MEMORANDUM
TO:
CHRISTOPHER MARSHALL, ENVIRONMENT CANADA
FROM:
MIKE HARRIS, MEMBER OF THE INTERSESSIONAL WG ON POPS WASTE GUIDELINES
SUBJECT:
COMMENTS ON DRAFT POPS WASTE GUIDELINES (18 JANUARY 2004 DRAFT)
DATE:
26 MARCH 2004
CC:
PIERRE PORTAS (SBC), IBRAHIM SHAFII (SBC)
Issue Paper 1: Low POPs Content
Comments on 22 February 2004 Draft
(N.B. the draft from Canada is actually dated 22 February 2003, in error)
On behalf of the chemical industry, I submit the following comments as a member of the small
intersessional working group acting under the auspices of the Technical Working Group of the Basel
Convention. The comments relate to the draft Issue Paper 1 dated 22 February 2003 (in error) and
submitted by Canada to the Basel Secretariat on 22 February 2004.
WCC believes that this draft is a useful starting point for further discussion within the Small Intersessional
Working Group, perhaps initially in the context of a possible contact group during OEWG-3 in April 2004.
We appreciate the opportunity to make these comments and look forward to seeing a much-improved draft
after OEWG-3.
Mike Harris, for the World Chlorine Council
1.
a.
G E N E RA L C O M ME N T S
The recommendations made seem a reasonable starting point for discussion within the Small
Intersessional Working Group.
b. However, we believe that a misunderstanding may have arisen with regard to the interpretation by
Canada of the submission from Austria and would ask that Austria check the Issue Paper carefully to
make sure that the entry for PCDDs/PCDFs in the summary table in Appendix 1 does indeed reflect
their views.
The summary table states that Austria has recommended that “low POPs content” for
PCDDs/PCDFs should be defined as 0.01µg TEQ/kg for both solids and liquids. 0.01 µg TEQ/kg
corresponds to 0.01 parts per billion (ppb). This level would be met by almost any conceivable sample
from anywhere (including the whole human race) as it is well below the prevailing global background
level. Such a level would also be very hard, if not impossible, to detect even using state of the art
technology. From comments made by Austria during the contact group at OEWG-2, WCC is unsure
whether this entry in the table really represents their view. An alternative interpretation of the Austrian
submission would set the figure at 10µg TEQ/kg, i.e. 10 parts per billion (ppb). As the two
interpretations differ by a factor of one thousand it is important to be clear which is intended.
c. Referring to the reproduced text of the submission from Austria (Appendix 2) we note that it reads in
part:
“The Basel Convention lists PCDD (in Annex 1 PCDF under Y43 and PCDD under Y44). In the OECD
Decision (92)39 FINAL wastes containing PCDD/PCDF were categorised as “red list wastes”. In the rational (sic)
to this OECD Decision a limit value of 10.000 ng TE/kg was proposed as a definition of “PCDD/PCDF” waste.
Different guidelines for the use of PCDD/PCDF contaminated areas give a limit value of 10.000 ng TE/kg in soil for
industrial sites as an acceptable concentration (while for domestic areas a lower value of 1.000 ng TE/kg is fixed).
Therefore a limit value of “low POP content” of 10.000 ng TEQ/kg seems appropriate keeping in mind that this is the
limit were (sic) steps for destroying existing POPs content are required. Nevertheless there is the obligation to reduce the
amount of (unintentionally) produced PCDD/PCDF which is not depending on any limit value.”
We assume that the entry in the table is derived from this paragraph. However, we believe that there is
potential for unintended confusion because of the difference in typographical conventions between the
Continental European countries on the one hand and those countries where English is a mothertongue (e.g. the UK, the USA, Canada) on the other. In Continental Europe, the “point” (.) is used in
numbers to represent the “thousands separator” and the “comma” (,) is used as the decimal separator.
In the “English-speaking” countries the usage is exactly the reverse. This raises the question of what
Austria intends with the number “10.000 ng TEQ/kg”. Is this written in Continental European
(including Austrian) usage (despite the fact that Austria has most courteously provided its comments in
the English language) – in which case it would denote “ten thousand nanogrammes” – and should have
been typed as “10,000”? Or is it written in “English” usage – in which case it would denote “ten
nanogrammes” (but with enormous precision, as it would cite the number “ten” to three decimal places
by typing as “10.000”). We believe that it is most probable that the “Continental European” reading
(i.e. “ten thousand nanogrammes”) was intended and that the typography has survived from the
(presumed) original German into the English-language version. This would bring the Austrian
suggestion more into the range of the suggestions from other contributors, rather than being the lowest
suggestion by a factor of 100.
We have tried – and failed – to find a copy of the referenced “rationale” to the OECD Decision (92)39
FINAL in order to check the original source. If Austria has this available that would help. It is – of
course – for Austria to say what they intend. We raise the question only in the interests of clarity, to
avoid possible confusion at a later stage and because the entry in the table in Appendix 1 seems very
out of line with the other entries.
d. Appendix 2 consists of submissions from various countries and organisations and as such is, of course,
not open to comment. However, we would like to draw attention to the possible discrepancy between
the text of the Austrian submission and the PCDD/PCDF entry in the summary table in Appendix 1
(see above).
World Chlorine Council
FINAL
27 March 2004