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UNITED
NATIONS
SC
UNEP/POPS/POPRC.8/INF/21
Distr.: General
11 September 2012
Stockholm Convention
on Persistent Organic
Pollutants
English only
Persistent Organic Pollutants Review Committee
Eighth meeting
Geneva, 15–19 October 2012
Item 5 (i) of the provisional agenda*
Technical work: intersessional work on
climate change and persistent organic pollutants
Comments and responses relating to the draft guidance on how
to assess the possible impact of climate change on the work of
the Persistent Organic Pollutants Review Committee
Note by the Secretariat
The annex to the present note contains a table listing comments and responses relating to the
draft guidance on how to assess the possible impact of climate change on the work of the Persistent
Organic Pollutants Review Committee, set out in document UNEP/POPS/POPRC.8/INF/20. It is
presented as submitted by the intersessional working group, without formal editing.
*
K1282619
UNEP/POPS/POPRC.8/1.
180912
UNEP/POPS/POPRC.8/INF/21
Annex
Comments and responses relating to the draft guidance on how to
assess the possible impact of climate change on the work of the
Persistent Organic Pollutants Review Committee
Minor grammatical or spelling changes have been made without acknowledgment. Only
substantial comments are listed.
Source of
Comment
Bulgaria
2
Page
Chapter
General
Bulgaria
General
Bulgaria
General
Bulgaria
General
Bulgaria
General
Bulgaria
General
Bulgaria
Annex D
Comments
Please add an executive summary at
the beginning and recommendations at
the end.
Recommends a “Table of Contents”,
“List of Tables” and “List of Figures”
to be added at the beginning of the
document
Enhance readability by starting each
chapter on a new page.
Add: Information on climate change
(as a short introduction) would be also
useful, shall improve generally the
guidance. Such an introduction is now
missing and thus a definition of
“climate change” is lacking.
The division in changes in
temperature, salinity, and irradiation is
very useful, but it would be
appreciated if this would be applied
throughout the text where often
“climate change” is used while the
relevant factor is change in
temperature and so on.
The draft guidance does not make a
very clear difference between facts,
data and figures from past and present
as provided by scientific studies and
predictions based on events that are
expected to happen in the future.
Throughout the text a lot of “can be”,
“may be” and “will be” can be found.
We consider that “may be” is better to
used throughout the text, due to the
fact that no figures of the uncertainties
in the predictions are provided in the
text.
Change: Documentation of
interactions between a nominated
substance and climate change shall be
collected by the nominating Party
Delete: shall
Add: may
Response
Accepted
Noted. This would be practical, but
because of the need to keep documents
short it was not done.
Noted.
Partly accepted. The scope and
mandate of the task set out by POPRC7
was to base the guidance on
UNEP/AMAP 2011, and a short
introduction on interactions and impact
between CC and POPs already exists in
the document.
To summarize the findings by IPCC
would be out of scope of this guidance.
However a short introduction on
climate change has been added, but
only on the impacts relevant according
to the report by UNEP/AMAP 2011.
Noted.
Partly accepted. The terms «may be»,
«will be», «can be» are often the
language of the original sources and it
is difficult to change it without
changing the tone.
However the text has been modified on
the basis of other comments and the
essence of this comment. The words
"can be”, “may be” and “will be” have
to a large extent been replaced with
"have been/ was observed" and "is
predicted to/projected to" to more
clearly distinguish between observed
and predicted/projected effects and to
make the level of certainty in the cited
data/ results more clear.
Partly accepted. Should is used in the
text.
UNEP/POPS/POPRC.8/INF/21
Source of
Comment
Canada
Page
Chapter
Executive
summary
Canada
5.1
Canada
5.1
Canada
5.1
Canada
5.1
Canada
5.1
Canada
5.1
Canada
5.1
Canada
7
Canada
7
Canada
7
Canada
7
Canada
7
Canada
7
Canada
7
Comments
This executive summary could be use
more work to improve clarity, flow
and grammar. It would appear that
much of the text below has been cut
and pasted from other sections section 5.1 and Chapter 7 in particular.
The POPRC should be mentioned
early in this paragraph
Several editorial comments provided
including use of abbreviation “CC” for
“climate change”.
Insert “transport in air” in the first
sentence of the first paragraph.
Insert “presenting information on”
instead of “discussing” in the third
paragraph.
Insert “of a candidate POP. These
considerations also apply” instead of
“as well as” in the third paragraph.
Insert “CC-related are especially
important” instead of “the climate
change will be of especially
importance” in the fourth paragraph.
Insert “as we move” instead of “in the
light of movement” in the fourth
paragraph.
“Sustainable development” in the
fourth paragraph is a bit vague. A few
more words of explanation are
required here to explain what the
sustainable development is referring
to.
Last paragraph, “in relation to the
criteria in the annexes” requires more
explanation. Which criteria and in
which annexes?
Overall, this section could be revised
with clearer language and perhaps a
clearer format in which conclusions
and recommendations are clearly
identified.
“This exercise” in the first paragraph
is unclear. What exercise?
Also suggest that this section begin
with a more definite statement.
Insert “are relevant to and should be
considered when assessing” instead of
“can be evaluated in light of” in the
first paragraph
“Criteria” in the first paragraph needs
more specificity – what criteria?
“Clearer taken into account” in the
second paragraph: Rephrasing
required.
“Recommended to add” in the second
paragraph:
Is this suggesting that the Annexes to
the Convention need to be formally
revised? If so, this should be clearer.
Perhaps also include a statement about
how this revision can be achieved.
Insert “This is in addition to risks
associated with” instead of “in
addition to the” in the third paragraph.
Response
Received late. Comments to be
considered.
Not accepted.
Accepted.
Accepted.
