Opinion on the reports by Environmental Resources Management "Assessment of the risks posed by Pentachlorophenol (PCP) through the exposure of man and the environment to dioxins" and "Analysis of the advantage and drawbacks of further restrictions on the marketing and use of PCP", opinion expressed at the 6th CSTEE plenary meeting, Brussels, 27 November 1998.

The CSTEE, on the basis of examination of the following reports (Environmental Resources Management)

- The risk aspects in the report on advantages and drawbacks of further restrictions on the marketing and use of PCP

- Assessment of the risks posed by PCP through exposure of man and the environment to dioxins

Is to answer the following two questions:

(1) With regard to PCP, is the reported degree of risk to the aquatic environment (and to humans via the aquatic environment) sufficiently justified by the study?

(2) Is the study of a good quality taking account of the constraints on the consultants in terms of budget and timing?

Human occupational and environmental exposure

Occupational exposure from industrial and professional usage of PCP has been well documented in several reports. Exposure from anti-sap-stain treatment depends on the technology used. 0.272 mg of PCP kg ^-1 d ^-1 has been estimated for dip application, 0.059 mg of PCP kg ^-1 d ^-1 for industrial spray application with NaPCP (1% w/w) and 0.674 mg of PCP kg ^-1 d ^-1 during professional remedial PCP spray treatment ¹.

Human exposure from the environment may be mediated primarily by contaminated drinking water, food or soil. The ERM report that deals with the risk related to such exposures (CSTEE document 98/8, untitled) has a number of important deficiencies. Many of the major conclusions (see below) are not supported by quoted data or references. In general, this report has a general handicap in lacking the key references. Some are indicated in the text, but also these are not listed in the References.

Dealing with the environmental behaviour of NaPCP and PCP, it most be taken into account that NaPCP will turn into PCP (and vice versa) depending on the acid-base status of the environment.

Wood is usually acid (pH<7); the vapour pressure of NaPCP is very low, but it will be present as PCP at low pH and vaporise from wood surfaces treated with Na-PCP as anti-sap-stain agent. Indoor air concentration of PCP was shown to be 100 to 1000 than that of outdoor air ¹. Soils also are acid in many parts of Europe (e.g. conifer forest belts), leading to a dramatic vaporisation of PCP as it is in contact with the soil. The statement of the ERM report (CSTEE 98/8, page 13) that most sap-stain control units operating outdoor and using Na-PCP, would bear low risk of occupational health exposure, is not justified by any reference to supporting data. Several examples of unacceptably high occupational risks have been listed in other recent reports ¹. The ERM report also neglects to mention these as well any of the reports where potential risks have been demonstrated such as many reports from Finland and elsewhere where workers of outdoor dipping facilities (using the sodium salt based product) were shown to be highly exposed, with urine concentrations mg litre range of PCP and other chlorophenols2,3. Moreover, a recent accident in Galicia, Spain (involving 5 persons hospitalised and one fatal case4 ) provided additional evidence of the risk.

The ERM report acknowledges frequency of ground water pollution cases from the outdoor usage of sodium chlorophenates (p 14-17). However, it does not fully acknowledge the potential for carcinogenic hazard. In fact, IARC has recently ⁷ evaluated as "sufficient" the evidence for carcinogenicity of PCP in experimental animals and "limited" the evidence in humans for the carcinogenicity of combined exposure to polychlorophenols and their sodium salts. The overall evaluation of "possibly carcinogenic to humans" (group 2B) is referred to combined exposure to polychlorophenols . In one area in Finland, residents in a community where groundwater was contaminated by chlorophenols, a statistically significant increased prevalence of respiratory infections, headache, eczema, loss of hair, exceptional tiredness and anorexia is reported 5,6.

PCP and other chlorophenols are converted in the environment into numerous different metabolites by hydroxylation, dechlorination, O-methylation or a combination of these ¹. Therefore the possible carcinogenicity of environment contaminated with PCP cannot be assessed by studying PCP alone.

