Guidance for the inventory of perfluorooctane sulfonic acid (PFOS) and related chemicals Update of the national implementation plan for the Stockholm Convention 24-Jan-12

2 The listing: Global phase out of PFOS with aim of elimination PFOS fulfills the POP criteria of the Stockholm Convention: – has a capacity to undergo long-range transport – is very toxic – extremely persistent – has substantial bioaccumulations and biomagnifying properties – although it does not follow the classic pattern of other POPs by partitioning into fatty tissues, but instead binds to proteins, e.g. in the blood and liver Molecules containing the PFOS moiety can be a precursor to PFOS. PFOS can be formed by environmental microbial degradation or by metabolism in larger organisms from PFOS-related substances Studies have indicated adverse effects of PFOS-related substances on reproductive health for humans (fewer normal sperm, delayed pregnancy) and developmental effects (reduced foetal growth, reduced size and weight at birth)

3 The listing in the Convention The listing includes PFOSF, PFOS, its salts and related substances PFOSF is the basic material for the manufacture of PFOS and its related substances PFOS is a fully fluorinated sulfonate with eight-carbon chain length PFOS related substances refers to a larger group of substances, which may degrade to PFOS 165 PFOS-related substances have been identified by OECD

4 Obligations Ban on export, import, use and production of PFOSF, PFOS, its salts and related substances – if not notified for specific exemptions or acceptable purposes – includes articles and mixtures containing those chemicals Ban recycling of PFOS and articles containing PFOS Notify to register for specific exemptions and acceptable purposes National Implementation Plan (an Action plan is recommended) Use of BAT/BEP (best available techniques/best environmental practice) Identify contaminated sites and environmentally sound strategies to manage them and clean up Environmentally sound management of stockpiles and waste Reporting every 4 years on progress to phase out

5 Acceptable purposes and specific exemptions for PFOS in the Stockholm Convention

6 Objective of the Inventory To identify whether the current situation meets the requirements of the Stockholm Convention and identify areas where it does not To identify economic sectors that have critical uses of PFOS that falls into the use categories listed as acceptable purposes and specific exemptions in the Convention To give valuable information towards developing a strategy in the NIP and identify the economic sectors that should be prioritized and the type of actions required for those sectors in an action plan To provide a basis for the reporting obligations under the Stockholm Convention for PFOS To identify gaps in information required to complete the inventory To identify the need for type of financial or technical support, when resources are limited to fill the gaps

7 Important elements Information on national use and production of PFOS and its related substances Information on PFOS and its related substances in stockpiles and wastes Identification of contaminated sites Identification of sources with high potential of harmful exposure of humans and environment Identification of the chemicals used and produced and if they are PFOS related substances (OECD list)

8 Production and use of PFOS and its related substances

9 The industrial sector The manufacture of products and articles containing PFOS can comprise several producers, suppliers, and downstream users and the supply chain can involve import and export across borders. The downstream users may not know that PFOS have been used in the preceding manufacturing processes For most countries, only the following need to be identified and described: – the national supply chain – the national professional users of PFOS – the national downstream users in the product chain for articles containing PFOS

10 (*compounders)

11 The industrial sector PFOS related substances have various specific uses as a chemical agent in the electronic, semi-conductor and photographic industry. They are used in small quantities in closed systems and are not intended to be a content of the final end products The use of PFOS in the oil and mining industry have the potential of releases to water, and the ground at the production sites can be contaminated The metal plating process can be in a closed system, if not it can represent potential releases of PFOS-related substances to the environment from the process, the stockpiles and waste Impregnation of textiles, carpets, leather and paper can be a potential source of PFOS from craddle to grave Recycling of synthetic carpets is banned and can be especially problematic when incorporated into new products like bio-solids. Recycling of paper containing PFOS is also banned

12 Consumer market Use areas of special concern: −Textiles, furniture's and carpets – elevated levels in house dust −Clothes, sporting apparels, shoes, cosmetics, and similar products – direct exposure to humans −Food packaging – exposure through food for humans and animals Importers and downstream users in the product chain often have poor knowledge of the content of articles Screening surveys of marketed articles common

13 Fire-fighting foams Fire-fighting foams with fluorosurfactants are used for extinguishing liquid fuel fires, and is normally used to suppress fires in flammable liquids like oil, petrol, other not water soluble hydro carbons, and flammable water soluble liquids like alcohols, acetone, etc. They are especially used at installations and plants were larger quantities of flammable liquids are stored The consumption of fire fighting foams depends on the frequency of fire drills and the rate of fire accidents The dispersive use and releases to the environment, contaminated sites and groundwater and management of stockpiles of special concern

