Thank you chair and good afternoon, Members of the Committee, Secretariat, and Observers.  

My name is Therese Karlsson and I am a science advisor for IPEN and for those of you dont already know IPEN, we are a global network of public interest, civil society organizations in more than 125 countries.  

We thank the drafters and the submitters for the work that they have done towards strengthening the recommendation.  

For the concentration limit the RME shows that a 0.1 % limit would result in emission reduction of 3000-6000 tonnes. If a concentration limit is adopted it should therefore not exceed 0.1% and preferably be lower.  

Regarding the chemical identity, the submissions, including from the EU and Switzerland during POPRC 18, 19, andintersessionally, as well as the presentations during the side event, have made it clear that the best way to identify the chemicals that have been identified as POPs is as congeners.   

Discussions at previous POPRCs have also clarified that this chemical identity fall within the scope and that is a simply a clearer, more practical and more accurate way of identifying the MCCPs that POPRC found were POPs during the risk profile.  Previous discussions have also highlighted that there is precedence with similar cases such as Octa and Penta c which during the evaluation process were primarily referred to as their commercial names.   

Regarding the exemptions the RME shows that there are alternatives, still the draft includes several broad exemptions, which a recent study showed are expected to lead to the generation of an additional10 million tonnes of hazardous wastes.  

Also, even though there are alternatives, these proposed exemptions include uses that will lead to continued human and environmental exposures, such as calendered PVC films that are commonly used for food packaging, metalworking fluids that will lead to direct emissions of MCCPs into the environment, and in running tracks that have been identified as of special concern because of high exposure for children.  

Dear colleagues, we really should not have to worry about whether our children are exposed to these toxic chemicals through food packaging and running tracks.  

We therefore hope that the work that we do together here during this week can serve to strengthen the nomination further to ensure the safety for everyone and especially those most vulnerable.  

Intervention on the nomination of dioxins and furans

Delivered by Therese Karlsson, IPEN Science Advisor, September 23, 2024

Intervention on long-chain PFCAs

Delivered by Sara Brosché, IPEN Science Advisor, September 23, 2024

Thank you, Mr Chair.

Thank you to everyone engaged in the work of gathering additional information for the draft addendum to the risk management evaluation. 

We noted already last year that the RME shows that alternatives are already available for most known applications of long-chain PFCAs. Looking at what information has been submitted, and noting that justifications for exemptions has in many cases not been submitted, there seems to be quite a lot of room for strengthening the recommendation to the COP. Exemptions should only be granted for justified, narrow, clearly defined applications,and therefore, the exemptions in brackets as shown on the screen should be removed. 

Any continued uses will mean continued exposures for consumers and workers as well as continued environmental contamination, leading to high societal costs, for example for waste treatment, remediation and health impacts. Therefore, the benefits for human health and the environment from taking global action on these substances are expected to significantlyoutweigh the costs of implementing control measures.

Finally, we would also encourage the POPRC to include a statement about the risk of regrettable substitution and the importance of avoiding replacing these PFAS with other PFAS substances, as is highlighted in the conclusion of the draft assessment and as has been done for previous PFAS listings.

Intervention on chlorpyrifos

Delivered by Sara Brosché, IPEN Science Advisor, September 23, 2024

Thank you, Mr Chair, 

We would like to start by thanking the drafters and working group for preparing this very thorough Risk Management evaluation.

Chlorpyrifos is a highly toxic pesticide that harms brain development in children, leading to irreversible harm. It causes harm to farmers and their communities, and environmental damage on non-target species and biodiversity. Its use has caused widespread contaminationin the Arctic and other places far away from where it is used, including traditional foods of Arctic Indigenous Peoples.

The RME provides comprehensive evidence that alternatives are available, accessible andwidely in use, and chlorpyriphos has already been banned in countries representing different climates, different economic development levels, covering a range of uses. 

It is therefore feasible to list chlorpyrifos for global elimination and IPEN supports listingchlorpyrifos in Annex A without exemptions. 

Thank you.

Intervention on the draft report for the evaluation and review of brominated diphenyl ethers

Delivered by Sara Brosché, IPEN Science Advisor, September 24, 2024

Thank you Chair,

And thank you to the secretariat for drafting the report, we also find it really helpful. 

This is a very timely topic, since the 2009 POP-BDEs can be seen a as a case study of the consequences of lack of transparency and traceability of POPs, and the severe challenges importing Parties have as was also raised under the previous agenda item.  

We wanted to raise a couple of points in relation to key issues in the report. 

First of all, one of the key messages from the report is about ending recycling of materials containing the 2009 POP-BDEs. This is of course crucial for these specific chemicals, but also broadly for all PBDEs and all POPs. 

IPEN has published a number of reports showing that the presence of PBDEs in recycled plastics is a global problem. This includes the 2009 POP-BDEs, but also other brominated flame retardants listed under the Stockholm Convention that ends up in a variety of products, including children’s products. For example, a study we conducted in 2021 analyzed recycled pellets made from high-density polyethylene, from 24 recycling facilities in 23 countries. We found that PBDEs in 22 of the 24 samples, with DecaBDE being the most frequently detected, despite its listing under the Stockholm Convention for global elimination in 2017 without any exemptions for recycling.

However, the listing decision of DecaBDE did come with a wide range of other exemptions, many of them with extended timelines. It seems clear that these exemptions in combination with the lack of transparency leads to widespread contamination of recycled plastics.   

The other issue we wanted to bring up is about the section addressing environmentally sound management of wastes containing PBDEs. We were quite surprised that this leaves out of a couple of key items from the technical guidelines.  

First of all, the section seems primarily focused on combustion-based methods, despite the added burden of managing hazardous bottom- and fly ash when using these techniques. However, there are actually two additional non-combustion techniques included in the technical guidelines that are not in this report: 

- Supercritical water oxidation and subcritical water oxidation;

- Gas-phase chemical reduction

It also leaves out the warning about generation of brominated dioxins and dibenzofurans from combustion and incineration of POP-BDE wastes that is included in the technical guidelines. This seems even more relevant in relation to the new POPs nomination addressed at this meeting.  

Both of these items need to be added to the report. 

Finally, there are a lot of lessons that can be learned from this report. This include the need to be very careful when allowing for exemptions given the widespread contamination they spread, and the urgent need to end the recycling exemption for the 2009 POP-BDEs. We would of course prefer ending all the exemptions as soon as possible.  

We therefore support the recommendations included in the report, to be forwarded to the COP.