PCDF - German policy and measures to protect man and the environment

Chcmosphere, Vol.27,Nos.l-3,pp 501-507, 1993 Printedin GreatBritain

0045-6535/93 S6.00+ 0.00 PergamonPressLtd.

PCDD/PCDF - GERMAN POLICY AND MEASURES TO PROTECT MAN AND THE ENVIRONMENT Schulz, D. Federal Environmental Agency, Bismarckplatz 1, D-1000 Berlin 33, Federal Republic of Germany. Keywords: PCDD/PCDF, regulations, risk management, limit values, measures, Germany. ABSTRACT During the last few years the German Federal Government has taken far-reaching legislative action to reduce further dioxin release into the environment. Among these are strict limit values, bans on certain chemicals or restrictions of their use. Further measures are under discussion. INTRODUCTION Polychlorinated dibenzodioxins and dibenzofuranes (PCDD/PCDF) have focussed public attention by a number of local cases of high soil pollution. Extreme concentrations in both soils and dust were detected, e. g. around former cable pyrolysis plants chemical plants. Dioxins in high concentrations were also found in soils of residential areas, where e. g. paper mill sludges had been used to "improve" soil quality. In other cases slags of high dioxin content had been used as material for sportsgrounds or children's playing grounds. Sewage sludges used in agriculture sometimes also showed alarming dioxin concentrations. Due to progress in analytical chemistry more and more "dioxin cases" got to be known; government agencies, local authorities and experts had to develop both methods for risk assessment and concepts for sanitary measures, based on single case studies. Thus the necessity for standardized assessment criteria, especially orientation and limit values easily to be handled by local authorities, and generalized sanitary measures gradually grew. In January 1990 the Federal Minister for Environment in cooperation with the federal states (Lander) Hessen and Baden-Wiirttemberg held an international dioxin symposium and public hearing in Karlsruhe/Germany to compile the scientific base for health-oriented limit values as well as for risk assessment of dioxins in brest milk and to develop a catalogue of measures to reduce dioxin release into the environment1. Afterwards both the Federal Health Office (BGA) and Federal Environmental Agency (UBA) published a report on measures as well as the verbatim record of the hearing2. Furthermore a joint working group of the Federation and the I ~ d e r 501

(Federal States) was established to elaborate

502

recommendations3. The results of this work up to the present,

which reflect the progress in

environmental policy in the dioxin problem during the last few years in Germany, is briefly described as follows. TOLERABLE DALLY INTAKE (DTA) After the symposium held in Karlsruhe in 1990 the Federal Health Office (BGA) came to the following conclusions, which are the basic concept for orientation values for PCDD/PCDF in the Federal Republic of Germany: - it seems justified to assume a human cancer risk after high toxic exposition, especially for 2,3,7,8 TCDD. - TCDD is regarded as a promotor. Therefore a threshold dose can be assumed. For setting orientation values a "classic" approach via NOEL and safety factors seems more adequate than a statistical risk assessment. - experimental data for TCDD suggest a safety factor higher than 100 (normally used for Xenobiotics). NOEL in rats for 2,3,7,8-TCDD is 1 ng/kg b.w. (lifelong dally uptake). - the scientific basis for toxic equivalents is insufficient. Nevertheless for purposes of administration toxic equivalents should be used until better tools for risk assessment are available. The following preliminary concept for tolerable daily intake values has been developed: value of precaution 1 pg TEQ/kg b.w.: If daily dioxin uptake amounts to less than 1 pg TEQ/kg b.w. human health implications can be excluded with high probability. range of risk 1 - 10 pg TEQ/kg b.w.: If daily dioxin uptake is between 1 and 10 pg TEQ/kg b.w., no health implications are to be expected. Yet there is no sufficient safety margin based on principles of preventive health protection. Measures are necessary to minimize dioxin release into the environment. The Federal Health Office and Federal Environmental Agency hold the opinion that all measures to be taken must be aimed at minimizing the individual burden by PCDD/PCDF to below 1 pg TEQ/kg b. w. on average for the whole life. value of intervention 10 pg TEQ/kg b.w.: If daily dioxin uptake exceeds 10 pg TEQ/kg b.w. for longer periods, immediate actions are necessary. Actions should again aim at a daily uptake of less than 1 pg TEQ/kg b.w. Daily human uptake of PCDD/PCDF in the Federal Republic of Germany is estimated at 1-3 pg TEq/kg b.w. (TEFs according to Federal Health Office) for adults and at 80 - 100 pg TEQ/kg b.w. for brest-fed infants4. This means for the case of brestfed infants that there is a safety margin between daily dioxin uptake and NOEL for 2,3,7,8 TCDD in animal experiments of only about 10. A comparably high safety margin as required for other dangerous substances is therefore not any longer given. Therefore a

