Deleted: ¶ ¶
HEXABROMOCYCLODODECANE
DRAFT RISK MANAGEMENT EVALUATION
Prepared by the ad hoc working group on HEXABROMOCYCLODODECANE Persistent Organic Pollutants Review Committee
April 2011
Persistent Organic Pollutants Review Committee
TABLE OF CONTENTS
Executive summary ...... 3
1. Introduction ...... 5 Deleted: 4
1.1 Chemical identity of the proposed substance ...... 5 Deleted: 4 1.2. Conclusions of the Review Committee regarding Annex E information ...... 7 Deleted: 6 1.3. Data sources ...... 7 Deleted: 6 1.4. Status of the chemical under international conventions ...... 9 Deleted: 8 1.5. Any national or regional control actions taken ...... 9 Deleted: 8 2. Summary information relevant to the risk management evaluation ...... 11 Deleted: 9 2.1. Identification of possible control measures ...... 12 Deleted: 9 2.2. Efficacy and efficiency of possible control measures in meeting risk reduction goals ...... 12 Deleted: 10 2.3. Information on alternatives (products and processes) where relevant ...... 14 Deleted: 11 2.3.1 Production of high impact polystyrene (HIPS) plastic ...... 15 Deleted: 13 2.3.2 Production of flame retarded textile back-coating ...... 16 Deleted: 13 2.3.3 Production of flame retarded expanded and extruded polystyrene (EPS/XPS) ...... 17 Deleted: 13 2.4. Summary of information on impacts on society of implementing possible control measures ...... 20 Deleted: 15 2.4.1. Health, including public, environmental and occupational health ...... 20 Deleted: 15 2.4.2 Biota (biodiversity) ...... 20 Deleted: 16 2.4.3 Economic aspects, including costs and benefits for producers and consumers and the distribution of costs and benefits ...... 20 Deleted: 16 2.5. Other considerations ...... 23 Deleted: 18 3. Synthesis of information ...... 23 Deleted: 18 3.1 Summary of risk profile information ...... 23 Deleted: 18 3.2 Summary of risk management evaluation information ...... 23 Deleted: 19 3.3 Suggested risk management measures ...... 24 Deleted: 19 4. Concluding statement ...... 24 Deleted: 20 References ...... 25 Deleted: 21
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Persistent Organic Pollutants Review Committee
Executive summary 1. Hexabromocyclododecane (HBCD; also HBCDD) was proposed as a POPs candidate by Norway in 2008. In 2010, the 6th meeting of the POPs Review Committee decided that HBCD 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. 2. HBCD was considered by the Executive Body of the UNECE Convention on Long-Range Trans-boundary Air Pollution (LRTAP) to meet the criteria for POPs as defined under the POPs protocol. HBCD is included as part of the brominated flame retardants group in the List of Substances for Priority Action of The Convention for the Protection of the Marine Environment of the North-East Atlantic (the OSPAR Convention). Also the Helsinki Commission Comment [A1]: This is not documented (HELCOM) has included HBCD in the list of priority hazardous substances. from the industry, and several studies on indoor levels of HBCD in homes, offices 3. HBCD is produced in China, Europe, Japan, and the USA. The current known annual production is and cars indicate that the use in textiles and approximately 23,000 tonnes per year (9,000 to 10,000 tonnes in China, 13,426 tonnes in Europe and the US). The EE-articles can be a bigger use than main share of the market volume is used in Europe. claimed by BSEF. 4. HBCD has been on the world market since the 1960s. It is used as a flame retardant additive, with the intent of Comment [A2]: References: Managaki et al 2009, Morf et al. 2008, delaying ignition and slowing subsequent fire growth during the service life of vehicles, buildings or articles, as well as ECHA 2008, Swerea 2010 (table 7), Klif while materials are stored. The main uses of HBCD are in flame-retarded expanded (EPS) and extruded (XPS) 2010 polystyrene foam insulation, with smaller scale use in textile applications and electric and electronic appliances (high Comment [A3]: References: UNEP- impact polystyrene/HIPS). In textiles HBCD is used in back-coatings for upholstery and other interior textiles, POPS-POPRC(1).6-13-add.2 including automotive applications. The volumes of HBCD flame retarded articles imported and exported globally is Deleted: substantially generally unknown. Comment [A4]: This is a voluntary Release of HBCD into the environment may occur during all stages of its life cycle; production and manufacturing, programme, and do not include all processing, transportation, use, handling, storage or containment, point-source discharges, migratory releases from producers and users. It is mainly based on manufactured product usage and from disposal of the substance or products containing the