training workshop on regulated - europa · check for obvious discrepancies missing or inconsistent...

LECTURE 7: OZONE-DEPLETING

SUBSTANCES

TRAINING WORKSHOP

ON ENVIRONMENTALLY

REGULATED SUBSTANCES

AGENDA

Why should we care about

ozone depleting substances?

Illegal smuggling and why it

occurs

Role of Customs officers in

preventing illegal trade in

ODS

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IMPACTS OF OZONE LAYER DEPLETION

Human health impacts: UV radiation

Skin cancer

Eye damage and cataracts

Immune system suppression

Environmental impacts from increased UV radiation

Ecosystems

Climate change

Crop damage (e.g., rice, soy beans)

Plankton productivity 3

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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COMMON USES OF ODS

Refrigerants

Blowing agent for foams

Cleaning solvent

Propellants for aerosols

Fire extinguishers

Fumigants

Chemical synthesis feedstocks

Sterilants for health care products

Laboratory uses

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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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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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WHY ODS SMUGGLING OCCURS

Decreasing availability of gases increases demand

Differing phaseout schedules

between developed and

developing countries

Alternative gases may cost more

Equipment containing ODS has long life:

conversion/retrofitting of equipment is costly

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ILLEGAL SMUGGLING SCHEMES

Mislabeling the canister as a non-ODS gas Noted worldwide

Example:

R-22 (or HCFC-22, Freon): illegal to trade

R-134-a (or HCFC-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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IF ONLY IT WAS ALWAYS THIS EASY…

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Reference: WCO Illicit Trade Report 2013

R-22 mix seized by Serbian Customs: July 2013

-Wrong label

-Wrong cylinder color

-Chemical name and number don’t match

MORE COMMON-

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Hand-held

analyzer results:

R22: 91.3%

R404A: 8.7%

Illegally labeled

as R134a

REFRIGERANT CYLINDER COLOR CODES

BENEFITS OF

PORTABLE REFRIGERANT ANALYZERS

Sampling of suspect cylinder at port

Does canister’s content match documentation?

Is canister’s content contaminated or a mixture?

If documentation and actual

contents do not match, analyze

in laboratory to verify

Will support legal actions

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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 ODS

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VEHICLE X-RAY SCAN

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GIFTS / DONATIONS OF SECOND-HAND

APPLIANCES MAY CONTAIN ODS AND

DANGEROUS CHEMICALS

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OLD REFRIGERATOR

CONTAINING R12

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ROLE OF CUSTOMS OFFICER IN

ENFORCING ODS REGULATIONS (UNEP)

Enforce ODS licensing system

Increase awareness of importers and exporters

Detect illegal trade

Detect illegal ODS at port: on-site analysis

Report ODS legal and illegal trade to National Ozone

Unit (NOU)

Seize illegal ODS, including storage and disposal

Support enforcement agencies in legal actions

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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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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

Misspellings of trade 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

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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 (HS, UN, chemical name/formula) on

documentation do not match actual canister

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SAFETY CONSIDERATIONS FOR

CONTAINERS AND EQUIPMENT

Do not vent ODS into the atmosphere

Do not store in a confined space

Do not store ODS in direct sunlight

Do not use open flames near ODS; watch for sparks

Do not sample ODS canisters unless you have been

trained

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

containing equipment

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AVAILABLE ON THE WEB:

Training Manual for Customs and

Enforcement Officers (3rd edition)

(UNEP)

Enforcement Strategies for Combating

the Illegal Trade in HCFCs and Methyl

Bromide (UNEP)

Ozone Depleting Substances Smuggling

and Concealment: Case Study

Handbook (Interpol/UNEP) .

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