National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Türkiye

National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey NATIONAL IMPLEMENTATION PLAN FOR PERSISTENT ORGANIC POLLUTANTS IN TURKEY 2022 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 1 Table of Contents 1. Introduction ......................................................................................................................... 4 1.1. Persistent Organic Pollutants (POPs) and International POPs regulations ................. 4 1.2. Stockholm Convention ................................................................................................ 7 1.3. CLRTAP & POPs Protocol ......................................................................................... 7 1.4. EU Regulations ............................................................................................................ 7 1.5. Turkish National Implementation Plan of the SC ....................................................... 9 2. Country Profile .................................................................................................................... 9 2.1. General Information .................................................................................................... 9 2.2. Legal and Institutional Framework Regarding Environmental Policies ................... 10 2.2.1. Turkey’s Environmental Policy and Strategies .................................................. 10 2.2.2. Roles and responsibilities ................................................................................... 11 2.2.3. Agreements/Conventions Related with POPs .................................................... 15 2.2.4. Legal Framework on POPs ................................................................................ 17 2.3. Inventory of POPs – status in Turkey ........................................................................ 17 2.3.1. Chemicals listed under Annex A of the Conventions ........................................ 17 2.3.1.1. Pesticides and HCB ........................................................................................ 17 2.3.1.2. Hexabromobiphenyl (HBB) and Polychlorinated biphenyls (PCBs) ............. 18 2.3.1.3. Polybrominated diphenyl ethers (PBDEs) ...................................................... 18 2.3.1.4. Hexabromocyclododecane (HBCD) ............................................................... 31 2.3.1.5. Other and newly listed POPs .......................................................................... 32 2.3.2. Chemicals listed under Annex B of the Conventions ........................................ 33 2.3.2.1. DDT ................................................................................................................ 33 2.3.2.2. Perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride ……………………………………………………………………………….34 2.3.3. Chemicals listed under Annex C of the Conventions (Unintentionally produced POPs) ………………………………………………………………………………….35 2.3.3.1. PCDDs/Fs Inventory ....................................................................................... 36 2.3.3.2. Unintentionally produced PCBs ..................................................................... 39 2.3.3.3. Other unintentionally produced POPs ............................................................ 39 2.3.4. Stockpiles, Wastes and Contaminated Sites ....................................................... 40 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 2 2.3.5. Current Programs and Results on Monitoring of POPs Emissions and Effects on Human Health and Environment ...................................................................................... 42 2.3.6. Current level of information, awareness and education among target groups; existing systems to communicate such information to the various groups; mechanisms for information exchange with other Parties to the Convention ............................................. 42 2.3.7. Activities of Non-Governmental Stakeholders related to POPs ........................ 43 2.3.8. Overview of technical infrastructure for POPs assessment................................ 43 2.3.9. Identification of Impacted Populations or Environments, Estimated Scale and Magnitude of Threats to Public Health and Environmental Quality and Social Implications for Workers and Local Communities ........................................................... 43 2.3.10. Relevant systems for the assessment and listing of new chemicals ................... 44 2.3.11. Relevant systems for the assessment and regulation of chemicals already in the market ………………………………………………………………………………….45 3. Strategy and Action Plan Elements of the POPs NIP ....................................................... 45 3.1. Introduction ............................................................................................................... 45 3.2. POPs National Priority Areas .................................................................................... 46 3.3. Activities, Strategies and Action Plans ...................................................................... 46 3.3.1. Institutional Capacity and Regulatory Strengthening Measures ........................ 47 3.3.2. Management of Annex A Pesticides .................................................................. 50 3.3.3. Management of PCBs and PCB Containing Equipment .................................... 50 3.3.4. Management of BFRs ......................................................................................... 52 3.3.5. Management of DDT ......................................................................................... 54 3.3.6. Management of PFOS ........................................................................................ 54 3.3.7. Management of polychlorinated naphthalenes, hexachlorobutadiene, pentachlorophenol and its salts and esters, and short-chain chlorinated paraffins ........... 55 3.3.8. Reduction of releases form the unintentional production of POPs .................... 57 3.3.9. Identification of stockpiles, articles in use and wastes plan for assessment and management of releases from stockpiles and wastes ........................................................ 59 3.3.10. Identification of contaminated sites (Annex A, B and C chemicals) and remediation in an environmentally sound manner ............................................................ 60 3.3.11. Facilitating or undertaking information exchange and stakeholder involvement ………………………………………………………………………………….61 3.3.12. Public awareness, information and education .................................................... 62 3.3.13. Assessment of Effectiveness .............................................................................. 63 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 3 3.3.14. Reporting ............................................................................................................ 63 3.3.15. Research, development and monitoring ............................................................. 64 3.3.16. Technical and financial assistance ..................................................................... 65 3.4. Timetable for Implementation and Measures to Take for Success ........................... 66 3.5. Final Statement .......................................................................................................... 66 4. References ......................................................................................................................... 68 5. Annexes ...……………………………………………………………………………….73 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 4 1. Introduction 1.1. Persistent Organic Pollutants (POPs) and International POPs regulations Persistent Organic Pollutants (POPs) are the chemicals that can remain in the environment for a long time without undergoing any kind of degradation, be transported long distances, bioaccumulate in the food chain and have significant adverse effects on the environment and human health. Since these chemicals are subjected to long range transport, they can even be detected in areas which none of these chemicals are produced or used. Hence, they pose a high risk not only nationwide but also worldwide. POPs are a subject of broad international interest on the global and regional scales. The Stockholm Convention on Persistent Organic Pollutants (SC) is a global treaty focused on the protection of human and environment against POPs. Very important regional activities are connected with the Convention on the Long Range Transboundary Air Pollution (CLRTAP) of the United Nations Economic Commission for Europe (UNECE) and its POPs Protocol. All of these conventions aim to evaluate the problems related to similar types of chemicals; such as pesticides, industrial chemicals and by-products, classified as POPs due to the characteristics listed below:  Persistency in the environment for long periods of time (due to the stable structure, resist to undergo any photolytic, biological and chemical reactions),  Semi-volatility (wide distribution throughout the environmental compartments, water, soil and air, hence subject to long range transport);  Accumulation in the lipids of living organisms and  Toxic effects on humans and wildlife. POPs can be separated to 3 groups by their characteristics and areas of use which are pesticides, industrial chemicals and unintentionally produced POPs. They can also be separated to 3 different groups by considering the annexes of convention. Table 1 lists the POPs with their areas of use and assignment to SC Annexes A, B and C. Some additional information about the SC POPs are summarized in the Annex I. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 5 Table 1: The list of SC and CRLTAP POPs Stockholm Convention Annex A (Elimination) Aldrin Chlordane Chlordecone Decabromodiphenyl ether (commercial mixture, c deca-BDE) Dicofol Dieldrin Endrin Heptachlor Hexabromobiphenyl Hexabromocyclododecane (HBCDD) Hexabromodiphenyl ether and heptabromodiphenyl ether Hexachlorobenzene (HCB) Hexachlorobutadiene Alpha hexachlorocyclohexa ne Beta hexachlorocyclohexan e Lindane Mirex Pentachlorobenzene Pentachlorophenol and its salts and esters Polychlorinated biphenyls (PCB) Polychlorinated naphthalenes Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds Short-chain chlorinated paraffins (SCCPs) Technical endosulfan and its related isomers Tetrabromodiphenyl ether and pentabromodiphenyl ether Toxaphene Annex B (Restriction) DDT Perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride Annex C (Unintentional production) Hexachlorobenzene (HCB) Hexachlorobutadiene (HCBD) Pentachlorobenzene Polychlorinated biphenyls (PCB) Polychlorinated dibenzo-p-dioxins (PCDD) Polychlorinated dibenzofurans (PCDF) National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 6 Polychlorinated naphthalenes POPs Protocol CLRTAP Annex I (Elimination) Aldrin Chlordane Chlordecone DDT Dieldrin Endrin Heptachlor Hexabromobiphenyl Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclohexanes Hexabromodiphenyl ether and heptabromodiphenyl ether Mirex Tetrabromodiphenyl ether and pentabromodiphenyl ether Pentachlorobenzene Perfluorooctane sulfonate (PFOS) Polychlorinated biphenyls (PCB) Polychlorinated naphthalenes (PCN) Short-chain chlorinated paraffins (SCCPs) Toxaphene Annex II (Restriction) DDT Hexachlorocyclohexanes Polychlorinated biphenyls (PCB) Perfluorooctane sulfonate (PFOS) Short-chain chlorinated paraffins (SCCPs) Annex III (Reduction of emissions) Polyaromatic hydrocarbons (PAHs) Polychlorinated dibenzo-p dioxins (PCDD) Polychlorinated dibenzofurans (PCDF) Hexachlorobenzene Polychlorinated biphenyls (PCB) National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 7 1.2. Stockholm Convention Stockholm Convention is an international convention which primarily aims to protect human health and the environment by promoting Parties to the Convention to take precautions for the elimination or reduction of POPs releases. The convention was signed by 125 countries including Turkey on the 23 rd of May 2001 in Stockholm regarding 12 POPs called dirty dozen. SC is effective by May 17 th 2004 and 185 countries or local institutions are Parties to the Convention as of 2022. Convention is focused to eliminate (Annex A), restrict (Annex B) the production and use, and reduce the unintentional release (Annex C) of first 12 POPs since the date it is first effective on and 18 additional POPs are listed since then (Table 1). 1.3. CLRTAP & POPs Protocol The UNECE Convention on Long-range Transboundary Air Pollution (CLRTAP) was the first international treaty to deal with air pollution on a broad regional basis. The Convention entered into force in 1983, aiming at an international cooperation for air pollution abatement including long range transboundary air pollution and setting up an institutional framework which has brought together research and policy. The executive body adopted the Protocol on POPs in Aarhus (Denmark) on 24 June 1998. It focuses on a list of 16 substances that have been singled out according to agreed risk criteria. The substances comprise eleven pesticides, two industrial chemicals and three by products/contaminants. The Protocol bans the production and use of some products, as well as some others scheduled for elimination at a later stage. The Protocol includes provisions for dealing with the wastes of products that will be banned. Furthermore, the Parties revised obligations for DDT, heptachlor, hexachlorobenzene and PCBs as well as emission limit values (ELVs) for waste incineration. In addition, to facilitate the Protocol’s ratification by countries with economies in transition, the Parties introduced flexibilities for these countries regarding the time frames for the application of ELVs and best available technologies (BAT). 1.4. EU Regulations The EC POPs regulation is the implementing legislation in the EU Member States of the SC. It is also the implementing legislation for the 1998 POPs Protocol of the 1979 UNECE National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 8 CLRTAP. EC POPs Regulation (No 2019/1021) aims to protect human health and environment from POPs through the measurements under the following legislations:  Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) contains provisions specifying how substances should be assessed with regard to their POPs characteristics. Under REACH, the production and use of substances exhibiting POP characteristics can be prevented and new POPs candidates can be identified.  Regulation (EU) No 649/2012 concerning the export and import of dangerous chemicals (PIC Regulation).  Council Directive 96/59/EC on the disposal of polychlorinated biphenyls and polychlorinated terphenyls (PCB/PCT). This Directive aims to completely dispose of PCBs and equipment containing PCBs as soon as possible and equipment with PCB volumes of more than 5 litres before the end of 2010. It also sets requirements for the environmentally sound disposal of PCBs.  Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures, amending and repealing (CLP).  Directive 2010/75/EC on industrial emissions (integrated pollution prevention and control) (IED. The IED lays down control measures to reduce emissions of unintentionally produced POPs by covering the major industrial stationary sources of these POPs.  Directive 2000/76/EC on the incineration of waste (WID). The WID Directive covers all waste incineration facilities that are a very important source of POPs by-products. In particular it sets strict limits for emission rates of dioxins / furans in the air.  Directives or Regulations concerning the evaluation and management of the dangers/risks associated with chemical substances.  Further Directives – E.R.A. of new pharmaceuticals. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 9 1.5. Turkish National Implementation Plan of the SC Turkey has signed the Stockholm Convention on POPs on May 23 rd 2001 and it has been approved by the Turkish Grand National Assembly as 5871 numbered Law (14.04.2009, No.27200), then published on July 30 th 2009 as approved by the Council of Ministers (30.07.2009, No.27304). The Convention is officially effective since January 12 th 2010. As stated by the Article 7 of the Convention, Turkey prepared the first NIP between 2004 and 2006 funded by GEF and revised it in 2010, submitted to the Stockholm Secretariat in 2011 which included initial 12 POPs issues of concern like uses, import, export, production, distribution in country and source related inventory, current stockpiles and its disposal options assessment, contaminated sites, POPs chemicals related infrastructure, legal instruments, monitoring, research and development capacity, monitoring system establishment and use. The first plan was reviewed and updated, in accordance with the responsibilities to the Convention, by funding with GEF on capacity building between the years 2012-2013. Later, in the framework of an EU Project, it is revised in order to cover CLRTAP/POPs Protocol and EU POPs Regulation in 2013-2015. Under this project, in addition to NIP revision, LGA, draft by-law, RIA and SIA were prepared. The NIP Update is submitted to the Stockholm Secretariat in 2016 which included the inventory, current stockpiles, contaminated sites, legal instruments, monitoring, research and development capacity, and action plans related to initial and new POPs according to Annex A, B and C. 2. Country Profile 2.1. General Information Turkey or Republic of Turkey in official name is a country, located in both in Europe and Asia and its capital is Ankara. Country’s land is located in Anatolia peninsula and Thrace which is an extension of Balkan Peninsula. Country is surrounded from 3 sides by Mediterranean, Black Sea, Aegean Sea and Sea of Marmara which is between Black Sea and Aegean Sea. Neighboring countries are; Greece, Bulgaria, Georgia, Armenia, Azerbaijan, Iran, Iraq and Syria. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 10 Governmental and Executive Structure Turkey is a democratic, secular, centralist and constitutional republic. President of Republic is the president of the country and elected with the direct selections in five year periods. Turkey is governed by the President holding the executive power; Turkish Grand National Assembly holding the legislative prerogative and Courts holding the jurisdiction. Turkish Grand National Assembly consists of 600 parliamentarians and they are elected in 5 year-periods. Biggest administrative departments are provinces and there are 81 of them. A province consists of city centrum, counties and the villages appurtenant to the counties. Government assigns Governors who are in charge of administration and execution in the province. Turkey is separated to 7 Geographic Regions however; no administrative structure is represented by these regions. The additional country information is presented in the Annex II. 2.2. Legal and Institutional Framework Regarding Environmental Policies 2.2.1. Turkey’s Environmental Policy and Strategies The first constitution that mentions environment is the Turkey’s 1982 Constitution. The Constitution’s most important article regarding environment is Article 56. According to Article 56, “Living in a balanced and healthy environment is a prerogative. Improving the environmental status, protecting environmental health and preventing environmental pollution is the duty of both the government and citizens” (1982 Constitution, http://www.anayasa.gen.tr/1982ay.htm, 20.04.2020). Environment prerogative concept is first mentioned in Article 56 and is protected under the article. The general framework of protection of the environment and improvement of its status is established by the Environmental Law. Environmental Law (2872) issued on August 11 th 1983 based on the 1982 Constitution’s Article 56, aims to establish a legal framework on protecting the environment, preventing environment from pollution or deterioration, rehabilitation of the environment from any former pollution, improving the environmental status, using the natural resources and energy efficiently, reduction of the waste amount at the source generated as a result of an activity and recovery of the waste generated via using http://www.anayasa.gen.tr/1982ay.htm National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 11 environmentally sound technologies, regulating and taking measures to sustain the good status of the environment to reserve its integrity for the next generations. Law on Amendments on the Environmental Law (5491) was published in the Official Gazette (26167) on May 13 th 2006. The new 5491 numbered Law had many other regulation and definitions that were not addressed in the initial 2872 numbered Environmental Law. The Law focused on the key issues in protection of the environment and regulations compatible with the international agreements also makes an emphasis on adoption of a sustainable development policy. In Turkey, the first National Environmental Strategy, consistent with the development plans, the EU Integrated Environmental Harmonization Strategy (IEHS) for the years 2007-2023 has been prepared within the framework of harmonization obligations with EU. The IEHS contains detailed information on the technical and institutional infrastructure, compulsory environmental amendments and regulations that has to be addressed to implement and comply with EU environmental acquis which is a prerequisite for Turkey to join EU. To achieve this, IEHS initially stated the goals to achieve, strategy and activities planned on control of water, soil, air pollution originated from wastes and industries, protection of nature and environment which is a horizontal plane affected by any activity. In this framework, the total amount of investment (except chemical and noise) is estimated as 59 billion Euro in environment to fully comply with EU environmental standards. The 20% of the total investment is considered to be invested by the private sector and the rest is considered to be by the public sector. 2.2.2. Roles and responsibilities Authority concerning to environmental matters are divided between the central and local government. Ministry of Environment, Urbanization and Climate Change and Climate Change has the authority on chemicals management. Responsibilities of the MoEUCC are:  to coordinate policies and strategies regarding education, research, project design and action plans for prevention of environmental pollution, development of standards and benchmarks, determination of measurement, detection and quality criteria; National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 12  To determine the criteria for air pollution, noise and vibration related to waste and chemicals that have negative effects on the environment throughout the country.  To determine the economic tools and develop standards in order to carry out an effective environmental management, and to ensure compliance of waste and chemicals with the environment.  To determine and implement the procedures and principles regarding the prevention and control of pollutants with the purpose of protecting groundwater, surface water and soil, to develop emergency response plans, to determine the appropriate technologies in order to protect the environment and accordingly to take necessary precautions.  To determine the goals, policies and benchmarks for the management of waste and chemicals.  To determine policies and strategies and to develop legislation on the waste minimization at the source, classification, collection, transportation, temporary storage, recovery, disposal, reuse, treatment, conversion to energy and final storage of wastes.  To determine, apply and monitor the principles regarding the transportation of wastes and licenses for hazardous wastes in cooperation with the relevant institutions and organizations, to determine the current pollution status of the sites contaminated with waste and chemicals, to carry out studies related to the risks to the environment and human health and remediation of contaminated sites.  To determine the criteria for the import and export of fuel, waste, chemicals and other substances to be banned and restricted and to ensure the implementation of these criteria.  To prepare, execute and coordinate national environmental strategy and action plans.  To coordinate with other institutions and organizations in order to determine plans, policies and strategies for taking precautions related to global climate change and ozone depletion. Responsibilities of other institutions that have a role in the preparation of the NIP and POPs NIP are described in Table 2. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 13 Table 2: Responsibilities of institutions that have a role in the preparation of the NIP and POPs NIP Institution Responsibility Ministry of Environment, Urbanization and Climate Change Main account institution, the competent authority and the National Focal Point (NFP) of Turkey for Stockholm Convention. Drafting and preparing legislation on POPs, performing, monitoring and coordinating activities on POPs Ministry of Foreign Affairs authorization and submitting the ratification instruments to relevant bodies of the international treaties and conventions in different ways as required by international laws or practices to prepare original or copy of all documents Ministry of Agriculture and Forestry Affairs coordinating and controlling the national water resources management (deriving the quality standards for POPs in water and monitoring and controlling of pollution caused by POPs in water resources) and creating policies for protecting water resources for sustainable use of water and also controlling, regulating and monitoring the licensing, production, import, export, sales, use, storage and old stocks of plant protection products including POPs pesticides Ministry of Industry and Technology determining industrial strategies and aims by constituting industrial committees and monitoring the studies on these subjects, and controlling the production of articles and National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 14 goods made by industrial chemicals which are related to the Ministry’s scope of its authority Ministry of Trade ensuring top legislative harmonization between the product safety, technical regulations, technical obstacles, technical suitability assessment and monitoring of the applications and adapting the technical legislations related to the products working in coordination with relevant institutions to the foreign trade and also determining the regulatory principles of product safety, import and export of chemicals Ministry of Energy and Natural Resources supervising the chemical waste and the equipment used in distribution and production of electricity and taking relevant precautions on the subject Ministry of Health developing sectoral health policies, implementing national health strategies, investigating the effects of chemicals on human health after short and long term exposure Ministry of Family and Social Services monitoring of occupational health and safety issues, auditing, policy development and planning, developing health and safety units and certifying the practices and also determining the rules and principles of working with chemicals and the measures necessary for the prevention of industrial accidents National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 15 Ministry of Transport and Infrastructure controlling the transport of the chemicals Ministry of National Education conducting public awareness and education activities Presidency of the Republic of Turkey the final approval of the international conventions as well as Stockholm Convention on POPs Presidency of Strategy and Budget determination of development and public investment policies regarding chemicals and environment and its coordination during implementation 2.2.3. Agreements/Conventions Related with POPs Stockholm Convention on POPs Turkey has signed the Stockholm Convention on POPs on May 23rd 2001 and it has been approved by the Turkish Grand National Assembly as 5871 numbered Law (14.04.2009, No.27200), then published on July 30th 2009 as approved by the Council of Ministers (30.07.2009, No.27304). The Convention is officially effective since January 12th 2010. Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal Turkey has signed the Basel Convention on March 22 nd 1989 and it has been approved by the Turkish Grand National Assembly on June 22 nd 1994. The Convention is officially effective since September 20 th 1994. Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade Turkey has signed the Rotterdam Convention on September 11 th 1998 and the Convention is effective since 2004. Turkey became a party to the Convention on December 2017. Convention on Long-Range Transboundary Air Pollution (CLRTAP) CLRTAP is approved by the 2667 numbered Law on April 28 th 1982 and published on March 23 rd 1983 Official Gazette. Protocol on Long-term Financing of the Cooperative Programme National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 16 for Monitoring and Evaluation of the Long-range Transmission of Air Pollutants in Europe (EMEP) is approved on June 3 rd 1985 and published in the Official Gazette on July 23 rd 1985. The protocol is effective internationally since January 28 th 1988. Total emission of 4 parameters (SO2, NOx, NMVOC, NH3) should be reported to European Environment Agency (EEA), The United Nations Economic Commission for Europe (UNECE) Secretariat and EMEP. There are 8 protocols under CLRTAP:  Protocol to Abate Acidification, Eutrophication and Reduction of Ground-level Ozone,  Protocol on Persistent Organic Pollutants (POPs),  Protocol on Heavy Metals,  Protocol on Further Reduction of Sulphur Emissions,  Protocol concerning the Control of Emissions of Volatile Organic Compounds or their Transboundary Fluxes,  Protocol concerning the Control of Nitrogen Oxides or their Transboundary Fluxes,  Protocol on the Reduction of Sulphur Emissions or their Transboundary Fluxes,  Protocol on the Reduction of Sulphur Emissions or their Transboundary Fluxes by at least 30 per cent The United Nations Framework Convention on Climate Change (UNFCCC) Turkey has been aware of the environmental and socio-economic consequences of climate change, hence; it has taken the initiative to reduce the Greenhouse Gases (GHGs) and made international collaborations. At the 7 th Conference of Parties (COP) of UNFCCC, Turkey was listed as an Annex 1 country and the Parties invited Turkey to acknowledge the special conditions which is different from the rest of the Annex 1 countries. After this decision, Turkey has become a Party to UNFCCC on May 24 th 2004 and on August 26 th 2009 Turkey has become a Party to the Kyoto Protocol. Even though Turkey has no obligation to reduce the emissions within the scope of the Kyoto Protocol, it has addressed the issues like energy efficiency, renewable energy resource use encouragement, reduction of emissions originating from waste and transport sectors. Moreover, Turkey is still working eagerly on the dissemination of voluntary emission market and integration of mandatory emission market. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 17 Montreal Protocol on Ozone Depleting Substances (ODS) Turkey ratified and became a Party to the Vienna Convention for Protection of Ozone layer and Montreal Protocol on Ozone Depleting Substances (ODS) in 1991. MoEUCC is the focal point for the Protocol and fulfills the duties and responsibilities such as following the national and international studies on the subject. Moreover, the processes related to ODS in the country (from import to use) is monitored under the “Programme of ODS Tracking” since 2009. 2.2.4. Legal Framework on POPs As a Party to the SC, there are a number of regulations and legislations adopted and implemented on POPs in order to comply with the Convention’s liabilities. The By-Law on Persistent Organic Pollutants by MoEUCC entered into force on November 14 th 2018 (No. 30595). It sets principles for implementing and enforcing the provisions of Stockholm Convention, prohibiting the production, placing on the market and use of POPs, restricting and gradually eliminating POPs, reducing of POPs releases, managing the wastes containing POPs. Additionally, Draft By-Law on Export and Import of Some Hazardous Chemicals which is aimed to implement and enforce the provisions of Rotterdam Convention and set the principles of Prior Informed Procedure in international trade of chemicals including POPs is foreseen to be published and entered into force in 2022 by MoEUCC. The rest of the regulations and legislations related to obligations of the SC are presented in Annex III. 2.3. Inventory of POPs – status in Turkey 2.3.1. Chemicals listed under Annex A of the Conventions 2.3.1.1. Pesticides and HCB Licensing process for pesticides is carried out by Ministry of Agriculture and Forestry Affairs. Pesticides listed under Annex A of the Conventions are either licensed and banned (aldrin, chlordane, DDT, dieldrin, heptachlor, endrin, toxaphene, lindane, α-HCH, β-HCH, National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 18 endosulfan) or never been licensed and used in Turkey (mirex, chlordecone, pentachlorobenzene, HCB). Among the pesticides recently listed in the Stockholm Convention, dicofol has neither produced nor licensed in the country, hence it has no stock. However, pentachlorophenol and its salts and esters were imported in the country even if the amounts were very low (Table AIV/1). 2.3.1.2. Hexabromobiphenyl (HBB) and Polychlorinated biphenyls (PCBs) HBB has been banned for a long time ago in Turkey, like many other countries in the world, hence is not used. PCBs were never produced in Turkey but imported either within equipment or as in the oil form. The first inventory for PCBs was made in 2007 (NIP, 2010) and the inventory update was conducted in 2012-2013 (NIP, 2016). Almost 60% of PCB-containing materials were eliminated until 2016 (NIP, 2016). During implementation of the POPs Legacy Elimination and POPs Release Reduction Project (No.140288) funded by GEF and cooperated by MoEUCC, UNDP and UNIDO, 300 tonnes of PCB containing materials and equipment was eliminated, and 6094 transformers were analysed for PCBs. According to the results of this analysis, 42,6 tonnes of transformer oil having a PCB concentration greater than 50 ppm were decontaminated. 2.3.1.3. Polybrominated diphenyl ethers (PBDEs) Since the twentieth century, manufacturers began to replace traditional materials such as wood, metal, and wool with petroleum-derived products such as plastics and polyurethane foam. These new “treated” materials are either less flammable or slowed down the rate of fire growth. The latter is achieved by treating the materials by flame retardants, mainly brominated (BFRs). Polybrominated diphenylethers (PBDEs) are one from the mostly frequently used group of brominated chemicals used as flame retardants and hence widely used in items that are susceptible to catch or sustain fire such as plastic in electronic devices, polymers in automobile, certain synthetic textiles and polyurethane foam in certain applications. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 19 In May 2009, tetrabromodiphenyl ether, pentabromodiphenyl ether (components of commercial pentabromodiphenyl ether, c-pentaBDE) hexabromodiphenyl ether and heptabromodiphenyl ether (components of commercial octanbromodiphenyl ether, c octaBDE) were included in the Stockholm Convention which prohibits production, use, import and export. Later, in 2017 decabromodiphenylether (main component of commercial c-decaBDE) was also added to the Annex A of Stockholm Convention. Inventory of c-PentaBDEs and c-OctaBDEs c-OctaBDE has been used in EE (and hence also seen in WEE) and in plastics vehicle parts (steering wheels, dashboards, door panels, etc.). Only a portion of the cars produced between 1975 and 2005 worldwide have been treated with c-PentaBDE. It is estimated that about 35% of the approximately 100 000 tons c-PentaBDE production has been used in the transport sector (Alcock et al. 2003, UNEP, 2010a, 2010b). Thus, the transport sector is one of the large material flows of goods and ultimately becomes a large waste and recycling flow. Moreover, the end-of-life management of the transport sector is a highly relevant material flow for the recovery of materials and for managing pollutants (Vermeulen et al., 2011). The c-PentaBDE inventoried in this 2012-2019 period in transport sector is presented in Table AIV/2. The expected ratios, percentages of c-PentaBDE were all taken from guide of the Stockholm Convention on POPs regarding PBDE. Among the assumptions given in the guide, 160 g c-PentaBDE / car, and /truck; 1 kg c-PentaBDE per bus, and 0.5 kg / minibus are used, which was the same approach followed in the previous NIP update of Turkey. Then this c PentaBDE were distributed to by 32% to tetraBDE, 56% to pentaBDE, 9% to hexaBDE, and 0.5% to heptaBDE. The POP-PBDEs in vehicles currently in use was calculated through obtaining the number of vehicles on traffic in 2018, corresponding to the models produced before 2005, as in these vehicles a certain c-PentaBDE constituent is assumed. There were 4 different vehicle categories as car, truck, mini/midibus and autobus. For truck, mini/midibus and autobus, 0.05 regional constant was used to find c-PentaBDE as their import from United States was quite low. For automobile, judging from the import numbers, 10% of the cars were assumed to National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 20 come from US and they were separately calculated with a 0.5 regional constant, then summed up with the rest. Unlike previous NIP, in this report only the last year’s import numbers and predicted maximum amount of POP-PBDEs within them was calculated using TURKSTAT’s Foreign Trade Statistics (Special Trade System) [with 12 numbered HS codes of 870120900000, 870210191100, 870210191200, 870210191300, 870210991100, 870210991200, 870210991300, 870321901000, 870322901000, 870323901100, 870323901200, 870323901300, 870324901000, 870331901000, 870332901100, 870332901200, 870332901300, 870333901011, 870333901012]. The reasons are twofold, the first one is previous years’ imports were already included in the currently in use number. The second reason is that, although the number of vehicles produced in different years (a.k.a. vehicles model years) in currently in use vehicles is known, there is no such separation for imported vehicles. This makes it hard to account for PBDE imported if it is to be calculated through all previous years since only <2005 models should be considered. This approach already covers <2005 model imported vehicles for up to 2018 currently in use safely, and the additional 2019 import data comes from the import database. Nevertheless, imported vehicles for 2019 is very low in number, so even the maximum amount of possible PBDEs in it was calculated as no more than 1.344 kg. This decline in the number of imported vehicles can be seen in the following Figure 1. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 21 Figure 1: Second-hand vehicle imports of Turkey between years of 2000-2019 For the end-of-life vehicles and corresponding PBDEs, the data was taken from deregistered vehicles for every year from TURKSTAT database. Only the vehicles between 2012-2019 were considered since those for the years before 2012 were already included in the previous inventory. Even though there is no model year of deregistered vehicles, it was assumed that all of them comes from 1975-2004 production line as mostly these vehicles would be ELV in between 2012-2019 and it will make a conservative estimation of PBDEs. The estimated values of recycled PBDE and disposed PBDE via ELV were also calculated over total deregistered vehicles. In addition to the total PBDE in all these ELV; between 2012-2019, the data of ELV separated for recycle were evaluated. Since the total number of mini/midibuses and cars for recycled number of ELVs are available, their separation was estimated through their ratio in deregistered number of vehicles in the corresponding year. Subsequently, 160 g/vehicle for car and 500 g/vehicle for mini/midibuses were used for c PentaBDE estimation. After the estimation of recycled amount, the rest of the ELV total PBDE was attributed to disposed of PBDEs. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 22 Except currently in use vehicles PBDE content, all these values were lower compared to the previous NIPs inventoried PBDE. This is because the number of <2005 model vehicles in use also increased. The decline in the rest was expected since the more >2005 model year vehicles were used and then deregistered, the less c-PentaBDE will be in these vehicles. Another contribution to this decline is that most of the imported vehicles came from non-US and European Countries, where c-PentaBDE use was already low and prohibited after 2005. Additionally, the ratio of recycled/disposed is quite higher than that of the previous NIP calculation. This in turn comes from the fact that more effort was put into the recovery and recycle of ELVs than before. However, there is one additional point of recycled amount of PBDE that, before the recycle, ELV’s might be depolluted from these possibly PBDE containing parts, which effectively reduce the recycled PBDE. For the estimation of the inventory of electrical and electronic equipment containing PBDEs, Tier 1 approach was chosen. Countries that have not yet established an EEE/WEEE inventory could initiate the inventory by estimating the minimum POP-PBDEs amount in CRT in the country. This requires estimating the country's penetration rate (number of appliances per capita) in analogy to countries with similar economic development and consumer behavior, and then extrapolating from the per capita data to the target country. Once the per capita data have been estimated, the POP-PBDEs content in CRT casings (TVs and computer monitors) can be calculated taking into consideration the following additional data:  Population of the respective country;  Weight of the CRTs: 25 kg per device (estimated average weight of a CRT monitor, either TV or PC monitor);  Polymer content of CRT casings: 30% (estimated average);  A range of c-OctaBDE content, 0.87-2.54 kg/ton, for these polymers used in CRT casings (estimated average). A range of c-OctaBDE in CRT devices can be calculated as follows: MPBDE(i) = [Number of CRTs/capita Region ] x population x 25 kg x 0.3 x [0.00087 to 0.00254] Where: MPBDE(i) is the amount of POP-PBDEs (i) in [kg] (in Polymer (k) of electrical and electronic equipment (EEE) (j)). The POP-PBDEs (heptaBDE and hexaBDE) in the c-OctaBDE can be calculated National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 23 according to the homologue content (of c-OctaBDE, the heptaBDE homologue is estimated as 43% and the hexaBDE as 11%). Number of CRT/ person can be taken from Asian average value of 0.17 (Gregory, 2009). The population of Turkey in 2019 was calculated as 83,154,997 people. As a result, the estimated c-OctaBDE content from CRT monitors in Turkey ranges between 92,200 and 269,300 kgs (Table AIV/3). c-OctaBDE inventoried in CRT monitors in Turkey between years 2013 and 2020 were also estimated and presented in Table AIV/4. Compared to the previous NIP, the POP-PBDEs imported via CRT monitors is extremely low, which was expected since these values reflect the import in 2019-2020 only, instead of what was up to 2013 as in previous case. The previous years’ import values were already included in the POP-PBDEs in stocks (Table AIV/4). CRT monitors are currently not preferred in the presence of plasma and LCD monitors, so understandably their import values declined, as can be seen in Figure 2. Figure 2: CRT monitor imports to Turkey between 2007-2020 years To generate the import values, CRT related HS codes of 852841, 852842, and 852849 were used. Unlike in the previous NIP, it is not assumed that imported computers include CRT monitors, as it would not reflect the reality of the current time. To sum up, imported PBDE via CRT is very negligible for the period of 2013-2020. 0 20000 40000 60000 80000 100000 120000 140000 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 N u m b e r o f im p o rt e d C R T m o n it o rs Imports of CRT monitors to Turkey by years National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 24 The PBDE-POPs in stocks were estimated by using the most up-to-date population, and a regional constant of 0.17 and 0.00087 tons of c-Octa-BDE application to 1 ton of polymers, ~92 tons of c-OctaBDE were expected. This is a highly conservative number as probably the regional constant of 0.17 for Asian region is not the current ratio of CRT monitors / capita. This number might be updated in the final report in case of a newer regional or relevant constant. With this calculation, it is lower than the amount found in the previous NIP as 168 tons, but as explained, low margin of PBDE to polymer application, i.e. 0.00087 tones, was used in the current case. In case of higher margin use, the amount would be 269 tones. This higher number was not used at this time since CRT is not the preferred monitor for either TVs or computers anymore. The CRT monitors entering the waste stream, and the corresponding PBDE in waste were calculated by dividing this stockpile by 8, as suggested by the Guide for PBDE inventory with the assumption of 8 years of life. It was expected that this number would be lower than that of previous NIP since there will be less and less amount of PBDE contained in CRT and correspondingly there will be less waste. The last variable, POP-PBDEs recycled via polymers obtained from waste CRT was calculated. The European Waste Catalogue numbers of 20-01-35 for household and 16-02-13 for industrial scale monitors were used to retrieve recycled polymers. The weakness in this calculation is that these codes also include LCD and plasma monitors, so the resulting number for PBDE estimation will be an overestimate. To solve this, imports of monitors LCD and plasma with HS codes of 852851, 852852, and 852859 were obtained and yearly ratio of imports of CRT to total CRT/LCD/plasma imports were obtained. Then to estimate the distribution of CRTs in this aggregate 20-01-35 and 16-02-13 wastes, 8-year-before’s import ratio of CRT to all monitors were multiplied with unit recycled waste in that code. Since 2004, ABS imported from European Countries was assumed to have no c-OctaBDE, so from then on the estimations were done for the countries filed exemption from banning c OctaBDE and c-PentaBDE use in their production. These countries are Brazil, Cambodia (for c-OctaBDE), Japan, Republic of Korea, and Turkey. Aside from EU Countries, it is unexpected to have ABS containing c-OctaBDE from China or India, either (Sharkey, et al. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 25 2020). Even if comparatively older, Peng et al. (2007) stated the extensive use of c-OctaBDE in Taiwan, so it was also included in the calculations, owing to the considerable volume of ABS import to Turkey from Taiwan. Before 2004, all imported ABS was assumed to contain c-OctaBDE. Figure 3 shows an example of ABS imports of Turkey from other countries for 2019, to illustrate major exporters. Figure 3: ABS import to Turkey from other countries, and their percentage compared to the total ABS import to Turkey for 2019 (TURKSTAT data). According to the Draft risk management evaluation of octaBDE (Persistent Organic Pollutants Review Committee, 2008), the c-OctaBDE weight loading on ABS polymers was stated as in between 12 – 18%. Here the same ratio for the estimation of the minimum/maximum range of c-OctaBDE entering Turkey via this route was used. Unfortunately, ratio of c-OctaBDE containing ABS to all ABS is unknown, but literature studies on analysis of certain EEE and their corresponding polymer and flame retardant content were used (Wäger et al., 2010; Wolf, 2001). There are three categories related to the single ABS: TV-housings, Housings of IT appliances and Monitors & TV sets, in which 60%, 10% and 25% of the appliances have octaBDE, respectively. As a result, 95 over 300 (100 for each category) corresponded to OctaBDE in ABS. Hence, roughly 1/3 of the ABS imported was assumed to have OctaBDE, USA 0% Azerbaijan 0% Algeria 0% China 0% Ethiopia 0% European Countries 18% Morocco 0% South Africa Republic 0% Republic of Korea 63% Georgia 0% India 0% Hong Kong 0% Iran 2% Israel 0% Japan 0% Kazakhstan 0% Kosovo 0% Northern Cyprus 0% Libya 0% Malaysia 1% Mali 0% Egypt 0% Uzbekistan 0% Russian Federation 0% Saudi Arabia 8% Thailand 0% Taiwan 7% Tunus 0% Turkmenistan 0% Ukrain 0% Other 0% 2019 ABS EXPORTER COUNTRıES SHARE ıN TOTAL ABS ıMPORT OF TURKEY National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 26 albeit the number is probably much lower as there were replacements of OctaBDE in ABS production. Consequently, 1/3 of ABS imports to Turkey from all countries between years 2000 and 2004 were considered to contain c-OctaBDE, while from 2005 on, imports from only 5 countries, i.e. Brazil, Cambodia, Japan, Republic of Korea, and Taiwan, were taken into account (Table AIV/6). The maximum octaBDE entry to Turkey via ABS imports between 2000 and 2020 ranged 41,643.2 – 62,464.8 tons. The direct import of tetra-, penta-, hexa-, hepta, and octaBDE was estimated based on the HS code of 382488 given in the United Nations Comtrade database (the import/export of the commodity of “Chemical products, mixtures and preparations; containing goods specified in Subheading Note 3 to this Chapter; containing tetra-, penta-, hexa-, hepta- or octabromodiphenyl ethers”). This HS code was investigated from TURKSTAT foreign trade statistics database for import of intermediate goods and specific trade system (Tables AIV/7&8). From these two categories of direct PBDE imports, a net of 181,713 kg of PBDEs were imported in between 2017 and 2019. Their use is still unknown, yet the amount is deemed significant to be reported. A summary of c-pentaBDE and c-octaBDE inventories in Turkey is demonstrated in Table 3. Obviously, the greatest challenge is the uncertainty in the amount of ABS produced in non European countries, not only undermining the effort of generating an accurate inventory of the c-OctaBDE amount in a specific country, but also preventing the implementation of actions to reduce it. Nonetheless, c-octaBDE entry via ABS import is still the most crucial part of the entire c-OctaBDE management. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 27 Table 3: Summary of the inventoried c-PentaBDE and c-OctaBDE in Turkey c-PentaBDE (kg) c-OctaBDE (kg) Motorvehicles in use 92,919 In CRT monitors 92,200 ELV in 2012-2019 9,183 In CRT entering waste 11,370 Recycled from ELV 4,677.6 Recycled from CRT 17,059 Disposed from ELV 4,505.7 Entered via ABS import 41,643,200 – 62,464,800 Total 111,285 Total 41,763,829 – 62,585,429 Inventory of decaBDE Decabromodiphenyl ether is an aromatic organobromine chemical that have been used since the 1970s as additive flame retardants in a wide range of consumer products. In May 2017, by decision SC-8/10, the Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants (POPs) amended Annex A to the Convention to list decabromodiphenyl ether (decaBDE; BDE-209) present in commercial decabromodiphenyl ether (c-decaBDE). The plastics industry is by far the major user of FR and the largest quantities of FR are supplied to raw-material manufacturers. The amount of c-decaBDE used in plastics and textiles globally varies but up to 90% of c-decaBDE ends up in plastic and electronics while the remaining ends up in coated textiles, upholstered furniture, and mattresses. In Turkey, there are researches in literature that found DecaBDE (or BDE-209) in some of their samples with considerable concentrations. Çetin & Odabaşı (2011) analyzed indoor and outdoor window organic films from Izmir, Turkey and found that in the determined samples technical penta-BDE and deca-BDE mixtures were prevailing, and emissions from steel plants in nearby were attributed as the source. In their another study, Çetin & Odabaşı (2007) found that both air-water exchange and dry deposition over İzmir Guzelyali Port in Turkey were decisive on PBDE levels, and BDE-209 was present in the highest concentrations. Uçar et al. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 28 (2011) analyzed butterfat from 18 different parts of Turkey in terms of PCDD/Fs, PCBs, and PBDEs, and albeit not in very high levels, significant BDE-209 presence was observed in some samples. Demirtepe & İmamoğlu (2019) reported worldwide highest BDE-209 concentration in industrial wastewater sludge, which comes from mainly automotive based Organized Industrial District. Beside these, DecaBDE use and their distribution has not been inventoried in Turkey previously. List of Undesirable Substances (LOUS) survey of EPA (Lassen et al. 2014), stated that in USA, the use of DecaBDE was partitioned into 5 sectors as 26% to automotive & transportation, 26% to building & construction, 26% to textile, 13% to EE and 9% to others, and that in EU EE is expected to be lower share due to the early ban in 2008, and that almost 50% use is allocated to textile in general. In Japan, the situation is a bit different. Sakai et al. (2006) reported that the DecaBDE flow from textile is less than 200 tons/year compared to the 1200 tons/year flow of TVs, and 90% of waste textile is either landfilled or incinerated. From automobile shredding residues and corresponding vehicles airbags, 100 tons/year DecaBDE flow was estimated. Another important point comes from the study of Strakova et al. (2018), in which 92% of the analyzed toys and consumer products, via recycled plastics, contained DecaBDE between 1 to 3310 mg/kg concentrations. Wäger reported that (2010) average concentration of DecaBDE in small WEE was around 510 ppm, and according to Schlummer (2007) in CRT housing this concentration might go higher than 21,500 ppm. End-of-life vehicles (ELV) also contain DecaBDE, among other PBDE congeners. In Ireland’s 7 th COP’s National Implementation Plan for Stockholm Convention, DecaBDE was found in concentrations of 100 to 200 mg/kg in the following components of ELV: dashboard, headrest, seats, door panels and bumpers. These non-metallic parts are generally referred as automotive shredder residue (ASR), as well. It comprises 15-25% weight of the ELV (Vermeulen et al. 2011). By assuming a coefficient of 0.625 g decaBDE content per kg of ASR component in recycled ELVs (Morf et al. 2003), 5.8 and 4.4 tons of decaBDE content was estimated for Turkey for 2015 and 2016, respectively, while for the following years waste amount was zero (Table AIV/9). It should be mentioned that the depolluted fraction of National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 29 recycled ELV (160106 waste code) in Turkey is nearly two orders of magnitude higher, yet where these depolluted parts are disposed is unclear from the data, and even if they were all carrying 0.625 g/kg ASR DecaBDE, the total number would still be on the order of a few tons. The next significant decaBDE source is WEEE. WEEE related by-law of Turkey does not yet prohibit the untreated recovery or recycle of the corresponding wastes; and thus, it is relevant to inventory the WEEE components flow by using CRT, plasma and LCD monitor imports and estimated DecaBDE (Table AIV/10). The available 4 year-data indicated that 875.4 tons of DecaBDE is estimated to re-enter to the consumer products via recycling. The waste stream’s DecaBDE content from 2015 to 2018 was estimated in TableAIV/11, including small household appliances, IT and telecommunication equipment, and consumer equipment all containing POPs under the banner of 20-01-35* waste code. From this category of WEEE, it is expected that around 27.9 tons of DecaBDE has reentered the consumer products, and relatively negligible amount was disposed between 2015-2018 period. As the same code also corresponds to the CRT, LCD, and plasma monitors. In the calculation, it was assumed that 20-01-35* waste code category in Turkey’s case is completely composed of CRT/LCD/plasma TV wastes and all contain DecaBDE, and in addition to the 122 tons coming from ELV recycle and 875.4 tons from CRT/LCD/plasma, total of 997.4 tons of DecaBDE was estimated to enter from waste recycle to the products. There is a predicted use of DecaBDE in building & construction materials as well. In TURKSTAT’s national production statistics, a relevant commodity is named as following: “Fire-proofing, water-proofing and similar protective preparations used in the building industry” with a product code of 20.59.59.67.00. Currently there are 81 recorded companies producing this good in Turkey and total yearly output is given in TableAIV/12. The recorded sales values are comprised of both national and international sales, and thus, it is difficult to understand what percentage of it remained in the country. However, the number of the total produced amount, 1,313,200,543 kg can still be used. Among the building construction sector flame-retarding materials, PE plastic sheeting and PVC plastic sheeting were already considered elsewhere in the statistics data. PUR foam in insulation, fillers, XPS, PE insulating National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 30 foam, PP plastic sheeting were not distinctively classified under another code, so it is assumed that especially their consideration for the building & construction sector were included under the 20.59.59.67.00 code. There are different weight percentages for different types ranging from 2% to 22%. However, for this instance it is not safe to assume that all content is DecaBDE used, not for the fact that there are other flame retardants, but also water-proof and other protective preparations were also included in the definitions. Thus, the smallest percentage 2% by weight (Morf et al. 2003) was taken, and it results in 26,264,010 kg DecaBDE, or 26,264 tons of DecaBDE. The last sector in which significant DecaBDE use can be expected is textile industry, especially the upholstery part. The product data in textile is extremely differentiated and numerous. There are specific categories for velour pile fabrics (a similar commodity of 13.20.41 as woven pile fabrics). According to the draft guide for DecaBDE inventory preparation, approximate DecaBDE addition is 0.35 fraction of the total fabric, and that is same for cotton as well. The DecaBDE content predictions were based on the corresponding m 2 /year productions, assuming densities for velour pile fabric as 75 g/m 2 and cotton as 35 g/m 2 . Even though not all the fabrics were included, textile is still predicted as the most important DecaBDE containing sector with its products. From 2005 to 2018, 52,203.3 tons of DecaBDE was estimated to be in the market through its products (Table AIV/13). In conclusion, 997 tons of DecaBDE is estimated to be in the waste stream and then recycled to the products, and 78,467 tons are expected to be in the products directly, which makes 78,467 tons. Industry survey results To examine the current use of flame retardants in different sectors in Turkey and check whether they used any of the persistent organic pollutants, surveys were sent to the a few thousands of selected companies with the product codes given in Table AIV/14 in their identification. In addition to these products, four sectors of 13.30 (finishing the textile products), 20.12 (dye materials and pigments), 20.59 (other unclassified chemical products) and 20.60 (artificial or synthetic fiber) were also included in the survey. Throughout the survey, none of the industry reported a flame retardant among Annexes of the Stockholm National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 31 Convention. What they reported is illustrated as a cumulative amount in Table AIV/15. From these findings, we can conclude that the industry in Turkey successfully moved to the alternatives of POPs while selecting flame retardants. 2.3.1.4. Hexabromocyclododecane (HBCD) 1,2,5,6,9,10-Hexabromocylcododecane (HBCD) is defined as a novel flame retardant and it has been increasingly used as a substitute for other brominated flame retardants such as polybrominated diphenyl ethers (PBDEs). The world production has increased from 16 000 tons in 2000 to 23 000 tons in 2008, and the most of this increase has occurred in China. Approx. 80% of HBCD produced is estimated to be used as a flame retardant in expanded polystyrene (EPS) and extruded polystyrene (XPS) insulation products for buildings and construction (EU, 2008). Transport of compounded polystyrene (PS) with HBCD (granules, masterbatch or beads) over long distances cannot be excluded, but information on this is totally lacking. EPS is available with or without HBCD and if HBCD is used, it constitutes approx. 0.5% (0.5-0.7% HBCD w/w) of the final product by weight (EUMEPS, 2002). The main application of HBCD is in the production of extruded and expanded polystyrene sheets used for insulation purposes in building & construction sector. Among the other uses, upholstered furniture, automotive internal textiles, automobile cushions and insulator blocks in trucks/vans, packaging materials and EEE. HBCD was listed under Annex A chemicals of the Stockholm Convention with an exemption that it could still be used until November 28 th , 2019 as alone or in mixture in the production of EPS. Considering the use areas of HBCD, there are 4 expanded and 7 extruded polystyrene producers in building and construction sector in Turkey. Globally speaking, Turkey’s EPS industry is the largest around Middle East and Central Asia region, and the third in Europe. The EPS industry in Turkey, represented by completely local pre-blended PS producers, in average made an annual consumption of 974,590 kg of HBCD before the national precautions regarding this chemical entered into force. According to the data provided by EPSDER (an industrial association), the total annual HBCD consumption was determined as 1,214,167 kg. Total PS production, import and HBCD consumption data were provided in Tables AIV/16&17. The By-law on Persistent Organic Pollutants, which was published and entered National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 32 into force in 2018, has banned the use of HBCD and as of 2020, the domestic use of the chemical has been ended. Approximately 23 tons of HBCD stock in the country was disposed of within the scope of the project carried out in cooperation with UNIDO and UNDP with the support of GEF. XPS industry is differentiated from EPS by their direct use of HBCD at the final process steps. All production requires the use of flame retardants and this has been done via HBCD based ones up to the present. Additionally, the sector is mostly based on local market. As it is a low-density high-volume commodity, its importation and exportation are comparably low owing to the obstacles in its transportation. Annual HBCD based flame retardant consumption by XPS producers in Turkey was 704.7 tons on average for 2016-2018 (Table AIV/18). 2.3.1.5. Other and newly listed POPs Information concerning to newly listed POPs is relatively scarce or not available. For hexachlorobutadiene, the information is not available through TURKSTAT’s foreign trade information system. Short chain chlorinated paraffins (SCCP) Chlorinated paraffins are industrial mixtures with a chlorine content ranging from 30 to 70% (Gao et al., 2012). SCCPs are primarily used in metalworking applications and in polyvinyl chloride (PVC) processing. SCCPs are also used as plasticizers and flame retardants in a variety of applications, including in paints, adhesives and sealants, leather fat liquors, plastics, rubber, textiles and polymeric materials. SCCP mixtures are named according to the chain length, and have varying carbon chain length and degree of chlorination. The SCCP inventory of Turkey was estimated through TURKSTAT Foreign Trade Information System according to the HS codes, representing the other paints and varnishes (including enamels and lacquers) based on synthetic polymers or chemically modified natural polymers that melt or disperse in a non-aqueous environment, other solvents based on acrylic, other solutions based on vinyl polymer, synthetic paraffin and other plasticizers for rubber and plastics since these are assumed to include SCCP (Table AIV/19). Total amount demonstrates some amount of SCCP residue in the country. However, there are no specific National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 33 data on this chemical, since it is newly introduced in the national legislation, hence there is a high possibility of overestimation in the amounts presented here. More detailed inventory study for SCCP is required. Polychlorinated naphthalenes (PCN) PCNs were used as transformer and capacitor dielectric fluids, insulating coatings in electrical wires, wood preservatives, rubber and plastic additives and in lubricants. Commercial PCN mixtures contain up to 75 congeners with varying degree of chlorination. The PCN inventory of Turkey was estimated through TURKSTAT Foreign Trade Information System according to the HS codes for the pure chemical mixture, and their import constitute 14 kg of total PCN for the years 2017, 2018 and 2019 (Table AIV/20). Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds PFOA, its salts and PFOA-related compounds are used in the production of fluoroelastomers and fluoropolymers, non–stick kitchen ware, food processing equipment, as surfactants and surface treatment agents in textiles, paper and paints, firefighting foams. The inventory for PFOA, its salts and PFOA-related compounds was analyzed within the frame of the HS Codes. (Table AIV/21). In the scope of the HS codes generally, other perhalogenated derivatives, finishing preparations of a type used in textile, paper, leather and similar industries, providing fixing or accelerating the dyeing process, lubricating preparations, paint, ink, adhesive and varnish derivatives were examined. As PFOA is newly added to both the Convention and to the Annex of National By-law, the data availability is limited. Sectoral analysis and inventory studies will be carried out in further stages. 2.3.2. Chemicals listed under Annex B of the Conventions 2.3.2.1. DDT DDT use in Turkey was restricted in 1978, and banned completely in 1985. The last stockpile was disposed as already explained in the previous NIP. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 34 2.3.2.2. Perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride PFOS is an anthropogenic chemical that is produced synthetically from PFOSF and from its salts. If a substance includes one or more PFOS groups (C8F17SO2), it becomes a PFOS related substance. They are mainly used in industrial processes and in fire-fighting foams, textiles, paper, leather, wax, polishes, paints, varnishes, metal surfaces, and carpets. There are also some uses in semiconductor industry and hydraulic fluids in aviation sector. Production and use of perfluorooctane sulfonic acid (PFOS), its salts and perfluorooctane sulfonyl fluoride (PFOSF) were added to the Annex B of the Stockholm Convention because of its high surface activeness and meeting the POPs criteria. It is eliminated by all Parties except for the use and production for some purposes and specific exemptions are applied in accordance with Part III of Annex B to the Convention. In Turkey, besides the Convention, PFOS is restricted in the Framework of the By-law on Persistent Organic Pollutants. PFOS is not produced in the country as a raw chemical, instead, it is imported. Considering the conjugates, it is assumed that PFOS enters to the country through the chemicals which are considered within the PIC framework. The estimated amounts of import&export of PFOS was analyzed in Table AIV/22. There is a significant decrease in total net amount of import of PFOS between 2017-2019. The HS codes for the articles that may contain PFOS is also determined and the import & export amounts of the articles which potentially contain PFOS is gathered from the TURKSTAT database (Table AIV/23). These articles include hydraulic oils, insecticides, fire extinguishing foam and devices. In general, it was observed that the amount of PFOS has decreased within the scope of pesticides and fire extinguishers which are main source of PFOS. However, a detailed inventory analysis should be done to formulate conclusive actions of controlling products and production processes with articles imported to country. There are six priority sectors examined for amount of PFOS in the country; • Metal Plating • Textile • Apparel National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 35 • Synthetic Carpet • Paper-Cardboard • Aviation Hydraulic Fluids Sectoral reports reviewed for production, import and export amounts for priority sectors are provided in Table AIV/24&25. The amounts were assumed considering previous years’ values. Approximately 50% of the total three-year imports in the textile industry came from European countries. Considering EU regulations, it is assumed that half of the imports unlikely have PFOS. The countries where PFOS may come from are estimated as Asia, Middle East and African Countries, which accounts for about thirty percent of all exports. According to IHKIB reports approximately 70% apparel is exported to EU. Under REACH Regulation, EU pays attention to the PFOS content in the imported apparels. This shows that the apparel industry in Turkey have manufacturing capacity without using PFOS. Considering the priority sectors, it is obvious that the total amount of PFOS remaining in the country has decreased over years. There are no detected stockpiles of PFOS. However, contaminated sites will be further analyzed. 2.3.3. Chemicals listed under Annex C of the Conventions (Unintentionally produced POPs) One of the major goals of the Stockholm Convention on POPs is the continuing minimization and, where feasible, ultimate elimination of unintentionally produced POPs. Parties are required to identify, characterize, quantify and prioritize sources of releases of unintentionally produced POPs, and develop strategies with concrete measures, timelines and goals to minimize or eliminate these releases. To this end, Parties must develop action plans as part of their NIP to identify, characterize and address the releases of unintentional POPs listed in Annex C; namely,  Polychlorinated dibenzopdioxins (PCDDs),  Polychlorinated dibenzofurans (PCDFs),  Polychlorinated biphenyls (PCBs), National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 36  Hexachlorobenzene (HCB),  Pentachlorobenzene (PeCB),  Hexachlorobutadiene (HCBD) and  Polychlorinated naphthalenes (PCNs). Action plans to be developed according to Article 5 of the Convention shall include evaluations of current and projected releases that are derived through the development and maintenance of source inventories and release estimates, taking into consideration the source categories listed in Annex C (UNEP, 2013). To achieve the goal of the Convention, Parties are required to implement or promote best available techniques (BAT) and best environmental practices (BEP), as described in the “Guidelines on Best Available Techniques and Provisional Guidance on Best Environmental Practices relevant to Article 5 and Annex C of the Stockholm Convention on Persistent Organic Pollutants”. 2.3.3.1. PCDDs/Fs Inventory Turkish uPOPs inventory was conducted for year 2019 based on the source groups and the results are summarized in Table AIV/26. Comparison of two inventories indicates that there is an estimated decrease of 35% in total uPOPs amount (1306 to 846 g TEQ/a) from 2014 to 2019. Changes of the uPOPs with respect to type of the releases, and to source categories are also given in Figures 4 and 5, respectively. The results showed that total uPOPs releases are estimated as 50% in the residues, 20% in the atmospheric emissions, 11% in the wastewater discharges and products and 8% in the land. When compared to previous inventory, while total releases decreased from 63% to 50% and from 24% to 20% for the residues and air, respectively; a significant increase (from 1% to 11%) is recorded for wastewater discharges which is attributed to the change in the amount of hazardous waste disposed in the landfills. The amount of hazardous waste stated in the inventory of 2010 was estimated as 580,847 t/a due to lack of data in that year, however, it seems that this is an underestimation as the National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 37 amount is determined as 1,675,047 t/a for the current inventory (TURKSAT, 2018) which leads to such an increase in the release of wastewater discharges. The significant decreases in the air emissions from 309.2 to 166.3 g TEQ/a (about 46%) and in residues from 816.9 to 425.1 g TEQ/a (about 48%) explains the difference between two inventories to a large extent (Figure 4). Figure 4: Change of the uPOPs in Turkey from 2010 to 2019 with respect to types of releases An assessment of the changes in the uPOPs releases for the individual source categories in the inventories of 2014 and 2019 indicates that the significant decrease in total uPOPs releases (from 723.8 to 234.6 g TEQ/a, 58% decrease) comes mainly from ferrous and non-ferrous metal production processes (Figure 5). This result supports the fact that necessary investments were introduced and proper air pollution abatement systems have been installed in the leading companies of the sector. In this sense, POPs Legacy Elimination and POPs Release Reduction Project had a great contribution to the PCDD/F reductions especially at the iron and steel production companies. During preparation phase of this project, the sector representatives were informed on the possible effects of the PCDD/F emissions and; acceptable and effective reduction technologies/techniques were recommended. In the light of all these rising awareness activities, the leading companies became stakeholder in the project and started their investment activities. During the implementation phase, BAT/BEP studies were performed, National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 38 site specific reports were developed for each company and investments were supported which clearly made contribution to the reduction. For instance, 150 mg TEQ/yr of PCDD/F reduction was recorded in one company with upgrade of electrostatic precipitators. In another company, modification of raw material to decrease the Cl content resulted in reductions of 6.09 g TEQ/yr. In addition, successful implementation of By-law on the Control of Industrial Air Pollution and effective auditing has led to significant reduction in PCDD/F emissions. Figure 5: Change of the uPOPs releases in Turkey from 2010 to 2019 with respect to source categories In addition to ferrous and nonferrous metal production, reduction was also observed in the production of mineral products proving that good dust abatement efforts made in the main sectors although increases in the production of these materials were recorded. On the other hand, 31% of increase (from 200.9 to 290.2 g TEQ/a) in the releases originated from disposal category is mainly due to the increase in the amount of hazardous waste disposed in the landfills as explained above. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 39 2.3.3.2. Unintentionally produced PCBs As a requirement of the By-law on the Control of Industrial Air Pollution, the representatives of industrial plants are responsible for reporting PCB levels in their emissions and to keep the values below 0.1 ng/Nm 3 in order to have license to continue on their productions. Therefore, available data supports the fact that the unintentionally produced PCBs levels are low in the atmosphere. In addition, the available data has been gathered from the literature studies since 2015 on emission sources in different environmental compartments. For example, Urganlı et al. (2016) determined ambient air PCB concentrations through active air sampling in Izmir, the third largest metropolis in Turkey and the annual mean concentration of 32 polychlorinated biphenyls (Σ32PCBs) was measured as 348 ± 334 pg/m 3 . The results also revealed that the estimated population risk associated with dermal contact and inhalation routes to Σ32PCBs did not exceed the acceptable level of 1 × 10 −6 . The study of Sarı et al. (2020), on the other hand, reported the concentrations of a total of 40 PCBs congeners in the outdoor air of three houses during summer and autumn in 2017 in Bursa, a city having eighteen of organized industrial zones. The average Σ40PCBs outdoor concentrations determined as 303 ± 183 pg/m 3 and 41 ± 23 pg/m 3 for summer and autumn, respectively and the potential source was defined as landfill located nearby. In the studies conducted in other areas of Turkey, the determined concentration of PCBs in outdoor sites were reported between 349 and 94,363 pg/m 3 in Izmir (Aydin et al., 2014) and 4152 pg/m 3 in Kocaeli (Cetin et al., 2017) where the sampling points were close to industrial sites. PCB levels were also monitored in water and sediment samples collected from 12 stations located in Ankara River for 12 months and the results showed presence of PCB101 residues in sediment, as no PCB was detected in water samples (Sevin et al. 2018). 2.3.3.3. Other unintentionally produced POPs There is no available official emission inventory of hexachlorobenzene, pentachlorobenzene, hexachlorobutadiene and polychlorinated naphthalenes in Turkey. On the other hand, PAH levels have been measured in the industrial plants as a requirement of the By-law on the National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 40 Control of Industrial Air Pollution, the values have been reported below 5 mg/Nm 3 , 1 mg/Nm 3 and 0.1 mg/Nm 3 for the flow rates of 25 g/hr, 5 g/hr and 0.5 g/hr, respectively, as stated in the By-law. Therefore, available data supports the fact that the unintentionally produced PAHs levels are lower than limits and are under control. Several literature studies provide data on unintentional production of PCNs in Turkey. For example, soil samples from Hatay-İskenderun where iron-steel processing industry dominate showed average ∑32PCNs concentration of 0.28±0.28 µg/kg dry weight (Odabaşı et al., 2010). Another study from the same region revealed ∑32PCNs concentrations of 0.36±0.40 µg/kg dry weight in soil, 1.5±0.86 µg/kg dry weight in 2-year needle from pine trees, and 113±56 pg/m 3 in air samples (Odabaşı et al., 2016), while the same type of samples from industrial sites in Aliağa-İzmir had ∑32PCNs concentrations of 1.11±1.14 µg/kg, 1.88±1.85 µg/kg, and 107±69 pg/m 3 respectively (Odabaşı et al., 2015). The industries involved in Aliağa region are iron steel plants, petrochemical plant, ship-breaking and power plants. Direct stack-gas measurements from steel plants in Aliağa-İzmir demonstrated ∑32PCNs concentrations between 30 and 402 ng/Nm 3 without including the plant with scrap preheating, indicating iron-steel plants to be the major sources for PCNs (Odabaşı et al., 2017). On the other hand, atmospheric concentrations of ∑32PCNs from suburban and urban sites in İzmir ranged between 3.7 to 229 pg/m 3 (Odabaşı et al., 2012). Lastly, soil PCN concentrations from Kocaeli, another region with heavy industrial activities, ranged between 0.04 to 7.07 µg/kg dry weight (Çetin, 2016). All these studies suggest significant unintentional production of PCNs in Turkey and emphasizes the need for further investigation. 2.3.4. Stockpiles, Wastes and Contaminated Sites In order for Turkey to take necessary measures on POPs, the location of contaminated sites, the condition of POPs stockpiles and the amount of POPs used must be systematically determined, with the help of accurate POPs inventory and established administrative and technical infrastructure. In this context, The By-law on Control of Soil Pollution and Sites Contaminated by Point Sources is implemented for determination of contaminated or possibly contaminated sites and recording these sites on Contaminated Sites Information System. However, this system should be updated to cover POPs contaminated sites. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 41 Most of the old POPs stockpiles have been identified and approximately 3000 tons of HCH (lindane) stockpile in Kocaeli have been eliminated in 2022 in the scope of GEF project conducted in collaboration with UNIDO/UNDP. As long as pesticides were banned and restricted in Turkey, necessary measures were taken and use of pesticides like aldrin, dieldrin, heptachlor, DDT, chlordane, toxaphene have been restricted since 1980s. Some exceptional uses of aldrin, heptachlor and DDT were once permitted; however when HCH residues on plants and DDT on straws were found, a warning has been issued to take necessary measures in 1985. During implementation of the POPs Legacy Elimination and POPs Release Reduction Project (No.140288) funded by GEF and cooperated by MoEUCC, UNDP and UNIDO, 300 tonnes of PCB containing materials and equipment was eliminated, and 6094 transformers were analysed for PCBs. According to the results of this analysis, 42,6 tonnes of transformer oil having a PCB concentration greater than 50 ppm were decontaminated. The Ministry of Environment, Urbanization and Climate Change limited the amount of PCB in the waste oil, prevention of flaming oils and disposal of the oil in an environmentally sound manner. Academic research studies conducted in Turkey reveal PCB concentrations in environmental and food samples as well as concentrations of other POPs, which might indicate possibly contaminated sites. However, they should be evaluated further considering the risk associated with these concentrations. The detail of the studies is provided in section 2.3.5. MoEUCC also set the methods and the principles of disposal of the waste electric and electronic equipment containing POPs and bans the use of several POPs in electric and electronic articles. The related POPs chemicals are PBB, PCB and PBDE. Moreover, MoEUCC is regulating the landfilling of hazardous wastes containing POPs. However, further assessment is needed on uncontrolled dumpsites, sites that may be contaminated with PBDEs and PFOS containing products and petroleum refinery sites. From uPOPs perspective, historical and current activities of related industries should be identified and potentially contaminated sites should be assessed by taking into account the degree of contamination and the associated risk. In this context, related industries are chlor alkali production plants, paper National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 42 production, timber production, waste incineration plants, iron and steel production and processing plants. Additionally, there is an ongoing project implemented by United Nations Development Program (UNDP) for capacity building and technical assistance for contaminated site remediation in Turkey. 2.3.5. Current Programs and Results on Monitoring of POPs Emissions and Effects on Human Health and Environment There is no systematic monitoring program on POPs emissions, releases and occurrence in the abiotic or biotic matrices in Turkey. However, some of the POPs are being monitored for auditing compliance with legislations such as pesticides with By-Law on Surface Water Quality management and By-law on Control of Pollution Caused by Dangerous Substances in Aquatic Environment, and uPOPs with By-law on Control of Air Pollution Arising from Industrial Facilities. Previous monitoring and academic research studies have been presented in the previous NIP in 2016. Hence, updated results on literature search for the POPs levels identified in abiotic and biotic matrices are summarized in Annex V. 2.3.6. Current level of information, awareness and education among target groups; existing systems to communicate such information to the various groups; mechanisms for information exchange with other Parties to the Convention Turkey, as a party to the Convention, is implementing actions for the involvement of stakeholders and the general public. The main instruments for information access are the POPs website (https://kalicikirleticiler.com/), where all information regarding POPs, Stockholm Convention and projects conducted are presented, informative videos played on mass media. Also, websites of public enterprises, non-governmental organizations and international foundations are providing a means by which people can access environmental information. According to the Environmental Law (No.2872), everyone, especially the administration, professional associations, unions and non-governmental organizations, is responsible for the protection of the environment and prevention of pollution, and are obliged to comply with the National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 43 measures to be taken and the principles determined. Hence, every region and every group should realize the function of the environment and potential problems that may occur. This emphasizes the need for environmental training at every level. Environmental training is included in the curriculum of primary schools in Turkey. There are studies on training of decision makers, training of all related source executives, raising awareness of public and raising the motivation for supporting the environmental activities. 2.3.7. Activities of Non-Governmental Stakeholders related to POPs Non-governmental organizations have a great role in raising awareness of public and supporting actions and measures to be taken by the governmental organizations about POPs management in Turkey. Specifically, the NGOs, such as the Chamber of Industry and Trade, provides a major contribution to effective information sharing with its members on activities related to POPs. Other NGOs for providing inventory information, helping candidate foundations to apply are IMMIB, TCUD, TCMB and TTD. Additionally, mass media in Turkey is very interested in environmental problems which create a great advantage on raising awareness of public about POPs. 2.3.8. Overview of technical infrastructure for POPs assessment Turkey has adapted many EU legislations during the EU Harmonization process and conducted projects in this respect. The projects contributed to build infrastructural and institutional capacity to meet Turkey’s liabilities and responsibilities to the Stockholm Convention on POPs. Turkey has conducted projects in regards to components within the scope of EU harmonization and technical assistance. 2.3.9. Identification of Impacted Populations or Environments, Estimated Scale and Magnitude of Threats to Public Health and Environmental Quality and Social Implications for Workers and Local Communities Declaration and Reporting of Priority Pollutant Releases DDT was the most commonly used POPs chemical in Turkey, followed by a group of widely used pesticides, i.e. aldrin+dieldrin+endrin, and HCH. By examining the inventories of National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 44 industrial chemicals, PCBs, PBDEs and PFOS can be considered as priority pollutants that need further assessment regarding the materials and wastes containing these chemicals and sites contaminated with these chemicals. Current Monitoring Standards and Capacity for POPs There is no systematic monitoring program on POPs emissions, releases and occurrence in the abiotic or biotic matrices in Turkey. However, some of the POPs can be monitored for auditing compliance with legislations by Ministry of Health, Ministry of Environment, Urbanization and Climate Change and Ministry of Agriculture and Forestry Affairs. Current Occupational Safety Measures of POPs Pesticides and Industrial Chemicals The POPs chemicals have been banned in Turkey and since they are not in use for some time, occupational safety measures for management of these chemicals and wastes containing these chemicals should be taken. In this context, not only ILO’s guidelines but also Regulation on Health and Safety Measures in Occupations with Chemical Substances (12 th August 2013, No: 28733) are taken into consideration. Employers has liabilities and responsibilities to determine the presence of a chemical of concern, to conduct risk assessment, prevent employee’s exposure to the chemicals and take precautions to minimize the risk of the hazards caused by the chemicals when exposures cannot be avoided. 2.3.10. Relevant systems for the assessment and listing of new chemicals Pesticides and industrial chemicals have different registration procedures in Turkey. The details of registration procedures were presented in the previous NIP. Accordingly, the assessment and listing of new chemicals are the concerns of By-law on Registration, Evaluation, Authorization and Restriction of Chemicals (by MoEUCC, June 23 rd , 2017 numbered 30105), By-law on Licensing and Placing on the Market of Plant Protection Products (by MoAFA November 9 th , 2017 numbered 30235), By-law on Wholesale, Retail Selling and Storage of Plant Protection Products (by MoAFA February 13 th , 2019 numbered 30685), and By-law on Biocidal Products (by MoH December 31 st , 2009 numbered 27449). National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 45 2.3.11. Relevant systems for the assessment and regulation of chemicals already in the market The details of assessment procedures were presented in the previous NIP. Accordingly, the assessment and regulation of chemicals are the concerns of By-law on Controlling the Plant Protection Products (by MoAFA July 6 th , 2011 numbered 27939), By-law on the Import of Plant Protection Products and Their Raw Materials (by MoAFA December 14 th , 2018 numbered 30625) and By-law on Biocidal Products (by MoH December 31 st , 2009 numbered 27449). 3. Strategy and Action Plan Elements of the POPs NIP 3.1. Introduction The main strategy objectives of the NIP are as follows:  Effective implementation of legislations related to the management of POPs and publishing or revising the legislations regarding the prohibition of the production, use, import and export of new POPs  Continuous update of inventory of old and new POPs as a tool for decision making process  Elimination of POP releases into the environment especially reduction of uPOPs releases  Elimination of legacy POPs stockpiles  Promotion and application of BAT/BEP principles as key principles of the future industrial development strategy and for elimination of POPs stockpiles and remediation of contaminated sites  Updating inventory of contaminated sites with special attention to POPs  Preparation and implementation of national monitoring programs. By-law on Persistent Organic Pollutants has entered into force and other relevant legislations are planned to be published in a couple of years. National POPs inventory studies have been conducted regarding intentionally and unintentionally produced POPs, and the results of inventory studies revealed the important sectors regarding BFR usage and uPOPs emissions. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 46 Successful implementation of legislations and auditing resulted in a decrease in uPOPs emissions. 3.2. POPs National Priority Areas The national priority areas for management of POPs are as follows:  Legislative applications including regulation and enforcement, involvement of the management of POPs policies in the development strategies of Turkey  Inventory of emissions, releases, stockpiles and contaminated sites for POPs  Identification of relevant sectors for past use of POPs and past and current production of uPOPs  Reduction of releases of intentionally and unintentionally produced POPs  Effective auditing, capacity building and promotion of BAT/BEP implementation in industry and for remediation of contaminated sites  Public education and awareness raising  Nation-wide long term monitoring and control of public health and environment  Information exchange and networking, inter-ministerial coordination and  Research and development for identification of POPs in environmental matrices, technical materials, products, wastes, and human matrices, remediation of contaminated sites, investigation of human exposure to POPs and identification of safer alternatives 3.3. Activities, Strategies and Action Plans Implementation of the obligations under the Stockholm Convention and CLRTAP/POPs Protocol in Turkey is assessed in this subsection by discussing the implementation performed so far and new action plans related to the corresponding obligation. Some of the actions included in the previous NIP were also listed here since they are still ongoing. Specific targets, milestones and performance indicators are outlined to allow progress of implementation to be reviewed and monitored. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 47 3.3.1. Institutional Capacity and Regulatory Strengthening Measures As a candidate country to European Union, Turkey is following, harmonizing, adopting and implementing the relevant EU legislations on controlling the POPs chemicals in domestic use. The EU Regulation concerning Persistent Organic Pollutants, the EU Regulation concerning the placing of plant protection products on the market and the EU Regulation concerning the making available on the market and use of biocidal products were the main sources to follow. By-law on Persistent Organic Pollutants was prepared by harmonizing Stockholm Convention, CRLTAP/POPs Protocol and EU POPs regulation, and entered into force on November 14 th , 2018 (No. 30595). Additionally, revisions have been made in other legislations regarding POPs in accordance with the action plans and measures proposed in the NIP prepared in 2016. In this context, for purposes of manufacturing, use, placing on the market and import, 12 POPs chemicals in industrial category and 18 POPs chemicals in pesticide category have been banned and restricted. For the unintentional production of PCBs, PCDD and PCDF, emission limits have been determined, while no action has been taken for unintentional production of HCB, hexachlorobutadiene, pentachlorobenzene and PCNs. This activity includes measures for development and implementation of more effective legal and regulatory framework for the management of old and new POPs. Activity 1: Institutional capacity and regulatory strengthening measures AP number Action Plan Time Control AP1.1 To publish draft By-law on Export and Import of Some Hazardous Chemicals to implement and enforce the provisions of Rotterdam Convention and set the principles of Prior Informed Procedure in international trade of chemicals including POPs so that the export of Annex A and Annex B chemicals will be controlled and regulated 2022 XII/2022 Responsibility MoEUCC National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 48 AP1.2 To include the policies regarding management of POPs in the development strategies of Turkey and to take into account the actions listed in NIP while determining the development strategies 2023 XII/2023 Responsibility Presidency of Strategy and Budget in cooperation with MoEUCC AP1.3 To publish a draft by-law regarding pollutant release and transfer register (PRTR) system for estimation of inventory of POPs 2023 XII/2023 Responsibility MoEUCC AP1.4 To implement the Turkish subordinate legislation technical aspects connected with the new and candidate POPs. In this context,  To prohibit the export of POPs as pure chemicals or products  To control export of POPs pesticides 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoAFA AP1.5 To prohibit production, use, placing on the market and import of deca-BDE, hexa-BDE, hepta-BDE, tetra-BDE, penta-BDE, PFOS and short-chain chlorinated paraffins by legal instruments 2022 XII/2022 Responsibility MoEUCC AP1.6 To update By-law on Licensing and Placing on the Market of Plant Protection Products to cover the physicochemical properties, bioaccumulation potential and ecotoxicological data for certification process of new pesticides 2022 XII/2022 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 49 Responsibility MoAFA in cooperation with MoEUCC AP1.7 To update By-law on Control of Air Pollution Arising from Industrial Facilities to include emission limits for other uPOPs, i.e. hexachlorobenzene, pentachlorobenzene, hexachlorobutadiene, polychlorinated naphthalenes 2023 XII/2023 Responsibility MoEUCC AP1.8 To update the By-law on POPs to include the monitoring procedures for all listed POPs 2022 XII/2022 Responsibility MoEUCC AP1.9 To implement and update relevant Turkish subordinate legislations regarding the regulation limits connected with POPs in water, soil, sewage, and waste 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoAFA AP1.10 To support regular control of the implementation of the NIP measures and continuous upgrade of national POPs inventory 2023 XII/2022, XII/2023 Responsibility MoEUCC AP1.11 To support the establishment and effective working of institutional framework covering individual departments of MoEUCC and other responsible ministries and institutions for successful implementation of the Stockholm Convention, CRLTAP/POPs Protocol and national subordinate legislation including the NIP measures 2023 XII/2023 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 50 Responsibility MoEUCC 3.3.2. Management of Annex A Pesticides All POP pesticides have been banned in Turkey, and production, manufacturing, marketing (including import) and use of unregistered plant protection products within the territory of the country are prohibited. The activities regarding the management of Annex A POP Pesticides focus on old storage and illegal storage of pesticides. Activity 2: Action Plans of Annex A POP-Pesticides AP number Action Plan Time Control AP2.1 To update the inventory of old agrochemical stores, storages, and contaminated sites 2023 XII/2023 Responsibility MoAFA in cooperation with MoEUCC AP2.2 To control existing storage sites and dumping sites, conduct and improve inspections and maintenance to prevent accidents or leakage 2023 XII/2022, XII/2023 Responsibility MoAFA in cooperation with MoEUCC AP2.3 To demolish, clean and empty POPs pesticides storage buildings using BAT/BEP procedures, and develop safe temporary storage if needed 2023 XII/2022, XII/2023 Responsibility MoAFA in cooperation with MoEUCC 3.3.3. Management of PCBs and PCB Containing Equipment Actions and measures regarding the management of PCBs and PCB containing equipment given in 2016 NIP have been implemented by the legislations issued and entered into force. By the implementation of projects, elimination of PCB containing materials, and National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 51 decontamination of transformer oils having a PCB concentration greater than 50 ppm are ongoing. Activity 3: Management of PCBs and PCB Containing Equipment AP number Action Plan Time Control AP3.1 To continuously update PCBs inventory of closed, semi closed and open PCB sources, especially identify products and materials containing PCBs in open applications 2022 XII/2022 Responsibility MoEUCC in cooperation with industrial associations AP3.2 To cease the usage of PCBs and PCB containing equipment as soon as possible 2023 Annually XII Responsibility MoEUCC in cooperation with industrial associations AP3.3 To update the inventory of PCB contaminated sites and lands, PCB stock sites 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with the universities, research institutions and industrial associations AP3.4 To regularly control stockrooms of PCB containing wastes and equipments, and to ensure that they are secured by the facility owners 2022 XII/2022 Responsibility MoEUCC AP3.5 To promote environmentally sound management and application of BAT/BEP for the purification and disposal of transformers and capacitors, disposal of 2023 XII/2023 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 52 PCBs and PCB containing wastes in related industries including ship recycling industry Responsibility MoEUCC in cooperation with MoIT, MoT, and industrial associations 3.3.4. Management of BFRs The inventory studies have been conducted for brominated flame retardants (BFRs) by estimating their use in related industries, collecting data on import and export of products, and estimating amounts of produced wastes. Inventory studies showed that more effort was put into the recovery and recycle of end-of-life vehicles than before. Surveys conducted with the industry in Turkey demonstrated that the industry successfully moved to the alternatives of POPs while selecting flame retardants. Inventory estimates also included decaBDE and HBCD which were added to the Annex A of the Convention. Estimates of deca-BDE use in textile sector highlighted the importance of inventory studies in this sector in Turkey. Additionally, Turkey’s EPS industry is the largest among Middle East and Central Asia region, and the third in Europe, which may correspond to large amounts of HBCD use and production of wastes. Main actions include identification of direct uses of PBDEs and HBCD, the locations of storage and waste disposal locations, and regularly updating BFR inventories. Activity 4: Production, import and export, use, stockpiles and wastes of brominated flame retardants AP number Action Plan Time Control Responsibility MoEUCC, MoIT, MoT and industrial associations AP4.1 To identify the landfills and dumpsites potentially contaminated with PBDEs by investigating all the sectors involved, 2023 XII/2023 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 53 manufacturing locations and locations of storage, wastes being disposed, bio-solids application, methods of waste disposal or treatment, and waste disposal locations Responsibility MoEUCC in cooperation with MoAFA and industrial associations AP4.2 To update WEEE related regulation for prohibition of the untreated recovery or recycle of the corresponding wastes and implementation of effective screening tools 2023 XII/2023 Responsibility MoEUCC AP4.3 To improve the inventory estimates for deca BDE especially for textile sector, which is one of the leading sectors in Turkish economy 2022 XII/2022 Responsibility MoEUCC, MoIT and industrial associations AP4.4 To promote usage of alternative flame retardants in related industries 2023 XII/2023 Responsibility MoEUCC, MoIT and industrial associations AP4.5 To improve and regularly update the inventory of BFRs and BFR containing products, including major and minor applications, and the assessment of waste flows, presence in end of life goods 2022 XII/2022 Responsibility MoEUCC, MoIT, MoT and industrial associations AP4.6 To assess the recycling activities and destruction technologies for BFR wastes and implementation of BAT/BEP guidelines in the related activities 2022 XII/2022 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 54 Responsibility MoEUCC, MoIT and industrial associations 3.3.5. Management of DDT DDT is not produced, imported, exported and used in Turkey. Activity 5: Management of DDT AP number Action Plan Time Control AP5.1 Ensure the environmentally sound disposal of illegally imported DDT In case of detection Responsibility MoAFA in co-operation with MoEUCC 3.3.6. Management of PFOS The main activities regarding management of PFOS include data collection on PFOS wastes, stockpiles and PFOS contaminated sites, improvement of inventory on PFOS and related chemicals, and application of BAT/BEP in the relevant industries. Activity 6: Production, import and export, use, stockpiles and wastes of PFOS, its salts and PFOSF (Annex B, Part III chemicals) AP number Action Plan Time Control AP6.1 To develop and update inventory of PFOS used in related sectors currently and in the past and to assess the disposal of PFOS wastes 2022 XII/2022 Responsibility MoEUCC in cooperation with MoIT, MoT and industrial associations AP6.2 To assess uncontrolled dump sites, sites that may be contaminated with PFOS containing products and petroleum refinery sites 2023 XII/2023 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 55 Responsibility MoEUCC in cooperation with MoIT, MoT and industrial associations AP6.3 To assess recycling activities and currently used technologies of PFOS and related chemicals and implementation of BAT/BEP Guidelines 2022 XII/2022 Responsibility MoEUCC in cooperation with MoIT and industrial associations AP6.4 To assess destruction technologies of PFOS and related chemicals and implementation of BAT/BEP Guidelines 2022 XII/2022 Responsibility MoEUCC in cooperation with MoIT and industrial associations 3.3.7. Management of polychlorinated naphthalenes, hexachlorobutadiene, pentachlorophenol and its salts and esters, and short-chain chlorinated paraffins The main activities regarding management of polychlorinated naphthalenes, hexachlorobutadiene, short-chain chlorinated paraffins and pentachlorophenol and its salts and esters include improvement of inventory on polychlorinated naphthalenes, hexachlorobutadiene, short-chain chlorinated paraffins and pentachlorophenol and its salts and esters and periodical update, data collection on wastes, stockpiles and contaminated sites, and application of BAT/BEP in the relevant industries. Hexachlorobutadiene has no records for import and export within the country, while polychlorinated naphthalenes and pentachlorophenol have been imported and exported even if the amounts remained low. On the other hand, there are records on the import and export of materials containing short-chain chlorinated paraffins, although the information gathered needs further examination. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 56 Activity 7: Production, import and export, use, stockpiles and wastes of polychlorinated naphthalenes, hexachlorobutadiene, short-chain chlorinated paraffins and pentachlorophenol and its salts and esters AP number Action Plan Time Control AP7.1 To perform, develop and update inventory of polychlorinated naphthalenes, hexachlorobutadiene, short-chain chlorinated paraffins and pentachlorophenol and its salts and esters used in related sectors currently and in the past and to assess the disposal of their wastes 2023 XII/2023 Responsibility MoEUCC in cooperation with MoIT, MoT and industrial associations AP7.2 To prepare protocols between Customs Office and MoEUCC to obtain the records of the export and import of these chemicals and articles with them in more comprehensive manner 2023 XII/2023 Responsibility MoEUCC in cooperation with MoT AP7.3 To assess uncontrolled dump sites, sites that may be contaminated with polychlorinated naphthalenes, hexachlorobutadiene, short chain chlorinated paraffins and pentachlorophenol and its salts and esters 2023 XII/2023 Responsibility MoEUCC in cooperation with MoIT, MoT and industrial associations AP7.4 To assess destruction technologies of wastes containing these chemicals implementation of BAT/BEP Guidelines 2022 XII/2022 Responsibility MoEUCC in cooperation with MoIT and National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 57 industrial associations 3.3.8. Reduction of releases form the unintentional production of POPs Total uPOPs releases in Turkey was estimated to decrease by 35% from 2014 to 2019, mainly due to the investments introduced and proper air pollution abatement systems installed in ferrous and non-ferrous metal production industries. More accurate emission estimates have been carried out especially for wastewater discharges. Successful implementation of By-law on the Control of Industrial Air Pollution and effective auditing has led to significant reduction in PCDD/F emissions. Activities to reduce releases of unintentional production of POPs consist of preparation and regular update of national emission inventory and promotion of BAT/BEP implementation. Activity 8: Reduction, elimination and control of uPOPs AP number Action Plan Time Control AP8.1 To prepare official emission inventory and identify potential sources of uPOPs: hexachlorobenzene, pentachlorobenzene, hexachlorobutadiene and polychlorinated naphthalenes, and regular update of emission inventories for all uPOPs 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoIT and industrial associations AP8.2 To integrate PRTR system for national inventory of uPOPs emissions 2023 XII/2023 Responsibility MoEUCC in cooperation with MoIT and industrial associations AP8.3 To develop strategies for control of uPOPs emissions and revise the related regulations accordingly to include emission limits for 2023 XII/2023 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 58 Polychlorinated naphthalenes, Hexachlorobutadiene, Pentachlorobenzene, Hexachlorobenzene Responsibility MoEUCC AP8.4 To routinely monitor emission of uPOPs and PAHs from industrial plants as a requirement of the By-law on the Control of Industrial Air Pollution to check if the emissions are lower than the limits defined in the by-law 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoIT and industrial associations AP8.5 To control potential emission sources of uPOPs, especially illegal use of waste and base-oil mixtures, ship breaking and recycling facilities, open burning of agricultural wastes, fires of dumps, iron steel production and processing facilities and production/import of uPOPs containing materials 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoIT, MoAFA AP8.6 To promote implementation of BAT/BEPs for the control of uPOPs emissions 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoIT and industrial associations National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 59 3.3.9. Identification of stockpiles, articles in use and wastes plan for assessment and management of releases from stockpiles and wastes Activities include identification of POPs containing stockpiles, risk assessment and application of BAT/BEP procedures to eliminate the problem associated with historical pollution caused by legacy POPs stockpiles. Activity 9: Identification of stockpiles, articles in use and wastes plan for assessment and management of releases from stockpiles and wastes AP number Action Plan Time Control Responsibility MoEUCC AP9.1 To update POPs-containing stockpiles and wastes inventory 2023 XII/2022, XII/2023 Responsibility MoEUCC AP9.2 Prioritisation and risk assessment of sources identified in inventory phase 2023 XII/2022, XII/2023 Responsibility MoEUCC AP9.3 To evaluate the appropriate BAT/BEP procedures and strategies for elimination of current stockpiles and wastes, ensure the guidelines for collection, transport and storage of these stockpiles and wastes are followed 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoIT AP9.4 To ensure the licensing, operation, tracking and control of storage facilities including handling and transport procedures in priority sectors (i.e. waste incineration, ship recycling, etc.) 2023 XII/2022, XII/2023 Responsibility MoEUCC National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 60 3.3.10. Identification of contaminated sites (Annex A, B and C chemicals) and remediation in an environmentally sound manner Studies for contaminated sites problem have been recently initiated in Turkey. Documents have been prepared for assessing available remediation technologies for sites contaminated with various pollutants. Additionally, there is an ongoing project implemented by United Nations Development Program (UNDP) for capacity building and technical assistance for contaminated site remediation in Turkey. The end recipient of the project is MoEUCC. As a result of this project, it is aimed to 1) technical and institutional capacity for management of POPs contaminated sites will be strengthened, 2) contaminated sites with POPs will be identified and classified, and 3) institutional experience for remediation of POPs contaminated sites will be increased. Other activities include application of appropriate remediation strategies and preparation of financial plan. Activity 10: Identification of contaminated sites (Annex A, B and C Chemicals and Annexes I, II and III) and remediation in an environmentally sound manner AP number Action Plan Time Control AP10.1 To update Contaminated Site Information System to cover POPs chemicals 2023 XII/2023 Responsibility MoEUCC AP10.2 To develop national database of contaminated sites with special attention to newly listed and candidate POPs 2023 XII/2023 Responsibility MoEUCC in cooperation with MoIT and MoAFA AP10.3 To prioritise and assess the risk associated with contaminated sites identified 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoAFA and MoH AP10.4 To evaluate appropriate BAT/BEP 2023 XII/2022, National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 61 procedures, strategies and guidelines for remediation of contaminated sites XII/2023 Responsibility MoEUCC AP10.5 To prepare a financial plan for remediation of priority contaminated sites 2023 XII/2023 Responsibility MoEUCC 3.3.11. Facilitating or undertaking information exchange and stakeholder involvement This activity contains information exchange and stakeholder involvement actions. Activity 11: Facilitating or undertaking information exchange and stakeholder involvement AP number Action Plan Time Control AP11.1 To update the information exchange system for international conventions related to chemicals management in cooperation with related institutions (reports, news, websites) 2022 XII/2022 Responsibility MoEUCC in cooperation with MoIT, MoAFA, MoT AP11.2 To ensure continuous information exchange with related institutions concerning POPs 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoIT, MoAFA, MoT, and universities AP11.3 To ensure information gathering from the Secretariats of the international conventions and regional centers of the SC 2023 XII/2022, XII/2023 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 62 Responsibility MoEUCC 3.3.12. Public awareness, information and education This activity includes developing and continuing public awareness program on POPs focusing on the POPs problems. A website for POPs has been produced to give information on the POPs and projects implemented on this issue. Action 12: Public awareness, information and education AP number Action Plan Time Control AP12.1 To ensure education programs and trainings for relevant institutions (ministries, custom service, administrative, scientists, teachers, etc.) on the national, regional and local scales 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoAFA, MoH, MoNE, MoT AP12.2 To carry out studies and /or projects with the Ministry of National Education (MoNE) regarding the effects of POPs chemicals on human health and environment and POPs, POPs waste and u-POPs management, especially in primary and secondary schools 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoNE AP12.3 To ensure the preparation of brochures, posters, bulletins, tv clips, educational video programs concerning to the POPs problems (sources, disposal, human and environmental impacts) 2023 XII/2022, XII/2023 Responsibility MoEUCC AP12.4 Awareness raising of policy and decision 2023 XII/2022, National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 63 maker authorities on POPs XII/2023 Responsibility MoEUCC 3.3.13. Assessment of Effectiveness This activity includes effectiveness evaluation of the actions in the NIP. Action 13: Assessment on effectiveness AP number Action Plan Time Control AP13.1 To annually check compliance and evaluate the effectiveness of the implementation of the convention in Turkey Annually XII/y Responsibility MoEUCC 3.3.14. Reporting This activity is related to the obligation regarding reporting the measures taken to implement the provisions of the convention to the conference of parties. This process has two parts, support of the official country reporting to the SC Secretariat and national reporting as a phase of collection of all relevant and required information. Action 14: Reporting AP number Action Plan Time Control AP14.1 To develop specific reporting mechanism regarding the implementation of the Convention 2022 XII/2022 Responsibility MoEUCC AP14.2 To ensure the national system of collection of all relevant information concerning to the implementation of the Annually XII/y National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 64 Turkish NIP measures and annual reporting of the data concerning to emissions, releases, products, wastes, stockpiles and contaminated sites Responsibility MoEUCC 3.3.15. Research, development and monitoring According to Article 11 of Stockholm Convention, parties shall conduct appropriate research, development, monitoring and cooperation activities. This activity involves research, development and monitoring actions. Action 15: Research, development and monitoring AP number Action Plan Time Control AP15.1 To ensure financial support of the priority research and development actions by projects from national funds 2023 XII/2022, XII/2023 Responsibility MoEUCC in cooperation with MoIT, universities and research institutions AP15.2 To include the actions required to implement the Convention in the national research and development programs 2023 XII/2023 Responsibility MoEUCC in cooperation with MoIT, universities and research institutions AP15.3 To develop a comprehensive long term monitoring plan and be a part of global or regional monitoring activities conducted by international organizations, to constitute funding opportunities for researchers/universities to be able to conduct systematic monitoring activities in the 2023 XII/2023 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 65 country Responsibility MoEUCC in cooperation with MoIT, MoAFA, MoH, universities and research institutions AP15.4 To ensure targeted pilot and research studies concerning POPs in environmental matrices and technical materials, products, wastes, and human matrices 2023 XII/2023 Responsibility MoEUCC in cooperation with MoIT, MoAFA, MoH, universities and research institutions AP15.5 To develop an inventory system available to collect data on the production, use, import and export of POPs by related users 2022 XII/2022 Responsibility MoEUCC in cooperation with MoIT, MoAFA, MoH, universities and research institutions 3.3.16. Technical and financial assistance In order to fulfill obligations under the Stockholm Convention and CRLTAP/POPs Protocol and for successful implementation of activities and actions to accomplish overall objectives, adequate financial and technical assistance would be required. Action 16: Technical and financial assistance AP number Action Plan Time Control AP16.1 To ensure a regular annual budget for inventories, disposal, monitoring, research and awareness rising based on the NIP conclusions and measures Annual XII/y National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 66 Responsibility MoEUCC 3.4. Timetable for Implementation and Measures to Take for Success The activities within the scope of POPs NIP are designed to be implemented in short, medium and long term. The short term activities are the ones to be covered in a period of 3-5 years. These include creating an inventory system and systematic update of inventories by data gathering from related institutions, preparing and implementing legislations, sectoral effect assessment and regulatory effect analysis. Medium term activities to be performed within 5-7 years consist of assessment of the chemicals to be banned or restricted by the convention, checking inventories for newly listed POPs, identification of contaminated sites, environmentally sound disposal of identified POPs stockpiles, checking industrial facilities for compatibility with BAT/BEP, starting monitoring activities and supporting research activities related to these issues. Long term activities to be performed within 7-15 years are environmentally sound disposal and elimination of POPs stockpiles and wastes, remediation of contaminated sites, maintaining the monitoring activities, and studies for management of newly listed chemicals. 3.5. Final Statement For successful implementation of POPs legislation in Turkey, By-law on Persistent Organic Pollutants was prepared by harmonizing Stockholm Convention, CRLTAP/POPs Protocol and EU POPs Regulation, and entered into force on November 14 th , 2018 (No. 30595). In this context, several other legislations have also been prepared and published, and some needs further improvements. For effective implementation of the legislations, institutional and organizational framework should be supported by involvement of all stakeholders including ministries, governmental organizations, industrial associations, universities and non governmental organizations, as well as public. Furthermore, provision of adequate financial and technical assistance would help Turkey to fulfill its obligations under the Stockholm Convention and CLRTAP/POPs Protocol. The policies regarding management of POPs in National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 67 Turkey should be included in the development strategies of Turkey and the actions listed in the NIP should be taken into account while determining the development strategies. Short term activities regarding preparation and regular update of inventories on POPs use, POP wastes and stockpiles, identification of dumpsites and contaminated sites, and improvement of inventories based on related sectors should be carried out for successful fulfillment of obligations of the conventions and for implementation of medium and long term activities. Special attention should be given to the unintentionally produced POPs, regarding their emission inventory and identification of potential sources including relevant industries. Application of BAT/BEP guidelines for management of POPs emissions, stockpiles and remediation of contaminated sites should be promoted and effective auditing should be performed. Comprehensive long term POPs monitoring plan should be developed, incorporating the assessment of POPs levels in environmental, technical and human matrices. Necessary auditing for water, soil, air quality, generated wastes, as well as food stuff should be controlled by regulatory actions and funding opportunities should be constituted for national laboratories, research institutions and universities to carry out such studies. For implementation and management of POPs related problems in Turkey, the control mechanisms and evaluation of the effectiveness of the actions should be clearly defined and established. Especially, assessment of risk associated with exposure of humans to POPs should be prioritized. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey 68 4. 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Retrieved in June 5, 2020 from: http://users.abo.fi/rzevenho/tkk-eny-14.pdf http://users.abo.fi/rzevenho/tkk-eny-14.pdf National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey National Implementation Plan of Persistent Organic Pollutants (POPs) Management in Turkey Annexes National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A1 Table of Contents Annex I: Persistent Organic Pollutants ...................................................................................... 2 Annex II: Country Profile ........................................................................................................ 13 Annex III: Legal Framework on POPs ..................................................................................... 15 Annex IV: National POPs inventory ........................................................................................ 26 Annex V: Current Programs and Results on Monitoring of POPs Emissions and Effects on Human Health and Environment .............................................................................................. 38 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A2 Annex I: Persistent Organic Pollutants POPs areas of use, CAS numbers and chemical structures are given below: Aldrin A pesticide applied to soil for killing termites, crickets, worms, generally for insect control. CAS No: 30-9-00-2 It can easily be metabolized into dieldrin in plants and animals. As a result, it is very difficult to find aldrin residues in foods and animals, if so in very small quantities. It is bound to the soil particles firmly. Due to its high volatility, it disappears in soil. Because of its persistency and hydrophobic property, aldrin and especially its transformed products become bio-concentrated. Aldrin is toxic to humans. The lethal dose of aldrin for an adult is estimated as 5 g (83 mg/kg body weight). It was observed that liver and gallbladder cancer rate increased in the professionals who were exposed to aldrin. Only evidence for aldrin causing cancer is based on animal tests. Therefore, IARC (International Agency for Research on Cancer) does not classify aldrin as human carcinogen. Chlordane An insecticide is widely applied in controlling termites and protecting agricultural products from other insects CAS No:57-74-9 Chlordane is a wide spectrum contact insecticide. It is semivolatile, so it can be present in the atmosphere. It can be bound to sediments in the water easily and become bioconcentrated in the fat tissues of organisms. When the chlordane exposed persons were checked up, it has been detected that significant changes had been occurred in their immune system. IARC categorizes chlordane as a possible human carcinogen (2B group: Possible human carcinogen). Average half-life in soil is 1 year. Chlordecone Chlordecone is a synthetic chlorinated organic compound, which was mainly used as an agricultural pesticide. CAS No: 143-50-0 Chlordecone is a synthetic chlorinated organic compound, which has mainly been used as an agricultural pesticide. It is closely related chemically to mirex. According to available data, chlordecone can be considered to be highly persistent in the environment. Chlordecone is not expected to hydrolyse or biodegrade in aquatic environments, nor in soil. Direct photodegradation is not significant. Chlordecone does not volatilise to any significant extent. With BCF-values in algae up to 6,000, in invertebrates up to 21,600 and in fish up to 60,200 and documented examples of biomagnification, chlordecone is considered to have a high potential for bioaccumulation and biomagnification. Concerning the potential for causing adverse effects, there is a convincing set of data. Chlordecone is readily absorbed into the body and accumulates following prolonged exposure. It is both acutely and chronically toxic, producing neurotoxicity, immunotoxicity, reproductive, musculoskeletal and liver toxicity. The International Agency for Research on Cancer has classified chlordecone as a possible human carcinogen (IARC group 2B). Moreover, chlordecone is very toxic to aquatic organisms, most sensitive group being the invertebrates. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A3 Decabromodiphenyl ether (commercial mixture, c-decaBDE) DecaBDE is used as an additive flame retardant, and has a variety of applications including in plastics/polymers/composites, textiles, adhesives, sealants, coatings and inks. DecaBDE containing plastics are used in housings of computers and TVs, wires and cables, pipes and carpets. CAS No: 1163-19-5 The decaBDE is highly persistent, has a high potential for bioaccumulation and food-web biomagnification, as well as for long-range transport. Adverse effects are reported for soil organisms, birds, fish, frog, rat, mice and humans. DDT Most known POPs type, used during World War 2 to protect soldiers and civillians from malaria, typhoid like diseases spreaded from insects. They are still used in some places to avoid malaria from mosquitos CAS No:50-29-3 In the post war era DDT use on agricultural products and vector combat continued. Because of the belief of its harmful effects on nature, especially on wild birds, most of the developed countries banned DDT in the beginning of 1970‟s. Due to its semi-volatile characteristic, it can be present in atmosphere. It can easily accumulate in the fat tissue of all living organisms; it was even detected in mother‟s milk. DDT and its related products are very durable in nature, even after 10 - 15 years from its application more than 50 % of them remain in the soil. Although there is not enough evidence of DDT being carcinogenic, IARC classified it as a possible human carcinogen based on the results of the animal tests. Dicofol Dicofol is an organochlorine pesticide comprising two isomers: p,p′-dicofol and o,p′-dicofol. It is an organochlorine miticidal pesticide that has been used in agriculture to control mites on a variety of field crops, fruits, vegetables, ornamentals, cotton, tea. It was also used an acaricide for cotton, citrus and apple crops. p,p′-dicofol CAS No: 115-32-2 o,p′-dicofol CAS No: 10606-46-9 Monitoring data have shown that dicofol is sufficiently persistent to be transported via riverine input to the open sea and to be detected in deep sediment layers dated back several decades. Dicofol has a high bioconcentration potential as demonstrated by experimental derived bioconcentration factor values in fish. Model results showed that dicofol and its metabolites can be transported to remote regions. Limited monitoring evidence of dicofol in environmental media from remote sources is available. Similar to DDT, dicofol is a toxic concentrated formulation found in the environment and humans with a long persistent and bioaccumulatative property. Prolonged or repeated exposure to dicofol can cause skin irritation, hyperstimulation of nerve transmissions along nerve axons. Dicofol is highly toxic in fish, aquatic invertebrates, algae and in birds is tied to eggshell thinning and reduced fertility. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A4 Dieldrin Used for insects and termites damaging textile plants and also used to control insect related diseases and applied to pests in some farmlands 60-57-1 Used principally to control insects and textile pests, dieldrin has also been used to control insect-borne diseases and insects living in agricultural soils. Due to its harmful effects on nature and human health, many countries banned dieldrin. It vanishes due to its high volatility in soil. It becomes bio concentrated because of its persistency and hydrophobic properties Relative increase of liver and gallbladder cancer were observed at workers contacting aldrin, endrin and dieldrin in factories. IARC did not classify dieldrin as a possible human carcinogen as there was no relevant evidence of both human and animal tests. Dieldrin has a half-life of 5 years in warm soil. Dieldrin residues were found in air, soil, fish, bird, mammals, human, and mother’s milk Dioxins (polychlorinated dibenzo-p-dioxins) These chemicals are produced unintentionally due to incomplete combustion, as well during the manufacture of pesticides and other chlorinated substances. They are emitted mostly from the burning of hospital waste, municipal waste, and hazardous waste, and also from automobile emissions, peat, coal, and wood. There are 75 different congeners, of which seven are considered to be of concern. Dioxins have been associated with a number of adverse effects in humans, including immune and enzyme disorders and chloracne, and they are classified as possible human carcinogens. various Among these, PCDDs and PCDFs (also collectively referred to as PCDDs/Fs) have never been used as commercial products, nor were intentionally manufactured for any reason other than laboratory purposes. PCBs, HCB and PeCBz are also unintentionally formed, usually from the same sources that produce PCDDs/Fs. However, unlike PCDDs/Fs, they have also been manufactured and used for specific purposes, their intentional production and use being by far higher than the unintentional formation and release. PCDDs/Fs releases are accompanied by releases of other unintentional POPs, which can be minimized or eliminated by the same measures that are used to address PCDDs/Fs releases. When a comprehensive inventory of PCDDs/Fs is elaborated, it allows to identify priority sources, set measures and develop action plans to minimize releases of all unintentional POPs. Endrin It is an insecticide sprayed to the leaves of cotton and grain. Used to control rats, microtus and small rodents. 72-20-8 Endrin is an organochlorine insecticide that used to control rodents such as mice and voles. Animals can metabolize endrin, so it does not accumulate in their fatty tissue to the extent that structurally similar chemicals do. It can reach up to atmosphere because of their volatile character and can be washed away from soil to the surface waters. Statistically a significant raise is seen in liver and gall bladder cancer on the workers of factories National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A5 producing aldrin, endrin and dieldrin. IARC didn’t classified dieldrin as carcinogen because lack of proof on human kind, and having limited data on experimental animals. Endrin can persist in the soil for up to 12 years and highly toxic to fish. Furans (polychlorinated dibenzofurans) These substances are produced mostly same as dioxins and produced unintentionally while producing PCB and similarly as dioxins are associated with a number of adverse effects. Various The basic characteristics is presented under Dioxins Heptachlor Primarily used to kill soil insects and termites, heptachlor has also been used more widely to kill cotton insects, grasshoppers, other crop pests, and malaria-carrying mosquitoes. CAS No. 72-20-8 Heptachlor is a non-systemic, effecting through digestive system and by contact. It has a very high volatility, so it can be found in the atmosphere. It can be bound to sediments in the water easily and become bioconcentrated in the fat tissues of living organisms. Heptachlor is metabolized to heptachlor epoxide in animals and this substance can be stored in animal fat tissues. It was determined that gall bladder cancer cases increase significantly in workers of heptachlor producing factories. Although there were no fatal cases for liver and gallbladder cancer, fatal cerebrovascular diseases (brain vessel diseases) were frequently observed. IARC classified Heptachlor as a possible human carcinogen. Hexabromobiphenyl Hexabromobiphenyl is an industrial chemical that has been used as a flame retardantIt is no longer produced or used. 36355-01-8 Hexabromobiphenyl (HBB) is a member of polybrominated biphenyls (PBBs) which are generally referred as Brominated Flame Retardants (BFRs) and generally used in 3 groups of products. These are ABS thermoplasticizers generally used in house appliances, sealants and Polyurethane (PUR) foams used in automobile dashboards. Like many countries in the world HBB is not used for a long while since it has been banned for a long time and has many alternatives. Hexabromocyclododecane Frequently used as brominated flame retardants in materials for insulation (expandable and extruded polystyrene), in polymers of electric and electronic parts, a texitile coating agent hexabromocyclododecane (CAS number 25637-99-4) and 1,2,5,6,9,10 hexabromocyclododecane (CAS number 3194-55-6) HBCD appear as white, non-volatile and odourless solids, insoluble in water but soluble in organic solvents, is very persistent in the environment. Degradation in the environment seems to be insignificant, and levels are mostly increasing. HBCD is for instance still present in sediment after 15 40 years. HBCD is lipophilic and bioaccumulative, the log KOW of 5.6 for HBCD is in the upper range for bioaccumulation, and it is comparable with that of DDT. Biomagnifies and concentrates in natural food chains. Hexachlorobenzene First introduced in 1945 to treat seeds, HCB kills fungi that affect food crops. It 118-74-1 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A6 was widely used to control wheat bunt. It was produced as industrial chemical and also was/is a byproduct of the manufacture of certain industrial chemicals, combustion processes and exists as an impurity in several pesticide formulations. It is highly soluble in fat and can be transferred through breast milk. Low dose of HCB can cause reproductive system malfunction. Hexachlorobutadiene Hexachlorobutadiene (HCBD) is a halogenated aliphatic hydrocarbon mainly generated as a by-product in the manufacturing of chlorinated hydrocarbons. HCBD has experienced a variety of uses, spanning from an intermediate in chemical production to transformer, hydraulic or heat transfer liquid to a viticulture pesticide. Its use and production have ceased in the UN ECE countries but information about ongoing application outside the UN-ECE is not currently available. The substance is still unintentionally released by industry, including during waste management. CAS No: 87-68-3 Based on the available evidence, HCBD is persistent, bioaccumulative and very toxic to aquatic organisms and toxic to birds. The comparison of effect data with monitoring data of marine sea water, freshwater as well as marine or freshwater sediments, indicates that the risk of significant adverse effects of HCBD to aquatic and sediment dwelling organisms is low but it cannot be excluded. Indeed, the level of uncertainty in identifying long-term risk according to the traditional risk assessment approach cannot be estimated with sufficient accuracy. In addition it should also to be taken into consideration that Arctic animals and top predators are exposed to a mixture of heavy metals and persistent organic substances. Alfa-hexachlorocyclohexane Alpha-HCH was produced as ballast isomer during the producton of Lindane, many years was use together with other HCH isomers and technical mixture. 