substance. The European estimations of emissions and not measurements. industry has since 2008 taken actions to substantially reduce HBCD emissions from HBCD production and first line use. When looking at the contribution from the different products in a life cycle approach, different surveys in Europe Deleted: first line and Asia have revealed that the use of HBCD in insulation boards and textiles accounts for the largest releases of Comment [A5]: References: ECHA HBCD (Managaki et al 2009, Morf et al. 2008, ECHA 2008, Swerea 2010 (table 7), Klif 2010). The surveys also 2008 og SWEREA 2010. indicates that the insulation boards will represent long term sources of releases of HBCD in the future, as a standing Deleted: Emission stock in buildings becoming demolished or renovated in the future, when becoming waste, deposited in landfills or Comment [A6]: The installation of recycled back in to the product stream of uses. While the use in electric and electronic articles have potential to cause boards in buildings represent relatively one serious problems for environment and health when exported for recycling operations in developing countries (UNEP- of the larger releases of the diffuse POPS-POPRC(1).6-13-add.2). The European industry has since 2008 taken voluntary actions to reduce HBCD emissions (SWEREA 2010, KLIF 2010, emissions from HBCD production of HBCD and the use in PS foam industry. This represents however only a small part ECHA 2008) of the releases during the life cycle of products (ECHA 2008 og SWEREA 2010). Comment [A7]: This is not documented from the industry, and several studies on 5. Emissions of HBCD can be reduced in production of HBCD, in processes where HBCD or articles containing indoor levels of HBCD in homes, offices HBCD are used, and during the waste management phase. But emission control techniques at the production sites and and cars indicate that the use in textiles and waste management alone will not be efficient in solving the problem HBCD is posing for the environment and health, EE-articles can be a bigger use than since it only will reduce the levels of emissions from those sources, and there are no existing tools to control the diffuse claimed by BSEF. emissions and releases to indoor and outdoor air, the water reserves and sewage systems from the use of products Deleted: from other less-commonly used containing HBCD. The process of remodelling and demolition of buildings suggests that HBCD emissions are likely to applications continue in the future from the installed amount of insulation boards containing HBCD. Wastes containing HBCD Deleted: products represent a large source of releases and increasing amounts of HBCD-containing wastes in landfills and other locations Deleted: and could be a long-term source of HBCD emissions. Wastes containing HBCD include production wastes, insulation boards, building and renovation wastes, and from products becoming wastesuch as electrical and electronic products Deleted: textiles and articles, textiles., furniture’s and vehicles. , If HBCD continue to circulate in the product and waste streams, the Deleted: The process of remodelling and build up of large amounts of waste that will need to be treated as hazardous waste, will represents a considerable demolition of buildings suggests that challenge for the waste management systems and stake-holders in the future, both when considering the handling and HBCD emissions are likely to continue in the future from the installed amount of the cost. materials containing HBCD. HBCD phase-out could include flame retardant substitution, resin/material substitution and product redesign. Moved (insertion) [1] retardantsThere are already available chemical alternatives on the market replacereplacing HBCD in high-impact Deleted: A number of alternative fire polystyrene (HIPS) and textile back-coating. Comparing their properties with HBCD and considering the possible management actions to reduce exposure, the available unhalogenated chemical alternatives can be considered to be Deleted: retardants better for the environment and health (Klif 2010, SWEREA 2010). Deleted: to 6. However, there appear to be no drop-in chemical alternatives for flame-retarded EPS/XPS products in all Deleted: replace regions. In the USA an alternative chemical flame retardant is used in the production of EPS, but not in Europe.drop-in Comment [A8]: References: Klif 2010, SWEREA 2010. 3
