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National Implementation Plan – Stockholm Conventionen on Persistent Organic Pollutants

2 Country baseline

• 2.1 Country profile
  • 2.1.1 Geography and population
  • 2.1.2 Political profile
  • 2.1.3 Economy and business
  • 2.1.4 The overall environmental situation in Denmark
• 2.2 Environmental-policy, legislative and institutional framework
  • 2.2.1 Environmental policy, strategy for sustainable development and legislative framework
  • 2.2.2 Roles and responsibilities of public institutions
  • 2.2.3 International commitments in relation to the POP area
  • 2.2.4 Legislation on POPs
  • 2.2.5 Central approach and procedures
• 2.3 The POP situation in Denmark
  • 2.3.1 Annex A and B substances (excl. PCBs)
  • 2.3.2 Annex B substances - DDT
  • 2.3.3 Intentional use of PCB
  • 2.3.4 Unintentional production of dioxin, HCB and PCB
  • 2.3.5 Stockkpiles, waste and contaminated sites
  • 2.3.6 Future intentional production of POPs and need for exemption
  • 2.3.7 Programmes for monitoring releases, health risks and emissions inventories
  • 2.3.8 Information to the public and exchange of information with other parties to the Convention
  • 2.3.9 Activities by non-public stakeholder organisations
  • 2.3.10 Technical infrastructure for POP assessments, measurements, analyses, research and development
  • 2.3.11 Particularly exposed population groups
  • 2.3.12 Systems for assessment and inclusion of new substances under the Convention

2.1 Country profile

2.1.1 Geography and population

Denmark covers an area of 43,093 km² and comprises the peninsula Jutland and 406 islands of which Zealand is the largest. Just under one-fifth of these islands are inhabited. The total coastline is 7,031 km. Denmark is connected to Germany with a 69 km land border. Since 1 July 2000, Denmark has also had a fixed link with Sweden via a bridge of almost 16 km across the Sound between Copenhagen and Malmø.

Denmark has 5.4 million inhabitants, which constitutes just over 1.4 per cent of the total EU population. The population density is approx. 123 pr. km². The population is relatively evenly distributed, but there is a greater concentration in the Copenhagen region with its approx. 1.7 million. Denmark has just over 3 million economically active inhabitants, while the group of young people under the age of 17 and the group of elderly people over the age of 60 both constitute just over 1 million. The average life expectancy is 79 years for women and 75 years for men.

Denmark has a temperate maritime climate. The climate is influenced by the country's proximity to large maritime areas and its position in a mild zone of western wind. This position means that, in the summer, the temperature lies around 20^oC and that the mean temperature in the winter is around freezing point. Precipitation is fairly evenly distributed over the year, but with more in the autumn months.

2.1.2 Political profile

Denmark's form of governance is parliamentary democracy with a royal head of state. The parliament, the Folketing, has the exclusive right to adopt legislation. The Folketing comprises 179 members, elected through proportional representation. 175 members are elected in Denmark, while Greenland and the Faroe Islands each elect two members. Denmark is a member of the EU, but has decided to stay out of the cooperation within a few areas. These include the common European currency, the euro, and military cooperation.

2.1.3 Economy and business

Historically, Denmark was an agricultural country, but in the past few decades, its business sector has become more complex and is now dominated by a large, export-oriented industry and a well-developed service sector.

The number of agricultural establishments has fallen steadily, and in 2002, it was down to 50,500 farm units. This sector now represents less than 5 per cent of the total value added in society and employs less than 4 per cent of the employed population. Despite this, agriculture represented approx. 11 per cent of Denmark's total exports in 2004.

Industry represents about 16 per cent of Denmark's annual value added, as much as 75 per cent of exports (2004), and just over 15 per cent of the employed population. Some of the most important product and service areas are foodstuffs, furniture and clothes, design and interior design, maritime transport, wind turbines, pharmaceuticals and medical devices, equipment for automatic cooling and heating, sensitive measuring equipment, and IT and communication.

Business in Denmark is characterised by many small and medium-sized enterprises, and workplaces with 1-19 employees constitute more than 90 per cent of the total.

Table 2.1
The economic sectors' gross value added*, employment and distribution of enterprises by size

*Gross value added is calculated as the value of production less the value of consumption in production. This corresponds to gross domestic product (GDP) less (product taxes less product subsidies).

Source: Statistics Denmark: Denmark in Figures 2005 (column 1), Statistical Yearbook 2005 (column 2) and DS figures from the end of November 2001 reproduced in the Ministry of Science, Technology, and Innovation: www.workindk.dk/Virksomheder (columns 3-6).

2.1.4 The overall environmental situation in Denmark

The overall environmental situation in Denmark is subject to a number of special characteristics. Denmark has a high population density and high economic activity. Forests and natural areas only constitute about 10 per cent of the territory, and Denmark is an island nation surrounded by sensitive shallow-water marine areas. Thus, the environment's capacity for taking up pollutants is relatively small, and a reduction of discharges has been on the political agenda for many years.

Through extensive regulation and close cooperation between the different social players, Denmark has come a long way in the last fifty years toward solving a number of environmental problems. For example, this has been done through cleaning of wastewater, putting filters in chimneys, banning the use of the most hazardous chemical substances, protecting natural areas, using less fertilizer and less toxic pesticides in agriculture, and introducing environmental labels and other initiatives to support organic and other environmentally friendly production and consumption. Now that the problems linked to discharges of hazardous substances from large point sources have generally been solved, focus has shifted to the environmental problems linked to modern lifestyle and industrialised agriculture.

Denmark is among the countries in the world with the highest consumption of goods, resources and energy per capita. The agricultural area constitutes about 65 per cent of the total area. Although discharges of nutrients from agriculture have been reduced considerably in recent years through targeted initiatives, many water bodies still receive too large additions of nutrients. Through increased consumption of consumer goods produced throughout the world, people are subjected to a large amount of chemical substances, despite the improvements achieved through bans of the most problematic substances.

Increasing traffic causes pollution with particles and noise, and the high consumption of fossil fuels entails that Denmark has relatively high emissions of greenhouse gases per capita despite intensive promotion of renewable energy sources. A high degree of wealth and a modern lifestyle result in increased resource consumption, and this constitutes a challenge as regards waste and derived environmental effects.

A decoupling of the increases in resource consumption, energy consumption and waste generation from economic growth is an environmental policy priority, and particularly in the energy area, the link between growth and pollution has been successfully decoupled. Decoupling will continue to be one of the major priorities in environmental policy.

2.2 Environmental-policy, legislative and institutional framework

2.2.1 Environmental policy, strategy for sustainable development and legislative framework

The starting point of Denmark's environmental policy is that the country should be a society where economic progress can go hand in hand with social development and an improved environment. The objective is for Denmark to develop in a sustainable direction, e.g. through better integration between the environment and other social sectors, improved resource efficiency, making businesses and consumers take responsibility, and through support of local Agenda 21 initiatives.

Denmark's strategy for sustainable development should therefore also be seen as the country's response to the challenge of Agenda 21, which was adopted at the UN General Assembly in Rio in 1992, to prepare national strategies for sustainable development. The Danish vision of sustainable development is based on eight targets and principles:

• The welfare society must be developed and economic growth must be decoupled from environmental impacts;
• There must be a safe and healthy environment for everyone, and we must maintain a high level of protection;
• We must secure a high degree of biodiversity and protect the ecosystems;
• Resources must be used more efficiently;
• We must take action at the international level;
• Environmental considerations must be taken into account in all sectors;
• The market must support sustainable development;
• Sustainable development is a shared responsibility and we must measure progress.

The strategy is built up around a number of sectors: foodstuff production, forestry, industry, transport, energy, urban and housing development in addition to intersectoral action: climate change, biodiversity, environment and health, resources and resource efficiency, knowledge and policies and measures, the global dimension and public participation. Chemicals initiatives are placed under environment and health, and the overall objectives are the generation goal in the Nordic strategy on sustainable development which states that emissions of chemicals that pose a threat to the environment and health are to cease within a generation, and that no products or goods on the market in 2020 may contain chemicals that have highly problematic effects on health or the environment. These objectives have subsequently been supplemented by the chemicals objective from the World Summit in Johannesburg that in 2020 chemicals must be used and produced in ways that lead to the minimization of significant adverse effects on human health and the environment.

Chemicals action plan

Through the 1980s and 1990s, Denmark enhanced its efforts within the chemicals area. The purpose is to reduce the environmental and health risks connected to the use of chemicals. Primarily, this is done through strong international cooperation, separate Danish regulation, control sanctions, and by providing the public, enterprises and agriculture with greater knowledge of chemicals.

In the autumn of 2005, the government presented the latest chemicals action plan ”Styr på kemikalier - Regeringens handlingsplan for en styrket kemikalieindsats 2006 - 2009” (control the chemicals – the Government's action plan for enhanced efforts to control chemicals 2006-2009).

Specifically, the Danish efforts within the chemicals area today include the following initiatives:

The government has decided to prioritise its efforts for particularly three areas in the period 2006- 2009. Focus on these areas together will ensure that Danes and the Danish environment are better protected: (i) more control, (ii) greater focus on products for consumers and (iii) better communication with enterprises.

The chemicals action plan is supplemented by the government's Waste Strategy 2005-2008.

Waste Strategy 2005-2008

In 2003, the government published its Waste Strategy 2005-2008 as an important element of its overall strategy for sustainable development. The Strategy has three purposes: to describe the government's waste policy until 2008, to outline the framework for municipalities' local waste planes and their implementation, and to draw up a national waste plan in accordance with EU obligations in the area.

According to the Strategy, efforts are to be made to prevent the loss of resources and environmental impacts from waste. Moreover, growth in waste must be decoupled from economic growth, and improved cost-effectiveness of environmental policies must be ensured.

The Waste Strategy is one strategic element that works in synergy with the Government's other environment policy strategies, inlcuding (i) the chemicals strategy - important for efforts to reduce the levels of contaminants in waste, (ii) the product-oriented environment strategy - with respect to the prevention of waste, (iii) the "Environment and health are closely related" strategy, and (iv) ”Making Markets Work for Environmental Policies - Achieving Cost-effective Solutions”.

2.2.2 Roles and responsibilities of public institutions

Below is a description of the public institutions involved in the activities related to the implementation plan in various ways.

The Folketing

The Folketing – the Danish parliament - adopts bills and resolutions, and it is the task of the Folketing to check the government's administration and policy by means of notifications to the standing committees, questions to the ministers, or consultations.

The Folketing's Environment and Regional Planning Committee is one of many committees of the Folketing whose work is primarily linked to processing of bills and resolutions and parliamentary checks and balances of the government. The areas of the Environment and Regional Planning Committee include environmental protection, nature conservation, forestry and spatial planning as well as gene technology, hunting, game administration, acquisitions for recreational activities, listing of procetced nature areas, raw materials in the soil and seabed, etc.

Ministry of the Environment

The Ministry of the Environment takes care of administration and operation tasks within spatial planning, environmental protection, environment-related health protection, nature and forest administration, surveying and mapping. Largely, these tasks are carried out by a number of agencies and institutes. Moreover, the Ministry carries out a number of studies and sector research tasks within environment and nature, forests and landscapes and geology. The Ministry prepares environmental strategies for a number of areas.

The Department, including the Minister’s secretariat services the Minister and attends to political and strategic functions. It also has a co-ordinating role regarding the EU and the horizontal international level, including UNEP and CSD.

