by Ms. Renata Sinovcevic

It has been observed that the existing national infrastructure developed for the safe chemicals management might in near future become one of the limiting factors for efficient response to new requirements and international obligations of Croatia. A new approach in safe chemical management has begun in 1995.

In September 1996, the Government of Croatia has formed an Intersectoral Committee for Safe Management of Chemicals, PSGK. This is an advisory body in the solution of substantial issues related to safe management of chemicals. The members of PSGK are representatives of 16 administration bodies responsible for safe chemical management and representative of the Croatian Chamber of Commerce. Representatives of professional institutions, nongovernmental societies and experts in particular fields join the PSGK as required. The basic task of PSGK are:

• improvement and reinforcement of the system for safe management of chemicals,
• improvement of the work on risk assessment,
• elaboration of program of measure for risk reduction,
• improvement classification, packaging and labelling of chemicals,
• improvement of the measure for prevention of illegal trade with toxic and other hazardous chemicals,
• improvement and reinforcement of the system for exchange of chemical information and other activities related to safe management of chemicals.

PSGK should submit to the government of Croatia annual report on its activities and work. Also PSGK should submit a proposal for improvement of safe management of chemical for next year. The work of PSGK is regulated by its rules of procedure.

The State Directorate for the Protection of Nature and Environment is a centre for coronation of PSGK activities related to safe management of chemicals, SPSGK. This is a Focal Point of PSGK for national and international communication, technical and operative support to PSGK in their work.

At the beginning of their work, PSGK has prepared A Draft on Chemical Management National Profile, DCMNP. Also PSGK has developed A Chemical Management National Mini Acting Programme, CMNMAP, containing a short time, and long time tasks for all partners included in safe chemical management. PSGK has established six co-ordination bodies and has nominated six co-ordinators responsible for co-ordination of activities on CMNMAP implementation (Picture 1).

PSGK has prepared its fires report on progress in CMNMAP implementation. The report has related to activities and work of national co-ordination bodies, since September 1996 to March 1998. Also PSGK has prepared a proposal with a list of priority activities for improvement safe management of chemicals for the period to 2000.

A work on improvement of existing national infrastructure for the POPs management started by public awareness raising. An information letter related to POPs properties and POPs management has been send by co-ordinator of Co-ordination Body for Infrastructure Improvement, CBII to responsible administration bodies. Also CBII has published an information paper related to POPs properties and POPs management in an official gazette

" Environment".

In November 1997 PSGK has obtained a commitment for establishing a working group for POPs, from following responsible administration bodies: Ministry of Health; Ministry for Labour and Social Welfare; Ministry for Agriculture and Forestry; State Directorate for the Protection of Nature and Environment; State Directorate for Water.

In December 1997, PSGK has formed a Working Group for POPs, RSPOPs. The members RSPOPs are the nominated representatives from 5 responsible government authorities. RSPOP acts under the umbrella of Co-ordination Body for Risk Assessment (Picture 2.). CBRA. Also CBII co-operate and support RSPOP in their work.

Two main aims of RSPOPs are as follow:

- A preparation of POPs Management National Profile, POPMNP

- A development of POPs Management National Acting Programme, POPMNAP for improvement of Work on POPs risk assessment and POPs risk reduce

RSPOP has established its Work-plan at its the first meeting. The Workplan contents five main steps as follow (Picture 3.):

• RSPOPs should identify the data source and collect data related to POPs life cycle management to Mart 1998.
• RSPOPs should elaborate the POPs Management National Profile to June 1998.
• RSPOPs should propose the priority list of the activities related to the infrastructure improvement and reinforcement to August 1998.
• RSPOPs should organise a national meeting on POPs management to October 1998.
• RSPOPs should include an expert team into the activities, and elaborate a National Acting Program to December 1998.

Also SPSGK has asked responsible administration bodies and each member of RSPOP for their response on the UNEP "POPs" Questionnaire.