Persistent Organic Pollutants Review Committee chemical flame retardant to HBCD is used in the production of EPS, but not in Europe. However, this year an alternative and technical feasible drop-in chemical to HBCD in EPS and XPS was licensed for global use, and will be fully commercially available on the global market next year. Some of the producers of PS foam have started to adjust and phase in the new chemical in their production processes. The alternative are carefully examined by the industry and found to have better properties for the environment and health than HBCD, and in the same time be able to provide the same level of fire safety. Comment [A9]: This information was submitted by Canada, and is available on 7. There are already several alternative materials commercially available on the market replacing flame retarded http://www.dow.com/licensing/news/2011/ EPS and XPS. They are phenolic foams, blankets and loose fills that may contain rock wool, fiber glass, cellulose or 20110329a.htm polyurethane foam. Another alternative used in some countries are EPS/XPS without flame retardants, together with And http://www.informe.basf.es/group/pressrele alternative construction techniques, and thermal barriers. There are alternative materials for all uses in buildings and ase/P-11-230 constructions fulfilling the fire safety needed, however, they are considered more environmentally friendly than the use of materials flame retarded with HBCD (Klif 2011). Many countries have set standards for building materials with Comment [A10]: Reference: regards to their contribution to fire. Consequently, inherently flammable materials, like EPS and XPS, must be treated Klif 2011 with a flame retardant to meet certain fire performance criteria, which are required in the country regulations for a Deleted: ¶ specific use. In some countries HBCD has effectively already been phased out. In those countries the fire safety regulations do not require the treatment with a flame retardant. The same level of fire safety is achieved by alternative means that are technically feasible and also commercially available. Here, polystyrene foams are used without flame retardants using thermal barriers to get the same level of fire safety, except for some specific uses with higher demands on fire safety, where alternative materials are used. Moved up [1]: HBCD phase-out could include flame retardant substitution, 8. HBCD is an intentionally produced industrial chemical. Under the Convention, the most adequate control resin/material substitution and product measure is listing in Annex A. To allow for certain time-limited critical uses of HBCD a specific exemption for use of redesign. HBCD, could be given together with detailed conditions for HBCD production and uses. Stockpiles and waste containing HBCD would be subject to the waste provisions in Article 6.
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Persistent Organic Pollutants Review Committee
1. Introduction 9. On June 18th 2008, Norway, as a Party to the Stockholm Convention, submitted a proposal to list the brominated flame retardant hexabromocyclododecane (HBCD; also HBCDD) as a possible Persistent Organic Pollutant (POP) under Annex A of the Convention (UNEP/POPS/POPRC.5/INF/16). 1.1 Chemical identity of the proposed substance 10. Commercial HBCD is a white solid substance. Producers and importers have provided information on this substance under two different names; hexabromocyclododecane (EC Number 247-148-4, CAS number 25637-99-4) and 1,2,5,6,9,10-hexabromocyclododecane (EC Number 221-695-9, CAS number 3194-55-6). The structural formula of HBCD is a cyclic ring structure with Br-atoms attached (Table 1). The molecular formula of the compound is C12H18Br6 and its molecular weight is 641 g/mol. Depending on the manufacturer and the production method used, technical HBCD consists of 70-95 % γ-HBCD and 3-30 % of α- and β-HBCD (European Commission 2008; Nordic Council of Ministers (NCM) 2008). Each of these stereoisomers has its own specific CAS number i.e. α-HBCD, CAS No: 134237-50-6; β-HBCD, CAS No: 134237-51-7; γ-HBCD, CAS No: 134237-52-8. Two other stereoisomers, δ- HBCD and ε–HBCD have also been found in technical HBCD in low concentrations. Further information pertaining to the chemical identity of HBCD is listed in Table 2 and may be found in the supplementary information to the Risk Profile on HBCD (UNEP/POPS/POPRC.6/INF/25). Table 1. Information pertaining to the chemical identity of HBCD Chemical structure
Structural formula of HBCD1:
1Structural formula for 1,2,5,6,9,10- HBCD, i.e., CAS no 3194-55-6. Note that CAS no 25637-99-4 is also used for this substance, although not correct from a chemical point of view as this number does not specify the positions of the bromine atoms. As additional information, the structures and CAS numbers for the diastereomers making up 1,2,5,6,9,10-HBCD are given below, although these diastereomers always occur as mixtures in the technical product.