319-84-6 Although the intentional use of alpha-HCH as an insecticide was phased out years ago, this chemical is still produced as unintentional by-product of lindane. For each ton of lindane produced, around 6-10 tons of the other isomers including alpha- and beta-HCH are created. α- HCH is classified as potentially carcinogenic to humans and adversely affects wildlife and human health in contaminated regions. Beta-hexachlorocyclohexane Although the intentional use of beta-HCH as an insecticide was phased out years ago, this chemical is still produced as unintentional by-product of lindane. 319-85-7 For each ton of lindane produced, around 6-10 tons of the other isomers including alpha- and beta National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A7 HCH are created. Large stockpiles of alpha- and beta-HCH are therefore present in the environment. Beta-HCH is highly persistent in water in colder regions and may bioaccumulate and biomagnify in biota and arctic food webs. This chemical is subject to long-range transport, is classified as potentially carcinogenic to humans and adversely affects wildlife and human health in contaminated regions. Lindane Lindane has been used as a broad spectrum insecticide for seed and soil treatment, foliar applications, tree and wood treatment and against ectoparasites in both veterinary and human applications. The production of lindane has decreased rapidly in the last few years and only few countries are still known to produce lindane. 58-89-9 Lindane is effecting through digestive system, respiratory system and by contact. It is in a colourless and crystalline structure. It is mostly used for soil and seed dressing. It is a wide spectrum insecticide used in animal ecoparacites, soil endemic insects, public health diseases, and predators. It is used in various crops (controlled pests: aphids, coleopterous larvas, millepedes, dipteras, lepidopteras, arthropodas and thrips), warehouses, public health applications (roaches, common flies, mosquitos, flies and flea control) and seed applications (it can also be used with fungicides in seed applications). Lindane has a persistent, with high potential to bioconcentration. Their toxic effects are proven on developmental and immune system by the experiments on animals and aquatic organisms. Commercial octaBDE Commercial mixture of octaBDE is mainly used as a flame retardant in electrical and electronic equipment. CAS No: 68631-49-2 CAS No: 207122-15-4 CAS No: 446255-22-7 CAS No: 207122-16-5 PBDEs represent one of the sub-groups of brominated flame retardants. PBDEs possess similar characteristics to PCBs1. When PBDEs are incinerated, they have a high risk in formation of polybrominated dibenzo-p-dioxins and dibenzofurans (PBDDs/Fs), having similar effects as PCDDs/Fs. PBDEs have PBT (persistent, bioaccumulative, toxic) properties and they can be found everywhere in the surrounding environment – in soil, water, sewage, in tissues of fish, birds, seals, whales and polar bears, in human blood, as well as in mother's milk. PBDEs concentrations in the environment are steeply rising. Commercial pentaBDE Mainly used as a flame retardant in Polyurethane foams which have many applications in such as automotive sector, furnitures, etc. CAS No: 5436-43-1 CAS No: 60348-60-9 The pentabromodiphenylether (PeBDE) commercial product is a mixture of primarily tetra- through hexaBDE congeners (plus trace amounts of triBDE and 0-1% heptaBDE). The ratio of the PBDE congeners in commercial PeBDE mixtures is different in different regions of the world. PeBDE is released into the environment during the manufacture of the commercial PeBDE mixture, the manufacture of products, during their use and after they have been discarded as waste. The releases are to air, water and soil. The major part of the releases ends up in soil. The distribution between the environmental compartments is: soil>>>water>air. The main part of PeBDE in the environment is bound to particles; only a small amount is transported in its gaseous phase or diluted in water. Due to PeBDEs high persistency in air, the main route for long-range transport is through the atmosphere. PeBDE is widespread in the global environment and in humans. Vulnerable ecosystems National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A8 and species are affected, among them several endangered species. The potential for the toxic effects in wild life and mammals is evident. The exposure to humans is through food, use of products and indoor air and dust. PeBDE transfers from mothers to embryos and lactating infants. Vulnerable groups can be pregnant women, embryos and infants. Mirex This insecticide is used mainly to combat fire ants, and it has been used against other types of ants and termites. It has also been used as a fire retardant in plastics, rubber, and electrical goods. 2385-85-5 Mirex is considered to be one of the most stable and persistent pesticides, which half-live in soils of up to 10 years. Mirex is relatively volatile with potential long-range transport. There is evidence of its potential for endocrine disruption and possibly carcinogenic risk to humans. Pentachlorobenzene PeCB was used in PCB products, in dyestuff carriers, as a fungicide, a flame retardant and as a chemical intermediate e.g. previously for the production of quintozene. PeCB might still be used as an intermediate. PeCB is also produced unintentionally during combustion, thermal and industrial processes. It also present as impurities in products such as solvents or pesticides. 608-93-5 The substance is persistent in the environment and is bioaccumulative. The small spatial variability across the Northern Hemisphere indicates that pentachlorobenzene has a very long atmospheric residence time, which allows it to become widely distributed in the global hemisphere. There are monitoring data from remote areas, backed up by modelling results that suggest that pentachlorobenzene can be transported over great distances. Pentachlorobenzene is moderately toxic to humans, but is very toxic to aquatic organisms. Present concentrations in remote areas are well below estimated critical body burdens. Pentachlorophenol and its salts and esters It is used as insecticide (termiticide), fungicide, non-selective contact herbicide (defoliant) and, particularly as wood preservative. It is also used in anti-fouling paints and other materials (e.g. textiles, inks, paints, disinfectants and cleaners) as inhibitor of fermentation. Technical PCP contains trace amounts of PCDDs and PCDFs. 87-86-5 (Pentachlorophenol) 131-52-2 (sodium pentachlorophenate) 27735-64-4 (as monohydrate) 3772-94-9 (pentachlorophenyl laurate) 1825-21-4 (pentachloroanisole) The rate of photodecomposition increases with pH (t1/2 100 hr at pH 3.3 and 3.5 hr at pH 7.3). Complete decomposition in soil suspensions takes >72 days. Although enriched through the food chain, it is rapidly eliminated after discontinuing the exposure (t1/2 = 10- 24 h for fish). It has been proved to be acutely toxic to aquatic organisms and have certain effects on human health, at the time that exhibits off-flavour effects at very low concentrations. PCP is an aromatic hydrocarbon of the chlorophenol family and was first introduced for use as wood preservative in the 1930’s. Since its introduction, PCP has had a variety of other applications (biocide, pesticide, disinfectant, defoliant, anti-sapstain agent, anti-microbial agent and used in the production of pentachlorophenyl laurate). The salt sodium pentachlorophenate (Na-PCP) was used for similar purposes as PCP and readily dissociates to PCP. The ester pentachlorophenyl laurate (PCPL) was used in textiles. PCP is produced by reacting chlorine with phenol at high temperatures in the presence of a catalyst. Contaminants including hexachlorobenzene, dioxins and furans are produced in the manufacturing process. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A9 Pentachlorobenzene is also suspected to be present. These compounds are inherently toxic, as well as environmentally persistent and their presence may increase the ecological risk associated with the use ofPCP. PCA is not used as a commercial chemical or pesticide and is not released directly into the environment. It can be produced through the transformation of PCP. PCA may result from the degradation of structurally related chlorinated hydrocarbons, such as PCP, hexachlorobenzene (HCB), lindane (HCH), and pentachlorobenzene (PCNB). Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds PFOA, its salts and PFOA-related compounds are used widely in the production of fluoroelastomers and fluoropolymers, for the production of non–stick kitchen ware, food processing equipment. PFOA-related compounds, including side-chain fluorinated polymers, are used as surfactants and surface treatment agents in textiles, paper and paints, firefighting foams. PFOA has been detected in industrial waste, stain resistant carpets, carpet cleaning liquids, house dust, microwave popcorn bags, water, food, and Teflon. Unintentional formation of PFOA is created from inadequate incineration of fluoropolymers from municipal solid waste incineration with inappropriate incineration or open burning facilities at moderate temperatures. CAS No. 335-67-1 PFOA is highly stable and persistent in the environment with the capacity to undergo long range transport. This is evidenced by monitoring data of PFOA in air, water, soil/sediment and biota in both local and remote locations like the Arctic. PFOA can bioaccumulate and biomagnify in air-breathing mammals and other terrestrial species including humans. PFOA exhibits adverse effects for both terrestrial and aquatic species. PFOA is identified as a substance of very high concern with a persistent, bioaccumulative and toxic structure for the environment and living organisms. PFOA-related compounds are released into the air, water, soil and solid waste, and degrade to PFOA in the environment and in organisms. Major health issues such as kidney cancer, testicular cancer, thyroid disease, pregnancy-induced hypertension, high cholesterol have been linked to PFOA. Perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride PFOS is both intentionally produced and an unintended degradation product of related anthropogenic chemicals. The current intentional use of PFOS is widespread and includes: electric and electronic parts, firefighting foam, photo imaging, hydraulic fluids and textiles. PFOS is still produced in several countries. Various PFOS is produced synthetically from PFOSF, and PFOS can be derived from its salts when dissolved. The term "PFOS-related substances" is used for all substances that contain one or more PFOS groups (defined as C8F17SO2) and that can, or are assumed to, be degraded to PFOS in the environment. These PFOS-related substances are restricted through the listing of PFOSF, the basic material for their manufacture, and the listing of PFOS in Stockholm Convention. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A10 PFOS and PFOS-related substances are known with their high surface activeness and they have been added to Stockholm Convention Annex B because they meet the POP criteria of the Convention. PFOS and PFOS-related substances have an extensive usage area which is limited by the Convention, permits to intended purposes and special exemptions. Polychlorinated biphenyls These compounds are used in industry as heat exchange fluids, in electric transformers and capacitors, in hydralulic systems and as additives in paint, carbonless copy paper, and plastics. Of the 209 individual congeners of PCBs, 13 exhibit a dioxin-like toxicity. Various PCBs are the general name given to a group of chlorinated aromatic compounds which are the polychlorinated biphenyls. As, there are 10 places that chlorine atom can occupy in a biphenyl structure, it has 209 different congeners depending on the chlorine atoms situated in PCB structure. As chemical stability and flame retardancy properties and high dielectric constant are high PCBs are mainly and widely used in electrical and electronic equipments, additives in lubricants used in hydraulic machines and other applications for operational safety and maintenance. PCBs are used as dielectric fluid in transformers and capacitors, heat transfer fluid in industries. Moreover, they are also used in carbonless copy paper, insulating materials and plastics. PCBs are highly dangerous in nature due to its stable structure and persistent properties and are subjected to long range transportation. Also, like other POPs compounds PCBs tend to accumulate in fatty tissues of organisms. Other than direct production, PCBs may also be produced as a by-product in PVC manufacturing, pesticide production or waste incineration process. Moreover, when the optimum conditions for incineration are not reached, i.e. retarded combustion PCDDs and PCDFs are released. Polychlorinated naphthalenes Polychlorinated naphthalenes (PCNs) are halogenated organic compounds. PCNs are divided into eight homologue groups, based on the number of chlorine atoms in the molecule. These homologue groups are referred to using the prefixes mono to octa- (e.g. mono-CNs, di-CNs, etc). Physical-chemical properties vary considerably due to the degree of chlorine substitution. Tri-to octa-CNs are very lipophilic and their water solubility and vapour pressure decrease with the degree of chlorination. Various CAS No: 70776-03-3 (chlorinated naphthalenes) PCNs had various uses similar to PCBs, which gradually replaced PCNs in many applications. Characteristic functions of PCN formulations were electric insulation, flame retardation and biocidal protection of goods. Until known global production virtually stopped in many countries, having drastically decreased already by the late 1970s, some 150–400 kilotons had been produced worldwide. While the commercial PCN manufacture in the UNECE region has drastically declined since their large-volume production in the first half of the 20th century, the major current source of PCNs is probably waste incineration. Releases from former uses of PCNs or as impurities of technical PCB contained in landfills or old appliances are plausible but difficult to assess. Polycyclic aromatic hydrocarbons PAHs are a group of compounds consisting of two or more fused aromatic rings. Most of these are formed during incomplete combustion of organic material and the composition of PAHs Various National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A11 mixture varies with the source(s) and also due to selective weathering effects in the environment. Some of them are produced. Persistence of the PAHs varies with their molecular weight. The low molecular weight PAHs are most easily degraded. The reported half-lives of naphthalene, anthracene and benzo(e)pyrene in sediment are 9.43 and 83 hours, respectively, whereas for higher molecular weight PAHs, their half-lives are up to several years in soils/sediments. The BCFs in aquatic organisms frequently range between 100 – 2 000 and it increases with increasing molecular size. Due to their wide distribution, the environmental pollution by PAHs has aroused global concern. The acute toxicity of low PAHs is moderate, whereas the higher PAHs exhibit higher toxicity. The critical effect of many PAHs in mammals is their carcinogenic potential. The metabolic action of these substances produces intermediates that bind covalently with cellular DNA. IARC has classified benz[a]anthracene, benzo[a]pyrene, and dibenzo[ah]anthracene as probable carcinogenic to humans. Benzo[b]fluoranthene and indeno-[123-cd]pyrene were classified as possible carcinogens to humans. Short-chain chlorinated paraffins Polychlorinated alkanes (CxH(2x y+2)Cly), in the case of SCCPs alkanes with C10-13. They are manufactured by chlorination of liquid n-alkanes or paraffin wax and contain from 30 to 70% chlorine. The products are often divided in three groups depending on chain length: short chain (C10 – C13), medium (C14 – C17) and long (C18 – C30) chain lengths. 85535-84-8 The largest application of CPs is as a plasticizer, where only MCCPs are used generally in conjunction with primary plasticizers such as certain phthalates in flexible PVC. The chlorinated paraffins also impart a number of technical benefits, of which the most significant is the enhancement of flame retardant properties and extreme pressure lubrication. CPs may be released into the environment from improperly disposed metal-working fluids or polymers containing chlorinated paraffins. Loss of chlorinated paraffins by leaching from paints and coatings may also contribute to environmental contamination. Short chain CPs with less than 50 % chlorine content seem to be degraded under aerobic conditions. CPs are bioaccumulated and both uptake and elimination are faster for the substances with low chlorine content. The acute toxicity of CPs in mammals is low with reported oral LD50 values ranging from 4 - 50 g kg 1 bw, although in repeated dose experiments, effects on the liver have been seen at doses of 10 – 100 mg kg 1 bw.day 1 . Short-chain and mid-chain grades have been shown, in laboratory tests, to show toxic effects on fish and other forms of aquatic life after long-term exposure. The NOEC identified in the EU risk assessment for the most sensitive aquatic species tested was 5 μg l 1 Technical endosulfan and its related isomers Widely used to control insects as an insecticide. It was being used since 2009 on grains, fruits, vegetables, forest products and in greenhouses until it is banned. 959-98-8 33213-65-9 According to the risk profile on endosulfan is persistent in the atmosphere, sediments and water. Endosulfan bioaccumulates and has the potential for long-range transport. It has been detected in air, sediments, water and in living organisms in remote areas, such as the Arctic, that are areas where endosulfan never been used. Endosulfan is toxic to humans and has been shown to have adverse effects on a wide range of aquatic and terrestrial organisms. Exposure to endosulfan has been linked to congenital physical disorders, mental retardations and deaths in farm workers and villagers in developing countries in Africa, Asia and Latin America. Endosulfan sulfate shows toxicity similar to that of endosulfan. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A12 Toxaphene This insecticide a non-systemic and contact effective insecticide, used on cotton, cereal grains, fruits, nuts, and vegetables. It has also been used to control ticks and mites in livestock. 8001-35-2 It becomes bioconcentrated in aquatic organisms. It can be carried through the atmosphere. High frequency chromosome aberration was observed on eight female workers, who had been working on a Toxaphene applied field with 2 kg ha-1 dosage compared with control group. IARC classified Toxaphene as possible human carcinogen. Its half-life in soil can vary from 100 days to 12 years depending on the soil type and climate. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A13 Annex II: Country Profile Governmental and Executive structure Turkey is integrated to the western world by being a member of European Council, NATO, OECD, AGIT AND G-20. Turkey is a privileged member of European Economic Community since 1963 and a member of Customs Union since 1995; started negotiating to be a full member of European Union. Also Turkey developed cultural, politic, economic and industrial contacts by joining Turkish Council, Turkish Culture and Art Collective Administration, Islam Collaboration Organization and Economic Collaboration Organization Demography Population is 83 154 997 by year 2019. Latest census show that the 92.8% of the population lives in provinces and counties. 23 province has a population over 1 million and 20 province has a population between 500 000 and 1 million. Only 3 provinces’ population is under 100 000. Most populated 5 provinces of Turkey are Istanbul (15.5 million), Ankara (5.6 million), Izmir (4 million), Bursa (3 million) and Antalya (2.5 million). There are significant differences between geological regions in population and population density. Physical factors (climate properties, geographical formations, soil characteristics) and human factors (industrialization, agriculture, underground resources, tourism, transportation) effects cause these differences. Maximum population rate is at Marmara Region and the minimum ratio is at East Anatolian Region. Approximate lifetime for men is 76 and 81 for women. Economy Turkey placed 13th in gross domestic product (purchasing power parity) and 19th in gross domestic product (nominal). Important sectors of Turkey are banking, construction, major appliances, electronics, textile, petroleum refining, petrochemical products, food, mining, iron-steel, machine industry, tourism and automotive. Geography Turkey is located in 36 and 42 degrees Northern Latitudes and 26-45 Eastern Longitudes and shaped like a rectangle. There is a 75 minutes of time difference between east and west sides and it is 1 600 km wide. It has a 783 562 km² projection area and it has the 37th biggest projection area in the world. It is surrounded by three seas; Aegean Sea on west, Black Sea in north and Mediterranean in south. It has Marmara Sea at northeast side. Turkey is a Eurasian country which has lands on two continents. 97. 5% of its land located in Asia, named Anatolia. The remaining 3% is located in Europe and it is called as East Thrace or Rumelia side. Dardanelles and Bosphorus separate European and Asian lands and links Black Sea and Aegean with Marmara Sea. Bozcaada and Gokceada, are two islands of many that Turkey have in Aegean. Turkey has its Bulgarian and Greek borders at East Thrace. Neighboring Georgia at northeast; Armenia, Azerbaijan and Iran at east, Iraq and Syria at southeast. Average elevation of the country is 1 132 meters. North Anatolian Mountains lined up in north and Taurus Mountains lined up at south, southeast and east sides of Turkey. The elevation level mostly increases from west to east therefore; the highest elevation level is at the east side of Turkey. The National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A14 Mountain Ararat within the boundaries of Agri is the highest mountain of the country. The biggest natural lake is Lake Van. The rivers Fırat, Dicle, Aras and Kura rise from Turkey but flow through borders to other countries. Biggest river rising from Turkey and flows to our borders is Kızılırmak. Turkey is separated to seven geographical regions. These regions are Mediterranean, East Anatolia, Aegean, Southeastern Anatolia, Central Anatolia, Black sea and Marmara regions. Black Sea region lies up through North Anatolia and one-sixth of the total surface area. Turkey is placed on several fault lines and has several dormant volcanos. Many earthquakes occurred in history which are 1939 Erzincan Earthquake, 1943 Tosya-ladik Earthquake, 1999 Golcuk Earthquake causing loss of many lives. Climate Three climate types could be observed in Turkey. In Aegean and Mediterranean shores has the Mediterranean climate characterized by hot and dry in summer, warm and rainy in winter. In Black Sea shores, Black Sea climate, which has a temperate climate and is rainy in every season, are observed. Natural vegetation is forest. Black Sea shores are the only region which is rainy during all year in Turkey and receives 2 000 - 2 500 mm rain per year. In Marmara shores located between Aegean and Black Sea, transition climate could be observed. Mediterranean climate is observed in South Shores, Black Sea climate in North Shores and Continental Climate is observed in northwest of Marmara Sea. Snowfall could only be seen a few days in Marmara and Black Sea regions and it only lasts for a few days. Mountains are parallel to the shores and prevent the temperate weather to reach to the middle. Continental Climate is observed in Central Anatolia, Southeast Anatolia and East Anatolia. In the continental climate temperature differences during day and night is high; hot and dry in summer, cold and snowy during winter. Severe weather conditions could be observed in Eastern sides of Turkey. In East Anatolia temperatures can decrease down to -30°C and -40°C (−22 °F to −40 °F) and snow is present at least 120 days in a year. Average temperature in west is 1°C (34 °F). However, it is hot and dry in summer. All across the country usually the dryest months are July and August as the temperature can get over 30 °C (86 °F) during the day, and the rainiest month is May. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A15 Annex III: Legal Framework on POPs There are numerous national legislations regarding management of chemicals and wastes, production of pesticides, control of import of products. These legislative instruments are described below (with their date and number of the Official Gazette in which regulation was published) and provisions of the Stockholm Convention are presented in Table AIII/1. Environmental Law (11.08.1983/2872), Council of Ministers (MoEU); aims to establish a legal framework on protecting the environment, preventing environment from pollution, rehabilitation of the environment from any former pollution, improving the environmental status, using the natural resources and energy efficiently, reduction of the waste amount at the source generated as a result of an activity and recovery of the waste generated via using environmentally sound technologies, regulating and taking measures to sustain the good status of the environment to reserve its integrity for the next generations. Article 2 of the law defines hazardous waste and Article 13 of the Law sets the procedures and principles regarding the identification, production, import, use, quantifying, labeling, packaging, classification, storage, risk assessment, transportation and exportation of hazardous chemicals. Law on the Approval of Ratification of the Stockholm Convention (30.07.2009, 5871), Council of Ministers (MoEU); on Persistent Organic Pollutants states that the ratification of Stockholm Convention by Turkey was approved. Law on the Approval of Ratification of the Basel Convention (30.12.1993, 3957), Council of Ministers (MoEU); on the Control of Trans-boundary Movements of Hazardous Wastes and their Disposal states that the ratification of Basel Convention by Turkey was approved. Law on the Approval of Ratification of the Rotterdam Convention (03.04.2017, 6988), Council of Ministers (MoEU); on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade states that the ratification of Rotterdam Convention by Turkey was approved. Law on Veterinary Services, Plant Health, Food and Feed (13.06.2010, 5996), Council of Ministers (MoEU); sets the principles of production, import, use, packaging, labeling, transport, storage, certified or non-certified sale, certification, control and supply of pesticides including POPs and provides the legal basis for the relevant by-laws. By-law on Persistent Organic Pollutants (14.11.2018, 30595), MoEU sets the principles of; o implementing and enforcing the provisions of Stockholm Convention, o prohibiting the production, placing on the market and use of POPs, o restricting and gradually eliminating POPs, National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A16 o reducing of POPs releases, o managing the wastes containing POPs. Draft By-law on Export and Import of Some Hazardous Chemicals (to be published in 2020), MoEU will implement and enforce the provisions of Rotterdam Convention and set the principles of Prior Informed Procedure in international trade of chemicals including POPs. By-law on Registration, Evaluation, Authorization and Restriction of Chemicals (23.06.2017, 30105), MoEU sets the principles of; o gathering and presenting data on production and import of chemicals and controlling of the associated risk caused by chemicals, o managing and controlling classification, packaging and labeling of hazardous substances on the market, o compilation and distribution of material safety data sheets, o restriction and prohibition the production, use and placing on the market of several industrial substances. By-law on Control of Polychlorinated Biphenyl (PCB) and Polychlorinated Terphenyl (PCT) (27.12.2007, 26739), MoEU sets methods and principles of disposal of PCB containing equipment and prohibits the production and import of PCBs. By-law on Waste Management (02.04.2015, 29314), MoEU sets the general principles for management of dangerous wastes including POPs. By-law on Control of Waste Oils (30.06.2008, 26952), MoEU is limiting the amount of PCB in the waste oil, prevention of flaming of these oils and disposal of the oil in an environmentally sound manner. By-Law on Control of Waste Electrical and Electronic Equipment (22.05.2012, 28300), MoEU sets the methods and the principles of disposal of the waste electric and electronic equipment containing POPs and bans the use of several POPs in electric and electronic articles. By-law on Landfilling of Wastes (26.0.2010, 27533), MoEU regulates the landfilling of POPs containing waste. By-law on the Incineration of Wastes (06.10.2010, 27721), MoEU regulates the basic principles of incineration of hazardous waste containing POPs. By-law on Control of Pollution Caused by Dangerous Substances in Aquatic Environment (26.11.2005, 26005), MoEU sets the principles on determination of National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A17 water pollution caused directly by POPs or POPs contaminated waste and their reduction. By-law on Control of Soil Pollution and Sites Contaminated by Point Sources (08.06.2010, 27605), MoEU sets the basic principles and the methodologies to determine the possibly contaminated or contaminated sites, cleaning methodologies and monitoring of the sites in a sustainable manner. By-law on Control of Air Pollution Arising from Industrial Facilities (03.07.2009, 27277), MoEU determines the emission limits of unintentional produced POPs (u POPs) from various industrial applications along with other control of other air pollutants. By-law on the Prevention and Reduction of the Effects of Major Industrial Accidents (02.03.2019, 30702), MoEU sets methods and principles concerning the necessary measures to ensure the efficient and continual prevention of the major industrial accidents in the facilities in which u-POPs can be formed as by-products of processes. By-law on Licensing and Placing on the Market of Plant Protection Products (PPPs) (09.11.2017, 30235), MoAFA covers the licensing of PPPs including POPs pesticides, the establishment of essays for licensing and the introduction of PPPs to the market. By-law on Controlling the Plant Protection Products (06.07.2011, 27939), MoAFA covers the procedures and principles regarding the banning/restricting, quality control, packaging, labeling, promotional banner, brochure, internet publication control of the PPPs including POPs licensed by the Ministry, and the application of the samples taken for the purpose of tests and control and the results of the analyzes to be performed. By-law on Wholesale, Retail Selling and Storage of Plant Protection Products (PPPs) (13.02.2019, 30685), MoAFA sets the principles of safe storing of PPPs including POPs. By-law on the Import of Plant Protection Products and Their Raw Materials (14.12.2018, 30625), MoAFA sets the principles of issuing and auditing the import permits of licensed PPPs including POPs and their raw materials. By-law on Biocidal Products (BPs) (31.12.2009, 27449), MoH sets the principles of production, import and placing on the market of BPs including POPs. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A18 By-law of Transportation of Dangerous Goods by Road (24.04.2019, 30754), MoTI sets the principles of transport of dangerous goods (including hazardous chemical substances like POPs) by public roads; conducting in a safe, secure and orderly manner without harming human health and other living assets and the environment in accordance with The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR, ECE/TRANS/275). Communiqué on Auditing of Import of Chemicals that are Controlled for Environmental Protection (27.12.2019, 30991), MoT regulates the import of hazardous chemicals including POPs that are banned or restricted by relevant institutions. The communiqué is annually updated. Communiqué on Auditing of Import of Plant Protection Products that are Controlled by the Ministry of Agriculture and Forestry Affairs (27.12.2019, 30991), MoT regulates the import of pesticides including POPs that are banned or restricted by the Ministry of Agriculture and Forestry Affairs. The communiqué is annually updated. National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A19 Table AIII/1. Turkish Legislations in accordance with Stockholm Convention’s Legal Liabilities Article No Requirement Responsible Institution Fulfillment Related Legislation 3 1.a Prohibit and/or take the legal and administrative measures necessary to eliminate i. production and use of the chemicals listed in Annex A MoEU (industrial chemicals) MoH (industrial chemicals) Prohibited Annex A chemicals in industrial category are as follows; Aldrin, Alpha Hexachlorocyclohexane, Beta Hexachlorocyclohexane, Chlordane, Chlordecone, Dieldrin, Endosulfan, Endrin, Heptachlor, Hexabromobiphenyl, Hexachlorobenzene, Hexachlorobutadiene, Hexabromocyclododecane, Lindane, Mirex, PCBs, Pentachlorobenzene, Pentachlorophenol and its salts and esters, Technical Endosulfan and its related isomers, Polychlorinated naphthalenes, Toxaphene. Prohibition of the production of electrical and electronic equipment containing and PBDEs (with some exceptions) Prohibition of the production of PCBs Prohibition of the use of α-HCH in cosmetic products By-law on By law on Persistent Organic Pollutants By-law on Control of Waste Electrical and Electronic Equipment By-law on Control of PCBs and PCTs By-law on Cosmetics MoAFA (pesticides) According to the relevant legislation, production, manufacturing, marketing (including import) and use of unregistered plant protection products within the territory of the country are prohibited. Prohibited POPs in pesticide category are as follows; Aldrin, Alpha hexachlorocyclohexane, Beta hexachlorocyclohexane, Chlordane, Chlordecone, Dieldrin, Endrin, Heptachlor, Hexachlorobenzene, Lindane, Mirex, Pentachlorobenzene. Pentachlorophenol and its salts and esters, Technical Endosulfan and its related isomers, Toxaphene. By-law on Licensing and Placing on the Market of Plant Protection Products By-law on Wholesale, Retail Selling and Storage of Plant Protection Products By-law on Controlling the Plant Protection Products National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A20 Table AIII/1. Turkish Legislations in accordance with Stockholm Convention’s Legal Liabilities Article No Requirement Responsible Institution Fulfillment Related Legislation ii. import and export of the chemicals listed in Annex A MoEU (industrial chemicals) MoEU (industrial chemicals) MoEU (industrial chemicals) MoEU (hazardous wastes) MoT (industrial chemicals) MoEU (industrial chemicals) Imports of following Annex A Chemicals are prohibited: Aldrin, Alpha Hexachlorocyclohexane, Beta Hexachlorocyclohexane, Chlordane, Chlordecone, Dieldrin, Endosulfan, Endrin, Heptachlor, Hexabromobiphenyl, Hexachlorobenzene, Hexachlorobutadiene, Hexabromocyclododecane, Lindane, Mirex, PCBs, Pentachlorobenzene, Pentachlorophenol and its salts and esters, Technical Endosulfan and its related isomers, Polychlorinated naphthalenes, Toxaphene. Prohibition of the import of PCBs Prohibition of the import and export of hazardous wastes containing POPs Prohibition of the import of electrical and electronic equipments containing hexabromobiphenyl and PBDEs in (with some exceptions) The Communiqué is a secondary legislation regulating the legislative procedures for Customs controls while importing hazardous chemicals. Prohibition of export of Annex A chemicals will be regulated by a Draft by-law which will be come into force in 2020. By-law on By law on Persistent Organic Pollutants By-law on Control of PCBs and PCTs By-law on Waste Management By-law on Control of Waste Electrical and Electronic equipment Communiqué on Auditing of Import of Chemicals that are Controlled for Environmental Protection Draft By-Law on Import and Export of Some Hazardous Chemicals According to the relevant legislation, imports of unregistered plant protection products within the territory of the country are prohibited. Prohibited POPs in pesticide category are By-law on Licensing and Placing on the Market of Plant Protection Products National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A21 Table AIII/1. Turkish Legislations in accordance with Stockholm Convention’s Legal Liabilities Article No Requirement Responsible Institution Fulfillment Related Legislation MoAFA (pesticides) MoT (industrial chemicals) as follows; Aldrin, Alpha hexachlorocyclohexane, Beta hexachlorocyclohexane, Chlordane, Chlordecone, Dieldrin, Endrin, Heptachlor, Hexachlorobenzene, Lindane, Mirex, Pentachlorobenzene. Pentachlorophenol and its salts and esters, Technical Endosulfan and its related isomers, Toxaphene. There is a special application for export of hazardous pesticides. Exporters planning to export of prohibited pesticides, they must inform and take permission to export from the National Authority of Importing country and the Ministry of Agriculture and Forestry Affairs simultaneously. The Communiqué is a secondary legislation regulating the legislative procedures for Customs controls while importing plant protection products. By-law on Wholesale, Retail Selling and Storage of Plant Protection Products By-law on Controlling the Plant Protection Products Communiqué on Auditing of Import of Plant Protection Products that are Controlled by the Ministry of Agriculture and Forestry Affairs 3 1.b Restrict the production and use of the chemicals listed in Annex B MoEU Restricted Annex B chemicals in industrial category are as follows; PFOS. Production and use of DDT in industrial category are prohibited By-law on By law on Persistent Organic Pollutants MoAFA Banned (hence restricted) Annex B chemicals in pesticide category are as follows; DDT, PFOS. By-law on Licensing and Placing on the Market of Plant Protection Products By-law on Controlling the Plant Protection Products 3 2.a Take the necessary measures to ensure that a chemical listed in Annex A or Annex B is imported only i. for the purpose of environmentally sound disposal MoEU MoEU Imports of hazardous wastes are prohibited (covering wastes which includes Annex A or B chemicals) Prohibition of the import of PCBs By-law on Waste Management By-law on Control of PCBs and PCTs By-law on By law on Persistent Organic Pollutants ii. for a use or purpose which is permitted for that Party under Annex A or Annex B National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A22 Table AIII/1. Turkish Legislations in accordance with Stockholm Convention’s Legal Liabilities Article No Requirement Responsible Institution Fulfillment Related Legislation MoAFA There is no special exemption for acceptable purposes on POPs containing industrial chemicals and pesticides. By-law on Licensing and Placing on the Market of Plant Protection Products By-law on Controlling the Plant Protection Products 3 2.b Take measures to ensure that a chemical listed in Annex A or B for which production or use specific exemptions and/or acceptable purpose are in effect is exported only i. for the purpose of environmentally sound disposal MoEU MoAFA MoEU Prohibition of export of Annex A or B chemicals will be regulated by a Draft by-law which will be come into force in 2020. Ensuring that the wastes containing POPs are export only for the purpose of environmentally soundly disposal Draft By-Law on Import and Export of Some Hazardous Chemicals By-law on Control of Wastes ii. to a party which is permitted to use that chemical iii. to a nonparty state by ensuring the environmental protection 3 2.c Take measures to ensure that a chemical listed in Annex A for which production or use specific exemptions are no longer in effect for any party is not exported from it except for the purpose of environmentally soundly disposal MoEU MoAFA Ensuring that the wastes containing POPs are export only for the purpose of environmentally soundly disposal There is a special application for export of hazardous pesticides. Exporters planning to export of prohibited pesticides, they must inform and take permission to export from the National Authority of Importing country and the Ministry of Agriculture and Forestry Affairs simultaneously. By-law on Control of Wastes By-law on Controlling the Plant Protection Products 3 3&4 Take measures to regulate the production and use of new industrial chemicals/pesticides which exhibit the characteristics of persistent organic pollutants MoEU MoAFA Once a new POPs chemical included to the annexes of the Stockholm Convention, then the Ministry of Environment and Urbanization starts the process of taking measures. The production of new pesticides is controlled. By-law on By law on Persistent Organic Pollutants By-law on Licensing and Placing on the Market of Plant Protection Products 5 a Develop an action plan to identify, characterize and address the release of Annex C chemicals including; i. evaluation of the current and projected releases; source inventory and release estimates MoEU Emission limits of unintentional produced POPs (PCDD, PCDF and PCB only) from various industrial applications were determined. Measures to ensure the efficient and continual prevention of the major industrial accidents in the facilities in which u-POPs can be formed as by products of processes were taken. By-law on Control of Air Pollution Arising from Industrial Facilities By-law on the Prevention and Reduction of the Effects of Major ii. evaluation of the effectiveness of the existing legislation National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A23 Table AIII/1. Turkish Legislations in accordance with Stockholm Convention’s Legal Liabilities Article No Requirement Responsible Institution Fulfillment Related Legislation iii. strategies to meet the obligations of the Convention Industrial Accidents iv. awareness raising activities v. periodic review of the activities vi. a schedule for the implementation of the action plan 5 b Promote the application of available, feasible and practical measures to reduce the releases MoEU The Ministry promotes available, feasible and practical measures (including Best Available Techniques) to reduce the releases of u-POPs listed in Annex-C of the SC. By-law on By law on Persistent Organic Pollutants 5 c Promote the development and use of substitute materials to prevent the formation of Annex C chemicals MoEU While the Ministry is considering recommendations to build new industrial facilities or to significantly change existing facilities using processes that release the chemicals listed in Annex-C of the SC, alternative processes, techniques that have similar uses but prevent the formation or release of substances listed in Annex-C. The Ministry prepares guidelines on measures that prevent or minimize the formation or release of substances listed in Annex-C of the SC. By-law on By law on Persistent Organic Pollutants 5 d, e Promote the use of best available techniques and best environmental practices to control and eliminate the production and releases of Annex C chemicals MoEU The Ministry promotes the Best Available Techniques to reduce the releases of u-POPs listed in Annex-C of the SC. By-law on By law on Persistent Organic Pollutants 6 1.a Develop appropriate strategies for identifying i. stockpiles containing Annex A/B chemicals MoEU In case there is a stockpile that contains any POPs substance that is not allowed to be used, the owner of the stockpile manages this stockpile as hazardous waste and takes the necessary precautions to protect human health and the environment. By-law on By law on Persistent Organic Pollutants ii. products and articles in use and wastes containing Annex A/B/C chemicals MoEU There are reduction calendars for each POPs chemicals, products, articles in use and wastes containing POPs chemicals. By-law on By law on Persistent Organic Pollutants 6 1.b Identification of the stockpiles of Annex A/B chemicals MoEU Most of the old stockpiles have been identified. By-law on By law on Persistent Organic Pollutants 6 1.c Manage stockpiles in an environmentally soundly manner MoEU Most of the old stockpiles have been disposed in environmentally soundly manner according to the international standards. By-law on By law on Persistent Organic Pollutants 6 1.d Take measures to ensure that POPs containing wastes are i. handled, collected, transported and stored in an environmentally soundly manner MoEU MoEU sets the general principles for management of dangerous wastes including POPs. MoEU limited the amount of PCB (only By-law on Waste Management By-law on Control of Waste National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A24 Table AIII/1. Turkish Legislations in accordance with Stockholm Convention’s Legal Liabilities Article No Requirement Responsible Institution Fulfillment Related Legislation ii. disposed appropriately or environmentally soundly considering the international regulations on hazardous waste management which is one of the POPs chemicals) in the waste oil, prevention of flaming oils and disposal of the oil in an environmentally sound manner. MoEU set the methods and the principles of disposal of the waste electric and electronic equipment containing POPs and bans the use of several POPs in electric and electronic articles. The related POPs chemicals are PBB, PCB and PBDE. MoEU is regulating the landfilling of hazardous wastes containing POPs. MoEU is regulating the basic principles of incineration of hazardous waste containing POPs and it also sets emission limits of unintentional produced POPs (PCDD and PCDF). The hazardous wastes including POPs chemicals are not transported across international boundaries without considering the international rules and regulations related to Basel Convention (as Turkey is a party to the convention). Oils By-law on Control of Waste Electrical and Electronic Equipment By-law on Landfilling of Wastes By-law on the Incineration of Wastes By-law on Waste Management iii. not permitted to be disposed of in such a way that can be resulted in the recovery, reuse, recycling and reclamation of the POPs iv. not transported across international boundaries without considering the international rules and regulations 6 1.e Endeavour to develop appropriate strategies to identify the contaminated sites MoEU MoEU set the basic principles and the methodologies to determine the possibly contaminated or contaminated sites, cleaning methodologies and monitoring of the sites in a sustainable manner. In this scope, Contaminated Sites Information System was established. By-law on Control of Soil Pollution and Sites Contaminated by Point Sources 7 1 Develop and update a review a national implementation plan in line with the provisions of the Convention MoEU First and second national implementation plans have been submitted to the secretariat in 2011 and 2016 respectively. By-law on By law on Persistent Organic Pollutants 7 3 Integrate national implementation plans in sustainable development strategies MoEU - 9 1 Undertake information exchange on reduction/elimination of the production, use and release of POPs and alternatives of POPs MoEU The Ministry and related institutions with the help of other countries and international organizations are engaging information exchange activities regarding to minimize, eliminate and determine the persistent organic pollutants and their alternatives, risks associated with these alternatives and economic and social costs. By-law on By law on Persistent Organic Pollutants 10 1 Enhance the awareness of public and decision makers on POPs issue MoEU Regarding persistent organic pollutants, the Ministry and the related institution encourage and facilitate; a) Reducing the health and environmental impacts, alternatives, manufacturing, uses and emissions of persistent organic pollutants, especially for policy makers, decision-makers and vulnerable groups (groups that require special By-law on By law on Persistent Organic Pollutants National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A25 Table AIII/1. Turkish Legislations in accordance with Stockholm Convention’s Legal Liabilities Article No Requirement Responsible Institution Fulfillment Related Legislation policy, such as young, old, disabled, pregnant or breastfeeding workers and female workers), b) Implementing awareness programs related to elimination, c) Providing information to the public, d) Training including employees, scientists, educators and technical and administrative staff. 10 5 Develop mechanisms to collect information on estimates of annual quantities of POPs like pollutant release and transfer registers MoEU - 11 1 Encourage research, development and monitoring activities on POPs All relevant governmental institutions Also the only monitoring procedure described in the Turkish By-law on POPs is for u-POPs. Although they are not specific to POPs, Turkish Scientific and Technical Research Council provides support to research activities. 