Miljøprojekt, 1134 – Evaluation of the Danish Statutory Order on Lead – 7 Uses in conflict with the Statutory Order on Lead

Evaluation of the Danish Statutory Order on Lead

7 Uses in conflict with the Statutory Order on Lead

7.1 Primers for bolt guns etc.
7.2 Equipment which could be imported illegally

As part of work to assess the need to revise the Statutory Order on Lead, certain existing or possible uses of lead have been recorded which in fact contravene the Lead Order. These uses are listed below.

7.1 Primers for bolt guns etc.

There was an exemption for lead in primers for bolt guns used, for example, to secure bolts and nails in concrete. This exemption applied until September 2005.

In this use, lead is a component in the primer for the cartridges. The primer is composed of several different chemical compounds, listed in the safety data sheet for the cartridges [Hovang, 2005]. According to the safety data sheet from the manufacturer Hilti, dated 30 May 2002, the cartridges contain lead 2,4,6-trinitroresorcinolate (CAS No. 15245-44-0), or lead styphnate as it is also called.

Lead is used to achieve the greatest degree of safety and to contain the explosion. Not using lead styphnate would just mean an explosion could be caused and the cartridge would be lost [Hovang, 2005].

Lead styphnate and possibly other lead compounds in the primer or detonator cap are general in ammunition. Detonator caps for ordinary ammunition are not produced in Denmark, and they are imported from Germany. Therefore, Danish ammunition manufacturers do not always know the complete composition of caps and may use lead unintentionally [Hansen, 2005].

The supplier for most Danish manufacturers states that, with regard to lead, a detonator cap contains 24 mg "Zenoxid", which contains 37-48 % lead styphnate and possibly lead oxide [Hansen, 2005].

The weapons industry in the US is working to find substitutes for lead, but so far it has not been able to find anything as stable as lead. It is therefore difficult to identify substitution possibilities [Hansen, 2005].

As far as is known, lead is also contained in detonators for explosives. There may typically be 0.02 – 0.37 g lead azide in each detonator [Schneider 2005].

Evaluation
It is likely that the use of lead compounds in primers in ammunition is widespread and therefore there are lead compounds in most types of ammunition, and possibly all. However, only few users are aware of this. Therefore exemption has only been applied for with regard to bolt guns. In fact all importers of ammunition and detonators should have applied for exemption.

There do not seem to be any practical substitutes under development. Therefore an exemption is required for the area. Such an exemption should be reassessed after a certain number of years.

7.2 Equipment which could be imported illegally

The study has become aware of the following examples of illegal imports or risks of illegal imports of lead-containing products.

Electrical cables

NKT has stated that foreign cables are sometimes marketed in Denmark as being lead-free. However, studies show that some of these cables do contain lead, and this may be because the foreign manufacturer has chosen cheap lead stabilisers for the PVC component instead of the more expensive lead-free alternatives such as calcium/zinc –stabilisers [Thiesen, 2005/06].

PVC products

As regenerated PVC with lead stabilisers is used in Germany and possibly other countries to manufacture PVC pipes and fittings, imports of lead cannot be ruled out in these products made of lead-containing regenerated PVC-granulate. However, the PVC industry considers that this illegal practice has stopped with regard to fittings and pipes [Grøndahl 2005].

The situation is more serious on this point for PVC windows. Many lead-containing windows and window profiles do appear on the Danish market. They primarily come from Germany, where production of windows with lead-containing PVC has not yet ceased. This is a great nuisance to Danish manufacturers of windows as they have invested tens of millions of DKK in substituting lead in their windows. They are now facing competition from illegally imported and cheaper windows and window profiles. Production of lead-containing windows in Germany and other countries will cease in 2015 according to the PVC industry’s voluntary environmental programme, Vinyl 2010. However, there is no indication that the use of lead-containing regenerate in Europe will be regarded as undesirable in the future [Grøndahl 2005].

Evaluation
As Denmark has introduced tighter regulation on the use of lead than neighbouring countries, there will always be a risk of illegal imports of products containing lead. The risk is present for most product groups where lead-free alternatives are more expensive than products containing lead and it can only be contained through control.