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UNEP/CHW/OEWG/4/INF/8

Distr.: General18 May 2005

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Open-ended Working Group of the Basel Conventionon the Control of Transboundary Movements ofHazardous Wastes and Their DisposalFourth sessionGeneva, 4–8 July 2005Item 5 (k) of the provisional agenda

Implementation of the decisions adopted by the Conferenceof the Parties at its seventh meeting: technical guidelineson persistent organic pollutants (decision VII/13)

Draft technical guidelines for environmentally sound management of wastes consisting of, containing or contaminated with dicholorodiphenyltrichloroethane (DDT)

Attached is the draft technical guidelines for environmentally sound management of wastes consisting of, containing or contaminated with dicholorodiphenyltrichloroethane (DDT) prepared by Mexico and comments submitted by Germany for consideration by the present meeting.

UNEP/CHW/OEWG/4/1.

200505

For reasons of economy, this document is printed in a limited number. Delegates are kindly requested to bring their copies to meetings and not to request additional copies.


Table of contents

I. Introduction................................................................................................4A. Scope .................................................................................................................................4B. Description, production, use and wastes..........................................................................41. Description...........................................................................................................................42. Use .................................................................................................................................53. Production............................................................................................................................5II. Relevant provisions of the Basel and Stockholm Conventions..............6A. Basel Convention................................................................................................................6B. Stockholm Convention......................................................................................................7III. Issues under the Stockholm Convention to be addressed cooperatively with the Basel Convention.................................................................................10A. Low POP content.............................................................................................................10B. Levels of destruction and irreversible transformation.................................................10C. Methods that constitute environmentally sound disposal............................................10IV. Guidance on environmentally sound management (ESM)..................10A. General considerations....................................................................................................101. Basel Convention...............................................................................................................102. Stockholm Convention......................................................................................................103. Organization for Economic Cooperation and Development..............................................10B. Legislative and regulatory framework..........................................................................11C. Waste prevention and minimization..............................................................................11D. Identification and inventories.........................................................................................121. Identification......................................................................................................................122. Inventories.........................................................................................................................13E. Sampling, analysis and monitoring................................................................................131. Sampling............................................................................................................................132. Analysis.............................................................................................................................143. Monitoring.........................................................................................................................15F. Handling, collection, packaging, labelling, transportation and storage.....................151. Handling.............................................................................................................................162. Collection...........................................................................................................................163. Packaging...........................................................................................................................174. Labelling............................................................................................................................175. Transportation....................................................................................................................176. Storage ..............................................................................................................................18G. Environmentally sound disposal.....................................................................................181. Pretreatment.......................................................................................................................182. Destruction and irreversible transformation methods........................................................183. Other disposal methods when destruction or irreversible transformation does not

represent the environmentally preferable option...............................................................184. Other disposal methods when the POP content is low......................................................18H. Remediation of contaminated sites.................................................................................18I. Health and safety.............................................................................................................181. High-volume, high-concentration or high-risk situations..................................................192. Low-volume, low-concentration sites or low-risk situations.............................................20J. Emergency response........................................................................................................20K. Public participation.........................................................................................................20

Annexes

I. Synonyms and trade names for DDT...........................................................................................21II. Bibliography .............................................................................................................................22

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Abbreviations and acronyms

ABS acrylonitrile butadiene styreneESM environmentally sound managementDDT DichlorodiphenyltrichloroethaneDE Destruction efficiencyDRE Destruction removal efficiencyGC gas chromatographyHASP health and safety planIPCS International Programme on Chemical SafetyMS mass spectrometryPBB polybrominated biphenylPCB polychlorinated biphenylPCDD polychlorinated dibenzo-p-dioxinPCDF polychlorinated dibenzofuranPCT polychlorinated terphenylPOP persistent organic pollutantTEQ toxic equivalent UNECE United Nations Economic Commission for EuropeUNEP United Nations Environment Programme

Units of measurement

gal gallonl litre

kg kilogrammg milligramng nanogram

Nm3 normal cubic metre refers to dry gas volume measured at 0 oC and 1 atmosphere of pressure (273.15 oK and 101.3kPa).

Rm3 reference cubic metre refers to dry gas volume measured at 25 oC and 1 atmosphere of pressure (298.15 oK and 101.3kPa).

kPa kilopascalkW kilowattkWh kilowatt-hoursMJ megajoule

mg/kg: Milligram(s) per kilogram. A measure of the concentration of an analyte in a given solid medium. Corresponds to parts per million (ppm) by weight.

μg/kg: Microgram(s) per kilogram. A measure of the concentration of an analyte in a given solid medium. Corresponds to parts per billion (ppb) by weight.

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I. Introduction

A. Scope

These technical guidelines provide guidance for the environmentally sound management (ESM) of wastes consisting of, containing or contaminated with dichlorodiphenyltrichloroethane (DDT) in accordance with decisions V/8, VI/23 and VII/13 of the Conference of the Parties to the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, decisions OEWG-I/4, OEWG-II/10 and OEWG-III/8 of the Open-ended Working Group of the Basel Convention, and taking into account decisions INC-6/5 and INC-7/6 of the Intergovernmental Negotiating Committee for an International Legally Binding Instrument for Persistent Organic Pollutants. The Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants will consider these guidelines in accordance with article 6.2 of that convention.

Along with DDT, these Technical Guidelines addresses containers, contaminated soil and other equipments or wastes that could be in contact or use with DDT as a class or category of substances owing to similarities acquired by the contamination or contact in the physico-chemical and toxicological properties of these substances. Topics addressed include conformation of inventories for purposes of identification, stock and waste management in the warehouses, and finally treatment and disposal techniques.

This document should be used in conjunction with the General Technical Guidelines for Environmentally Sound Management of Wastes Consisting of, Containing or Contaminated with Persistent Organic Pollutants (General Technical Guidelines). This document provides more detailed information on the nature and occurrence of wastes consisting of, containing or contaminated with DDT for purposes of their identification and management.

B. Description, production, use and wastes

1. Description

The dichlorodiphenyltrichloroethane commonly known as DDT is a group of halogenated aromatic hydrocarbons (Tomes Plus System From Micromedex). The substance DDT was synthesized by Zeidler in Switzerland for first time in 1874, it does not occur naturally in the environment, its pesticides properties were recognized until 1939 by Paul Muller.

