECE countries, Canada
and the USA. Neither for Canada nor for the USA leather processing has been indicated as
major use. No information is available for eastern European UNECE countries.
Against this background it can be assumed that no relevant cost implications will affect the
leather processing sector in the UNECE region as a consequence of a phase out of SCCPs
for this specific use.
4.4.1.4 Cost implications for non-emissive applications
Applications and Quantities Used
SCCPs are used in a range of non-emissive applications:

as plasticisers in paints, coatings and sealants

as flame retardants in rubber, textiles and plastics.
All these uses are already phased out in those countries of the UNECE region who accepted
PARCOM Decision 95/1 (see chapter 4.3.3).
In the EU the amounts used in non-emmissive applications have decreased by approximately
one third from 1998 to 2005 (from 1,999 tonnes to 625–875 tonnes). It can be assumed that
expectable cost implication in this sector would be diminished correspondingly. In Canada
only minor uses are indicated as a flame retardant in plastics and rubber. Though exact
36
amounts used are not known, the most significant amounts for non-emissive applications
appear to be used in the USA. According to CPIA up to 50% of all CPs are used in nonemissive applications with an unknown share of SCCPs (see chapter 3.1.2). No information
on used amounts is available from eastern European UNECE countries.
According to the Dutch study (TNO 2006) costs for substitution in these sectors are estimated
as approximately 1,000 € per ton. Especially in flame retarded conveyor belts significant
investment and research needs are assumed as no other substances are currently thought to
be suitable for the products in question. Based on the amounts estimated for non-emissive
uses amounting up to approximately 900 t/y in the EU (seeTable 3-3) additional costs of a
maximum of 0.9 m€ are anticipated for the EU. Thereof 0.37 m€ can be allocated to the use
in paints, coatings and sealants, 0.12 m€ to the use in rubber and as flame retardants and
0.41 m€ to other non-emissive uses.
Assuming a 50% share for non-emissive applications in the USA and an overall use of
roughly 8,000 t/y results in potential additional costs of 4 m€ in the USA. On the basis of the
use shares of chlorinated paraffins in the USA (see chapter 3.1.2) these potential additional
costs can be allocated to different uses as follows: plastics 1.6 m€, rubber 0.96 m€, paints
0.72 m€, adhesives 0.48 m€ and miscellaneous 0.24 m€.
Technical & Economic Implications of Restrictions for Users
The phase out of SCCPs in those countries that accepted PARCOM Decision 95/1
demonstrates that alternatives are available for non-emissive uses. For all use types
alternatives are available that are generally considered less harmful than SCCPs (see
chapter 4.1).
The only uses where it would be difficult to substitute SCCPs are those applications where
they are used as a flame retardant additive. In some applications (e.g. as a flame retardant
additive for rubber formulations) SCCPs enable the optimisation of high levels of chlorine
content for maximum fire retardancy combined with workability of the formulation (as viscosity
of the CPs is a function of chain length and chlorine content) (UNECE survey 2007, Euro
Chlor). Even if alternatives are available there might still be uses where alternatives do not
fulfil all technical and security demands.
Plasticiser in Paints/Coatings
SCCPs are used as a plasticiser for paint resins. There appeared to be considerable
confusion within the industry of the exact application of these SCCP-based paint resins.
Corresponding information from different suppliers, formulators and users was quite
contradictory (ERM 1999).
SCCPs are considered the most cost-effective plasticiser soluble in specific paints and it has
been estimated that the use of SCCPs in solvent based acrylic paints may increase. It has
also been estimated (with a high degree of uncertainty) that a ban in the EU on SCCPs might
lead to a 7% increase in the cost of acrylic paints.
37
As a consequence a ban on SCCPs for use in paints and coatings may lead to an increase in
the cost of specific paints in those countries of the UNECE region which have not already
phased out this specific use. It is to be expected that the increase will be passed onto the