The remaining main present usage of pentachlorophenol in Europe is Na-PCP as anti-sap-stain agent in industrial and professional use. The applications of PCP on materials in contact with human or animal food and in buildings for decorative purposes are banned by the directive 76/769/EEC and its amendments. (ERM report and ref. 8). However, the reported major damages to the environment and human health were related to industrial and professional uses of PCP. Therefore the only meaningful way of eliminating such damages in the future is to reduce exposure from industrial and professional uses of PCP.

Pentachlorophenol is relatively volatile and soluble in most organic solvents, but poorly soluble in water at the slightly acidic pH generated by its dissolution (pKa 4.7) . However at higher pH it forms highly water-soluble salts and at the close to neutral pH of most natural waters pentachlorophenol is >99% ionised (anion) ⁶. PCP (and other chlorophenols) reversibly sorb to soil organic matter. It has high potential of leaching into to surface waters and ground water differing in this behaviour from the polychlorinated dinzofurans and -dioxins (impurities of commercial PCP preparations) which remain sorbed to soil organic matter ⁶. Sorption is reversible ¹ and contaminated soil layers thus form a possibility for groundwater contamination. In Finland several serious ground water contamination cases resulted from normal operation of industrial wood treatment with chlorophenols ^10,11.

Spontaneous remediation of PCP contaminated aquifers has so far not been reported. There is a biotechnical solution, and it has been operating at technical scale (50m ³ reactor) on a severely polluted site in Finland since 1991. The results obtained by 1997 show that >250 more years of treatment will be needed before the aquifer is restored ¹².

Risk assessment for the aquatic environment

The document on risk assessment of PCP calculates PNECs for the aquatic environment, according to Technical Guidance Document (TGD) supporting 93/67/EEC, on the basis of a relatively wide literature review of toxicity data. In particular, the PNEC for freshwater seems very low (0.17 µg/l) in comparison with the Water Quality Objective of 1 µg/l proposed by CSTE ¹³ and calculated with a procedure comparable to TGD. This low figure is obtained on the basis of a single long term NOEC (growth rate and food conversion efficiency on Oncorhynchus nerka) far from the lower end of the range of all other long-term effects, and can probably be considered as an outlier.

An important question which is not addressed adequately is the possibility of high levels of PCP in areas influenced by the residual uses of the chemical. The restrictions of PCP uses obviously have produced an overall reduction of mean values in water. Nevertheless, the possibility of high concentrations in water bodies directly influenced by emissions from the residual uses of PCP (wood activities, textile industries) cannot be excluded. From the report it is not clear if such "hot spots" were taken into account in the monitoring.

Notwithstanding, data shown in tables 8.2 and 8.3 clearly indicate a significant number of cases of environmental concentrations above the PNEC (and even above the WQO set by the CSTE). These data refer generally to maximum values but, in some cases, also the average values are above the PNEC. Thus, the conclusion should be that, even if no precise data for areas of direct influence of PCP discharges are reported, a risk for the aquatic environment appears evident. In the conclusions of the report, there is a tendency to minimise this aspect.

The second report is aimed to evaluate the risk due to polychlorinated dibenzodioxins and furans (PCDD/Fs) deriving from the use of PCP. Referring to the risk for the aquatic environment, many aspects are not clearly explained. In some cases the origin of numbers used for the development of a risk assessment are controversial and unclear.

The major criticisms can be made to the following sections of the report.

Chapter 3 - Dose-Effect Assessment

Evaluation of toxicity of TCDD for the aquatic environment is based on data reported in Table 3.3a. In the table there are various mistakes in units (mg/kg, µg/kg, ng/kg). Moreover data in the table are not in agreement with data reported in the review of the literature (Annex 3). A more careful evaluation of data reported in Annex 3 allows the following conclusions:

Fish - NOEL from water exposure: 0.001 ng/l (long term effects on juvenile rainbow trout). The validity of this value is confirmed by tests on adult carp and on fathead minnow indicating adverse effects at concentrations as low as 0.05 and 0.06 ng/l, respectively.

