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Possible Control of EU Priority Substances in Danish Waters 5 Assessment of DEHP
5.1 Definition of the reference state5.1.1 IntroductionDEHP (di(2-ethylhexyl)-phthalate; CAS no. 117-81-7)) is a substance belonging to the group of phthalic acid esters whose dominant technical function, as a group, is to act as a plasticizer in a variety of polymer products. DEHP almost exclusively has this technical function and is predominantly used for softening of PVC products. Environmentally, DEHP is a lipofilic (i.e. fat-soluble) substance with rather low water solubility and affinity to particulate (organic) matter. Also, the volatility of the substance is rather low. It is moderately degradable in the environment (soil and water) under aerobic conditions /1/. 5.1.2 Main uses and pollution sourcesBy far the largest use of DEHP is as a plasticizer in PVC products. Flexible PVC is used for the production of a wide range of products such as pipes and tubes, flooring and wall lining materials, sealants, various foils, cable and wire sheathing, tarpaulins, rain coats, rubber boots, shoes, toys, office supplies, catheters and other medical utility devices /2/. The sources of DEHP release to the aquatic environment comprise point sources as well as diffuse sources. The most important point source type is the discharge of effluents from municipal sewage treatment plants. The DEHP in domestic type sewage originates from the release of the substance from the mentioned products and materials by slow diffusion to the surface of the product/material from where it is washed off during cleaning operations or continuously if in direct contact with water (tubes and pipes). Other contributions of DEHP to sewage come from enterprises producing or using products and materials based on flexible PVC. DEHP also occurs in urban surface runoff, which is discharged either separately or, in the case of combined sewers, mixed with sewage and discharged together with this from the sewage treatment plants. The DEHP in surface runoff originates partly from releases from building materials and vehicles and partly from the diffuse atmospheric deposition of volatilised DEHP from all kinds of PVC products and materials. The total consumption of phthalates in Denmark was in 2001 approximately 11,000 tonnes of which by far the largest amount was used for producing flexible PVC /2/. There exists no separate figure for the consumption of DEHP but it is considered to be the quantitatively most important of the phthalates and it is the cheapest of the existing plasticizers for PVC /3/. However, recent information from DEPA /4/ indicates that the significance of the substance is decreasing (DEHP slowly being replaced by DINP). DEPA has assessed that in 2001 the most significant single use of phthalates was for cable and wire sheathing (3,400 tonnes) while the consumption for flexible pipes and tubes was about 1,260 tonnes /4/. About 340 tonnes were used for flooring and wall lining products and 3,450 tonnes for other uses. For two specific outdoor applications, tarpaulins and steel (roof) gutter coatings, the consumption was estimated to 870 tonnes and 1,300 tonnes respectively. It is assessed that today DEHP still constitutes at least half of the amount of plasticizers used in PVC and, hence, that the present annual consumption in Denmark is at least 5,000 tonnes. 5.1.3 Releases to and state of the aquatic environmentThe most important uses of DEHP leading to releases to the aquatic environment are considered to be flexible pipes and tubes, flooring and wall lining products, prints on textiles (plastisols), and, among the outdoor uses, underseal for cars and coating of roof gutters. Further, the combined diffuse contribution from a wide range of product categories to both sewage and urban surface runoff should not be underestimated. If combining the monitoring results presented in Table 5-1 below with the volumes of sewage effluent and sewage sludge in 2001 (/5/ /6/), the total release of DEHP from municipal sewage treatment plants to the aquatic environment in 2001 can be estimated to about 1.1 tonnes while the effluents from separate rain runoff systems contributed with about 4.8 tonnes. The amount of DEHP ending up in the sewage sludge was about 3.6 tonnes. The above value for rain runoff may be somewhat overestimated since the concentration in table 5-1 originates from data that are almost 10 years old, and the investigation was carried out in the Copenhagen metropolitan area (a highway and a residential area) where the load is considered to be higher than the average. Recent figures from separate runoff systems in two residential suburban areas in northern Jutland show ranges from 1.8-10 μg/L and 0.5-2.7 μg/L, respectively /10/ /11/. However, in both areas the traffic intensity as well as the contribution from general atmospheric deposition are considered to be rather low. The above calculation indicates that the largest contribution to the total load of DEHP on the aquatic environment comes from the about 10,000 discharge points from large or small separate surface runoff systems. Table 5-1 Monitoring data for DEHP (average or 50% percentile values). The values in parenthesis are the 95 % percentiles. References: /5/, /7/, /8/.
