The Stockholm Convention on POPs is the first global, legally binding instrument whose aim is to protect human health and the environment by controlling production, use and disposal of toxic chemicals. IPEN views the Stockholm Convention text as a promise to take the actions needed to protect the global public’s health and the global environment from the injuries that are caused by persistent organic pollutants, a promise that was agreed by representatives of the global community: governments, interested stakeholders, and representatives of civil society. We call upon all Stockholm Convention Parties and stakeholders to honor the integrity of the Convention text at the first Conference of the Parties (COP1) in Uruguay. Keep the promise!!

Promises to Keep

1. Financial and Technical Resources
Funds and other resources must be provided to developing country Parties to cover full incremental costs associated with fulfilling their obligations under the Stockholm Convention. Regular monitoring and evaluation of how financial resources are utilized is needed. This promise is explicit in the Stockholm Convention text, and it must be honored.

2. Public Participation and Awareness
IPEN calls upon all Parties and signatories to keep the Convention promise of full access to information, transparency and public participation in Convention implementation activities, including the design and application of National Implementation Plans and other related activities. In the spirit of Article 10, special attention should be given to women, children and workers in public awareness programs and trainings aim at the effects of POPs on human health and the environment, and alternatives.

3. Eliminate Intentionally Produced POPs
We are hopeful that all production and use of most of the listed POPs pesticides will quickly end, and that PCBs still in use will be phased out even more quickly than the final deadline detailed in the Convention. The COP should consider establishing an international expert group to evaluate the potential for the further development of illegal, cross-boundary trafficking in POPs. The Convention properly exempts DDT use for the purpose of disease vector control, but sets as its goal, “reducing and ultimately elimination of the use of DDT. ” Unfortunately, diversions of DDT to non-World Health Organization (WHO) approved uses are being promoted by an irresponsible but well-funded international public relations campaign aimed at convincing world opinion that (in the face of good evidence to the contrary), DDT has minimal or no adverse human health impacts. Realistically, the limiting factor in how rapidly DDT can be globally phased out depends on the amount and the quality of international assistance aimed at delivering superior means of controlling malaria and similar vector-born diseases. IPEN calls upon Parties to address this limiting factor and to consider holistic alternatives to promote substitutes for internally produced POPs that are not harmful to human health or the environment.

4. Eliminate and Reduce Unintentional POPs
The agreed text establishes the Convention’s goal for U-POPs to be “their continuing minimization and, where feasible, ultimate elimination .” For NGOs associated with IPEN, this goal is a critical, guiding principle. Two important documents may be considered by the Parties:

Best Available Techniques/Best Environmental Practices (BAT/BEP)
The draft BAT/BEP Provisional Guidelines document remains a work-in-progress with some very useful sections, and with others where substantial further work is needed. As an example, a reader of the Guidelines could easily conclude that it is acceptable for any cement kiln, of any design, in any region of the world, to accept and burn POPs waste and other halogenated wastes; and if the kiln is “properly operated,” doing so will result in U-POPs releases of at most, “minor importance.” The Stockholm Convention correctly states that using a cement kiln to burn POPs wastes or other halogenated wastes has the potential to generate and release large quantities of U-POPs to the environment. This exemplifies the inconsistencies in the BAT/BEP Guidelines and the need for further work.

Dioxin Toolkit
We suggest COP1 consider proposing further development of the Toolkit, but with guidance as detail below. The information sources that the Toolkit uses to reach conclusions should be fully documented. When considerable uncertainty exists, emission factors should not be reported as a single number, but should be listed as a likely high figure; a likely low figure; and a likely median figure. In addition the Toolkit should not be limited to references and circumstances only from developed countries, but should include data from developing countries and countries with economies in transition. Addressing these issues will help Parties put the conclusions they draw from using the Toolkit into a more balanced perspective. Parties and stakeholders need better opportunities for review and for input. Finally, the process should not only be more responsive and transparent, but it should also be subject to independent review and verification by experts in the field who have no personal stake in the present product. In order for countries to fully address their dioxin inventories and sources, and access resources to implement the Convention, the Toolkit must be revised.

Substitute or modified materials and products as a way to minimize and eliminate unintentional POPs should be addressed in future intersessional work following COP1.

5. Disposal of POPs Wastes
The Basel Convention POPs Waste Guidelines should not be adopted at COP1 as they are not consistent with Article 6 of the Stockholm Convention. The Stockholm Convention requires that technologies used to destroy or irreversibly transform POPs in wastes must, as nearly as possible, do so with effectively 100 percent efficiency. The Basel POPs Waste Guidelines establish allowable levels of POPs releases from processes used to treat POPs wastes. This does not meet the requirement of the Stockholm Convention for the establishment of levels of destruction and irreversible transformation that ensure that POPs characteristics are no longer exhibited.

In other words, the Basel Convention POPs Waste Guidelines are not based on considerations of potential impacts on public health and the environment nor are they based on the capabilities of available technologies for the destruction/irreversible transformation of POPs in wastes. The extraordinarily high values chosen will have the effect of minimizing the quantities of POPs wastes that are prioritized for destruction and maximizing the quantities of POPs wastes that are left to be dealt with through land-filling or other methods of disposal. The result of the high values for “low POPs content” is diminished availability of assistance for destroying POPs and increased potential for negative impacts on public health and the environment from POPs that are, as a consequence, not destroyed. The Basel Convention POPs Waste Guidelines should not be adopted at COP1.

6. Identify New POPs
As an urgent matter, several substances widely used and known to have POPs characteristics – persistence, bio-accumulation, long-range transport and adverse health and environmental impacts – should be considered for early listing by the POPs Review Committee POPRC: hexachlorocyclohexane (HCH, including ?-HCH, lindane), Dicofol, and Endosulfan; brominated flame retardants; perfluorinated chemicals, including but not limited to perfluorooctane sulfonate (PFOS); chlorinated paraffins; organotins; brominated dioxins and bromo-chloro-dioxins, polychorinated napthalenes (PCN) and octachlorostyrene (OCS). The POPRC should also consider listing of methyl mercury.