Fish - NOEL from diet exposure: 3.3 ng/g in the diet (long term effects on juvenile rainbow trout).

The validity of this value is confirmed by the results of other tests on fish dietary toxicity.

Mammals - NOEL from diet exposure: 0.001 µg/kg b.w. (long term effects on rat). The validity of this value is confirmed by the results of other tests indicating long term effects at levels as low as 0.01 and 0.002 µg/kg b.w.

Using the TGD procedure, a PNEC for TCDD may be calculated by applying a safety factor of at least 10 to the lowest long term NOEL (if data on at least three trophic levels are available). Thus, for TCDD, a PNEC for the aquatic environment of 0.0001 ng/l can be justified.

Referring to PCP, a value of water concentration safe for the aquatic environment (Water Quality Objective) may be set at 1 µg/l 13.

Therefore, the ratio between the WQO for PCP and the PNEC for TCDD is:

1 µg/l / 0.0001ng/l = 107

Chapter 6 - Exposure Assessment - Environment

Much useful information is reported but a number of aspects are not clear. There appear to be mistakes in units in tables 6.3a and 6.3b.

The information provided is not adequate for a reliable evaluation of exposure to PCP and to PCDD/Fs, which is needed for the risk assessment.

Chapter 7 - Risk characterisation and Chapter 8 - Conclusions

The conclusion of the study is not a risk assessment for PCP and related compounds, but an evaluation of the contribution of PCP derived PCDD/Fs on the total PCDD/Fs pollution.

Opinion

Referring to human risk via the environment or occupational exposure, the report leaves a number of established and potential risks unmentioned. A number of important references are missing.

For the aquatic environment, the information reported by the ERM studies is insufficient for a full risk assessment for PCP. In particular, there are many inconsistencies between reported data and conclusive statements. In the first report the evaluation of monitoring data is unsatisfactory. In the second report, both aspects of effects and exposure are not clearly described.

However, information on PCP is very abundant in the literature, if this would be included, a position on the potential risk from exposure to PCP and derived compounds is possible.

Potential for human exposure to PCP

As to the potential human risk via environmental exposure, there is literature data showing that:

- ground water has frequently become polluted in areas where PCP or NaPCP has been used in outdoor facilities;

- contamination of the environment can be long-term. Ground waters polluted in 1960's in Finland, have remained polluted (unusable as drinking water) in 1990's. Soils around treatment facilities have shown persistent pollution and no satisfactory intrinsic remediation is currently available. Chlorophenols may convert in soil into chloroanisols, more hydrophobic and persistent and with relatively unknown effects. In chlorophenol-contaminated soils large amounts of chlorinated compounds with high molecular weight were detected, indicating the possibility of formation of highly hydrophobic and persistent chemicals15. Furthermore, the PCDD and PCDF impurities of the commercial PCP and NaPCP preparations have contaminated the soils around treatment facilities with PCDDs and PCDFs. In some cases (with high level of chlorophenol pollution) these chemicals have leached into ground water.

Occupational exposure from working at industrial treatment facilities (anti-sap-stain) and professional usage has been demonstrated.

Aquatic environment

As quoted above, a Water Quality Objective (comparable to PNEC according to TGD procedure) for PCP has been set at 1 µg/l on the basis of existing toxicity data on aquatic organisms 13. If the lowest NOEC value available is taken into account, a PNEC as low as 0.17 µg/l can be set.

These values should be taken as reference points for the risk assessment for the aquatic environment.