consumer.
The total increase on the basis of additional costs for substitution of 1000 € per tonne is
expected to amount to 0.37 m€ for the use in paints, coatings and sealants in the EU and to
0.72 m€ for the use in paints in the USA.
Plasticiser in Sealants/Adhesives
SCCPs and MCCPs are used as inert plasticisers in a wide range of sealants and mastics for
use in construction, automotive and industrial applications (e.g. polysulphide sealants and
polyurethane-based resins). They are also used in adhesives as a plasticiser or flame
retardant additive.
Some producers stated that they would need up to 2 years to find and test alternatives and
that costs to end users may increase by 5%. Other companies have substituted SCCPs with
MCCPs and report no apparent loss in performance or increase in cost.
According to TNO 2006 the replacement of SCCPs in sealants and adhesives might cause
equivalent or greater costs per ton than in metal working.
In the light of the phase out of the use of SCCPs in plasticizers and sealants that is now
already in place in several European countries, additional costs are expected to arise mainly
in other UNECE regions. Against the background of limited amounts used in sealants and
adhesives (Estimated use of SCCPs for adhesives in the USA ~ 480 tonnes/year) related
costs are expected to be moderate (e.g. 0.48 m€ for the use as adhesives in the USA on the
basis of additional costs for substitution of 1000 € per tonne).
Flame Retardant in Rubber, Textiles and Plastics
Short-chain chlorinated paraffins (C10-C13) or long-chained, with 70-72% chlorine, are used
as flame retardant additives in synthetic rubber and flexible PVC. They are often used in
combination with antimony trioxide and other substances to improve flame resistance. Their
main application is in inflammable conveyor belts, hoses and tubes in underground mining
applications, where use of SCCPs has been justified on grounds of the high flame resistance
required for safety reasons.
Under the PARCOM Decision 95/1, exemptions were allowed for the use of SCCPs in dam
sealants and underground mine conveyor belts until 2004.
According to the ERM study (ERM 1999) available alternatives were substantially more
expensive than SCCPs (required in greater quantities to achieve desired chlorine level, or up
to 4 or 5 times as costly). Reformulation costs were assumed to be in the order of 75,000
Euros per producer, and reapproval costs could be in the order of 1.5 m€ for the larger
38
producers. This was estimated to lead to a rise in cost of finished products of 15-20% if
SCCPs were banned and to possible losses of jobs.
Against the background of the experiences made in those countries where SCCPs is already
phased out, it can be expected that corresponding costs in other UNECE countries will be
lowered. However, cost implications may arise for reformulation, reapproval and on the price
for the finished product if the use of SCCPs in rubber will be prohibited. On the basis of
estimated additional costs for substitution of 1000 € per tonne, the expected increase
amounts to 0.12 m€ for the overall use in rubber in the whole EU and to 0.96 m€ for the
overall use in rubber in the USA.
Having in mind the high total investment and operating costs that are expended in
underground mining and dam construction, additional costs caused by a ban of the use of
SCCPs in rubbers e.g. for conveyor belts or dam sealants seem to be economically
justifiable. It is not expected that price increases will influence the investment decisions in
underground mining or dam construction.
For the use of SCCPs as flame retardant in textiles and plastics viable alternatives (mainly
inorganic substitutes) are available (see Table 4.1). No significant cost implications are
expected if this specific use will be banned.
4.4.1.5 Cost implications for the disposal and recovery/reclamation sector
Due to the relative importance of releases during service life and disposal it would be
important to implement BAT/BEP (Best Available Technologies/Best Environmental
Performance) at disposal and recycling/recovery installations for minimisation of releases,
also if a ban of SCCPs will come into force in the UNECE region (see chapter 4.2).
Costs related to the application of BAT can per se be considered economically viable as this
term designates economically and technically available techniques. The best environmental