Chiral components of commercial HBCD: Br Br Br Br
Br Br Br Br
Br Br Br Br Br Br Br Br
Br Br Br Br
Br Br Br Br alpha-HBCD gamma-HBCD beta-HBCD CAS No: 134237-50-6 CAS No: 134237-52-8 CAS No: 134237-51-7
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Persistent Organic Pollutants Review Committee
Table 2. Chemical identity Chemical identity
Chemical Name: Hexabromocyclododecane and 1,2,5,6,9,10 -hexabromocyclododecane
EC Number: 247-148-4; 221-695-9
CAS Number: 25637-99-4; 3194-55-6
IUPAC Name: Hexabromocyclododecane
Molecular Formula: C12H18Br6
Molecular Weight: 641.7
Trade names/ other Cyclododecane, hexabromo; HBCD; Bromkal 73-6CD; Nikkafainon CG 1; Pyroguard F 800; synonyms: Pyroguard SR 103; Pyroguard SR 103A; Pyrovatex 3887; Great Lakes CD-75P™; Great Lakes CD-75; Great Lakes CD75XF; Great Lakes CD75PC (compacted); Dead Sea Bromine
Group Ground FR 1206 I-LM; Dead Sea Bromine Group Standard FR 1206 I-LM; Dead Sea Bromine Group Compacted FR 1206 I-CM.
Stereoisomers and Depending on the producer, technical grade HBCD consists of approximately 70-95% γ- purity of commercial HBCD and 3-30 % of α- and β-HBCD due to its production method (European Commission, products: 2008). Each of these has specific CAS numbers. Two other stereoisomers, δ-HBCD and ε– HBCD have also been found by Heeb et al. (2005) in commercial HBCD in concentrations of
0.5 % and 0.3 %, respectively. These impurities are regarded as achiral at present. According to the same authors, 1,2,5,6,9,10-HBCD has six stereogenic centers and therefore, in theory, 16 stereoisomers could be formed.
11. HBCD has been on the world market since the 1960s. Production has been reported in China, Europe, Japan, and the USA. The current known annual production is approximately 23,000 tonnes per year (9,000 to 10,000 tonnes in China, 13,426 tonnes by the BSEF member companies in Europe and the US). Japanese production data is not available. No information on production in other countries or by non-BSEF member companies was received. 12. Based on responses from Parties and Observers, it appears that the main consumption and use of HBCD takes place in Europe. According to the global demand reported by the industry in 2001, more than half of the market volume (9,500 of 16,500 tonnes) was used in Europe. Total global demand for HBCD increased over 28% by 2002 to 21,447 tonnes, and rose again slightly in 2003 to 21,951 tonnes (BSEF 2006). In the US the sum of manufactured and imported HBCD is reported to lie between 4,540 to 22,900 tons in 2005 (US EPA 2008). The total volume of HBCD used in the EU was estimated to be about 11,580 tonnes in 2006. The demand of HBCD within the EU is bigger than the production there and the net import to the EU was expected to have been around 6,000 tonnes in 2006 (ECHA 2008a). The authorities in Japan have reported the sum of domestic production and import of HBCD to be 2,844 tonnes in 2008 and 2,613 tonnes in 2009. Several other national authorities report an import of HBCD as a pure compound or in products; Canada (100-1,000 tonnes), Australia (<100 tonnes), Poland (500 tonnes imported from China annually), Romania (185 tonnes), and Ukraine (BSEF 2011, UNEP/POPS/POPRC.6/13/Add.2). Available information suggests that use of HBCD may be rising (ECHA 2008a). There is also evidence that HBCD may be replacing some polybrominated diphenyl ether (PBDE) flame retardants (notably the commercial decabromodiphenyl ether formulation) (Environment Canada 2010a). Deleted: 2 13. HBCD is used as an additive flame retardant, with the intent of delaying ignition and slowing subsequent fire ) growth during the service life of vehicles, buildings or articles, as well as while materials are stored (BSEF 2010, see