On the basis of the data reported in the study and of many other literature sources, it could be demonstrated that the Water Quality Objective for PCP of 1 µg/l (and even more a possible PNEC of 0.17 µg/l) could be frequently exceeded in water bodies subject to PCP contamination. Before use restrictions were introduced, levels of several µg/l were frequent in many European water bodies ¹⁴. After the partial use ban, mean values were substantially reduced. Nevertheless, at least in waters directly influenced by emissions from uses exempted from the ban (hot spots), the probability of concentrations above 1 µg/l is practically unchanged.

Referring to PCDD/Fs, exposure can be evaluated on the basis of the content of PCDD/Fs in technical PCP formulations. From data reported by WHO ¹⁵, the concentration of PCDD/Fs can be converted into Toxic Equivalent Factors (TEF, see Annex 1 of this document). Using a worst case scenario (maximum amount of impurities) this results in a value of more than 5 ppm of 2,3,7,8-TCDD equivalents. Comparable results derive also from the data reported in the ERM study (see Annex 1 of the ERM Report).

This evaluation is based on data referring to old PCP formulations. At the time being there is an agreement to reduce impurities in PCP formulations. The compounds normally used as indicators of purity are HxCDD and there is a commitment to reduce HxCDD level to 4 ppm. A recent meeting of representatives of the Penta Task Force indicates that the level can be reduced up to 2 ppm. This is a substantial reduction, in comparison to old formulations (maximum HxCDD level 9 ppm, see Annex 1 of this document). Nevertheless, precise data on the levels of other PCDD/Fs, present in large amount in old formulations, has not been provided.

Therefore, it cannot be excluded that PCP concentrations above 1 µg/l could produce in water TEF values as high as 0.0001ng/l (corresponding to 0.1 ppm in relation to PCP) of TCDD. This is an approximated evaluation of the total input of PCDD/Fs mixtures and does not take into account that compounds with different physico-chemical properties (such as highly hydrophobic chemicals) may behave differently in water. Nevertheless, highly hydrophobic chemicals may produce higher risk through accumulation in sediments or biota.

Conclusions

1) Due to an unsatisfactory literature review, to many inconsistencies between reported data and conclusions and to the unclear description of some aspects, the ERM studies cannot be considered adequate for a risk assessment of PCP.

The amount of information on PCP (including literature data not reported in ERM studies) allow to conclude that:

2) The CSTEE declines to comment on the budget and timing constraints placed on ERM in preparing the report.

REFERENCES

1. Advisory Committee on the Pesticides. Review of the use of pentachlorophenol, its salts and esters in wood preservatives and surface biocides. Health and Safety Executive Pesticides Registration Section, Merseyside, 1994.

2. V. Kitunen, R. Valo & M. Salkinoja-Salonen. 1985. Analysis of chlorinated phenols, phenoxyphenols and dibenzofurans around wood preserving facilities. Intern. J. Environ. Anal. Chem. 1985: 20: 13-18.

3. T. Kauppinen & L. Lindroos. 1985. Chlorophenol exposure in sawmills. Am. Ind. Hyg. Assoc. J- 46:34-38.

4. Un brote de intoxication por pentaclorofenato sodico (PCP-Na) ocurrido en la communidad de Galicia en 1997. Concellaria de Sanidade e Servicios Socials, Report 15 Decembre, 1997 (Santiago de Compostela).

5. Lampi, P., Hakulinen, T., Luostarinen, T., Pukkala, E., Teppo L. 1992. Cancer incidence following chlorophenol exposure in a community in southern Finland. Arch. Environ. Health 47:167-175.

6. Tuomisto J. 1998 Pentachlorophenol. In: Guidelines for Drinking Water Quality. Second Edition. Addendum to Volume 2, 229-243, WHO 1998

7. IARC 1998. IARC Monographs Vol. 71

8. European Commission: Marketing and Use of PCP; Directive 76/769/EEC and the 9 ^th Amendment to it 91/173/EEC

9. Rijksinstitut voor Volksgezondheid en Milieu (RIVM). 1991. Integrated Criteria document: Chlorophenols.

10. Kitunen, VH, Salkinoja-Salonen, MS. 1990. Soil contamination at abandoned saw mill areas. Chemosphere 20 (10-12):1671-1677.