performance is usually achieved by the installation of BAT and its operation in the most
effective and efficient manner. It can be assumed that within the UNECE region application of
BAT is generally economically justifiable. The installation of end-of-pipe control technologies
could for example be costly. However, in most countries requirements for end-of-pipe
measures already exist for disposal and recycling/reclamation plants (e.g. for off-gas cleaning
in inceration plants and emission control in shredding plants). Therefore expected cost
implications are limited.
Costs will also arise from collection, separation, dust abatement, waste water treatment and
disposal of residues.
4.4.2
Cost implications for consumers
Increasing costs for substituting SCCPs in metal working, leather and textile and nonemmissive applications may be passed onto the consumer.
39
This is only relevant for those countries and uses where prohibitions are not already in place.
It can be assumed that experiences made with substitution in the EU and those countries who
accepted PARCOM decision 95/1 can be used in other UNECE regions to moderate possible
price increases for consumers.
Whereas additional costs have been reported to be mainly absorbed by producers as
concerns metal working in case of substitution with MCCP (see chapter 4.4.1.2), moderate
increases in costs might be expected for adhesives and sealants. Cost increases are also
expected in the case of solvent based acrylic paints and the use of SCCPs in specific rubber
products (e.g. mine conveyor belts) see chapter 4.4.1.4.
In any case it is not expected that the price increases will influence the decision of the
consumer.
4.4.3
Cost implications for state budgets
No specific information on additional costs for state budgets could be identified. However it
can be expected that some additional budget for enforcement and compliance will be required
depending on the current status or plannings on the phase out of specific uses of SCCPs in
each country. Though no specific information was available on cost implications of a ban of
SCCPs, some conclusions can be drawn from estimations for the ban of other POPs. The
total enforcement and compliance promotion costs for a ban and phase out of c-octaBDE for
the Canadian Government over a 25-year time frame were estimated to be in the order of
439,646 Canadian dollars21. Therefore full additional costs for a ban of SCCPs for a country
like Canada are expected to amount to several 100,000 €. Over a 25-years period this does
not seem to be important.
No relevant additional costs will occure in countries who have accepted PARCOM decision
95/122 (phase out already completed). Restricted additional cost can be expected in countries
which have phased out use in metalworking and leather processing but which still allow the
non emissive uses (phase out partly completed) or which currently plan restrictions on
SCCPs (e.g. Canada). Full additional costs will occur in countries whithout any present or
planned restrictions on SCCPs (e.g. eastern European UNECE countries, the USA).
21
22
Which corresponds to approximately 290,000 €
BE, DE, DK, FI, FR, IE,ICE, LUX, NL, PO, ES, SE, NO, CH
40
5 Identification and discussion of possible management options
under the UNECE POPs protocol
The Task Force on POPs concluded that SCCPs are bioaccumulating, toxic and are generally
persistent and have potential for long-range environmental transport (with some uncertainty
relating to persistence; ECE/EB.AIR.5/2006/10). Recently reported results confirmed the
criteria for persistency (ECB 2007).
Releases of short-chain chlorinated paraffins (SCCPs) can occur during production, storage,
transportation, and use of SCCPs. Production and use of SCCPs has been restricted over the
last years in several UNECE countries but no total prohibition has yet been foreseen23. On
the other hand, production and use of SCCPs continues unrestricted in many other countries.
As SCCPs can move in the atmosphere far from its sources, single countries or groups of
countries alone cannot abate the pollution caused by SCCPs. Due to the harmful POP
properties and risks related to its widespread production and use, international action is
warranted to control this pollution (see ECE/EB.AIR.5/2006/10, ECE/EB.AIR/87 and POPRC
2007).
Possible options to manage SCCPs are to

