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Pentechlorophenol (PCP)

 

 

(I) German Regulations / Test Methods

 

German Food and Commodities Act LMBG, Recommendation XL VII

 

Chemikalienverbotsverordnung – Chemical prohibition Act – Pentachlorophenol (PCP) in wood and textiles

 

Extractable PCP - German Chemical Prohibition Regulation Appendix 15, DIN 53313:1996

 

DIN CEN/TS14494, § 35 LMBG B 82.02-8 2001-06, IUC 25 – Nachweis und Bestimmung von Pentachlorphenol in Bedarfsgegenständen, insbesondere aus Leder und Textilien (DIN 53313)

Leather and Textiles - Chemical tests - Determination of Pentachlorophenol (PCP) content

 

 

(II) Germany – Pentachlorophenol (PCP) in several products

 

Pentachlorophenol (PCP) can be used to prevent fungal growth and decay by bacteria. In textile and leather industry, PCP is mostly used for preservation finishing; in ligneous products PCP can be used in conservation paints. PCP can also be used in wooden toys and handicrafts.

PCP and its salts are highly toxic for aquatic systems, harmful to human health and highly persistent in the environment. Products containing PCP may form highly toxic substances when they are incinerated.

In Germany, import and trade of products containing more than 5 ppm PCP (pentachlorophenol), pentachlorophenol sodium, all pentachlorophenol salts and compounds in products is prohibited. In practice, the low maximum concentrations allowed in
Germany imply that the use of PCP is prohibited.

The legislation in
Germany is stricter than the EU legislation (Directive 91/173 of 5 April 1993) concerning PCP (maximum 0,1% by weight (1000 ppm).

 

 

 

(III) Regulatory Impact Assessment -- Pentachlorophenol (PCP)

 

Implementation of the 5th amendment to Annex 1 of the Marketing and Use Directive - Council Directive 76/769/EEC (Pentachlorophenol)

 

1. Purpose and Intended Effect of the Measure

 

New Regulations to introduce a lower permissible content of total hexachlordibenzoparadioxin (H6CDD) in pentachlorophenol (PCP) preparations placed on the market. Required to meet the UK's obligation to implement the provisions (in part) of European Commission Directive 1999/51/EC (the 5th amendment to Annex 1 of the Marketing and Use Directive 76/769/EEC).

The Regulations reduce the permitted total H6CDD content in PCP, or any substance containing PCP, to 2 parts per million from 4 parts per million and provide that PCPs may no longer be used in industrial installations as a synthesising and/or processing agent in industrial processes. The Regulations also remove the exemption permitting the use of structural timbers treated with PCPs.

Given the hazards of PCP and H6CDD, the Regulations seek to minimise the overall risk to man and the environment.

 

2. Risk Assessment

 

The Directive was negotiated in 1998/99 as part of a package including organostannic compounds (tributyltin) and cadmium; DTI, HSE and the then DETR collaborated in these discussions. The Directive was negotiated because of the EU Accession Treaty for Sweden, Finland and Austria (who had previously banned PCP). It is based on an assessment of human occupational and consumer exposure as well as environmental risk conducted by Environmental Resources Management (ERM) Ltd on behalf of the European Commission. A detailed opinion was given by the EC Scientific Committee for Toxicity, Ecotoxicity and Environment (CSTEE), based on the ERM report and additional published literature. The CSTEE concluded that human exposure could occur from contaminated soil and that there was a risk to the environment from localised 'hotspots'.

 

3. Options

 

The proposed Regulations are required to fulfil the UK's obligation to implement the provisions (in part) of European Commission Directive 1999/51/EC (the 5th amendment to Annex 1 of the Marketing and Use Directive 76/769/EEC). Directive 76/769/EEC harmonises Member States' controls over the marketing and use of dangerous substances and a series of amendments since 1976 have added further substances and/or restrictions to those already controlled. Article 2 of the Directive calls for Member States to apply its provisions from 1 September 2000. There are no options other than to implement. Failure to do so will result in legal action by the European Commission against the UK.

 

4. Benefits

 

The Regulations minimise risks posed by PCP and H6CDD to human health and the environment in the EU. PCP is known to cause chloracne in occupational exposures and is on the EU 'red list' as toxic to the environment; H6CDD is an unwanted contaminant in PCP.

 

5. Business Sectors Affected

 

PCP is manufactured in the United States and imported for use by the Wood Preserving and Damp Proofing industry and the Textile industry, which are the only UK sectors to be affected by this legislation. Most companies have already withdrawn PCP products on commercial grounds and remaining uses are due to cease in 2008 in any case. The UK firm Catomance Ltd produces PCP laurate as a synthesising/processing agent, but DG Sanco have confirmed that this manufacture is not prohibited by this Directive. The Defence Logistics Organisation (DLO), which used PCP laurate for application to military items such as parachute webbing, have confirmed that they have taken steps to secure alternative finishes for the products under their responsibility.