11. Kitunen, VH, Valo, RJ, Salkinoja-Salonen MS. 1987. Contamination of soil around wood preserving facilities. Environ. Sci Technol 21:96-101.

12. Puhakka, J., Melin, E. S. 1998. Chlorophenol contaminated ground water remediation at low temperature. In R.A. Meyers (Ed): Encyclopedia of Environmental Analysis and Remediation. John Wiley & Sons, N.Y., pp 1111-1120.

13. Ecotoxicity section of CSTE/EEC. 1994. EEC Water Quality Objectives for chemicals dangerous to aquatic environments. Rev. Environ. Contam. Toxicol. ,137, 83-110.

14. Salkinoja-Salonen, M., Uotila, J., Jokela, J., Laine, M., Saski, E. 1995. Organic halogens in the environment: studies of environmental biodegradability and human exposure. Environmental Health Perspectives, 103, 63-69.

15. WHO. 1987. Pentachlorophenol. Environmental Health Criteria, No. 71. WHO, Geneva.

Annex 1

Impurities of PCP from WHO 1987 (reference 15).

International Toxic Equivalent Factors (TEF)

2,3,7,8- TCDD 1

1,2,3,7,8- PeCDD 0.5

1,2,3,4,7,8- HxCDD 0.1

1,2,3,7,8,9- HxCDD 0.1

1,2,3,6,7,8,- HxCDD 0.1

1,2,3,4,6,7,8,- HpCDD 0.01

OCDD 0.001

List of documents made available to the Scientific Committee on Toxicity, Ecotoxicity and the Environment via its Secretariat to help it reach the opinion requested by the services of the Commission on the ERM reports: "Assessment of the risks posed by Pentachlorophenol (PCP) through the exposure of man and the environment to dioxins" and "Analysis of the advantage and drawbacks of further restrictions on the marketing and use of PCP"

CSTEE/98/8

Assessment of the Risks Posed by Pentachlorophenol (PCP) through the Exposure of Man and the Environment to Dioxins.

Final report DG III - December 1997.

CSTEE/98/8 - Add. 1

Briefing paper on further restrictions on the marketing and use of pentachlorophenol

CSTEE/98/8 - Add. 2 "Doc. III/3506/98"

Review of Directive 91/173 on pentachlorophenol (PCP)

CSTEE/98/8 - Add. 3

Biodegradation of chlorophenolic compounds in wastes from wood-processing industry. In : Current Perspectives in Microbial Ecology (eds M.J. Klug, C.A. Reddy), American Society for Microbiology Washington DC, 668-676.

M. Salkinoja-Salonen, Valo, J.H.A. Apajalahti, R. Hakulinen, L. Silakoski, & T. Jaakkola. 1984.

CSTEE/98/8 - Add. 4

Chlorinated phenols as contaminants of soil and water in the vicinity of two Finnish saw mills. Chemosphere 1984 : 13(8) : 835-844.

R. Valo, V. Kitunen, M. Salkinoja-Salonen & S. Räisänen. 1984.

CSTEE/98/8 - Add. 5

Analysis of chlorinated phenols, phenoxyphenols and dibenzofurans around wood preserving facilities. Intern. J. Environ. Anal. Chem. 1985 : 20 : 13-18.

R. Valo, V. Kitunen, M. Salkinoja-Salonen. 1985.

CSTEE/98/8 - Add. 6

Chlorinated phenols and their derivatives in soil and ground water around wood preserving facilities in Finland. Water sci. Technol. London, 1985 : 17 : 1381-1384.

R. Valo, V. Kitunen, M. Salkinoja-Salonen & S. Räisänen. 1985.

CSTEE/98/8 - Add. 7

Microbial transformation of polychlorinated phenoxy phenols. J. Gen. Appl. Microbiol. Tokyo 32 : 505-517.