Text rewritten.
The whole text deleted.
The whole text deleted.
The whole text deleted.
Accepted. Section revised and divided
into to subchapters.
Accepted. Words added and section
rewritten.
Accepted.
Accepted. Text revised.
Accepted. Text revised.
Accepted. Text revised.
Text changed, to make clear that
climate change and multiple hazardous
substances is an example of
environmental stressors.
3
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Canada
Canada
Chapter
7
7
Canada
7
Canada
7
Canada
7
Canada
Executive
summary
Canada
Colombia
Executive
summary
General
Colombia
5
Colombia
4
Page
Comments
Response
Insert “to multiple” instead of “of a
cocktail of” in the third paragraph.
Insert “CC-related effects” instead of
“observed climate change effects” in
the third paragraph.
Third paragraph: Some wordsmithing
is required here
Fourth paragraph: Be clearer here.
This reads as more of a summary than
a conclusion. This section could be
more concise and would benefit from
some wordsmithing.
Fifth paragraph: This paragraph needs
to be reworked. Suggest that the
recommendation to assist developing
regions to address the CC effects issue
simply be tagged onto one of the
earlier recommendations.
The wording of the first sentence
should be adjusted. Each paragraph
should begin with a new conclusion.
This paragraph begins with an action
item.
Not clear what process is referred to.
Unclear what is the “scarce
information”.
This executive summary could be use
more work to improve clarity, flow
and grammar. It would appear that
much of the text below has been cut
and pasted from other sections section 5.1 and Chapter 7 in particular.
Accepted.
First para: The POPRC should be
mentioned early in this paragraph.
The document contains valuable
information that will serve to guide the
work of the POPRC, concerning the
effects of climate change and the
behavior of POPs.
In section 5.2.1. Persistence (a) The
effects of climate change on
persistence, states that "while
Increased temperatures may increase
the microbial activity, Increased
thermal stress may hamper the activity
(UNEP / AMAP 2011)", I suggest you
include the following: appearance
which can increase the biodegradation
of POPs.
Studies show that the effects of
climate change influence on POPs
characteristics such as persistence,
bioaccumulation, potential for longdistance transport and adverse effects,
which as noted in the text are
evaluated for a variety of controlled
conditions, but in many cases not
consider the real environmental
conditions. Considering that the
document seeks to guide the work of
the POPRC to establish the effects of
climate change in relation to the
behavior of persistent organic
pollutants, according to the criteria set
out in Annexes D, E and F of the
Stockholm Convention, recommend
Accepted. Text revised.
Accepted
Accepted. Section revised.
Accepted. Section revised.
Accepted. Section revised.
Accepted. Text revised.
Noted.
Not accepted.
The uncertainties will be different for
every substance, impact, scientific
test/observation and region, and even
more complex than the estimation of
climate change impacts done by IPCC.
At this stage we do not know which
substance will be nominated.
POPRC should be able take into
account any uncertainties given in the
specific data presented on CC impacts
on a specific substance, derived from
laboratory studies or field
experiments/observations the same way
it does now with other data on
properties etc.
UNEP/POPS/POPRC.8/INF/21
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Chapter
Ecuador
General
Ecuador
General
Ecuador
General
Ecuador
General
Georgia
General
The
Netherlands
Annex D
Comments
Response
defining the criteria to be considered
for laboratory studies and field such
as: the range of increasing
temperature, increase or decrease in
rainfall, increased ultraviolet radiation,
changes in salinity, lower pH, etc.
considering the criteria adopted
climate change experts, the above to
have a unified approach by the
POPRC.
The guidance underlines that any
predicted or observed effects should be
considered on a case-by-case basis (i.e.
chemical per chemical) using what is
available of data for the specific
substance. The uncertainties given in
the scientific data is then also included
in the evaluation, in a weight-ofevidence approach, as has currently
been the practice of POPRC in the past.
Climate change has the potential to
alter the hazardous properties of
environmental contaminants, so it
should include information from other
areas of the planet. Only thing
recorded are more frequent extreme
weather.
Arctic Monitoring and Assessment
Programme (AMAP) data is very
important.
Add: The results obtained from the
analysis of data from 20 years of air
monitoring in the Arctic, show that if
conditions remain or become warmer
it would release a larger amount of
persistent organic pollutants into the
atmosphere.
•You are kindly asked to include
information about the other zones of
the planet where extreme climate
changes, such as flooding and heat
waves, are registered more frequently,
and where interesting data/facts about
this topic have been reported.
• Additionally it is suggested to
strengthen the synergies between the
political agendas of climate change
and POPs related to identifying areas
of uncertainty, gaps of information,
knowledge and data at the global level
and in particular of the countries in the
process of development in order to
have a more complete and detailed
report. Due to all the alterations the
environment globally is going through
because of climate change the
monitoring plans must be extended to
increase the generation of information
in all the signatory countries of the
convention to the moment when a
harmonized and general strategy is
established.
We consider (from our point of view
i.e. Climate Division) no proper
attention is paid to the interaction
between climate change and POPs in
mountainous areas in the Guidance.
Climate change does not change the
characteristics of the criteria in annex
D, but may change their reasons for
concern. That should be clear
throughout the text of the document
This is clarified in the text.
Agreed. A table on regional differences
is added, with information from all
regions mentioned in the IPCC report.
Agreed in principle, but a reference is
needed to be able to include this
sentence.
Accepted.
Partly accepted. See text added to the
recommendations in chapter 7 and in
the Executive Summary.
Agreed, but references are needed to be
able to include more information on
mountain areas. The need to generate
more information has been noted in the
recommendations.
Agreed. Text modified to make this
clearer in the text. See also
added/modified text in objective and
chapter 5.
