Chemicals Calling for Priority Action an Analysis of the Inventory of Existing Chemical

Substances in China 2009Tianjie Ma and Miao Zhang, Greenpeace China, Jun 2010

AbstractThis study aims to identify potentially hazardous chemicals within the Inventory of

Existing Chemical Substances in China 2009 (IECSC 2009). Through a preliminary

screening analysis using the U.S. EPA EPI Suite software and cross-checking

with six existing lists of hazardous chemicals, this study has yielded information

concerning the number of potentially hazardous chemicals existing in China and

a list of chemicals that are already identified by both international authorities and

academics as of special concern. Identifying priority chemicals in China is one of the

first urgent steps that regulatory agencies and industries need to take to rein in the

pollution caused by hazardous chemical substances, protect people’s health and

the environment and better prepare for increasing regulations on chemicals globally.

In the long run, mechanisms should be in place to restrict, reduce and ultimately

eliminate the production, use and discharge of priority hazardous chemicals in China.

IntroductionChina’s environment is threatened by a huge number of hazardous chemicals, some of which are already causing long-term and often irreversible damages. In 2009 alone, the Ministry of Environmental Protection (MEP) received reports on twelve incidents of serious heavy metal pollution, affecting the health of thousands of people, many of them children.1 Recent scientific data also shows that Persistent Organic Pollutants (POPs) are widely found in China. The downstream areas of the Yangtze River, for instance, see high concentrations of such chemicals as organochlorine pesticides (OCPs) and DDTs.2 Scientists have also found perfluorinated compounds such as PFOS and PFOA in blood samples of Chinese infants, toddlers and children, with levels higher than those observed in developed countries.3 These hazardous chemicals are putting further pressure on China’s already stressed ecosystems. Endocrine disruptors are already damaging fish populations in Chinese waters, causing increased incidence of imposex (male sex organ forming on normal females).4 Leading Chinese scientists have also discovered that TPT, a chemical continued to be used in ship paints and fungicides in China, is a major contributor to the declining numbers of the extremely endangered Chinese sturgeon.5

The above mentioned chemicals have certain common characteristics that make them particularly disturbing. They are often persistent, and do not easily break down in the environment. They are able to accumulate in the tissues of living organisms and build up along the food chain,therefore having the potential to cause great harm even at seemingly low background concentrations. Some are also able to cause cancer, alter DNA, damage reproductive systems or disrupt the hormone systems. There are hundreds of thousands of chemicals that are currently being produced and used by the human society. New chemical substances are introduced on a daily basis. The U.S. Toxic Substance Control Act (TSCA) covers over 82,000 chemicals in commerce.6 In China, a governmental inventory published in 2009 lists more than 45,000 chemicals that are currently being produced, marketed or imported in the country.7 In addition, more than 100 new chemicals are being added to the inventory every year.8 Managing these chemicals to prevent harm to the environment and human health proves to be a huge challenge for policy makers. China has only just started to regulate environmentally

hazardous chemicals and a regulatory scheme covering the large number of chemicals in commerce is yet to be developed. The country’s central environmental agency, the Ministry of Environmental Protection (MEP), has only recently set up a Chemical Management Unit under its Pollution Prevention Department. In 2009, MEP significantly revised the 2003 Measures on the Management of New Chemical Substances to incorporate registration and assessment procedures that better prevents new hazardous chemicals from entering into the market. However, up until now, no such schemes exist for the over 45000 existing chemicals that have been inventoried by the government.

As a way to bring attention to the threats posed by hazardous chemicals and to provide valuable information to policy makers interested in regulating them, Greenpeace China conducted this analysis of China's inventory of existing chemical substances (2009) to identify the chemicals that are potentially hazardous and therefore requires priority action. Identifying priority chemicals in China is one of the first urgent steps that regulatory agencies and industries need to take to rein in the pollution caused by hazardous chemical substances, protect peoples health and the environment and better prepare for increasing regulations on chemicals globally (for example REACH).

The Inventory of Existing Chemical Substances in China 2009 (IECSC 2009)The Inventory of Existing Chemical Substances in China was established initially as a basis for the management of new chemical substances.9 It consists of chemical substances that are being produced, processed, marketed, used or imported in China since 1992. In principle, it does not include pesticides, radioactive substances, food additives, pharmaceuticals and cosmetics that are separately regulated by other government agencies. The earliest version of the Inventory was compiled in 1995, and underwent continuous updates since then. In 2000, the Inventory contained 26,707 chemical substances. That figure has expanded to 45,355 in the latest 2009 version.

