LECTURE 6: OZONE-DEPLETING SUBSTANCES

TRAINING WORKSHOPON ENVIRONMENTALLY REGULATED SUBSTANCES

INECE Capacity Building Program on Controlling Shipments of Environmentally Sensitive Goods at Seaports

WHAT IS AN OZONE-DEPLETING SUBSTANCE? Chemical substances that can react with

ozone in the stratosphere

Various hydrocarbons with chlorine, fluorine and bromine

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Largest ozone hole:Sept 24, 2006

July 26, 2014

IMPACTS OF OZONE LAYER DEPLETION

Human health impacts from increased UV radiation

Increased risk of skin cancer Increased risk of cataracts and eye damage Immune suppression

Environmental impacts from increased UV radiation

Negative impact on ecosystems Some ODS drive climate change Lower yields for several key crops (e.g., rice, soy

beans) Reduced productivity of plankton which form the

base of the marine food web

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COMMON USES OF ODS

Refrigerants Blowing agent for foams Cleaning solvent Propellants for aerosols Sterilants for health care products Fire extinguishers Fumigants Chemical synthesis feedstocks Laboratory uses

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OZONE:GOOD UP HIGH, BAD NEARBY

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MONTREAL PROTOCOL

International treaty ratified in 1987 to reduce and eliminate emissions from ODS

September 2009: Montreal Protocol became first treaty in history of the United Nations to achieve universal ratification: 197 nations.

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DEVELOPING COUNTRIES HAVE INCREASED ODS CONTROLS

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REQUIRED PHASEOUT

Phaseout: Chloroflurocarbons (CFCs) Hydrochlorofluorocarbons (HCFCs)

Equipment should be replaced or retrofitted to accept new gases: can be expensive

However, as supply decreases, smuggling may increase

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ONE CONSEQUENCE OF PHASEOUT

CFCs HCFCs HFCs

Ozone depletion Global Warming Potential

Carbon dioxide = 1 Global Warming PotentialHFCs = 124 – 14,800 Global Warming Potential

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WHY ODS SMUGGLING OCCURS

Decreasing availability of gases being phased out or banned, increases demand

Differing phaseout schedules between developed and developing countries

Alternative gases may cost more

Equipment containing ODS has long life

Conversion/retrofitting of equipment is costly10

SOURCES OF ODS

Manufacturers: China is largest global source of virgin ODS

Consumers/disposers of ODS: United States European Union Japan Australia

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ROLE OF CUSTOMS OFFICER IN ENFORCING ODS REGULATIONS (UNEP)

Enforcement of ODS licensing system Increasing importer and exporter awareness of ODS

regulations Detecting illegal trade On-site use of refrigerant analyzers and detectors Reporting ODS legal and illegal trade to the National

Ozone Unit (NOU) Seizing illegal ODS, including storage and disposal Provide support to other enforcement agencies to

support legal actions

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ILLEGAL SMUGGLING SCHEMES

Mislabeling the canister as a non-ODS gas

This modus operandi has been noted worldwide

Example: R-22 (or HCFC-22, Freon): illegal to trade R-134-a (or HFC-134-a): non-ODS gas R-22 is being smuggled in canisters marked R-134-a

Canisters may contain illegal mixtures of gases; for example R-22 and R-404a, but be labeled as pure legal product

Cardboard packaging may not represent gas in canister: R-134a outer package may contain R-22 canister

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R-22 LABELED AS R-134A

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OLD FRIDGE CONTAINING R12

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ONLY TESTING WILL CONFIRM CONTENTS

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PORTABLE REFRIGERANT ANALYZERS

Allow sampling of suspect cylinder at port Determine if canister’s content match

documentation Determine if canister’s content is contaminated or a

mixture

If documentation and actual contents do not match, contents should be analyzed in laboratory to verify

Laboratory analysis is needed to support legal actions 17

ADDITIONAL SMUGGLING SCHEMES

Mislabeling virgin gas as recovered/used/recycled gas Virgin gas may be illegal; recycled gas may be allowed

Hiding canisters Illegal gas canisters hidden behind non-ODS canisters Concealing smaller canister within

larger one (double layering) Vehicle scan useful in detection of

hidden cylinders

Equipment contains ODS: Refrigerator compressors not purged Equipment modified to hold excess

amounts of ODS18

SOME SAFETY CONSIDERATIONS: ODS CONTAINERS AND ODS-CONTAINING EQUIPMENT

Do not vent ODS into the atmosphere Do not store in a confined space Do not store ODS in direct sunlight Do not use open flames near ODS; watch for

sparks Do not sample ODS canisters unless you have

been trained Do not eat, drink or smoke near ODS or ODS-

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GIFTS / DONATIONS OF SECOND-HAND APPLIANCES MAY CONTAIN ODS AND DANGEROUS CHEMICALS

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CUSTOMS CHECKLIST

Compare all documentation to ensure it matches

Check Customs code on entry with invoice Verify country origin Check that importer exists Check that importer is licensed to import

specific material Inspect material: packaging, size, label and

shape: should match information on paperwork

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IT MAY BE AN ILLEGAL SHIPMENT IF:

Based on previous knowledge or targeting information, documentation indicates suspicious quantity, source and/or destination information for the ODS

Verify that the importer and place of business actually exist

Information on various documents does not match

Various codes (ASHRAE, HS, UN, chemical name/formula) on documentation do not match actual canister

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SOME DOCUMENTS TO CONSIDER

Invoices Packing lists Bills of lading Customs documents Import/export licenses

Does information on all documents match?Can information be verified?Do you see obvious mistakes, omissions?

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CHECK FOR OBVIOUS DISCREPANCIES Missing or inconsistent information on the label

Misspellings of trade names or company names

Check that stickers on canister have not been changed or are not covering up original markings

Incorrect HS Codes may be used to avoid detection Check for consistency on all documentation

Check color of canister Color-coding system is not universal, but may indicate

an illegal shipment Canisters may be repainted to misrepresent contents:

determine if paint scratches off to reveal another color 24

REFRIGERANT CYLINDER COLOR CODES

AVAILABLE ON THE WEB: Training Manual for Customs and

Enforcement Officers (3rd edition) (UNEP)Comprehensive training manual on controlling ODS for Customs and Enforcement officers

Enforcement Strategies for Combating the Illegal Trade in HCFCs and Methyl Bromide (UNEP)Guidance for establishing and implementing enforcement programs for preventing the illegal trade in HCFCs and methyl bromide. 

Ozone Depleting Substances Smuggling and Concealment: Case Study Handbook (Interpol/UNEP)Information and guidance for police, customs and border security officers on methods commonly used by criminals to hide and smuggle illegal ODS. 

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SOME NUMBERS TO CHECK: ASHRAE number: identifies halocarbon and

hydrocarbon refrigerants Appears in trade name (CFC-12)

CAS numbers: unique identifier for each chemical or chemical mixture 5 to 9 numbers divided into three groups:

up to 6 numbers - 2 numbers - 1 number (CAS 75-45-6 = R-22)

UN Number: 4 numbers that identify certain hazardous substances (UN 1081 = R-22)

HS Codes: WCO international system for identifying commodities; on documentation, but not canisters

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