List of Undesirable Substances

The DEPA's discussion The DEPA sent out its discussion paper. "Status og perspektiver for

paper kemikalieområdet. Et debatoplæg" (an English-language summary entitled "Chemicals - Status and Perspectives" is available), to provide a review of the status of actions in the field of chemicals and, in extension thereof, to prepare the way for a debate on forthcoming actions.

The overall goal of actions in the field of chemicals is to reduce the impact of substances, so that the quality of the environment is not diminished for mankind or nature in general.

An annexe to the discussion paper contained a proposed list of undesirable substances, selected by the DEPA because of their effects and the quantities in which they are marketed, and supplemented by substances that the DEPA considers problematical for other reasons.

The Minister's review After a hearing on the discussion paper and questioning in the Folketing (Danish Parliament) in January 1997, the Minister of Environment and Energy sent to the Folketing a review of the initiatives which the Minister is contemplating in the field of chemicals.

Official list As one of many initiatives the review mentions that the "List of Undesirable Substances" will be published as an official list. This official list is now available.

The substances on the List ("Listed substances") are the same as the substances on the list included in the discussion paper, however, the substances for which the only problem is their benzene content have been grouped together as a single "metasubstance". Moreover, the group of substances known as brominated flame retarders has been added, as they are within the scope of the criteria for inclusion on the List. The official list is accompanied by other information, including information on activities which have been implemented or which are being considered for the various substances/groups of substances.

It must be emphasised that the List is not exhaustive as new knowledge, changed patterns of consumption and new international initiatives are constantly emerging. This means that the List must be periodically updated. New, problematical substances will obviously appear, whereas other substances may possibly be removed from the List, either because they are no longer used or because they no longer present a problem.

Selection of substances The basis for selection of the substances is described in the Danish reports "Kriterier for udvælgelse af uønskede stoffer" (Criteria for selection of undesirable substances) (Arbejdsrapport fra Miljøstyrelsen, 71/1996) and "Effektlisten" (List of effects) (Arbejdsrapport fra Miljøstyrelsen, 1/1997).

Reduced application The fact that a substance is included on the List does not signify that the DEPA has decided to recommend prohibition of that substance. Regulations on total or partial prohibition are considered to be just one of many means of reducing the environmental loading caused by problematical substances. Other means of restricting use include, e.g., classification and labelling, taxes on particularly problematical chemicals, stricter standards, voluntary agreements on phase-out initiatives, Eco-labelling, green guidelines for purchasing, positive/negative lists for selected product areas, subsidies for substitution initiatives, emission control and information campaigns.

Thus, the List should be considered as a signal and a guideline for the manufacturers, product developers, purchasers and other players concerned with chemicals, the use of which should either be restricted or stopped in the long term. This could be achieved by the companies involved, which based on the information on the List take the initiative to substitute the problematical substances themselves.

When substituting one substance for another, it is always vital to ensure that the substitute is less hazardous to the environment and health than the substance it replaces. Every effort should therefore be made to use alternatives which have well-documented effects. It is also important to be aware of whether or not the environmental and health effects of the substitute will be of any significance to the product in which it will be used. It is also necessary to determine whether the alternative is actually usable from the technical standpoint.

The DEPA's "Effektlisten" (List of Effects) (Arbejdsrapport fra Miljøstyrelsen, 1/1997) provides an overview of the environmental and health effects of over 1,100 substances. The primary selection criterion for the inclusion of a substance on the List of Undesirable Substances is that its consumption in Denmark exceeds 100 tonnes. This means that many of the substances on the List of Effects can have effects which are just as hazardous as the effects described in the List of Undesirable Substances.

Who can use the List? Under the right conditions the List can be used by the product developers in companies, by professional purchasers when making environmentally-aware purchases and by others who are interested in how chemical substances are used in products.

The use of the List does, however, presume a certain level of professional expertise in environmental matters, if the user is to be able to assess the use of the substances in products, the properties of the alternatives and their suitability, etc.

Subdivision of the List In the List, each substance/group of substances is shown on a data sheet which contains various information fields. The content of these fields is explained below. Data sheets that concern a single substance also show the relevant CAS and EINECS numbers.

Product groups These fields state selected product groups in which the relevant substances are included and the use of which can constitute a special problem.

Reason for selection Chemical substances and products can be hazardous to human beings and the environment throughout their entire life cycle, i.e. manufacture, use and disposal. A substance could, thus, have been selected because it has undesirable properties in general and/or because it is considered to be a problematical in specific contexts, such as in the waste cycle or in the marine environment. Moreover, a substance can be selected, for instance, on the basis of a Danish political decision on phase-out.

As far as Listed substances are concerned, which were selected because of problems in the waste cycle, documentation can be found in the DEPA's discussion paper of 1997, on "Industrial waste and selected waste flows". Forthcoming activities in this field can be found in the "Waste Statement", which was presented to the Folketing by the Minister of Environment and Energy early in 1998.

If a substance has been selected on the basis of its classification, this means that it is classified on the "List of hazardous substances" because of its particularly serious effects on the health and the environment. Such effects include, e.g., high acute or chronic toxicity; carcinogenicity, toxicity to reproduction and cumulative effect; allergenic effects on the skin and respiratory system, as well as its hazardous effects in the environment.