Chemicals Calling for Priority Action 01

Total:45355(official)/45311(checked)

CAS No.:37291(official)/37247(Checked) No CAS No.:8064

With CAS & Molecular Info:20654 With CAS but No Molecular Info:16593No CAS but

have Molecular info:2747

No CAS & No Molecular Info:5317

Wrong CAS No.:29

Bugs in EPI SUITE:9

With SMILES:16921

No SMILES match in EPI SUITE:20288

With molecular

info but No SMILES:7323

No molecular info & No SMILES:12965

A typical entry in the inventory consists of an identification number, the name of the chemical, the molecular formula of the chemical and structural information (if available). 37247 chemicals in IECSC 2009 have CAS numbers as their identification,10

while the remaining 8064 chemicals were assigned a sequence number from 1 to 8064. Only 23401 chemicals in the inventory have molecular formula information

Screening for Potentially Hazardous ChemicalsMethods

Given the large number of chemicals in commerce, protecting human health and the environment from the hazardous ones becomes a huge challenge for regulators. Traditional methods for assessing the hazards of chemical substances often require costly experiments, which leads to very limited experimental data that policy makers can use to make regulatory decisions on an ever expanding pool of chemical products. This situation prompted the development of models that try to predict properties of chemicals based on their structural information. Substantial progress has been made in this area, with the advancement of Quantitative Structural Activity Relationship (QSAR) models that can establish the relationship between a chemical’s structure with its behavior. Computerized

tools enable the application of such models to tens of thousands of substances that have gone through very little experimental scrutiny. The values predicted by the models, together with experimental data (if available), can then be compared to a set of criteria which are used to identify potentially hazardous chemicals. In this analysis, we use EPI Suite (version 4.0)12 to generate a set of property values for chemicals listed in IECSC 2009, which were then compared to internationally recognized criteria for the identification of hazardous chemicals. EPI Suite is a software developed jointly by the U.S. Environmental Protection Agency and Syracuse Research Corporation for the screening of large quantities of chemicals. It incorporates a set of 14 QSAR models that are able to predict chemical property values such as the octanol-water partition co-efficient (Log Kow), their bioconcentration factor (BCF) and their octanol-air partition coefficient (Log Koa). It also incorporates the Level III Fugacity model developed by Mackay and co-workers for the prediction of the partitioning of organic compounds in different environmental media. Such data are important for the identification of chemicals that tend to persist in the environment and to accumulate in the tissues of living

Figure I Composition of the Inventory of Existing Chemical Substances in China (2009)

02 Chemicals Calling for Priority Action

(although within this group 2747 substances do not have CAS identification). Among the 20625 substances that do have both a proper CAS identification and molecular formula information, 16921 chemicals have SMILES identification11 that allows them to be analyzed for their properties using Quantitative Structure-Activity Relationship (QSAR) modeling tools (see Figure I). This last group constitutes the basis of the analysis that follows this chapter.

Chemicals Calling for Priority Action 03

Mutagenic and toxic to Reproductive systems), EDC (endocrine disruptor) as well as long-range transport abilities. The following chart shows the lists that are used in this analysis:

The Stockholm Convention's List of Persistent Organic Pollutants (21 substances or groups of substances) 27 The Oslo-Paris (OSPAR) Convention's List of Substances for Priority Action (42 substances or groups of substances) 28 The US EPA's PBT Chemical List under the Toxic Release Inventory (20 substances or groups of substances) 29 The EU's Candidate List of Substances of Very High Concern (SVHC) under the REACH regulation30 (38 substances or groups of substances) The EU's Priority Substances List under the Water Framework Directive (33 substances or groups of substances) 31 Brown and Wania's List of 120 Potential Arctic Contaminants 32 (120 substances)

Results

The screening analysis using EPI Suite generates results that are shown in the chart below. It shows that more than 4000 chemicals in IECSC 2009 have Log Kow over 5, indicating that they might bioaccumulate in living organisms. The modeling result for BCF, another indicator of bioaccumulation, shows that 462 chemicals meet the more conservative threshold for bioaccumulation (BCF>5000), while 961 meet the more inclusive threshold used by the EU REACH regulation. Many of the chemicals are also considered persistent (according to internationally recognized criteria) in different environmental media. For instance, 2040 chemicals are predicted to have a half-life in water over 60 days; 8752 of the chemicals persist in sediments. All meeting the persistence criteria (in water, soil and sediment) set by the Stockholm Convention. It should be noted that these results may have missed a number of hazardous chemicals within IECSC 2009 due to the fact that about 54% of the entries in the inventory do not have proper structural information (or even CAS identification) that enables QSAR prediction. Even for those chemicals with proper identification and structural information, EPI Suite is inapplicable to some of them because they are inorganic or organometallic substances. In addition, certain model-predicted values should be viewed with caution. For instance, the BCF values predicted using the regression-based approach33