5
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Netherlands
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The
Netherlands
Table
7
Comments
Authors states that climate change
does not change the inherent
properties of the substance, but they
seem to have forgotten that in other
parts of the guidance document.
Please correct such flaws
Annex D
The
Netherlands
The
Netherlands
Chapter
As nomination of substance should be
purely based on the annex D criteria,
data on the effects of climate change
can only support nomination in terms
of reasons of concern. In climate
change related data the Netherlands
would express a strong preference to
use specific data on these substances
rather than generic ones.
General
The Netherlands would be in favor of
a recommendation whether the subject
“climate change” should be addressed
either in the nomination dossier or the
risk profile or the risk management
evaluation.
Annex D, E
and F
Table 7 of present draft shows a
complete overlap of subjects in annex
D and E, and only one item in annex F
The
Netherlands
General
The
Netherlands
4, 5 and 6
The
Netherlands
General
The document would be greatly
improved by adding an executive
summary and a recommendations
section
Start on a new page to increase the
readability and text should have
consistency
Add: general information on climate
change predictions
Response
Agreed. Corrected text/modifications of
the text to make this clearer in chapter
4 and 5.
In addition have new text been added to
make this still clearer in the document.
See added text in objective and
chapter 5.
Agreed. But the document already
states that CC data in the screening
stage only should be used in terms of
reasons of concern. Use of generic data
is not recommended in the text, only
data on analogous substances where
scientifically supportable.
New text added to make this still
clearer in the document. See added text
in objective and chapter 5 and 6.
The mandate from POPRC 7 was to
consider relevant data on CC in all
stages. The scope and mandate of the
task set out by POPRC7, was to base
the guidance on UNEP/AMAP 2011.
From the conclusions and
recommendations in the report all
stages will be relevant. However, some
may have more weight than others.
This is now clearer spelled out in the
text.
The table is not fully developed in 2nd
draft, as also noted in the text.
In annex E the criteria in annex D are
used. But to do the evaluation of
environmental fate and the hazard
assessment more data are needed and
other aspects would need to be included
in the evaluation (see risk profile
outline).
The table, however, has been deleted
for other reasons.
Accepted.
Noted. Text revised.
Partly accepted. The scope and
mandate of the task set out by
POPRC7, was to base the guidance on
UNEP/AMAP 2011, and a short
introduction on interactions and impact
between CC and POPs already exists in
the document.
To summarize the findings by IPCC
would be out of scope of this guidance.
However a short introduction on
climate change is added, but only on
the impacts relevant according to the
report by UNEP/AMAP 2011.
6
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The
Netherlands
The
Netherlands
The
Netherlands
Page
Chapter
Comments
General
Should be a clear distinction between
facts and data from scientific studies
and predictions
General
Relations with the obligations if the
convention should be clear
Guidance would be greatly enhanced
when a short introduction on climate
change is added together with relevant
references. Such an introduction is
now lacking and this „climate change“
is not defined
General
The
Netherlands
General
The
Netherlands
General
The
Netherlands
General
It would be appreciated if there was
division throughout the text where
often “climate change” is used while
the underlying factor is change in
temperature
The guidance does not make a very
clear distinction between facts, data
and figures from past and present as
provided by scientific work and
predictions based on events that are
expected to happen
Abundance of “can be”, “maybe” and
“will be” can be found. No figures of
the uncertainties in these predictions
are provided in the text.
Response
Accepted. The words "can be”, “may
be” and “will be” have to a large extent
been replaced with "have been/ was
observed" and "is predicted
to/projected to" to more clearly
distinguish between observed and
predicted/projected effects and to make
the level of certainty in the cited data/
results more clear. However it should
be noted that much of the statements
made in the text and the use of the
words "can be”, “may be” and “will be”
are derived directly from the UNEP/
AMAP 2011 report.
Agreed. See changes in chapter 5.
Partly accepted. The scope and
mandate of the task set out by
POPRC7, was to base the guidance on
UNEP/AMAP 2011, and a short
introduction on interactions and impact
between CC and POPs already exists in
the document.
To summarize the findings by IPCC
would be out of scope of this guidance.
However a short introduction on
climate change is added, but only on
the impacts relevant according to the
report by UNEP/AMAP 2011.
Not accepted. Have not found places
where this has been relevant.
Accepted. The words "can be”, “may
be” and “will be” have to a large extent
been replaced with "have been/ was
observed" and "is predicted
to/projected to" to more clearly
distinguish between observed and
predicted/projected effects and to make
the level of certainty in the cited data/
results more clear. However it should
be noted that much of the statements
made in the text and the use of the
words "can be”, “may be” and “will be”
are derived directly from the UNEP/
AMAP 2011 report.
Not accepted. The aim of this text is to
highlight climate change effects on
POPs, both predicted and observed,
that POPRC should be aware of and
consider when evaluating new
substances for listing. As decided by
POPRC7 the text is based on the
UNEP/ AMAP 2011 report, which
makes predictions on climate change
effects on POPs. The UNEP/ AMAP
2011 report does not estimate the
uncertainties, hence neither does this
guidance.
Given the novelty of the topic. the
guidance, as well as the UNEP/ AMAP
report, contains quite a substantial
7
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Chapter
Comments
Response
number of "field data" or "field
observations" i.e. scientific reports on
climate change effects on POPs that
are/ have been observed in real life in
the wild and not only in the lab. In the
UNEP/ AMAP 2011 report and the
guidance these "field" data are used
along with data from controlled lab
studies and model estimates to make
more generalized predictions. Hence
although the UNEP/AMAP report
makes predictions these predictions are
rooted in actual observations.
The uncertainties will be different for
every substance, impact, scientific
test/observation and region, and even
more complex than the estimation of
climate change impacts done by IPCC.
At this stage we do not know which
substance will be nominated.
POPRC should be able take into
account any uncertainties given in the
specific data presented on CC impacts
on a specific substance, derived from
laboratory studies or field
experiments/observations. Since the
evaluation of uncertainties will not be
different from evaluation of
uncertainties in other data presented to
POPRC in the past evaluations.
The guidance underlines that any
predicted or observed effects should be
considered on a case-by-case basis (i.e.
chemical per chemical) using what is
available of data for the specific
substance. The uncertainties given in
the scientific data is then also included
in the evaluation, in a weight-ofevidence approach, as has currently
been the practice of POPRC in the past.
The
Netherlands
8
Annex D
The
Netherlands
25
The
Netherlands
8
Chapters 4
and 5
Change: Documentation of
interactions between a nominated
substance and climate change shall be
collected by the nominating Party
Delete: Shall
Add: may
Clear link needed between statements
and conclusions in chapter 5 and those
in chapter 4. Chapter 5 states “Field
studies and monitoring data indicating
increase in persistence with climate
change.” However the text in chapter
4 on persistence and Table 2 suggest
that the trend is to a shorter half life
time rather than to a higher
persistence.
Lack scientific backing, reference
needed: “POPs with endocrine
disrupting properties
This is made clearer in the text.
Accepted.
Not accepted. This is related to
statement of reasons of concern, and is
not a general evaluation. See new text.
Changes have been made to the text.
References were added to the text to
provide documentation for the
statement that POPs can have
endocrine disrupting properties.
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Chapter
Comments
Change: “POPs with endocrine
disrupting properties is adding to this
concern, since the endocrine systems
is important for Arctic mammals to
respond adequately to environmental
stressors, cognitive learning,
reproduction and sexual behavior
(Letcher et al. 2010; Jenssen 2006).”
Review: Citation summary Jenssen
(2006): “Even though behavioral and
morphological effects of persistent
organic pollutants are consistent with
endocrine disruption, no direct
evidence exists for such
relationships.”
Review: “However, the usage are still
of importance as shown by the study
contributing to the levels found in the
Adélie penguins living in the
Antarctica due to its long-range
transport, and is adding to the releases
from the melting glaciers”
Edit: statement should be backed-up
with analysis of the origin of the DDT
found in the penguins i.e. not clear on
the amount of concentration of DDT
in the penguins originates from the
present usage.
8
The
Netherlands
11
The
Netherlands
11
Review: The survey revealed
remarkably higher levels of
dichlorodiphenyl trichloroethane
(DDTs) in the flooded arable soil than
in reference soil samples.
Edit: No information is provided on
the reference soil samples, so it is not
if the soils are comparable in
composition.
The
Netherlands
18
Sudan
4
3
Sudan
Sudan
5
5
4.1
4.1(a)
Table 2: There is no reference in the
text to the temperature dependency of
homeotherms. Not clear on which
data this statement is based on.
Para 1: Where are the other 3 sections,
are they the above 3 parts, if so change
to sections or parts in the two para.
Check figures
Para 1: Climate change on the
different global regions (Check with
IPCC doc).
Impacts always depend on rise of
temperature no matter in which region.
Level of impact varies from region to
Response
Changes have been made to the text in
chapter 4.1 (c) to address this concern
and to clarify that the statement made
by Jenssen et al. 2006, that relates to
the difficulty of proving cause and
effect relationships in wild organisms.
Accepted. Several changes in the text
also made in light of other types of
comments, to make the findings from
this study clearer to the reader. The
findings Geisz et al. (2008) suggest that
climate change induced ice melting
may be a source to DDT exposure in
Adélie penguins living in Antarctica.
The authors of the study did not
perform an analysis to identify the
origin of the DDT in the penguin
samples themselves, but leans on other
data showing an increase in DDT
releases due to ice melting in the area.
To mirror the text of the cited paper
and make it clearer what "reference" in
this context means the "word reference
soil samples" has been replaced with
"reference (non-flooded soil)".
However, that the survey revealed
remarkably higher levels of
dichlorodiphenyl trichloroethane
(DDTs) in the flooded arable soil than
in "reference" soil samples is the
authors' own statement and should not
be changed. With regard to the
comparability of the soil samples the
guidance do not go into such details.
The details about their comparability
may be found in the materials and
methods section of the paper which is a
published and peer-reviewed study (i.e.
its contents and conclusion including
its the comparability of the soil samples
have been evaluated by external
reviewers and have been found
sufficiently good for publication).
Accepted. Text changed to
poikilothermic organisms.
Accepted. Text is changed.
Accepted. Text is changed.
Accepted. Text is changed.
9
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Chapter
Sudan
6
4.1(a)
Sudan
6
4.1(a)
Sudan
7
4.1(b)
Sudan
Sudan
7
8
4.1(c)
4.1(c)
Sudan
8
4.1(c)
Sudan
9
4.1(c)
Sudan
14
4.2(d)
Tanzania
General
Tanzania
General
United
States
4
2
United
States
4
3
United
States
5
4
Comments
another depending on the region. So
the variation of impacts that depend on
the region not the impact itself.
Para 4: A warming climate may also
alter the migration patterns of
contaminated species (e.g., fish and
seabirds), and may cause future
transport of POPs to previously
uncontaminated regions – sentence not
clear/how?
Para5: What is the impact on POPs
here? Reference?
Para 3/4 and 5: How? Reference
needed. Needs to be more clear
Para 2: how again?
Para 4: No relevance to climate
change regarding to
Para 5: Same as above no clear link
Para 10: Do you mean that when there
is a decrease in agriculture and
livestock due to C. C you increase the
use of pesticides, link is not clear
enough with C.C.
Para 2: True but no clear relation with
the POPs here.
(a) Typographical and grammar
which we are confident the Secretariat
will have noticed;
(b) To ensure that the objective of the
guidance document i.e. to incorporate
the complex climate change
interaction with POPs are identified
deliberate intervention by the
Secretariat will be required to enable
developing countries to effectively
participate in the process. This is
particularly important as climate
change effects will be different in
magnitude and variability in different
regions. And as such if developing
countries are not assisted, some effects
may go unnoticed for a fairly long
time.
Change: climate change on the
substance under evaluation,
Add: climate change even if there is
not specific information on the
chemical under evaluation,
consideration can be given to data on
analogous substances where
scientifically supportable
Para 1: it is unclear if the three parts
being referred to are distinct from the
Sections 4-7 below or if Sections 4-7
make up the three parts. Also, if the
three parts consist of Section 4-7, it is
confusing that there are four Sections
representing three parts.
Citation needed: Climate change will
alter salinity, ocean acidification,
eutrophication, water oxygen levels,
and the nutritional status of species
and their adaptability
Citation needed: Toxicity and toxicokinetics of POPs could be altered as a
direct result of changes in temperature
Response
Text added to make this more clear.
Text added to make this more clear.
Text added to make this more clear,
and references added.
Text added to make this more clear.
Text changed to make the link to CC in
the para more clear.
Text changed to make the link to CC in
the para more clear.
Text added to make this more clear.
Text added to make this more clear.
Noted.
Partly accepted. See text added to the
recommendations in chapter 7 and in
the Executive summary.
Accepted.
Accepted. Text is changed.
Accepted.
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Unclear what kind of regional
variability is referred to here. There is
variability between regions in how
large the increase in temperatures is
observed to have been and is projected
to be. Have not found any statements
that some regions may cool in the
observations and projections by IPSS.
See the added text from IPCC 2007 b,
c.
See the added text from IPCC
2007 b, c.
6
4(a)
Para 2: This is factually incorrect.
Some regions may cool in a warmer.
Could clarify the statement to read
“Each of these climate zones are very
likely to experience varying degrees of
warming as global temperatures
increase, though strong regional
variability will exist”.
6
4(a)
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Para 3: These statements are all too
definitive and do not reflect the
current state of climate science in the
sense that a large degree of regional
variability is likely. These statements
either need to have caveated language
citing regional variability OR perhaps
better would be to take statements
directly from IPCC’s AR4 WG1
report (2007).
Para 5: This has not been observed
yet, but it is projected to occur if the
stratosphere continues to cool.
Para 2: Increased heat and sunlight do
not cause changes in salinity as much
as freshwater inputs (and other
factors) do. See first para on next
page which is much more accurately
stated.
Para 4: Have wind speeds increase
over all of the oceans?
Para 6: Will the trend *increase* or
*continue*? These are two very
different consequences. Check the
Schiedek reference.
Para 6: Perhaps list some areas that
will be affected; these are NOT global
impacts, so stressing the regional
difference is important for local
decision-makers.
Para 8: What is meant by this “species
composition”, physical composition
(physiology) of species?
Please define this acronym – OHC
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4(c)
Para 9: Ever what? Due?
Text revised.
9
4(c)
Agreed. Text added.
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4.2 (a)
Para 10: The link between pathogens
contaminating food as a result of
extreme weather is not intuitive and
deserves more elaboration. Also, this
will not be observed similarly across
the globe. The scientific community’s
understanding of how climate change
will impact extreme events is in its
infancy, so please take great care in
drawing links between extreme
weather and climate change.
Para 2: First time the term “legacy
POPs” has been used and is worthy of
being defined.
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4.2(a)
Para 3: Release of What? DDT? Not
clear.
Unclear what kind of regional
variability is referred to here. There is
variability between regions in how
large the increase in temperatures is
observed to have been and is projected
to be.
Accepted. Text changed.
Not agreed. This sentence is referring
to open ocean waters, where fresh
water inputs have less influence on the
salinity, and is correct according to the
references used. See added text
Text added to make this more clear.
Accepted. Text changed.
Accepted. Text added.
Text reworded.
Text revised.
“Legacy POPs” has been removed and
the specific substances added instead.
“Legacy POPs” has also been removed
in other places.
Accepted. Text added.
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Comments
Para 5: Is this accurate? Seems odd
that one site would continue to
observe this “pulse” years after the
event itself since wind would transport
these pollutants away,
typically…unless there is a continuous
source of revolatilization?
Para 6: This is an unsubstantiated
statement, attributing any single
extreme event to climate change is
virtually impossible and subject to
great uncertainty, so it is best to avoid
such statement altogether.
Para 7: As stated above, this is also an
unsubstantiated statement. We suggest
that this sentence is deleted.
Para 8: Not a globally true statement.
Characterize with appropriate
regionally-specific language
Insert citations
Para 8:
Do we really have reliable records of
these events – and the consequent
extreme events associated with them –
to make such bold statements – prior
to 1900? Can this be gleaned from
paleo data?
Para 3: Why are subtropical latitudes
called out explicitly?
Para 4: Was this a region-specific
study or are the findings relevant to
ALL soils ALL over the word?
Para 1: Again, less definitive
statements would be more
scientifically accurate; i.e. “is
projected to”, etc.
Para 2: Might be worth pointing out
somewhere that – as noted earlier –
both more rain/more drought – like
conditions can both cause an increase
in POP mobilization.
Para 2: How does an increased
environmental exposure (to POPs)
cause an increase in the levels of food
and water? Not clear
Table.1: temperature – again, for all of
these taper down the definitive nature
of the statements to more accurately
reflect the state of the science,
“increase temps are projected to cause
an increase in the water….”
This comment applies to the entire
table.
Para 1: How does this effect compare
to the INCREASE revolatilization of
POPs due to increased rainfall and
drought in other areas??
Para 2: Particles are not necessarily
lipids? In fact most airborne
particulate matter is not lipid-based,
but largely inorganic (black carbon,
sulfate, nitrate, etc.). In short, it is not
clear what the relevance of lipid
affinity is here.
Response
Accepted. Text added.
Agreed. Text from IPCC reports added
on this matter.
Agreed. Text from IPCC reports added
on this matter.
Not accepted. Text added from IPCC
report.
Conclusion from IPCC 2007 report and
Li have used records 1,100 years back
in time on drought reconstruction based
on tree ring records. Citation added.
See explanation under 4.1.b
Text and more references are added.
Accepted.
Not agreed. It is mentioned elsewhere
in the document, but does not imply to
be mentioned in the concept explained
here. See added text.
Agreed. Text added.
Accepted. Text revised.
Increase in rainfall and drought may
give a remobilization of POPs to air
and water, due to soil erosion and
evaporation. This is not connected to
persistence dealt with in this section.
But perhaps the question has been
misunderstood.
Text changed to be more precise.
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4.6(b)
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4.6(C)
Comments
Response
Para 1: How is this defined? More
favorable for what?
Para 1: Specific dependent (What is
meant by this???)
Para 7: Change will cause (Again, less
definitive statements would be more
scientifically accurate “climate change
is projected to….” Etc.
Para 1: What are environmental
“compartments”?
Para 1: We suggest citing the
Hemispheric Transport of Air
Pollutants project (HTAP) that had a
specific section on long-range
transport of POPs:
http://www.htap.org/activities/2010_Fi
nal_Report/HTAP%202010%20Part%
20C%20110408.pdf
Para 4: lipid affinity
(Again, not sure where lipid affinity
comes into play from an atmospheric
chemistry standpoint?)
Para 6: Some photolytic reactions DO
have a strong temp dependence
Cite the more recent IPCC report from
2007
(Macdonald, 2005) - There is a heavy
reliance on this single study
throughout this section. It might be
worth looking for more recent/diverse
investigations into this area. Read and
cite the HTAP report, which is a
comprehensive assessment of the
topic. Also, check of the ARCTAS
field campaign:
http://www.espo.nasa.gov/arctas/
Para 7: What is the “polar dome”? the
dynamical polar vortex of atmospheric
circulation?
Text revised.
Table 4. – Modified wind fields and
higher wind speeds (How confident is
the community that wind speeds will
increase? And assuredly, this cannot
be a global statement. Therefore, this
language should be caveated
accordingly (regionally, etc.).
Para 1: Increased salinity – The
aforementioned factors would cause a
*decrease* in salinity.
Para 2: Why? Also, cite example of
where this is likely to occur
Table.5: Salinity
Where is salinity projected to
increase? Most of this report talks
about salinity declines in marine
environments because of freshwater
inputs? Or is this outweighed by
evaporation that leads to increased
salinity levels? Either way, a clearer
explanation – with citation – is
warranted.)
Accepted. Text from IPCC used.
Text revised.
Accepted.
Text revised.
Reference is added, although the
reference provided did not look at the
relationship between CC and POPs.
The reviews referred to are believed to
satisfy the scientific backing of the
statements made.
Text changed to be more precise.
Need a reference to change this
sentence. The review by Mac Donald et
al., (2005) conclusion is based on the
literature available up to 2005.
Mac Donald et al., 2005) is a
comprehensive review of this topic, as
well as UNEP/AMAP 2011 and 2012.
HTAP report is not looking at the
climate change effect on LRT of POPs.
I checked the ARCTAS campaign, but
did not find their publications.
A statement from IPCC is used instead.
Text revised.
This is already elaborated on in 4.1.b
Text revised.
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Comments
Para 2: Not only predictions based on
modeling will be relevant for the
evaluation of long-range transport and
climate induced effects on the
transport
(…but what else will be? In situ
observations. Also, consider citing
HTAP project again in this section. )
Long-range transport (para 1 and 2):
This is all relating to one study, much
more appropriate to cite and discuss
the findings of the HTAP project
which was an assessment of peerreviewed literature, along with some
new research.
Table.6 title: While intuitively true,
this is a qualitative table that could
really benefit from citing some
literature to back up the claims.
Throughout, there are scientific
statements that are not backed up by
references. To most appropriate
characterize the science – and in still
the highest degree of confidence in the
guidance – a more substantial review
of the scientific literature is warranted,
and these studies should be cited
accordingly. We note many places
where such citations would be
valuable.
United
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General
United
States
General
Given the guidance’s deep
connections to the science of climate
change, we would encourage that the
guidance is reviewed by climate
science experts to avoid any
inaccuracies.
United
States
General
In quite a number of areas, there are
characterizations of climate change
impacts that go beyond the current
state of knowledge with respect to the
certainty of the causality and the
definitiveness and significance of the
impact(s). For example, throughout
the draft report, sentences state,
“Climate change will…” It is more
appropriate and accurate to state,
“Climate change is projected to…”
We have highlighted a number of
areas where this minor language
change could be implemented.
Response
Text revised.
This part is describing a study as an
example of data you may come across
and give guidance on how to evaluate
the data against the criteria, and while
doing so taking into account the cc
impact.
Citation added.
As decided by POPRC7 the text is
based on the UNEP/ AMAP 2011
report which makes predictions on
climate change effects on POPs. This
was a substantial review of the
scientific literature available at the time
(2011). All conclusions on CC and
POPs are from this report. In addition
several other reviews on CC impact and
interactions with POPs and
contaminants are used in this guidance.
The references referred to in those
reviews are checked as far as possible.