The Danish Environmental Protection Agency (the Danish EPA) manages environmental legislation, prepares draft legislation, policies and strategies, engages in EU and international negotiations and advises the Minister for the Environment. The Danish EPA handles the state tasks for which the Minister for the Environment is responsible within the following areas: environmental impacts on water, air and soil and on human health. It collates and processes knowledge about the development of the environment and about connections between environmental impacts and environmental effects. Moreover, the Danish EPA is responsible for summarising and assessing research and monitoring results as well as environment inspection and control results, etc. The Danish EPA initiates studies and research projects within the environment area, participates in international cooperation on environmental protection, and manages environmental subsidy schemes for the EU's new neighbours and for the Arctic area.

The Danish EPA is the authority responsible for approval of pesticides and control and supervision of compliance with the Act on Chemical Substances and the Statutory Order on Pesticides. The Danish EPA Chemical Inspection Service is thus responsible for supervision and control of compliance with the regulations in the Act on Chemical Substances which, amongst other things, bans marketing or use of the POP pesticides covered by the Stockholm Convention. The Danish EPA is also responsible for supervising and enforcing compliance with the regulations in the Statutory Order on PCBs.

The Danish Forest and Nature Agency manages nature legislation, prepares draft legislation, policies and strategies, engages in EU and international negotiations and advises the Minister for the Environment. The Danish Forest and Nature Agency handles the state tasks for which the Minister for the Environment is responsible within the following areas: nature conservation and nature management, national planning, environmental conditions of agriculture, forestry, hunting and game administration, gene technology, outdoor recreation, raw materials management as well as environmental assessments and local Agenda 21.

The National Environmental Research Institute of Denmark (NERI) is a sector research institution under the Ministry of the Environment. NERI's tasks include preparing and strengthening the scientific basis for environmental policy priorities and decisions, carrying out data collection, consultancy and communication, and developing tools and methods to ensure coherent and consistent prioritisation.

Since 2000, NERI has been working with the Danish EPA on a number of studies of emissions from known dioxin sources and on estimating the extent of dioxin pollution in Denmark in general. Further to this, it is the responsibility of NERI to prepare official Danish annual inventories of emissions into the atmosphere and report the total dioxin emissions to the EU and UNECE. NERI monitors pollutants in the Arctic environment, e.g. in connection with the Arctic Monitoring and Assessment Programme (AMAP) and participates in the monitoring of conditions for nature and the environment in Danish fjords and marine areas in cooperation with the regional authorities.

The Centre for Corporate Management is the Ministry of the Environment's administrative centre responsible for the Ministry's tasks as regards personnel, organisation, financial administration, IT services, practical information and building services.

The Geological Survey of Denmark and Greenland (GEUS) is an independent sector research institute under the Ministry of the Environment. GEUS carries out scientific tasks in connection with parts of the legislation managed by the Ministry of the Environment, e.g. within water supply, raw materials, hydrocarbon resources and subsurface areas. Moreover, GEUS participates in national and international research programmes and carries out environment and energy tasks on contract terms. In relation to POPs, GEUS has been involved in a number of studies of POPs in ice cores from Greenland.

Ministry of Food, Agriculture and Fisheries

One of the main objectives of the Ministry is to ensure that the foodstuffs produced and sold to consumers are healthy and of high quality, and to ensure that the level of information on foodstuffs is high. The Ministry carries out planning and development tasks as well as regulatory, administrative and control functions. It has tasks related to the EU cooperation and other international relations significant to the agriculture, fisheries and foodstuff sectors. For example, the Ministry is involved in an initiative to enhance efforts to reduce human exposure to dioxin in cooperation with the Ministry of the Environment and the Ministry of Family and Consumer Affairs. This cooperation includes the Dioxin Action Plan aimed at both foodstuffs and animal feed.

Ministry of Family and Consumer Affairs

The Ministry takes care of the interests of families in a broad sense, including consumer protection and food safety, as well as nutrition, livestock diseases and food inspection. As mentioned above, the Ministry of Family and Consumer Affairs cooperates with the Ministry of the Environment and the Ministry of Food, Agriculture and Fisheries to reduce human exposure to dioxin. The Danish Veterinary and Food Administration under the Ministry is responsible for development, coordination and drawing up regulations within the veterinary and foodstuff areas and carries out food inspection and supervision of veterinary matters. The Danish Veterinary and Food Administration is also responsible for measuring dioxin in breast milk.

Ministry of Employment

The Ministry of Employment is responsible for worker protection and is managing a Product Register of chemical products used professionally in Denmark. The Danish Working Environment Authority and the Danish EPA are using the Register to get information about which chemical substances are being used in Denmark.

The Product Register contains information about approx. 38,000 chemical products and approx. 140,000 chemical substances. The Product Register contains information about the content of chemical substances in chemical products used professionally in Denmark. The Danish Working Environment Authority and the Danish EPA use the data to achieve an overview of the use of chemicals in Denmark. The legislative background for the Register is the Ministry of Labour Executive Order no. 466 of 14 September 1981 and Executive Order no. 559 of 4 July 2002 on Special Duties of Manufacturers, Suppliers and Importers, etc. of Substances and Materials pursuant to the Danish Working Environment Act with subsequent amendments.

The Product Register was established in 1979. The Register contains information about chemical products reported by Danish and foreign enterprises. The Register contains information about the products' trade name, composition, danger labelling, use (where they are used and what they are used for) and imported/produced amounts.

Enterprises that produce, import or change trade names of chemical products used for commercial purposes are required to report these products to the Product Register.

Municipalities

Today, Denmark is divided into 271 municipalities. From 1 January 2007, the municipal structure will be changed to 98 larger municipalities. The main service areas are social services, childcare, schools, after-school services, services for the elderly. Within the waste area, the municipalities are responsible for management of all waste generated in the municipality. The municipalities are required to establish schemes ensuring that the waste generated within the municipality is managed in an environmentally acceptable way. The schemes may be either assignment or collection schemes. Moreover, municipalities are required to draw up waste plans and regulations on the scope and operation etc. of waste schemes. They also have a number of supervisory tasks as regards waste. Municipalities are also responsible for operation of incineration plants, often through inter-municipality waste enterprises. The new large municipalities will take over most of the nature and environment as well as spatial planning task currently under the counties.

Counties

Today, Denmark is divided into 13 counties. Three municipalities – Copenhagen and Frederiksberg as well as the Bornholm Regional Municipality – function as both counties and municipalities. From 1 January 2007, the county structure will be replaced by five new regions.

In addition to a number of other areas, the counties have a number of areas within nature and environmental protection until the restructuring. These areas include supervision of heavily polluting enterprises, water quality control, mapping and clean-up of contaminated sites, planning of water abstraction and mineral resources exploitation as well as nature conservation. The counties also prepare regional plans for spatial planning. The counties participate in monitoring of nature and environment conditions in Danish fjords and marine areas.

Regions

After the restructuring, most environmental tasks will lie with either municipalities or the state. Within nature and the environment, the new regions will have a right of consultation and an opportunity to give input to state planning proposals. The regions will also have a coordination role and a mediating function in relation to the municipalities. The regions will also be responsible for some of the tasks relating to mineral resources exploitation and soil contamination

2.2.3 International commitments in relation to the POP area

Besides the Stockholm Convention, Denmark also has a number of other international commitments on POPs through participation in international or regional environmental conventions and cooperation. Denmark is also subject to EU regulation where the agreements have been implemented into EU legislation. These are reviewed below.

UNECE’s POP Protocol

This Convention covers the countries of the UN Europe region. Denmark ratified the POP Protocol in 2001.

Basel Convention

Global convention. Denmark ratified the Basel Convention in 1994.

Rotterdam Convention

Global convention. Denmark ratified the Rotterdam Convention in 2004.

Helsinki Convention and HELCOM

The Convention covers the Baltic Sea, Øresund (the Sound), the Little Belt and the Great Belt as well as the Skagerrak up to a line from the Skaw to Gothenburg. Besides the EU, all countries bordering on the Baltic Sea, including Denmark, have acceded to the Convention. The Helsinki Commission, referred to as HELCOM is the governing body for the work under the Convention. Denmark has ratified both the original Convention and the updated 1992 Convention.

OSPAR

The 1992 Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR) forms the framework for international cooperation on the protection of the marine environment of the North-East Atlantic. Denmark ratified the Convention in 1995.

Nordic Council of Ministers

Under the auspices of the Nordic Council of Ministers, Denmark cooperates with the other Nordic countries on problems related to POPs. The cooperation of the Nordic environment ministers builds on four-year environment action programmes. Amongst other things, the Environmental Action Plan 2005-2008 contains initiatives in relation to POPs in the joint follow-up to international conventions on hazardous substances, including POPs and work on initiatives to strengthen the Stockholm Convention and the POP Protocol as preparation of dispersion models for heavy metals and POPs.

Strategy for sustainable development in the Nordic countries

In 1998, the Nordic prime ministers commissioned the Nordic Council of Ministers to prepare a cross-sectoral-based sustainable development strategy for the Nordic countries and their neighbouring areas. This work resulted in the strategy ”Sustainable Development - New Bearings For Nordic Countries” which entered into force at the beginning of 2001. The strategy focuses on the areas where joint Nordic efforts to implement sustainable development have high priority. These include climate, biodiversity and genetic resources, the sea, chemicals and food safety.

In accordance with the strategy, the Nordic countries will contribute to effective international implementation of the global conventions: the Montreal Protocol, the PIC Convention, the Stockholm Convention and the international agreement on the use of TBT on ships. The Nordic countries will also work to get more substances with undesirable properties covered by these conventions.

According to AEPS the Arctic countries agree to inter alia to carry our measures to reduce or control the use of chlordane, DDT, toxapen and PCB. These substances are now covered by the Stockholm Convention.

AEPS and the Arctic Council

In 1991, Denmark joined the international Arctic Environmental Protection Strategy (AEPS) which forms the basis for the national Danish environmental efforts in the Arctic. The Arctic Council was formed in 1996 as an inter-state forum consisting of the eight Arctic states' governments and seven indigenous peoples. The Council works with cases of a common interest for countries and peoples in the Arctic.

According to the AEPS, the Arctic countries undertake to introduce measures to reduce or control the use of chlordane, DDT, toxaphene and PCB. The agreement between the countries regarding these substances has subsequently been covered and specified in the Stockholm Convention.

2.2.4 Legislation on POPs

Close interplay between EU legislation and national regulation

Regulation of POPs and POP waste in the Stockholm Convention is characterised by a close interplay between EU and national regulation. The majority of the Danish regulations for POPs are a consequence of EU legislation.

The Stockholm Convention has been implemented in the EU in Regulation (EC) no. 850/2004 on persistent organic pollutants (the POP Regulation). The Regulation applied immediately as a Regulation automatically becomes part of Danish law.

The Regulation implements the most important provisions of the Stockholm Convention and the UNECE Protocol on Persistent Organic Substances by banning manufacture, use and marketing of the substances on the annexes. In order to achieve a high level of protection for health and the environment, the Regulation has not made use of the possibilities allowed for in international agreements to continue, to a limited extent, manufacturing, placing on the market and using some of the substances on the list.

The requirements of the Regulation on identification and characterisation of releases, and on preparation and implementation of national action plans are more specific on some points than those stipulated in the Convention.

Besides the provisions on control measures, the Regulation also includes general obligations, which build on the provisions of the Convention and the Protocol. Finally, the Regulation contains provisions on stockpiles and waste which are stricter that the provisions of the Convention.

The POP Regulation is supplemented by Regulation (EC) no. 304/2003 of the European Parliament and of the Council of 28 January 2003 on export and import of dangerous chemicals (the PIC Regulation) and Council Regulation no. 259/93 of 1 February 1993 on supervision and control of shipments of waste within, into, and out of the European Community (the Transport Regulation). This is described in more detail below under waste management.