restrict or eliminate production and use of SCCPs totally in order to completely
remediate the above mentioned concerns and potential risks

ban the critical uses in order to partly remediate the above mentioned concerns and
potential risks.
5.1
Possible management options under the UNECE POPs protocol
The objective of the POPs protocol is to control, reduce or eliminate discharges, emissions
and losses of persistant organic pollutants.
The main emissions are related to the following specific uses of SCCPs:

metal working and formulation of products for this use

leather finishing applications and formulation of products for this use

formulation and processing of backcoatings and application of backcoatings to textiles

conversion and combined conversion/compounding of rubber

industrial use of paints and coatings
23
All major uses of SCCPs are prohibited in those countries who have accepted PARCOM decision 95/1 (see
chapter 4.3.3).
41
In addition losses over life-time and at disposal of products containing SCCPs are a relevant
source of releases.
In order to remediate the concerns and potential risks two general options are possible:
Option 1.
So as to completely remediate the concerns and to eliminate all risks related to
SCCPs it would be possible to list SCCPs in annex I of the POPs protocol in
order to eliminate its production and use
Option 2.
So as to partly remediate the concerns and to specifically eliminate the main
emissive applications (critical uses) of SCCPs it would be possible to list SCCPs
in annex I and annex II of the POPs protocol and to specify allowed uses and
related conditions in the implementation requirements of annex II
If option 2 will be chosen, it is necessary to specifiy allowed uses. It might be reasonable to
allow the uses where according to the present state of knowledge significant cost implications
might be expected which are not outweighed by the benefits or for which there are no suitable
alternatives available. Allowed use should be subject to a review process for the
reassessment of the derogation in the light of updated information (e.g. technical
development and impact assessment) including the specification of a time frame of e.g. two
years in the implementation requirements of annex II.
Option 2 could be defined in different ways. Two possible options are discussed below as
option 2a and option 2b.
Option 2a: Ban of all uses except “dam sealants and conveyor belts for underground mining”
Option 2b: Ban of uses in metal working and leather processing. All other known major uses
allowed i.e. as plasticizer in paints, coatings and sealants and as flame retardant in rubber,
textiles and plastics.
It is also possible to combine the options in different ways. A third option could be a
combination of options 1 and 2a and 2b.
Option 3.
So as to partly remediate the concerns it would be possible to list SCCPs in
annex I in order to ban all uses (option 1) but to except a number of uses such
as dam sealants and conveyor belts (option 2a) or other non-emissive uses
(option 2b) specified in annex II, with specific conditions for a stepwise phaseout (limited derogations for specific uses or non-EU countries) and a reassessment of the allowed uses in the light of technical progress and additional
knowledge.
All options would include the obligation to develop measures related to the service life of
products and their disposal as, according to Article 3(3) of the POPs protocol, “each Party
should develop appropriate strategies for identifying articles still in use and wastes containing
such substances, and shall take appropriate measures to ensure that such wastes and such
42
articles, upon becoming wastes, are destroyed or disposed of in an environmentally sound
manner” for substances listed in annex I or II of the POPs protocol.
5.2
Discussion of options
Releases of SCCPs in the UNECE region arise from production, use, handling and transport,
use of products containing SCCPs and from disposal/recycling/dismantling of waste
containing SCCPs. In this context releases from production and use of metal working fluid
and leather processing as well as releases during life-time and disposal of products can
generally be regarded as fields of major concern.
Management options should aim to remediate adverse environmental or human health effects
as a consequence of all possible releases. Listing of SCCPs under the POPs protocol
addresses releases at all life cycle stages.
As measures related to the service life of products and their disposal are to be developed
both for substance listed in Annex I and II the impact of both options related to releases at
disposal is similar. In particular measures could be suggested to reduce releases at disposal
by applying BAT/BEP at disposal and recycling/dismantling/reuse. If option 2 will be chosen
such measures (e.g. restrictions and provisions for disposal) are of higher importance as
SCCP containing products and waste from allowed uses will continue to arise also in the
future.
‘With respect to option 1 (complete ban of production and all uses) the following advantages
and disadvantages have to be taken into account:
Advantages option 1:

General concerns and all definite risks would be completely remediated.

Releases from service life and disposal of all products would be comprehensively
addressed in the long term.

Existing market distortions that are due to the already existing ban of SCCPs in all
major uses in several UNECE countries would be remediated.

Compliance could be easily ensured if a ban will be effective throughout the UNECE
region (no problems in trade between UNECE countries)

Benefits are expected for environment and health.
Disadvantages option 1:

Significant cost implications may be possible in specific sectors.