organisms. Different groups of researchers have used EPI Suite to screen large groups of chemicals for the potentially hazardous ones. Very recently, for example, Howard and Muir13 screened 22,043 chemicals in commerce in the U.S. and Canada for potential Persistent Organic Pollutants (POPs). An earlier study was carried out by Brown and Wania in 2008 which involved the screening of 105,584 chemicals for those most likely to become Arctic contaminants.14 In China, one study was conducted in 2003 using EPI Suite to screen IECSC 2000 (a much smaller database that consisted of 26,707 chemicals) for potential POPs.15 Scientists contend that since experimental data is in extreme shortage, tools such as EPI Suite provide "the most extensive available" database and can "help identify high concern chemicals which have not yet been closely examined."16 However, it should also be noted that the application of tools such as EPI Suite has several limitations. First of all, it is generally not suitable for inorganic and organometallic substances. Researchers have also cautioned that the application of models to a wide range of organic chemicals is still relatively untested,17 and that EPI Suite's ability of toxicity prediction is limited.18

Given the strengths and limitations of EPI Suite, we have adopted the following criteria for a preliminary screening analysis of IECSC 2009. The analysis is largely designed to show the number of potentially hazardous chemicals in the inventory, based on their Persistence and Bioaccumulation properties only. Toxicity screening is not conducted for this analysis. Whenever available, experimental data is given priority over predicted property values.

Log Kow (octanol-water partition co-efficient) > 5 19

BCF (Bioconcentration Factor) > 5000 2021

BCF (Bioconcentration Factor) > 2000 22

Half-life in water > 60 days 2324

Half-life in soil > 180 days 25

Half-life in sediment > 180 days 26

Besides a screening analysis using EPI Suite, we also cross-checked IECSC 2009 with several existing lists of high priority hazardous chemicals that are either promulgated by regulatory authorities in other countries or proposed by leading academics in the field. Such lists of priority chemicals often incorporate not only the persistence and bioaccumulation criteria, but also important criteria such as CMR (Carcinogenic,

Criteria Number

Log Kow (octanol-water partition co-efficient) > 5

4267

BCF > 5000 462

BCF > 2000 961

Half-life in water > 60 days 2040

Half-life in soil > 180 days 2040

Half-life in sediment > 180 days 8752

might be problematic in some cases when correction factors are unavailable for particular chemicals.34

The cross-checking with existing lists of hazardous chemicals found that, of the 229 discrete chemicals and 12 categories of chemicals which appear on these established lists and which have therefore already been specifically identified (and in some cases prioritised) as hazardous substances under those initiatives, 163 substances appear on the current list of chemicals on the Chinese market.35 (See full result in Appendix I) Among these chemicals, many, such as mercury compounds, are well-known PBT chemicals. Others like pentachlorophenol and nonylphenol are dangerous carcinogens or endocrine disruptors. It is noteworthy that 31 out of the 33 priority substances under the EU's Water Framework Directive are found in China's Inventory of Existing Chemicals. In addition, 11 out of the 20 priority PBT chemicals (and categories of chemicals) under the U.S. EPA's Toxic Release Inventory and 22 out of the 38 Substances of Very High Concern under the EU REACH regulation are present in China. Many of them are chemicals in widespread daily-use in applications such as textiles, electronics, paints and plastics. And some are seeing their production volume rising in China. For example, the production of atrazine, a herbicide that is listed as priority substance under EU's Water Framework Directive, has been rising each year in China since the 1980s, with the current annual production over 5000 tons.36 The fact that these chemicals are already subject to public disclosure requirements or are being phased out in other countries only raises more questions as to what should be done in China.

Mechanism to Select Hazardous Chemicals for Priority Action

The significant number of chemicals that are identified as being hazardous or potentially hazardous in China’s Inventory of Existing Chemical Substances illustrates the need for immediate action. Although China has already made progress on the so-called "Dirty Dozen," twelve persistent organic pollutants listed under the Stockholm Convention for global elimination, reduction and restriction, there are evidently many more hazardous chemicals that require greater regulatory oversight. Many of them, such as nonylphenol (NP) and octylphenol (OP), are still being used and produced widely in China. (The annual usage of NP in China was estimated to be 93000 tons in 2003, representing about 10% in global usage.)37 The fact that Chinese scientists have already documented the severe negative environmental impacts of chemicals such as TPT and NP/OP only increases the urgency of this issue. Since administrative resources are often limited, policy makers in different parts of the world have adopted screening methods developed by scientists to select the most hazardous chemicals for prioritized regulatory actions. Such efforts generate "lists" of chemicals that are deemed to be of the most concern. These lists are regularly updated to keep abreast with new developments in the scientific understanding of chemicals. There are several key elements to this approach: 1. a set of key screening/selection criteria (that are not necessarily numerical cut-off values) based on the "intrinsic properties" of chemicals: There are a few hazardous properties of chemical substances that are particularly detrimental to human health and the environment. They include:

Persistence (the ability to not readily breakdown in the environment as the result of biodegradation or other processes)Bioaccumulation (the ability to accumulate in organisms, and whose concentration can even increase further along the food chain) Carcinogenicity (the ability to cause cancer) Mutagenicity (the ability to induce mutation and genetic defects)

Table II Number of substances meeting certain indicative persistence and bioaccumulation characteristics

04 Chemicals Calling for Priority Action

Chemicals Calling for Priority Action 05

Toxicity to the reproductive system (the ability to harm the reproductive system, including its development)Endocrine Disruption (the ability to disrupt hormone systems)

Based on these intrinsic hazardous properties, regulators around the world have developed selection criteria that aim to identify the most hazardous chemicals. Examples are the Stockholm Convention's criteria for the identification of POPs (Persistent Organic Pollutants), which incorporate parameters of persistence, bioaccumulation, toxicity and the ability to long-range transport, the US EPA's criteria for PBT chemicals (Persistence, Bioaccumulation and Toxic), the European Union's criteria for the identification of Substances of Very High Concern (SVHC), which not only consider PBT chemicals and vPvB chemicals (very persistent and very bioaccumulative) but also CMR parameters. 2. a process that further ranks the chemicals based on their occurence and effect: The process ranks the initial screening result with factors related to the actual occurence of chemicals, i.e. production volumes, use patterns and monitoring data of emissions. Data on the effect of these chemicals on human and the ecosystem can also be taken into consideration. 3. a prioritzation process based on expert opinion on a list of chemicals that requires most prioritized action: This step is usually done with the support of expert judgment that assigns levels of priority to highly hazardous chemicals already identified by the previous steps. It generates a list of priority chemicals that regulators will act upon.

Such a mechanism for the selection of chemicals for prioritized action is urgently needed in China. It serves as the first step to put the most hazardous chemicals under scrutiny/control, protecting public health and the environment that are already enduring their impact. It will also mark the initiation of a more proactive approach towards hazardous chemicals in China: by actively screening for potentially harmful chemicals and taking prompt action, China, with its industries, can be better prepared for the ever increasing restrictions on hazardous chemicals globally. Therefore, we recommend that.

China should set up a mechanism to identify the most hazardous chemicals that are currently being used and produced in China and take prioritized action to restrict, reduce and finally eliminate their production, use, and discharge, import and export. Criteria for the identification should include, not exclusively, PBT, CMR and EDC. Information disclosure provisions should be in place so that the publc can be informed of the use and release of such chemicals by industry.

The mechanism should allow the regular update of the list of priority chemicals to be able to incorporate latest developments in science. It should also be an open process so that different stakeholders, including the scientific community, industry and the civil society, can all participate and give inputs.

A typical mechanism to select and prioritize hazardous chemicals is the DYMAMEC process developed under the OSPAR Convention, a treaty among North-East Atlantic nations to protect the environment, in particular the marine environment, of the area. Under the OSPAR Convention's strategy to prevent hazardous substances from polluting the area, the Dynamic Selection and Prioritisation Mechanism for Hazardous Substances (DYNAMEC)38 is established to select hazardous chemicals for prioritized reduction and ultimate phase-out. The mechanism constitutes a Selection/Screening process, a Ranking process and a Prioritization process based on the previous two steps. The Selection/Screening process picked out those hazardous substances on the basis of their "intrinsic properties" of persistence, liability to bioaccumulate and toxicity (P,B,T). After the initial screening, a Ranking process will rank the chemicals according to their actual occurrence and effects in the environment. Based on the result of the first two steps, the OSPAR Commission will make a decision on a List of Substances for Priority Action with the advice from experts. The latest OSPAR List, for instance, consists of 42 chemicals/groups of chemicals that the parties to the Convention have committed to eliminate by the year 2020.

CAS Chemical name OSPAR TRI PBT POPs SVHC WFD B&W2043-54-1 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-

12-iodo-Dodecane B&W

2043-53-0 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8-heptadecafluoro-10-iodo-Decane

