Singapore Singapore announces public consultation on new regulations for five chemicals

NEA intends to add five substances under review in the Stockholm Convention and the Rotterdam Conventions into the Environmental Protection and Management Act

Singapore announces public consultation on new regulations for five chemicals

On August 30, 2021, the National Environment Agency of Singapore (NEA) released a proposal of national legislations for five chemicals that are being reviewed as new controlled substances in the Stockholm Convention and the Rotterdam Conventions (Amitrole, Nonylphenol and Nonylphenol Ethoxylates, Iprodione, Dechlorane Plus, and UV-328). In order to ensure implementation of the international conventions, the NEA proposes to regulate these five substances as “hazardous substances (HS)” under the Environmental Protection Management Act (EPMA) and the Environmental Protection Management (Hazardous Substances) Regulations (EPM (HS) Regulations) tentatively by March 1, 2023.

The call for comments will run until September 24, 2021.

The original announcement by the NEA on this matter can be viewed at the following URL.
https://www.reach.gov.sg/Participate/Public-Consultation/National-Environment-Agency/Pollution-Control/public-consultation-on- proposed-control-of-additional-chemicals-as-hazardous-substances-%28hs%29-in-singapore

Five chemical substances under consideration for new inclusion in international conventions and obligations of parties

Rotterdam Convention

(i) Amitrole

(ii) Nonylphenol (NP) and Nonylphenol Ethoxylates (NPE)

(iii) Iprodione

Stockholm Convention

(i) Dechlorane Plus (DP)

(ii) UV-328

If the Conference of the Parties (COPs) in June 2022 decides to add these chemicals to the Annexes, the obligations of the Parties will enter into force within 9 to 12 months of the decision.

Environmental Protection and Management Act of Singapore

This is the basic regulations for the management of hazardous substances in Singapore. It governs the import, sale and supply of hazardous substances, and is administered by the National Environment Agency (NEA), a subordinate body of the Ministry of Sustainability and the Environment. Under this act, any person who imports, owns for sale, or sells hazardous substances is required to obtain a license. The amendments in 2019 newly added 10 substances adopted or considered under the Stockholm Convention, such as Perfluorooctanoic Acid (PFOA) and Perfluorohexane Sulfonic Acid  (PFHxS), and under the Rotterdam Convention, such as Benzidine, Acetochlor, and Amitraz.

 

 

Substance Information

The detailed information of the five substances excerpted from NEA’s document is the following:

Name Dechlorane Plus
CAS RN 13560-89-9,

135821-03-3 for its syn-isomer; and

135821-74-8 for anti-isomer.

Category Industrial chemical
Common Use Additive flame retardant in electrical wire and cable coatings, plastic roofing materials, hard plastic connectors in TV and computer monitors and in polymeric systems such as nylon and polypropylene plastic.
Environmental Impact and Health Effects
  • Very persistent, long-term exposures in sediment and soil.
  • Very bio-accumulative
  • Potential for long-range transport, due to strong absorption to suspended solids/particulates when released to surface water.
  • Risk to operators, nearby residents
  • Neurotoxicity was observed in fish and earthworms
  • Endocrine modulative effects in fish and humans

 

Name UV-328
CAS RN 25973-55-1
Category Industrial chemical
Common Use
  • UV stabilizer in plastic shrink films (including food packaging), outdoor furniture, clear coat automotive finishes
  • Light stabilizer in coating, ABS resin, epoxy resin, fibre resin, PVC, unsaturated polyesters, polyacrylates and polycarbonates
  • UV absorber in Construction materials, fillers, surface treatment, adhesives, paint/lacquers/varnishes, printing inks, consumer fragrances, fabric/textile/leather products and inert pesticides
Environmental Impact and Health Effects
  • Causes damage to organs through prolonged or repeated exposure
  • May cause long lasting harmful effects to aquatic life
  • Persistent pollutant to environment
  • Very bio-accumulative
  • Low potential for biodegradation

 

Name Amitrole
CAS RN 61-82-5
Category Pesticide
Common Use Used as herbicide
Environmental Impact and Health Effects
  • Classified as probable human carcinogen
  • Risk to human health due to high risk of groundwater contamination by amitrole and its metabolites
  • Risk to terrestrial and aquatic organisms

 

Name Nonylphenol Nonylphenol Ethoxylates
CAS RN

NOTE:
The list of CAS RN is not exhaustive.

