NEA’S RESPONSE TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON THE CONTROL OF SHORT-CHAIN CHLORINATED PARAFFINS (SCCP) IN SINGAPORE
1 The National Environment Agency (NEA) has concluded the public consultation on the proposed control of short-chain chlorinated paraffins (SCCP) in Singapore. The three-week consultation exercise was open for public comments from 8 Sep to 29 Sep 2017.
2 During the period of the REACH consultation, NEA received comments and questions from 10 organisations. Overall, no concerns were raised on the proposed control of SCCP. Responders mainly sought clarification on the types of substances that are being proposed for control.
3 NEA’s replies to the questions raised are in the table below.
4 NEA would like to thank all stakeholders who 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 short-chain chlorinated paraffins (SCCP) 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 SCCP in Singapore. The consultation period will last for 3 weeks from 8 Sep 2017 to 29 Sep 2017.
Short-Chain Chlorinated Paraffins (SCCP)
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 can 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 SCCP (C10 - C13 chloroalkanes) is a POP, which is used as a component in lubricants in metal working applications, and as a fire retardant/plasticiser in paints, sealant, rubber and polymers. According to reports published on the Stockholm Convention website, the global production of SCCP is decreasing. These reports, as well as publications from developed countries, also mention that there are commercially available alternatives to SCCP.
4 At the 8th Meeting of the Conference of Parties of the Stockholm Convention (COP-8) in 2017, SCCP was listed in Annex A (with specific exemptions shown in Table 1 below) 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.
Table 1: Listing of SCCP in Annex A of the Stockholm Convention
5 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.
6 At the 8th Meeting of the Conference of Parties of the Rotterdam Convention (COP-8) in 2017, SCCP 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 in Singapore
7 In line with the obligation to phase out the production, import, export and use of SCCP, and in view of global indications on the availability of alternatives for SCCP, the domestic control measures for SCCP are being reviewed.
8 NEA plans to gazette the control of SCCP under the EPMA and EPM (HS) Regulations by December 2017. Importers, manufacturers and distributors of SCCP and chemical products containing SCCP will have 6 months from the date of gazette to comply with the control. With effect from June 2018, the production, import, export and use of SCCP and chemical products containing SCCP in Singapore will not be allowed.
9 Parties who wish to provide feedback on the proposed control of SCCP should submit their comments to Miss Stefanie Koh, at “firstname.lastname@example.org”. The consultation exercise will end on 29 Sep 2017.
10 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.
11 This proposal is released for the purpose of consultation. All relevant information received during the consultation exercise will be taken into consideration and treated in confidentiality.