Citations are provided. In addition
IPCC report is now referred to in all
places where relevant, and a short
summary on CC impacts of relevance
given.
Three experts involved in drafting the
UNEP/AMAP 2011 report and other
reviews on this subject have been
consulted and have given comments to
the text. In addition to experts on cc
from the Climate and Pollution Agency
in Norway have checked the
information on CC impacts.
See the above response.
This could be a thought for POPRC to
consider after it has reviewed the
guidance.
Accepted, though not agreed. The
statements have been checked against
the findings in the IPCC report.
Citations are given to make this more
clear.
In addition have the words "can be”,
“may be” and “will be” to a large
extent been replaced with "have been/
was observed" and "is predicted
to/projected to" to more clearly
distinguish between observed and
predicted/projected effects and to make
the level of certainty in the cited data/
results more clear. However it should
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General
In a similar vein, many climate change
impacts will vary significantly on a
regional basis. This important
distinction does not come through in
this draft report which tends to make
broader, global statements. The report
could benefit by – where possible –
citing specific case studies /examples /
regions where these impacts are
known to or projected to occur. We
note several places where such
insertions would be valuable.
We think the section is unnecessary
because much of the information is
already captured in other sections.
Therefore, we suggest deleting the
section in its entirety.
It is redundant to summarize the
scientific discussion in Chapter 4 in
the first section of Chapter 5 and we
therefore suggest deletion.
“Will not change the POP properties”
in para 3: We question whether this
can be stated with such absolute
certainty. We can imagine scenarios
where ambient conditions (temp,
humidity, etc.) may impact the
biochemical properties of the POP and
its impacts on organisms. Isn’t this
correct? Therefore, please consider
modifying the language to be less
definitive. Or narrow the scope of
“POP properties” to those that will not
change (i.e., the molecular structure,
perhaps?).
This paragraph seems out of place.
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The first two paragraphs are repetitive.
We have provided edits, but we
believe that the best path forward
would be to entirely delete the first
paragraph to reduce redundancy.
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We question highlighting these criteria
when the guidance document does not
discuss the specific criteria in each
Annex.
Response
be noted that many of the statements
made in the text and the use of the
words "can be”, “may be” and “will be”
are derived directly from the UNEP/
AMAP 2011 report.
More regional data on CC impact is
added observed or projected in the
fourth report by IPCC.
Partly accepted. Text added of
relevance for the review processes
under POPRC. Needed to explain the
solutions in the sub chapters coming.
Accepted.
Agreed. Climate change effects in a
real-life exposure scenario can affect
and modulate physico-chemical and
biological processes and thereby impact
the conditional expressions of intrinsic
properties of POPs. The intrinsic
properties that are referred to in the
text, however, are not predicted to
change with climate change. "POP
properties" deleted and exchanged with
"intrinsic properties", to make this
clearer.
Not agreed. But text changed to make
the relevance more clear.
Accepted to delete the text.
Accepted. Text revised.
For example, the section in the
guidance document on persistence
discusses Increased abiotic and
photolytic degradation rates, increased
microbial degradation or hampered
microbial activity depending on the
capacity of the microorganisms to
endure climate fluctuations, and the
impact of alterations in salinity. How
does this result in Annex D(1)(b)(ii),
“Evidence that the chemical is
otherwise sufficiently persistent to
justify its consideration within the
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scope of the Convention,” being a
strong enough criteria that is warrants
being highlighted in the Conclusion
chapter versus the more specific
Annex D(1)(b)(i), “Evidence that the
half-life of the chemical in water is
greater than two months, or that its
half-life in soil is greater than six
months, or that its half-life in sediment
is greater than six months”? The
thought process of highlighting these
specific elements of the Annexes is
not clear.
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If specific criteria are highlighted, then
the author should provide an
explanation of why each measure
should be given extra weight when
considering the interaction between
climate change and POPs. An
alternative is to delete this sentence.
We do not clearly understand what is
being suggested in these two
sentences. This could be interpreted
as the guidance suggesting amending
the text of the Convention; this is a
matter for consideration at the COP,
not the POPRC. Such a suggestion
should be deleted. Additionally, it is
beyond the mandate for this guidance
document (POPRC-7/11). If this is
not the intention, then the sentences
need to be clarified. Further, we
question highlighting “movement
towards sustainable development” in
Annex F. From our viewpoint, this
appears to be selecting the most
ambiguous element of the Annex and
suggesting it is the most appropriate
place to discuss climate change
impacts, which is not a convincing
recommendation. What is the
author’s reasoning for selecting
“movement towards sustainable
development” over other elements?
Text revised to be more clear.
However, based on the findings in the
guidance a change of the annex E and F
is recommended in the text. From the
possible magnitude of the climate
change interactions on POPs, this needs
to be more explicitly addressed in the
guidance. This kind of information
should be presented to the POPRC if
available. The movement towards
sustainable development is deleted.
However, on a chemical by chemical
basis, and only if chemical specific
information is available. It will not be
stronger criteria than "the toxicological
interactions" mentioned in Annex E
already.
We have provided suggested text.
Para 3 is redundant to what has
already been stated.
Not agreed.
Para 4: Please see our comment above
regarding the recommendation to add
multiple stressers in Annex E. This
would be a matter for the COP. Also,
this is beyond the scope of the
guidance document. Additionally,
even if appropriate, this paragraph is
repetitive.
Not agreed. Multiple stressors is one of
the key findings in the report and
clearly related to CC interactions with
POPs. Multiple stressors have been
identified by UNEP/AMAP expert
group and other reviews to be an
important element when considering
adverse effects of contaminants and
climate change. The POPRC should
take into account all matters of concern
and multiple stressors could be one of
these. On this basis POPRC could
consider to address this in Annex E
more explicitly, to ensure that this is
considered when evaluating risk.