RSPOP has checked the progress in the Workplan implementation, on its interim meeting, at the end of April 1998. A result is as follows:

• RSPOP has taken the most of data from Draft of Chemical Management National Profile.
• There are no official data for POPs manufacturing, use and disposal.
• CBII has selected data related to import of "POPs" pesticides and PCBs fin 1997 from the export/import national register.
• CBII has selected and searched the national legislation related to a POPs management. Also SPSGK has done a summary of key legal instrument related to POPs management (Pictures 3 - 6.).
• CBII has done a list of relevant national norms developed on the bases EN and ISO norms.
• CBII has prepared a list of relevant EEC directives, regulations and their amendments.
• CBII has identified the main administration bodies and a summary of their responsibilities has prepared (Pictures 7. - 8.).
• RSPOP has identified a main relevant institution for new POPs nomination.
• RSPOP has identified the main control laboratories for POPs release and environment, public health and occupational health exposure.
• CBII have prepared the thirteen summary tables of prescribed maximum allowed concentration of different POPs in different medium.
• RSPOP has collected same data related to PCB, Dioxin and Furry releases and PCB public health exposure by UNEP "POPs" Questionnaires.
• RSPOP did not obtain requested available data that relate to control of POPs release in water, sea, air, soil as well as monitoring data related to POPs public health exposure, occupational health exposure and environmental exposure from the responsible administrative bodies.
• CBII has selected the pesticides containing POP as active substance from an official list of 565 pesticides licensed by Ministry for Agricultural and Forestry for distribution. An summary of selected data SPSGK has done (Picture 9.).
• CBII has began prepare a summary of properties POPs that manufacture, distribute, use and control in different media in Croatia. Also cbii has began harmonisation relevant legal bases with EEC directives.

• A Draft of Chemical Management National Profile has taken as a source of much data related to POPs management and helped to shorten a data collecting process. The collecting of available official data from other official sources takes much time. The data related to manufacturing, use and disposal leak. This information shows that an official chemical information system did not develop according new needs.
• There are no the separate legal instruments prescribing the POPs as a separate group of toxins or other dangerous chemicals. The life cycle of POP management indirectly prescribed by 19 lows and other regulations prescribing the life cycle of toxins, and other dangerous substances. A control of maximum allowed concentration of different POPs in different media is prescribe directly.
• CBII has selected 13 relevant national norms bases on EN or ISO norms from national register of national norms. RSPOP should prepare a priority list of other national norms that should develop on the bases relevant EN and ISO norms. An expert team should propose implementation of relevant norms in legal framework for POP management.
• CBII has prepared a list of 18 Directives containing their amendmend that indirectly related to POPs management. RSPOP should identify their implementation in existing national legislation. Frothier an expert team should propose a frothier harmonisation of existing legal instrument for classification, notification, registration of new POPs as well as POPs legal instrument for risk assessment and risk reduce with relevant legal instrument in EEC directives, as sun as possible.
• RSPOP should permanently encourage the government authorities responsible for POPs management for data collecting and better co-operation with RSPOP.
• There is non "GLP" laboratory for testing new chemicals. Main licensed institution for a new toxin property's investigation is State Toxicological Institute.
• RSPOP has identified 53 licensed laboratories as follow:
  • 6 licensed control laboratories for drinking water and food quality control,
  • 13 licensed control laboratories for air emissions and air quality control,
  • 16 licensed control laboratories for environmental quality monitoring,
  • 28 licensed control laboratories for west property control.
    
• RSPOP should complete the lists of laboratories for POPs release and POPs exposure control. Also RSPOP should collect data related to testing capacities and capabilities of licensed laboratories.
• An accreditation process for giving license to the control laboratories for water quality control on the bases of EN 45001 - EN 45003 norms is just on the way.
• RSPOP should do a comparison of prescribed maximum allowed concentration of POPs with relevant value in EEC directives. Also an expert team should propose a necessary correction of prescribed values and propose new POPs control.
• RSPOP should collect more data related to POPs release and POP exposure. Also RSPOP should encourage responsible administration bodies and licensed institution to completely open their data related to POPs.

There are 565 formulations of pesticides containing 270 active substances licensed by Ministry of Agriculture and Forestry. This pesticides manufacturer could import and distribute on the market of the Republic of Croatia.