R. Valo & M. Salkinoja-Salonen. 1986.

CSTEE/98/8 - Add. 8

Contamination of soil around wood preserving facilities by polychlorinated aromatic compounds. Environ. Sci. Technol. Washington DC, 21 : 96-101.

R. Valo, V. Kitunen & M. Salkinoja-Salonen. 1987.

CSTEE/98/8 - Add. 9

O-methylation of chlorinated phenols in genus Rhodococcus. Archives in Microbiology 152 :6-9.

Max M. Häggblom, Dieter Janke, Peter Middeldorp & M. Salkinoja-Salonen. 1989.

CSTEE/98/8 - Add. 10

Cleanup of old industrial sites. In : Advances in Applied Biotechnology, Vol. 4 (ed. By D. Kamely, A. Chakrabarty and G. Omenn), Gulf Publishing Company, Houston TX, pp. 347-367.

M. Salkinoja-Salonen, P. Middeldorp, M. Briglia, R. Valo, M. Häggblom & A. McBain. 1989.

CSTEE/98/8 - Add. 11

Soil contamination at abandoned sawmill areas. Chemosphere 20 (10-12) : 1671-1677.

V. Kitunen & M. Salkinoja-Salonen. 1990.

CSTEE/98/8 - Add. 12

Measurement of organic halogen compounds in urine, an indicator of exposure. Scand. J. Work Environ. Health, 17 :75-78.

M. Salkinoja-Salonen & J. Jokela. 1991.

CSTEE/98/8 - Add. 13

Biomobility of organic halogen compounds from contaminated soil - earthworms as a tool. In : The contaminants in the Nordic Ecosystem : The dynamics and the fate (ed. by M. Munavar & M. Luotola). SPB Academic Publishing (Amsterdam), pp. 143-150.

M. Laine, J. Jokela & M. Salkinoja-Salonen. 1995.

CSTEE/98/8 - Add. 14

Organic halogens in the environment : studies of environmental biodegradability and human exposure. Environmental Health Perspectives, 103, 5, pp. 63-69.

M. Salkinoja-Salonen, J. Uotila, J.K. Jokela, M.M. Laine and E. Saski. 1995.

CSTEE/98/8 - Add. 15

Fate and toxicity of chlorophenols, polychlorinated dibenzo-p-dioxins and dibenzofurans during composting and contaminated sawmill soil. Environmental Science and Technology, 31(11)3244-3250.

M.M. Laine. 1997.

CSTEE/98/8 - Add. 16

Report concerning a study entitled «Analysis of the Advantages and Drawbacks of Further Restrictions on the Marketing and Use of Pentachlorophenol»

Environmental Resources Management (ERM) contracted by DG III

CSTEE/98/8 - Add. 17

The use and formation of CPs, PCPPs and PCDDs/PCDFs in mechanical and chemical wood processing industries

Veikko H. Kitunen - Helsinki 1990

CSTEE/98/8 - Add. 18

Bioremediation of chlorophenol-contaminated sawmill soil

M. Minna Laine - Department of Applied Chemistry and Microbiology, Division of Microbiology, University of Helsinki, Finland, and Finnish Environment Institute, Laboratory Division, Applied Environmental Biotechnology Unit, Finland - 1998

CSTEE/98/8 - Add. 19

Occurrence and metabolism chlorophenolic wood preserva in the environment

Risto Valo - Helsinki 1990

CSTEE/98/8 - Add. 20

Population health after long-term chlorophenol exposure (book)

Pentti Lampi - Kuopio 1996

CSTEE/98/8 - Add. 21

Informe de las inspecciones realizadas - informe de las caracteristicas clinicas, analiticas y epidemiologicas del brote

XUNTA de Galicia, Conselleria de sanidade e servicios sociais - 23/12/1997.