B&W

3457-61-2 1,1-dimethylethyl 1-methyl-1-phenylethylPeroxide B&W80-07-9 1,1'-sulfonylbis 4-chlorobenzene B&W634-66-2 1,2,3,4-tetrachlorobenzene B&W87-61-6 1,2,3-trichlorobenzene OSPAR B&W95-94-3 1,2,4,5-tetrachlorobenzene B&W85-68-7 1,2-Benzenedicarboxylic acid, butyl phenylmethyl ester SVHC328-84-7 1,2-dichloro-4-(trifluoromethyl)-Benzene B&W107-06-2 1,2-dichloroethane, WFD626-39-1 1,3,5-tribromobenzene B&W108-70-3 1,3,5-trichlorobenzene OSPAR87-68-3 1,3-Butadiene, 1,1,2,3,4,4-hexachloro- WFD B&W4904-61-4 1,5,9-Cyclododecatriene OSPAR98-15-7 1-chloro-3-(trifluoromethyl)benzene B&W27905-45-9 1H,1H,2H,2H-Heptadecafluorodecyl acrylate B&W678-39-7 1H,1H,2H,2H-Perfluoro-1-decanol B&W865-86-1 1H,1H,2H,2H-Perfluoro-1-dodecanol B&W2043-57-4 1H,1H,2H,2H-Perfluorooctyl iodide B&W647-42-7 1H,1H,2H,2H-Tridecafluoro-1-n-octanol B&W24448-09-7 1-Octanesulfonamide,

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-heptadecafluoro-N-(2-hydroxyethyl)-N-methyl-

B&W

13472-08-7 2,2'-Azobis(2-methylbutyronitrile) B&W69045-83-6 2,3-dichloro-5-trichloromethylpyridine B&W1897-45-6 2,4,5,6-tetrachloro-1,3-Benzenedicarbonitrile B&W108-77-0 2,4,6-trichloro- 1,3,5-Triazine B&W88-06-2 2,4,6-trichlorophenol B&W732-26-3 2,4,6-tris(1,1-dimethylethyl)-Phenol OSPAR121-14-2 2,4-Dinitrotoluene SVHC69045-78-9 2-chloro-5-trichloromethylpyridine B&W84-51-5 2-ethyl- 9,10-Anthracenedione B&W63734-62-3 3- 2-chloro-4-(trifluoromethyl)phenoxy -benzoic acid B&W55525-54-7 3,3'-(ureylenedimethylene)bis(3,5,5-trimethylcyclohexyl)

diisocyanateOSPAR

75147-20-5 3-Butenoic acid, 2,2,3,4,4-pentachloro-, butyl ester B&W98-73-7 4-(1,1-dimethylethyl)- Benzoic acid B&W793-24-8 4-(dimethylbutylamino)diphenylamin (6PPD) OSPAR117-08-8 4,5,6,7-tetrachloro- 1,3-Isobenzofurandione B&W83-32-9 Acenaphthylene, 1,2-dihydro- OSPAR TRI PBT79-06-1 Acrylamide SVHC15972-60-8 Alachlor WFD3825-26-1 Ammonium perfluorooctanoate B&W120-12-7 Anthracene OSPAR TRI PBT SVHC WFD90640-80-5 Anthracene oil, anthracene-low SVHC1303-28-2 Arsenic oxide SVHC1327-53-3 Arsenic trioxide SVHC1912-24-9 Atrazine WFD101-77-9 Benzenamine, 4,4 -methylenebis- SVHC71-43-2 Benzene WFD120-82-1 Benzene, 1,2,4-trichloro- OSPAR WFD B&W136-60-7 butyl benzoate B&W7440-43-9 CADMIUM OSPAR WFD115-28-6 Chlorendic acid B&W115-27-5 Chlorendic anhydride B&W144-79-6 chloromethyldiphenylsilane B&W2921-88-2 Chlorpyrifos WFD7646-79-9 Cobalt chloride SVHC294-62-2 Cyclododecane OSPAR52314-67-7 Cypermethric acid chloride B&W50-29-3 DDT POPs B&W78-63-7 DHBP B&W53-70-3 Dibenz(a,h)anthracene OSPAR TRI PBT

APPENDIX I

06 Chemicals Calling for Priority Action

Chemicals Calling for Priority Action 07

80-10-4 dichlorodiphenylsilane B&W75-09-2 dichloromethane WFD115-32-2 Dicofol OSPAR B&W60-57-1 Dieldrin POPs84-69-5 Diisobutyl phthalate SVHC88-85-7 Dinoseb B&W512-04-9 Diosgenin OSPAR330-54-1 Diuron WFD540-97-6 Dodecamethylcyclohexasiloxane B&W115-29-7 Endosulfan OSPAR WFD B&W72-20-8 Endrin POPs118-74-1 hexachlorobenzene TRI PBT POPs WFD B&W77-47-4 Hexachlorocyclopentadiene B&W34123-59-6 Isoproturon WFD7439-92-1 LEAD OSPAR TRI PBT WFD7758-97-6 Lead chromate SVHC12656-85-8 Lead chromate molybdate sulfate red(C.I. Pigment Red