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IPEN
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4.2(c)
IPEN
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4.3(a)
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4.5(a)
Comments
Response
References are missing: Holoubek, I.,
Klánová, J., Jarkovský, J., Kohoutek,
J. (2007): Trends in background levels
of persistent organic pollutants at
Kosetice observatory, Czech Republic.
Part I. Ambient air and wet deposition
1988-2005. J. Environ. Monitoring,
9:557 – 563.
Reference is added.
Study on temperature and herbicide
not included - describes one of the few
experiments where the two impacts
were investigated in experiments, so
the results are experimental results and
not just deductions from observations
where cause and effect cannot be
firmly linked
Study: van Dam, J.W., Negri, A.P.,
Mueller, J.F., Altenburger, R. and
Uthicke, S. (2012) Addictive pressures
of Elevated sea surface temperatures
and herbicides on symbiont-bearing
foraminifera, pLoS ONE
Para 2: add: as well as general
management issues for its wate phase,
for example, possible disposal in
landfill susceptible to water incursion.
Some references such as Blais et al.,
2007, Krümmel et al., 2003 are
missing from the reference list
Para 10: Add: Climate change may
exacerbate the contamination and
availability of fish and marine
mammals that are essential to the diet
of Arctic Indigenous people, thus
profoundly affecting food security.
Para 7: Delete: The extreme flood
event has been suspected to be a result
of climate change in Central Europe
Add: This is an example of the type of
extreme flooding event that may
increase in frequency with climate
warming
Para 3: “For POPs of high persistence
like PCB and PFOS an increase of the
environmental temperature would
have insignificant effect”
Not sure I understand the rationale for
this statement, probably needs another
explanatory sentence`?
Para 3: Add: Melting sea ice may pose
a particular threat to the species-rich
marine communities of the ice edge
polnyas, as stored reservoirs of POPs
are mobilized directly into this fragile
environment. Declining sea ice may
also increase atmospheric loading to
ice-free ocean waters. The 2009
AMAP report raises the concern, for
example, that in a warmer Arctic there
will be increase loading of endosulfan
from the atmosphere to ice-free ocean
surfaces.
Accepted. Text added.
Not accepted. Seems out of place in
this para.
References are added.
Need a reference to include this
statement.
Partly agreed. Text from IPCC reports
added on this matter.
Agreed. Text changed.
Partly accepted. Text on endosulfan has
been added. Need a reference to include
the statement on polnyas.
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Chlorine
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General
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Chlorine
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General
Comments
Para 4: “However, it should be taken
into account that the increase of a
substance in organisms is not in itself
always an indicator of an increase in
bioaccumulation”
The sentence may need more of an
explanation
Table.7: it would be very useful for
POPRC members to at a glance known
whether an impact should be
considered under each of the Annexes
including F. e.g. impacts on assessing
costs including environmental and
health costs of control measures and
alternatives assessments are affected
by climate change effects.
Para .7: Add; Are the tested species
including and sex
Add: How can the impacts including
additive/synergistic impacts of real
world exposure be incorporated into
the method?
Para 9: Add; number of “expert
judgments”
• As the understanding of climate
change as well as its potential effect
on the POPRC’s work is in its initial
stages, it seems useful to apply a
stepwise approach, as proposed.
• It is well established that changes in
climate over time may cause
temperature rises and decreases. Even
for the last decades there are different
views on whether the temperature has
risen, stayed steady or even decreased.
Therefore the report should provide
guidance for temperature increases
and for decreases on potential effects
on POP assessment.
• The report makes a useful step from
the UNEP/AMAP 2001 report towards
guidance, but the key element which
still needs to be developed is
quantification of the various possible
effects. For example, under
‘Bioaccumulation’ 5.2.2. , 2nd
paragraph, salinity changes are
mentioned. In order to make such
elements useful for POPRC’s
evaluation work it would be necessary
to indicate what the suggested changes
would mean in a quantitative way.
Only then it can be established
whether the element is of relevance in
relation to the POP criteria (in this
case bioavailability-bioconcentration)
or whether this is negligible.
Response
Accepted. Text deleted.
Noted. However, the relevant
information is given in chapter 5. Table
is deleted.
Agreed. Text added.
Accepted.
Noted.
The document is based on the
observations and projections by IPCC.
The text has been changed to make this
clearer.
The uncertainties and ranges of changes
that may have an impact will be
different for every substance, impact,
scientific test/observation and region,
and even more complex than the
estimation of climate change impacts
done by IPCC. At this stage we do not
know which substance that will be
nominated. On this basis
quantifications of the various possible
effects will not be possible to do on a
general basis. This has to be evaluated
chemical by chemical and based on
documented scientific findings with
uncertainties and ranges of change
given in the scientific results.
POPRC should be able take into
account any uncertainties or ranges of
change given in the specific data
presented on CC impacts on a specific
substance, derived from laboratory
studies or field
experiments/observations. Since the
evaluation of uncertainties or ranges of
change will not be different from
evaluation of uncertainties and ranges
in other data presented to POPRC in
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the past evaluations.
The guidance underlines that any
predicted or observed effects should be
considered on a case-by-case basis (i.e.
chemical per chemical) using what is
available of data for the specific
substance. The uncertainties or ranges
given in the scientific data is then also
included in the evaluation, in a weightof-evidence approach, as has currently
been the practice of POPRC in the past.
World
Chlorine
Council
General
• It would be useful to have some well
documented case-studies providing
thoroughly evaluated evidence on
climate related quantitative effects on
either the screening criteria or the
Annex E type of evidence.
This is made clearer in the text.
Noted. There are several reviews and
studies on this matter that are included
in the guidance.
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