15 1 Report to the Conference of Parties on the measures taken to implement the Convention and the effectiveness of these measures All relevant governmental institutions The relevant institution transmits information about the implementation of the SC to the Ministry every three years, including information on violations and penalties. The relevant institutions, manufacturers and importers provide statistical data to the Ministry each year regarding the total production and placing on the market of any POPs substances. Every three years, the relevant institution provides the Ministry with the following information; a) Information compiled from notifications regarding inventories, b) Information compiled from prepared release inventories, c) Information compiled from prepared u-POPs inventories. Regarding to the information compiled above, the Ministry prepares a report at the intervals to be determined by the Conference of the Parties on the basis of the information provided under the inventory and transmits it to the Secretariat. By-law on By law on Persistent Organic Pollutants 15 2 Provide statistical data to the secretariat on the production, import, export of POPs MoEU Whenever it is requested by the Secretariat, the Ministry provides statistical data to the secretariat on the production, import, export of POPs. By-law on By law on Persistent Organic Pollutants 16 2 Conduct monitoring studies to obtain meaningful data for evaluating the effectiveness of the Convention All relevant governmental institutions Whenever it is requested by the Secretariat, the Ministry conducts monitoring studies. By-law on By law on Persistent Organic Pollutants National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A26 Annex IV: National POPs Inventory Table AIV/1: Import and export amounts for pentachlorophenol and its salts and esters (TURKSTAT, 2020) HS codes Name of the Chemicals Activity Year (kg) Residual 2017 2018 2019 2908.11 Pentachlorophenol import 1 3 1 +5 export 2908.19 Pentachloropenol salts and esters import - - export - - Total +5 Table AIV/2. c-PentaBDE inventoried in the transport sector of Turkey for 2012-2019 (the fifth column is the difference between 3 rd and 4 th column) in kg POP-PBDEs in vehicles currently in use in inventory year (2018) (kg)* POP-PBDEs imported in vehicles only in the inventory year (2019) (kg)** POP-PBDEs in end-of life vehicles generated between 2012-2019 (kg)*** POP-PBDEs recycled from transport sector between 2012-2019 (kg)**** POP-PBDEs disposed of from the transport sector between 2012 2019 (kg)**** Inventoried c PentaBDE 92,919.2 1.3 9,183.3 4,677.6 4,505.7 tetraBDE 29,734.1 0.4 2,938.7 1,496.8 1,441.8 pentaBDE 52,034.7 0.8 5,142.6 2,619.5 2,523.2 hexaBDE 8,362.7 0.1 826.5 421.0 405.5 heptaBDE 464.6 0.0 45.9 23.4 22.5 * TURKSTAT database for vehicles currently in use ** TURKSTAT special trade system foreign trade database *** TURKSTAT database for deregistered vehicles **** Ministry of Environment and Urbanization ELV recycle data, < 5000 kg ELV, assuming > 5000 kg c-pentaBDE contribution negligible Table AIV/3. Estimated c-OctaBDE (kg) and corresponding POP-PBDE content of CRT monitors in Turkey by 2019 c-OctaBDE heptaBDE homologue hexaBDE homologue 0.00087 ton/ton application 92,200 39,700 10,100 0.00254 ton/ton application 269,300 115,800 29,600 Table AIV/4. c-OctaBDE inventoried in CRT monitors in Turkey between 2013-2020 years POP-PBDEs Imported in 2019 2020 * POP-PBDEs in stocks for inventory year of 2020** POP-PBDEs entering the waste stream in 2020*** POP-PBDEs in recycled polymers for years of 2015-16-17-18**** Number of computers 245 14,136,349.49 1,742,582.493 2,614,432.6 c-OctaBDE (kg) 1.6 92,239.7 11,370.4 17,059.2 hexaBDE (kg) 0.2 10,146.4 1,250.7 1,876.5 heptaBDE (kg) 0.7 39,663.1 4,889.3 7,335.4 octaBDE (kg) 0.6 32,283.9 3,979.6 5,970.7 * TURKSTAT special trade system database, HS codes of 852841, 852842, and 852849 ** Calculated according to the Guide Document, Asian Regional Constant of 0.17 CRT/capita *** Calculated according to the Guide Document, 8 years of lifetime assumption **** Calculated using MOTAT KDS, with EU waste codes of 200135, 160213 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A27 Table AIV/5. ABS imports to Turkey by countries and by years (in kg) [2019 and 2020 values are temporary] TURKSTAT data with HS code of 39033000 ABS import Brazil Cambodia Japan Republic of Korea Taiwan Total 2000 200 0 25,754 6,126,821 2,658,003 33,473,837 2001 0 0 17,700 6,099,626 2,212,944 23,296,074 2002 0 0 116,975 8,848,169 1,453,642 32,067,630 2003 0 0 90,075 11,430,075 2,733,675 38,332,118 2004 0 0 157,852 8,712,493 3,589,148 50,688,439 2005 0 0 218,809 7,927,881 2,540,098 53,863,172 2006 0 0 361,740 12,750,081 3,886,600 58,995,903 2007 0 0 177,196 24,743,024 4,703,841 66,284,382 2008 0 0 265,530 25,610,987 3,337,075 63,915,458 2009 0 0 257,713 29,793,366 3,434,912 64,118,882 2010 0 0 413,664 36,285,151 5,212,250 84,432,206 2011 0 0 353,234 45,661,678 6,851,100 87,315,158 2012 0 0 32,974 44,080,972 8,712,500 86,935,555 2013 0 0 99,094 57,080,129 8,222,350 99,393,058 2014 0 0 2,743 60,630,786 5,840,050 98,840,465 2015 0 0 4,100 72,512,659 7,588,274 110,932,682 2016 150 0 8,750 74,956,013 7,474,765 114,086,004 2017 0 0 15,100 79,876,430 10,402,475 132,340,858 2018 0 0 3,600 68,893,510 7,050,100 113,149,087 2019 0 0 20,980 76,010,628 8,761,950 120,254,962 2020 0 0 16,825 46,022,773 4,115,750 73,558,033 Table AIV/6. Estimated octaBDE entry to Turkey via direct import of ABS, assuming 1/3 of them contained octaBDE, TURKSTAT data on special trade system foreign trade database Year Estimated octaBDE entry (12 %) in tons Estimated octaBDE entry (18 %) in tons 2000 1,339.0 2,008.4 2001 931.8 1,397.8 2002 1,282.7 1,924.1 2003 1,533.3 2,299.9 2004 2,027.5 3,041.3 2005 427.5 641.2 2006 679.9 1,019.9 2007 1,185.0 1,777.4 2008 1,168.5 1,752.8 2009 1,339.4 2,009.2 2010 1,676.4 2,514.7 2011 2,114.6 3,172.0 2012 2,113.1 3,169.6 2013 2,616.1 3,924.1 2014 2,658.9 3,988.4 2015 3,204.2 4,806.3 2016 3,297.6 4,946.4 2017 3,611.8 5,417.6 2018 3,037.9 4,556.8 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A28 2019 3,391.7 5,087.6 2020 2,006.2 3,009.3 TOTAL 41,643.2 62,464.8 Table AIV/7. TURKSTAT Foreign Trade Statistics Import of Intermediate Goods Data on 382488 HS Code Import (kg) 2017 138,380 2018 43,531 2019 48,953 Total 230,864 Table AIV/8. TURKSTAT Foreign Trade Statistics Specific Trade System Data 382488 HS Code Import (kg) Export (kg) Net (kg) 2017 90,425 19,405 71,020 2018 22,844 139,799 -116,955 2019 237 3,092 -2,855 2020 - 361 -361 Total 113,506 162,657 -49,151 Table AIV/9. Recycled ELV’s ASR components and their corresponding estimated DecaBDE content with a constant of 0.625 g/kg (Morf et al. 2003) 16-01-04 code waste amount kg Corresponding ASR 25 % kg DecaBDE content coefficient per kg DecaBDE content kg 2015 37,180 9,295 0.625 g/kg 5,809 2016 28,280 7,070 0.625 g/kg 4,418 Table AIV/10. Recycled waste stream of the TV and Monitors of CRT, plasma, and LCD types in Turkey and estimated DecaBDE (Sakai et al. 2006) 20-01-35* kg 16-02-13* kg 20-01-35* units 1 16-02-13* units 1 Total estimated DecaBDE t 2015 5,873,993 4,982,427 524,463.7 444,859.6 145.4 2016 14,606,171 6,722,230 1,304,122 600,199.1 285.6 2017 9,519,039 7,582,704 849,914.2 677,027.1 229.0 2018 4,888,355 11,185,897 436,460.3 998,740.8 215.3 Total 34,887,558 30,473,258 3,114,961 2,720,827 875.4 * Calculated using MOTAT KDS 1 This is according to Kalmykova et al.’s (2015) study, conservative estimate of 6 kg/ unit LCD and 16.4 kg/ unit CRT, equal average of 11.2 kg/unit. Table AIV/11. Small household appliances, IT and telecommunication equipment and consumer equipment recycled (and disposal + recycle in parentheses) waste in kg in Turkey with corresponding DecaBDE content 20-01-35* waste (kg) DecaBDE content with 0.8 kg/t constant 2015 5,873,993 (5,879,684) 4,699.2 2016 14,606,171 (14,633,514) 11,684.9 2017 9,519,039 (9,534,677) 7,615.2 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A29 2018 4,888,355 (4,928,790) 3,910.7 Total 34,887,558 27,910 * Calculated using MOTAT KDS Table AIV/12. Number of building & construction material producing enterprises and their volume of productions*. Number of Enterprises Volume of Production (kg) Volume of sales (kg) Net (kg) 2012 14 166,679,990 136,317,583 30,362,407 2013 16 214,442,625 193,456,263 20,986,362 2014 20 207,224,453 191,236,835 15,987,618 2015 17 153,828,532 142,740,603 11,087,929 2016 34 192,709,313 190,117,379 2,591,934 2017 34 184,701,070 186,382,615 -1,681,545 2018 35 193,614,560 238,648,336 -45,033,776 Total 35 1,313,200,543 1,278,899,614 34,300,929 * TURKSTAT yearly industrial production database Table AIV/13. Velour pile fabrics (13.20.41) and cotton production related to the products (13.20.20.17.00 and 13.20.20.74.00) other than clothing and corresponding predicted DecaBDE amount* 13.20.41 m2 13.20.20.17.00 m2** 13.20.20.74.00 m2** DecaBDE t 2005 138,578,990 86,879,453 111,154,038 6,063.6 2006 47,576,676 100,667,470 52,684,851 3,127.5 2007 28,161,048 99,105,265 40,623,124 2,450.9 2008 27,201,509 96,804,326 43,085,083 2,427.7 2009 27,490,522 155,566,234 32,746,244 3,028.4 2010 32,356,634 83,055,798 34,908,888 2,294.4 2011 28,277,586 137,912,391 36,625,995 2,880.4 2012 31,056,838 192,804,878 40,692,178 3,675.6 2013 42,706,306 205,944,060 60,520,363 4,385.2 2014 51,343,614 184,222,507 54,196,463 4,268.4 2015 47,959,273 226,255,234 45,764,544 4,591.2 2016 40,800,201 183,201,700 50,800,681 3,937.5 2017 33,702,770 180,601,584 58,472,313 3,813.4 2018 69,264,374 199,781,791 81,111,618 5,259.1 Total 646,476,341 2,132,802,691 743,386,383 52,203.3 * TURKSTAT yearly industrial production database ** Product code for uses other than clothing Table AIV/14. Product codes and corresponding definitions of the companies the surveys sent Product Code Definition 13.96.14.00.00 Textile fabrics, impregnated, coated or covered n.e.c. 20.16.20.35.00 Expansible polystyrene, in primary forms 20.16.20.39.00 Polystyrene in primary forms, except EPS 20.16.20.50.00 Styrene-acrilonitrile copolymers, primary forms 20.16.20.70.00 Acrylonitrile-butadiene-styrene (ABS) copolymers, in primary forms 20.16.20.90.00 Polymers of styrene, in primary forms (excluding polystyrene, styrene-acrylonitrile (SAN) copolymers, acrylonitrile-butadiene-styrene (ABS) copolymers) 20.16.56.70.00 Polyurethanes, in primary forms 20.30.11.70.03 Paints and varnishes, incl. industry paints, electrostatics paints, polyurethane protective paints and etc., based on electrophoretic, dispersed or dissolved in an aqueous medium 22.21.10.90.00 Monofilament with any cross-sectional dimension > 1 mm; rods; sticks and profile shapes of plastics (excluding of polymers of ethylene, of polymers of vinyl chloride) 22.21.41.50.00 Cellular plates, sheets, film, foil and strip of polyurethanes 22.21.41.80.00 Cellular plates, sheets, film, foil and strip of plastics (excluding of polymers of styrene, of polymers of National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A30 vinyl chloride, of polyurethanes, of rengenerated cellulose) 22.21.42.79.00 Other plates, sheets, films, foil and strip, of polymerization products 22.29.29.90.00 Other articles of plastics or other materials 26.40.34.40.00 Colour video monitors with cathode-ray tube Table AIV/15. Flame retardants used in Turkey, their chemical base and amount used. Name Chemical Basis Amount used PES 1090 Non-halogenated, phosphorus based 2,000 tons/year ADDIFLAM 650 1,2-benzisothiazol-3(2H)-one, antimony trioxide 120,500 kg/year TCPP tris (1-chloro-2-propyl) phosphate 78,260 kg/year Nor 116 triazine derivative 1,500 kg/year ADDIFLAM PES LW92 phosphonic acid derivative 1,250 kg/year Orgaflame FR-33 ECO Water/halogen based, antimony mixed 360 kg/year RUCO FLAM PSC Alkyl phosphonate 120 kg/year POLYOL IXOL M 125 halogenated aliphatic polyether diol 71.986 kg/year Zinc phosphate Zinc phosphate 50 kg/year Aluminum trihydroxide Aluminum trihydroxide 20 kg/year Red phosphorus Red phosphorus 20 kg/year Ammonium polyphosphate Ammonium polyphosphate 20 kg/year Zinc borate Zinc borate 20 kg/year Halosite Halosite 20 kg/year 9-10-dihydro-9-oxa-10 phosphophenantrene-10-oxide 9-10-dihydro-9-oxa-10-phosphophenantrene-10-oxide 20 kg/year Non-halogenated FR Without halogen 5 kg/year Table AIV/16. The market data of Pre-mixed PS imported or produced in Turkey between the period of 2015-2018 (t/year) Market and HBCD Consumption (t/year.) 2015 2016 2017 2018 TOTAL EPS pre-mixed PS product amount 230,000 232,000 239,000 238,000 National Production 130,000 138,000 148,000 154,000 HBCD based flame retardant use 792.80 989.00 997.42 823.84 Imported Products 100,000 94,000 91,000 84,000 Import from EU 63,000 60,000 59,000 55,000 Predicted flame retardant use 567 540 531 495 Import from Far East 37,000 34,000 32,000 29,000 Predicted flame retardant use 278 255 240 218 TOTAL FLAME RETARDANT USE 1,637.30 1,784.00 1,768.42 1,536.34 Source: EPSDER – EPS Industry Association Table AIV/17. The summary of the total HBCD consumption of 4 plants which produces pre mixed polystryene used in the production of EPS 2018 Production Data (t/year.) HBCD based flame retardant production (kg/year) Capacity Production HBCD Production 2015 2016 2017 2018 2016-2018 average TOTAL 351,500 263,328 66,573 792,800 989,005 997,420 823,841 974,590 Source: Survey data of the participating companies Table AIV/18. The total HBCD consumption summary of the XPS producers in the period of 2016-2018 2018 Production Data (t/year.) HBCD based flame retardant production (kg/year) National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A31 Capacit y Productio n 201 6 201 7 201 8 2016-2018 average TOTAL 1,814,58 6 1,244,586 753,694 749,805 604,923 704,706 Source: Survey data of the participating companies Table AIV/19. Import and export amounts for short chain chlorinated paraffins (kg) (TURKSTAT, 2020) HS codes Activity Year (kg) Residual (kg) 2017 2018 2019 32.08.10.90 import 5,025,380 5,984,454 5,626,605 5,075,458 export 2,962,235 4,011,331 4,587,415 32.08.20.90.00.11 import 6,117,105 6,710,687 7,221,572 7,793,679 export 3,688,284 3,864,478 4,702,923 32.08.20.90.00.12 import 4,116,218 3,272,351 3,382,982 9,836,935 export 386,398 209,736 338,482 27.12.20.10 import 1,097,019 1,329,850 1,897,945 1,632,124 export 2,103,590 1,939,054 1,914,294 38.12.20.90 import 9,561,442 9,593,776 8,566,370 26,830,587 export 216,523 217,879 456,599 Table AIV/20. Import and export amounts for polychlorinated naphthalenes (kg) (TURKSTAT, 2020) HS codes activity year residual 2017 2018 2019 29.03.99.80 import 1 6 7 +13 export 1 - Table AIV/21. Import and export amounts for PFOA, its salts and PFOA-related compounds (kg) (TURKSTAT, 2020) HS codes Activity Year (kg) Residual (kg) 2017 2018 2019 29.03.78.00 import - - 850 export 850 - 38.09.92.00.10.00 import 139,870 320,075 136,761 355,365 export 116,540 115,780 9,021 38.09.92.00.90.00 import 6,667,535 6,013,233 6,458,589 16,069,741 export 818,837 1,346,705 904,074 38.09.93.00.10.00 import 1,060,484 1,134,134 1,279,145 1,353,063 export 688,281 753,971 678,448 38.09.93.00.90.00 import 3,642,470 3,312,367 4,198,525 7,767,487 export 1,122,913 971,479 1,291,483 34.03.11.00 import 4,618,366 4,313,280 4,154,704 10,296,403 export 1,143,136 740,841 905,970 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A32 34.03.19.10.00 import 701,601 727,291 803,916 1,642,869 export 160,086 177,587 252,266 34.03.99 import 12,706,320 12,938,890 12,099,670 32,871,947 export 1,804 2,261,462 2,609,667 32.08.10.90.00 import 2,945,054 2,561,628 1,180,352 6,325,299 export 50,153 140,014 171,568 32.08.20.90.00.11 import 6,117,105 6,710,687 7,221,572 7,793,679 export 3,688,284 3,864,478 4,702,923 38.11.29.00.90.00 import 133,586 167,670 292,646 384,917 export 83,118 87,646 38,221 32.15.11.10 import 95,383 - 15,060 export 80,323 - 32.15.11.90.00 import 2,610,802 - 843,628 export 3,454,430 - 35.06.99.00.90.19 import 4,433,533 2,777,873 4,044,035 22,443,158 export 14,009,403 9,719,518 9,969,678 38.22.00.90 import - 13,223,940 13,374,353 24,620,794 export - 704,868 1,272,631 TOTAL 86,208,988 National Environment Agency, 2019 Table AIV/22. The amount of PFOS used in the country by taking the difference between the import and export amounts for three years 17-18-19 (TURKSTAT) HS codes Name of the Chemicals Activity Year (kg) Residual (kg) 2017 2018 2019 2904.31 Perfluorooctane sulfonic acid import - 2 + 2 export - - 2904.34 Potassium perfluorooctane sulfonate import 50 - 50 export - 100 2904.33 Lithium perfluorooctane sulfonate import - - 125 export - 125 2904.32 Ammonium perfluorooctane sulfonate import - 75 + 75 export - - 2922.16 Diethanolammonium perfluorooctane sulfonate import 784 - + 784 export - - 2923.30 Tetraethylammonium perfluorooctane sulfonate import 250 - 26 + 276 export - - 2923.40 Didecyldimethylammonium perfluorooctane sulfonate import 20 20 + 40 export - - 2935.10 N-Methylperfluorooctane sulfonamide import 6 1 2 + 9 Export - - 2935.30 N-Ethyl-N-(2-hydroxyethyl) import 1 - - + 1 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A33 perfluorooctane sulfonamide export - - 2935.40 N-(2-Hydroxyethyl) Nmethylperfluorooctane sulfonamide import 1 - 2 + 3 export - - 2904.36 Perfluorooctane sulfonyl fluoride import - - 2000 export - 2000 Total - 985 Table AIV/23. Import and export amounts of specific HS codes for 2017-2019 for PFOS related substances HS codes Name Activity Year (kg) Residual (kg) 2017 2018 2019 2710 19 83 0000 Hydraulic oils import 29,081,598 27,517,007 14,959,010 18,902,900 export 15,257,680 18,268,818 19,128,217 3808 91 20 0019 Insecticides import 945 4,593 45,973 165,887 export 86,493 63,809 67,096 3808 91 90 0019 Insecticides import 3,845,353 4,825,320 4,806,458 -12,444,935 export 1,068,204 11,845,665 13,008,197 3813 00 00 0017 Materials and compositions for fire extinguishers; firefighting bombs of all kinds import 3,117,710 3,116,367 2,453,660 6,093,343 export 510,312 1,125,689 958,393 8424 10 00 0000 Fire extinguishers import 1,266,299 2,042,495 983,136 977,830 export 1,804,491 1,546,156 1,919,113 3824 87 00 00 00 Containing perfluorooctane sulfonic acid, its salts, perfluorooctane sulfonamides or perfluorooctane sulphonyl fluoride import 19,245 - 19,118 export 127 - National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A34 Table AIV/24. Priority Sectors Production, Import and Export Amounts Sector Production Amount (kg) Import Amount (kg) Export Amount (kg) Amount Remaining (kg) 2017 2018 2019 2017 2018 2019 2017 2018 2019 2017 2018 2019 Metal Plating * * * * * * * * * * * * Textile 1 3,458,823,529 3,489,705,882 3,520,588,235 2,285,296,226 2,059,304,230 2,113,696,832 1,192,212,151 1,253,906,009 1,191,357,248 4,551,907,604 4,295,104,103 4,442,927,819 Apparel 1 3,373,939,394 3,403,535,354 3,551,515,152 39,384,271 32,234,761 29,813,306 385,278,452 397,934,144 417,170,837 3,028,045,212 3,037,835,971 3,164,157,620 Synthetic Carpet 2 967,651,621 1,003,606,998 1,116,883,833 2,279,692 1,993,617 1,906,470 580,590,972 602,164,199 670,130,300 389,340,340 403,436,417 448,660,004 Paper Cardboard 3 13,513,514 11,666,667 * 2,533,596,368 2,610,161,093 * 462,454,457 280,275,429 * 2,084,655,424 2,341,552,331 * Aviation Hydraulic Fluids 4 * * * 65,424,189 62,601,681 58,324,743 134,798,699 147,574,862 167,063,528 * * * 1 İHKİB Sectoral Reports on import and export, 2 Ministry of Trade, General Directorate of Export, Sectoral Report on Carpet, 3 Paper-Cardboard Manufacturing Industry Sectoral Report, 4 Import and Export amount predicted from HS Codes; 2710.19.81.00.00 (engine oils, compressor and turbine oils), 2710.19.83.00.00 (hydraulic oils), 3819.00.00.00.00 (petroleum oils for hydraulic brake fluids and hydraulic transmissions) Table AIV/25. Approximate PFOS Amount for Priority Sectors Remaining Product amount in country (kg) PFOS amount per product (low-high) mg PFOS kg-1 product) 1 Approximte PFOS amounts remaining in country (tonne PFOS) SECTORS 2017 2018 2019 2017 2018 2019 Scenario 2 Low Value High Value Low Value High Value Low Value High Value Textile 4,551,907,604 4,295,104,103 4,442,927,819 500-5000 0.001% 0.023 0.228 0.021 0.215 0.022 0.222 0.01% 0.228 2.276 0.215 2.148 0.222 2.221 0.1% 2.276 22.760 2.148 21.476 2.221 22.215 1% 22.760 227.595 21.476 214.755 22.215 222.146 10% 227.595 2275.954 214.755 2147.552 222.146 2221.464 Apparel 3,028,045,212 3,037,835,971 3,164,157,620 500-5000 0.001% 0.015 0.151 0.015 0.152 0.016 0.158 0.01% 0.151 1.514 0.152 1.519 0.158 1.582 0.1% 1.514 15.140 1.519 15.189 1.582 15.821 1% 15.140 151.402 15.189 151.892 15.821 158.208 10% 151.402 1514.023 151.892 1518.918 158.208 1582.079 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A35 Synthetic Carpet 389,340,340 403,436,417 448,660,004 500-5000 0.001% 0.002 0.019 0.002 0.020 0.002 0.022 0.01% 0.019 0.195 0.020 0.202 0.022 0.224 0.1% 0.195 1.947 0.202 2.017 0.224 2.243 1% 1.947 19.467 2.017 20.172 2.243 22.433 10% 19.467 194.670 20.172 201.718 22.433 224.330 Paper-Cardboard 2,084,655,424 2,341,552,331 * 500-5000 0.001% 0.010 0.104 0.012 0.117 * * 0.01% 0.104 1.042 0.117 1.171 * * 0.1% 1.042 10.423 1.171 11.708 * * 1% 10.423 104.233 11.708 117.078 * * 10% 104.233 1042.328 117.078 1170.776 * * TOTAL 0.001% 0.052 0.503 0.050 0.504 0.040 0.403 0.01% 0.522 5.027 0.504 5.039 0.403 4.028 0.1% 5.222 50.270 5.039 50.390 4.028 40.279 1% 52.216 502.697 50.390 503.896 40.279 402.787 10% 522.164 5026.974 503.896 5038.964 402.787 4027.873 1 Stockholm Convention PFOS Inventory Guideline, 2 It is not applicable to predict PFOS amount of the Products. The Scenario shows possible amount of PFOS . National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A36 Table AIV/26. 2019 uPOPs inventory of Turkey Source Groups Annual Releases (g TEQ/a) Group Air Water Land Product Residue 1 Waste Incineration 0.1 0.0 0.0 0.0 3.0 2 Ferrous and Non-Ferrous Metal Production 48.1 0.3 0.0 0.0 186.2 3 Heat and Power Generation 44.0 0.0 0.0 0.0 26.0 4 Production of Mineral Products 4.0 0.0 0.0 0.1 2.9 5 Transportation 3.4 0.0 0.0 0.0 0.0 6 Open Burning Processes 66.6 0.0 65.1 0.0 0.0 7 Production of Chemicals and Consumer Goods 0.1 7.4 0.0 87.2 11.4 8 Miscellaneous 0.0 0.0 0.0 0.0 0.0 9 Disposal 0.0 87.5 0.0 7.1 195.6 10 Identification of Potential Hot-Spots 0.0 0.0 1-10 Total 166.4 95.2 65.1 94.4 425.1 Grand Total 846 Table AIV/27. 2014 uPOPs inventory of Turkey Source Groups Annual Releases (g TEQ/a) Group Air Water Land Product Residue 1 Waste Incineration 0.2 0.0 0.0 0.0 7.0 2 Ferrous and Non-Ferrous Metal Production 156.2 0.1 0.0 0.0 567.4 3 Heat and Power Generation 60.5 0.0 0.0 0.0 31.2 4 Production of Mineral Products 11.2 0.0 0.0 0.2 2.7 5 Transportation 2.6 0.0 0.0 0.0 0.0 6 Open Burning Processes 78.4 0.0 76.8 0.0 0.0 7 Production of Chemicals and Consumer Goods 0.3 7.5 0.0 87.4 15.3 8 Miscellaneous 0.0 0.0 0.0 0.0 0.1 9 Disposal 0.0 6.1 0.0 1.6 193.2 10 Identification of Potential Hot-Spots 0.0 0.0 1-10 Total 309.2 13.7 76.8 89.2 816.9 Grand Total 1306 Table AIV/28. 2010 uPOPs inventory of Turkey Source Groups Annual Releases (g TEQ/a) Group Air Water Land Product Residue 1 Waste Incineration 62.8 0 0 0 1.3 2 Ferrous and Non-Ferrous Metal Production 624.7 0 0 0 675.4 3 Heat and Power Generation 59 0 0 0 13 4 Production of Mineral Products 10 0 0 0.3 0.1 5 Transportation 21.5 0 0 0 0 National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A37 6 Open Burning Processes 151 0 96 0 0 7 Production of Chemicals and Consumer Goods 0 5.3 0 72.5 23.3 8 Miscellaneous 0 0 0 0 0.1 9 Disposal 0 6.5 0 2.2 180 10 Identification of Potential Hot-Spots 0 0 0 0 0 1-10 Total 929 11.8 96 75 893.2 Grand Total 2005 References İHKİB, Turkey apparel and textile foreign trade, 2009-2019. İHKİB, Apparel Industry Export Evaluation report, 2019. İTKİB, December 2019. Textile and Raw Materials Industry Export Performance Report. İstanbul Chamber of Industry, 2019. Paper-Cardboard Industry Sector Strategies Project. Ministry of Trade ınformation System, Turkey Apparel and Textile Foreign Trade Data, 2007-2011. National Environment Agency, 2019. Listing of Chemicals Under the Stockholm Convention, PFOA, Dicofol. The BRS Convention, Stockholm Convention Secretariat; http://chm.pops.int/Home/tabid/2121/Default.aspx The BRS Secretariat, 2019. Codes from the Harmonized Commodity Description and Coding System (HS) for chemicals listed in Annex III to the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade. Turkish Statistical Institute. Statistics of Foreign Trade, General Trading System, 2017-2019. UNIDO Statistics Data Portal, Country Profile Turkey; https://stat.unido.org/ http://chm.pops.int/Home/tabid/2121/Default.aspx https://stat.unido.org/ National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A38 Annex V: Current Programs and Results on Monitoring of POPs Emissions and Effects on Human Health and Environment The First Long Term Monitoring Study in Turkey Under the global passive air monitoring network (MONET) project, background sampling station was located in Çamkoru, Ankara, Turkey. Atmospheric levels of POPs have been identified since 2009 and contaminant levels ranged 0.5-2.1 ng/sample for 7 indicator PCBs, 494-4072 ng/sample for 29 PAHs, 0.02-3.1 ng/sample for 10 PBDEs and 0.7-3.2 ng/sample for DDTs. The data is freely available at https://data.genasis.cz/outdoor/. Levels of POPs in various biotic and abiotic matrices identified by academic studies The updated information regarding the POPs levels identified in various biotic and abiotic matrices in Turkey are provided in Tables AV/1-4. Table AV/1: Concentrations of pesticides in various matrices in Turkey Medium Location Site Year Compound Concentration Ref. Air Antalya agricultural rural 2013 endosulfan 0.610-64.5 pg/m3 [1] total DDT bdl-25.9 pg/m3 heptachlor bdl-7.38 pg/m3 chlordane bdl-0.828 pg/m3 total HCH bdl-2.55 pg/m3 Sediment Edremit Bay 2015 pp-DDE nd-1.2 ng/g dw [2] Soil Meriç-Ergene river basin industrial and agricultural total OCP 6-83 ng/g [3] Lichen 7-86 ng/g Pine needle 10-97 ng/g Pine needles & branches Bursa Suburban 2016 10 OCPs 10+3.8 ng/g [4] Pine needle Mersin mountain 2009 2010 HCH 1.4-129 pg/g fw [5] DDT 67.3-795.8 pg/g fw Butter Gaziantep 2015 HCH 2.39-7.22 ng/g fat [6] DDT 5.07-32.1 ng/g fat OCP 2.39-35.1 ng/g fat Mardin HCH 4.18-25.12 ng/g fat DDT 4.52-660.4 ng/g fat OCP 4.52-675.93 ng/g fat Şanlıurfa HCH 5.99-22.5 ng/gfat DDT 18.5-750 ng/g fat OCP 29.5-770 ng/g fat Raw cow milk Konya total HCH 11.23-127.19 ng/g lipid wt [7] total DDT 1.99-81.53 ng/g lipid wt heptachlor <4-20.38 ng/g lipid wt endosulfan 1.83-44.82 ng/g lipid wt endrin 4.48-155.15 ng/g lipid wt aldrin 0.26-8.4 ng/g lipid National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A39 wt dieldrin 0.56-13.29 ng/g lipid wt UHT milk several cities total HCH 23.33-141.66 ng/g lipid wt total DDT 6.67-20 ng/g lipid wt heptachlor 4.36-33.87 ng/g lipid wt endosulfan 7.2-36.67 ng/g lipid wt endrin 8.06-63.33 ng/g lipid wt aldrin 0.97-10 ng/g lipid wt dieldrin 1.67-20 ng/g lipid wt Table AV/2: Concentrations of PCBs in various matrices in Turkey Medium Location Site Year Concentration no.of PCBs Refere nce Air Kocaeli industrial 2015 2016 177-41781 pg/m3 41 [8] Air throughout Turkey 2014 2015 108+132 pg/m3 43 [9] Air Bursa Suburban 2016 50-250 pg/m3 79 [4] Outdoor air Bursa urban 2014 19-510 pg/m3 40 [10] Indoor air 140-960 pg/m3 Air Antalya agricultural rural 2013 nd-213 pg/m3 15 [1] Soil Kocaeli industrial 2015 2016 0.83-239 ng/g 41 [11] Soil Bursa Rural 2016 5.82-18.71 ng/g 43 [12] Pine needles & branches Bursa Suburban 2016 2-10.9 ng/g 81 [4] Soil Meriç-Ergene river basin industrial and agricultural 10-63 ng/g 15 [3] Lichen 7-68 ng/g 15 Pine needle 11-33 ng/g 15 Honey Bursa urban-semi-urban 2017 71.57-178.36 ng/g dw 46 [13] Honeybee 93.31-166.91 ng/g Pollen 47.8-112.86 ng/g Raw cow milk Konya 10.59-35.91 ng/g lipid wt 7 [7] UHT milk several cities 21.63-101.32 7 Fish İzmir 2010 2013 ND-34.3ng/g 7 [14] Butter Gaziantep 2015 26.24-257.63 ng/g fat 9 [6] Mardin 5.15-341.5 ng/g fat Şanlıurfa 7.58-104.6 ng/g fat National Implementation Plan for Persistent Organic Pollutants (POPs) Management in Turkey A40 Table AV/3: Concentrations of PBDEs in various matrices in Turkey Medium Location Site Year Concentration no.of PBDEs Reference Air throughout Turkey 2014-2015 191+329 pg/m3 14 [9] Car dust Bursa 2018 <MDL-40198 ng/g 13 [15] Raw cow milk Konya bdl-20.22 ng/g lipid wt 5 [7] UHT milk several cities bdl-20 ng/g lipid wt 5 Table AV/4: Concentrations of PAHs in various matrices in Turkey Medium Location Site Year Concentration No. of PAHs Refere nce Soil Kocaeli industrial 2015 2016 49-10512 ng/g 15 [11] Ambient air İnegöl 2017 2018 113.12-3122.97 ng/m3 16 [16] Air Bursa urban& semi urban 2017 1.08-16.54 ng/m3 16 [17] Sediment Edremit bay 2015 0.65-175 ng/g 18 [2] Soil İstanbul Urban & rural 2013 2014 22.11+14.71 ng/m3 (urban) 19.53+16.45 ng/m3 (rural) 16 [18] Pine needle Bursa Bursa suburban 2016 626+306 ng/g 14 [4] Air 2016 23.1+18.3 ng/m3 14 Air Bursa semi-rural 2013 2014 6-798 ng/m3 15 [19] Soil Meriç-Ergene river basin industrial and agricultural 67-887 ng/g 16 [3] Lichen 75-1278 ng/g 16 Pine needle 113-589 ng/g 16 Air Kocaeli industrial 2015 2016 4.2-3842 ng/m3 15 [8] References [1] Can-Güven, E., Gedik, K., Kurt-Karakuş, P.B. 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