104)SVHC

1344-37-2 Lead sulfochromate yellow (C.I. Pigment Yellow 34) SVHC7439-97-6 MERCURY OSPAR TRI PBT WFD72-43-5 Methoxychlor OSPAR TRI PBT64667-33-0 Methyl 4,6,6,6-tetrachloro-3,3-dimethylhexanoate B&W81-14-1 Musk ketone B&W81-15-2 Musk Xylene OSPAR SVHC B&W91-20-3 Naphthalene OSPAR TRI PBT WFD52270-44-7 Neodecanoic acid, cobalt(2+) salt B&W51000-52-3 Neodecanoic acid, ethenyl ester OSPAR1691-99-2 N-EtFOSE alcohol B&W7440-02-0 NICKEL WFD1836-75-5 Nitrofen B&W115-25-3 Octafluorocyclobutane B&W140-66-9 Octylphenol OSPAR WFD98-56-6 p-Chlorobenzotrifluoride / 1-chloro-4-(trifluoromethyl)-

Benzene B&W

40487-42-1 Pendimethalin TRI PBT608-93-5 Pentachlorobenzene, TRI PBT POPs WFD133-49-3 Pentachlorobenzenethiol, B&W82-68-8 Pentachloronitrobenzene B&W87-86-5 Pentachlorophenol, OSPAR WFD86508-42-1 Perfluoro compounds, C5-18 B&W423-50-7 Perfluorohexane Sulphonyl Fluoride B&W311-89-7 Perfluorotributylamine B&W338-84-1 Perfluorotripentylamine B&W1763-23-1 PFOS OSPAR POPs29081-56-9 PFOS ammonium (NH4+) salt POPs70225-14-8 PFOS diethanol-amine (DEA) salt POPs29457-72-5 PFOS lithium (Li+) salt POPs2795-39-3 PFOS potassium (K+) salt POPs2116-84-9 Phenyltris(trimethylsiloxy)silane B&W65996-93-2 Pitch, coal tar, high temp SVHC1336-36-3 Polychlorinated biphenyls (PCBs) OSPAR TRI PBT POPs307-35-7 PFOSF POPs B&W122-34-9 Simazine WFD10588-01-9 Sodium dichromate anhydrate SVHC7789-12-0 Sodium dichromate, dihydrate SVHC688-73-3 Tributylstannane WFD67-66-3 Trichloromethane WFD1582-09-8 Trifluralin OSPAR TRI PBT WFD1652-63-7 Trimethyl-1-propanaminium iodide POPs115-96-8 Tris(2-chloroethyl)phospate SVHC

Dioxin and Dioxin-like compounds1746-01-6 2,3,7,8-TCDD TRI PBT POPsPolycyclic aromatic Hydrocarbons (PAHs)91-20-3 Naphthalene OSPAR TRI PBT WFD56-55-3 Benz(a)anthracene OSPAR TRI PBT83-32-9 Acenaphthylene, 1,2-dihydro- OSPAR TRI PBT86-73-7 Fluorene OSPAR TRI PBT

85-01-8 Phenanthrene OSPAR TRI PBT120-12-7 Anthracene OSPAR TRI PBT SVHC WFD129-00-0 Pyrene OSPAR TRI PBT206-44-0 Fluoranthene OSPAR TRI PBT WFD50-32-8 Benzo(a)pyrene OSPAR TRI PBT WFD53-70-3 Dibenz(a,h)anthracene OSPAR TRI PBTBrominated Flame Retardants3194-55-6 1,2,5,6,9,10-hexabromo-Cyclododecane OSPAR B&W147-82-0 2,4,6-tribromobenzenamine B&W118-79-6 2,4,6-tribromophenol OSPAR B&W92-86-4 4,4'-Dibromobiphenyl OSPAR2050-47-7 4,4'-Dibromodiphenyl Ether OSPAR92-66-0 4-Bromobiphenyl OSPAR13654-09-6 Decabromobiphenyl OSPAR68928-80-3 Heptabromobiphenyl ether OSPAR POPs B&W25637-99-4 HexabromoCyclododecane OSPAR B&W36483-60-0 Hexabromodiphenyl ether OSPAR POPs B&W32536-52-0 Octabromodiphenyl ether OSPAR B&W63936-56-1 Pentabromo(tetrabromophenoxy)-benzene OSPAR B&W32534-81-9 Pentabromodiphenyl ether OSPAR POPs B&W1163-19-5 Pentabromophenyl ether OSPAR B&W79-94-7 Tetrabromobisphenol A (TBBP-A) OSPAR TRI PBT B&W40088-47-9 Tetrabromodiphenyl ether OSPAR POPs B&W632-79-1 Tetrabromophtalic anhydride OSPAR B&W49690-94-0 Tribromodiphenyl ether OSPAROrganic tin compounds7440-31-5(org)