If a substance has been selected on the basis of PC calculations, this indicates that it is considered to be especially serious from the ecotoxicological standpoint and has been identified with the aid of computerised assessment techniques (QSAR). Such substances are designated on the List as being hazardous to the aquatic environment.

Finally, some substances are selected because they are considered to contribute strongly to the greenhouse effect (cf. the UN climate convention).

Goals These fields state the DEPA's specific goals and activities for restricting the use of the relevant substance. Concerning international or regional declarations on restricting the use of specific substances, see Annexe 1 to the DEPA's discussion paper ("Status og perspektiver for kemikalieområdet"), of 1996.

Classification These fields state the danger categories and risk phrases assigned to substances on the List of Undesirable Substances.

Present regulation These fields indicate whether or not a substance is covered by regulations on restricted application or other restriction initiatives, such as voluntary phase-out agreements with the industry. Furthermore, they indicate whether or not quality criteria or limit values have been defined for soil, air or watercourses, lakes and the sea. These fields also include references to any special working-environment regulations for working with a substance. All substances are, moreover, subject to a number of general working-environment regulations (see the reading list at the end of this report). Finally, there can be references to some other form of regulation, for instance, a surcharge on a substance.

The specific regulations are shown in the reference list.

Activities For each Listed substance, the activities which have been started, or which are being contemplated, are also shown.

Substances with special The "Goals and Activities" fields of 26 of the data sheets indicate that

priorities the substances concerned are the subject of high-priority activities. The particular activities associated with these high-priority substances/groups of substances refer to the first three of the activities listed below - they are shown in the "Activities" fields on the data sheets.

Initiatives for prohibition In the case of Listed substances for which the body of knowledge is

or restriction already sufficient to justify initiatives for prohibition or restriction, a description is given of the specific initiative being contemplated for implementation. The same applies to substances for which an action plan has already been drafted or is in the process of being drafted.

The especially high-priority substances targeted by these initiatives are:

arsenic and arsenic compounds

lead and lead compounds

creosote compounds

musk xylenes (in cosmetics)

nonylphenol ethoxylates in detergents (see data sheet for alkylphenol ethoxylates)

phthalates

coal tar (in cosmetics).

Acquisition of knowledge In the case of Listed substances for which the goal is restriction, there

for phase-out initiatives is a need to acquire additional scientific knowledge to facilitate the implementation of prohibitions or restrictions. This could be a matter of knowledge pertaining to the specific use of the substances in all types of product, possible substitutes, as well as an assessment of the socio-economic consequences of such regulation, before deciding how the restriction of use can be implemented.

The especially high-priority substances for which this activity is planned are:

alkylphenols

alkylphenol ethoxylates (miscellaneous applications)

azo dyes, selected

chromium compounds

dichloromethane

formaldehyde

hydrogenated fluorocarbons (HFC)

copper compounds

organotin compounds

perfluorinated hydrocarbons

sulphur hexafluoride.

EU risk assessment in The "Activities" fields also indicate whether or not a substance has

progress been selected for submission to common risk assessment in the EU, as well as the country which has been appointed to conduct the assessment.

Some of the substances undergoing risk assessment have progressed so far into the EU process that any national initiatives must await the results of this common work within the EU.

The especially high-priority substances for which this activity is planned are:

brominated flame retarders

cadmium and cadmium compounds

chlorinated paraffins, short and medium chain

ethyl glycol

ethyl glycol acetate

nickel and nickel sulphate

perchloroethylene

1,2,4 trichlorobenzene

trichloroethylene.

Classification initiatives Certain substances are shown as already undergoing classification or as requiring assessment for classification in the future. This activity is included since a risk assessment is the first step in the final assessment of a given substance. In addition, the classification and labelling of a substance - or of the products of which it is an ingredient - will constitute vital information which purchasers and consumers can use, for instance, to reject the most hazardous chemicals.

Updating and scientific The List also covers some of the problematical coal and oil

studies derivatives, if their low-purity fractions are used. The DEPA will collaborate with the National Register of Chemical Substances and Products, Denmark and the industry to investigate the extent to which fractions containing hazardous impurities are in use today. The bodies responsible for such products will, of course, be urged to switch to purer fractions.

Paints, varnishes and adhesives belong to the product groups in which some of the undesirable substances are included. Known alternatives for a number of these substances are available and have already been taken into use by part of the industry. The activity in this case is to investigate in collaboration with the National Register of Chemical Substances and Products, Denmark and industry, e.g., the progress of substituting Listed substances with less hazardous alternatives. If the current body of knowledge is not sufficiently integrated in this activity, initiatives will be adopted to ensure that the responsible bodies carry out such substitution rapidly. Another item to be studied is the extent to which the undesirable substances constitute ingredients of products which are sold to consumers through retail outlets, including acceptable levels for the content of undesirable substances in the form of any impurities.

Finally, scientific studies intended to elucidate the environmental impact of the substances are already in progress. Any initiatives which target these substances will therefore not be started until the results of these studies are available.

Surveillance programme The "Activities" field also indicates whether or not a given substance is included in the proposal for a future national surveillance programme, with an indication of the media in which surveillance is desired.