Impact assessment

Summary of responses and government response

Updated 15 August 2023

Executive summary

Defra held a call for information for 3 substances being proposed for listing as Persistent Organic Pollutants (POPs) on the UN Stockholm Convention. POPs proposals are reviewed by the Convention’s POPs Review Committee (POPRC), and POPRC had requested additional information about these substances to feed into draft Risk Profiles and draft Risk Management Evaluations documents.

These substances were:

• chlorpyrifos
• chlorinated paraffins with carbon chain lengths in the range C14 to 17 and with chlorination levels at or exceeding 45 percent chlorine by weight, known as medium-chain chlorinated paraffins (MCCPs)
• long-chain perfluorocarboxylic acids, their salts and related compounds (LC-PFCAs)

This call for information was held to collect additional information relating to the adverse effects resulting from the long-range transport of chlorpyrifos, to inform revisions to the draft risk profile for chlorpyrifos (Annex E of the Stockholm Convention).

The first risk profile for chlorpyrifos set out the evidence that this substance meets the criteria for a POP. Further information was required relating to the adverse effects resulting from long-range transport of chlorpyrifos, to enable revisions to be made to the first draft risk profile ahead of the 19th meeting of the POPRC.

The call for information was also held to collect information on any social and economic impacts of a ban or restriction of MCCPs and LC-PFCAs, to be used to assist with drafting Risk Management Evaluations (RMEs) for MCCPs and LC-PFCAs (Annex F of the Stockholm Convention). This information informed the need for specific exemptions and acceptable uses of the substances.

Number of responses

2 responses were received for MCCPs from:

• Chartered Institution of Wastes Management (CIWM) - a UK-based professional membership organisation for individuals and affiliated organisations in the sustainability, resources and waste management sector across the UK and overseas.
• H&I Chemicals Ltd - a UK-based buyer and supplier of chemicals to UK industry.

Summary of responses

CIWM provided information on the uses of MCCPs for the purposes of considering the need for any specific exemptions and acceptable uses.

CIWM reported that MCCPs have been used as flame retardants and plasticisers in plastics (especially in electrical and electronic equipment), in rubbers, inks, paints, adhesives, surface coatings and in leather from shoe manufacture.

CIWM also reported that they believe MCCPs are still used as secondary plasticisers in some flexible polyvinyl chloride (PVC) applications where flame-retardancy is important but, as PVC cloth applications are reducing in number, they would not expect the use of MCCPs in such applications to be very common.

H&I Chemicals Ltd provided a general overview of the use of MCCPs, including emissions, costs and use of alternatives. They reported that MCCPs are used in many applications as plasticisers to impart flexibility to finished products without which products would be brittle and not able to perform as required and that in some applications MCCPs not only act as plasticisers but also offer some flame retardancy properties.

H&I Chemicals provided information on plasticisers available as alternatives to MCCPs. They reported that long chain chlorinated paraffins (LCCPs), long chain phthalates and citrate plasticisers are all significantly more expensive than MCCPs, and that both long chain phthalates and citrate plasticisers do not generally offer flame-retardant properties.

H&I Chemicals suggested that to ban the use of MCCPs would add to the costs of the products in which they are used in, which could present challenges. They also suggested that, providing there are adequate controls on the use of MCCPs during production processes, there should be minimal risk of release of MCCPs to the environment.

Government response

The draft POPRC evaluation documents for MCCPs are being drafted by the UK. During the drafting process, Defra has considered the comments and additional information supplied to us via this call for information, as well as other information gathered during targeted stakeholder engagement, and the information passed on to Defra by POPRC following their own call for information.

The Stockholm Convention website has more information about POPRC’s calls for information.

The RME for MCCPs has now been through 3 rounds of commenting by the POPRC intersessional working group. The second draft was made available for comment on the Stockholm Convention website, and was also open for comments on GOV.UK for a period of 8 weeks, alongside the draft RME for LC-PFCAs and the revised draft risk profile for chlorpyrifos. Read about the draft evaluations of 3 chemical substances proposed as Persistent Organic Pollutants (POPs): call for comments.

The UK submitted the fourth draft of the MCCPs RME to the POPRC in June 2023, where it will be considered at the next POPRC meeting (October 2023), alongside the draft RME for LC-PFCAs and the draft risk profile for chlorpyrifos.