DDT’s molecular structure indicates that it is a chemically stable substance and therefore persistent, due to the delocalization mainly of the electronic cloud on the benzenes rings, in which participates too the electronic cloud of chlorine atoms. Due to thr aromatics characteristics and charge distribution, this molecule is soluble in non-polar dissolvents and fat (lipophylice); therefore it can bioaccumulates and biomagnify1, as many studies have shown that it is causative of adverse effects to medium and long term. The molecular structure is shown as follows:

1 Grows to concentrations many times greater than the applied or ambient concentrations.

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2. Use

DDT was the first of the chlorinated organic insecticides that came into wide commercial usage during Second World War as a pesticide against mosquitoes for the prevention of malaria, yellow fever, and control of tsetse flies (Tomes Plus System From Micromedex). It has also been used as an insecticide on crops, including tobacco and cotton. If released to the terrestrial compartment, it will adsorb very strongly to soil and be subject to evaporation and photo oxidation near the surface. It will not hydrolyze and will not significantly biodegrade in most waters. If released to the air it will be subject to direct photo degradation and reaction with photo chemically produced hydroxyl radicals. DDT was regarded as an ideal pesticide2 because it was toxic to a wide range of insects but it was relatively harmless to mammals, fish, and plants, particularly in comparison to other pesticides commonly used at the time, such as lead arsenate.

DDT was banned by most developed countries during the 1970’s due to its damaging effects on the environment and the human health. However, DDT is still used today under restrictions for vector control to prevent malaria transmission and for controlling epidemics in some countries

3. Production

The early popularity of DDT, was due to its reasonable cost, effectiveness, persistence, and versatility (EPA, 1975). In the U.S during the 30 years prior to its cancellation, a total of approximately 1,350,000,000 pounds of DDT was used domestically. After 1959, DDT usage declined greatly, dropping from a peak of approximately 80 million pounds in that year to just under 12 million pounds in the early 1970s. The decline in DDT usage was the result of (1) increased insect resistance; (2) the development of more effective alternative pesticides; (3) growing public concern over adverse environmental side effects; and (4) increasing government restrictions on DDT use. In addition to domestic consumption, large quantities of DDT have been purchased by the Agency for International Development and the United Nations and exported for malaria control. DDT exports increased from 12 percent of the total production in 1950 to 67 percent in 1969. However, exports have shown a marked decrease in recent years dropping from approximately 70 million pounds in 1970 to 35 million in 1972.

Prominent trade names of DDT products include those listed below. (See Annexx I for a more detailed list of DDT trade names and synonyms and section IV.D of the present report for considerations regarding precautions to take when using trade names in inventory exercises.)

AgritanAnofexArkotineAzotoxBosan supraBovidermolChlorophenothanDedeloDeoval

2 The International Code of Conduct on the distribution and use of pesticides (FAO, 1990) defines pesticides as: “Any substance or mixture of substances intended for preventing, destroying or controlling any pest, including vectors of human or animal disease, unwanted species of plants or animals causing harm during, or otherwise interfering with, the production, processing, storage, transport, or marketing of food, agricultural commodities, wood and wood products or animal feedstuffs, or which may be administered to animals for the control of insects, arachnids or other pests in or on their bodies. The term includes substances intended for use as a plant growth regulator, defoliant, desiccant, or agent for thinning fruit or preventing the premature fall of fruit, and substances applied to crops either before or after harvest to protect the commodity from deterioration during storage and transport”.

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4. Wastes

Obsolete pesticide stocks included DDT are present in the majority of developing countries and countries in transition (FAO 1999). Quantities in individual countries range from a few tonnes to several thousands. In 1994, FAO conducted an inventory of obsolete pesticide stocks in Africa and the Near East. Results of this inventory indicated that the total volume of obsolete pesticides in Africa probably exceeds 15000 tonnes. In 1993, at least three Asian countries were known to have quantities of obsolete pesticides within the range of 5000 to 10000 tonnes each. Unconfirmed figures from eastern European countries suggest that several of these countries hold very large quantities. The total in non-OECD countries may be well in excess of 100000 tonnes. In addition, there are large quantities of heavily contaminated soil and thousands of contaminated empty containers that must be regarded as hazardous waste. In many cases, the contaminated soil needs to be treated in the same manner as the obsolete pesticides. Common types of obsolete pesticides include organochlorine compounds such as DDT, dieldrin and HCH, which have been withdrawn or banned for public health and/or environmental reasons. Countries in the migratory locust zone often still have large quantities of these compounds remaining from old strategic stocks for locust control. Several of these stocks were acquired over 20 years ago. Another large group is organophosphates and carbamates that have deteriorated as a result of prolonged or improper storage. In many cases, obsolete pesticides are stored under conditions that do not meet basic standards for safe and responsible storage of such hazardous materials.

II. Relevant provisions of the Basel and Stockholm Conventions

A. Basel Convention

Article 1 (“Scope of Convention”) outlines the waste types subject to the Basel Convention. Article 1 paragraph 1(a) of the Basel Convention contains a two-step process for determining if a “waste” is a “hazardous waste” subject to the Convention. First, the waste must belong to any category contained in Annex I to the Convention (“Categories of Wastes to be Controlled”). Second, the waste must possess at least one of the characteristics listed in Annex III to the Convention (“List of Hazardous Characteristics”).

Annex I lists some of the wastes that may consist of, contain or be contaminated with DDT. These include:

Y4 Wastes from the production, formulation and use of biocides and phytopharmaceuticals

Y14 Waste chemical substances arising from research and development or teaching activities which are not identified and/or are new and whose effects on man and/or the environment are not known

Y18 Residues arising from industrial waste disposal operations

Y39 Phenols; phenol compounds including chlorophenol

Y45 Organohalogen compounds other than substances referred to in this Annex (e.g. Y39, Y41, Y42, Y43, Y44)

Wastes contained in Annex I are presumed to exhibit an Annex III hazardous characteristic – for example H11 “Toxic (Delayed or Chronic)”; H12 “Ecotoxic”; or H6.1 “Poisonous (Acute)” – unless, through “national tests”, they can be shown to not exhibit the characteristics. National tests may be useful for a particular hazard characteristic in Annex III until such time as the hazardous characteristic is fully defined. Guidance papers for each Annex III hazardous characteristic are currently being developed under the Basel Convention.

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List A of Annex VIII describes wastes that are “characterized as hazardous under article 1 paragraph 1(a)” although “Designation of a waste on Annex VIII does not preclude the use of Annex III (hazard characteristics) to demonstrate that a waste is not hazardous.” List B of Annex IX lists wastes that will not be wastes covered by article 1 paragraph 1(a), unless they contain Annex I material to an extent causing them to exhibit an Annex III characteristic. In particular, the following Annex VIII wastes are applicable to DDT:

A4030 Wastes from the production, formulation and use of biocides and phytopharmaceuticals, including waste pesticides and herbicides which are off-specification, outdated,3 or unfit for their originally intended use

A4100 Wastes from industrial pollution control devices for cleaning of industrial off-gases but excluding such wastes specified on list B

A4130 Waste packages and containers containing Annex I substances in concentrations sufficient to exhibit Annex III hazard characteristics

A4140 Wastes consisting of or containing off-specification or outdated chemicals corresponding to Annex I categories and exhibiting Annex III hazard characteristics

A4150 Waste chemical substances arising from research and development or teaching activities which are not identified and/or are new and whose effects on human health and/or the environment are not known

A4160 Spent activated carbon not included on list B (note the related entry on list B B2060)

For further information please refer to section II.A of the General Technical Guidelines.

B. Stockholm Convention

The Stockholm Convention differentiates between two categories of POPs:

(a) Intentionally produced POPs whose production and use are to be eliminated or disposed of in accordance with the provisions of Annex A and/or restricted according with the provisions of Annex B

(b) Unintentionally produced POPs listed in Annex C, for which Parties are required to take specified measures to reduce total releases derived from anthropogenic sources “with the goal of their continuing minimization and, where feasible, ultimate elimination”.

Annex B Restriction, Part I (“DDT (1,1,1-trichloro-2,2-bis(4-chlorophenyl)ethane)”), outlines specific requirements with respect to DDT, as follows:

3 “Outdated” means unused within the period recommended by the manufacturer.

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Notes:

(i) Except as otherwise specified in this Convention, quantities of a chemical occurring as unintentional trace contaminants in products and articles shall not be considered to be listed in this Annex;

(ii) This note shall not be considered as a production and use acceptable purpose or specific exemption for purposes of paragraph 2 of Article 3. Quantities of a chemical occurring as constituents of articles manufactured or already in use before or on the date of entry into force of the relevant obligation with respect to that chemical, shall not be considered as listed in this Annex, provided that a Party has notified the Secretariat that a particular type of article remains in use within that Party. The Secretariat shall make such notifications publicly available;

(iii) This note shall not be considered as a production and use specific exemption for purposes of paragraph 2 of Article 3. Given that no significant quantities of the chemical are expected to reach humans and the environment during the production and use of a closed-system site-limited intermediate, a Party, upon notification to the Secretariat, may allow the production and use of quantities of a chemical listed in this Annex as a closed-system site-limited intermediate that is chemically transformed in the manufacture of other chemicals that, taking into consideration the criteria in paragraph 1 of Annex D, do not exhibit the characteristics of persistent organic pollutants. This notification shall include information on total production and use of such chemical or a reasonable estimate of such information and information regarding the nature of the closed-system site-limited process including the amount of any non-transformed and unintentional trace contamination of the persistent organic pollutant-starting material in the final product. This procedure applies except as otherwise specified in this Annex. The Secretariat shall make such notifications available to the Conference of the Parties and to the public. Such production or use shall not be considered a production or use specific exemption. Such production and use shall cease after a ten year period, unless the Party concerned submits a new notification to the Secretariat, in which case the period will be extended for an additional ten years unless the Conference of the Parties, after a review of the production and use decides otherwise. The notification procedure can be repeated;

(iv) All the specific exemptions in this Annex may be exercised by Parties that have registered in respect of them in accordance with Article 4.

Annex B Restriction, Part II (“DDT (1,1,1-trichloro-2,2-bis(4-chlorophenyl)ethane)”), outlines specific restrictions with respect to DDT, as follows:

(a) The production and use of DDT shall be eliminated except for Parties that have notified the Secretariat of their intention to produce and/or use it. A DDT Register is hereby established and shall be available to the public. The Secretariat shall maintain the DDT Register.

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(b) Each Party that produces and/or uses DDT shall restrict such production and/or use for disease vector control in accordance with the World Health Organization recommendations and guidelines on the use of DDT and when locally safe, effective and affordable alternatives are not available to the Party in question.

(c) In the event that a Party not listed in the DDT Register determines that it requires DDT for disease vector control, it shall notify the Secretariat as soon as possible in order to have its name added forthwith to the DDT Register. It shall at the same time notify the World Health Organization.

(d) Every three years, each Party that uses DDT shall provide to the Secretariat and the World Health Organization information on the amount used, the conditions of such use and its relevance to that Party’s disease management strategy, in a format to be decided by the Conference of the Parties in consultation with the World Health Organization.

(e) With the goal of reducing and ultimately eliminating the use of DDT, the Conference of the Parties shall encourage:

(i) Each Party using DDT to develop and implement an action plan as part of the implementation plan specified in Article 7. That action plan shall include:

(1) Development of regulatory and other mechanisms to ensure that DDT use is restricted to disease vector control;

(2) Implementation of suitable alternative products, methods and strategies, including resistance management strategies to ensure the continuing effectiveness of these alternatives;

(3) Measures to strengthen health care and to reduce the incidence of the disease.

(ii) The Parties, within their capabilities, to promote research and development of safe alternative chemical and non-chemical products, methods and strategies for Parties using DDT, relevant to the conditions of those countries and with the goal of decreasing the human and economic burden of disease. Factors to be promoted when considering alternatives or combinations of alternatives shall include the human health risks and environmental implications of such alternatives. Viable alternatives to DDT shall pose less risk to human health and the environment, be suitable for disease control based on conditions in the Parties in question and be supported with monitoring data.

(f) Commencing at its first meeting, and at least every three years thereafter, the Conference of the Parties shall, in consultation with the World Health Organization, evaluate the continued need for DDT for disease vector control on the basis of available scientific, technical, environmental and economic information, including:

(i) The production and use of DDT and the conditions set out in paragraph 2;

(ii) The availability, suitability and implementation of the alternatives to DDT;

(iii) Progress in strengthening the capacity of countries to transfer safely to reliance on such alternatives.

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(g) A Party may, at any time, withdraw its name from the DDT Registry upon written notification to the Secretariat. The withdrawal shall take effect on the date specified in the notification.

For further information, please refer to section II.B of the General Technical Guidelines.

III. Issues under the Stockholm Convention to be addressed cooperatively with the Basel Convention

A. Low POP content

The following provisional definition for low POP content should be applied for DDTs: 50 mg/kg For further information, please refer to section III.A of the General Technical Guidelines.

B. Levels of destruction and irreversible transformation

Regarding the provisional definition for levels of destruction and irreversible transformation, please refer to section III.B of the General Technical Guidelines.

C. Methods that constitute environmentally sound disposal

Section G of chapter IV below contains a description of methods that are considered to constitute environmentally sound disposal of wastes consisting of, containing or contaminated with DDTs.

IV. Guidance on environmentally sound management (ESM)

A. General considerations

1. Basel Convention

One of the main vehicles for the promotion of ESM is the preparation and dissemination of technical guidelines such as the present document and the General Technical Guidelines. For further information please refer to section IV.A.1 of the General Technical Guidelines.

2. Stockholm Convention

The term ESM is not defined in the Stockholm Convention. Environmentally sound methods for disposal of wastes consisting of, containing or contaminated with DDT are, however, to be determined by the Conference of the Parties in cooperation with the appropriate bodies of the Basel Convention.

Parties should consult the document Interim Guidance for Developing a National Implementation Plan for the Stockholm Convention (UNEP 2003b).

3. Organization for Economic Cooperation and Development

For information regarding the Organisation for Economic Cooperation and Development and ESM, refer to section IV.A.3 of the General Technical Guidelines.

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B. Legislative and regulatory framework

Parties to the Basel and Stockholm Convention should examine national controls, standards and procedures to ensure that they are in line with of the respective conventions and their obligations under them, including those that pertain to ESM of wastes consisting of, containing or contaminated with DDT.

Elements of a regulatory framework applicable to DDT could also include the following:

(a) Enabling environmental protection legislation (sets release limits and environmental quality criteria);

(b) Prohibitions or restrictions on the manufacture, sale, import and export (for use) of DDT;

(c) Phase-out dates for DDTs that remain in inventory or storage;

(d) Hazardous materials and waste transportation requirements;

(e) Specifications for containers, equipment, bulk containers and storage sites;

(f) Specification of acceptable analytical and sampling methods for DDT;

(g) Requirements for waste management and disposal facilities;

(h) General requirement for public notification and review of proposed government regulations, policy, certificates of approval, licences, inventory information and national emissions data;

(i) Requirements for identification and remediation of contaminated sites;

(j) Requirements for health and safety of workers;

(k) Other potential legislative controls (waste prevention and minimization, inventory development, emergency response).

(l) The restriction in production and use and, eventually, the timing of the phase-out of DDT will probably be the most critical legislative concern for most countries, although most of them already have some form of legislative framework dealing with DDT.

For further information please refer to section IV.B of the General Technical Guidelines.

C. Waste prevention and minimization

Both the Basel and Stockholm Conventions advocate waste prevention and minimization, while DDT are targeted in the Stockholm Convention for restriction in production and use and/or complete phase-out. DDT wastes should be disposed of in an environmentally sound manner.

Quantities of waste containing DDT should be minimized through isolation and source separation in order to prevent mixing and contamination of other waste streams. For example, obsolete DDT poorly packaged in warehouses can contaminate large amounts of soil and water.

Mixing of wastes with a DDT content above a defined low POP content with another material solely for the purpose of generating a mixture with a POP content below the defined

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low POP content is not environmentally sound. However, mixing of materials prior to waste treatment may be necessary in order to optimize treatment efficiencies.

Parties with ongoing production and/or use of DDT should consider the following actions:

(a) Formula modifications in order to reduce DDT content and concentration;

(b) Maintenance activities of equipment to prevent spills and leaks;

(c) Training in correct use of DDT, ways to minimize waste production during use, handling, transport, storage;

(d) Recovering resources practices could be required to develop waste management plans, for example: decontamination of containers and equipment containing DDT. Logically, such a plan would be for all toxic and hazardous wastes, with POPs wastes taken into consideration as one component of such a plan;

For further information, please refer to paragraph 6 and section IV.C of the General Technical Guidelines.

D. Identification and inventories

1. Identification

DDT and its wastes (including its metabolites) are typically may be found in the following industries and locations:

(a) Industrial storage of formulation and fabrication of DDT (soil, groundwater and sediments);

(b) Government storage from health and agriculture ministries;

(c) Storage facilities within farms and stables;

(d) Houses, drugstore, shopping centers, schools, hospitals, industrial facilities, office and apartment buildings;

(e) Contaminated materials like: protection clothes, application equipment and accessories, containers or barrels, floors, walls, windows and others.

It is important to note that even experienced technical persons may not be able to determine the nature of an effluent, substance, container or piece of equipment by its appearance or markings. It is very probably that obsolete DDT containers are not properly. Experienced inspectors may be able to determine the original contents from other information by using guidance manuals issued by diverse organizations or by contacting the manufacturer. Critical aspects of waste identification require knowledge of products or articles consisting of, containing or contaminated with DDT, including: manufactures, trade names and synonyms, when they were manufactured, how they were used (applications) and by whom they were used (industry sectors).

When identifying DDT, information on production, use and waste types outlined in section I.B of the present report may be useful.

For further information, please refer to section IV.D.1 of the General Technical Guidelines.

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2. Inventories

Inventories are important tools for identifying, quantifying and characterizing wastes. A national inventory may be used to:

(a) Establish a baseline quantity of products, articles and wastes consisting of, containing or contaminated with DDT;

(b) Determine which of these are obsolete and which might still be usable;

(c) Obtain accurate information needed to draw up a plan for site stabilization; (containment (repackaging) of products in leaking and deteriorated containers; clean-up of spills; and packaging of contaminated materials);

(d) Identify suitable disposal options;

(e) Assist with regulatory inspections;

(f) Assist with the preparation of emergency response plans; and

(g) Track progress to minimize and phase-out these chemicals were applicable.

When developing an inventory, priority should be placed on the identification of wastes with high DDT concentrations.

The development of a national inventory requires a long-term commitment by the national government, the cooperation of owners, possesors and manufacturers of DDT and its wastes, a sound administrative process for collecting information on an ongoing basis and a computerized database system for storage of information. In some cases, government regulations may be required to ensure that owners report their holdings and cooperate with government inspectors.

A complete inventory of DDT could be very difficult to compile, mainly because of dispersive uses and/or storage of this chemical in wide rural and urban areas.

For further information, please refer to section IV.D.2 of the General Technical Guidelines. It is advisable to refer to the Pesticide storage and stock control manual (FAO, 1996) and the Provisional guidelines on prevention of accumulation of obsolete pesticide stocks (FAO, 1995a).

E. Sampling, analysis and monitoring

1. Sampling

Sampling in this section refers to the taking of a sample of gas, liquid or solid for later analysis either in the field or in a laboratory.

The types of matrices that are sampled for analysis of DDT are shown below.

(a) Liquids:

(i) Water (surface water, rainwater, groundwater, soil pore water, drinking water, industrial process water, effluent water, condensate);

(ii) Landfill leachate;

(iii) Liquid DDT in bulk or small storage;

(iv) Obsolete liquid DDT in bulk or small storage;

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(v) Liquid DDT in products;

(vi) Biological liquids (lipids and milk);

(vii) Liquids collected from spills or from free-product subsurface recovery systems at contaminated sites;

(b) Solids:

(i) Solid or semi-solid DDT products;

(ii) Containers or equipment (rinse or wipe sample);

(iii) Mixed solid wastes: clothes protection, application equipment and accessories, containers or barrels, floors, walls, windows and others

(iv) Soil, sediment, rubble, compost;

(v) Tissues or fabric used in the collection of wipe samples;

(vi) Filter materials;

(vii) Solids extracted from a liquid or sludge (suspended solids, precipitates, coagulated solids, and filtered material);

(viii) Solids from industrial or disposal processes;

(ix) Ice, snow and other frozen materials;

(x) Plant materials and food;

(xi) Biological solids (whole animals, tissues, faeces);

(c) Gases:

(i) Stack gases from industry and treatment processes;

(ii) Volatile emissions from products, wastes, processes and contaminated sites;

(iii) Soil and groundwater gases;

(iv) Air (ambient, personal breathing, confined space);

(v) Biological gases (exhaled air, gases released by organisms).

For further information, please refer to section IV.E.1 of the General Technical Guidelines.

2. Analysis

Analysis refers to the determination of the physical, chemical or biological properties of a material using documented, peer-reviewed and accepted laboratory methods.

Each country should identify, through guidelines or legislation, standard methods that are required to be used for DDT and its metabolites and wastes and the situations in which the methods should be used.

The methods specified should cover all aspects of the analytical process for each type of sample that could be collected, as per the list of sample materials in paragraph 45 above.

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In very general terms, the methods available for chemical analysis for DDT (UNEP 1999) are the following:

(a) Packed-column gas chromatography (GC)/electron capture;

(b) (GC/mass spectrometry (MS) – for determining individual congeners. May not be able to detect low concentrations;

Because laboratory facilities for DDT are not available in most developing countries, it may be difficult to determine whether a pesticide may still be used after its indicated shelf-life has expired. Inadequate labelling and the absence of a date of manufacture/release on labels or on the container may complicate the matter. For this reason, there is often an understandable tendency to deviate from the principle of “first in – first out” and to use a newer product to be certain of its effectiveness; this practice leads to prolonged storage of older products.

Accreditation and certification of laboratories and interlaboratory calibration studies are important aspects of a national analytical programme. All laboratories should be able to meet quality standards as set and tested by government and by an independent body such as the International Organization for Standardization or by an association of laboratories.

For further information, please refer to section IV.E.2 of the General Technical Guidelines.

3. Monitoring

Monitoring programs should be implemented for operations managing wastes consisting of, containing or contaminated with DDT.

In this section “monitoring” refers to the measurement of DDT and its wastes (included its metabolites) in the environment or in humans or from known or suspected sources to the environment or evaluation of its effects on the environment, human health, societies and economies.

Nations that have DDT monitoring programmes should continue or expand them to meet the requirements of the Stockholm and Basel Conventions.

Monitoring programmes for DDT have, in general, not been established by national governments, although some research studies have been carried out. Nations should implement initial monitoring studies for DDT, possibly in cooperation with other nations, and then determine whether further monitoring is necessary and the scope of that monitoring.

Environmental monitoring for DDT should focus on key “marker” species in which they are known to bioaccumulate and have toxic effects. Examples of the species that fall into this category for DDT are gulls, eagles, peregrine falcon, fish-eating ducks, cormorants, seals, fish-eating whales, dolphins, polar bear, mink, otters, salmon, and cod.

Research and monitoring results should be published in government reports or scientific journals or be submitted to the Basel or Stockholm Secretariat for incorporation into an international publication

For further information please refer to section IV.E.3 of the General Technical Guidelines.

F. Handling, collection, packaging, labelling, transportation and storage

Handling, collection, packaging, labelling, transportation and storage are critically important steps as the risk of a spill, leak or fire (for example in preparation for storage or

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disposal) is equal to or greater than that during the normal operation of the equipment. The Basel Convention: Manual for Implementation (UNEP 1995), the International Maritime Dangerous Goods Code (International Maritime Organization (IMO), 2002), the International Air Transport Association Dangerous Goods Code and the United Nations Recommendations on the Transport of Dangerous Goods Model Regulations (Orange Book) should be consulted to determine specific requirements for transport and transboundary movement of hazardous wastes.

1. Handling

The main concerns when handling wastes consisting of, containing or contaminated with DDT are human exposure, accidental release to the environment and contamination of other waste streams with DDT. Such wastes should be handled separately from other waste types in order to prevent contamination of these other waste streams. Recommended practices for this purpose include:

(a) Inspecting containers for leaks, holes, rust, high temperature;

(b) Handling wastes at temperatures below 25oC, if possible, due to the increased volatility at higher temperatures;

(c) Ensuring that spill containment measures are adequate and would contain liquid wastes if spilled;

(d) Placing plastic sheeting or absorbent mats under containers before opening containers if the surface of the containment area is not coated with a smooth surface material (paint, urethane, epoxy);

(e) Removing the liquid wastes either by removing the drain plug or by pumping with a peristaltic pump and Teflon or silicon tubing;

(f) Using dedicated pumps, tubing and drums, not used for any other purpose, to transfer liquid wastes;

(g) Cleaning up any spills with cloths, paper towels or absorbent;

(h) Triple rinsing of contaminated surfaces with a solvent such as kerosene to remove all of the residual DDT;

(i) Treating all absorbents and solvent from triple rinsing, disposable protective clothing and plastic sheeting as wastes consisting of, containing or contaminated with DDT when appropriate.

Staff should be trained in the correct methods of handling hazardous wastes.

2. Collection

A significant part of the total national amount of DDT may be held in small quantities by small farms and business owners and homeowners (e.g. commercial size of DDT containers, small size containers of pure products and small stockpiles). It is difficult for small-quantity owners to dispose of these materials. For example, the regulatory situation may require that they be a registered waste generator, logistical considerations may prevent or discourage pick-up (e.g. no industrial waste pick-up allowed or available in a rural location or residential neighbourhood), and costs may be prohibitive. National, regional or municipal governments should consider establishing collection stations in rural and urban areas for these small quantities so that each small-quantity owner does not have to make individual transport and disposal arrangements.

Collection and collection depots for wastes consisting of, containing or contaminated with DDT should be separate from those for all other wastes.

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It is imperative that collection depots do not become long-term storage facilities for wastes consisting of, containing or contaminated with DDT. The risk of environmental and human health impairment is higher for a large amount of wastes, even if properly stored, than for small quantities scattered over a large area.

For further information, please refer to section IV.F.2 of the General Technical Guidelines.

