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Training workshop on environmentally regulated substances. Lecture 6: Ozone-depleting Substances. INECE Capacity Building Program on Controlling Shipments of Environmentally Sensitive Goods at Seaports. What is an ozone-depleting substance?.
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Training workshopon environmentally regulated substances Lecture 6: Ozone-depleting Substances INECE Capacity Building Program on Controlling Shipments of Environmentally Sensitive Goods at Seaports
What is an ozone-depleting substance? • Chemical substances that can react with ozone in the stratosphere • Various hydrocarbons with chlorine, fluorine and bromine Largest ozone hole: Sept 24, 2006 July 26, 2014 eschooltoday.com
Impacts of Ozone Layer Depletion Human health impacts from increased UV radiation • Increased risk of skin cancer • Increased risk of cataracts and eye damage • Immune suppression Environmental impacts from increased UV radiation • Negative impact on ecosystems • Some ODS drive climate change • Lower yields for several key crops (e.g., rice, soy beans) • Reduced productivity of plankton which form the base of the marine food web
Common Uses of ODS • Refrigerants • Blowing agent for foams • Cleaning solvent • Propellants for aerosols • Sterilants for health care products • Fire extinguishers • Fumigants • Chemical synthesis feedstocks • Laboratory uses
OZONE:Good up high, bad nearby epa.gov
Montreal Protocol • International treaty ratified in 1987 to reduce and eliminate emissions from ODS • September 2009: Montreal Protocol became first treaty in history of the United Nations to achieve universal ratification: 197 nations.
Developing countries have increased ODS controls http://www.epa.gov/ozone/intpol/pograph.html
Required Phaseout • Phaseout: • Chloroflurocarbons (CFCs) • Hydrochlorofluorocarbons (HCFCs) • Equipment should be replaced or retrofitted to accept new gases: can be expensive • However, as supply decreases, smuggling may increase
One consequence of Phaseout CFCsHCFCsHFCs Ozone depletion Global Warming Potential Carbon dioxide = 1 Global Warming Potential HFCs = 124 – 14,800 Global Warming Potential
Why ODS Smuggling Occurs • Decreasing availability of gases being phased out or banned, increases demand • Differing phaseout schedules between developed and developing countries • Alternative gases may cost more • Equipment containing ODS has long life • Conversion/retrofitting of equipment is costly
Sources of ODS • Manufacturers: • China is largest global source of virgin ODS • Consumers/disposers of ODS: • United States • European Union • Japan • Australia
Role of Customs Officer in enforcing ods regulations (UNEP) • Enforcement of ODS licensing system • Increasing importer and exporter awareness of ODS regulations • Detecting illegal trade • On-site use of refrigerant analyzers and detectors • Reporting ODS legal and illegal trade to the National Ozone Unit (NOU) • Seizing illegal ODS, including storage and disposal • Provide support to other enforcement agencies to support legal actions
Illegal Smuggling schemes • Mislabeling the canister as a non-ODS gas • This modus operandi has been noted worldwide • Example: R-22 (or HCFC-22, Freon): illegal to trade R-134-a (or HFC-134-a): non-ODS gas R-22 is being smuggled in canisters marked R-134-a • Canisters may contain illegal mixtures of gases; for example R-22 and R-404a, but be labeled as pure legal product • Cardboard packaging may not represent gas in canister: R-134a outer package may contain R-22 canister
Portable refrigerant analyzers • Allow sampling of suspect cylinder at port • Determine if canister’s content match documentation • Determine if canister’s content is contaminated or a mixture • If documentation and actual contents do not match, contents should be analyzed in laboratory to verify • Laboratory analysis is needed to support legal actions
Additional Smuggling Schemes • Mislabeling virgin gas as recovered/used/recycled gas • Virgin gas may be illegal; recycled gas may be allowed • Hiding canisters • Illegal gas canisters hidden behind non-ODS canisters • Concealing smaller canister within larger one (double layering) • Vehicle scan useful in detection ofhidden cylinders • Equipment contains ODS: • Refrigerator compressors not purged • Equipment modified to hold excessamounts of ODS
Some Safety Considerations: ODS containers and ODS-containing equipment • Do not vent ODS into the atmosphere • Do not store in a confined space • Do not store ODS in direct sunlight • Do not use open flames near ODS; watch for sparks • Do not sample ODS canisters unless you have been trained • Do not eat, drink or smoke near ODS or ODS-containing equipment
Gifts / donations of second-hand appliances may contain ODS and dangerous chemicals epa.gov ghananewsagency.org
Customs Checklist • Compare all documentation to ensure it matches • Check Customs code on entry with invoice • Verify country origin • Check that importer exists • Check that importer is licensed to import specific material • Inspect material: packaging, size, label and shape: should match information on paperwork
It may be an illegal shipment if: • Based on previous knowledge or targeting information, documentation indicates suspicious quantity, source and/or destination information for the ODS • Verify that the importer and place of business actually exist • Information on various documents does not match • Various codes (ASHRAE, HS, UN, chemical name/formula) on documentation do not match actual canister
Some documents to consider • Invoices • Packing lists • Bills of lading • Customs documents • Import/export licenses Does information on all documents match? Can information be verified? Do you see obvious mistakes, omissions?
Check for obvious discrepancies • Missing or inconsistent information on the label • Misspellings of trade names or company names • Check that stickers on canister have not been changed or are not covering up original markings • Incorrect HS Codes may be used to avoid detection • Check for consistency on all documentation • Check color of canister • Color-coding system is not universal, but may indicate an illegal shipment • Canisters may be repainted to misrepresent contents: determine if paint scratches off to reveal another color
Available on the Web: • Training Manual for Customs and Enforcement Officers (3rd edition) (UNEP)Comprehensive training manual on controlling ODS for Customs and Enforcement officers • Enforcement Strategies for Combating the Illegal Trade in HCFCs and Methyl Bromide (UNEP)Guidance for establishing and implementing enforcement programs for preventing the illegal trade in HCFCs and methyl bromide. • Ozone Depleting Substances Smuggling and Concealment: Case Study Handbook (Interpol/UNEP)Information and guidance for police, customs and border security officers on methods commonly used by criminals to hide and smuggle illegal ODS.
Some numbers to check: • ASHRAE number: identifies halocarbon and hydrocarbon refrigerants • Appears in trade name (CFC-12) • CAS numbers: unique identifier for each chemical or chemical mixture • 5 to 9 numbers divided into three groups: up to 6 numbers - 2 numbers - 1 number (CAS 75-45-6 = R-22) • UN Number: 4 numbers that identify certain hazardous substances (UN 1081 = R-22) • HS Codes: WCO international system for identifying commodities; on documentation, but not canisters