NEA’S RESPONSE TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON THE CONTROL OF POLYCHLORINATED NAPHTHALENES (PCN) AND TRICHLORFON IN SINGAPORE
1 The National Environment Agency (NEA) has concluded its public consultation on the control of polychlorinated naphthalenes (PCN) and trichlorfon in Singapore. The three-week consultation exercise was open for public comments from 10 July to 31 July 2017.
2 During the period of the REACH consultation, NEA received 18 responses. Overall, the responses indicated that there were no concerns on the proposed control of PCN and trichlorfon in Singapore. Some respondents sought clarification on the Chemical Abstracts Service (CAS) Registry Numbers of PCN that are proposed for control. NEA has since provided the clarifications.
3 NEA appreciates the responses/comments received on the proposed control of PCN and trichlorfon in the consultation. We would like to thank all stakeholders who have participated in the consultation exercise. We look forward to your active participation again in our future public consultation.
The National Environment Agency (NEA) of Singapore is consulting the public on the proposal to control polychlorinated naphthalenes (PCN) and trichlorfon as Hazardous Substances (HS) under the Environmental Protection and Management Act (EPMA) and EPM (Hazardous Substances) Regulations, and to phase-out the production, import, export and use of PCN. The consultation period will last for 3 weeks from 10 July 2017 to 31 July 2017.
Polychlorinated Naphthalenes (PCN)
2 The Stockholm Convention on Persistent Organic Pollutants (POPs) is a global treaty to protect human health and the environment from POPs. POPs are chemicals that remain intact in the environment for long period of time, can be widely distributed geographically, accumulate in the fatty tissues of humans and wildlife, and have harmful impacts on human health or the environment.
3 PCN is a POP, which is found in cable insulation, wood preservatives, rubber and plastic additives, and in capacitors. According to reports published on the Stockholm Convention website, the intentional production of PCN has already ended. It was also reported in these reports, as well as publications from developed countries that the use of PCN has been substituted by alternatives which are already in use.
4 Notwithstanding, PCN can be unintentionally produced during incineration or high-temperature industrial processes. The existing measures to control dioxins and furans emissions to ensure that they fall within the stipulated limits (i.e. 0.1 ng TEQ/Nm3 for waste incinerators commissioned on or after 1 Jan 2001, 1.0 ng TEQ/Nm3 for waste incinerators commissioned before 1 Jan 2001) under the EPM (Air Impurities) Regulations will also mitigate PCN emissions.
5 At the 7th Meeting of the Conference of Parties of the Stockholm Convention (COP-7) in 2015, PCN was listed in Annex A (with specific exemptions shown in Table 1 below) and C of the Convention. For chemicals listed in Annex A of the Convention, Parties would have to take measures to prohibit the production, import, export and use of the chemicals. For Annex C chemicals, Parties would have to reduce or eliminate the unintentional production of the chemicals.
6 The Rotterdam Convention on the Prior Informed Consent (PIC) Procedure for Certain Hazardous Chemicals and Pesticides in International Trade is a global treaty to promote shared responsibility and cooperative efforts among Parties in the international trade of certain hazardous chemicals in order to protect human health and the environment.
7 Trichlorfon, which is an organophosphate, is used in pesticides for field crops, fruits, vegetables, and ornamental plants. It is also used for pest control in cattle and horses. Currently, there are other active ingredients that are being used as alternatives to trichlorfon.
8 At the 8th Meeting of the Conference of Parties of the Rotterdam Convention (COP-8) in 2017, trichlorfon was listed in Annex III of the Convention. Chemicals listed in Annex III are subjected to the PIC procedure which involves formally obtaining the decisions of importing Parties on whether they wish to receive future shipments of the chemical of concern and ensuring that exporting Parties comply with the decisions of importing Parties.
Proposed Regulatory Control
9 In line with the obligations of the Conventions and with the availability of alternatives for PCN and trichlorfon, the domestic control measures for these chemicals are being reviewed.
10 NEA plans to gazette the control of PCN and trichlorfon under the EPMA and EPM (HS) Regulations by November 2017. Importers, manufacturers and distributors of these chemicals and products containing these chemicals will have 6 months from the date of gazette to comply with the control measures. With effect from May 2018, the production, import, export and use of PCN in Singapore will not be allowed. A HS Licence will be required for companies that import, export and sell trichlorfon, while end-users that store and use trichlorfon will be required to obtain a HS Permit.
11 Parties who wish to provide feedback on the proposed control measures for PCN and trichlorfon should submit their comments to firstname.lastname@example.org. The consultation exercise will end on 31 July 2017.
12 In order to ensure that the consultation is productive and focused, respondents are requested to adhere to the following guidelines when providing their feedback:
a. Identify yourself as well as the organization you represent (if any) so that NEA may follow up with you to clarify any issues, if necessary.
b. Be clear and concise in your comments.
c. Focus your comments on the proposal and how it can be improved.
d. Substantiate your points with illustrations, examples, data or alternative suggestions.
13 This proposal is released for the purpose of consultation. All relevant comments received during the consultation exercise will be taken into consideration.