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National Implementation Plan – Stockholm Conventionen on Persistent Organic Pollutants

3 Strategy and action plan elements

• 3.1 Political letter of intent:
• 3.2 Implementation strategy:
• 3.3 Activities, strategies and action plans
  • 3.3.1 Measures to reduce or eliminate releases from intentional production and use of POPs covered by annex A and annex B
  • 3.3.2 Measures to reduce or eliminate releases from intentional production and use of annex B substances (DDT)
  • 3.3.3 Measures to reduce or eliminate releases from intentional production and use of PCB (annex A substances)
  • 3.3.4 Specific exemptions regarding production and use of POPs covered by annexes A and B
  • 3.3.5 Action plan for reduction of releases from unintentional production of dioxin, PCB and HCB
  • 3.3.6 Measures to reduce or eliminate releases from stockpiles, waste and contaminated sites
  • 3.3.7 Listing of new chemical substances in annexes A, B and C
  • 3.3.8 Exchange of information and public information
  • 3.3.9 Research, development and monitoring
  • 3.3.10 Financial and technical assistance to other countries
  • 3.3.11 Effectiveness evaluation
• 3.4 Institutional and regulatory strengthening and prioritised areas
• 3.5 Costs
• 3.6 Timetable

3.1 Political letter of intent:

The effort against harmful chemicals has since many years been a high priority for Denmark. The objective is, in accordance with the Danish national strategy on sustainable development from 2002 Ashared future - balanced development, that we towards 2020 continuously abolish chemicals that have harmful effects on human health and the environment. The high priority is reflected in the fact that all the substances listed under the Stockholm Convention that are subject to intentional production are banned in Danmark, and for the most part have been so for a number of years.

The remaining challenge for Denmark concentrates on the unintentionally produced POP substances and international regulation of further POP-substances uder the Convention. The efforts in this regard will be continued.

The Government will continue to work for the minimization of the burden on human health and the environment from POP substances, nationally as well as in international fora, on the basis of the precautionary principle and the principle of substitution.

3.2 Implementation strategy:

Denmark has since the 1980’ies continuously intensified the efforts in the chemicals area. The purpose is to reduce the risks to human health and the environment that are connected with the use of chemicals. This is especially done through efforts at the international level, Danish regulation, enforcement sanctions and by providing citizens and enterprises with greater knowledge on chemicals.

POP substances today comprise an integrated part of the existing systems and strategies for regulation, approval, monitoring and handling of waste in relation to chemicals. In implementing the Stockholm Convention, it is therefore not necessary to strengthen the institutional or regulative framework for the handling and monitoring of POP substances in Denmark.

The implementation of the obligations of the Stockholm Convention on POP substances and POPs waste is also characterised by a close interplay between EU regulation and measures on the one hand and national regulation and measures on the other.

The Stockholm Convention is implemented by Regulation no. 850/2004 on persistent organic pollutants, which supplements the already considerable EU legislation on POPs. The regulation is automatically a part of Danish law.

Denmark to a high extent implements the obligations of the Stockholm Convention through existing regulation, strategies and programmes, and the implementation plan therefore contains relatively few new initiatives.

The Danish implementation plan has been elaborated by the the Danish Environmental Protection Agency under the Ministry of the Environment. The unit on Chemicals Conventions and Pesticides, which has also been appointed focal point for exchange of information in accordance with article 9 under of the Convention, will on a regular basis and in accordance with the recommendations under the Convention review and revise the plan.

3.3 Activities, strategies and action plans

The following section presents a number of activities, strategies and action plans which describe how Denmark is implementing the Stockholm Convention. Each substance area topic follows more or less the same structure:

• Reference to the provisions in the text of the Convention applicable for the area in question;
• Status of manufacture and use of the relevant POPs, or the current situation in the area affected, including the relevant implementation legislation and the occurrence of the substances in food, nature etc.;
• Initiatives in progress (activities, projects, programmes etc.) in the area;
• Planned new initiatives in the area.

The section on reduction of releases from unintentional production of dioxins and furans, PCB and HCB deviates from this structure, as a reference is made to the separate action plan on this issue in annex 1.

