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This same reasoning should also allow a case-by-case review of dredged 
material containing Annex I substances in light of “special care” measures 
which may allow the safe disposal of the material at sea. When this can be 
done, the rationale of the listing criteria should permit the dumping under 
a special permit, as in the case of substances classified to Annex II. 
In the succeeding sections of this submission, detailed consideration will 
be given to a number of innovative “ special care” measures which should be 
of particular benefit in the safe disposal of dredged material at sea. 
WORKING DEFINITIONS OF ANNEX I AND II PARAMETERS 
The three Annex I properties of being toxic, of being susceptible to bioac- 
cumulation, and of being persistent or refractory to degradation in the 
environment are legitimate concerns; however, we have come to learn more 
and more about the fate of pollutants in the marine environment from field 
studies and there is little hard evidence that dredged material has caused 
~ substantial biological damage in the ocean. It is our position, therefore, 
that the special care disposal measures that we address in this submission 
for disposal of dredged material containing Annex I substances will secure 
continued protection of the marine environment. 
Toxic. To state that a constituent of any material is toxic is 
equivalent to saying that it is poisonous and capable of causing death. 
The degree of toxicity depends upon several factors, including 
(a) The particular element or compound involved. 
(b) The amount of the element or compound. 
(c) The presence of other metals or substances with 
which it is synergistic or will complex. 
(d) The kind of organisms exposed to the toxicant. 