The POP Regulation is further supplemented by the Danish Environmental Protection Act and the Danish Chemicals Act, as well as a number of statutory orders issued pursuant to these. Moreover, there are EU regulations for dioxins and PCBs in animal feed and foodstuffs.

The following briefly describes the current Danish legislation for POPs and POP waste, including bans on placing on the market and use, as well as approval schemes for pesticides and requirements on supervision and enforcement of the rules.

The ten POPs for intentional use

Marketing and use of the ten pesticides and industrial chemicals has been banned in Denmark for several years. Table 2.2 lists when the bans on the ten substances took effect in Denmark.

The bans in the POP Regulation are supplemented by the Chemicals Act^[2], the Statutory Order on Pesticides^[3] and the Statutory Order on POPs.^[4]

PCB

• PCB is regulated in accordance with the Danish Environmental Protection Act and the Chemicals Act, including the Statutory Order on PCBs.^[5]
• In 1977 ”open” use was banned in Denmark, i.e. in paint, fillers, self-copying paper etc.
• Sales and imports of PCB as well as equipment or chemical products containing PCB have been banned in Denmark since 31 October 1986.^[6] Existing apparatus containing PCB could still, however, be used for a transition period up to 1995 for the largest and most important types of equipment. Since 1 January 1995, use of PCB-containing capacitors and transformers above a certain weight (total weight > 1 kg or output > 2 kW) has been banned.
• It has been permitted to use equipment containing small amounts of PCB, primarily small capacitors, for the rest of the equipment’s useful life. The most recent statutory order of December 1998, which implements the EU PCB/PCT Directive, introduces supplementary requirements for larger equipment containing PCB, including transformers with a concentration of PCB of more than 0.05 percent by weight, to be disposed of or decontaminated as soon as possible, and before 1 January 2000, irrespective of whether or not it is in use.
• The Statutory order on PCB contains stricter regulations than those in the Stockholm Convention and the EU PCB Directive (96/59/EC) with regard to the date for decontamination and/or disposal. In the Stockholm Convention, decontamination and/or disposal must be no later than 2028 and in the Directive no later than 2010. Small capacitors and transformers may be used until the end of their useful economic life.

Supervision and enforcement is carried out by the Danish EPA with regard to the regulations in the Statutory Order on PCB on sale, import, use, maintenance, storage and labelling of PCB and apparatus containing PCB, as well as regarding compliance with regulations on reporting information.

The nine banned substances

The Chemicals Act bans placing on the market or use of aldrin, chlordane, dieldrin, DDT, endrin, heptachlor, hexachlorobenzene (HCB), mirex, and toxaphene in pesticides or groups of these (cf. annex 2, list B in the Act).

Other sale, import and use of aldrin, chlordane, dieldrin, DDT, endrin, heptachlor, hexachlorobenzene (HCB), mirex, and toxaphene are banned under the Statutory Order on POPs.

The Danish EPA Chemical Inspection Service supervises and checks compliance with the rules.

Approval scheme and reassessment of existing chemicals for POP properties

Approval of pesticides is laid down in the Chemicals Act (part 7) and the Statutory Order on pesticides^[7] (part 2). The Danish EPA is the competent authority for approval of pesticides and supervision of compliance with the Act and the Statutory Order. Danish legislation implements Directive 91/414/EC on plant protection products and Directive 98/8/EC on biocides.

A plant protection product must not be imported, sold or used in Denmark, unless the product has been approved by the Danish EPA. Applications for approvals of plant protection products are submitted on a special form to the Danish EPA by the person wishing to import or market a plant protection product in Denmark. The application should be accompanied by all the information necessary for a complete assessment of the active substance and the product. More detailed regulations on the content of applications are in the Statutory Order on pesticides.

Reduction of releases of unintentionally formed POPs

With regard to POPs arising unintentionally, a number of instruments in EU legislation and in Danish environmental protection legislation will help reduce releases of these substances. The most important measures to limit releases are in Directive 96/61/EC (the Directive on ”Integrated Pollution Prevention and Control” - IPPC), which covers the largest stationary sources of POPs formed unintentionally. The IPPC Directive has been implemented via the Danish Environmental Protection Act and the Approval Order.

The Danish Environmental Protection Act is based on the fundamental principle that overall pollution of the surroundings should be prevented or limited as much as possible. On this basis, the Environmental Protection Act requires individual enterprises to use the best available techniques (BAT), so that overall pollution is a little as possible.

The regulations on incineration of waste in the Statutory Order on Waste and in the Statutory Order on installations which incinerate waste^[8] cover a very important source of unintentionally formed POPs. The Statutory Order on Waste states that incineration of waste is permitted in plants approved for the purpose. This provision links with the regulation in the Statutory Order on installations which incinerate waste concerning design and operation of incineration plants and combined incineration plants, including limit values for air emissions. The current emission limit value for air emissions from incineration plants and combined incineration plants is 0.1 ng I-TEQ/Nm³.

The Statutory Order on management of waste in the form of motor vehicles and derived waste fractions^[9] requires dangerous components to be removed from vehicles before the chassis is dismantled, and appropriate disposal of shredder waste. This requirement helps reduce emissions of POPs from car-breakers.

Finally, the WEEE Statutory Order requires that components containing PCB in scrap electrical and electronic equipment must be removed from the products and destroyed.

The Commission Decision 2000/479/EC introduces a European Pollutant Emission Register (EPER), which is a register of the most important emissions and sources of pollution. It covers all unintentionally formed POPs, except PCB. The list of registered pollutants will be extended in 2007, partly as a result of the Stockholm Convention, and also because PCB will be included in the list. In future the list will also include inventories of emissions from diffuse sources.

Stockpiles

Management of stockpiles before they become waste, is covered by the current chemicals legislation.

Management of POP waste

Many of the provisions on waste management in the Convention are already in the Statutory Order on Waste and the “bekendtgørelser for særlige fraktioner af affald” (statutory order on special waste fractions), which implement EU waste legislation.

Municipalities are responsible for all waste collection and management, cf. section 45(1)-(3) of the Environmental Protection Act. Therefore the local council has an obligation to assign waste disposal facilities, undertake collection and disposal of waste, and to prepare waste plans and regulations on the scope and organisation of waste schemes etc.

Waste containing PCB and any other POP waste is hazardous waste. The management requirements are laid down in part 9 of the Statutory Order on Waste. The provision in section 54 of the Statutory Order on Waste (no. 619 of 27 June 2000 with subsequent amendments) applies for apparatus containing PCB, and this states that the local council must establish collection-at-source schemes for hazardous waste, including waste containing PCB and any other POP waste.

Besides the general provisions on collection of hazardous waste, electrical and electronic products must also be collected separately and capacitors containing PCB and oil must be taken out. This waste must be delivered to enterprises approved under part 5 of the Environmental Protection Act to dispose of hazardous waste, and which at all times must comply with the relevant regulations on disposal of PBC. This regulation is included in a new Statutory Order no. 664 of 27 June 2005 on management of waste electrical and electronic equipment (the WEEE Order), which also introduces producer liability.

The Statutory Order on Waste stipulates (section 58a), that waste containing the substances aldrin, chlordane, dieldrin, DDT, endrin, heptachlor, hexachlorobenzene, mirex, toxaphene, polychlorinated dibenzo-p-dioxin and polychlorinated dibenzofuranes must be disposed of in such as way that they no longer possess the properties of POPs. If technically possible, the local council may, however, allow the waste to be disposed of in some other environmentally appropriate manner.

Furthermore, after application, the Danish EPA can allow the waste to be managed in another environmentally appropriate manner, provided there is a low content of POPs.

Transboundary transport of waste is dealt with in the Council Regulation (EEC) no. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. This regulation is the most important instrument for implementation of the Basel Convention in Community legislation. Wastes consisting of, containing or contaminated with POPs are also covered by the Regulation.

Today, shipment of this type of waste within the EU is covered by a procedure based on advance written notification and written consent. With regard to exports from the Community, the Regulation stipulates that exports for disposal are completely banned, while exports for recovery are only permitted, if treatment is in an OECD country. Imports into the Community are permitted, provided they are from EFTA countries or countries which are parties to the Basel Convention, or – if the waste is for recovery – from other OECD countries.

The Regulation has been under revision. There is political agreement to the proposal, and final adoption by the Council of the European Union is expected before July 2006. The proposal states that shipments of waste consisting of, containing or contaminated with substances listed in the Stockholm Convention are covered by the same provisions as shipments of waste for disposal. In reality this will mean that shipments within the Community are still covered by the requirement for written notification and written consent, and that all exports from the Community are banned. With regard to imports into the Community, these will only be permitted if they are from EFTA countries or countries which are party to the Basel Convention. Adoption of the POP Regulation in 2004 did not set common EU levels for concentrations of POPs in waste. The Commission forwarded three proposals for amendments to annex IV (list of substances covered by the provisions on waste management in article 7) and annex V (waste management) for vote by the Technical Adaption Committee (TAP) on 25 January 2006, but the three proposals were not adopted by the TAP. Therefore, the Commission must submit the matter to the Council of the European Union.

Regulations for dioxins and dioxin-like PCBs in foodstuffs

EU limit values (maximum levels) for the dioxin content in foodstuffs have been set. These appear in the Commission Regulation (EC) No. 466/2001 of 8 March 2001 setting maximum levels for certain contaminants in foodstuffs, most recently amended by the Commission Regulation (EC) No. 199/2006 of 3 February 2006.

Besides maximum levels for dioxins, Regulation 199/2006 introduces maximum levels for the sum of dioxins and dioxin-like PCBs, and action levels for dioxin-like PCBs in addition to the existing values for dioxins. The regulations enter into force on 4 November 2006.

Because of the high dioxin content in the Baltic Sea, Denmark has introduced limits for fishing and sales of certain fish species from the Baltic Sea.

The new maximum levels and action levels are compared with levels found in Danish foodstuffs in section 4.3.4.

Requirements for sampling and analysis methods are laid down in the Commission Directive 2002/69, which was implemented by Denmark in Statutory Order no. 194 of 21 March 2005 on certain contaminants in foodstuffs.

Regulations for dioxins and dioxin-like PCBs in animal feed

In parallel with the amendments to the regulations on foodstuffs (Regulation 199/2006), the regulations for dioxin and dioxin-like PCBs in animal feed were also amended. The limit values for dioxins are unchanged. The Directive^[10] introduces maximum values for the sum of dioxins and dioxin-like PCBs (total TEQ). A new aspect is the introduction of maximum values for dioxins and total TEQ in trace substances (additives category microminerals) and mixtures. Furthermore, the Directive contains action levels for dioxins and dioxin-like PCBs. The amendments have not yet been implemented in Danish legislation.

2.2.5 Central approach and procedures

The central approach and procedures to ensure enforcement of the relevant legislation for POPs are as follows:

• System for approval of pesticides;
• System for environmental approval of listed activities;
• System for registration of chemical products and their constituents placed on the market;
• Registration and approval system for waste treatment enterprises;
• Registration system to follow waste from enterprises and municipalities from door to grave.

2.3 The POP situation in Denmark

2.3.1 Annex A and B substances (excl. PCBs)

Neither DDT nor the other pesticides covered by the Stockholm Convention: aldrin, chlordane, dieldrin, endrin, heptachlor, mirex and toxaphene, are used in Denmark. Therefore all annex A and annex B pesticides are described together.

As far as is known only five of the nine POP pesticides have ever been used as pesticides (insecticides) in Denmark. These are DDT, aldrin, dieldrin, endrin and heptachlor. Of these, only DDT and dieldrin have been extensively used, while the others have only been sold in small amounts and left the market in 1963 (aldrin, endrin) and 1972 (heptachlor). Therefore, the following only describes the two first substances in detail.