Organic tin compounds OSPAR

683-18-1 Dibutyltin (DBT) OSPAR639-58-7 Triphenyltin (TPT) OSPAR56-35-9 Hexabutylditin OSPAR SVHCShort chained chlorinated paraffins (SCCP)85535-84-8 Chloroalkanes C10-13 OSPAR SVHC WFDHexachlorocyclohexane isomers (HCH)319-85-7 β-666 OSPAR POPs58-89-9 Lindane OSPAR POPs WFD B&W319-86-8 delta-Hexachlorocyclohexane OSPARNonylphenol/ethoxylates (NP/NPEs) and related substances25154-52-3 Nonyl-Phenol OSPAR WFD104-40-5 (4-(para)-nonylphenol) OSPAR WFD84852-15-3 4-Nonylphenol OSPAR11066-49-2 Isononylphenol(mixed isomers) OSPARCertain phthalates: dibutylphthalate (DBP), diethylhexylphthalate (DEHP)84-74-2 Dibutyl phthalate OSPAR SVHC117-81-7 DEHP OSPAR SVHC WFDPolychlorinated naphthalenes1321-65-9 Trichloronaphthalene OSPAR1335-88-2 Tetrachloronaphthalene OSPAR

08 Chemicals Calling for Priority Action

1 China Central Government Website, «Speech by Minister Zhou Shengxian at the National Environmental Protection Conference 2010,» Jan 25, 2010. Available at: http://www.gov.cn/gzdt/2010-01/30/content_1523387.htm (accessed Jun 11, 2010)2 Kong, Dingjiang, Daoji Li and Ying Wu. «Evolution of Organic Pollution in the Changjiang River Estruary in the Past Fifty Years,» Transactions of Oceanology and Limnology, No. 2, 2007, pp. 94-1013 Zhang, Tao et al. «Perfluorinated Compounds in Whole Blood Samples from Infants, Children and Adults in China,» Environmental Science and Technology, Vol. 44, No.11, 2010, pp. 4341-43474 An, Wei and Jianying Hu. «Effects of Endocrine Disrupting Chemicals on China's Rivers and Coastal Waters, » Frontiers in Ecology and the Environment, Vol.4, No.7, 2006, pp. 378-3865 Hu, Jianying et al. «Malformations of the Endangered Chinese Sturgeon Acipenser Sinensis, and its causal agents,» PNAS, Vol. 109, No. 23, 9339-9344. 6 Brown, Trevor N. and Frank Wania. «Screening Chemicals for the Potential to be Persistent Organic Pollutants: A Case Study of Arctic Contaminants,» Environmental Science and Technology, Vol. 42, No. 14, 2008, p. 5202. 7 Chemical Registration Center of the Ministry of Environemntal Protection, China. Inventory of Existing Chemical Substances in China, 2009.8 Liu, Jian guo, Zhengyu Li and Yan Mao. «Major Issues and Policy Framework for Environmentally Sound and Strategic Management of Chemicals in China,» Special Policy Study Report, CCICED, 2007.9 The term «new chemical substance» is defined as any substance that is not listed in the Inventory of Existing Chemical Substances in China.10 Some entries in the original IECSC 2009 are duplicated (42), and after deleting them there are still 29 entries with wrong CAS numbers that cannot be fixed.11 SMILES (simplified molecular input line entry specification) is a specification for unambiguously describing the structure of chemical molecules using short ASCII strings. We checked the chemicals listed in IECSC 2009 in the EPI Suite database for available SMILES identification.12 US EPA. Estimation Programs Interface Suite™ for Microsoft® Windows, v 4.00. United States Environmental Protection Agency, Washington, DC, USA, 2010.13 Howard, Philip H. and Derek Muir. «Identifying New Persistent and Bioaccumulative Organics among Chemicals in Commerce,» Environmental Science and Technology, Vol. 44, No. 7, 2010, pp. 2277-228514 Brown, Trevor N. and Frank Wania. «Screening Chemicals for the Potential to be Persistent Organic Pollutants: A Case Study of Arctic Contaminants,» Environmental Science and Technology, Vol. 42, No. 14, 2008, p. 5202.15 Huang, Jun, Gang Yu and Pengyi Zhang. «Computer-aided Primary Screening for Potential Persistent Organic Pollutants in China,» Environmental Pollution and Prevention, Vol. 25, No.1, 2003, pp. 16-1916 Brown, Trevor N. and Frank Wania. «Screening Chemicals for the Potential to be Persistent Organic Pollutants: A Case Study of Arctic Contaminants,» Environmental Science and Technology, Vol. 42, No. 14, 2008, p. 5203.17 Brown, Trevor N. and Frank Wania. «Screening Chemicals for the Potential to be Persistent Organic Pollutants: A Case Study of Arctic Contaminants,» Environmental Science and Technology, Vol. 42, No. 14, 2008, p. 5203.18 Huang, Jun, Gang Yu and Pengyi Zhang. «Computer-aided Primary Screening for Potential Persistent Organic Pollutants in China,» Environmental Pollution and Prevention, Vol. 25, No.1, 2003, p.1719 This is an indicator of a chemical's ability to bioaccumulate that is used by the Stockholm Convention, the UNECE Convention on Long-range Transboundary Air Pollution and the Canadian Toxic Substance Management Policy

