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LECTURE 7: OZONE-DEPLETING
SUBSTANCES
TRAINING WORKSHOP
ON ENVIRONMENTALLY
REGULATED SUBSTANCES
AGENDA
Why should we care about
ozone depleting substances?
Illegal smuggling and why it
occurs
Role of Customs officers in
preventing illegal trade in
ODS
2
IMPACTS OF OZONE LAYER DEPLETION
Human health impacts: UV radiation
Skin cancer
Eye damage and cataracts
Immune system suppression
Environmental impacts from increased UV radiation
Ecosystems
Climate change
Crop damage (e.g., rice, soy beans)
Plankton productivity 3
WHAT IS AN OZONE-DEPLETING SUBSTANCE?
Chemical substances that can react with ozone in
the stratosphere
Various hydrocarbons with chlorine, fluorine and
bromine
4
COMMON USES OF ODS
Refrigerants
Blowing agent for foams
Cleaning solvent
Propellants for aerosols
Fire extinguishers
Fumigants
Chemical synthesis feedstocks
Sterilants for health care products
Laboratory uses
5
MONTREAL PROTOCOL
International treaty ratified in 1987 to reduce and
eliminate emissions from ODS
September 2009: Montreal Protocol became first
treaty in history of the United Nations to achieve
universal ratification: 197 nations.
6
REQUIRED PHASEOUT
Phaseout:
Chloroflurocarbons (CFCs)
Hydrochlorofluorocarbons (HCFCs)
Equipment should be replaced or retrofitted to
accept new gases: can be expensive
However, as supply decreases, smuggling may
increase
7
WHY ODS SMUGGLING OCCURS
Decreasing availability of gases increases demand
Differing phaseout schedules
between developed and
developing countries
Alternative gases may cost more
Equipment containing ODS has long life:
conversion/retrofitting of equipment is costly
8
ILLEGAL SMUGGLING SCHEMES
Mislabeling the canister as a non-ODS gas Noted worldwide
Example:
R-22 (or HCFC-22, Freon): illegal to trade
R-134-a (or HCFC-134-a): non-ODS gas
R-22 is being smuggled in canisters marked R-134-a
Canisters may contain illegal mixtures of gases; for example R-22 and R-404a, but be labeled as pure legal product
Cardboard packaging may not represent gas in canister: R-134a outer package may contain R-22 canister
9
IF ONLY IT WAS ALWAYS THIS EASY…
10
Reference: WCO Illicit Trade Report 2013
R-22 mix seized by Serbian Customs: July 2013
-Wrong label
-Wrong cylinder color
-Chemical name and number don’t match
MORE COMMON-
11
Hand-held
analyzer results:
R22: 91.3%
R404A: 8.7%
Illegally labeled
as R134a
REFRIGERANT CYLINDER COLOR CODES
BENEFITS OF
PORTABLE REFRIGERANT ANALYZERS
Sampling of suspect cylinder at port
Does canister’s content match documentation?
Is canister’s content contaminated or a mixture?
If documentation and actual
contents do not match, analyze
in laboratory to verify
Will support legal actions
13
ADDITIONAL SMUGGLING SCHEMES
Mislabeling virgin gas as recovered/used/recycled gas
Virgin gas may be illegal; recycled gas may be allowed
Hiding canisters
Illegal gas canisters hidden behind non-ODS canisters
Concealing smaller canister within
larger one (double layering)
Vehicle scan useful in detection of
hidden cylinders
Equipment contains ODS:
Refrigerator compressors not purged
Equipment modified to hold excess
amounts of ODS
14
VEHICLE X-RAY SCAN
15
GIFTS / DONATIONS OF SECOND-HAND
APPLIANCES MAY CONTAIN ODS AND
DANGEROUS CHEMICALS
16
OLD REFRIGERATOR
CONTAINING R12
17
ROLE OF CUSTOMS OFFICER IN
ENFORCING ODS REGULATIONS (UNEP)
Enforce ODS licensing system
Increase awareness of importers and exporters
Detect illegal trade
Detect illegal ODS at port: on-site analysis
Report ODS legal and illegal trade to National Ozone
Unit (NOU)
Seize illegal ODS, including storage and disposal
Support enforcement agencies in legal actions
18
CUSTOMS CHECKLIST
Compare all documentation to ensure it matches
Check Customs code on entry with invoice
Verify country origin
Check that importer exists
Check that importer is licensed to import specific
material
Inspect material: packaging, size, label and shape:
should match information on paperwork
19
SOME DOCUMENTS TO CONSIDER
Invoices
Packing lists
Bills of lading
Customs documents
Import/export licenses
Does information on all documents match?
Can information be verified?
Do you see obvious mistakes, omissions?
20
CHECK FOR OBVIOUS DISCREPANCIES
Missing or inconsistent information
Misspellings of trade or company names
Check that stickers on canister have not been changed or are not covering up original markings
Incorrect HS Codes may be used to avoid detection
Check for consistency on all documentation
Check color of canister
Color-coding system is not universal, but may indicate an illegal shipment
Canisters may be repainted to misrepresent contents: determine if paint scratches off to reveal another color
21
IT MAY BE AN ILLEGAL SHIPMENT IF:
Based on previous knowledge or targeting information,
documentation indicates suspicious quantity, source
and/or destination information for the ODS
Verify that the importer and place of business actually
exist
Information on various documents does not match
Various codes (HS, UN, chemical name/formula) on
documentation do not match actual canister
22
SAFETY CONSIDERATIONS FOR
CONTAINERS AND EQUIPMENT
Do not vent ODS into the atmosphere
Do not store in a confined space
Do not store ODS in direct sunlight
Do not use open flames near ODS; watch for sparks
Do not sample ODS canisters unless you have been
trained
Do not eat, drink or smoke near ODS or ODS-
containing equipment
23
AVAILABLE ON THE WEB:
Training Manual for Customs and
Enforcement Officers (3rd edition)
(UNEP)
Enforcement Strategies for Combating
the Illegal Trade in HCFCs and Methyl
Bromide (UNEP)
Ozone Depleting Substances Smuggling
and Concealment: Case Study
Handbook (Interpol/UNEP) .
24