Significant risks may be caused if safety standards (e.g. flame retardancy) can not be
43
maintained due to the ban in selected uses.
It can be stated that option 1 is related to important advantages and contributes fully to the
objective of the POPs protocol to control, reduce or eliminate discharges, emissions and
losses of SCCPs as releases from all uses and from life-time and disposal of products would
be covered. The precautionary principle would be fully applied.
On the other hand possible disadvantages have to be taken into consideration when
discussing option 1.
Generally option 1 is related to possible cost implications in specific sectors. As long as the
economic impacts are not exhaustively assessed, it could be reasonable to include provisions
for a stepwise phase-out.
Cost implications are expected to be relatively low in the metalworking sector (in particular as
long as MCCPs will be accepted as substitutes) and in the leather processing sector. No
significant cost implications are furthermore expected for the use as flame retardant in
plastics and textiles. (for expected cost implications see chapter 4.4).
In particular for two specific uses significant cost implications or problems may be expected:
The ban of the use of SCCPs as plasticizer in paints and coatings may lead to a significant
increase in the cost of specific paints in those countries of the UNECE region which have not
already phased out this specific use.
Even more significant cost implications can be expected for a ban of the use of SCCPs as
flame retardant in rubber for the production of inflammable conveyor belts and dam sealants
for underground mining. However, having in mind the high total investment and operating
costs that are expended in underground mining and dam construction additional costs caused
by a ban of the use of SCCPs in rubbers e.g. for conveyor belts or dam sealants seem to be
economically justifiable. It is not expected that price increases will influence the investment
decisions in underground mining or dam construction. If price increases are not economically
reasonable, it could be prudential to allow these specific uses for a certain time frame.
Another disadvantage of a complete ban would be that significant risks may be caused if
safety standards (fire retardancy) can not be maintained due to the ban of SCCPs for use in
rubber. Their main application is in inflammable conveyor belts, hoses and tubes in
underground mining applications, where the use of SCCPs has been justified on grounds of
the high flame resistance required for safety reasons. Therefore, under the PARCOM
Decision 95/1, derogations were made for the use of SCCPs in dam sealants and
underground mine conveyor belts until 2004. If SCCPs would be listed to annex 1 of the
POPs protocol safety risks may arise in the UNECE regions where the use of SCCPs in
rubber is not already prohibited. It should be evaluated whether such risks could be avoided
on the basis of the experiences that are already made in those countries where the use in
dam sealants and conveyor belts has been banned since 2004. To this end information would
be needed on whether alternatives are at present available and if they fulfil the required
44
safety standards.
Conclusion option 1:
Option 1 could be a reasonable recommendation. If the cost implications are economically
justifiable and safety standards (in particular in the field of conveyor belts and dam sealants in
underground mining) can be maintained despite a total ban of SCCPs, option 1 should be
selected in order to achieve a maximum and long term elimination of releases and to prevent
a re-introduction of SCCPs. In this way a maximum of non-quantifiable benefits will be
achieved and all concerns and potential risks will be completely remediated.
‘With respect to option 2 (ban with exceptions) the following advantages and disadvantages
have to be taken into account:
Advantages option 2:

Possibilty to mitigate inacceptable cost implications in specific cases

Possibility to maintain safety standards in specific applications

Possibility to phase out allowed uses within a reasonable time frame against the
background of economic and safety aspects, risk assessment and technical
development

Major concerns and possible risks would be remediated.

Releases from the service life and disposal of products would be partly addressed.

Reasonable time frames for re-assessment of allowed uses would enable to invent
appropriate substitutes for critical or low emissive uses

Benefits are expected for environment and health
Disadvantages option 2:

Medium to long term releases from allowed uses and over the service life of related
products would remain

A number of releases would continue as long as the corresponding uses will be
allowed.

Existing market distortions that are due to the already existing ban of SCCPs in all
major uses in several UNECE countries would remain.