CSTEE/98/8 - Add. 22

Interim position to be submitted at the 3 ^rd plenary meeting of CSTEE 24/4/1998.

CSTEE/98/8 - Add. 22 rev.1

Interim position to be submitted at the 3 ^rd plenary meeting of CSTEE 24/4/1998.

CSTEE/98/8 - Add. 23

Analysis of the advantages and drawbacks of further restrictions on the marketing and use of pentachlorophenol - March 1998 - DG III.

CSTEE/98/8 - Add. 24

Euro Chlor Risk Assessment for the Marine Environment - OSPARCOM Region - North Sea - Pentachlorophenol - February 1998.

CSTEE/98/8 - Add. 25

- Cover letter from Irene O'Neill (HSE - Pesticides Registration Section) - 5/5/1998 - "DG XXIV Scientific Committee"

- Letter from Irene O'Neill (HSE - Pesticides Registration Section) - 5/5/1998 - "DG XXIV Scientific Committee - the Pesticides PCP, CCA and TBT"
+ Annex I (table) "Pentachlorophenol in UK Surface Waters 1994-1996".

- Note concerning "Pentachlorophenol and its esters - a brief comparison" - July 1997.

- Report of the Advisory Committee on Pesticides - "Review of the use of Pentachlorophenol and its salts and esters in wood preservatives and surface biocides - HSE, Pesticides Registration Section - September 1994.

CSTEE/98/8 - Add. 26

Comments on the ERM-Report "Assessment of the Risks Posed by Pentachlorophenol (PCP) through the Exposure of Man and the Environment to Dioxins" (draft final report of April 1997) - German Delegation 29/4/1998.

CSTEE/98/8 - Add. 27

Remarks concerning "Briefing paper on further restrictions on the marketing and use of pentachlorophenol (PCP)" (Annex I).

CSTEE/98/8 - Add. 28

Estimating Exposure to Dioxin-Like Compounds - Volume I : Executive Summary (Review Draft - June 1994). This document has been sent only to the Chairman of the Working Group "PCP" (Prof. Vighi).

CSTEE/98/8 - Add. 29

Estimating Exposure to Dioxin-Like Compounds - Volume II : Properties, Sources, Occurrence and Background Exposures (Review Draft - June 1994). This document has been sent only to the Chairman of the Working Group "PCP" (Prof. Vighi).

CSTEE/98/8 - Add. 30

Annex 4. "Trends in Pentachlorophenol Concentrations in European River Waters".

CSTEE/98/8 - Add. 31

!! Confidential document - not to be circulated !!

RISK ASSESSMENT of IPBC (3-iodo-2-propynyl-n-butyl carbamate) as active ingredient in sapstain control - CAS-No.: 55406-53-6 - EINECS-No.: 259-627-5 - Interim Report of May 1998.

Supplementary information on PCP substitutes.

CSTEE/98/8 - Add. 32

Swedish comments regarding the draft final report on "Assessment of the risks posed by pentachlorophenol (PCP) through the exposure of man and the environment to dioxins" (ERM, dated April 1997).

KEMI - 15 september 1997.

CSTEE/98/8 - Add. 33

Comments on the ERM Report "Assessment of the risks posed by pentachlorophenol (PCP) through the exposure of man and the environment to dioxins".

Prof. Christoffer Rappe, Institute of Env. Chemistry, Umeä University (Sweden) - 12/9/1997 (fax).

CSTEE/98/8 - Add. 34

Report of the Advisory Committee on Pesticides (issue no. 66) - Review of the use of Pentachlorophenol, its salts and esters in wood preservatives and surface biocides - An evaluation of Pesticide Products under the Control of Pesticides Regulations 1986.

HSE - December 1994.

CSTEE/98/8 - Add. 35

(a) Cover letter from A. Bywater (McKenna&Cuneo, L.L.P.) - 28/7/1998 - Re: PCP .