Among 565 licensed pesticides there are 56 pesticides containing following 11 POPs as active substances: Atrazin; Bentazone; Chlorpicrin; Dichlorvos; 2,4-D; Endosulfan; Fetion; Lindane; Malathion; Parathion; Simazine.

Three formulators from Croatia, and 15 formulators from another country have the license for distribution pesticides containing POP as active substance.

A total annual manufacture of pesticides containing POP as active substance does not identify yet. In 1997 Croatia imported 503.760,180 kg of pesticides containing POPs as active substance. Main exporting countries of pesticides containing POPs as active substances are as follows:

• Slovenia 99. 548,73 kg
• Belgium 93.694,870 kg
• Italy 89.440.32o kg
• Switzerland 65.894,56 kg
• Other

According to the data of Ministry of Agriculture and Forestry a total annual use of pesticides amounts as follow:

• 7.661,00 tonnes (3,25 kg/ha)
• 3,418,oo tonnes (1,4 kg/ha)

It is estimated that 7,2% of this amount are pesticides containing POP as active substance.

A total annual use of pesticides containing POPs as active substance does not identify yet. According to data of Hazardous Waste Agency an use of pesticides, including pesticides containing POPs as an active substance, per local regions amounts as follows:

According to data of the Hazardous Waste Agency a total stock of obsolete pesticides including pesticides containing POPs does not know jet. It could expect that the annual stocks of pesticides are minimal as well as the annual stock of pesticides containing POP as active substances, because an annual manufacture and import of pesticides make plans depending on annual agricultural plan.

The obsolete pesticides as well as packaging of the pesticides have to be treated as a hazardous waste. The establishing of register of hazardous waste is just on the way. This register will be an official source of "POPs" waste.

RSPOP did not collect the data related to health and environmental problems in manufacture, use and disposal pesticides containing POPs as active substances. RSPOP should encourage the administrative bodies to open this data as an important base for POPs management policy developing.

There is no manufacturer of PCBs in Croatia. In 1997 Croatia imported 2.255.543, 91 kg of transformer oils. It is expect that imported oils contain PCBs. The main imported countries are as follows:

Austria 1.722.161,00 kg

Germany 339445,00 kg

Cyprus 102.720,00 kg

Romania 40.200,00 kg

Slovenia 23.735,oo kg

Other

There are 405 users of 22532 (573.843,4 kg) "PCB" condensers and 293 (706.903,o kg) "PCB" transformers in Croatia. In Croatia there are none "PCB" destruction capacity. The "PCB" transformer, condenser and PCB oils export to France for destruction. During last 4 year Croatia has exported 10% of its "PCBs" transformer and condenser. In 1997 Croatia exported in France as follow:

1 tonne PCB oils

9 tonnes "PCB" transformers

6,2 tonnes "PCB" condensers

Ministry of Health has licensed Public Health Institute of Zagreb County, PHIZC for monitoring PCB exposure. PHIZC has informed on PCB release to Kupa river from Slovenian ago 1982. Also PHIZC has inform on PCB residue in human milk up 2,7 ppm and fat tissue up 5,2 ppm as well as on ambient air, ground water, surface water a soil PCB exposure. RSPOP should encourage PHIZC that as a licensed institution for PCB exposure monitoring completely open data related to PCB. Also RSPOP should encourage PHIZC for their co-operation with RSPOP. They should work together on improvement of POPs risk assessment acting plan.

The main following activities are:

- continue data selecting and interpretation,

- elaborate a draft of POPMNP,

- propose a list of priority activities,

- organise a national meeting,

-elaborate National Acting Programme,

- work on implementation of National Acting Program.

CBII Co-ordination Body for Infrastructure Improvement

CBRA Co-ordination Body for Risk Assessment

CMNMAO Chemical Management National Mini Programme

DCMNP Draft of Chemical Management National Profile

PSGK Intersectoral Committee for Safe Chemical Management

PMNP POPs Management National Profile

PMNAP POPs Management National Acting Programme

PHIZC Public Health Institute of Zagreb County

RSPOP Working Group for POPs

SPSGK Centre for Co-ordination for of Activities Related to Safe

Chemicals Management

Picture 8.