503

catalogue of measures was developed to reduce human dioxin body burden, especially with respect to brestfed infants. To protect both human health and the environment it is essential to reduce further dioxin release as much as possible. The German Federal Government up to the present has taken far reaching legislative actions to obtain this goal. MEASURES OF THE GERMAN FEDERAL GOVERNMENT TO REDUCE DIOXIN RELEASE INTO THE ENVIRONMENT. O r d i n a n c e on M u n i c i p a l W a s t e Incinerators:

Under the Federal Immissions Control Act (BImSchG; Clean Air Act) the Ordinance on Incinerators for Wastes and Similar Combustible Material (17. BImSchV) was put into force on 01/12/1990. A limit value for dioxins in exhaust gases amounting to 0,1 ng TEQ/m 3 was established. Old incinerators have to be in accordance with this ordinance by 01/03/1994, in some exceptions by 01/12/1996. Sophisticated air purification techniques (including active carbon or dry sorption adsorbers) are necessary to meet this limit value. By this dioxin release from MWls will decrease by a factor of about 100 and will sum up to not more than about 5 g TEQ/a in all Germany. Thus MWls will not be relevant dioxin sources any more. Simultaneously the release of other pollutants (such as mercury) is reduced too as a result of these new technologies. Ban on the use of scavengers:

Also under the Federal Immission Control Act (BImSchG) the German Federal Government on 17/01/1992 released an Ordinance on Chlorinated and Brominated Compounds as Petrol Additives (scavengers). The ordinance (19. BImSchV) prohibits to use chlorinated and brominated compounds as petrol additives and to place such substances on the market for the purpose of it. The ordinance was put into force on 24/07/1992. By this dioxin release via car exhausts will be considerably reduced. N e w O r d i n a n c e on sewage sludges:

The amendment of the Ordinance on Sewage Sludges (AbfKI~V) was put into force on 01/07/1992. A limit value of 100 ng TEQ/kg sludge dry matter was established for dioxins in sludges used in agriculture. Sludge application to grassland and pasture was generally banned, as grazing animals may take up sludge particles directly from the ground, or forage may be polluted with sludge and soil particles. Thus direct dioxin transfer from sludge to animals should be prevented. On cropland used for field forage growing or for the cultivation of sugar beets, to the extent that the sugar beet leaves are used as animal food, sewage sludge may only be applied prior to sowing with subsequent deep ploughing. On cropland only up to 5 t of sludge dry matter per ha within 3 years are allowed. Ban on Pentachlorophenol (PCP):

Under the Chemicals Act (ChemG) an Ordinance on the Ban on Pentachlorophenol (PCP-V) was released on 23/12/1989. Production, trade and use of PCP in the Federal Republic of Germany are forbidden.

