List of undesirable substances 2000

1. Preface

The Danish EPA's discussion paper

The Danish EPA sent out its discussion paper, Status og perspektiver for kemikalieområdet. Et debatoplæg (an English-language summary entitled "Chemicals - Status and Perspectives" is available) in December 1996, 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 was, and four years later still is, to reduce the impact of substances which load the environment, so that the quality of the environment is not diminished for mankind or nature in general.

An annexe to the 1996 discussion paper contained a proposed list of substances with undesirable effects. The Danish EPA selected these substances because of their effects on health and the environment, and because of the quantities in which they are used. The LOUS was also supplemented by substances that the Danish EPA 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 in May 1997 a review of the initiatives which the Minister is contemplating in the field of chemicals.

Official list

As one of many initiatives, the review mentioned that the "List of Undesirable Substances" (LOUS) was later to be published as an official list.

For the foregoing reason, the first LOUS was published in 1998. It was also decided at that time that the task of monitoring and providing information on the most problematical substances be carried out continuously.

In the autumn of 1999, work was started on revising the "List of Undesirable Substances" according to the same methods and principles as were applied in 1996.

The 2000 edition of the new, revised, LOUS is now available. As compared to its predecessors, a number of substances or substance groups are no longer on the LOUS. The relevant substances/substance groups are discussed in greater detail in the Section entitled "Changes," together with the reasons for their removal.

Apart from the removal of certain substances/substance groups from the LOUS, new substances have been added. The names of the new substances are briefly listed in the Section entitled "Changes". A more detailed description of all substances on the LOUS can be found in the data sheets of Section 5.

It must be emphasised that the LOUS is not exhaustive, as new knowledge, changed patterns of consumption and new international initiatives are constantly emerging. This means that the LOUS must also be periodically updated in the future.

Selection of substances

The basis for selection of the substances is described in the reports "Criteria for selection of undesirable substances" (Working Report No. 71, December 1996) and "List of Effects 2000" (Environmental Review No. 6, 2000).

One important selection criterion has been the distribution/consumption pattern of a given substance in Denmark. As the point of departure, the most problematical substances in Denmark are listed on the List of Effects 2000. These substances have been systematically selected based either on their classification in the EU or on computerised assessment of their ecotoxicological properties. This list contains a total of 1404 substances. The List of Effects 2000 includes substances classified according to such effects as:
high acute and/or chronic toxicity
carcinogenicity
ability to cause heritable genetic damage
ability to impair fertility
ability to induce allergy
environmental impact.

It is possible to limit the number of substances by assigning them priority according to their consumption on the Danish market. The Danish EPA has elected to apply a limit of 100 tonnes. Note that this does not mean that smaller quantities present no difficulties. The specific use of a substance can constitute a considerable risk, even though the total quantity consumed in Denmark is limited.

If they are used industrially, dangerous chemical substances must be reported to the National Working Environment Authority. Manufacturers and importers are obliged to update this information when changes occur. Earlier studies, e.g., in connection with mass stream analyses, have shown, however, that some parties forget to update information on quantity and forget to report discontinued products for which reason, spot checks on the quantity information have been necessary when selecting the substances.

The systematic selection applied in the case of the List of Effects 2000 has certain limitations. For this reason, supplementary selection has been applied, based on the present body of knowledge of the substances' effects and dissemination in the environment. The List of Undesirable Substances is partly based on substances taken from the List of Effects 2000, which are used in quantities exceeding 100 tonnes in products and, partly, on the supplementary selection of chemicals, which also includes problematical substances that are used in goods or materials (e.g., phthalates in soft PVC). The list therefore consists of substances classified in the EU and substances that have not yet been classified.

Supplementary selection

Supplementary selection covers, e.g., substances that present problems in the marine environment, waste disposal and ground water.

In brief, the supplementary substances have been selected on the basis of one or more of the seven criteria listed below. Selection criterion No. 7 (substances considered problematical with respect to ground water) is new, as compared to the earlier list.

  1. Substances being phased out due to their environment- or health-related properties, but for which no time limits have been set in certain areas of application, as no technically and economically feasible alternatives have yet been found for these areas.
  2. Substances that are only subject to partial restrictions on use, although other uses are also considered to arouse concern for the health or environment.
  3. Substances, the use in Denmark of which is considered give cause for concern, and substances which are already regulated or for which regulation is being considered.
  4. Substances that make problematical the use of the residual products of waste streams (flue-gas cleaning products, slag, sludge and compost).
  5. Substances included on the phase-out lists of marine conferences, where there is a desire to phase out the use in products of those substances.
  6. Substances covered by political phase-out goals.
  7. Substances considered problematical with respect to ground water.

Reduced application

The fact that a substance is included on the LOUS does not signify that the Danish EPA 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 substances that have undesirable effects. Other means of restricting use include, e.g., classification and labelling, duties on particularly problematical chemicals, stricter standards, voluntary agreements on phase-out, environmental labels, green guidelines for purchasing, positive/negative lists for selected areas, subsidies for substitution initiatives, emission control and information campaigns.

Thus, the LOUS should be considered as a signal to, 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 of the LOUS, take the initiative to substitute the problematical substances themselves.

When substituting one substance for another, it is always vital to ensure that, apart from determining whether the alternative is actually usable from the technical standpoint. the substitute is less hazardous to the environment and health than the substance it replaces. Every effort should therefore be made to use alternatives, the effects of which have been studied and documented. 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.

Who can use the LOUS?

Under the right conditions the LOUS can be used by corporate product developers, 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 LOUS does, however, presume a certain level of professional expertise in environmental matters, before the user is able to assess the usability of the substances in products, the properties of any alternatives and their suitability, etc.