14 Fire-fighting foams They have a wide range of users and will often require special attention and resources in the inventory It is recommended to have a sub-project on fire-fighting foams with stakeholder meetings for feed back and awareness rising Because of the low content of PFOS it might be that the producer of the hydraulic fluid is not obliged to mention PFOS in the corresponding Material Safety Data Sheet of the product. The costumers might therefore consider that their substance is PFOS free, which is not necessarily true

15 Aviation hydraulic fluids PFOS is added to inhibit erosion (and to control damages) of mechanical parts of hydraulic systems such as servo valves that are used in aircrafts Because of the very low content of PFOS it might be that the producer of the hydraulic fluid is not obliged to mention PFOS in the corresponding Material Safety Data Sheet of the product. The costumers might therefore consider that their substance is PFOS free, which is not necessarily true Hydraulic fluids becoming waste have been recycled and handled by physical chemical treatment to generate a new product by oil recycling companies- this is now banned Contaminated sites and groundwater and management of stockpiles can be of concern

16 Insecticides PFOS and PFOS precursors applied in the agricultural sector as insecticides are on the list of registered chemicals for use by farmers and grain merchants in some developing countries Sulfluramid, N-ethyl perfluorooctane sulfonamide (EtFOSA), is both a surfactant and an active substance in insecticide products used in tropical areas such as Brazil against termites, cockroaches and other insects. Sulfluramid is registered in some developing countries for producing bait to control leaf cutting ants It is a PFOS precursor that is covered under the Convention through the listing of PFOSF Dispersive use and releases to the environment, direct exposure of humans, contaminated sites, groundwater and management of stockpiles are of special concern If the insecticide is registered for use in the country guidance for the inventory of insecticides should then be applied (guidance for POP pesticides)

17 Waste Waste from treatment of effluents – Sewage sludge and use on agricultural areas of special concern Waste from consumer products containing PFOS – Synthetic carpets and food packaging of special concern Industrial waste – Can be of concern at dump sites and landfills and municipial waste water treatment plants

Stockpiles Type of stockpiles:  Used chemical agents, formulas and mixtures in the industry  Used galvanic baths  Fire-fighting foams  Aviation hydraulic oils  Insecticides  Drilling fluids Location:  Oil and gas facilities  Airports  Warehouses and storage facilities of chemical importers and farms  Industrial sites  Mines  Professional users of fire-fighting foams

19 Potential contaminated sites Areas of accidental leakage and spills of stockpiles (industry, like metal plating and professional users of fire-fighting foams, insecticides and aviation hydraulic fluids) Fire drill areas Contaminated soil and ground water from use of insecticides or in oil- and mining industry Production sites Landfill and dump sites Waste water treatment plants Incineration of waste

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21 The inventory Step- by-step

22 National inventory team: e.g. National EPA, Food Agency, and Customs w/project leader in EPA (The National focal point) Scope and focal sectors based on: -objectives and important elements of the inventory -outcome of preliminary survey -resources and capacity Textiles and furnitures Galvanic industry Fire-fighting foams Aviation hydraulic fluids Import/export Articles and chemicals WasteStockpiles Contaminated sites Examples of focal areas Stage 1 – Planning of the inventory

23 Stage 1 – Planning of the inventory The development of a work plan should include: Inventory strategy Methodologies to be used for inventory Activities needed Resource allocation including responsibility and budget Time line and milestones

24 Planning Preliminary survey Identification of scope Workplan Stage 2-4 Initial assessment in targeted areas Stakeholders identified Fire-fighting foam project established (STAKEHOLDER MEETING) Stage 4 Preliminary survey Data collection and compilation w questionnaires More in-depth analysis Data management and reporting Workplan: Example w/ sub project on fire-fighting foams 1 month 2 months5 months6 months Responsible: National inventory team (NIT) Identified Experts/ Consultants Identified Experts/ Consultants Identified Experts/ Consultants together w NIT Stage 1 – Planning of the inventory

25 Stage 2 – Identification of stakeholders Tools could be: – National registers/phone books – Web search – interviews Strategy for contact in this stage could be: – Preliminary consultations with larger stakeholders – Stakeholder group meetings for key focal area: fire-fighting foams