3.3.1 Measures to reduce or eliminate releases from intentional production and use of POPs covered by annex A and annex B

Convention provisions

Article 3 of the Stockholm Convention supplemented by annex A (part 1) and annex B.

Status

Implementation legislation. The requirements of the Convention have been implemented in article 3(1) of the POP Regulation. The bans in the Regulation are stricter than in the Convention as the Regulation bans manufacturing, placing on the market and using the nine POPs covered by the ban in the Convention and DDT, which is only limited under the Convention, as well as three of the other four substances covered by the POP Protocol. The bans in the POP Regulation are supplemented by the Danish Chemicals Act, the Statutory Order on Pesticides, and the Statutory Order on POPs.

The Chemicals Act bans placing on the market and use of the nine pesticides in plant protection products, while sales, imports and other uses of the substances are banned under the Statutory Order on POPs.

Production and use. As mentioned in section 2.3, only DDT, aldrin, dieldrin, endrin and heptachlor have been used in Denmark. Of these, only DDT and dieldrin have been used extensively. The other substances have only been sold in small amounts and quickly fell out of the market. None of the substances have been marketed for many years.

New initiatives and initiatives in progress

As a result of the low or non-existent occurrences of substances in foodstuffs, waste products, the environment and the groundwater (see section 2.3.1), no further initiatives will be taken in the area of POP pesticides.

3.3.2 Measures to reduce or eliminate releases from intentional production and use of annex B substances (DDT)

For the sake of simplicity, annex B substances (DDT) have been mentioned with other pesticides in the section above.

3.3.3 Measures to reduce or eliminate releases from intentional production and use of PCB (annex A substances)

Convention provisions

Article 3 and annex A, parts 1 and 2 of the Stockholm Convention, including the commitment to dispose of equipment containing or contaminated with PCB by no later than 2028.

Status

Implementation legislation. The commitments in the Stockholm Convention have been implemented in article 3(1) of the POP Regulation and in the Statutory Order on PCB (see section 2.4). The Statutory Order on PCB contains stricter regulations than those in the Stockholm Convention with regard to the date for decontamination and/or disposal of equipment containing PCB. The Statutory Order requires that large types of equipment must be decontaminated and/or disposed of as soon as possible and no later than 1 January 2000.

Production and use. PCB has never been produced in Denmark. PCB was used for a period for various technical purposes and in equipment. In 1977 use of PCB was banned for ”open uses”, i.e. paint, fillers, self-copying paper etc. In 1986 a total ban was introduced on selling PCB and apparatus and other products containing PCB. 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.

Initiatives in progress

In 2005, the Danish EPA initiated a study on the occurrence of PCB in building materials. The results of the study are not yet available.

Planned new initiatives

When the results of the above study are concluded, the necessity for further measures in the area will be considered.

3.3.4 Specific exemptions regarding production and use of POPs covered by annexes A and B

Convention provisions

Article 3 and annex A, parts 1 and 2 of the Stockholm Convention

Status and plans on registration of exemptions

Implementation legislation. The very limited general exemptions from the provisions on production, placing on the market and use in article 3(5) and annexes A and B of the Convention have been implemented in article 4 of the POP Regulation. There is a general exemption for amounts of substances used for research at laboratory level or as reference standards, or occurring as unintentional trace contaminants in products and articles.

Except for the general exemption for amounts of substances used for research at laboratory level or as reference standards, Denmark does not apply the exemptions in the Convention or the Regulation.

Plans. On acceding to the Convention, Denmark did not register for specific exemptions regarding production and use of the substances for which exemption provisions exist. There are no plans to register such exemptions in the future.

3.3.5 Action plan for reduction of releases from unintentional production of dioxin, PCB and HCB

An action plan for reduction of releases from unintentional production of dioxin, PCB and HCB is placed in annex 1 to this implementation plan.

3.3.6 Measures to reduce or eliminate releases from stockpiles, waste and contaminated sites

Convention provisions

Article 5 of the Stockholm Convention.

Status

Implementation legislation. The provisions in the Convention on POP stockpiles have been implemented in article 5 of the Regulation, which follows from article 6(1)(a)-(c) of the Convention and states that stockpiles of POP must be identified and managed in an environmentally appropriate manner, see also section 2.2.4.

The requirements in the Convention for waste management have been implemented in article 7 and annex V of the Regulation, which contain a number of specific waste-management provisions, see also section 2.2.4.

Management of POP waste: Waste containing PCB and any other POP waste is hazardous waste. Management requirements have been stipulated in the Statutory Order on Waste and the WEEE Order, which are described in more detail in section 2.2.4.

Transfrontier shipments of waste are covered by Council Regulation (EEC) no. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community, see also section 2.2.4.

Stockpiles: It is unlikely that there are stockpiles of obsolete POP pesticides in Denmark.

Initiatives in progress

As mentioned earlier, the Danish EPA has initiated a study of the occurrence of PCB in building materials. The results of the study are not yet available.

Planned new initiatives

Denmark expects to decide how flue gas purification waste is to be managed in the future.

When the results of the current study on PCB mentioned above are available, the necessity for further work in the area will be considered.

3.3.7 Listing of new chemical substances in annexes A, B and C

Convention provisions

Addition of new substances in annexes A - C follows the procedures in article 22(4).

Status

Implementation provisions: The procedures for incorporation of new substances to the Regulation are described in article 14 of the Regulation on amending the annexes.

Proposal for Council Decision on incorporation of new substances: Work to identify and investigate new substances for listing under the POP Protocol and the Stockholm Convention primarily takes place within the EU in interplay between Member States and the Commission.

In 2004, the Commission prepared a proposal for a Council Decision on a proposal to nominate nine new substances for listing under the POP Protocol and the Stockholm Convention. In 2005 the proposal was changed to a Council Decision which included the following five substances for listing under the POP Protocol: hexachlorobutadien, polychlorinated naphthalenes, octabromodiphenyl ether, pentachlorobenzene and short-chained chloroparaffins. Most recently, a Council Decision on nominating three substances for the Stockholm Convention was adopted, which covers the three latter substances covered by the Council Decision on nominations under the POP Protocol.

Sweden has nominated perfluorooctanyl sulphonate (PFOS) for the Stockholm Convention.

Initiatives in progress

Denmark would generally like to see relevant POPs covered by international regulation. Denmark welcomes inclusion of relevant substances in the annexes to the POP Protocol and the Stockholm Convention and will work to have the substances included in the lists of substances.

The ten substances under consideration in the EU and their uses are briefly described in the following table.

Table 3.1
Substances considered in proposals for new substances in the POP Protocol and the Stockholm Convention

Beside the studies on the 10 substances indicated above, Denmark has also carried out a number of investigations in recent years, describing applications of a number of persistent organic substances in Denmark, and the possibilities for limiting uses of the substances. Investigations have been made of brominated flame retardants (including the substances/substance groups PBDE, PBB, TBBPA and HBCD), siloxanes, perfluoro-octane acid (PFOA) and perfluoro-octane sulfonates (PFOS), and related substances and selected PBT substances (persistent and bioaccumulative toxic substances and vPvB substances (very persistent and very bioaccumulative substances).

Planned new initiatives

Denmark will carry out regular assessments on whether new substances should be proposed for inclusion in the POP Protocol and the Stockholm Convention substance annexes.

3.3.8 Exchange of information and public information

Convention provisions

Articles 9 and 10 of the Stockholm Convention.

Status

Implementation legislation: Provisions of the Convention on information exchange, public information etc. are incorporated in article 10 of the Regulation.

Information exchange: Information on problems relating to POPs is disseminated at many levels and in many fora.

In most cases, information on POPs forms part of broader initiatives including other dangerous substances.

New initiatives and initiatives in progress

Intentional use of POPs included in the Stockholm Convention has been banned for all substances for a number of years, and it is not considered necessary to give special information to the public on the use and disposal of these substances.

All results of monitoring of POPs in the environment and in foodstuffs, emissions inventories, and reviews, investigations and studies on POPs will continue to be published on the website of the relevant institutions, and, thus, be available to the public.

Under the Nordic environmental action programme, Nordic working groups have been set up for the various substance areas. The groups exchange information and initiate studies, for instance on the costs in EU countries in relation to the use of PCB. Through membership of the EU, Denmark is taking part in information exchange with the other Member States on a continuous basis on a number of issues involving POPs.

Measures will be taken to update and extend information on POPs in existing relevant educational material on chemicals, targeted in particular towards young people.

3.3.9 Research, development and monitoring

Convention provisions

Article 11 of the Stockholm Convention.

Current monitoring initiatives

POPs are included in ongoing monitoring programmes for environmentally dangerous substances and releases from point sources carried out by NERI. The Department of Arctic Environment at NERI also monitors pollutants in the Arctic environment, e.g. in connection with the Arctic Monitoring and Assessment Programme (AMAP).

Current monitoring of POPs in foodstuffs and assessment of possible risks to health is in the hands of the Danish Institute for Food and Veterinary Research. Current monitoring of dioxin and dioxin-like PCB in animal feed is in the hands of the Danish Plant Directorate, and from 2005, the Plant Directorate has taken part in a harmonised EU programme on mapping, monitoring and control of dioxin, dioxin-like PCB and PCB in animal feed.

Emissions of POPs from industrial installations are recorded on a continuous basis in the Danish EPA register of the environmental situation of installations, which forms part of the joint European Pollutant Emission Register, EPER.

Current research initiatives

Denmark is engaged in extensive research in connection with the occurrence of POPs and their impact on the environment, animals and humans. Much of this research addresses the effects of POPs in the Arctic environment, and takes place within the international work under AMAP (Arctic Monitoring and Assessment Programme). Some of the initiatives are financed by the Danish EPA Arctic assistance programme, DANCEA. Denmark takes part in the AMAP biological time trend programme, which monitors the development of concentrations of POPs in a number of species.

POPs are included in a number of investigations at NERI, Department of Arctic Environment, for instance on the occurrence of ”new” POPs in the Arctic marine environment. Monitoring focuses on brominated flame retardants, polychlorinated naphthalenes (PCN), perfluorooctane sulfonate (PFOS) and synthetic musk compounds, and analyses of samples of air to determine long-range transport of polybrominated diphenyl ethers (PBDE)) and polychlorinated naphthalenes to the Arctic.

The Environmental Medicine research unit at the Institute of Healthcare Research, University of Southern Denmark, is carrying out a research project ”Children’s Health and the Environment in the Faeroes”. The project is investigating the presence of PCB and chloroorganic pesticides (including dieldrin, DDT/DDE and HCB) in children in the Faeroe Islands. The research unit is also studying possible effects of exposure to PCB.

The Center for Environmental Medicine of the University of Aarhus is carrying out experimental and epidemiological studies of the effects of a number of environmental toxins, including PCB in the Arctic. Epidemiological studies include monitoring of human impacts from PCB in Greenland as part of the AMAP programme. The Center also acts as the secretariat for the AMAP Human Health Expert Group, and is chairman of the group.

The research group for ecotoxicology at the Biological Institute, University of Southern Denmark deals with methods of screening chemicals with endocrine effects. A number of the POPs have other undesired effects, including a documented endocrine-disrupting effect.

So far, ongoing initiatives regarding monitoring of POPs are considered sufficient to ensure assessment of the pressure on humans and the environment on a continuous basis.

Planned new initiatives

The Danish EPA will continue work to support research initiatives taken to investigate occurrences of POPs in the Arctic environment, and their impact on animals and humans. Investigations include POPs covered by the Stockholm Convention, as well as potential candidates for inclusion under the Convention.

The Danish EPA is studying the degradation of dioxins in the Baltic Sea, aiming at determining the degree to which dioxins accumulated in fish originate from atmospheric depositions, or whether they are due to dioxins being remobilised and released from the seabed.

