The proposed limits of toxic substances in wastes degrade the Stockholm Convention

25.11.2005 - Prague / London

The EU proposed limits for persistent organic pollutants (POPs) (1) are so weak that they do not begin to address the problems they were designed to solve. ”The proposed limits undermine not only the aims of the Stockholm Convention, but also all earlier efforts in the EU to limit the exposure of the European population to these substances, ” said  Dr. Jindrich Petrlik, co-chair of the IPEN (2) - Dioxin, PCBs and Waste Working Group (DPW WG) and chairman of the Arnika Association (Czech Republic). Dr. Petrlik, said IPEN DPW WG had ”many  reservations over the science and methods of  calculations used to arrive at the proposed  limits.”  These concerns are supported by a letter addressed to to European politicians, requiring a strengthening of the limits and signed by 106 non-governmental organisations, experts and members of representative bodies from 50 countries on  five continents (3).

The limits in question were proposed in September by the German advisory company BiPRO, on the basis of an order of the European Commission. By the end of 2005, the Waste Management Committee, composed of representatives of ministries of the EU Member States, should prepare a decision on limits of the content of fourteen persistent organic pollutants in wastes. The purpose of setting of these limits was to eliminate hazardous substances in wastes, and, through that, to avoid further contamination of the environment and food chains.

The BiPRO company proposed two limits for each of the four basic groups of POPs: dioxins (PCDD/Fs), polychlorinated biphenyls, POP pesticides and other POPs. The proposed low POPs content limit defines the level above which (for example) the waste cannot be freely used (e.g., for construction purposes). The maximum POPs content limit defines the level of content of these substances which if exceeded, requires the waste, without exceptions, to be subjected to the process of decontamination (destruction or irreversible transformation) (4). According to the recommendation of the study wastes between these two limits can, under certain conditions, be deposited (for example) on landfills, if the state in question considers it to be the most suitable method from the environmental point of view.

"The German consultant recommended levels, when viewed within the context of the Stockholm Convention, are too weak and do not reflect technical nor feasible ability to achieve stronger, more protective levels. In this respect, the recommended levels fail to reflect the objective and provisions of the Stockholm Convention, and thereby would result in a failure to adequately implement the Convention," Kevin Stairs, who signed the letter on behalf of Greenpeace International said. According to Dr. Petrlik "The proposed limits degrade the Stockholm Convention to a toothless tool. ”

”It seems as if the authors of the limits did not know just what persistent organic pollutants are and their effects on human health. For example, in Newcastle upon Tyne , England, a mixture of incinerator fly ash and bottom ash containing concentrations of dioxins by an order of magnitude lower than the minimum limit proposed by the BiPRO company, was used for the construction of pedestrian pathways around food growing areas. Subsequently, dioxin concentrations exceeding by ten times the European standard were found in poultry eggs. This is typical for persistent organic pollutants,” explained Ralph A. Ryder from Communities Against Toxics (UK).

Another example could be the handling of toxic wastes in the industrial plant most contaminated by dioxins in the Czech Republic - the Spolana Neratovice company. Debris contaminated by dioxins in this plant is now subjected to a complicated decontamination process at the cost of 92 million EUR. ”If the limits proposed by the BiPRO were implemented already Spolana could simply transport the debris to a landfill and not be responsible for it after that. This is an example from the Czech Republic, but the BiPRO study enables its repetition in any country of the European Union,” warns the Arnika spokesman Marek Jehlička.

Non-governmental organisations raised objections to the limits in the past already. However, the BiPRO company ignored their comments completely during preparation of the study. Because of that, the Dioxin, PCBs and Waste Working Group of the IPEN network instigated a letter addressed to the chairman of the European Commission, José Manuel Barroso, and two of the Commissioners. This week, the letter was sent also to the Member States for the attention of the Ministers of the Environment. In the letter, the non-governmental organisations also criticise the whole process of the preparation of the limits was not sufficiently open to public discussion.

”In many cases, the proposed limits undermine even stricter legislation now in force in the EU Member States (for example, in Austria, Czech Republic, Germany), and are much milder than comparable POPs limits in the USA,” states the letter.

”If the benevolent limits of POPs content in wastes are accepted in Europe, it will have an impact on the whole world. Paradoxically, the European Union, and not the USA, may become the entity degrading the Stockholm Convention, which should protect the world against these highly hazardous toxic substances. Because of that, we appeal to the European politicians to reject the proposed levels.” concluded Dr. Petrlík.

(1) POPs – Persistent organic pollutants: are described by many working in that field of science as ”the most toxic substances ever created by man.” They include, for example, dioxins, DDT, or polychlorinated biphenyls (PCBs). At very low doses they disrupt and interfere with the hormonal and immune systems (especially that of the developing fetus and growing child), and endanger the reproductive ability of animals, including man. They decompose very slowly and do not dissolve in water. In body fats they bind and bio-accumulate. Due to their chemical stability, they persist in the environment for decades  and as a result "travel" thousands of kilometres from their sources of origin.

(2) IPEN – International POPs Elimination Network is an international network of non governmental organisations which co-operate on pushing through the Stockholm Convention on persistent organic pollutants. The aim of this network is prohibition and elimination of these substances (for example, aldrin, dieldrin, endrin, DDT, chlordane, heptachlor, hexachlorobenzene, mirex, toxaphene, PCBs and dioxins). The network was formed at the same time as the start of the process of preparation of the international convention on the elimination of persistent organic pollutants ( spring 1998). Arnika has been its member organisation from the very beginning. At present, over 350 world-wide  non-governmental organisations are taking part in the work of IPEN. More info about IPEN at

(3) The signatories include representatives of well-known international non-governmental organisations. For example Greenpeace, Friends of the Earth, and Health Care Without Harm. The highest number of signatories (16) is from the Czech Republic, followed by the USA, UK, India, and Philippines. The letter is part of the campaign run by non-governmental organisations which began before the first Conference of Parties to the Stockholm Convention (2005) with the purpose (among others) to prevent adoption of  benevolent limits of POPs content in wastes. The campaign called "Keep the Promise, Eliminate POPs in Waste!" has its internet pages.


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