Years for entry into force of regulation of the banned POPs in Denmark appear in table 2.2. The two most important instruments are the Statutory Order on Pesticides (No. 208 of 26 March 1992) and the Statutory Order on POPs (No. 820 of 29 Sept. 2003).

Table 2.2
Regulation of annex A and B substances in Denmark

* ”Total ban” means a ban on import, sale and use except for unintentional trace contaminations and use as reference material at laboratory level cf. Statutory Order no. 820 of 29 September 2003.

DDT

Sales of DDT on the Danish market were first recorded in 1956, and as far as is known this was also the first year sales of pesticides were officially recorded in Denmark. In 1956 consumption was already 39 tonnes active substance. Therefore there is reason to believe that at that time the substance had already been in use for some years. DDT was used for several pesticide purposes up to the final ban in 1984. Over the 27 years the substance was on the market, a total of 530 tonnes was sold, calculated as active substance. The highest consumption in a single year was 43 tonnes in 1959, but in general between 1956-1969 annual consumption was 35-40 tonnes active substance.

Up to and including 1969, DDT was used as an insecticide on agricultural crops, primarily on cruciferous crops such as oil seed rape and mustard. Direct agricultural use was banned from and including 1970, and consumption fell as a result to an annual average of about 1,100 kg in the period from 1970 to when the final ban entered into force in 1984.

From 1970-1983 DDT could be used for indoor treatment of young conifers, but the substance was also contained in an insecticide for furniture and woodwork.

Dieldrin

Dieldrin also first appears in Danish statistics from 1956, but only with consumption of 179 kg active substance. Over a few years consumption rose somewhat and the average annual sales for the 29 years the substance was on the market in Denmark were 863 kg. Dieldrin was banned in Denmark in 1988.

Dieldrin has never been used for agricultural purposes in the open countryside in Denmark. The substance has had two main uses, partly as a coating against insects, but only in places where it would not come into contact with foodstuffs, and partly (like DDT) against pests in wood. However, the substance could not be used in premises for production or storage of foodstuffs, cereals or animal feed and not in stables, hen houses and similar.

Industrial use of HCB

From 15 October 2003, import, sale and use of HCB and chemical products and other goods containing HCB has been banned. However, the ban does not apply when the substance is used as a reference material or in research at laboratory level. On the basis of information that consumption in Denmark for laboratory purposes was 100 kg HCB in 1992, a study at screening level in 1995 estimated that the total annual emissions from intentional use would only be around 20 kg. It is unlikely that the substance is used intentionally in Denmark.

Industrial use of mirex

Mirex has been used internationally as a flame retardant in plastics etc. Just as for HCB, import, use and sale of mirex has been banned since 15 October 2003. The substance is not recorded in the Product Register and it is unlikely that the substance is used intentionally in Denmark.

POP pesticides in foodstuffs

The Danish monitoring programme for foodstuffs also contains measurements of a number of pesticides, including chlordane, DDT, dieldrin, HCB, and heptachlor. The results of the monitoring programme for 1998-2003 are reported in FødevareRapport 2005:1 (only in Danish). On the basis of the measurements, the total average intake of the substances is estimated as follows:

ΣClordan: 0.11 μg/day

ΣDDT: 0.27 μg/day

Dieldrin: 0.13 μg/day

HCB: 0.09 μg/day

Heptachlor sum: 0.05 μg/day

Daily intake has fallen significantly for all the substances over the past 20 years. The Danish Veterinary and Food Administration concludes that, on the basis of the estimated intake compared with the ADI (acceptable daily intake) or TDI (tolerable daily intake), the content of POP pesticides found does not give grounds for health concerns.

POP pesticides in the environment

A number of chlorinated pesticides, including DDT/DDE, HCB and chlordane, are included in the ongoing monitoring of pollutants in the environment and in emissions from point sources. The substances have been monitored over a number of years and there is a lot of data. The most recent monitoring report for marine areas, which includes data on chlorinated pesticides in mussels and fish, concludes that the concentration of chlorinated pesticides is at a level which is not deemed to be a risk to the environment. In the period 1993-2003 a number of measurements were taken of all the POP pesticides in the groundwater (25-70 measurements per substance) without finding the substances.

As the environmental and health risks are today primarily linked to PCBs and dioxins, POP pesticides will not be mentioned further here.

2.3.2 Annex B substances - DDT

DTT, which at the moment is the only Annex B substance, is treated together with the other pesticides in section 2.3.1. DDT is not used in Denmark.

2.3.3 Intentional use of PCB

Historical uses of PCB

PCB has never been produced in Denmark. However, as in the rest of the world, Denmark has for some periods been using PCB for various products and equipment for technical applications. The first overall study of the consumption of PCB in Denmark was made in 1983, and presents a fairly good picture of historical consumption of PCB in Denmark, see table 2.3. The table shows consumption up to 1981. In the period 1981-1986, small amounts of PCB may also have been used in electrotechnical equipment, so that total consumption was slightly larger than the table indicates. However, data are not available for this period.

Table 2.2
Consumption of PCB in Denmark in accordance with a study from 1983

* Small amounts of PCB may have been used in equipment for large capacitors and transformers up to 1986 when the ban was introduced, and total consumption may therefore have been slightly larger than indicated in the table.

Source: Based on: Hansen, E. et al. 1983. PCB/PCT-forurening - En udredning om forbrug, forurening og transportveje for PCB og PCT i Danmark. (PCB/PCT contamination – a study of consumption, contamination and pathways of PCB and PCT in Denmark).

In the late 1960s and the early1970s, it became clear that PCB spreads and accumulates in the environment, and that it may occur in foodstuffs at levels that give rise to concern. Therefore, a number of regulatory measures were taken, see section 2.2.4.

PCB in electrotechnical equipment

From 1998, when the Statutory Order was prepared, an extensive questionnaire study was made in order to ensure that potential holders of equipment were aware of the requirements and took care of the disposal of the equipment. In this study, 19 enterprises stated that they were still holding PCB-containing equipment, and the equipment was subsequently disposed of. Overall quantities identified during the study were 3.3 tonnes. A single enterprise, that was in possession of PCB-containing transformers and capacitors, accounted for 2.5 tonnes.

The study concluded that small numbers of PCB-containing large capacitors for power factor compensation and that perhaps also a few transformers might still be used in small enterprises. However, it was not possible to identify such equipment in practice. The study underlined that the electronics industry should maintain focus on old electronic equipment, and make sure that PCB-containing equipment could be disposed of in a safe manner.

Small PCB-containing capacitors have been used mainly in household appliances and fluorescent tubes. Today, capacitors have been disposed of together with the products, but small amounts may still be used, especially in old tubes. According to the Danish WEEE Order, fluorescent tubes, like other waste electrical and electronic equipment, are subject to special regulations on disposal.

PCB in building materials

As stated in table 2.3, PCB was used until 1974 in fillers and glue for double-glazing window panes. Based on the technical specifications for such products, their useful economic life is generally expected to be shorter than the 30 years that have passed since they were installed.

In connection with the Ministry of the Environment Waste Strategy 2005-2008, a study will be made on potential risks for health and the environment from the use, restoration and demolition of buildings containing PCB. Therefore, in 2005, the Danish EPA launched a study of PCB in building materials in old buildings. However, the results are not yet available. Further, from studies made by the City of Copenhagen it appears that PCB can be found in building materials in a number of buildings.

PCB in foodstuffs

In connection with the Danish foodstuffs monitoring programme, the content of PCB in foodstuffs has been monitored since the programme started in 1983.

The latest results are presented in reports covering the monitoring period 1998-2003. Developments over time for the content of chloro-organic pesticides and indicator PCB in fish were monitored in this and three preceding monitoring periods. A general fall in the content of PCB was observed for the period 1983-1998, whereas falling amounts have not been ascertained in the latest period (1998-2003).

The fall from 1986 to 2005 is illustrated in figure 2.1, which shows developments of PCB contents in cod liver. PCB levels were significantly higher in the 1970s. However, changes of analysis methods prevent exact comparison of developments in the period.

Figure 2.1
PCBs in cod liver from Danish waters

Source: Danish EPA Indicators for sustainable development, based on the foodstuffs monitoring programme. Regression lines based on logarithmic transformation of basic data. (http://www.mst.dk/indikator/BU/ShowIndi.asp?Indikator_ID=196&Sprog_ID=1&Produkt_ID=1)

Average daily intake by Danes in the period 1998-2003 is estimated at 0.9 µg/day for the sum of 10 indicator PCBs. Estimates for individuals with relatively high intake of the substances (0.95 fractile) show that they consume approx. twice the amount consumed by the average Dane. However, intake levels of individuals with special patterns of intake, for instance because they eat substantial amounts of cod liver or cod liver oil, are expected to be even larger. The largest amounts of chloro-organic compounds come from fish, meat and dairy products. Children have a higher intake from milk and dairy products, and a lower intake from fish than adults.

The assessment of impacts on human health from PCB is particularly complicated, because we are dealing with a mixture of congeners with different toxicological properties and modes of action. Most toxicological studies were made with the original commercial products, which are not representative of the mixtures accumulating in the food chains. Besides, toxicological studies regarding PCB are also subject to a number of other uncertainties.

 Based on a number of assessments, the Danish Veterinary and Food Administration has fixed a tolerable daily intake (TDI) for total PCB of 0.1 µg/kg bodyweight/day.

The Veterinary and Food Administration concludes that – comparing estimated intake with TDI – the levels that have been found do not give rise to health concerns. Average intake for children amounts to 25 per cent of TDI, and for adults, 13 per cent of TDI.

PCB in the environment

PCB in the Danish environment has been monitored for several decades. PCB became an area of considerable concern in the mid 1970s, when suspicion arose that the substance contributed to reducing populations of seal in the Baltic Sea – a suspicion that was later confirmed. According to HELCOM, populations, when lowest, counted approx. 2,000 individuals. Today, the number has increased to about 10,000. It is less clear whether contamination in Danish waters with xenobiotic substances such as POP substances has been sufficient to cause evident reduction of Danish seal populations. However, NERI has observed improved health of seal in Danish waters, at the same time as PCB levels in the marine environment have been decreasing.

PCB is also considered to contribute to the reduced numbers of otters in Denmark in the last half of the 20th century. PCB has many different toxic effects, for instance it disturbs the degradation of vitamin A in the body. Tests with mink and seal show that poisoning with PCB affects reproduction. Moreover, the animals suffer from vitamin deficiency, resulting in negative impacts on the immune system. Therefore, animals poisoned with PCB are more likely to become ill. Falling levels of PCB in otters caught in Danish waters in the period 1980-1990 have been found. Around 1990, contamination with PCB in Denmark was still big enough to cause low levels of vitamin A in a small number of animals. According to NERI, today PCB contamination in Denmark appears not to be at a level causing negative impacts on the Danish population of otters.

The latest report, dating from 2004, from the Danish water and nature monitoring programme 2004-2009, NOVANA, concluded that concentrations of PCB in mussels and sediment were generally still at a level where effects on the marine environment cannot be excluded, although the concentration of PCB has been falling during the last centuries.

Concentrations in mussels of PCB and the chlorinated pesticides DDT and HCH are shown in figure 2.2. In all areas, the concentration was above the lower EAC threshold value (based on ecotoxicological assessment criteria) which means that there may be impacts on the environment caused by the concentrations of PCB.

Figure 2.2
Concentrations of chlorinated pesticides and PCB in mussels (mean value and maximum), compared to limit values based on ecotoxicological assessment criteria (EAC). Unit: µg kg^-1 wet weight. Note other scaling factor for HCH.^[11]

Translation of text: same as Danish except: Vadehavet = The Wadden Sea; Lillebælt = The Little Belt; Storebælt = The Great Belt; Øresund = The Sound

Extensive material on concentrations of PCB in water, sediment and a large number of organisms is compiled in the report ”Kortlægning af dioxinforurening samt kilder til dioxinforurening i Østersøen ” (Mapping of dioxin contamination and sources of dioxin contamination in the Baltic Sea).

2.3.4 Unintentional production of dioxin, HCB and PCB

Following the Seveso accident in 1976, where the environment was contaminated with extensive dioxin pollution, a working group set up by the Danish EPA in 1977 prepared the first investigation aiming at assessing the potential occurrences of dioxin in products marketed in Denmark and at assessing production of dioxin in various processes.

At that time, focus was primarily on the presence of dioxin in chemical products. Denmark had introduced a limit value for dioxin in the plant protection product 2,4,5-T, one of the ingredients in the defoliant known as Agent Orange. The working group recommended that a maximum limit value be introduced for dioxin in pentachlorophenol (PCP), and that various precautions be taken in using the wood preserving product sodium pentachloro-phenolate (na-PCP) and other metal salts of chlorinated phenols. Further, the working group recommended that considerations were to be made on a ban on burning impregnated wood.

The ban on the use of pentachlorophenol and preserving agents based on the substance has now been in force for a number of years. However, as shown in a study by the Danish EPA in 2003, dioxin still occurs in wood treated with PCP-containing agents in the mid 1970s.

During the 1980s regulation was introduced on the use of dioxin-containing chemicals, and focus was on unintentional production of dioxin during incineration processes. In this period, development in the incineration sector was intense all over Denmark, and it became increasingly clear that these installations were the source of substantial releases of dioxin, and that better cleaning was required.

In 1990-1992 and 1997, more extensive studies were made. Later, in order to get an overview of the flow of dioxin in Danish society, two mass flow analyses were made, describing the situation in 1998/99 and in 2000-2002.

Following the dioxin scandal in Belgium in 1999, where contaminated fat in animal feed caused unacceptable contamination of foodstuffs, international focus was directed towards issues of food security and dioxin and similar substances in foodstuffs. On the basis of the scandal in Belgium, Denmark and other EU Member States initiated intensified efforts to reduce the pressure on humans from dioxin. In Denmark, such efforts took the form of coordinated cooperation between the Ministry of Food, Agriculture and Fisheries, the Ministry of Family and Consumer Affairs, and the Ministry of the Environment.

Reports have been published on measurements of dioxin emissions from private wood stoves, on measurements of dioxin in soil, compost, bio-ash, percolate from landfills, cow’s milk and breast milk, air, water, sediment, deposition monitoring (atmospheric depositions of dioxin), and of brominated dioxin in flue gases from waste incineration plants. The results are available in a number of status reports. Some of the main results are presented below.

The Ministry of Family and Consumer Affairs (Danish Veterinary and Food Administration) and the Ministry of Food, Agriculture and Fisheries (Danish Plant Directorate) have contributed to efforts in the dioxin area with the dioxin action plan, which addresses both animal feed and foodstuffs. The main results of the action plan, which was published in 2005, are presented later in this chapter.

There are no inventories of unintentional production of PCB and HCB in Denmark. None of the processes known to contribute significantly to unintentional HCB production, such as production of certain chemicals, electrolytic production of aluminium and production of magnesium, take place in Denmark.

As regards monitoring of substances in foodstuffs, animal feed and the environment, PCB and HCB are also included in the monitoring programmes, but the starting point of such efforts has been intentional uses of the substances. Measurements of HCB and PCB are therefore presented in sections 2.3.1 and 2.3.3, intentional uses.

In the following, focus is on dioxin and dioxin-like PCB.

Sources of dioxin pollution

Inventories of dioxin emissions to soil, air and water are given in the action plan for reduction of releases of unintentionally formed POP substances, see annex 1. Discussions on sources and efforts regarding selected sources are also presented in the annex.

In 2004, the most important sources were incineration of waste, burning of biofuels (wood, wood waste, straw), production of cement, and transport processes.

In order to get an overall overview of the production and emissions of dioxin to all media and waste deposits, two mass flow analyses have been made. Figure 2.3 shows that the overall production of dioxin in various processes in Denmark around 2002 is in the order of 72-689 grammes I-TEQ/year, i.e. much larger than overall emissions. The reason is that large parts of the production of dioxin end up in residues from flue gas purification. Estimates are subject to great uncertainty, because the content of dioxin in residues varies, and the number of measurements is limited.

Since the elaboration of the mass flow analyses, new regulation has entered into force, which has led to a substantial reduction in the emissions from incineration plants. In the Act on incineration plants a threshold value of 0,1 ng I-TEQ/Nm³ for the emission of dioxin from incineration plants has been set. The threshold value has been in force for new plants since 24 March 2003. For existing plants the value has been in force since 28 December 2005. If all plants comply with the threshold value, the total emissions on dioxin can be estimated to no more than 2,2 g I-TEQ/year, comprising approximately 7 per cent of the total emissions from incineration plants in 1990.

It should be noted that the figures for dioxin emissions are being revised, and that the figures given cannot be used directly.

A number of the plants where a destruction of dioxins takes place, are at the same time amongst the most important sources of production of dioxins. This is especially the case for incineration plants, where the amount formed is considerably larger than the amount destroyed. The dioxin is captured in the flue gas purification process.

Figure 2.3
Overall flow of dioxin in Denmark 2000-2002, in grammes I-TEQ/yr ^[12]

Dioxin in products

As mentioned in the introduction to this chapter, a ban on PCB has been in force for many years in Denmark. However, PCBs may occur as preserving agents in imported wood, textiles and leather, because the substance is still used in certain parts of the world. Based on measurements, the overall content of PCB in import of textiles and leather is estimated at 1 g I-TEQ/yr. New studies confirm that single-use pallets imported from countries in Southern Europe may contain PCB, but below the current limit value of 5 mg/kg.

Dioxin and dioxin-like PCB in food, breast milk and animal feed

As mentioned above, the Ministry of Family and Consumer Affairs, and the Ministry of Food, Agriculture and Fisheries contribute to cooperation on dioxins, i.a. by the dioxin action plan, focusing on animal feed as well as foodstuffs. The latest results of work with the action plan were presented in 2005.

The EU has fixed limit values for the content of dioxin in foodstuffs, which entered into force on 1 July 2002.^[13] The Regulation underlines that measures based on limit values for dioxin and dioxin-like substances in foodstuffs are not sufficiently effective to reduce human exposure to dioxins. If so, limit values should be so low that large parts of foodstuffs would have to be declared unsuitable for human consumption. The EU therefore recognises that the desired reduction of dioxin levels cannot be immediately achieved, but must be aimed at with measures taking place over a period of some years. The strategy involves a gradual reduction of limit values.

The EU also operates with two other sets of ”limit values”, known as action levels and target values, combined with measures to reduce emissions.

Action levels are tools which can be used by competent authorities and business to identify cases where it is relevant to examine the source of pollution in more detail, with a view to possible measures to reduce or remove it. Not only in case of violation of the Regulation, but also in cases where dioxins are ascertained in foodstuffs at levels which are substantially above normal background values.

Target values are the levels to be achieved in order to ultimately reduce the major part of human exposure to the tolerable weekly intake (TWI) set by the EU Scientific Committee for Foodstuffs.

Data on occurrences of PCB-like dioxin are limited, and therefore, to begin with, limit values were set only for dioxin.

As outlined in section 2.2.4 on legislation, limit values were introduced recently, regulating the sum of dioxin and dioxin-like PCBs (total TEQ) and specifying action levels for dioxin-like PCBs which go beyond existing action levels for dioxin. The rules are set out in Commission Regulation no. 199/2006 of 3 February 2006.

As of 4 November 2006, both existing limit values for dioxin, and the stricter limit value for total TEQ, must be observed.

The new limit values for total TEQ are presented in figure 2.4, together with levels found in Danish foodstuffs. More results and more detailed discussion of the measurement results can be found in the latest report from the monitoring programme for foodstuffs, and in the final reporting of the dioxin action plan.

Special attention has been directed towards dioxin in eggs. In other countries, higher dioxin concentrations have been found in organic eggs than in eggs from conventional farming. In 2005 the Danish EPA launched a study of sources of dioxin in organic farming in Denmark.

Studies of the content of dioxin in Danish foodstuffs show that, generally, levels are below prescribed values for total TEQ, except for certain fish species.

With the new limit values for the sum of dioxin and dioxin-like PCB, it is expected that – besides higher values in salmon from the Baltic Sea and in herring form the Baltic Sea north of Bornholm – limit values will also be exceeded for sea trout from the areas offshore Bornholm, and in eel from the Sound (Figure 2.4).

Based on the results of mapping, and in accordance with current limit values for dioxin, the Danish Veterinary and Food Administration issued a ban in 2004 on fishing and sales of herring from the eastern part of the Baltic Sea, and for salmon above 4.4 kg (fresh weight) from all of the Baltic Sea.

Later, the Veterinary and Food Administration and the Nordbornholms Røgeri (smokehouse) carried out a number of tests to remove adipose fat from salmon through trimming, in order to reduce the content of dioxin. As a result of these studies, and in accordance with Statutory Order no. 851 of 15 September 2005, large salmon can now be sold, provided they have been subject to trimming to remove adipose fat in a process specified in a branch code that is approved by the Veterinary and Food Administration.

Figure 2.4
Measured sum of dioxin and dioxin-like PCB (total TEQ) in samples of Danish foodstuffs 2000-2004. Note the different scales and units in the two figures. Contents measured are stated in mean values and the interval from lowest to highest measured value. The maximum limit values proposed are indicated with red horizontal lines. ** For fruit, vegetables and cereals, there are no maximum limit values, and the sum of action levels for dioxin and dioxin-like PCB are stated instead. ^[14]

Human intake of dioxin and dioxin-like PCB

On the basis of an overall estimate, levels of intake of dioxin and dioxin-like PCB by part of the Danish population are considered to be too high.

In 2001, the EU Scientific Committee for Food (SCF) fixed a tolerable weekly intake (TWI) of dioxin and dioxin-like PCB for humans of 14 pg WHO-TEQ/kg body weight/week.

Mean intake of dioxins and dioxin-like PCB by Danish adults is calculated at between 5.6 and 7.7 pg WHO-TEQ/kg body weight/week. Average values for the 5 per cent Danes with the highest intake (95 per cent fractile) are between 12.6 and 25.9 pg WHO-TEQ/kg body weight/week.

Disregarding intake from fish, the mean intake for children between the age of 4 and14 years is estimated at 7.7 pg WHO-TEQ/kg body weight/day, and between the age of 4 to 6 years it is 10.5 pg WHO-TEQ/kg body weight/day. The 95 per cent fractile for the two groups of children is 14.0 and 16.8 pg WHO-TEQ/kg body weight/day, corresponding to 100 per cent and 120 per cent of TWI. For children eating fish the level will be even higher.

It is estimated that more than 90 per cent of the dioxin exposure originates from foodstuffs – approx. 80 per cent from animal food. The percentage distribution of the mean intake of dioxins and dioxin-like PCB from all foodstuffs is between 30-40 per cent from milk and dairy products, 3-4 per cent from eggs, 13-18 per cent from meat, and 38-55 per cent from fish.

It should be noted that studies of human diet show that the Danes do not eat enough fish, and that the average Dane eats only half the amount of the dietary recommendation. If the consumption of fish is increased to the recommended level, dietary recommendations underline the importance of basing intake on a variety of fish, and not only on fatty fish from contaminated waters. Moreover, it is recommended to eat both fat and low-fat fish species from different areas. The bigger the consumption of fish with a high dioxin and PCB content, the more Danes will be close to or exceeding the TWI.