It would be more difficult to ensure compliance if a ban will be effective in some
countries of the UNECE region and in others not (problems in trade between UNECE
countries)
45

The non-quantifiable benefits would not be maximised
Option 2 is related to the mentioned advantages as it allows maintaining specific uses. Thus
inacceptable possible impacts of a total ban can be mitigated even if major emissions would
be reduced.
On the other hand option 2 is releated to the specific disadvantages that, if specific uses will
be allowed emissions will partly continue, the general concerns related to SCCPs would not
be completely remediated and the non-quantifiable benefits would be reduced. Thus the
objective of the POPs protocol to control, reduce or eliminate discharges, emissions and
losses of SCCPs would not be completely targeted.
It is furthermore noteworthy, that currently market distortions exist within the UNECE region
because the use of SCCPs is already banned in major uses in several UNECE countries.
Diverging restrictions between UNECE countries lead to competitive advantages in those
countries where the use of SCCPs is less restricted. Furthermore different restrictions give
rise to problems in trade between UNECE countries and make it difficult to ensure the
compliance with the restrictions. Problems concerning compliance and currently existing
market distortions will partly remain if option 2 will be selected.
In order to minimise remaining releases from life-time and disposal of products containing
SCCP, an additional condition related to environmental sound disposal and recovery (e.g.
disposal as hazardous waste, impermeable soils, coverage of storing facilities and dust
abatement in recovery installations) could be added to option 2 as condition for allowed uses
in annex II.
As proposed under option 2a the use of SCCPs in “dam sealants and conveyor belts for
underground mining” could be specified as allowed use. This could be justified with possible
cost implications and/or with safety standards which need to be maintained. On the other
hand potential risks related to conversion and combined conversion/compounding of rubber
will remain if this use continues.
Conclusion option 2a:
Option 2a could be a reasonable option. The use of SCCPs in “dam sealants and conveyor
belts in underground mining” could be specified as allowed use if safety risks and cost
implications cannot be avoided on the basis of the experiences that are already made in other
countries. If option 2a is selected the non-quantifiable benefits will not be fully achieved and
potential risks will not be fully eliminated. Market distortions and problems with compliance
will remain. Therefore this option should be reassessed within e.g. two years.
As proposed under option 2b the use of SCCPs in metal working and leather processing
could be banned. The use of SCCPs as plasticizer in paints, coatings and sealants and as
flame retardants in rubber, textiles and plastics could be specified as allowed use. The
selection of option 2b could be justified with possible cost implications and/or safety
standards (fire retardancy) which need to be maintained and limited environmental risks.
46
On the other hand option 2b is releated to the specific disadvantages that, if certain uses will
be allowed important releases over life-time and at disposal will remain, the general concerns
related to SCCPs would not be completely remediated and the non-quantifiable benefits
would be even more limited than with option 2a. Thus the objectives of the POPs protocol to
control, reduce or eliminate discharges, emissions and losses of SCCPs would not be
completely targeted. Market distortions and problems with compliance would remain.
Conclusion option 2b:
It can be stated that option 2b contributes less efficiently as option 2a to the objective of the
POPs protocol to control, reduce or eliminate discharges, emissions and losses of SCCPs by
eliminating use in the major source sectors for releases, whereas it provides more time to find
solutions for phase-out in less-emissive use sectors. If option 2b is selected the nonquantifiable benefits will not be fully achieved and potential risks will not be fully eliminated.
Market distortions and problems with compliance will remain. Therefore this option should be
reassessed within e.g. two years.
Conclusion option 3:
As option 3 is in fact a combination of options 1, 2a and 2b it is related to specific advantages
and disadvantages from these options. Option 3 constitutes of a principal ban of SCCP with
limited exemptions for specific uses or specific countries. It would benefit from the advantage
to meet the objective of the POP protocol to control, reduce and eliminate releases at least in
the medium to long term and it puts pressure on the search for suitable alternatives (limited
derogation) without imposing inacceptable costs and taking into consideration deficits in
applicability as well as in knowledge on environmental risks and impacts of existing
substitutes.
47
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50
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51