Australian AICIS extends dechlorane plus risk evaluation deadline by 1 year

On June 30, 2022, the Australian Industrial Chemicals Introduction Scheme (AICIS) announced the extension of the risk evaluation deadline for dechlorane plus (1,2,3,4,7,8,9,10,13,13,14,14-dodecachloro-1,4,4a ,5,6,6a ,7,10,10a ,11,12,12a, -dodecahydro-1,4;7-dimethanodibenzo [a, e] cyclooctene) (hereafter referred to as “DP”). The new risk evaluation deadline is June 30, 2023, one year after the announcement. The reason for the extension is that AICIS is considering the results of long-term research on toxicity to the aquatic environment, and AICIS expects that the results of the research will be announced at the same time as the international conference* at which decisions based on the “Stockholm Convention on Persistent Organic Pollutants (POPs Convention)” are made. At the 17th meeting of the Persistent Organic Pollutants Review Committee (POPRC) held in January 2022, the United Kingdom observer mentioned that “studies on long-term toxicity to fish using dietary exposure are being conducted, and the results are expected to be released in May-June 2022”, and in response, AICIS extended the deadline for DP evaluation in January 2022.

Below are the answers to the inquiries sent to AICIS.

“Since the test results were not available at the scheduled time, AICIS extended the scheduled time for completion of the evaluation to June 2023. The results of the study are expected to be published at the next POPRC, but if they are not, an update on the progress of the study may be provided. Based on this information, AICIS will determine a schedule for future risk evaluations. However, the publication of the evaluation is not based on the Convention’s schedule, but is rather to evaluate the risk of chemical use in Australia and to take into account all relevant information.”

* Inquiries to AICIS revealed that the meaning of the international conference in the press release is the 18th POPRC scheduled to be held in September 2022.

Background information

“DP and its syn- and anti-isomers” will be discussed at the final stage of the POPs Convention’s POPRC, the draft “Risk Management Evaluation”, at the 18th meeting of the POPRC in September 2022. The draft risk management evaluation that will be the subject of public consultation will be published on June 30, 2022. The following is a summary of the draft.

An industrial brand DP mixture is a commercially-available polychlorinated flame retardant. Industrial brand DP mixtures contain two stereoisomers, a syn-type DP and an anti-type DP, which are present in a ratio of about 1:3 or in a ratio of 25% syn-type DP and 75% anti-type DP. DP is marketed as a substitute for decabromodiphenyl ether (decaBDE).

DP is also used as a flame retardant in adhesives, sealants and polymers  and, to a lesser extent, as an extreme pressure additive for grease. Automotive use accounts for 70-90% of the world total, and its main applications (about 80%) are cables and wires. Other applications include aerospace and defense, electrical and electronic equipment, ships, horticultural and forestry machinery, consumer electronics, and medical and radiotherapy.

The global production of DP is estimated at 750 to 6000 tons per year, or 1980 tons on average. Several commercially available alternative chemicals have been identified that are suitable for substitution of DP. Annex F and other available information indicate that the market is transitioning from DP and that, even if not for all applications, substitutes are in place or in progress for almost all known uses. However, the aerospace and defense sectors and medical imaging and radiotherapy equipment and facilities have suggested that there may be challenges associated with a long-term introduction period. For applications in targeted sectors, a time-limited exemption may be necessary. Furthermore, a time-limited exemption for use with legacy spare parts is required to enable repair of molded articles with a long service life, such as:

• • Motor vehicles covering all land vehicles
  • Industrial machinery used in agriculture and construction
  • Ship, horticultural, and outdoor power units
  • Aerospace and defense applications
  • Medical and radiotherapy applications

However, a draft published in June 2022 stated that “an exemption beyond the first five years for which a Contracting Party has registered for a specific exemption is probably not necessary” given the ban on the production and use of DP in China.

In the light of the above, POPRC “recommends to the Conference of the Parties to the POPs Convention that, in accordance with Article 8, paragraph 9, of the POPs Convention, dechlorane plus be listed in Annex A and that the manufacture and use of DP for aerospace and defense applications and medical imaging and radiotherapy systems and equipment be considered for time-limited exemptions, as the stringent safety requirements of these products may result in lengthy processes. In addition, POPRC will consider time-limited exemptions for the manufacture and use of legacy spare parts for ship, horticultural, and outdoor power equipment, including automobiles, industrial machinery used in agriculture and construction, and forestry machinery, as well as aerospace and defense applications and medical image processing and radiotherapy equipment and facilities.”

The AICIS press release and the draft published on June 30, 2022 can be viewed at the following URL:

• List of current and completed evaluations updated June 2022
  https://www.industrialchemicals.gov.au/news-and-notices/list-current-and-completed-evaluations-updated-june-2022
• UNEP/POPs/POPRC.18/2 “Draft risk management evaluation: Dechlorane Plus ”
  http://chm.pops.int/TheConvention/POPsReviewCommittee/Meetings/POPRC18/Overview/tabid/9165/Default.aspx