Dioxin and dioxin-like PCB in breast milk

When planning the dioxin action plan, emphasis was placed on including beast milk sampling in order to monitor the impact of dioxins and dioxin-like PCBs on humans. As more than 90 per cent of dioxin consumption by humans stems from food, analyses of the contents of dioxins and dioxin-like PCBs in for example breast milk will give us a picture of the overall human exposure to these substances.

The samples, which were part of the action plan, were taken at the breast-milk centres at Hvidovre and Skejby hospitals. The breast milk sampled originates from first-time mothers between the age of 25 and 29, and was milked primarily between 3 and 8 weeks after giving birth. The sampling was standardardised and can therefore be compared to previous surveys of breast milk in Denmark.

Figure 2.5 shows average values from analyses for the years 1999, 2002 and 2004. The figure also shows the results from previous Danish surveys in 1986 and 1993. There is a clear fall in the content of dioxins and dioxin-like PCBs. From 1993 to 2004 there is a fall of 48 per cent for dioxins, and of 67 per cent for dioxin-like PCBs, as well as a fall of 58 per cent for the sum of dioxins and dioxin-like PCBs together.

Since phasing-out the use of PCBs began in the 1980s, there has been an observable reduction in human exposure to PCBs. Because dioxin-like PCBs are part of overall PCB levels, the fall in dioxin-like PCBs must be seen primarily as a consequence of the general fall in PCB levels stemming from the phase-out. The fall in human exposure to dioxins must be ascribed to efforts, both at Danish and international levels, to reduce emissions of dioxins.

The amount of dioxins in breast milk can be seen as an indicator for the actual impact on the population, and it is worth noticing that the level in 2004 was still at around 50 per cent of the level in 1986, which was a very high level, despite the substantial falls in emissions in Denmark.

Figure 2.5
Contents of dioxins and the sum of dioxin and dioxin-like PCB content in Danish breast milk. The figure shows average content in breast-milk samples collected in the years 1986, 1993/94, 1999, 2002 and 2004. ^[15]

Dioxins and dioxin-like PCBs in animal feed

As part of the dioxin action plan, Danish animal feed were sampled annually in the period 2000 to 2004. Samples were analysed for contents of dioxins and dioxin-like PCBs and indicator PCBs. A total of 460 animal feed samples were taken in the period 2000 to 2004 under the dioxin action plan for the purpose of analysis. In 43 cases, the content of dioxins was above the limit values which entered into force on 1 July 2002. However, only one out of the 84 samples taken from animal feed in 2004 had a content of dioxins exceeding the limit value. In general, the content of dioxins and both types of PCB was slightly higher in feedingstuffs including contents of fish (fish oil, fishmeal, fish fodder and fur-animal feed). In feeding fats (both animal and vegetable) the content of dioxins, but not the content of dioxin-like PCBs and indicator PCBs, was relatively high (for dioxins, almost at the same level as fishmeal). In the other feed mixes, contents were low for both dioxins and for both types of PCB.

The limits for maximum levels of dioxin in animal feed entered into force on 1 July 2002^[16] and were amended by Commission Directive 2003/57/EC with regard to minerals and binders especially. The new Directive, which amends Appendix 1 of the Directive 2002/32/EC, establishes maximum levels for dioxin-like PCBs and indicator PCBs, adjusts the existing action levels for dioxins, and introduces action levels for dioxin-like PCBs.

Dioxins in the environment

As a part of the dioxin action plan, sediments, soil, air and deposition have been sampled for dioxins. Moreover, from 2005, dioxins and dioxin-like PCBs have been included under Denmark’s national nature and water-monitoring programme, NOVANA.

Dioxins in sediments

Samples of sediments have been taken from the bottom of 18 fjords and lakes throughout Denmark, and from the Sound and the Kattegat. The content of dioxins varied considerably, from 0.6 to 24 ng/kg I-TEQ. In general, dioxin levels were lower in Jutland than on Zealand, but otherwise sampling showed no obvious link between dioxin-levels and geographic location, or any consistent difference between city and countryside. The great variation and the height of the levels indicate that water-born pollution plays an important role. Based on measurements of the atmospheric deposition, one should expect levels between 0.2 – 1.2 ng/kg, which accords with the lowest sediment results. Dioxin concentrations measured in sea sediments were at the same level as concentrations measured in sediments from fjords and lakes.

Dioxins in soil

In 2002-2003 a national survey of dioxins in soil was carried out. Samples were taken from 32 locations. The majority of dioxins in soil are present 0-10 cm from the surface. Dioxin levels in samples from unpolluted arable reference areas and other rural areas reached 0.7 ± 0.2 ng/kg I-TEQ (average ± variation). In samples from exposed rural areas downwind from cities, industrial areas and larger point sources, dioxin levels also reached 0.7 ± 0.2 ng/kg I-TEQ. Thus, there is no observable increase in dioxin levels in soil from exposed land. On the other hand, the content of dioxins in garden and park soil from cities is considerably higher: 6.2 ± 5.6 ng/kg I-TEQ in samples from the cities of Copenhagen and Nyborg.

In 2003-2004 the survey was followed up with extra sampling of garden and park soil from a number of cities, and of soil from a rural zone in Southern Jutland. The survey showed that the content of dioxins in soil samples from Copenhagen parks and gardens varies from 1.6-34 ng/kg I-TEQ, whereas dioxin contents in soil from provincial parks varied from 1.5-2.5 ng/kg I-TEQ. The overall data material showed falling levels of dioxins, from south to north in Denmark. This is a consequence of the greater atmospheric transport of dioxins from south to north, than from north to south in Denmark.

Dioxin deposition

As part of the dioxin action plan, a measurement programme was launched in 2001 which covered measurements of dioxins in the air and in atmospheric deposition. Dioxins were measured in bulk deposition at three forest stations in western Jutland (Ulfborg), northern Zealand (Fredensborg) and on Bornholm, as well as in an urban area (Copenhagen). In Fredensborg, measurements were also taken of dioxins in deposition under pine forest canopy (drip through). The concentration of dioxins in the air was measured in Fredensborg and Copenhagen, as well as in a village (Gundsømagle) with many wood-burning stoves. The programme ended in 2005 and the results have been described in a recent report. Below is a brief account of the main results.

Deposition of dioxins from the air is decisive for the transfer of dioxins from sources to the land and the sea. Depositions are a direct measure of the intensity of exposure associated with a geographical area, which is directly linked to the dioxin amounts the area receives.

The surveys revealed a regular seasonal variation in concentrations of dioxins in the air, with maximum levels in the wintertime. Atmospheric concentrations in northern Zealand and Copenhagen followed each other closely and synchronously, which indicates that long-range transport is a significant contribution to dioxins in the atmosphere. In the village, the winter maximum was especially high - the highest measured in the programme – and must be interpreted as caused by emissions from wood-burning stoves during the heating season.

As a consequence of the seasonal variation in the atmospheric concentrations, the deposition of dioxins is greater in the winter than in the summertime, although this is more pronounced in some stations than others. Depositions tend to be higher above Bornholm (the Baltic Sea) than above Ulfborg (the North Sea), as expected according to model calculations of atmospheric transport of dioxins in the region. The total geographical variation from Copenhagen to Ulfborg is not big, but constitutes a factor of 2.1.

Measurement programmes have also examined whether there is a relationship between regional differences in deposition and the concentrations of dioxins in soil and sediments.

Depositions can account, more or less, for the content of dioxin in soil from rural areas. However, the concentrations in soil samples from Copenhagen are far too high to be explained by deposition. The concentrations in the sediments from all but a few lakes are too high to be attributed to depositions alone. This applies to sea sediments as well. The Danish EPA launched a survey in 2005 on the basis of the measurements in order to examine the relationship between dioxin concentrations in the water, atmospheric deposition and the release from sediments in the Baltic Sea.

Depositions on the surface of the sea in the western part of the Baltic Sea are estimated at 1.3 mg I-TEQ/km²/yr., which corresponds to more than 200 times the amount that is collected annually per km² in fatty fish such as herring and salmon. Depositions contribute to dioxins to the Baltic Sea which are available for uptake in the food chain. Therefore, deposition on the surface of the sea is a significant source of the population’s intake of dioxins through fish many years ahead.

The deposition measurements made it possible to calculate the annual deposition of dioxins more precisely than the 13-130 g I-TEQ stated in the flow diagram in figure 2.3. On the basis of the measurements, the annual deposition on Danish land has been calculated at around 40-90 g I-TEQ, which indicates that, in net terms, Denmark receives more dioxin from other countries.

Long-range transboundary air pollution
The EMEP programme (Co-operative Programme for Monitoring and Evaluation of the Long-range Transmission of Air pollutants in Europe) under the Convention on Long-range Transboundary Air Pollution (LRTAP) makes calculations of how much pollution the individual European country receives from and imposes on other countries.

EMEP publishes a range of regular reports with calculations for the individual country, including Denmark. For dioxin, these calculations include calculations of emissions; atmospheric deposition; concentrations in air, soil and vegetation; as well as exchange of dioxin between Denmark and major European countries. Naturally, the calculations are subject to some uncertainties, because they depend on the individual country’s submission of correct emission inventories to the EMEP. Moreover, the models applied are also prone to considerable uncertainty.

According to the latest status report with model calculations for 2003, about half of total air emissions from Danish sources were deposited in countries on the European continent, including Denmark. The remainder was deposited in the sea outside Europe or degraded in the atmosphere. Of the half that was deposited in Europe, about 30 per cent was deposited in Denmark. The major recipient countries of dioxins from Danish sources were Sweden, Russia and Poland which received 19, 14 and 7 per cent respectively.

Of the amounts deposited in Denmark in 2003, more than half came from Danish sources, whereas 8 per cent came from the United Kingdom, and 7 and 4 per cent, respectively, came from Germany and Poland.

These figures only tell us about depositions over land and therefore do not give us an idea of the countries of origin of dioxins in fish, which is a significant source of human exposure to dioxins.

2.3.5 Stockkpiles, waste and contaminated sites

POP pesticides in waste products and depositories

There has been no systematic monitoring of POP pesticides in waste products in Denmark apart from in sewage sludge from public treatment plants, where the substances aldrin, dieldrin and endrin were included in the point source programme under NOVA2003 until, and including, the year 2003.

According to the point source report for 2003 there had been no detections made of the three substances in either discharge or sludge from the treatment plants examined. Therefore it was decided to omit POP pesticides from the new monitoring programme when NOVA2003 was replaced by the NOVANA programme.

In a previous survey of the environmental impact of waste treatment plants, DDX (i.e. DDT/DDD/DDE) was included in the analysis programme for xenobiotic substances in waste products and emissions from selected waste incineration plants, composting plants and landfills, however it was not detected in any of samples taken.

In 1961 the Ministry of Agriculture instigated a national collection of pesticides waste and pesticide residues which were deposited in a repository on Harboøre Tange (an offshore bar at Ringkjøbing Fjord). It is uncertain which exact substances were deposited from the collection, but POP pesticides may have been included. Part of the repository was washed out into the North Sea as early as February 1962 during a storm, leading to extensive fish mortality in the area. The repository was later remediated but work to reduce leaking of dangerous substances from remaining waste is still going on. However, none of the substances which have been detected are POPs.

It is likely that uncontrolled and inappropriate depositing of pesticide residues took place before there were any actual rules and regulation for the disposal of hazardous waste, although the most common practice was to incinerate residues and packaging locally at farms. For many years, pesticide residues and packaging have been disposed of via municipal delivery schemes. The waste the municipalities receive is transported to Danish municipalities’ own treatment facility, Kommunekemi, for destruction or final depositing.

