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U g i l e c U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

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Page 1: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

U g i l e cU g i l e c

Re-assessment under provisions of UN-ECE POPs protocol

1st meeting of TFPOP, The Hague March 2004

Page 2: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Ugilec 141

formulaC14 H10 Cl4water solubility5 µg/l (20 °C)

vapour pressure< 10 Pa (20°C)

log Kow6.03 – 6.44log BCF1.67 – 2.68 l/kg (fish)4.43 – 5.19 l/kg (mussels)

DT50atmosphere (AOPWIN)3.1 days

Cl Cl

CH3Cl

Cl

Page 3: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Ugilec 121 or 21

formulaC14 H2 Cl2water solubility< 1 µg/L (20 °C)

vapour pressure0.005 Pa (20°C)

log Kow5.85 (QSAR)

log BCF1.67 – 2.68 l/kg (fish)4.43 – 5.19 l/kg (mussels)

T/2atmosphere (AOPWIN)2.3 days

Cl Cl

CH3

Page 4: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Annex II of UN-ECE protocol on POPssubstances scheduled for restrictions on use

DDT; HCH; PCB

a)

a) The Parties agree to reassess under the Protocol by 31 December 2004 the production and use of polychlorinated terphenyls and “ugilec“

Page 5: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Regulatory Action within the EU

Directive 76/769/EEC on the approximation of the laws, regulations and adminisrative provisions of the MSs relating to restrictions on themarketing and use of certain dangerous substances and preparations

11th amendment: Council Directive 91/339/EEC

Though less dangerous to man and the environment than the PCBs it was designated to replace …

By virtue of its ecotoxcity, persistence and potential to bio-accumulate Ugilec 141 constitutes a high risk to the environment

Significant environmental contamination has already been documented in the vicinity of mining operations using this substance as a hydraulic fluid

Page 6: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Monitoring (Ugilec 141 in German river sediments)

concentrations of Ugilec and PCBs in sediments of river Saar (Germany) peaks indicate vicinity of mining operations- using Ugilec 141 as a hydraulic fluid

Page 7: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Regulatory Action within the EC

Council Directive 91/339/EEC – (continued)

In the event of a fire involving any equipment containing this substance highly toxic substances may be given off

This substances (Ugilec 121 or 21) has similar properties and behaviour and was untended for uses similar to that of Ugilec 141 …

Page 8: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Regulatory Action within the EC

As from 18 June 1994 the marketing and use of Ugilec 141 and of preparations and products containing this substance shall be prohibited.

Exception in the case (of the maintenance) of plant and machinery already in service on 18 June 1994 until such plant and machinery is disposed of

As from 18 June 1994 the placing on the secondhand market of this substance, preparations containing this substance and plant/machinery containing this substance, shall be prohibited.

The marketing and use of Ugilec 121 or Ugilec 21 and of preparations and products containing it shall be prohibited.

Page 9: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Regulatory Action within the EC (waste disposal)

Council Directive 96/59/EC on disposal of PCBs and PCTs (and Ugilec) obliges Member States to:

Compile inventories of equipment containing more than 0.005% PCBs and mixtures of PCBs, whose volume is in excess of 5 liters

Prohibit separation of PCBs for purpose of re-use Prohibit the topping up of transformers with PCBs Safely remove PCBs from transformers containing more than

0.005 % PCBs (or mixtures with PCBs) by weight Allow continued use of PCBs containing transformers only if

they are in good working order Destroy waste containing PCBs and equipment containing PCBs

as soon as possible (not later than by 2010) Develop installations for the disposal, decontamination and safe

(permanent) storage of PCBs

Page 10: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Regulatory Action within the US and Canada

U.S. Not on Toxic Substances Control Act (TSCA) Section 8b Inventory of existing industrial chemicals in commerce. Any intended industrial chemical-type use would require 90-day advance pre-manufacture notification (PMN). No other information found suggesting current or historical domestic production

CanadaNot on the list of existing substances. Intended uses would be treated as new substance, thus being subject to risk assessment and subsequent risk management measures

Page 11: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Outcome from a questionnaire in 2001

At no time commercially available in the US / Canada

Manufacture and use ceased in Europe from mid 1994 onwards (“unknown“ for Armenia and Khazakhstan)

Lacking information about extent of historical uses (and possibly ongoing uses)

phasing-out programme in place along with PCBs (EU)

subject to specific waste management system (EU)

Page 12: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

Socio-economic considerations - Alternatives

Liquid alternatives

Mineral oils, silicon oils, castor oil etc.

Dry insulating

insulating inert gases, resin castings , plastics coatings

Page 13: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

related compounds ...

Bis(p-chlorophenyl) methane (101-76-8)

intermediate for the synthesis of industrial polymers

Cl Cl

Page 14: U g i l e c Re-assessment under provisions of UN-ECE POPs protocol 1 st meeting of TFPOP, The Hague March 2004

related compounds ...

DBBT (dibromo- diphenyl methane (99688-47-8)regulated in the EU along with Ugilec 121 or 21

CH3

BrBr