* Average value of 50% percentile values for five Danish lakes; max. value in parenthesis. EQS proposal The EQS value proposed for DEHP in the aquatic environment is AA-EQS = 1.3 μg/l (surface waters) while no MAC-EQS has been defined in the proposal (stated to be "not applicable"). 5.1.4 Existing legislation/regulation and their impactAct no. 954 of 20/12/1999 from the Ministry of Taxation on taxes on polyvinylchloride and phthalates with subsequent updates By this Act, which entered into force in 2000, tax was put on phthalates in a significant number of flexible PVC products including pipes and tubes (except for medical uses), electrical cables and wires, flooring and wall lining materials, foils and tarpaulins etc. i.e. most of the significant uses in Denmark. Assessment: No reporting has been published, which evaluates the effect of the taxation act on the consumption of DEHP or other phthalates for use in flexible PVC. However, five years having elapsed since the entry into force of the act, it is believed that the act cannot exert much more influence on the DEHP consumption. However, many products containing DEHP have a long life and, hence, it may take a considerable number of years before a possible reduced use of PVC plasticizers (or of flexible PVC as such) is reflected in the levels monitored in sewage effluents and other releases to the aquatic environment. Statutory Order no. 151 of 15/03/1999 from the Ministry of the Environment banning phthalates in toys for children aged 0 – 3 and in certain childcare articles. Articles aimed for use by children below three years of age must not contain DEHP or other esters of o-phthalic acid in concentrations exceeding 0.05%. This ban also includes inflatable bathing/swimming pools, beach toys and, since January 2004, inflatable safety jackets, bathing rings and bathing wings for children under three years. Assessment: It is assessed that the full (or close to full) effect of this statutory order has been achieved. Occasionally, however, cases will probably continue to be uncovered where imported products for children turn out to contain DEHP or other phthalates. Statutory Order no. 786 of 11/07/2006 from the Ministry of the Environment Toys and childcare articles for use by children below 14 years of age must not contain DEHP, DBP or BBP in concentrations exceeding 0.1%. This ban includes all types of toys and childcare articles which are included in the Toys Directive 88/378/EEC. Assessment: This Statutory Order, which is by virtue of the 22nd amendment of Council Directive 76/769/EEC, will come into force January 2007. The order is not believed to have any significant influence on the overall level of DEHP in releases and discharges into the aquatic environment. Statutory Order no. 74 of 14/01/2005 from the Ministry of the Environment on cosmetics According to this recent statutory order, DEHP and other phthalates are not permitted for use in cosmetic products. Assessment: This regulation is very new and cannot yet be expected to have been fully enforced, especially because many cosmetic articles are imported. However, the impact of this ban on the releases of DEHP to the aquatic environment, even when DEHP has become fully phased out of cosmetic products, is believed to be relatively insignificant as DEHP is probably not in general an important constituent of cosmetic products. Statutory Order no. 439 of 3 June 2002 from the Ministry of the Environment on the list of dangerous substances Since 1 July 2002 DEHP has been on the so-called "List of dangerous substances" as harmful to reproduction as well as posing a teratogenic risk. The listing implies that products such as paint, glues and cleaning agents etc. must not be sold in retail stores if the content of DEHP in the product exceeds 0.5%. Assessment: The List of dangerous substances is not believed to have the same judicial power as a specific statutory order and can therefore not in itself be expected to lead to a complete phase-out of such products in retail sale. However, the bad publicity associated with the possible uncovering of violations will probably have a preventive effect. 5.1.5 Conclusion on the need for further regulationThe 50% percentile level of DEHP in sewage treatment plant effluents is presently only approx. 40% higher than the proposed AA-EQS while the 95% percentile level requires an initial dilution of 4.7 times to comply with the AA-EQS. As the decreasing trend in the use of DEHP can be expected to continue and as by far the largest volume of Danish sewage effluents are discharged at locations where the initial dilution is (significantly) more than 5 times, it is assessed that no further national measures are required to achieve AA-EQS compliance for this type of release to the aquatic environment. To evaluate the possible need for measures in relation to discharges of untreated stormwater from separate systems the concentrations of DEHP observed in this type of discharges (see table 5.1) should be compared to the MAC-EQS. As, however, such a MAC value has not been defined, the evaluation cannot be carried out at present (the AA-EQS is not considered suitable for this purpose). The monitoring data from Danish lakes indicate that on the average the existing levels easily comply with the AA-EQS while the highest value observed was 2.7 times higher than the AA-EQS. Thus, there appears to be no need for further measures to be able to comply with the proposed EQS values for DEHP and thereby not either a need for further progressive reduction in Scenario A. Further, it is assessed that the existing Phthalate Action Plan /9/ fulfils the requirement of Scenario B to continue progressive reduction beyond the EQS compliance level. In conclusion, and as DEHP is not classified as a priority hazardous substance, there appears to be no need for further national regulation, neither in relation to Scenario A nor to Scenario B. 5.2 Possible reduction/elimination measures5.2.1 Technical measures to reduce/eliminate DEHPThe Phthalate Action Plan comprises proposals for initiatives within practically the whole span of uses of phthalates in flexible plastic products, predominantly PVC. In relation to protection of the aquatic environment, the following are considered to be the most central areas for action:
Regarding the two former, the Action Plan mentions that alternatives have been identified but that these are more costly to use than DEHP. Therefore, it is suggested in the plan to impose a tax on phthalates for these uses as an incentive to speed up the process of substituting DEHP with alternative substances. Plastisols for textile prints is recognised as a complex area with many imported products and where common EU action is needed in order for the possible measures to be effective. Danish initiatives in support of this have been announced. The plan mentions that alternative underseal products for cars without phthalates exist, but that these are not without problems. Also within this area DEPA suggests to work actively for common regulatory measures in the EU. Additionally, since the launching of the Action Plan, fully galvanized car bodies, for which undersealing is unnecessary, have become much more common in the international manufacturing of cars. As mentioned earlier, the existing Phthalate Action Plan appears to comprise ideas and initiatives within all relevant areas of DEHP/phthalate use and, hence, there seems to be no need for additional initiatives (only common follow-up) in consequence of the requirements in Scenario A/C or B. Stormwater runoff As mentioned in section 5.1.3, the dominant source of release to the aquatic environment appears to be stormwater runoff from separate systems affected by diffuse sources of DEHP. Therefore, an initiative to reduce this input could be considered though the need in relation to compliance with a MAC-EQS cannot be evaluated at present and though it is considered technically as well as economically unrealistic to introduce measures specifically aimed at reducing DEHP or phthalates in stormwater runoff. The majority of the PS/PHS including DEHP are characterised by properties such as lipofilicity and significant sorption onto particulate (organic) matter. Therefore, it is assessed that technological measures that generally aim at retaining suspended particles in surface runoff will significantly reduce the loads of DEHP and many other PS/PHS on the aquatic environment. Since this type of measure is not substance specific, it is described technically and assessed economically in a separate chapter (Chapter 13). 5.2.2 Possible synergies with other (priority) substancesThe specific measures against DEHP/phthalates contained in the Phthalate Action Plan are not assessed to have any significant bearing on the other substances included in the proposed directive's list of PS/PHS. However, a possible general action against suspended matter/pollutants in stormwater runoff will not only lead to a significant reduction in DEHP inputs to the aquatic environment but also in most of the other PS/PHS. 5.2.3 Summary and assessment of technical possibilitiesIt is assessed that there is no need for additional initiatives to the Phthalate Action Plan to meet the directive's requirement to progressively reduce the pollution or emissions/discharges/losses of DEHP. However, a combined, general action against pollutants in stormwater runoff from roads, roofs etc. will have a beneficial impact on the total load of DEHP on the aquatic environment. 5.3 Economic AssessmentNeither the implementation of Scenario A/C nor Scenario B will imply costs additional to the costs resulting from implementing the Phthalate Action Plan (the reference state/Scenario 0). There is therefore no difference in cost between implementing the two scenarios. The cost of general action against suspended matter/pollutants in stormwater runoff is estimated after the substance-specific chapters in this report. 5.4 Conclusion regarding DEHPAccording to the monitoring data available, the concentrations of DEHP in various wastewater discharges as well as in surface waters do not pose a problem in relation to compliance with the proposed AA-EQS. Stormwater discharge is assessed to be the largest direct source of DEHP releases to surface waters in Denmark. However, as no MAC-EQS has been defined for DEHP, the possible need for further measures aimed to reduce the inputs from this type of source to the aquatic environment has not been evaluated. Because of the initiatives and actions included in the already existing Phthalate Action Plan it is assessed that there no need for additional national initiatives to meet the requirements of Scenario B or Scenario A. Therefore, it is concluded that implementation of the requirements of Scnenario A or Scenario B will not imply additional costs on Denmark with regard to DEHP. 5.5 References/1/ Kjølholt J, Winther Ringgaard K, Skårup S (2006). Kilder og miljøtilstand for prioriterede stoffer under Vandrammedirektivet. Miljøprojekt nr. XXXX (in press). Danish Environmental Protection Agency. /2/ Skårup S, Skytte L (2003). Forbruget af PVC og phthalater i Danmark år 2000 og 2001. Kortlægning af Kemisk Stoffer i Forbrugerprodukter, nr. 35, 2003. Danish Environmental Protection Agency. /3/ Plastindustrien i Danmark (1996). Redegørelse om phthalater i blød PVC. /4/ Miljøministeriet (2003). Status for phthalater. /5/ Miljøstyrelsen (2004). Punktkilder 2003. /6/ Miljøstyrelsen (2003). Spildevandsslam fra kommunale og private renseanlæg i 2000 og 2001. Orientering nr. 9, 2003, fra Miljøstyrelsen. /7/ Miljøstyrelsen (1997). Miljøfremmede stoffer i overfladeafstrømning fra befæstede arealer. Miljøprojekt nr. 355. /8/ DMU (2004): Søer 2003. Faglig rapport nr. 516 fra DMU. /9/ Miljø- og Energiministeriet (1999). Handlingsplan for at reducere og afvikle anvendelsen af phthalater i blød plast. /10/ Arnbjerg-Nielsen et al. (2002). Bearbejdning af målinger af regnbetingede udledninger af NPO og miljøfremmede stoffer fra fællessystemer i forbindelse med NOVA 2003. Miljøprojekt nr. 701, 2002. /11/ Miljøstyrelsen (2006). Målinger af forureningsindhold i regnbetingede udledninger. Arbejdsrapport fra Miljøstyrelsen Nr. 10, 2006.
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