20 There are two approaches to the prediction of BCF in the QSAR model (BCFBAF), the regression-based approach and the Arnot-Gobas approach. In this analysis we use the regression-based approach to predict the BCF values, which is also used in the previous studies above mentioned.21 This is an indicator of a chemical's ability to bioaccumulate adopted by the Stockholm Convention, the UNECE Convention on Long-range Transboundary Air Pollution, European Union's REACH regulation (vPvB criteria), and the New Chemicals Program under the U.S. Toxic Substance Control Act22 This is a more expansive bioaccumulation indicator used by the European Union's REACH regulation (PBT criteria)23 All half-life data was generated using the Level III Fugacity Model24 This is an indicator of a chemical's persistence in the environment adopted by the Stockholm Convention, the UNECE Convention on Long-range Transboundary Air Pollution and the European Union's REACH regulation (vPvB criteria)25 This is an indicator of a chemical's persistence in the environment adopted by the Stockholm Convention and the UNECE Convention26 This is an indicator of a chemical's persistence in the environment adopted by the Stockholm Convention and the UNECE Convention) 27 The Stockholm Convention's List of Persistent Organic Pollutants, Available at: http://chm.pops.int/Convention/ThePOPs/tabid/673/language/en-US/Default.aspx (Accessed Jun 21, 2010)28 OSPAR List of Chemicals for Priority Action, Available at: http://www.ospar.org/documents/DBASE/DECRECS/Agreements/04-12e_List%20of%20Chemicals%20for%20Priority%20action.doc (Accessed Jun 21, 2010)29 TRI PBT Chemical List, Available at: http://www.epa.gov/triinter/trichemicals/pbt%20chemicals/pbt_chem_list.htm (Accessed Jun 21, 2010)30 Candidate List of Substances of Very High Concern for Authorization (updated Mar 30, 2010), Available at: http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp (Accessed Jun 21, 2010)31 Priority Substances under the Water Framework Directive, Available at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2001:331:0001:0005:EN:PDF (Accessed Jun 21, 2010)32 Brown, Trevor N. and Frank Wania. «Screening Chemicals for the Potential to be Persistent Organic Pollutants: A Case Study of Arctic Contaminants,» Environmental Science and Technology, Vol. 42, No. 14, 2008, p. 520233 The estimation equations used by BCFBAF are:

Log BCF = 0.6598 Log Kow - 0.333 + Σ correction factors (for Log Kow 1.0 to 7.0)Log BCF = -0.49 Log Kow + 7.554 + Σ correction factors (for Log Kow > 7.0)

34 Huang, Jun, Gang Yu and Pengyi Zhang. «Computer-aided Primary Screening for Potential Persistent Organic Pollutants in China,» Environmental Pollution and Prevention, Vol. 25, No.1, 2003, p.1935 This is not including the 135 lead compounds, 35 mercury compounds and 95 nickel compounds that are listed under IECSC 2009. Only lead, mercury and nickel themselves are included in the cross-checking exercise. Moreover, it is also possible that the cross-checking does not capture all the individual chemicals belonging to one big category, such as «brominated flame retardants», which is listed under the OSPAR Convention as a whole.36 An, Wei and Jianying Hu. «Effects of Endocrine Disrupting Chemicals on China's Rivers and Coastal Waters, » Frontiers in Ecology and the Environment, Vol.4, No.7, 2006, p. 38237 Ibid., p.38138 The Dynamic Selection and Prioritisation Mechanism for Hazardous Substances, Available at: http://www.ospar.org/documents/DBASE/Publications/p00256_New%20DYNAMEC%20Manual.pdf (Accessed Jun 21, 2010)

NOTE:OSPAR = OSPAR List of Chemicals for Priority ActionTRI PBT = List of PBT Chemicals under the U.S. Toxic Release InventoryPOPs = List of Persistent Organic Pollutants under the Stockholm ConventionSVHC = EU's Candidate List of Substances of Very High Concern (SVHC) under the REACH regulationWFD = EU's Priority Substances List under the Water Framework DirectiveB & W = Brown and Wania's List of 120 Arctic Contaminants

Chemicals Calling for Priority Action 09

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