According to assessments, there are no stockpiles of obsolete POP pesticides in Denmark today.

PCBs in waste products

The amount of waste which contains PCBs and PCTs (polychlorinated terphenyls) is calculated in the Danish EPA ISAG system which calculates information on waste and recycling based on reports from Danish waste treatment plants. The period from 1997 to 2004 has seen a falling trend in the amounts of PCB-containing waste, as can be seen in figure 2.6. The large figure for 2000 is due to the disposal of a large single load of PCB-contaminated soil.

Figure 2.6
Amounts of PCB/PCT-containing waste registered in the ISAG.

PCB/PCT-containing waste is for the major part sent to Kommunekemi. Trends in the amounts of the most important categories of PCB/PCT-containing waste that is sent to Kommunekemi are illustrated in figure 2.7. Please note that waste amounts are stated in tonnes. PCBs make up about one-third of the total weight in capacitors and transformers. These two waste fractions show a regular fall in the period 1995 to 2005. In 2005, a total of 3.4 tonnes of capacitors was disposed of in 13 deliveries. Assuming they are large capacitors, this corresponds to around 1 tonne of PCB in 70-150 capacitors. Results confirm that there is a small quantity of PCB-containing equipment still in use which will not be revealed until the equipment is disassembled.

Apart from the fractions illustrated, a total of 44 kg of waste fell under the category of “Miscellaneous” in 2005. Furthermore, in the period before 2000 large amounts of soil, landfilled waste and groundwater were disposed of on occasion.

Figure 2.7
The amount of the three major fractions of PCB/PCT-containing waste delivered to Kommunekemi 1993-2005. Based on information from Kommunekemi.

PCB-contaminated sites

There are no Danish quality criteria for PCBs or dioxins in soil, and it is therefore up to the individual county to decide which concentrations should trigger remediation measures.

Incidents of soil contamination are registered by Danish counties, which report annually to the Danish EPA. The incidents are registered in the Danish EPA database register of contaminated sites, ROKA. From the start of registration in ROKA to 2004, a total of three contamination incidents have been registered which involve PCBs as a contaminant. The three incidents were registered in 1989, 1998 and 2002.

There have been many examinations for PCBs in soil at power and transformer stations but no findings of significant amounts of PCBs have been made.

The Danish electricity company NESA conducted surveys in 2003-2004 examining the soil under capacitor batteries in 11 of the company’s 65 main transformer stations. PCBs were used previously in capacitors at main transformer stations, whereas, by and large, PCB-containing transformers have not been used in the supply grid. In the soil under two out of the eleven capacitor batteries examined, elevated concentrations of PCB were found. Concentrations were of up to 3.5 mg/kg (a total of 10 PCB congeners). The sites have subsequently been remediated.

Dioxins in residues from waste incineration

During flue-gas cleaning, a large proportion of the dioxin formed will end up in the flue-gas cleaning product.

On the basis of measurements of dioxin concentrations in flue gas and residues, the latest mass-flow analysis estimates that 58-436 g I-TEQ are formed annually from incineration at Danish incineration plants. Of these, an estimated 6.4-28.9 g I-TEQ were emitted to the air, 2-5 g I-TEQ ended up in slag, while the remaining 50-402 g I-TEQ ended up in flue-gas cleaning products (please note that waste treatment in figure 2.3 also covers other waste treatment). The considerable uncertainty regarding total amounts is due to very large variation in the dioxin concentrations measured in the flue-gas cleaning products. For example, 21 measurements at different plants varied from 135 to 35,566 ng I-TEQ per kg dry matter. The average for dioxins in the flue-gas cleaning products was 4,162 ng I-TEQ/kg.

It should be noted that during waste incineration some of the dioxins are destroyed. Waste disposed of through normal waste incineration has an estimated total content of 9-310 g I-TEQ/year, according to the mass-flow analysis. Using European average figures for dioxins in waste^[17], the total amount can be estimated at 107 g per year. This amount would end up in landfills if the waste was deposited instead of incinerated, and in a net statement it would cancel out some of the dioxins which are formed during waste incineration.

In two of the plant types used at Danish incineration plants, part of the dioxins are captured together with activated carbon, forming a separate product, which can then be incinerated destroying the captured dioxins in the process. These plant types have bag filters with activated carbon placed after the other flue-gas cleaning, or they utilise the so-called ADIOX process where the dioxin bonds with a glass fibre material with embedded activated carbon, which after filling (typically following several years) can be sent to destruction/incineration. In the other plant types, the activated coal blown in is captured with the remaining flue-gas cleaning products.

Whereas the slag from waste incineration is used mainly for plant-internal purposes, almost all flue-gas cleaning products are sent to landfills in Norway or Germany. In Norway, the residues are stabilised with iron sulphate and sulphuric acid, a waste product from Norwegian industries. The resulting plaster is filled into an old stone quarry on the island of Langøya in the Oslo Fjord. In Germany the residues are mixed with concrete and other added materials to form a concrete mass that is built into old salt mines.

Dioxins in residues from energy generation

No measurements of dioxins in fly ash from Danish power plants exist, and due to the lack of up-to-date measurements, the mass-flow analysis estimates, however with great uncertainty, that the total content of dioxins in the fly ash is 0.3-40 g I-TEQ/year. A more recent report from the EU¹⁷ estimates the total amount of dioxins in fly ash from coal incineration in Denmark to be 17 g I-TEQ/year, based on European average figures.

Dioxins in bio ash

Surveys of dioxins in ash from incineration of biofuels were carried out as a part of the dioxin action plan. A total of 23 ash samples were taken. Of these, seven samples came from small straw-fired farm burners, four came from small heating plants (of which two were straw-fired and two wood-chips-fired), and twelve samples from burners fired exclusively on wood chips. Finally, a sample from a household wood-burning stove was included. Sampling results showed that the ash from straw-fired farm burners contains an average of 3.7 ng I-TEQ dioxins per kg, varying from 0.2-12 ng/kg I-TEQ. The estimated total amount of dioxins in ash is estimated at 0.005 – 0.1 g I-TEQ/year, according to the latest mass-flow analysis. This ash is widely applied to farmland, but due to the small quantities the dioxin content is not considered to go against using the ash for this purpose.

The ash from the small heating plants had a significantly smaller average dioxin content, 0.6 ng I-TEQ per kg of ash, varying from 0.03-1.4 ng I-TEQ/kg. The ash from the wood-chip burners had an average dioxin content of 18 ng I-TEQ/kg, which is considerably higher than for the straw-fired burners. They also showed greater variations, as the values measured range from 0.02 to 74 ng I-TEQ/kg. The lone sample taken from a household wood-burning stove had a very low dioxin content of 0.03 ng I-TEQ/kg.

Compared to flue-gas cleaning products from waste incineration, where the average was at around 4,000 ng I-TEQ/year, bio ash contains about 1,000 times less dioxins per kg.

Dioxins in percolated water from landfills

As a part of the dioxin action plan, samples were taken of percolated water from seven landfills. Concentrations varied from 0.01 to 0.11 pg I-TEQ per litre. For comparison, concentrations in rainwater measured at five different locations were 0.7-3.0 pg I-TEQ per litre, i.e. up to 30 times higher. Water which has percolated from landfills is therefore at present considered to be of significantly less importance than rainwater to dioxin impacts on groundwater and watercourses.

2.3.6 Future intentional production of POPs and need for exemption

There is no intentional production or use of POPs, and there is therefore no need for specific exemptions.

2.3.7 Programmes for monitoring releases, health risks and emissions inventories

Monitoring POPs in foodstuffs and health risks

The content of dioxin and dioxin-like PCB, indicator PCBs, chlordane, DDT, endrin, dieldrin, heptachlor and HCB in food is monitored continually as part of the Danish monitoring programme for food. The monitoring program is conducted by the Danish Institute for Food and Veterinary Research under the Ministry of Family and Consumer Affairs.

On the basis of the values found the intake with food is calculated, and the estimated intake is compared with the recognised tolerable daily or weekly intake.

The results of this monitoring are reported periodically and are available to the public on the Danish Veterinary and Food Administration website (www.foedevarestyrelsen.dk).

Monitoring POPs in animal feed

In the period 2000-2004, as part of the national dioxin action plan, the Danish Plant Directorate examined a total of 491 samples of animal feed for dioxin, dioxin-like PCBs and indicator PCBs (control samples and monitoring samples). Since 2005, the Danish Plant Directorate has been part of an EU harmonised mapping, monitoring and control programme for dioxins, dioxin-like PCBs and PCBs in animal feed. The Danish Plant Directorate reports data regularly to the Commission.

Monitoring POPs in the environment

Monitoring POPs in the environment is part of the National Programme for Monitoring of the Aquatic Environment and Nature, NOVANA. Monitoring of nature and environmental conditions in Danish fjords and marine areas is carried out in collaboration between the regional authorities and the National Environmental Research Institute of Denmark (NERI). In general, the regional authorities are responsible for monitoring fjords and coastal waters, while NERI is responsible for open waters. Implementation of the point source programme builds to a large extent on existing wastewater supervision by counties and municipalities, as well as enterprises’ own internal controls.

The NOVANA programme includes measurements of the following POPs:

Mussels:          Basic programme: PCBs (10 indicators), DDT/DDE, HCB.
                        Extended programme: dioxins and dioxin-like PCBs.

Fish:                PCBs (10 indicators), DDT/DDE and HCB.

Sediment:        DDT/DDE, HCB, PCBs (10 indicators), dioxins and dioxin-like PCBs.

Point sources: PCBs, HCB, dieldrin, endrin, aldrin.

POPs in the air, atmospheric deposition, soil, etc. are not included in continuous monitoring, but have been covered by special studies.

None of the POPs are included in the continuous groundwater monitoring carried out by GEUS, which is the reference centre for groundwater and borings. In the period 1993-2003, GEUS took a number of measurements of all the POP pesticides in the groundwater (25-70 measurements per substance) without finding the substances.

The results of monitoring are reported annually and are available to the public on NERI’s website (www.dmu.dk).

Monitoring dioxin releases from incineration plants and other point sources

The Danish EPA reference laboratory for measurement of emissions into the air is at Force Technology (previously DK-Teknik), and it has built up a database of measurements of emissions of dioxins. The database is primarily based on registration of measurements at incineration plants for waste and hazardous waste, but it is also possible to register emissions measurements from other types of installations.

There is a spreadsheet for using the database which incineration plants can use for reporting. Reporting is voluntary, and so far only a limited number of installations submit reports.

The database makes it possible to extract the necessary data, for example to calculate emissions factors, annual emissions, dioxin patterns or I-TEQ rates. It is hoped that all emissions measurements of dioxins, both enterprises’ own internal controls and controls by the authorities will be reported to the dioxin database. The data in the database is planned to be available directly on the reference laboratory’s website (www.ref-lab.dk), but as yet it is unknown when the database will be developed to this level.

Emissions of POPs from installations

The Danish EPA register on the environmental situation of installations contains information about releases from Danish installations subject to the IPPC legislation. In 2004 the register contained information on about 7,000 installations subject to approval, including releases from 158 large Danish installations into the air and water. The register contains information on 50 priority substances, including dioxin, HCB and ”haloginated organic compounds”. The register is based on annual information which installations issue in their green accounts.

The register is under development as it will be expanded to a ”Pollutant Release and Transfer Register” - PRTR register – and contain information on diffuse sources and emissions into the soil. Information in the register is used by NERI in preparation of national inventories of releases into the air. The information is available on the Danish EPA website (https://secure.mim.dk/mst/simi/) and on the website for the common European Pollutant Emissions Register, EPER (http://eper.cec.eu.int/eper/default.asp).