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Products containing PCP may not have more than 5 mg PCP/kg. Production and use of PCP were one of the main sources of dioxin release into the environment during the last decades. The ban on PCP eliminates this source. Ban on PCBs: Also under the Chemicals Act an Ordinance on the Ban on PCBs was put into force on 29th of July 1989 banning produetion, trade and use of PCBs, PCTs and Vinylchloride as well as products containing more than 50 ppm of these compounds. As PCBs may be polluted with PCDFs, environmental pollution with PCDF via this source was thus stopped. Ban on polybrominated flame retardants: A ban on polybrominated flame retardants is under way to reduce the entry of PBDD/PBDF into the environment, to protect consumers and workers from exposure to these substances. Initiated by the German Minister for Environment, Nature Protection and Reactor Safety the Commission of the EEC in 1991 issued a draft on the regulation of brominated biphenyl ethers. The draft focusses on a gradual ban on

these

substances.

The

economically

most

important

compounds

(penta-,

octa-,

decabromobiphenylethers) are to be regulated 5 years after a guideline has been accepted. The German Government opts for a shorter transition period. Ordinance on Dangerous Substances: The German Ordinance on Dangerous Substances (GefStoffV; under the Chemicals Act) sets strict limit values for 8 PCDD/PCDF congeners in substances, preparations and articles placed on the market. It focusses mainly on requirements for the purity of commercial chemicals and their use. This regulation is currently reevaluated in order to reduce limit values and extend the scope to all 17 PCDD/PCDF-congenets substituted in 2,3,7,8-position as well as 8 selected PBDD/PBDF-congeners. The old (currently valid) and the proposed new (under discussion) limit values are shown in table 1. Packaging Materials: Dioxin contamination of milk caused by cardboard packaging may also contribute to the dioxin load of consumers. By reducing the dioxin content of packaging material used for liquid foodstuffs (e.g. milk) to a maximum of 1 ppt TEQ according to a mutual agreement between the Federal Health Office (BGA) and the industry, a further source has been eliminated.

505

Ordinance on Dangerous Substances (GefStoffV)

Ordinance on Dioxins

26.08.1986

under discussion

for substances, preparations and articles placed on the market - 2 ppb for 2,3,7,8 TCDD - 1 ppb for 2,3,7,8 TCDD and 1,2,3,7,8 PeCDD and 2,3,7,8 TCDF and 2,3,4,7,8 PeCDF (sum of concentrations, not TEQ!) - 5 ppb for 12 congeners ("dirty dozen")

- 5 ppb for 8 congeners

- 100 ppb for all 17 congeners substituted in

(sum of concentrations):

2,3,7,8-position

2,3,7,8-TCDD and 1,2,3,7,8-PeCDD and

-

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

limit values for PBDD/PBDF:

- 1 ppb for

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

2,3,7,8 TBDD and

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

1,2,3,7,8 PeBDD and

2,3,7,8-TCDF and

2,3,7,8 TBDF and 2,3,4,7,8 PeBDF

2,3,4,7,8-PeCDF and

- 5 ppb for the

1,2,3,6,7,8-HeCDF

4 congeners above and 1,2,3,4,7,8 HxBDD and 1,2,3,7,8,9 HxBDD and 1,2,3,6,7,8 HxBDD and 1,2,3,7,8 PeBDF Table 1. Old (currently valid) and proposed new limit values for PCDD/PCDF under the Chemicals Act. FURTHER RECOMMENDATIONS

PROPOSED

BY

THE FEDERAL HEALTH

OFFICE

(BGA),

THE FEDERAL ENVIRONMENTAL AGENCY (UBA) AND THE JOINT W O R K I N G GROUP OF THE FEDERATION AND THE L~NDER ON DIOXINS. Federal Health Office and Federal Environmental Agency have proposed further measures to reduce human body burden and environmental pollution by PCDD/PCDF 2. Some of these proposals are: -

technical measures to reduce dioxin emissions in metallurgical processes, especially copper smelters and recycling plants.

506

- limitations in the use of halogenated plastics. - modifications in the pulp bleaching process:

- a short term substitution of elementary chlorine. - a long term substitution of all chlorine compounds.

