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The Causes of the Scientific and Regulatory Gap in the Listing of New Persistent Organic Pollutants into the Stockholm Convention Ying Wang* and Yang-Zhao Sun Foreign Economic Cooperation Office, Ministry of Environmental Protection, Beijing, 100035, China pentachlorophenol’s metabolite, pentachloroanisole, meets the criteria set out in Annex D, rather than pentachlorophenol. This means that its salt and esters, which are the source of pentachloroanisole in the environment, should be jointly considered.3 The decision on both chemicals was delayed by a year to gather new information before moving forward. The environmental risk assessment of short-chain chlorinated paraffins (SCCPs) had been reviewed six times. Although the POPRC11 decided to adopt the draft risk profiles for this chemical, members and observers expressed their concerns about the paucity of research on the chemicals in question in developing countries, in addition to the comparability of monitoring data and the POPRC11’s approach to scientific information.1 Standard rules of procedure are required to facilitate the neutral discussion, on a case-by-case basis, of scientific information obtained from invited experts and from scientific publications. Similar scientific debates happened during the Annex E review of dicofol because the quality and extent of relevant data is questionable. This means further scientific research is required in developing countries, so the decision has been delayed until the next committee meeting in 2016. The scarcity and ambiguity of scientific data regarding n 2015, the 11th meeting of the Persistent Organic potential POPs has led to inconclusive decision-making and Pollutants Review Committee (POPRC11) of the Stockunclear conclusions. holm Convention (SC) reviewed the potential listing of It was noted that “dicofol had only been proposed for listing pentadecafluorooctanoic acid (PFOA), its salts, and PFOAonce developed countries had stopped using it.”1 Interestingly, related compounds in the SC. The POPRC confirmed that there is also a timeline for phasing out PFOA, its salts and pentadecafluorooctanoic acid met the criteria of Annex D and PFOA-related compounds. The European Union has considagreed to prepare a draft risk profile pertaining to that chemical ered PFOA as a Substance of Very High Concern (SVHC) for the Annex E evaluation stage. This included consideration under Registration, Evaluation, Authorization and Restriction of of issues related to the inclusion of PFOA-related compounds Chemicals (REACH) regulations since June 2013. Canada and that potentially degrade to PFOA, and the inclusion of PFOA the US have implemented a voluntary program between salts. The main reasons why the POPRC did not reach an government and major companies in the industry alongside agreement on PFOA-related compounds were (1) on the basis regulatory efforts. They have committed to eliminate PFOA of currently available reports, data on PFOA-related comand its precursors by 2015, which was the first year that PFOA was reviewed by POPRC. Conversely, China has become one pounds is insufficient; and (2) the academic description of of the major producers and consumers of PFOA. This PFOA-related compounds is too ambiguous to make global phenomenon demonstrates the global geographical shift in regulatory efforts.1 The disagreement relates to the uneven the chemical industry toward developing countries, which development of chemical industries, technology, and legislation occurs right after actions are implemented to phase chemicals between developing and developed countries. out in developed countries. This can be explained by the The SC started initially with 12 POPs; in 2016, the meeting divergent chemical management practices in different countries. of the Conference of the Parties resulted in the inclusion of 14 Briefly, developed countries are advanced and emphasize risk new POPs into the SC. During the POPRC review process, assessment and management, while developing countries certain pollutants were discussed. For example, the inclusion of struggle with a simplified version of chemical management, dicofol as well as pentachlorophenol and its salts and esters had which focuses on safe management.4 Furthermore, small-scale both been challenged at the POP screening stage. The and scattered manufacturing centers in developing countries challenge to the former arises from the different interpretations of current scientific data, which are mainly from developed countries, and which are inconsistent with respect to its adverse Received: April 28, 2016 effects.2 The argument against the latter is due to the fact that Published: June 7, 2016
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DOI: 10.1021/acs.est.6b02120 Environ. Sci. Technol. 2016, 50, 6117−6118
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Environmental Science & Technology
(3) Report of the Persistent Organic Pollutants Review Committee on the work of its seventh meeting; UNEP/POPS/POPRC.7/19; Persistent Organic Pollutants Review Committee: Geneva, 2011; chm. pops.int/TheConvention/POPsReviewCommittee/ ReportsandDecisions/tabid/3309/ctl/Download/mid/10928/Default. aspx?id=5&ObjID=13613. (4) GCO: Global Chemicals Outlook Towards Sound Management of Chemicals; Highlights of GAO-07−713; DTI/1639/GE; United Nations Environment Programme(UNEP): Washington, DC, 2007; unep.org/chemicalsandwaste/Portals/9/Mainstreaming/GCO/ Rapport_GCO_calibri_greendot_20131211_web.pdf.
lack the motivation and capability to upgrade their technology or to use alternatives for the purposes of environmental protection rather than to improve their performance-price ratio. This means that there is more weight in executive measures and government legislation on legal guidance, which should be both clear and professional. As a mandatory international environmental agreement, the SC aimed to encourage the international phase-out or reduction in the production, use, and emission of POPs. As demonstrated above, developed countries dominated the POP review process because they have more comprehensive risk assessment data, advanced technology, significant regulatory frameworks and plenty of chemical management experience. In keeping with the precautionary approach to protect human health and the environment, in our opinion, it is welcome that developed countries share their scientific research and management experience regarding potential POPs, but we believe that decisions should not be made if they rely on data concentrated only in certain regions. This is because uneven industrial development and different chemical management systems make the situation far from satisfactory to take accordant global action. Developing countries continuously ask for technological or financial assistance, but the assistance that developed countries give usually come with “certain conditions”, such as having a well-rounded legislative system, advanced industrial technology, sufficient national monitoring capability and financial support, which therefore blocks both the negotiations regarding the listing of POPs and the implementation of the SC. Clearly, the scant, inconsistent nature of scientific data is well acknowledged by the committee. A standardized monitoring method, PBT(Persistent Bioaccumulative Toxic) screening criteria and a risk assessment methodology to increase the integrity and consistency of the published data is necessary to improve understanding. Research on the emission, transformation, and human exposure to POPs and POP-like chemicals during their production, usage, recycling and disposal is urgent. Further, the committee should take notice of the uneven circumstances of chemical industries and chemical management in developing and developed countries, and should try to use more information from developing countries, which would smooth the review process when listing new POPs.
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AUTHOR INFORMATION
Corresponding Author
*E-mail:
[email protected]. Notes
The authors declare no competing financial interest.
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REFERENCES
(1) Report of the Persistent Organic Pollutants Review Committee on the work of its eleventh meeting; UNEP/POPS/POPRC.11/10; Persistent Organic Pollutants Review Committee: Geneva, 2015; chm. pops.int/TheConvention/POPsReviewCommittee/ ReportsandDecisions/tabid/3309/ctl/Download/mid/14594/Default. aspx?id=5&ObjID=21458. (2) Report of the Persistent Organic Pollutants Review Committee on the work of its ninth meeting; UNEP/POPS/POPRC.9/13; Persistent Organic Pollutants Review Committee: Geneva, 2013; chm. pops.int/TheConvention/POPsReviewCommittee/ ReportsandDecisions/tabid/3309/ctl/Download/mid/11303/Default. aspx?id=5&ObjID=17481. 6118
DOI: 10.1021/acs.est.6b02120 Environ. Sci. Technol. 2016, 50, 6117−6118