 

6. Compliance Costs for a Typical Business

 

No costs to business are expected as a consequence of the Regulations. We have conducted the normal consultation process with the Wood Preserving and Damp Proofing industry, the Textile industry, DLO and Catomance Ltd, none of whom made any comments. DLO will incur costs in testing for an alternative which meets NATO specifications, but it appears unlikely that these will be passed on to business.

 

7. Consultation Process

 

The DTI, the National Assembly of Wales and the Scottish Executive were consulted in the normal way and all are content with implementation of the proposed Regulations on a GB-wide basis, as proposed. DoENI are transposing the requirements of 1999/51/EC separately into Northern Ireland legislation.

 

8. Summary and Recommendations

 

It is recommended that the part of Directive 1999/51/EC dealing with PCP is enacted into national law using powers conferred by section 2(2) of the European Communities Act 1972. This option minimises risks posed by PCP and fulfils the UK's obligation to implement the provisions of the European Directive. The costs associated with the Regulations will be negligible.

 

 

 

(IV) What is Pentechlorophenol (PCP) ?

 

Introduction

 

Pentachlorophenol (PCP) is a synthetic substance that was first produced in the 1930s. It is marketed under the trade names, Santophen, Pentachlorol, Chlorophen, Chlon, Dowicide 7, Pentacon, Penwar, Sinituho and Penta among others. It can be found in two forms: PCP itself or as the sodium salt of PCP, which dissolves easily in water. In the past, it has been used as a herbicide, insecticide, fungicide, algaecide, disinfectant and as an ingredient in antifouling paint. Some applications were in agricultural seeds (for nonfood uses), leather, masonry, wood preservation, cooling tower water, rope and paper mill system.

Since the early 1980s, the purchase and use of PCP in the U.S has not been available to the general public. Nowadays most of the PCP used in the U.S is restricted to the treatment of utility poles and railroads ties.

There are two general methods for preserving wood. The pressure process method involves placing wood in a pressure-treating vessel where it is immersed in PCP and then subjected to applied pressure. In the non-pressure process method, PCP is applied by spraying, brushing, dipping, and soaking. Utility companies save millions of dollars in replacement poles, because the life of these poles increases from approximately 7 years for an untreated pole to about 35 years for a preservative-treated pole.

 

Toxicity

 

Short-term exposure to large amounts of PCP can cause harmful effects on the liver, kidneys, blood, lungs, nervous system, immune system, and gastrointestinal tract. Further, elevated temperature, profuse sweating, uncoordinated movement, muscle twitching, and coma are additional side effects.

Contact with PCP (particularly in the form of vapor) can irritate the skin, eyes, and mouth. Long-term exposure to low levels such as those that occur in the workplace can cause damage to the liver, kidneys, blood, and nervous system. Finally exposure to PCP is also associated with carcinogenic, renal, and neurological effects. The EPA classifies PCP in group B2 (probable human carcinogen).

 

Releases to the environment

 

PCP has been detected in surface waters and sediments, rainwater, drinking water, aquatic organisms, soil, and food, as well as in human milk, adipose tissue, and urine. As PCP is generally used for its properties as a biocidal agent, there is considerable concern about adverse ecosystem effects in areas of PCP contamination.

Releases to the environment are decreasing as a result of falling consumption and changing use methods. However, PCP is still released, to surface waters from the atmosphere by wet deposition, from soil by run off and leaching, manufacturing and processes facilities. Also, PCP is released directly into the atmosphere via volatilization from treated wood products and during production. Finally, releases to the soil can be by leaching from treated wood products, atmospheric deposition in precipitation (such as rain and snow), spills at industrial facilities and at hazardous waste sites. In the United States, any drinking water supply with a PCP concentration exceeding the MCL, 1 ppb, must be notified by the water supplier to the public. Disposal of PCP and PCP contaminated substances are regulated under RCRA as a F-listed hazardous waste.

 

Environmental fate

 

After PCP is released into the atmosphere it is transformed via photolysis. The main biodegradative pathway for PCP is reductive dehalogenation. In this process, the compound PCP is broken down to tetra-, tri-, and dichlorophenols. Another pathway is methylation to pentaclhloroanisole (a more lipid soluble compound). These two methods eventually lead to ring cleavage and complete degradation.

In shallow waters, PCP is also quickly removed by photolysis. In deep or turbid water processes such as sorption and biodegradation take place. In reductive soil and sediments, PCP can be degraded within 14 days to 5 years, depending on the anaerobic soil bacteria that are present. However, adsorption of PCP in soils is pH dependent because it increases under acidic conditions and it decreases in neutral and basic conditions.

 

 

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