Contaminated soils may be a source of considerable human exposure to PCDD/PCDF. Dioxins from soil may reach humans via the food chain or by direct uptake of contaminated soil or dust particles, especially by children when playing. The Joint Working Group of the Federation and the L/inder on dioxins therefore proposed in a report to the Conference of Ministers for the Environment (UMK) the following reference values for dioxins in soils3: 5 ng T E Q / k g soll dry matter:

no restrictions in soil use. A contamination by less than 5 ng TEQ/kg dm must be therefore regarded as target und aspects of preventive action concerning in particular emissions via air but also other pathways of pollution. Deteriorations of the present status of contamination are to be avoided. If contaminated soils are exchanged in case of required remedial actions this value should be applied to the exchanged soil as a target as well. 5 - 40 ng T E Q / k g :

examinations and measures under aspects of precaution. Possible increased transfer (e.g. via cows milk or eggs) may be analyzed. Techniques for harvesting grass and forage should keep pollution by dust and soil particles low. Forage plants like potatoes or beets should be kept clean by using appropriate harvest technology or subsequent cleaning. Foodstuff for human consumption should be rinsed thoroughly. From plants with big leaves growing close to soil (such as salad, cabbage etc.) the leaves next to soil should be removed. Management of greenland (pasture) may be changed. Sources of dioxin pollution should be identified and measures taken to minimize emissions. above 40 ng T E Q / k g :

Sources of soil pollution should be identified urgently and measures taken to minimize further emissions. Fruits, legumes and forage plants growing near to the soil should not be cultivated. Animals should not be kept running free. Only plants with notably low dioxin transfer (cereals, fruit trees etc.) should be grown. above 100 ng T E Q / k g :

measures on playing grounds for children, like soil exchange (0 - 10 cm), decontamination or soil sealing. On locations in residential areas often used by children for playing measures should be taken to reduce soil contact (soil uptake), such as planting lawns etc. above 1 000 ng T E Q / k g :

measures (as described above) in residential areas.

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above 10 000 ng TEQ/kg soil: measures (as described above) independent of location. The reference values for soils and the corresponding measures mentioned above are not yet part of a law or an ordinance, i. e. they are not compulsory. The Conference of Ministers for the Environment (UMK) in autumn 1991 confirmed the necessity to elaborate orientation and limit values for PCDD/PCDF in soil, water and air as well as in foodstuff and forage. But at present, the scientific basis for this is not deemed to be sufficiently reliable. Several IAnder declared to provisional implement the recommendations until new and reliable knowledge is available. Discussions are currently under way in Germany on - whether the limit value for emissions from MWIs (0. l ng TEQ/m 3) can be applied to other sources (like steel mills, non-iron metal production plants etc.) - which values should be set for dust depositions (dry depositions) in different regions - which orientation values for foodstuff and forage could help to better protect consumers. There is some evidence that environmental pollution and human body burden by PCDD/PCDF is decreasing in Germany. Sediment cores show decreasing dioxin concentrations over the last years, and brestmilk analyses in Nordrhein-Westfalia suggest a tendency towards lower values too. So dioxin problems may be regarded as a challenge for risk management, but we believe these problems are to be solved by a determined and consequent environmental policy. REFERENCES 1 The Toxicology Forum. Health Effects and Safety Assessment of Dioxins and Furans. Washington, 1990. 2 UBA. Dioxinsymposium Karlsruhe Januar 1990. Volume 1: Sachstandsbericht; Texte 49/91. Volume 2: Wortprotokoll der AnhOrung; Texte 50/91. Published by the Federal Environmental Agency, Berlin, 1991. 3 BMU. Bericht der Bund/Llinder-Arbeitsgruppe DIOXINE - Rechtsnormen, Richtwerte,

Handlungsempfehlungen, Meflprograngne, Meflwerte und Forschungsprogramme. Published by the Federal Ministry for Environment, Bonn, 1992. 4 Beck H, Eckart K, Mathar W, Wittkowski R. PCDD and PCDF body burden from food intake in the Federal Republic of Germany. Chemosphere 1989, 18:417-24.