Preparing Rotterdam Convention Notification to List Lead Chromates – A Reference and Guidance Paper

This paper is intended as a guidance and reference document for those engaged in promoting a Rotterdam Convention decision to list lead chromates in its Annex III.

It discusses why and how many of the governments that recently adopted lead paint control laws can – if they wish – submit Notifications to the Rotterdam Convention that nominate lead chromates for a Convention listing.The paper also discusses how to address several of the challenging issues that may arise when a government of a low- or middle-income country that recently adopted a lead paint control law decides it might be interested in preparing a Notification to the Rotterdam Convention.

It is the second in a series of three papers on topics that should be helpful to those interested in promoting a Rotterdam Convention decision to list lead chromates. It should also be helpful to those engaged in preparing (or helping prepare) Rotterdam Convention Notifications. 

All three papers focus on topics and solutions that are most relevant to low- and middle-income countries.

The first paper in this series is titled: Controlling Lead Chromate Pigments: The Case for a Rotterdam Convention Listing. Its topics are: What are Lead Chromates; The Lead Chromate Hazard; Uses of Lead Chromates; and the Impact of a Rotterdam Convention Listing. 

A third paper in this series will address how to prepare a Rotterdam Convention Notification that should be able to fully satisfy all the elements of the Convention’s Criterion (b). Its primary focus will be how to prepare the supporting documents that will accompany the Notifications when they are submitted.

Topics addressed in this paper:  

• Why many of the countries that recently adopted lead paint controls can notify the Rotterdam Convention that their regulatory action severely restricts lead chromates and why, because of this, they are eligible to nominate lead chromates for a Rotterdam Convention listing.
• The process the convention will use in deciding whether to list lead chromates.
• Why many of the countries that recently adopted lead paint controls can state that they did so based on a risk evaluation. And why their risk evaluations should be able to satisfy the Convention’s Criterion (b).
• Why the Convention’s PIC procedure should apply not only to lead chromates in their powder form, but also to international trade in paints that contain lead chromate pigments. And the information a Notification can contain to help ensure this happens.
• How a Notification can satisfy the Convention’s Criterion (c). And how, in doing this, the notification will demonstrate that the country imposed a sufficiently severe restriction on lead chromates to justify a decision to list them in the Convention’s Annex III.