Stockholm Convention on Persistent Organic Pollutants

Transcription

1 UNITED NATIONS SC UNEP/POPS/COP.8/13 Stockholm Convention on Persistent Organic Pollutants Distr.: General 22 November 2016 Original: English Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants Eighth meeting Geneva, 24 April 5 May 2017 Item 5 (e) of the provisional agenda* Matters related to the implementation of the Convention: listing of chemicals in Annex A, B or C to the Convention Recommendation by the Persistent Organic Pollutants Review Committee to list decabromodiphenyl ether (commercial mixture, c-decabde) in Annex A to the Convention and draft text of the proposed amendment Note by the Secretariat I. Introduction 1. At its tenth meeting, by its decision POPRC-10/2, the Persistent Organic Pollutants Review Committee adopted a risk profile for decabromodiphenyl ether (commercial mixture, c-decabde) 1 and decided that the decabromodiphenyl ether component (BDE-209) of c-decabde was likely, as a result of its long-range environmental transport, to lead to significant adverse human health and environmental effects such that global action was warranted. 2. At its eleventh meeting, by its decision POPRC-11/1, the Committee adopted a risk management evaluation for decabromodiphenyl ether (commercial mixture, c-decabde) 2 and decided, in accordance with paragraph 9 of Article 8 of the Stockholm Convention on Persistent Organic Pollutants, to recommend to the Conference of the Parties to the Stockholm Convention that it consider listing decabromodiphenyl ether (BDE-209) of c-decabde in Annex A to the Convention with specific exemptions for some critical spare parts, to be defined, for the automotive and aerospace industries. 3. In the same decision the Committee also invited Parties and observers, including from the automotive and aerospace industries, to provide information that would assist the Committee in further defining such critical spare parts and invited Parties and observers from small and medium-sized enterprises of the textile industry in developing countries to provide information on the use of decabromodiphenyl ether in the textile industry before 31 January The Committee also decided to establish an intersessional working group to prepare an assessment of the information provided by Parties and observers with the intention of strengthening the recommendation on the listing of the chemical for consideration at its twelfth meeting. K * UNEP/POPS/COP.8/1. 1 UNEP/POPS/POPRC.10/10/Add.2. 2 UNEP/POPS/POPRC.11/10/Add.1.

2 4. At its twelfth meeting, by its decision POPRC-12/4, the Committee agreed on an assessment of the additional information on decabromodiphenyl ether 3 and adopted the summary, conclusion and recommendations of that assessment as an addendum to the risk management evaluation for the chemical In the same decision, the Committee decided, in accordance with paragraph 9 of Article 8 of the Convention, to recommend to the Conference of the Parties that it consider listing decabromodiphenyl ether (BDE-209) of c-decabde in Annex A to the Convention with specific exemptions for the automotive industry, with the production and use of c-decabde limited to parts for use in legacy vehicles, defined as vehicles that have ceased mass production, and with such parts falling in one or more of the following categories: (a) Powertrain and under-hood applications such as battery mass wire, battery interconnection wire, mobile air-conditioning (MAC) pipe, powertrains, exhaust manifold bushings, under-hood insulation, wiring and harness under hood (engine wiring, etc.), speed sensors, hoses, fan modules and knock sensors; (b) Fuel system applications such as fuel hoses, fuel tanks and fuel tanks under body; (c) Pyrotechnical devices and applications affected by pyrotechnical devices such as air bag ignition cables, seat covers/fabrics (only if airbag relevant) and airbags (front and side). 6. In addition, the Committee concluded that the information from the aerospace industry made available to the Committee did not allow the further defining of critical spare parts for that industry and that there was no apparent need for an exemption for textile production in small and medium-size enterprises in developing countries. 7. Pursuant to paragraph 2 of Article 21 of the Convention, on 20 October 2016, more than six months before the eighth meeting of the Conference of the Parties, the Secretariat communicated the Committee s recommendation on decabromodiphenyl ether to the Parties and signatories to the Convention and invited Parties to provide any comments. A compilation of comments received from Parties relating to the proposed listing of decabromodiphenyl ether is set out in document UNEP/POPS/COP.8/INF/21. The executive summary of the risk management evaluation on decabromodiphenyl ether and the decisions of the Committee setting out its recommendations in respect of decabromodiphenyl ether are reproduced in the annex to the present note. The executive summary is presented without formal editing. 