Limits proposed for EU and limits under Stockholm Convention and Basel Convention
The figures below compare the limits called for by the Stockholm Convention, established and/or to be considered by the Basel Conventions and those set forth in the BiPRO report and proposed for use in the waste-related provisions of the EC regulation on POPs:
POPs Levels called for by Stockholm Convention, established and/or to be considered by Basel Convention
POPs limits proposed for waste-related provisions of EC regulation on POPs (e.g., see slides 4 and 6 of BiPRO presentation and page 7 of the draft executive summary)
As these figures indicate, the maximum POPs content limits proposed for use in the EC regulation on POPs are functionally equivalent to the low POPs content levels called for in the Stockholm Convention and provisionally established by the Basel Convention, while the low POPs content limits are functionally equivalent to the de minimis levels that have not yet been established by the Basel Convention.
As can be seen above, the recommended maximum POPs content limits values are orders of magnitude greater than the provisional low POPs content levels established in the Basel guidelines for POPs wastes, while the recommended threshold limits values are quite similar to the provisional low POPs content levels. We suggest that it is necessary to review and revise definitions of the terms, maximum POPs content limits and low POPs content limits, so that they are in agreement with similar terms used in the Stockholm and Basel Conventions. Further, we suggest that the limit values recommended in this study may not be sufficiently protective of human health and the environment and propose that, following the necessary revisions of the key terms and the availability of the full draft report, that the limit values are reassessed and revised so that they support this objective of the Stockholm Convention and are also at least as stringent as the provisional low POPs content levels established in the Basel guidelines for POPs wastes.
Further, we suggest that regulations allowing the storage of wastes containing POPs at concentrations above low POPs content levels in salt mines, safe deep hard rock formation may not comply with the requirements of the Stockholm Convention unless such storage is determined to be a method of disposal that is environmentally preferable to destruction or irreversible transformation, as specified in Article 6, paragraph 1 (d)(ii) of the Convention.