Finally, the Danish EPA will investigate sources of dioxins in organic farm units.

3.3.10 Financial and technical assistance to other countries

Convention provisions

Article 12 of the Stockholm Convention.

Status

Implementation legislation. Provisions on technical assistance are set out in article 11 of the POP Regulation. This article establishes the Commission’s and the Member States’ general obligation to provide technical assistance to developing countries and countries with economies in transition. Assistance may also be provided through non-governmental organisations.

Technical assistance provided so far. Since 1989, Denmark has provided assistance for enhancement of the environment in the new democracies in Central and Eastern Europe. The main objective of assistance has been to contribute to protecting the environment in Eastern Europe, by supporting accession candidate countries in their efforts to implement EU regulation on the environment, and international environmental conventions. Further, Denmark has helped CIS countries and other non-EU-applicants reduce human exposure to pollution, reduce transboundary pollution, and protect nature and biodiversity.

Assistance has been provided primarily as bilateral assistance, but some of has been channelled through the Arctic Monitoring and Assessment Programme (AMAP) and the Arctic Council Action Plan to Eliminate Pollution of the Arctic (ACAP), UNEP and NEFCO.

Assistance in the POPs area has targeted projects relating to pesticides, PCB and dioxins. Assistance has been provided for mapping and managing pesticides, including disposal of POP pesticides and obsolete stocks of pesticides. For PCB, assistance has focused on mapping PCB consumption and management, action plans for collection, storage and disposal of PCB, and studies of alternatives to PCB. Assistance has also been provided for mapping dioxin emissions in several countries, and to a technical, environmental and socio-economic review of alternative disposal technologies. The bilateral support to new EU members has been phased out in step with their accession to the EU in 2004.

Denmark has provided bilateral assistance to environmental work in the developing countries, besides via the EU, see also the section below on current initiatives.

Financial assistance. The Global Environment Facility (GEF) is financing projects and programmes within biodiversity, climate change, marine pollution, ozone depletion, desertification and POPs. In the period 2001-2004, GEF has financed POP projects with support amounting to more than USD 141 mill. with co-financing amounting to USD 91 mill. The large majority of funds were used to finance preparation of action plans in the developing countries and countries with economies in transition. In recent years, Denmark has increased its contribution to GEF. Denmark contributes through its general GEF contributions, which,cover a number of POP projects. Denmark has in recent years increased its contributions to the GEF.

Current initiatives

Through its general contributions to the EU budget, Denmark also contributes to EU work in developing countries and countries with economies in transition, for instance TACIS programmes, of which some deal with POP problems.

To supplement efforts made via the EU and GEF, Denmark has allocated approx. DKK 850 mill. for the years 2004-2007 towards an overall Danish neighbourhood initiative in the new EU Eastern neighbours, focussing especially on the Baltic Sea region and the Balkans. Of this amount, DKK 81 mill. will cover projects primarily in Eastern Europe. Assistance is granted primarily to Russia, and also to Ukraine, Rumania, and Bulgaria.

A detailed strategy for spending the funds in these countries has not yet been prepared. However, it is expected that some of them will address activities relating to POPs. An overall study is currently being carried out in order to identify possible projects on POPs, heavy metals and other hazardous substances in Russia, Ukraine and China. Further, a project is being carried out in Russia, in Leningrad, Oblast and St. Petersburg, on collection and storage of PCB-containing electrical equipment, and another project on environmentally safe management of obsolete stocks of pesticides in Pskov and Vologda Oblast’s. It is expected that these two projects will be completed in a couple of years.

For a number of developing countries, Danish assistance is directed towards enhancement of the environment. In some countries it has also included POP-related problems, such as mapping and disposal of obsolete stocks of pesticides in southern Africa. Activities are supported primarily through contributions to the extensive African Stockpiles Programme implemented by the World Bank, with a total budget of USD 250 mill. Denmark has contributed DKK 15 mill. In addition, assistance is being provided to Malaysia for the development of regulatory capacity regarding hazardous chemicals, including implementation of chemicals-related environmental conventions.