26 Stage 3 – Methodology for data collection

27 The methodology could be decided to the following by using the tiered approach : – Industrial sector: initial assessment stage/Questionnaire surveys – Consumer market: more-in depth analyses/Questionnaire surveys and verifying presence of PFOS in articles by analysis – Professional use areas: initial assessment stage/Questionnaire surveys – Waste management: focus on stockpiles and prioritize larger waste segments/Questionnaire surveys – Contaminated sites: focus on identification/Questionnaire surveys Stage 3 – Methodology for data collection

28 Stage 4 - Data collection and compilation The following types of numeric data are needed to be collected in the inventory: – Quantities of PFOS in products, waste, and stockpiles – Quantities used in industrial processes and manufacture of articles and products – Releases of PFOS from industrial point sources (if available in National Pollutant Release and Transfer Registers (PRTRs)) Methodology approach usually based on estimations and Qualitative /Indicative surveys

29 Step by step approach for the key focal areas as described in the guidance Questionnaires for key focal areas are in the guidance Evaluation step is important; involves also a decision on activity to fill the gaps Because of the low content of PFOS in some chemical mixtures and articles it might be that the producer is not obliged to mention PFOS in the corresponding Material Safety Data Sheet of the product. The costumers might therefore consider that their substance is PFOS free, which is not necessarily true The OECD list on PFOS related substances will be a important tool to identify if the produced or used substances or mixtures are included by the regulations under the Stockholm Conevntion and shall be included in the inventory. Both producers, suppliers and users can be unaware of this fact Stage 4 - Data collection and compilation

30 Stage 5 – Data management In order to quantify the amounts of PFOS in focal areas: −Statistics from a National Statistical Institute on manufacture, export and import volumes could be used to calculate the net consumption: −Estimations based on compiled data from questionnaire surveys (ex. Textile impregnation): Annual net consumption of PFOS in [country] = [manufacture + import – export] x PFOS amount T=L∙C T=Total quantity of PFOS used in the industrial process per year L=PFOS concentration or % of PFOS in the textile formula C=Yearly consumption of the textile formula

31 Stage 5 – Evaluation A mechanism for evaluation of the process, strategy used and information collected is needed, to identify: – gaps and limitations and measures needed to complete the inventory – if the obligations under the SC are fulfilled and the necessary actions needed to fulfill them – the need of notification to the registers of acceptable purposes and specific exemptions under the Convention The evaluation will be the basis for updating the NIP and development of an Action Plan for PFOS and its related substances Gaps, limitations and necessary actions will be valuable information in the NIP, and can be used in an application for funding

32 The possibilities and options for substitution to alternatives and the time-frame needed for the phase out of PFOS and its related substances will be important elements in the development of the Action Plan. To get the information needed for the use-categories with a need of a phase-out plan a follow up of the inventory can be necessary for some sectors Information about the alternatives to the use of PFOS and its related substances are provided in a guideline on alternatives developed by the POP review committee under the Stockholm Convention (UNEP 2010b) Information on risk reduction and BAT/BEP is provided in the Guideline on BAT/BEP for PFOS and its related substances Stage 5 – Evaluation

33 Recommendations on risk reduction To identify, and implement more environmentally sound alternatives, withdraw and cease use in open applications, (e.g., in impregnated/ surface modified paper, insecticides, fire-fighting foam, chemically driven oil production, carpet, textile, leather, furniture, detergents) To identify and cease using stocks containing PFOS (fire-fighting foams, carpets and others). Such stocks should be collected and stored safely or if technology is available destroyed as hazardous waste If contaminated sludge has been applied as a biosolid to agricultural areas or other soils, such practices should be stopped To raise awareness of the environmental and human health effects of PFOS, providing training for relevant professionals in how to handle collection, storage and disposal of PFOS

34 To monitor occupational exposure at production and industrial use facilities and to implement appropriate occupational health and safety measures If using PFOS in industrial applications apply the guidance on BAT/BEP for PFOS, for metal plating closed loop systems will be recommended Apply the BAT/BEP guidance for an environmentally sound handling and management of waste Drinking water from reservoirs and wells in the vicinity of landfills with waste containing PFOS, sites of PFOS production and user areas (fire- fighting foams) should be analysed To monitor rivers and lakes and, in particular, the fish in the lakes and rivers close to landfills and production and industrial use areas. Depending on the PFOS levels in fish, an advisory board for fish consumption should be established Recommendations on risk reduction

35 The structure of the Guidance

36 Thank you! For more information, please contact: Secretariat of the Stockholm Convention 11-13, Chemin des Anémones Châtelaine, Switzerland Tel.: +41 (0) Fax: +41 (0) Website: