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Part 3: An Action Plan for Dioxins and Other Annex C Chemicals

Article 5: Measures for Unintentional POPs

Introduction

This Action Plan for Dioxins and Other Annex C Chemicals has been prepared to set out how New Zealand intends to comply with the obligations of Article 5 of the Stockholm Convention.  Article 5 requires parties to take measures to reduce or eliminate releases of the unintentionally produced POPs listed in Annex C: PCDDs, PCDFs, PCBs and HCB.  For ease of reference, PCDDs, PCDFs are sometimes collectively referred to in this Plan as “dioxins”.  This also reflects the fact that much of the previous New Zealand work on unintentional POPs has been directed mainly at the PCDDs and PCDFs, and to a lesser extent at dioxin-like PCBs.

This Action Plan:

  • presents background information about dioxins and other Annex C chemicals
  • explains the New Zealand context for the Action Plan
  • sets out measures
  • builds on past efforts to address dioxin-related issues and reduce releases
  • focuses on consolidating measures and improving data quality concerning the release of dioxins and other Annex C chemicals to all media, but with particular emphasis on releases of dioxins to air.

Goal

The goal of the Action Plan for Dioxins and Other Annex C Chemicals is to protect human health and the environment from unintentionally produced POPs.

Objective

The objective of the Action Plan for Dioxins and Other Annex C Chemicals is to identify, characterise and address the release of unintentionally produced POPs, as required under Article 5 and Annex C of the Stockholm Convention, in working towards the goal of their continuing minimisation and, where feasible, ultimate elimination.

Outcomes

The outcomes from implementing the Action Plan will be that:

  • the present margin of safety in protecting human health from dioxins and other Annex C chemicals will be extended as body burdens decline
  • risks from historical residues of dioxins and PCBs on contaminated sites will be addressed
  • the quality of New Zealand primary food products (especially meat and dairy products) will be further safeguarded
  • the status of New Zealand’s clean environment will be strengthened.

Context for the Action Plan for Dioxins and Other Annex C Chemicals

What are unintentional POPs?

Some POPs may be unintentionally produced and released, often as by-products or inadvertent contaminants.  The Stockholm Convention lists PCDD, PCDF, HCB and PCB as the unintentionally produced Annex C POPs that should be addressed under Article 5 of the convention.

PCDDs/PCDFs have never been produced intentionally (other than for research) and are a group of tricyclic chlorinated aromatic chemicals, of which 17 have significant toxicity.  They are persistent in the environment, lipophilic (reside in fat), can bioaccumulate through the food chain, and can produce a range of toxic effects.  They are formed in some chemical production processes and in thermal processes where carbon and chlorine are present.

Most attention has been focused on those compounds that exhibit “dioxin-like” toxicity, comprising 17 isomers of PCDD/PCDF and 12 PCBs.  The term “dioxin” (singular), or TCDD, is usually used to refer to the congener 2,3,7,8-TCDD (2,3,7,8-tetrachlorodibenzo-p-dioxin).  TCDD was a toxic contaminant in the herbicide 2,4,5-T.

Both HCB and PCB have been intentionally produced and used for a variety of purposes.  They can also be formed as by-products in various chemical production processes and thermal processes in a manner analogous to the formation of PCDD/PCDF, although there are much fewer data than for PCDD/PCDF.

Most Annex C POPs can be found throughout the world in air, soil, sediment and water.  Once in the environment, these POPs can accumulate in the fatty tissue of animals such as birds, fish, shellfish, marine mammals and domestic animals, and in people.  POPs break down only very slowly and can remain in the environment and in people’s bodies for a very long time.

Animal studies show that some dioxin and dioxin-like compounds are extremely toxic.  Although less is known about their impact on human health, it is widely assumed that dioxins have the potential to cause neurobehavioural, developmental, reproductive and immunotoxic effects at low doses.  Significantly, dioxin (TCDD) is classified as a human carcinogen (IARC).[TCDD (2,3,7,8-tetrachlorodibenzo-para-dioxin) was evaluated by the International Agency for Research on Cancer (IARC) in 1997. Based on human epidemiology data, dioxin was categorised by IARC as a “known human carcinogen”.]  Annex C chemicals can travel great distances on air currents and in water – even to polar regions – affecting people and wildlife far from their point of release.  Since the early 1970s dioxin and dioxin-like compounds have caused a great deal of public concern, and have been the subject of extensive investigation by the scientific community and regulatory agencies.

Further information on Annex C chemicals (dioxins, furans, PCBs and HCB) is provided in Appendix 3.

How are people exposed to dioxins and other Annex C chemicals?

Annex C chemicals (PCDDs/PCDFs, HCB and PCBs) may be released routinely in very small amounts to air, land or water as well as being present in products and wastes.  Releases to the environment from a variety of sources can lead to low-level exposure to the general population, usually via the food chain.  There are also international examples where industrial releases, and where contaminated material introduced into animal feedstocks, led to localised human exposure.  Occupational exposure has been significant in the past.

Dioxins and other Annex C chemicals released into air can be carried a great distance before settling on soil or water.  If these POPs settle on pastoral land they may be taken up by grazing animals and stored in the animals’ fat.  These POPs can also enter our rivers, lakes and estuaries in effluent discharges, where they may be taken up by fish and shellfish.

Most New Zealanders’ exposure to Annex C chemicals is generally very low.  Over 90% of our exposure is thought to come from eating foods of animal origin, such as meats, dairy products and fish.  To a much lesser extent we may also be exposed when we breathe air and come into contact with contaminated materials.

The bioaccumulative character of these and other POPs and their presence in breast milk helps explain why the Stockholm Convention is overwhelmingly supported by most governments.

Historical sources of Annex C chemicals in New Zealand

Annex C chemicals are not deliberately manufactured, but are released to the environment from a variety of industrial discharges and combustion processes, and as unwanted by-products in various chlorinated chemical formulations.  Historically, the manufacture and use of chlorinated aromatic chemicals have been sources of dioxins in the New Zealand environment.  Notable examples include the wood preservative and biocide pentachlorophenol (PCP), phenoxy herbicides, and the PCBs.  Other processes, such as the manufacture of chlorine-bleached pulp, have led to environmental contamination and the trace contamination of pulp and paper products, particularly by TCDD.

Combustion and other thermal processes where chlorine and carbon are present appear to result in the formation of dioxins and other Annex C chemicals (e.g. the incineration of wastes; the production of iron and steel and other metals, including scrap metal reclamation; fossil fuel plants; domestic coal and wood fires; automobile engines; and accidental fires).  Tighter government regulations, improved industrial processes and the use of modern pollution control equipment have resulted in a lowering of releases of dioxins produced unintentionally.

For general information on dioxins and other Annex C chemicals, see: Dioxins.

What do we know about dioxins and other Annex C chemicals in New Zealand?

In preparing to meet Stockholm Convention obligations on Annex C chemicals, the Government has available to it the research undertaken by the Ministry for the Environment and the Ministry of Health.  This research has generated a wealth of data on the levels of dioxin and other dioxin-like compounds in human breast milk and in human serum, in the diet of New Zealanders, and in the environment (air, soil, rivers and estuaries, and some biota).

These scientific studies indicate the following.

  • The background levels of dioxins and other Annex C chemicals in the New Zealand environment (air, soil, rivers, estuaries) are generally low compared with the levels recorded in many other countries.
  • The level of dioxins in the serum of non-occupationally exposed New Zealanders tends to be at the lower end of the range of concentrations measured internationally.
  • Levels of dioxins (and organochlorine pesticides) in the milk of New Zealand women (in which the results from two separate groups of women were compared) declined by about 70% over the 10-year period 1988 to 1998.  In general, the exposure of New Zealanders to dioxins and other POPs is low relative to exposures in most other countries where comparable studies have been carried out.
  • The levels of dioxins in New Zealand foods, including our meats, dairy products and fish, are low: the current dietary intake of dioxins by New Zealanders is considered relatively low when compared internationally, and is below the World Health Organisation’s tolerable daily intake.
  • An independent report to the Ministry for the Environment on the health risks of dioxins concluded that the current background exposures to dioxin-like compounds for the New Zealand population have only a small margin of safety, and steps should be taken to further reduce exposures.
  • With the possible exception of coastal marine mammals, such as Hector’s dolphin, there is minimal risk to wildlife from background exposures to dioxins.

Unborn children may be exposed to POPs via the placenta, and nursing infants are exposed to the POPs present in breast milk.  The presence of low levels of dioxins (and other POP contaminants) in human serum and breast milk is a sensitive and emotional issue, and reinforces the commitment the New Zealand Government has to the Stockholm Convention.  The view of the Ministry of Health (as is the view of the WHO, and infant and child health groups in New Zealand and internationally) is that the benefits of breastfeeding far outweigh any risks from POP contaminants.  Breastfeeding is considered the best way to provide the nutritional requirements to ensure optimum physical and intellectual development of a baby, and the presence of low levels of POP chemicals does not alter that assessment.[Refer also to Ministry of Health, 2006.]

The Ministry of Health advises that:

  • modelling of exposures in infants and children shows that New Zealand babies reach similar tissue levels of dioxins to their mothers after about six months of breastfeeding
  • other modelling studies undertaken in the United States show that children who were bottle-fed as babies and children who were breastfed as babies have similar (low) dioxin levels in their bodies by age 10
  • breast milk does not contribute any greater lifetime dioxin body burden.

The research and technical reports arising from the New Zealand Organochlorines Programme can be viewed and downloaded from: Hazards Publications

A list of these and other reports relevant to POPs in New Zealand is presented in Appendix 2.  In particular, the environmental studies, and the dietary intake, serum and breast milk studies, serve as reference data important to the future monitoring of the Convention undertaken nationally and internationally.

Levels of dioxins are falling

Over the past decades the amount of dioxins released into our environment has decreased.  The reasons for this include:

  • phasing out leaded petrol from 1986 (completed by 1996)
  • the timber industry ceasing the use of PCP in 1988 (PCP was deregistered in 1991)
  • discontinuing the manufacture of 2,4,5-T in 1987
  • upgrades of industrial plants that historically emitted dioxins
  • prohibiting the import (1987) and use (1994) of PCBs
  • the collection and disposal overseas of PCBs
  • the closure of many smaller school and hospital waste incinerators that were poorly designed and/or operated.

A study for the Ministry of Health (Bates et al, 2001) measured the levels of dioxins in the breast milk of nursing mothers.  As indicated above, the study confirmed that a progressive decline in the body burden of dioxins is occurring (a 70% decline over the 10-year period 1988 to 1998).

Since 2000, additional measures have been, and are being, implemented to minimise releases of dioxins and other Annex C chemicals.  The measures outlined in this Plan (e.g. national environmental standards that ban landfill fires and other activities) are expected to ensure a continuing decline in environmental levels.

Stockholm Convention measures

Measures required

The measures to be taken in order to comply with the Stockholm Convention concerning Article 5 can be summarised as requiring parties to take measures to reduce and, where feasible, ultimately eliminate releases of Annex C chemicals from anthropogenic sources.  These obligations are set out in the text of Article 5 and in Annex C (reproduced in Appendices 3 and 4).

Recent measures taken by New Zealand

National environmental standards

The main measure taken recently to reduce the release of dioxins and other Annex C chemicals has been the development and entry into force of national environmental standards as regulations under the Resource Management Act 1991.  In particular, the National Environmental Standard Relating to Certain Air Pollutants, Dioxins and Other Toxics[Resource Management National Environmental Standards (Relating to Certain Air Pollutants, Dioxins and Other Toxics) Regulations 2004, including Amendments 2005.] specifically bans certain activities that produce dioxins and other air toxins (for details, see the discussion under ‘Article 5(a)(ii)’ below).

Emissions inventory

In 1998 the Ministry for the Environment estimated emissions of dioxins from industry and domestic activities (for details, see the discussion under ‘Article 5(a)(i)’ below).  Landfill fires, now banned, were previously identified as New Zealand’s most significant source of dioxin releases to air.  The overall pattern of emissions indicated contributions from industrial combustion processes (including secondary metal processing and waste incineration), non-industrial sources (primarily domestic wood and waste burning), and uncontrolled fires.  Releases to land, mainly in residues that were landfilled, were of a comparable magnitude to emissions to air, whereas releases to water were much less of an issue.  The recent introduction of National Environmental Standards Relating to Certain Air Pollutants, Dioxins and Other Toxics, along with other measures, are likely to result in a change to the pattern of emissions estimated in 1998.

New Zealand also has reservoirs of POPs in contaminated soils, waste dumps and landfills.  The POPs present in these reservoirs can potentially be redistributed back into our environment over a long period of time.  The importance of these reservoirs relative to current ongoing emissions is unknown.  Dioxin historically released into the New Zealand environment was estimated at between 1.45 and 1.7 kg I-TEQ,[TEQ, toxic equivalents, is the resultant toxicity given by a mixture of dioxin congeners.] arising from the rural use of 2,4,-T herbicide, in addition to the use of pentachlorophenol at sawmills, miscellaneous contributions to landfills, and from pulp and paper production (Ministry for the Environment, 2000).  Not included in this estimate, due to a lack of available data, was the likely TEQ contribution from the historical use of 2,4-D herbicide and a closed reservoir of wastes from the historical manufacture of chlorophenols.

Priorities

This Action Plan for Dioxins and Other Annex C Chemicals is focused on minimising and, where feasible, eliminating releases of unintentional POPs to all media, with particular emphasis on releases to air.  As outlined in earlier work (Ministry for the Environment, 2001), this rationale has the following basis.

  • The sources of discharges of dioxins and other Annex C chemicals to air and the pathways of population exposures are relatively well understood.
  • Most of the dioxins stored in the body tissue of the average New Zealander have originated from processes that discharged dioxins and other Annex C chemicals to air.
  • Most dioxins and other Annex C chemicals released to air are newly created.  Reducing these releases to air will diminish the amounts of Annex C chemicals that end up persisting in the environment.

Matters to be addressed

Matters to be addressed as Article 5 obligations are summarised in the following section and form an agenda for consideration and inclusion in this Action Plan for Dioxins and Other Annex C Chemicals to identify, characterise and minimise the release of these chemicals.

Framework for the Action Plan for Dioxins and Other Annex C Chemicals

The framework for the Action Plan for Dioxins and Other Annex C Chemicals is given by the obligations of Article 5 of the Convention.  The full text of Article 5 is reproduced in Appendix 4, but to facilitate the reading of these obligations for the purposes of preparing this Plan, a paraphrased summary is set out in Table 8.

Table 8: Summary of Article 5 obligations

Summary of Article 5 obligations (paraphrased)

Article 5(a)(i): Evaluate current and projected releases, including the development and maintenance of source inventories and release estimates, taking into consideration the source categories identified in Annex C.

Article 5(a)(ii): Evaluate the efficacy of laws and policies to manage releases.

Article 5(a)(iii): Identify strategies to meet dioxin reduction obligations, taking into account the evaluations in (i) and (ii).

Article 5(a)(iv): Take steps to promote education and training and raise awareness of the strategies.

Article 5(a)(v): Review, evaluate and report on strategies every five years in meeting release reduction obligations.

Article 5(a)(vi): Develop a schedule for implementation of the Action Plan, including the strategies and the measures identified in them.

Article 5(b): Promote the application of available, feasible and practical measures that can readily achieve a realistic and meaningful level of release reduction or source elimination.

Article 5(c): Promote the development and use of substitute or modified materials, products and processes to prevent the release of Annex C chemicals.

Article 5(d): Promote/require BAT/BEP for new installations (sources) in accordance with Part II of Annex C.

Article 5(e): Promote BAT/BEP for existing installations (sources) in accordance with Parts II and III of Annex C.

Elements of the Action Plan for Dioxins and Other Annex C Chemicals

An overall framework for the proposed Action Plan for Dioxins and Other Annex C Chemicals is illustrated in Figure 2, while each element of the plan is addressed below.

Figure 2: Outline of the Action Plan for Dioxins and Other Annex C Chemicals

See figure at its full size (including text description).

Article 5(a)(i): evaluate current and projected releases, including the development and maintenance of source inventories and release estimates, taking into consideration the source categories identified in Annex C

A New Zealand Inventory of Dioxin Emissions to Air, Land and Water, and Reservoir Sources was published by the Ministry for the Environment in March 2000.  The investigatory work leading up to the compilation of the inventory was begun in 1998.  Subsequently, the Stockholm Convention was negotiated (including Article 5), UNEP Chemicals prepared the Standardised Toolkit for Identification and Quantification of Dioxin and Furan Releases,[See UNEP Chemicals, 2005.  The first edition of the Toolkit was released in 2003; the second edition was released in February 2005.  The Toolkit is a guide and methodology for compiling inventories, and notes that the best inventories use local test data.] and the advance draft of the BAT/BEP Guidelines was circulated by UNEP Chemicals in December 2004.[See UNEP Chemicals (unpublished draft circulated December 2004).]

The first New Zealand Inventory of Dioxin Emissions was followed up by a focused assessment of emissions to air from the secondary metallurgical industry, undertaken in 2002/03 (Ministry for the Environment, 2004a).  In a preliminary review (Sinclair Knight Mertz, 2005), the New Zealand dioxin inventory was compared to the UNEP Toolkit.  The review found that the New Zealand inventory was comprehensive in addressing the potential sources of dioxins and was still relevant because a reasonable level of New Zealand test data for emissions were available at the time the inventory was prepared.  Table 9 presents a summary of the New Zealand inventory, published in 2000 from 1998 data, and re-collated to the format of the UNEP Standardised Toolkit.

Table 9: Summary of dioxin releases to air, land and water in New Zealand for 1998, giving TEQ/annum [TEQ, toxic equivalents, is the resultant toxicity given by a mixture of dioxin congeners.]

From UNEP
category

Source

Best estimate air
gTEQ/a

Total to air
(%)

Best estimate land
gTEQ/a

Total to land
(%)

Best estimate water
gTEQ/a

Total to water
(%)

Total to all media
gTEQ/a

1

Waste incineration

3.58

11.09

2.97

6.5

 

6.55

2

Ferrous and non-ferrous metals production

1.75

5.42

7.01

15.33

0.015

0.67

8.78

3

Power generation and heating/cooking

7.28

22.55

5.32

11.63

 

12.60

4

Production of mineral products

0.46

1.43

0.78

1.7

 

1.61

5

Transport

0.64

1.98

 

 

0.64

6

Uncontrolled combustion processes

18.30

56.69

5.7

12.47

 

24.00

7

Production and use of chemicals and consumer goods

0.04

0.13

0.83

1.82

0.275

12.22

0.72

8

Miscellaneous

0.23

0.71

 

 

0.23

9

Disposal/landfilling

 

23.11

50.55

1.96

87.11

25.08

 

Total TEQ/annum

32.28

100

45.72

100

2.25

100.00

80.21

The 2005 review also identified areas where activity data should be updated to improve the quality of New Zealand’s Release Inventory of Dioxins and other Annex C Chemicals.  These areas are listed below as items 1 to 15 in the work programme.  For example, most of the small incinerators situated among the country’s 2700 schools were expected to cease operating by the time the National Environmental Standard applies on 1 October 2006.[The Ministry of Education has been especially proactive in promoting this measure, and recently estimated that around 600 incinerators, or about 85% of the total, will have ceased operating by this date.]

The aim is for the update to provide information on trends and progress towards achieving reductions in these priority areas.  Sources were also identified where obtaining New Zealand emission data is desirable to reduce uncertainty and thereby refine the overall inventory.

Producing an updated Release Inventory of Dioxins and other Annex C Chemicals will involve checking, refining and improving the quality of the data, in addition to updating the activity data for 2003, where this is worthwhile.  Priority areas of the inventory will also undergo a more detailed review than the one conducted in February 2005 to identify whether further updates to activity data and/or emission factors are justified.

The structure of the updated New Zealand Release Inventory of Dioxins and other Annex C Chemicals should be aligned with that of the UNEP Toolkit for ease of comparison with inventories produced internationally.  UNEP emission factors should be used where there are no New Zealand-derived factors and there is no other clear justification for the factors currently used in the New Zealand inventory.

Work objective

To further review and update a New Zealand Release Inventory of Dioxins and other Annex C Chemicals, including future projections, in priority areas to reflect changes since activity data were collected in 1998 and 2003; and, as, appropriate, to incorporate new emission factor data and align with international protocols for inventory preparation.

Expected output

To update the New Zealand Release Inventory of Dioxins and other Annex C Chemicals (first revision) relative to the selected reference year, and including future projections, by December 2007, and provide updates thereafter as necessary to report to the Convention Secretariat by December 2010.

Work programme

Following is the agenda to progressively update the release estimates for dioxins and other Annex C chemicals in readiness for reporting by December 2010.

Item 1 Review activity data for waste incineration (including medical care, quarantine, schools and other small facilities) and investigate and revise emission factors if indicated.

Item 2 Review release estimates to land from New Zealand’s waste incinerators in line with the outcome of Item 1.

Item 3 Update New Zealand estimates for releases to land from secondary steel production to include waste lime and slag, either based on the UNEP Toolkit figures or gather New Zealand data, as appropriate.

Item 4 Update secondary metallurgical industry estimates to reflect New Zealand data gathered in 2003.

Item 5 Convert New Zealand emission factors for power generation and heating from fuel (mass) consumption to energy values to allow a comparison with the UNEP Toolkit.

Item 6 Review international data and, as feasible, local data for their relevance to estimating releases to air from New Zealand’s domestic solid-fuel heating appliances.

Item 7 Review emission factors for domestic solid-fuel heating releases to land.

Item 8 Update estimates for releases to air and as wastes from biomass combustion for power and heating by collating available industry measurement data.

Item 9 Review the emission factors for estimating releases to air, land and water from cement manufacturing in New Zealand.  Include emissions from brick, ceramic and asphalt production if activity data are available.

Item 10 Review vehicle estimates using the UNEP fuel consumption-based emission factors if appropriate New Zealand data are available, and update estimates based on these factors and any relevant changes in the characteristics and performance of the vehicle fleet.

Item 11 Review local and international information on estimates of releases to air and land from uncontrolled combustion (e.g. structural fires, burning of plastics, domestic and rural waste burning, agricultural burn-off, including additional research if necessary) and update New Zealand estimates, as appropriate.

Item 12 Confirm that releases to air, land and water from biomass drying, smoke houses and drycleaning are inconsequential in the New Zealand context.

Item 13 Review the New Zealand approach to recording landfill releases (treated as a discharge to land versus a reservoir source by UNEP), noting the importance of tracking the fate of waste streams for assessing exposure potential, and review and update local and international data on waste composition, waste leaching and landfill leachate.

Item 14 Investigate whether more recent emission test data are available for emissions to air, land and water from pulp and paper, or sample discharges to water from the pulp and paper mills.

Item 15 Collect data on current practices for the disposal and/or combustion of treated timber.

Article 5(a)(ii): Evaluate the efficacy of laws and policies to manage releases

The Resource Management Act 1991 (RMA) is the primary piece of legislation for environmental management in New Zealand, which has the purpose of promoting the sustainable management of natural and physical resources.

Regional councils have the primary functions under the Act for controlling discharges to air, land and water.  The tools available to regional councils for managing discharges are regional policy statements, regional plans and resource consents.  All regional councils have proposed or operative plans to address discharges to air, land and water.  Many of these contain rules that relate to activities that produce unintended releases of dioxins and other POPs (e.g. prohibitions on the open burning of certain substances, and consent requirements for metal processes above a certain size).

The Minister for the Environment can issue national policy statements and make national environmental standards to be promulgated as regulations.  The Minister may also “call-in” resource consent applications if it is in the national interest to do so.

The RMA framework allows councils and the Minister to develop a mix of regulation, promotion and education for addressing environmental issues, including controlling dioxin and other Annex C chemical emissions.

Central government gazetted the Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins, and Other Toxics) Regulations in October 2004, with amendments in December 2004 and July 2005.  National environmental standards, prepared in accordance with sections 43 and 44 of the Act, are mandatory technical environmental regulations implemented by agencies and parties with responsibilities under the RMA.  The standards automatically set a bottom line to controls placed by local government.

The standards prohibit seven activities that would otherwise discharge significant quantities of dioxins and other toxics into the air:[Regulations 6–12, Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins, and Other Toxics) Regulations 2004.]

(i) lighting fires and burning of waste at landfills

(ii) burning of tyres in the open

(iii) burning of coated wire in the open

(iv) bitumen burning for road maintenance

(v) burning of oil in the open (with some exceptions)

(vi) operating an incinerator at a school or a health-care institution, unless a resource consent is obtained by September 2006

(vii) operating new high-temperature hazardous waste incinerators.

Included in the national environmental standard package is the requirement for large landfill sites (over 1 million tonnes in design capacity) to collect and destroy greenhouses gases (by September 2007).[Regulations 25–27, Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins, and Other Toxics) Regulations 2004.]  Although the purpose of this regulation is to control greenhouse gas emissions at landfills, its effect will also be to reduce the likelihood of a spontaneous or accidental fire, and in that sense this regulation can be seen as a POPs release reduction measure.

A detailed explanation of the above national environmental standards is given in The Updated Users Guide to Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins, and Other Toxics) Regulations 2004 (Including Amendments 2005) (second draft), (Ministry for the Environment, 2005b).

In addition to the standards listed above, two other national environmental standards directed at improving air quality will also have significant effects on minimising the release of dioxins and other Annex C chemicals from combustion.

  • Ambient air quality standards,[Regulations 13–19, Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins, and Other Toxics) Regulations 2004.] from September 2005, place limits on allowable levels of PM10 and will require air quality improvements in airsheds where the standard is exceeded.[The fine particle standard requires councils to clean-up the air by 1 September 2013 to the target level of 50 micrograms of fine particles per cubic metre of air over any daily 24-hour period.]  Reducing emissions of particulates to comply with the standard will also reduce releases of dioxins and other Annex C chemicals associated with particulate matter.
  • New woodburners sold for installation in domestic dwellings after 1 September 2005 are required to meet new flue gas particulate and thermal efficiency design standards.[Regulations 22–24, Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins, and Other Toxics) Regulations 2004.]

These measures are significant in view of the estimate that domestic home heating from the burning of wood presently contributes up to 17% of the annual total dioxin releases to air (Ministry for the Environment, 2000).  The best ways to encourage families to make their homes more energy efficient and to install cleaner heating systems are being investigated under the Government’s Warm Homes Project, to reduce the effects of home heating on the environment while at the same time allowing people to stay warm.

Unleaded petrol was introduced to New Zealand in 1986 and the use of halogenated lead scavengers ceased in 1995.  The Government has now introduced tighter controls on vehicle build standards for emission control in line with internationally accepted standards and has announced plans to further tighten these further in coming years. Although the main objective is to reduce air pollution generally, such measures may also have the beneficial effect of reducing releases of dioxins from land transport sources, presently estimated at between 0.8% to 2.3% of total releases to air (Ministry for the Environment, 2000).

Work objective

To monitor and periodically evaluate the efficacy of New Zealand’s environmental management framework for managing sources of dioxins and other Annex C chemicals.

Expected output

To report on the adequacy of New Zealand’s environmental management framework for managing sources of dioxins and other Annex C chemicals, by 2010.

Work programme

Item 16 Monitor the implementation of, and compliance with, the National Environmental Standard Regulations (Air Quality) relating to dioxins, the PM10 standard and the standard for domestic woodburners.

Item 17 Monitor implementation and compliance for phasing in tighter vehicle emissions standards.  Evaluate the potential for achieving any reductions in dioxins from such controls.

Item 18 Estimate reductions in dioxins achieved from implementing national environmental standards via updates to the national inventory.

Item 19 Review progress in addressing release reductions from priority activities, including the disposal of farm plastics, school incinerators, and the use of PVC in building materials, and identify areas (if any) in relation to these or other sources where regulation or other central government initiatives are required to implement BAT/BEP (best available techniques/best environmental practice) controls on priority activities (see also Item 34).

Article 5(a)(iii): Strategies to meet Annex C chemicals reduction obligations taking into account the evaluations in (i) and (ii)

Several strategies have been identified that will help minimise the release of dioxins and other Annex C chemicals:

  • updating and reviewing the New Zealand Release Inventory of Dioxins and other Annex C Chemicals against the BAT/BEP guidelines to identify any priority areas to be addressed to achieve reductions in the release of dioxins and other Annex C chemicals
  • implementing the National Environmental Standards on Air Quality (regulations relating to certain air pollutants, dioxins, and other toxics)
  • improving waste management practices via industry-based schemes for particular waste products to avoid their open burning (e.g. used tyres, used oil).

These strategies are incorporated into the present Action Plan for Dioxins and Other Annex C Chemicals.

Work objective

To prepare a strategy to meet dioxin and other Annex C chemicals reduction obligations based on the review of the New Zealand Dioxin Inventory and the legislative review, and to implement subparagraphs (b) to (e) of Article 5 of the Convention.

Expected output

An Action Plan for Dioxins and Other Annex C Chemicals to implement subparagraphs (b) to (e) of Article 5 of the Convention (i.e. the final version of the current document).

Work programme

The following items are in addition to the tasks identified to implement Articles 5(i) and (ii) of the Convention.

Item 20 Monitor the action plans for Annex C chemicals of other countries.

Item 21 Take into account the Action Plan for Reducing Discharges of Dioxin to Air (Ministry for the Environment, 2001) and the supporting documents.

Item 22 Consult on and review a draft Action Plan for Dioxins and Other Annex C Chemicals, and submit the final plan to the Convention Secretariat before December 2006.

Article 5(a)(iv): Steps to promote education and training, and to raise awareness of the strategies

Minimising releases of dioxins and other Annex C chemicals

Generally, actions that improve air quality will also result in reduced formation of dioxins and other Annex C chemicals; for example, not burning refuse and plastics, using a modern and efficient home-heating appliance when burning wood and coal, and not burning chemically treated timber or driftwood (which contains high levels of chlorine from sea salt).

The Ministry for the Environment’s Users Guide to the National Environmental Standard Regulations (Ministry for the Environment, 2005b) raises awareness of those activities prohibited under the National Environmental Standard because they discharge dioxins and other toxic compounds.  The main audience for this guide is local government.

The Action Plan for Dioxins and Other Annex C Chemicals includes measures to promote improved practices where regulation is not warranted.  This may involve liaison with industry when preparing relevant codes of practice, and promotion to regional councils to include consideration of controls on dioxins emissions and activities they already regulate (e.g. submissions on resource consents, where appropriate).  Raising awareness among the general public of the importance of not burning treated timber, plastics and other wastes will also help minimise releases of Annex C chemicals.  The Action Plan for Dioxins and Other Annex C Chemicals was open to comment from industrial sectors and stakeholder groups.

Work objective

To promote the Action Plan for Dioxins and Other Annex C Chemicals and the strategies within it.

Expected output

Stakeholders are informed about the Action Plan for Dioxins and Other Annex C Chemicals.

Work programme

Item 23 Promote awareness of the Action Plan via the Ministry for the Environment’s website.

Item 24 Inform industry and regional councils of the Action Plan through work with stakeholder Task Teams on the inventory update and implementation of BAT/BEP.

Item 25 Promote the Action Plan among other stakeholders, including through the work of Task Teams on the inventory update and implementation of BAT/BEP.

Item 26 Promote the Action Plan under relevant Ministry for the Environment programmes, including the work on farm plastics, construction and demolition wastes, and the Warm Homes project.

Article 5(a)(v): review, evaluate, and report on strategies every five years in meeting Annex C chemicals reduction obligations

This Action Plan for Dioxins and Other Annex C Chemicals contains strategies for achieving reductions in the unintentional production of POPs.  Article 5(a)(v) of the Convention requires a review of the Action Plan for Dioxins and Other Annex C Chemicals every five years.

Work objective

To evaluate the Action Plan for Dioxins and Other Annex C Chemicals and the strategies within it.

Expected output

A report on progress under the Action Plan for Dioxins and Other Annex C Chemicals every five years.

Work programme

Item 27 Review progress in implementing the strategies in the Action Plan for Dioxins and Other Annex C Chemicals.

Item 28 Evaluate how successful the strategies have been in achieving dioxin reductions, both overall and in relation to specific priority areas, including the disposal of farm plastics, school incinerators, and the use of PVC in building materials.

Item 29 Revise the strategies, where appropriate, to achieve further reductions and update the Action Plan for Dioxins and Other Annex C Chemicals.

Item 30 Prepare a report summarising the above.

Article 5(a)(vi): A schedule for implementation of the Action Plan, including the strategies and measures identified therein

The Action Plan for Dioxins and Other Annex C Chemicals sets out strategies and measures to be implemented over the period 2006–2010.

Article 5(b): Promote the application of available, feasible and practical measures that can expeditiously achieve a realistic and meaningful level of release reduction or source elimination

The terms “expeditiously”, “realistic” and “meaningful” are interpreted as referring to measures that can be implemented relatively easily, without undue delays and/or significant costs.

The National Environmental Standards for Certain Air Pollutants, Dioxins and Other Toxics have prohibited a number of activities (see discussion under Article 5[a][ii]).  This measure effectively eliminates some sources of dioxins and other Annex C chemicals, such as landfill fires and road seal burning.

The Ministry for the Environment has prepared a Users Guide (Ministry for the Environment, 2005b) to promote understanding and facilitate implementation of the new national environmental standards.  To facilitate compliance with the new standards, the Ministry of Education has already identified best practices to enable schools to avoid waste incineration and is currently working with schools to adopt alternatives for managing waste, including composting, recycling and landfilling.  Health-care institutions are expected to incorporate new technologies, such as steam sterilisation and autoclaving, as part of an integrated waste management approach to treat medical wastes.

Two initiatives to reduce the open burning of waste in rural areas are worth noting.  It is estimated that annually 8000 tonnes of plastic are used in New Zealand agriculture as baleage wrap (7000 tonnes) and agrichemical containers (1000 tonnes).  Although the plastic used to manufacture these products is potentially recyclable, in practice contamination issues make it difficult to recycle these particular plastic products.  Work is ongoing to manage unwanted farm plastics, including the following.

  • The feasibility of recycling baleage wrap into plastic sheet suitable for feed pad floors, or pipe for culverts or drains, is presently being investigated by the Wellington region’s Enviromart Waste Exchange.
  • A product stewardship scheme involving the cleaning and recycling of plastic waste agrichemical containers is being developed by the New Zealand Agrichemical Education Trust.

These initiatives, supported by the Ministry for the Environment, have the potential to significantly reduce the quantity of wastes otherwise burnt on farms and currently contributing to air pollution and releases of dioxins and other Annex C chemicals.

Other measures for reducing sources of dioxins and other Annex C chemicals are identified under the discussion on Articles 5(c) to (e).

Work objective

To promote measures to expeditiously achieve reductions in releases of dioxins and other Annex C chemicals and the elimination of specific sources.

Expected output

Information on measures for reducing and eliminating dioxin and other Annex C chemicals that can be readily implemented by target groups.

Work programme

Item 31 Promote the Users Guide on the national environmental standards to reduce releases of dioxins and other air toxics.

Item 32 Support other initiatives that minimise releases of dioxins and other Annex C chemicals.

Article 5(c): Promote the development and use of substitute or modified materials, products and processes to prevent releases of Annex C chemicals

There are a number of examples in New Zealand where the application of substitute or modified materials, products and processes has already led to significant reductions in releases, or potential releases.  These include the elimination of elemental chlorine from the bleaching of pulp and paper, the phase-out of unleaded petrol, the use of improved wood stoves under the National Environmental Standard, and the move towards steam sterilisation of health-care and quarantine wastes.  It is expected that further opportunities will be identified during the work with stakeholders on the implementation of BAT/BEP.

The preparation of guidance on substitution is to be co-ordinated by the Convention Secretariat, including information on substitute and modified materials, and on products and processes to prevent the generation and release of dioxins and other Annex C chemicals.  It is proposed that this guidance be reviewed when it becomes available.

Article 5(d): Promote/require the use of BAT/BEP for new installations (sources) in accordance with Part II of Annex C

The sources listed in Part II of Annex C comprise waste incinerators (including co-incinerators of municipal, hazardous or medical wastes), thermal processes in secondary metallurgical industries, cement kilns firing hazardous wastes, and the production of pulp using elemental chlorine for bleaching.

New high-temperature hazardous waste incinerators are a prohibited activity under the National Environmental Standard.  New cement kilns or pulp and paper facilities are unlikely in the foreseeable future.  Any new waste incinerator (low-temperature or non-hazardous) or secondary metallurgical facility would attract the regulatory attention of regional councils.

Work objective

To identify the most appropriate measures to promote or require BAT/BEP for new Part II, Annex C, sources.

Expected output

A report on regulatory and non-regulatory means to promote or require BAT/BEP for new Part II, Annex C, sources.

Work programme

Item 33 Work with stakeholder Task Teams to review the significance of Part II, Annex C, sources to New Zealand releases of Annex C chemicals, and to determine the most appropriate methods for implementing BAT/BEP and/or the use of substitute or modified materials, products and processes.

Item 34 Report on any significant issue involving BAT/BEP concerning new Part II, Annex C, sources, including any requirements for changes to laws and policies (see Item 19), and further work on education and awareness (see Items 24 and 25).

Article 5(e): Promote the use of BAT/BEP for all existing installations (sources) in accordance with Parts II and III of Annex C

The aim of this article is to promote the use of BAT/BEP to new and existing sources not otherwise addressed under Article 5(d).  To set the context for this obligation, Table 10 shows the findings from an initial review of the BAT/BEP guidelines against current New Zealand practice.  The capacity to minimise releases of dioxins and other Annex C chemicals has been categorised for the various sources as high, medium or low.  Residential waste burning and home heating exhibit a high capacity for further reduction in releases, while the metals industry and boilers show a medium capacity for reduction.

Table 10: Potential to apply BAT/BEP and reduce releases from specific source categories

Source categories Part II, Annex C

Meets BAT/BEP

Annex C chemicals reduction capacity

Waste incinerators

No

Medium

Secondary metallurgical industry thermal processes

Most do; some don’t

Medium

Hazardous waste incinerators

Yes

Nil

Cement kilns

Yes

Nil

Pulp and paper

Yes

Nil

 

Source categories Part III, Annex C

Meets BAT/BEP

Annex C chemicals reduction capacity

Residential waste open burning

No

High

Residential combustion for domestic heating

No

High

Other metallurgical thermal processes (not in Part II)

Most do; some don’t

Medium

Boilers (fossil fuel)

Not all

Medium

Boilers (biomass)

Not all

Medium

Crematoria

Not all

Low

Motor vehicles

No

Low

Animal carcasses

No

Low

Chemical production

Yes

Low

Open burning (landfills)

Yes

Nil

Copper cable smouldering

Yes

Nil

Textile and leather

No concern

Nil

Vehicle shredding

No concern

Nil

Waste oil refining

No concern

Nil

Work objective

To identify the most appropriate measures to promote the application of BAT/BEP for new and existing Annex C, Parts II and III, sources.

Expected output

A report on the regulatory and non-regulatory means to promote BAT/BEP for new and existing Annex C, Parts II and III, sources.

Work programme

Item 35 Work with stakeholder Task Teams to review the significance of Annex C, Part III, sources to New Zealand releases of dioxins and other Annex C chemicals, and to determine the most appropriate methods for implementing BAT/BEP and/or the use of substitute or modified materials, products and processes.

Item 36 Report on any significant issue involving BAT/BEP concerning Annex C, Part III, sources, including any requirements for changes to laws and policies (see Item 19), and further work on education and awareness (see Items 24 and 25).

Summary of the Action Plan for Dioxins and Other Annex C Chemicals

Implementation and oversight of the Action Plan for Dioxins and Other Annex C Chemicals is the responsibility of the Ministry for the Environment.  In summary, the Action Plan for Dioxins and Other Annex C Chemicals to minimise and, where feasible, ultimately eliminate releases of unintentional POPs to air has been compiled in accordance with the following measures.

Measures (M)

M.1 Review, and update five-yearly, a New Zealand Release Inventory of Dioxins and Other Annex C Chemicals [Article 5(a)(i)] (Items 1–15).

M.2 Monitor and periodically evaluate laws and policies to manage releases of dioxins and other Annex C chemicals [Article 5(a)(ii)] (Items 16–22).

M.3 Identify strategies to minimise releases of dioxins and other Annex C chemicals [Article 5(a)(iii)] (Items 20–22).

M.4 Promote information (where appropriate) to support the above programmes [Article 5(a)(iv)] (Items 23–26).

M.5 Report progress under the Action Plan for Dioxins and Other Annex C Chemicals every five years [Article 5(a)(v)] (Items 27–30).

M.6 Implement the Action Plan for Dioxins and Other Annex C Chemicals to:

  • maintain and promote the implementation schedule [Article 5(a)(vi)]
  • promote the measures of the Action Plan [Article 5(b)] (Items 31–32)
  • take account of guidance prepared by the Conference of the Parties [Article 5(c)]
  • provide consideration of BAT/BEP requirements for any new Annex C, Part II, installations (sources) [Article 5(d)] (Items 33–34)
  • provide consideration of BAT/BEP requirements for all existing installations (sources) in accordance with Parts II and III of Annex C [Article 5(e)] (Items 35–36).

In addition, the Ministry for the Environment is to:

  • submit the New Zealand Action Plan for Dioxins and Other Annex C Chemicals (as a component of the National Implementation Plan) to the Convention Secretariat by December 2006
  • report the New Zealand Release Inventory for Dioxins and Other Annex C Chemicals, Revision 1, to the Convention Secretariat by December 2010
  • report a five-yearly review of strategies to meet obligations for reducing and, where feasible, eliminating releases of dioxins and other Annex C chemicals to the Convention Secretariat by December 2010.