Emissions into the atmosphere

NERI is responsible for preparation of the annual official Danish inventories of emissions into the atmosphere. NERI reports the total estimated emissions of dioxins to the EU and the Convention on Long Range Transboundary Air Pollution (CLRTAP). The inventories are available to the public on the website for the EU databank (Central Data Repository at http://cdr.eionet.eu.int/).

2.3.8 Information to the public and exchange of information with other parties to the Convention

Problems associated with POPs are communicated at many levels and in many fora. In most cases, information on POPs will be in a slightly broader context when it is included with other hazardous substances.

Only a few examples of information dealing more specifically with POPs will be mentioned here.

Dioxin reports

As part of the dioxin action plan, in recent years a number of dioxin reports have been developed, see above, and these are available (in Danish) to the public on the Danish EPA website at http://www.mst.dk/kemi/02280000.htm.

A sensible stove for “pure” enjoyment

The primary source of POPs pollution from the public is through burning waste and using wood burning stoves.

In 2000/2001, the Danish EPA launched the campaign ”Fyrer du med skrald ryger miljøet” (heating with waste scolds the environment), and in 2004 this was followed up in association with Foreningen af Danske Producenter af Pejse og Brændeovne (an association of Danish stove manufacturers) with the campaign ”Fyr fornuftigt - og få ren hygge” (a sensible stove for pure enjoyment) (see annex 3). The aim of the campaign was to prevent smoke from stoves from containing hazardous substances, including POPs, because of using incorrect fuel. The folder for the campaign encourages people to use clean wood and to avoid using advertisements, magazines, milk cartons, cardboard, or treated or painted wood. The campaign folder was distributed in shops selling stoves and other places. A Danish website was set up for the campaign with good advice and information about environmental aspects and atmospheric pollution: http://www.fyrfornuftigt.dk/.

Some years ago, the former Bygge- og boligstyrelsen (National Building and Housing Agency) prepared a booklet (in Danish) ”Korrekt fyring. Sådan udnyttes brændslet bedre” (Correct heating. How to use firewood better), which encouraged people to use only clean and untreated wood. The booklet has now been updated and is distributed via the Local Government Denmark (LGDK) website (http://www.kl.dk/).

Stove and fuel dealers, as well as many municipalities and supply companies refer to the booklet on their websites.

Say goodbye to PVC waste and impregnated wood

In 2002 the Danish EPA launched a campaign to tell the public that products containing PVC should not be thrown away with ordinary waste. The reason was to prevent PVC waste from being sent for waste incineration, primarily to avoid formation of the large amounts of residues caused by PVC. As stated in the government Waste Strategy 2005-2008, the chlorine content in the waste can also cause production of dioxins on incineration. As PVC waste is a source of chlorine, there is a likely spin-off benefit when this waste is kept away from waste incineration plants to the extent possible. The folder is still available in Danish on the Danish EPA website (http://www.mst.dk.).

Dioxins and dioxin-like PCBs in foodstuffs

The Danish Veterinary and Food Administration (DVFA) website ”Alt om kost - smag for livet” (all about diet – a taste for life) (www.altomkost.dk) provides information about dioxins and dioxin-like PCBs in foodstuffs, harmful effects and what type of food is especially prone to containing the substances. The 2003 report ”Helhedssyn på fisk og fiskevarer” (an overall view of fish and fish products) by the DVFA includes information about a number of POPs in fish and fish products, including dioxins and dioxin-like PCBs.

DAKOFA

Because waste incineration has been the most important source of dioxin emissions into the atmosphere in Denmark, within the framework of the Dansk Komite for Affald (DAKOFA), a stakeholder organization on waste, a number of initiatives have been completed in conferences and meetings to inform about and discuss the possibilities to reduce emissions of dioxin from waste incineration plants.

Information exchange with other parties to the Convention

Through reports to UNECE, Denmark annually exchanges information on emissions of some POPs with those parties to the Convention which are also parties to the POP Protocol.

Through its membership of the EU, Denmark regularly exchanges information on a number of points regarding POPs with other Member States.

Similarly information on POPs is regularly exchanged through Nordic involvements.

2.3.9 Activities by non-public stakeholder organisations

WWF informs about POPs on their website (http://www.wwf.dk), and POPs are an integrated part of the organisation’s work to tighten chemicals legislation in the EU.

Greenpeace does work in relation to the Stockholm Convention and studies implementation as well as shares information on implementation with the international NGO network IPEN – International POPS Elimination Network. In Denmark the organisation focuses especially on cleaner technology and on enterprises emitting dioxin and their environmental approvals. Greenpeace also provides information about POPs on their website.

The Information Centre for Environment and Health is an independent information centre on environment, health and consumption, and it is funded by the Ministry of the Environment. The Centre has issued a large number of articles about the problems associated with POPs, especially dioxins in food.

2.3.10 Technical infrastructure for POP assessments, measurements, analyses, research and development

Laboratories competent to measure POPs

There are a number of laboratories in Denmark and Sweden which are accredited to analyse for POPs. The following laboratories have been designated to analyse POPs in one or more media under the NOVANA monitoring programme, but more laboratories may have the capacity:

• Dioxin: NERI (Roskilde), DVFA ;
• PCB: NERI (Roskilde), Eurofins (Aalborg), Eurofins (Vallensbæk), Milana (Elsinore);
• HCB: NERI (Roskilde), Eurofins (Aalborg), AnalyCen (Fredericia), Eurofins (Vallensbæk), Steins (Brørup);
• DDT/DDE: NERI (Roskilde), Eurofins (Aalborg);
• Aldrin, dieldrin, endrin: Eurofins (Aalborg) AnalyCen (Lidkùping, Sweden), Milana (Elsinore), Eurofins (Vallensbæk/Viborg), Steins (Brørup);

Three Danish laboratories measure dioxins in flue gases: Force Technology, Eurofins and the Danish Technological Institute. These laboratories collect the samples, while the actual analyses are usually conducted by German laboratories.

Research into occurrence and effects of POPs

POPs are part of a number of research programmes at Danish research institutions. Current POP-related research programmes at the institutions are described in more detail in section 3.3.9 under strategy elements.

Much research aims at POPs in the Arctic and is part of work under the Arctic Monitoring and Assessment Programme, AMAP, funded through the Danish EPA programme, Danish Cooperation for Environment in the Arctic (DANCEA).

The following institutions work with the problems linked to the occurrence and effects of POPs:

• NERI, Department of Arctic Environment;
• The research unit for Environmental Medicine at the Institute of Public Health at the University Of Southern Denmark, Odense;
• Centre for Arctic Environmental Medicine at the Institute of Public Health, Aarhus University;
• The research group for ecotoxicology at the Institute of Biology of the University Of Southern Denmark, Odense.

The Department of Atmospheric Environment at NERI, which has completed a large number of studies aimed at revealing the link between sources of dioxin and occurrences in the environment.

2.3.11        Particularly exposed population groups

Greenland and the Faeroe Islands

The populations of Greenland and the Faeroe Islands are particularly exposed to POPs through their large intake of fish and marine mammals. As Greenland and the Faeroe Islands are not covered by this implementation plan, the problem will not be described in more detail here.

Women of child-bearing age

Pollution from dioxin and other POPs represents a particular risk for women of child-bearing age as well as pregnant and nursing mothers. The DVFA recommends on their website ”alt om kost”, for example, that women of child-bearing age, and pregnant and nursing women eat no more than one portion of salmon from the Baltic Sea per month. Children who eat a lot of fish could exceed the maximum recommended intake.

Socio-economic effects – fishing from Bornholm

The existing limit values for dioxin in fish have particularly dire economic consequences for fishermen on Bornholm. The ban on catching salmon weighing more than 4.4 kg, before cleaning, for the entire Baltic Sea and the ban on herrings from the eastern Baltic has affected the industry. 25 Bornholm salmon fishermen have been affected by the ban on salmon weighing more than 4.4 kg and have received compensation from the Ministry of Food, Agriculture and Fisheries. As herring from the western Baltic may still be caught, the ban on catching fish from the eastern Baltic has not affected the total amount of fish that can be landed, as the same quota has been maintained.

2.3.12 Systems for assessment and inclusion of new substances under the Convention

In Denmark a number of reports have been completed in recent years which describe the use of a number of persistent organic pollutants in Denmark and the opportunities of limiting their use. A report on brominated flame retardants (including PBDE, PBB, TBBPA and HBCD) siloxanes, perfluorooctane acid (PFOA) and perfluorooctane sulfonates (PFOS) as well as related substances and selected PBT substances (persistent, bioaccumulative and toxic substances) and vPvB substances (very persistent and very bioaccumulative substances).

Within the EU, Denmark is working with the other Member States on assessment of new POPs, regulation of these within the EU, and nominating substances under the POP Protocol and the Stockholm Convention.

Footnotes

^[2] Consolidated Act no. 21 of 16 January 1996 from the Ministry of Environment and Energy on Chemical Substances and Products with subsequent amendments

^[3] Statutory Order no. 533 of 18 June 2003 with subsequent amendments

^[4] Statutory Order no. 820 of 29 September 2003 on certain persistent organic compounds

^[5] Statutory Order no. 925 of 13 December 1998 with subsequent amendments

^[6] Cf. section 3 of Ministry of Environment and Energy Statutory Order No. 718 of 9 October 1986 on limiting the use of PCB and PCT. The Statutory Order was replaced by the Statutory Order on PCB (no. 925 of 13 December 2000), cf. section 28

^[7] Statutory Order no. 533 of 18 June 2003 on pesticides with subsequent amendments

^[8] Statutory Order no. 162 of 11 March 2003. The Statutory Order implements a number of provisions in the Directive on the incineration of waste (Directive 2000/76/EC)

^[9] Statutory Order no. 480 of 19 June 2002. The Statutory Order implements a number of provisions in Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of-life vehicles

^[10] Commission Directive 2003/100/EC of 31 October 2003 amending annex I of European Parliament and of the Council Directive 2002/32/EC of 7 May 2002 on undesirable substances in animal feed

^[11] Source: Ærtebjerg et al. 2002. Marine områder 2001 - Tilstand og udvikling i miljø- og naturkvaliteten. NOVANA. (Marine areas 2001 – state and development of the quality of environment and nature).Technical report, NERI, no. 419, National Environmental Research Institute.

^[12] Source: Based on Hansen et al. 2003. Substance Flow Analysis for Dioxin 2002. Environmental Project no. 811. Danish EPA, Copenhagen.

^[13] Commission Regulation no. 466/2001 of 8 March 2001 setting maximum levels for certain contaminants in foodstuffs as regards dioxins and dioxin-like PCBs, as last amended by Commission Regulation (EC) no. 199/2006 of 3 February 2006.

^[14]      Source: Based on: Statusredegørelse for indsatsen mod dioxiner (Status report on measures against dioxins). Ministry of the Environment, Ministry of Family and Consumer Affairs, and Ministry of Food, Agriculture and Fisheries, 25 May 2005.

^[15] Source: Danish Institute for Food and Veterinary Research.“Dioxinhandlingsplan 2000-2004. Slutrapport” (Dioxin action plan 2000-2004. Final report; only available in Danish). Ministry of Family and Consumer Affairs, Danish Insitute of Food and Veterinary Research.

^[16] Directive 2002/32/EC of the European Parliament and the Council of 7 May 2002 on undesirable substances in animal feed.

^[17] BIPRO. 2005. Study to facilitate the implementation of certain waste-related provisions of the Regulation on Persistent Organic Pollutants (POPs). European Commission, Brussels.

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