8. As indicated in paragraph 9 of Article 8 of the Convention, the Conference of the Parties, taking due account of the recommendations of the Committee, including any scientific uncertainty, is to decide, in a precautionary manner, whether to list the chemical, and specify its related control measures, in Annexes A, B and/or C to the Convention. If the Conference of the Parties decides to list the chemical in Annexes A, B and/or C, the respective annex or annexes will be amended in accordance with Articles 21 and 22 of the Convention. II. Proposed action 9. The Conference of the Parties may wish to adopt a decision along the following lines: The Conference of the Parties, Having considered the risk profile, the risk management evaluation and the addendum to the risk management evaluation for decabromodiphenyl ether (commercial mixture, c-decabde) as transmitted by the Persistent Organic Pollutants Review Committee, 5 Taking note of the recommendation by the Persistent Organic Pollutants Review Committee that decabromodiphenyl ether (BDE-209) of c-decabde be listed in Annex A to the Convention with specific exemptions, 6 3 UNEP/POPS/POPRC.12/INF/9/Rev.1 4 UNEP/POPS/POPRC.12/11/Add.4. 5 UNEP/POPS/POPRC.10/10/Add.2; UNEP/POPS/POPRC.11/10/Add.1; UNEP/POPS/POPRC.12/11/Add.4. 6 UNEP/POPS/COP.8/13. 2

3 1. Decides to amend part I of Annex A to the Stockholm Convention on Persistent Organic Pollutants to list decabromodiphenyl ether (BDE-209) present in commercial decabromodiphenyl ether therein, with specific exemptions for the production and use of commercial decabromodiphenyl ether limited to parts for use in legacy vehicles, defined as vehicles that have ceased mass production [and for critical spare parts for the aerospace industries] by inserting the following row: Chemical Activity Specific exemption Decabromodiphenyl ether (BDE-209) present in commercial decabromodiphenyl ether Production Use As allowed for the Parties listed in the Register Parts for use in legacy vehicles in accordance with Part [ ] of this Annex 2. Also decides to insert a new part in Annex A as follows: Part Decabromodiphenyl ether (BDE-209) present in commercial decabromodiphenyl ether [Critical spare parts for the aerospace industry in accordance with Part [ ] of this Annex] The production and use of decabromodiphenyl ether (BDE-209) present in commercial decabromodiphenyl ether shall be eliminated except for Parties that have notified the Secretariat of their intention to produce and/or use it in accordance with Article 4 of the Convention. Specific exemptions may be available for the production and use of commercial decabromodiphenyl ether limited to parts for use in legacy vehicles, defined as vehicles that have ceased mass production, and with such parts falling in one or more of the following categories: (a) Powertrain and under-hood applications such as battery mass wire, battery interconnection wire, mobile air-conditioning (MAC) pipe, powertrains, exhaust manifold bushings, under-hood insulation, wiring and harness under hood (engine wiring, etc.), speed sensors, hoses, fan modules and knock sensors; body; (b) Fuel system applications such as fuel hoses, fuel tanks and fuel tanks under (c) Pyrotechnical devices and applications affected by pyrotechnical devices such as air bag ignition cables, seat covers/fabrics (only if airbag relevant) and airbags (front and side). [Specific exemptions may also be available for the production and use of commercial decabromodiphenyl ether limited to critical spare parts for the aerospace industries, defined as ] 3

4 Annex Risk management evaluation on decabromodiphenyl ether (commercial mixture, c-decabde) and the recommendations of the Persistent Organic Pollutants Review Committee I. Executive summary of the risk management evaluation on decabromodiphenyl ether (commercial mixture, c-decabde) 1 1. In 2013, Norway submitted a proposal to list commercial decabromodiphenyl ether (c-decabde) as a persistent organic pollutant under the Stockholm Convention. In 2014, at the 10 th meeting of the POPs Review Committee, it was decided that BDE-209, the main constituent of c-decabde is likely, as a result of its long-range environmental transport, to lead to significant adverse human health and environmental effects, such that global action is warranted. An ad hoc working group was established to prepare a risk management evaluation for c-decabde, in accordance with Annex F of the Convention, for consideration by POPs Review Committee at its 11th meeting in October C-decaBDE is an intentionally produced chemical consisting of the fully brominated decabde congener or BDE-209 ( 90-97%), with small amounts of nona- and octa-bromodiphenyl ether. C-decaBDE has been under investigation for its potential health and environmental impacts for more than a decade and has been subject to restrictions and voluntary risk management actions in some countries and regions, as well as by some companies. Production of c-decabde but is still ongoing in a few countries globally. 