3. Packaging

Wastes consisting of, containing or contaminated with DDT should be packaged prior to storage or transport. Liquid wastes should be placed inter alia in double-bung steel drums. Regulations governing transport often specify containers of a certain quality (e.g. 16-gauge steel coated inside with epoxy). Therefore, containers used for storage should meet transport requirements in anticipation that they may be transported in the future.

Drums and equipment may be placed on pallets for movement by forklift truck and for storage. Equipment and drums should be strapped to the pallets prior to movement.

Bulk quantities of pesticides are commonly supplied in 200-litre metal drums. For countries without good repackaging facilities this may create problems if the DDT is intended for use by plant protection staff, extension staff or small-scale farmers. In order to transfer the contents of large drums into smaller packages, large quantities of small empty containers, a pump, labels, etc. are needed. These are often not available, or are insufficient, at the repackaging location. Consequently, DDT may remain unused or improvised measures may be taken that are dangerous to handlers or users.

DDT sometimes could be delivered in containers of poor durability that soon start leaking. Once drums have corroded or leak, they can no longer be transported, which makes it considerably more difficult to use their contents. The same applies to torn bags and other damaged packaging. If the container quality is not specified in tender documents, bidders may be tempted to reduce their price by compromising on the quality of containers


4. Labelling

All drums or containers containing or contaminated with DDT should be clearly labelled with both a hazard warning label and a label that gives the details of the drum or container including the exact volume of liquid, the type of waste, and the name and telephone number of the responsible person.


5. Transportation

Transportation of dangerous goods and wastes is regulated in most countries, and the transboundary movement of wastes is controlled in particular by the Basel Convention.

Companies transporting wastes within their own country should be certified as shippers of hazardous materials and wastes and their personnel should be qualified.


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6. Storage

While many countries have adopted storage regulations or developed storage guidelines related to hazardous materials and waste, most do not have specific storage regulations or guidance related to DDT. However, it can be assumed that the storage procedures should be similar to those mentioned. While recommended practice varies somewhat from country to country, there are many common elements to safe storage of these wastes.


G. Environmentally sound disposal

1. Pretreatment

Regarding pretreatment, please refer to section IV.G.1 of the General Technical Guidelines.

2. Destruction and irreversible transformation methods

Regarding destruction and irreversible transformation methods, please refer to section IV.G.2 of the General Technical Guidelines.

3. Other disposal methods when destruction or irreversible transformation does not represent the environmentally preferable option

Regarding other disposal methods when destruction or irreversible transformation does not represent the environmentally preferable option, please refer to section IV.G.3 of the General Technical Guidelines.

4. Other disposal methods when the POP content is low

Regarding other disposal methods when the POP content is low, please refer to section IV.G.4 of the General Technical Guidelines.

H. Remediation of contaminated sites

Poor handling and storage practices may lead to releases of DDT at sites storing these chemicals, resulting in contamination of sites with high levels of DDT, which may pose serious health concerns. For information on the identification and remediation of contaminated sites, please refer to section IV.H of the General Technical Guidelines.

I. Health and safety

A health and safety plan for an individual facility should be developed by a trained health and safety professional with experience in hazardous materials and waste management in general and DDT in particular. In general there are three main ways to protect workers from chemical hazards (in order of preference):

(a) Keep the worker away from all possible sources of contamination;

(b) Control the contaminants so that the possibility of exposure is minimized;

(c) Protect the worker using personal protective equipment.

All health and safety plans should adhere to the above principles and recognize local or national labour standards. For further information please refer to section IV.I of the General Technical Guidelines.

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1. High-volume, high-concentration or high-risk situations

High-volume, high-concentration or high-risk DDT situations may include:

(a) Farms with high production, facilities for pesticide distribution and sites where pesticides are applied;

(b) Areas where DDT is produced;

(c) Handling for transport;

(d) Dedicated (large-volume) storage sites;

(e) Treatment and disposal areas;

(f) Facilities used for treatment and disposal of wastes consisting of, containing or contaminated with DDT:

(g) Sites contaminated with a high concentration of DDT at or near the surface.

At a minimum, the following should be included in DDT health and safety plans for high-volume, high-concentration situations or high-risk situations:

(a) The health and safety plan (HASP) should be in writing, with a copy posted at each site;

(b) Workers, who are to have access to the site, should read the HASP and sign that they have read and understood it;

(c) The HASP may be written to encompass all hazards at a site but should have a section or chapter specifically detailing procedures for DDT;

(d) Workers should only be present at a site when necessary for the servicing or inspection of equipment or stored materials;

(e) Workers entering a site should have appropriate health and safety and operational training for chemical, physical and biological hazards;

(f) Health and safety training should be performed annually;

(g) DDT should be routinely monitored for these contaminants in air;

(h) When appropriate, workers entering a site should wear appropriate respiratory protection and impermeable fabric should cover the entire body (i.e coveralls with hood, face shield, gloves and boot covers or a full body suit);

(i) Spill clean-up kits and personal decontamination materials should be present in all areas containing DDT;

(j) Workers who are, or are expected to be, routinely entering sites or working with these substances should be medically monitored, including a baseline medical examination;

(k) Where DDT are to be handled in an open system, or where it is reasonably expected that the protective clothing of a worker may contact DDT, a contaminant reduction zone should be established where workers can be decontaminated and remove their protective equipment;

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(l) The HASP and general work procedures should be reviewed at least annually and revised if necessary to enhance safety and health at the site.

2. Low-volume, low-concentration sites or low-risk situations

The recommended health and safety practices outlined in the previous section do not apply to sites that contain or are contaminated with DDT in amounts or concentrations that are seen as acute or chronically hazardous to human health and the environment. Low-volume, low-concentration or low-risk situations may include:

(a) Properties that contain products or articles that contain or are contaminated with DDT in small quantities or low concentrations (e.g. application devices, protective and working clothes);

(b) Commercial storage or inventory rooms that contain small quantities of DDT that are to be used in acceptable application situations;

(c) Objects with low quantities of DDT like empty containers;

(d) Facilities that unintentionally release DDT in very low concentrations compared with human exposure limits;

(e) Sites contaminated with a low concentration of DDT or where the contamination cannot directly come into contact with workers (for example, contamination is underground or under water and is not being excavated).

Despite the low risk some health and safety measures should be taken to minimize exposure, including health and safety training of personnel who are likely to come into contact with DDT.

J. Emergency response

Emergency response plans should be in place for DDT, in storage, in transport and at a disposal site. Further information on emergency response plans can be found in section IV.J of the General Technical Guidelines.

K. Public participation

Parties to the Basel or Stockholm Convention should have an open public participation process. For further information please refer to section IV.K of the General Technical Guidelines.

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Annex I

Synonyms and trade names for DDT

Chemical Some synonyms and trade namesDDT Agritan, Anofex, Arkotine, Azotox, benzene,1,1’-(2,2,2-

trichloroethylidene)bis(4-chloro-alpha,alpha-bis(p-chlorophenyl)-beta,beta,beta-trichlorethane, Bosan Supra, Bovidermol, chlorophenothan, chlorophenothanes, chloro phenothan, chlorophenothane, chlorophenotoxum, Citox, Clofenotane, p,p’-DDT, Dedelo, Deoval, Detox, Detoxan, Dibovan, dichlorodiphenyltrichloroethane, p,p’- dichlorodiphenyltrichloroethane, 4,4’-dichlorodiphenyltrichloroethane, Dicophane, Didigam, Didimac, Diphenyltrichloroethane, Dodat, Dykol, Estonate, Genitox, Gesafid, Gesapon, Gesarex, Gesarol, Guesapon, Guesarol, Gyron, Havero-extra, Hildit, Ivoran, Ixodex, Kopsol, Micro DDT 75, Mutoxin, Neocid, OMS 16, Parachlorocidum, Pentachlorin, Pentech, Ppzeidan, R50, Rukseam, Santobane, Tech DDT, Trichlorobis(4-chlorophenyl)ethane, 1,1,1-Trichloro-2,2-bis(p-chlorophenyl)ethane, 1,1,1-trichloro-2,2-di(4-chlorophenyl) ethane, 1,1’-(2,2,2-trichloroethylidene)bis(4-chlorobenzene), 1,1-bis-(p-chlorophenyl)-2,2,2-trichloroethane, 2,2-bis(p-chlorophenyl)-1,1,1-trichloroethane, 4,4’-dicholorodiphenyltrichloroethane, Zeidane, Zerdane

Note: The list of trade names is not intended to be exhaustive.

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Annex II

Bibliography

About DDT

Agency for Toxic Substances and Disease Registry. Toxicological Profile Information Sheets. Available at www.atsdr.cdc.gov

Global Programme of Action (GAP) for the Protection of the Marine Environment from Land-based Activities. GPA clearing-house mechanism. Available at http://pops.gpa.unep.org

World Health Organization (WHO) International Programme on Chemical Safety (IPCS), 1995. A Review of the Persistent Organic Pollutants -- An Assessment Report on: DDT, Aldrin, Dieldrin, Endrin, Chlordane, Heptachlor, Hexachlorobenzene, Mirex, Toxaphene, Polychlorinated Biphenyls, Dioxins and Furans. Available at www.pops.int

IPCS INCHEM datasheets. Available at www.inchem.org

US EPA, 2002. The Foundation for Global Action on Persistent Organic Pollutants: A United States Perspective. EPA/600/P-01/003F, NCEA-I-1200. Washington, D.C. Available at www.epa.gov

Basel Convention

United Nations Environmental Programme (UNEP), 1994. Guidance Document on the Preparation of Technical Guidelines for the Environmentally Sound Management of Wastes Subject to the Basel Convention. Available at www.basel.int

OECD

OECD, 2003. Core Performance Elements of the Guidelines for Environmentally Sound Management of Wastes. Available at www.oecd.org

Legislative and regulatory framework

UNEP, 1995. Basel Convention: Manual for Implementation. Available at www.basel.int

UNEP, 1995. Model National Legislation on the Management of Hazardous Wastes and Other Wastes as well as on the Control of Transboundary Movements of Hazardous Wastes and Other Wastes and their Disposal. Available at www.basel.int

UNEP, 1998. Basel Convention: Guide to the Control System. Available at www.basel.int

Waste prevention and minimization

Food and Agricultural Organization (FAO), 1995. Prevention of accumulation of obsolete pesticide stocks. Provisional guidelines. No. 2. Available at www.fao.org

A Generic Risk Assessment Model for Insecticide Treatment and Subsequent Use of Mosquito Nets, 2004. World Health Organization. Available at www.who.org

CropLife, 2004. Managing obsolete stocks of crop protection products Available at www.croplife.org

Inter-Organization Programme for the Sound Management of Chemicals, 2002. Reducing and Eliminating the use of Persistent Organic Pesticides: Guidance on alternative strategies for sustainable pest and vector management. Available at www.chem.unep.ch

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http://www.chem.unep.ch/pops/pdf/redelipops/redelipops.pdf

http://www.fao.org/

http://www.fao.org/

http://www.fao.org/

http://www.basel.int/



http://www.oecd.org/

http://www.basel.int/meetings/sbc/workdoc/techdocs.html

http://www.epa.gov/ncea/pdfs/pops/POPsa.pdf

http://www.inchem.org/pages/pds.html

http://www.pops.int/

http://pops.gpa.unep.org/

http://www.atsdr.cdc.gov/


Identification and inventories

WHO 2002. The WHO Recommended Classification of Pesticides by Hazard. Available at www.who.org

FAO. Prevention and Disposal of Unwanted Pesticide Stocks in Africa and the Near East. Available at www.fao.org

UNEP, 2000. Methodological Guide for the Undertaking of National Inventories of Hazardous Wastes Within the Framework of the Basel Convention. Available at www.basel.int

Sampling, analysis and monitoring

American Society for Testing of Materials (ASTM), 1996. Sampling Environmental Media. Available at www.astm.org

Handling, collection, packaging, transporation and storage

FAO, 1996. Pesticide storage and stock control manual. No. 3. Available at www.fao.org

FAO, 1995. Guidelines for packaging and storage of pesticides. Available at www.fao.org

FAO. Prevention and Disposal of Unwanted Pesticide Stocks in Africa and the Near East. Available at www.fao.org

IMO, 2002. International Maritime Dangerous Goods Code. Avaliable at www.imo.org

UNEP, 1993. Storage of Hazardous Materials: A Technical Guide for Safe Warehousing of Hazardous Materials. Available at www.uneptie.org

Environmentally sound destruction and disposal

FAO, 1996. Disposal of bulk quantities of obsolete pesticide in developing countries. Available at www.fao.org

WORLD BANK Technical Paper No. 93. The Safe Disposal of Hazardous Wastes – The Special Needs & Problems of Developing Countries Volume III.

Santoreli, Reynolds & Theodore, 2000. Introduction to Hazardous Waste Incineration.

National Pesticide Stewardship Alliance Conference 2001 – USA. Gas-Phase Chemical Reduction: A Proven and Accepted Technology for Pesticide and Dioxin Treatment.

