DDT is listed in Annex B.Short chain chlorinated parrafins (SCCPs)Draft Risk Profile for SCCPsWe are disappointed that SCCPs did not proceed to the Annex F evaluation at POPRC3. Despite the POPRC’s obligation to evaluate the SCCPs Draft Risk Profile in a scientific manner using thecriteria outlined in Annex E, a political discussion took placethat revealed the difficulties of prohibiting a currently used substance such as SCCPs. Ironically, the socio-economicelements that underlined much of theconcerns are precisely the elements, which Annex F takes up. We believe the SCCPs meet all Annex E criteria and strongly support efforts to finalize the Risk Profile and begin Annex F evaluation. See Annex 3 for more information.Annex 1. Why octaBDE needs to be listed in Annex CThe proposal for an Annex C listing of octaBDE will raise questions about the degree of BDE debromination in the environment. When debromination of BDEs was first reported, many disregarded it as an in vitro phenomenon and not relevant to environmental conditions. However, the Committee has agreed in the c-OctaBDE Risk Profile that debromination is occurring in aquatic organisms, mammals, and birds and that components of the c-OctaBDE mixture are produced in the environment by debromination of c-DecaBDE. This debromination has been found to occur in fish1, by photolysis234567, and by the action of bacteria in sewage sludge89. Recently c-DecaBDE was found to debrominate under normal environmental conditions in house dust forming three c-nonaBDE congeners and several c-OctaBDE congeners10. Furthermore, there is a sizeable body of data on the properties of c-DecaBDE that should raise concerns about its debromination to form components of c-OctaBDE including: decaBDE is present in humans1112131415, decaBDE is found in biota161718; decaBDE can be absorbed by dietary intake in carp, lake trout and rats19202122; and high concentrations in terrestrial animals suggest that decaBDE can bioaccumulate.. These studies indicate the need for the Committee to seriously take up the question of an Annex C listing for c-OctaBDE. Evaluations of this type carry various uncertainties due 2
to availability of data, however, the Convention reminds the POPRC in Article 8 para 7a that, “Lack of full scientific certainty shall not prevent the proposal from proceeding.” This statement codifies the Convention commitment to use available information in protecting public health from the harms caused by POPs.Annex 2: Forest fires are not a major source of dioxinsThe draft PeCB Risk Management Evaluation cites data from forest fire simulations in the US and concludes that forest fires could be a major source of both dioxins and PeCB.
You've reached the end of your free preview.
Want to read all 7 pages?
- Fall '16
- Jeff Miller