3. C-decaBDE is an additive flame retardant that has a variety of applications including in plastics, textiles, adhesives, sealants, coatings and inks. C-decaBDE containing plastics are used in electrical and electronic equipment, wires and cables, pipes and carpets. In textiles, c-decabde is mainly used in upholstery, window blinds, curtains and mattresses for public and domestic buildings, and in the transportation sector. The amount of c-decabde used in plastics and textiles globally varies but up to about 90% of c-decabde ends up in plastic and plastics used in electronics while the remainder is used in coated textiles, upholstered furniture and mattresses. 4. Emissions of c-decabde to the environment occur at all its life cycle stages, but are assumed to be highest during service life and in the waste phase. The average service life for electric and electronic equipment is about 10 years hence c-decabde will continue to be released to the environment through articles in use for years to come. The most efficient control measure to reduce the releases of c-decabde and its main constituent BDE-209, would be to list BDE-209 (c-decabde) in Annex A of the Convention without specific exemptions. Furthermore, efficient control measures for the handling of waste containing c-decabde will also be essential. Due to the historical- and present use of c-decabde as a flame retardant, a large number of products in use will become waste in the future. Controlled incineration of waste containing c-decabde at high temperatures is one way of destruction, with systems to remove possible brominated furan/dioxin compounds produced in the process, along with continuous monitoring and strict compliance with Convention BAT/BEP guidelines and environmentally sound treatment of fly ashes. Other means are described in document UNEP/POP/COP.7/INF/22 which also provides constraints in recycling. 5. According to Article 6 of the Convention, waste shall be disposed of in such a way that the POP content is destroyed or irreversibly transformed so that it does not exhibit the characteristics of POPs, or otherwise disposed of in an environmentally sound manner when destruction or irreversible transformation does not represent the environmentally preferable option or the POP content is low. For this reason, recycling of material containing c-decabde above the low POP content limit value is not recommended and should be avoided. Recently, BDE-209 has been detected in a number of articles, made from recycled material, including articles in contact with food. This indicates that it is difficult to control the content of c-decabde in plastic material destined for recycling and that recycling may contribute to human exposure to c-decabde. Monitoring data also shows that recycling contributes to significant environmental pollution and health risks for local populations, particularly in developing countries where recycling occurs in the informal sector. Technical solutions are available in the waste sector to achieve more sustainable waste management e.g. by sorting out components containing hazardous chemicals are not available on an industrial scale and especially in developing countries. A 4 1 UNEP/POPS/POPRC.11/10/Add.1.

5 restriction on c-decabde might have an economic impact on the recycling industry, but the economic costs and benefits are hard to predict. At present, recycling of c-decabde containing plastics and textiles is not known to occur to a great extent and available information suggests that the socioeconomic impact of not recycling c-decabde may be limited. 6. On a country or regional basis an analysis of the economic impacts to recycling facilities needs to be undertaken. What could be defined as an optimal solution depends very much on the economic and cultural context in which the system operates. The cost of labour, the structure of the economy including the important informal sector, the existing regulatory framework and the possibilities and limits of law enforcement have to be taken into account in order to find solutions that can improve the situation with regard to environmental impacts, occupational hazards and economic revenue. 7. Based on the information submitted during the risk management evaluation and the collective experience reported, there may be challenges for some sectors, i.e., legacy spare parts for the aerospace and automotive industries. Some parties identified challenges for recycling. Because of the concerns about articles, products in use, and recycled products containing decabde being exported especially to developing countries and countries with economies in transition, other experts opposed recycling exemption due to lack of capacity to identify and analyse products containing deca BDE. Additional risk management measures could include an obligation to label new articles that contains decabde. 8. However, a number of non-pop chemical alternatives are already on the market for the substitution of c-decabde in plastics and textiles. Furthermore, non-chemical alternatives and technical solutions such as non-flammable materials and physical barriers, respectively, are also available. Annex F information and other available information indicates that textile-, furniture- and electronics markets are in transition away from the use of c-decabde and that substitutions have been performed or are in progress for most, if not all, known applications. 