(b) Letter from Robert D. Sloan (McKenna&Cuneo, L.L.P.) - 24/7/1998 - Re: PCP .

(c) Response to CSTEE (DG XXIV) Criticism of ERM (DG III) Penta Reports - 22/7/1998 .

CSTEE/98/8 - Add. 36 (only one file copy)

List of all the relevant documents in connection with the current Commission review of Pentachlorophenol, including documents that have already been submitted to Environmental Resources Management in the UK and to DG III within the context of the review currently taking place concerning Pentachlorophenol, with a view to amending Annex I of Directive 76/769/EEC.

From McKenna & Cuneo's client KMG-Bernuth, a US-based producer of pentachlorophenol.

(a) Agence de l'Eau Adour-Garrone (1998). Facsimile submitting PCP monitoring data for freshwater in Adour-Garrone.

(b) Chrostowski, P.C. (1997). Environmental Fate and Transport of Pentachlorophenol. Presentation to the United Nations Economic Commission for Europe, Geneva, October 20 ^th, 1997.

(c) Environ (1997). Review and Summary of Fish BCF data for Pentachlorophenol and its implications for UNECE LRTAP POP scoring and classification of PCP.

(d) Hobbs SJ, Howe PD and Dobson S (1993). Environmental Hazard Assessment Pentachlorophenol, Toxic Substances Division, Department of the Environment, UK.

(e) HSE Health and Safety Executive (1994) - Review of the use of Pentachlorophenol, its salts and esters in wood preservatives and surface biocides. (By Advisory Committee on Pesticides).

(! Ce document fait partie de l'Add. 25!)

(f) HSE Health and Safety Executive (1998) - UK monitoring data (1994-1996) - Annex I - Pentachlorophenol in UK Surface Waters 1994-1996.

(! Ce document fait partie de l'Add. 25!)

(g) Marchal P., Vasseur P. and Ozanne G. (1993). Environmental impact of PCP and NaPCP in the aquatic and atmospheric compartment. Centre Technique du Bois et de l'Ameublement, Paris, France.

(h) Ministry of the Environment, France (1997). PCP monitoring data for fresh water, freshwater sediments and freshwater suspended matter in northern France.

(i) Ozanne G. (1995). Penta : the non-emotional approach. Presentation to the 3 ^rd Symposium of "The Challenge Safety-Environment", Cannes Mandelieu, 6-7 February 1995.

(j) Penta Task Force (1993). Submission to the Commission of the European Communities in Connection with Suggested Proposal to Amend the Ninth Amendment to Council Directive 76/69. Vulcan Chemicals/KMG-Bernuth, 1 February, 1993.

(j-1) - Information on Pentachlorophenol;

(j-2) - Appendices to Information on Pentachlorophenol.

(k) Penta Task Force (1997a). Comments of the Pentachlorophenol Task Force on the listing of pentachlorophenol as a POP. Attachment for letter to Mr. Sjoerd Hoornstra (DG XI) and Mr. Paul Glynn (DG III), January 14 ^th 1997.

(l) Penta Task Force (1997b). Euro Chlor Risk Assessment for the Marine Environment - OSPARCOM Region - North Sea : Pentachlorophenol (approved by Working Group in 1998).

(m) Sloof W., Bremmer HJ, Janus JA and Matthiesen AJCM, eds (1991). Integrated criteria document chlorophenols. Report No. 710401013. Rijksinstituut voor Volksgezondheid en Milieuhygiene, Bilthoven, The Netherlands.

(n) US Environmental Protection Agency (1981). Wood preservative pesticides - Creosote, pentachlorophenol and the inorganic arsenicals (Wood Uses) : Position Document 2/3. Office of Pesticides and Toxic Substances, Washington, D.C.

(o) US Environmental Protection Agency (1984). Wood preservative pesticides - Creosote, pentachlorophenol and the inorganic arsenicals : Position Document 4. Office of Pesticides and Toxic Substances, Washington, D.C.

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