Planned new initiatives

In the future, Danish assistance to POP-related activities will primarily be channelled through GEF, which for the time being is appointed financial mechanism for the Stockholm Convention. Estimates are not available today on the scope of resources to be provided by industrial countries to the financial mechanism in order to assist developing countries and countries with economies in transition in their efforts to meet the requirements under the Convention. Therefore, there is no indication of the funds to be reserved for implementing the Stockholm Convention under GEF. It should be noted that specific national contributions are not charged for the financial mechanism under the Convention.

Further, Denmark contributes to the Stockholm Convention secretariat. The size of contributions depends on the number of parties to the Convention, calculated at USD 44,879 in 2006, and USD 32.210 in 2007, when more countries are expected to have ratified the Convention.

Assistance for implementing regulation of POPs may to a limited extent be included in general assistance for capacity building in environmental authorities in Denmark's programme cooperation countries, if the countries prioritise this.

3.3.11 Effectiveness evaluation

Convention provisions

Article 16 of the Stockholm Convention.

It is most likely that the schemes will be implemented by the Parties on a regional basis in accordance with their technical and financial capabilities, using existing monitoring programmes and mechanisms as far as possible. Results of the monitoring activities on a regional and global basis must be reported to the Parties to the Convention.

The Parties to the Convention have also invited relevant organisations to cooperate on this task, by providing data for the evaluation. Moreover, the secretariat has been asked to test the schemes at national and regional levels, and to present the results of the test at the third meeting of the Parties to the Convention.

New initiatives and initiatives in progress

As described in this implementation plan, Denmark is engaged in various monitoring activities on POPs in foodstuffs, animal feed, waste products, groundwater, and the environment in general. Moreover, through AMAP, Denmark is monitoring POPs in the Arctic environment. Denmark will await the decisions of the Parties to the Convention on which data to be reported and on other elements to be included in the evaluation of effectiveness, and will adjust initiatives to such decisions.

3.4 Institutional and regulatory strengthening and prioritised areas

There is not considered to be any need for strengthening the institutional and regulatory framework for managing and monitoring POPs in Denmark.

Since problems with POP pesticides and PCB are assessed to be either solved or fairly limited in Denmark, highest priority is given to the following areas in order to meet the commitments under the Convention:

• Further reduction of releases of dioxin and other unintentionally formed POPs, and improved inventories of emissions of unintentionally formed POPs, as stated in annex 1, the action plan;
• Studies of other substances with POP properties, with a view to nominating substances for inclusion in the annexes to the Convention;
• Continued studies of impacts of POPs in and on the environment, animals and exposed population groups, focusing in particular on the Arctic.

Activities within these areas can be carried out within existing institutional structures.

3.5 Costs

Additional costs relating to Denmark’s accession to the Stockholm Convention are considered to be linked primarily to Denmark’s contribution to the functioning of the secretariat, and to GEF.

This is due to the fact that the majority of the measures required to meet the commitments under the Convention have already been taken, and further, that POPs have for many years ranked high on the agenda, and form an integral part of current monitoring and research programmes.

Major elements of the costs relating to ongoing POP-related activities are:

• Maintenance and operation of installations to reduce emissions of dioxin and other unintentionally formed POPs, and disposal of residues from flue gas purification;
• Monitoring of POPs in emissions, in the environment, in foodstuffs, and in animal feed;
• Destruction of PCB-containing equipment and clean-up of PCB-contaminated sites;
• Ban on fish with excessive levels of dioxin. This measure does not implement provisions of the Stockholm Convention, but EU regulation;
• Programmes to investigate the occurrence and effects of substances with POP properties on humans and in the environment;
• Programmes to assess the possibilities of reducing emissions from burning biomass;
• Technical assistance to POP-related activities to party countries with economies in transition, and to developing countries.

3.6 Timetable

The implementation plan will be realised on the basis of the following timetable, not including, however, measures regarding unintentional substances according to annex C of the Convention. These substances are covered by the action plan in annex 1.

Table 3.2 Timetable for new initiatives

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Version 1.0 June 2006, © Danish Environmental Protection Agency