Environmental Partnerships Branch Ministry of the Environment Toronto Canada. A gas-phase chemical reduction process. Available at www.ene.gov.on.ca

FAO, 1999. Guidelines for the management of small quantities of unwanted and obsolete pesticides. No. 7. Available at www.fao.org

FAO, 1999. Obsolete pesticides: problems, prevention and disposal. Available at www.fao.org

University of Connecticut. Handling and Disposal of Chemicals. Best Management Practice Environmental Fact Sheet.

UNEP, 2004. Preparation of technical guidelines on the environmentally sound management of wastes consisting of, containing or contaminated with persistent organic pollutants. Available at www.basel.int

UNEP, 1999. Technical Guidelines on Hazardous Wastes: Physicochemical Treatment and Biological Treatment. Available at www.basel.int

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http://www.fao.org/

http://www.fao.org/

http://www.ene.gov.on.ca/

http://www.fao.org/

http://www.uneptie.org/

http://www.fao.org/

http://www.fao.org/

http://www.fao.org/

http://www.astm.org/


http://www.fao.org/

http://www.fao.org/


UNEP, 2001. Destruction and Decontamination Technologies for PCB and Other POPs Wastes Part I. Available at www.basel.int

UNEP, 2001. Destruction and Decontamination Technologies for PCB and Other POPs Wastes Part II. Available at www.basel.int

UNEP, 2001. Destruction and Decontamination Technologies for PCB and Other POPs Wastes Part III. Available at www.basel.int

Health and safety

ILO, 1999. Safety in the use of chemicals at work: Code of Practice. Available at www.ilo.org

ILO No date. International Chemical Safety Cards. Available at www.ilo.org

Emergency response

OECD, 2003. Guiding Principles for Chemical Accident Prevention, Preparedness and Response, Second Edition. Available at www.oecd.org

NFPA 472. Standard for Professional Competence of Responders to Hazardous Materials Incidents.

Public Participation

Australia Department of Environmental Health, 2000. A Case Study of Problem Solving Through Effective Community Consultation. Available at www. deh .gov/au/industry/chemicals/scheduled-waste/commuinty-consultation.html

Other

UNEP, 2004. Preparation of technical guidelines on the environmentally sound management of wastes consisting of, containing or contaminated with persistent organic pollutants. Available at www.basel.int

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http://www.deh.gov/au/industry/chemicals/scheduled-waste/commuinty-consultation.html

http://www.oecd.org/

http://www.ilo.org/

http://www.ilo.org/





German comments on the technical guidelines for environmentally sound management of wastes consisting of, containing or contaminated with DDT (Draft of 10 March 2005)

Title and AbbreviationsReplace “dicholorodiphenyltrichloroethane“ by „1,1,1-trichloro-2,2-bis(4-chlorophenyl)ethane”.Rationale: cf. General Technical Guidelines.

Units of measurementThe text for Nm3, mg/kg and μg/kg should the same as in the General Technical Guidelines.

Para. 1: In the last but one line at the end, replace “will” by “may”.Rationale: It is not certain if the Stockholm COP will consider these guidelines in accordance with Art. 6.2 because they do currently not contain substance relevant to Art. 6.2 in addition to the General technical guidelines. Cf. para. 1 of the draft pesticides guidelines.

Para. 2: Delete para. 2. The scope is already container in para. 1 in the first three lines. Instead, for clarification, the following para. may be inserted:“DDT has been addressed in Annex B of the Stockholm Convention and is addressed in these technical guidelines owing to its importance for malaria vector control in many tropical countries, whereas all pesticides listed as POPs in Annex A of the Stockholm Convention are addressed separately in the Technical Guidelines for Environmentally Sound Management of Wastes consisting of, containing or contaminated with the pesticides Aldrin, Chlordane, Dieldrin, Endrin, Heptachlor, Hexachlorobenzene, Mirex or Toxaphene.”

Para. 5: Replace the text of para. 5 by the following:“Pure p,p’-DDT (or 4,4’-DDT) is a colorless crystalline or powderlike substance with a melting point of 109 °C and a boiling point of 260 °C. It is nearly unsoluble in water but soluble in many organic solvents. Because of its lipophility (log Pow = 6.36), it enriches in sediments and shows bioaccumulation in adipose tissues and biomagnification. Furthermore, it is a flammable substance (flash point 72 – 75 °C). Technical DDT consists of different isomers with similar properties.”Rationale: cf. data from International Chemical Safety Cards.

Para. 8: Replace the figures in “pounds” by figures in Mg (1000 kg).

Para. 10: The whole para. should look similar to para. 37 of the draft pesticides guidelines and para. 27 of the PCB guidelines.

In line 1, replace “included” by “consisting of or containing”.

In the last but sixth line, delete “dieldrin and HCH” and delete the last but one sentence.Rationale: Dieldrin, HCH, carbamates, and organophosphates are beyond the scope of these guidelines.

Para. 13: Replace “H6.1 “Poisonous (Acute)” by H3 “Flammable liquids” and H4.1 “Flammable solids”.Rationale: The H characteristics relevant for DDT and waste management should be given.

Para. 14: At entry A4140, insert the following footnote after “outdated”:“Outdated” means unused within the period recommended by the manufacturer.

Para. 16: Text should be amended taking into account para. 23 of the General technical guidelines and para. 44 of the draft pesticides guidelines.

Para. 20: Replace “DDTs” by “DDT” and insert the following text in footnote 4: “Determined according to national or international methods and standards.”

Para. 22: Replace text by“Reference is made to section G of chapter IV below and section IV.G of the General technical guidelines.”Rationale: cf. para. 50 of the draft pesticides guidelines.

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Para. 28(l): Text should be moved to a separate para. after para. 28.Rationale: cf. para. 48 of the PCB guidelines.

Para. 30: Delete the second sentence.

Para. 36: Text seems to be missing at the end of the second sentence.

Para. 61:Insert the following in line after “2002)”:“the International Civil Aviation Technical Instructions for the Transport of Dangerous Goods, ”Rationale: The ICAO instructions are also relevant.

In line 6, replace “Code” by “Regulations”.

Para. 62(b): At the end, add “and the flammability”

Annex I: Add the following in the synonyms and trade names:“Hylotox 59Bercema-Aero-Super, Bercema-Spritz-Aktiv, Bercema-Bekusal”Rationale: In Germany, DDT was produced in the German Democratic Republic before 1990 under the trade name Hylotox 59. Furthermore, the following DDT containing formulations were produced:Bercema-Aero-Super (17 % DDT, 4 % lindane)Bercema-Spritz-Aktiv (15 % DDT, 8.5 % lindane)Bercema-Bekusal (58 % DDT)

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