9. A positive impact on human health and the environment can be expected from a global reduction or elimination of c-decabde. BDE-209, the main constituent of c-decabde, and its degradation products is widely detected in the indoor and outdoor environments and is found in some organisms at levels close to or at reported effect concentrations for developmental-, neurotoxic-, and endocrine disruptive effects. 10. The Committee recommends, in accordance with paragraph 9 of Article 8 of the Convention, the Conference of the Parties to the Stockholm Convention to consider listing and specifying the related control measures of the decabromodiphenyl ether component (BDE-209) of c-decabde in Annex A with specific exemptions for some critical legacy spare parts that still need to be defined in the automotive and aerospace industries. II. Summary, conclusion and recommendations of the assessment of additional information on decabromodiphenyl ether (commercial mixture, c-decabde) for the further defining of some critical spare parts in the automotive and aerospace industries and on the use in textiles in developing countries 2 Summary 1. By its decision POPRC-11/1, the Persistent Organic Pollutants Review Committee has invited further information on some critical spare parts in the automotive and aerospace industry requiring the continued use of decabromodiphenyl ether (commercial mixture, c-decabde) with the purpose of assisting the Committee in further defining such parts and strengthening the decision on listing for consideration at its twelfth meeting (POPRC-12). In addition, Parties and observers from small and medium-size enterprises in the textile industry in developing countries were invited to provide information on the use of c-decabde in textiles. 2. The information from the risk management evaluation and this intersessional work confirms that substitution of c-decabde is possible and that phase-out of c-decabde is ongoing in both the automotive and aerospace industries. The submitted information may allow the Committee to further define critical spare parts in the automotive industry. No additional information indicating any use of 2 UNEP/POPS/POPRC.12/11/Add.4. The summary, conclusion and recommendations are reproduced, except for acronyms, as set out in the assessment contained in document UNEP/POPS/POPRC.12/INF/9/Rev.1, which has not been formally edited. 5

6 c-decabde in textiles produced by small and medium-size enterprises in developing countries was submitted. 3. The intersessional work suggests that the production and use of c-decabde in vehicles can be further defined and limited to spare parts for use in legacy vehicles. According to the submission by European Automobile Manufacturers Association (ACEA), legacy vehicles could be defined as vehicles that have ceased mass production prior to July Canadian Vehicle Manufacturers Association (CVMA) on the other hand requests an exemption for the use of c-decabde in new vehicles until 2021 and an exemption for service and replacement parts (spare parts) for up to 15 years after the entry into force of a global regulation. To accommodate the latter proposal, further listing considerations would then be required. Both ACEA and CVMA have indicated what spare parts they consider as critical and in need of a global exemption, the main difference between the two being that number of critical uses indicated by CVMA is larger, and also covers use of c-decabde in interior applications. It should also be noted that the wider exemption requested by CVMA was already requested in advance of POPRC-11 and the information provided in support of the exemption was part of the information, forming the basis for the decision making at POPRC The justifications for the exemptions provided by both industry associations relates to technical, practical and economic issues. Estimates for Europe provided by ACEA indicates that the consumption of c-decabde under their suggested definition of critical spare parts will likely be limited, but will continue for a maximum of 10 years, should the suggested definition of some critical legacy spare parts in an exemption be granted. Global estimates for use and emissions of c-decabde from such use are not available. Similarly, consumption and emission estimates for the wider exemption scenario as suggested by CVMA, which includes a larger number of spare parts, are not available. However, considering that CVMA requests that the use in new cars may continue until 2021 and that a larger number of uses will be exempted under this proposed scenario, and such uses may continue until 15 years after the entry into force of the regulation, substantially larger emissions may be anticipated, should an exemption for the requested applications be granted. Furthermore, two of the uses suggested for exemption by CVMA i.e. back coatings of textiles and shrinking tubes in wiring harnesses, were the main uses of c-decabde in automotive applications (by weight). According to ACEA and CVMA, the use in legacy spare parts is expected to be highest in the early years after the entry into force and to decline progressively. In both scenarios, increasing the waste burden in developing countries from older vehicles that continue to be serviced with spare parts that contain decabde is a concern. However, access to the spare parts can increase the life time of the vehicles. The information provided by CVMA and ACEA has not been verified by independent sources. 5. No detailed suggestions to assist in further defining critical spare parts in the aerospace industry have become available. However, some of the product types identified to contain c-decabde like carpets, life vests and seat coverings, seem less critical. Overall, the submitted information suggests that the phase-out of decabde in new aircrafts by 2018 is widely supported, but that there are regional differences in the ability to achieve phase out in existing aircraft types. The Boeing Company expects a phase-out of c-decabde to be possible by 2018, the year when the global restriction on c-decabde could enter into force, should the Parties agree to list c-decabde at the Conference of the Parties in The expected phase-out also includes all spare parts, even though a narrow exemption in this case is not fully excluded by the Boeing Company. On the other hand, submissions by the European Association for AeroSpace and Defence industries (ASD) and the Trade Organisation for the Aerospace, Defence, Security and Space sectors in the UK (ADS) suggest a continued need for the use of c-decabde in all spare parts for producing existing aircraft types in Europe (ASD 2016, ADS 2016). ASD request a derogation for the continued use of c-decabde in spare parts for existing aircraft types for the remainder of their product lives. Another option suggested is to postpone significantly the proposed date of entry into force to at least A key obstacle towards a complete phase-out of c-decabde within 2018 in vehicles and in aircrafts appears to be the costs. In addition, the industry have concerns regarding technical- and practical challenges related to the substitution including the testing and certification scheme that has to be applied. 7. The available information does not indicate any use of c-decabde in textile production in small and medium-size enterprises in developing countries. 6

7 Conclusion and recommendations UNEP/POPS/COP.8/13 8. The Persistent Organic Pollutants Review Committee has decided to recommend to the Conference of the Parties that it consider listing decabromodiphenyl ether (BDE-209) of c-decabde in Annex A to the Convention, with specific exemptions for some critical spare parts, to be further defined, for the automotive and aerospace industries. 9. For the automotive industry, the production and use of c-decabde should be limited to parts for use in legacy vehicles, defined as vehicles that have ceased mass production, and with such parts falling in one or more of the following categories: (a) Powertrain and under-hood applications such as: battery mass wire, battery interconnection wire, mobile air-conditioning (MAC) pipe, powertrains, exhaust manifold bushings, under-hood insulation, wiring and harness under hood (engine wiring etc.), speed sensors, hoses, fan modules and knock sensors; (b) Fuel system applications such as: fuel hoses, fuel tanks, fuel tanks under body; (c) Pyrotechnical devices and applications affected by pyrotechnical devices such as: air bag ignition cables, seat covers/fabrics (only if airbag relevant) and airbags (front and side); 10. Knowing that generic parts for cars in general are available and noting that some spare parts could possibly be retrofitted to legacy car models, it may be possible to limit the specific exemptions for civilian cars even further than described above. 11. The late proposal by CVMA for critical spare parts noted some regional differences and requested a wider definition that included the two main sources for c-decabde in automotive applications. The proposal was not available during the peer review process and it could not be sufficiently documented that the uses were indeed critical. It therefore could not be concluded whether it was sufficiently different from not defining any critical spare parts in the automotive industry. 12. According to ACEA and CVMA, the use in legacy spare parts is expected to be highest in the early years after the entry into force and to decline progressively. In both scenarios, increasing the waste burden in developing countries from older vehicles that continue to be serviced with spare parts that contain decabde is a concern. However, access to the spare parts can increase the life time of the vehicles. 13. For the aerospace industry a phase-out of c-decabde in new aircraft types by 2018 is widely supported, while conflicting information is provided by the aerospace and defence industry in Europe and in North America, concerning existing aircraft types. The Boeing Company expects a complete phase-out of c-decabde to be possible by the entry into force of a possible amendment of Annex A, while an exemption for the continued use of c-decabde in all spare parts for existing aircraft types for the remainder of their product lives is requested by the European industry. Some information about c-decabde containing spare parts used in existing aircraft types was given by the aerospace industry, however, it is concluded that the information does not allow the further defining of critical spare parts by the Committee. 14. The available information does not indicate any use of c-decabde in the textile production in small and medium size enterprises in developing countries. Based on this it can be concluded that there is no apparent need for an exemption for such use. As mentioned in the risk management evaluation, labelling or other means of identification of newly produced articles containing c-decabde could be useful when articles become waste, noting the implementation challenges. 7

8 III. Decisions setting out the recommendations of the Committee POPRC-11/1: Decabromodiphenyl ether (commercial mixture, c-decabde) The Persistent Organic Pollutants Review Committee, Having concluded in its decision POPRC-9/4 that decabromodiphenyl (commercial mixture, c-decabde) ether fulfils the criteria set out in Annex D to the Stockholm Convention, Having evaluated the risk profile for decabromodiphenyl ether (commercial mixture, c-decabde) adopted by the Committee at its tenth meeting 3 in accordance with paragraph 6 of Article 8 of the Convention, Having concluded in its decision POPRC-10/2 that the decabromodiphenyl ether component (BDE-209) of c-decabde is likely, as a result of its long-range environmental transport, to lead to significant adverse human health and environmental effects such that global action is warranted, Having completed the risk management evaluation for decabromodiphenyl ether (commercial mixture, c-decabde) in accordance with paragraph 7 (a) of Article 8 of the Stockholm Convention, Noting that non-persistent organic pollutant alternatives to decabromodiphenyl ether are available, 1. Adopts the risk management evaluation for decabromodiphenyl ether (commercial mixture, c-decabde); 4 2. Decides, in accordance with paragraph 9 of Article 8 of the Convention, to recommend to the Conference of the Parties that it consider listing decabromodiphenyl ether (BDE-209) of c-decabde in Annex A to the Convention with specific exemptions for some critical spare parts, to be defined, for the automotive and aerospace industries; 3. Invites parties and observers, including from the automotive and aerospace industries, to provide information that would assist the further defining by the Committee of such critical spare parts and invites parties and observers from small and medium-sized enterprises of the textile industry in developing countries to provide information on the use of decabromodiphenyl ether in the textile industry before 31 January 2016; 4. Requests the Secretariat to compile the information provided in accordance with paragraph 3 above and make it available to the Committee; 5. Decides to establish an intersessional working group to assess the information provided in accordance with paragraph 3 above with the intention of strengthening the recommendation on the listing of the chemical for consideration at its twelfth meeting. POPRC-12/4: Decabromodiphenyl ether (commercial mixture, c-decabde) The Persistent Organic Pollutants Review Committee, Recalling its decision POPRC-11/1, by which it recommended to the Conference of the Parties that it consider listing decabromodiphenyl ether (BDE-209) of c-decabde in Annex A to the Convention with specific exemptions for some critical spare parts, to be defined, for the automotive and aerospace industries, Having assessed the information provided in accordance with paragraph 3 of decision POPRC-11/1, 5 1. Adopts the addendum to the risk management evaluation for decabromodiphenyl ether (commercial mixture, c-decabde); UNEP/POPS/POPRC.10/10/Add.2. 4 UNEP/POPS/POPRC.11/10/Add.1. 5 UNEP/POPS/POPRC.12/INF/9/Rev.1. 6 UNEP/POPS/POPRC.12/11/Add.4.

9 2. Decides, in accordance with paragraph 9 of Article 8 of the Convention, to recommend to the Conference of the Parties that it consider listing decabromodiphenyl ether (BDE-209) of c-decabde in Annex A to the Convention with specific exemptions for the automotive industry, with the production and use of c-decabde limited to parts for use in legacy vehicles, defined as vehicles that have ceased mass production, and with such parts falling in one or more of the following categories: (a) Powertrain and under-hood applications such as battery mass wire, battery interconnection wire, mobile air-conditioning (MAC) pipe, powertrains, exhaust manifold bushings, under-hood insulation, wiring and harness under hood (engine wiring, etc.), speed sensors, hoses, fan modules and knock sensors; body; (b) Fuel system applications such as fuel hoses, fuel tanks and fuel tanks under (c) Pyrotechnical devices and applications affected by pyrotechnical devices such as air bag ignition cables, seat covers/fabrics (only if airbag relevant) and airbags (front and side); 3. Concludes that the information from the aerospace industry made available to the Committee does not allow the further defining of critical spare parts; 4. Also concludes that there is no apparent need for an exemption for textile production in small and medium-size enterprises in developing countries; 5. Notes that increasing waste burden in developing countries from older vehicles that continue to be serviced with spare parts that contain decabde is a concern. 9