84852-15-3
25154-52-3
11066-49-2
90481-04-2
104-40-5
127087-87-0
9016-45-9
26027-38-3
37205-87-1
68412-54-4
Category Industrial chemical/ Pesticide
Common Use Production of nonylphenol ethoxylates, plastics, resins, stabilizers in the polymer industry; phenolic oximes in the metal extraction industry
  • Adjuvants in pesticide formulations to enhance the absorption and efficacy of active ingredients in pesticides
  • Surfactant in cosmetics formulations and industrial, household cleaning products
  • Textile and leather processing
  • Cleaning of metal products
  • Emulsifiers in polymers (paints, resins, coatings)
  • Paper and pulp manufacturing
  • Fluxes, dyes, chemical baths in the manufacture of electronic circuit boards
  • Wetting agent in the development of photographic film
Environmental Impact and Health Effects
  • Persistent, low-moderately bio-accumulative and highly toxic to aquatic organisms
  • Potential risk to human health via occupational exposure – high levels of exposure may cause severe skin and eye irritation

 

Name Iprodione
CAS RN 36734-19-7
Category Pesticide
Common Use
  • Contact fungicide
  • Nematicide
  • Antifungal agrochemical Post-harvest dip, as a seed treatment or as a dip or spray at planting
Environmental Impact and Health Effects
  • Suspected of causing cancer
  • Very toxic to aquatic life with long lasting effects
  • Very toxic to aquatic life

 

(Edit in March, 2022)
Singapore government revealed public comments submitted by industries. Here is its excerption:

Comment

Answer from NEA

Consider regulating the 5 identified chemicals as hazardous substances only upon their listing under the Annexes of Rotterdam and Stockholm Conventions. NEA will only implement the obligations of the Stockholm and Rotterdam Conventions (i.e. Prior Informed Consent procedure, elimination, restriction) when the chemicals are adopted by Parties for listing in the respective Annexes of the Conventions. The means to implementing the obligations is by listing the 5 identified chemicals as controlled hazardous substances under the Environmental Protection and Management Act (EPMA) and EPM (Hazardous Substances)
Consider excluding (i) the chemicals that exist as impurities and (ii) the chemicals in products that are present in concentrations that do not require any classification and/or labelling based on Globally Harmonised System from licensing controls Unintentional trace quantities of the chemicals present as contaminants in products will be exempted from the proposed regulatory control, as allowed for and in alignment with the provisions under Stockholm Convention and Rotterdam Convention. NEA may require relevant supporting documentation (e,g. safety datasheets, analytical reports, etc.) to be furnished when such cases surface.
Consider exempting products containing Dechlorane Plus (DP) and UV-328 that are already placed in the market The proposed domestic controls are aligned with the obligations of the Stockholm Convention when the 5 chemicals are adopted for control by the Parties. This includes the type of products or articles that are adopted for exemption.

NEA recognizes the concerns raised by industry on whether products containing DP and UV-328 that are already placed in the market will be prohibited for sales. Similar to the approach taken for other controlled hazardous substances (e.g. perfluorooctanoic acid that was listed in Annex A under the Stockholm Convention in 2019), the industry will be allowed to deplete its existing stock of DP and UV-328, including their products which are already placed in the local market, before the effective date of the obligation.

https://www.reach.gov.sg/Participate/Public-Consultation/National-Environment-Agency/Pollution-Control/public-consultation-on-proposed-control-of-additional-chemicals-as-hazardous-substances-(hs)-in-singapore

Author / Responsibility

AOKI Kenji

Senior Consultant, EnviX Ltd.
General Director, E&H Consulting Co., Ltd.

Business Performance

Expertise in EHS (environment, health and safety) consulting in ASEAN region.
- Environmental regulations updating
- Chemical regulations consulting

Background

MSc in Earth Science, The University of Tokyo

AOKI Kenji