Deleted: )4 UNEP/POPS/POPRC.6/13/Add.2 for overview). The main uses of HBCD globally are in flame-retarded expanded Comment [A11]: This is not (EPS)1 and extruded (XPS)3 polystyrene foam insulation (more than 95% in Europe), while the use in textile documented from the industry, and several applications5 and electric and electronic appliances (high impact polystyrene/HIPS)7 is of a smaller scale ((BSEF 2011, studies on indoor levels of HBCD in homes, offices and cars indicate that the use in textiles and EE-articles can be a bigger use 1 0.5-0.7 % HBCD w/w than claimed by BSEF globally, seems like this only refers to the European market. 3 0.8-2% HBCD w/w 6 5 10-15% HBCD w/w Deleted: 7 1-7 % HBCD w/w Deleted: )8 6
Persistent Organic Pollutants Review Committee
UNEP/POPS/POPRC.6/13/Add.2 and references therein e.g. ECHA 2008a, US EPA report, OECD 2007, INE- SEMARNAT 2004, Lowell Center For Sustainable Production (LCSP 2006), BSEF 2010). The use of HBCD in insulation boards started in the 1980s. HBCD is used in textile back-coating in upholstery furniture and other interior textiles, including applications in vehicles for transport (Japan 2011, LCSP 2006). Some other minor uses have also Comment [A12]: Mostly used for cars, been reported by KEMI (2006). Må sjekkes i markedsrapporten! and does not include aero planes etc. 14. EPS and XPS are highly combustible. According to industry EPS should not be used uncovered, not only for fire Deleted: automotive performance but also for mechanical and long-term insulation properties. It is recommended by the industry that EPS is Deleted: used with a covering material, a thermal barrier, that are non-combustible, like brick, concrete or gypsum.(Klif 2011b) 15. Based on the responses from the Parties and Observers and ECHA (2009), the volumes of import and export of HBCD in flame retarded articles is generally unknown. Polystyrene foams and textiles are usually tailor made for the local market, and the main share of the production is for local consumption, and not exported (SWEREA 2010, BSEF 2011). 1.2. Conclusions of the Review Committee regarding Annex E information 16. At its sixth meeting in October 2010, the POPs Review Committee evaluated the draft risk profile for HBCD in accordance with Annex E (UNEP/POPS/POPRC.6/13) and adopted this (UNEP/POPS/POPRC.6/13/Add.2). The POPRC decided that, “in accordance with paragraph 7 (a) of Article 8 of the Convention, hexabromocyclododecane 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”. The Committee also decided to establish an ad hoc working group to prepare a risk management evaluation that includes an analysis of possible control measures for hexabromocyclododecane in accordance with Annex F to the Convention for consideration at its next meeting.
1.3. Data sources Comment [A13]: In this chapter only the different data sources should be listed. 17. This risk management evaluation was developed using Annex F information submitted by Parties and observers, including the industry using and producing HBCD. The summaries of the annex F submissions does not in our view sufficiently cover the 18. Sixteen Parties and country Observers submitted information (Brazil, Burundi, Canada, China, Costa Rica, range of data in the submissions from the Czech Republic, Ecuador, Finland, Germany, Japan, Nigeria, Norway, Mauritius, Romania, and Sweden). Five non- different countries. governmental Observers submitted information – Bromine Science and Environmental Forum (BSEF), It would be more appropriate to provide the PlasticsEurope/Exiba, Instituto do Meio Ambiente (IMA) Brazil, Extruded Polystyrene Foam Association (XPSA) and submissions from the countries as they are Canadian Plastics Industry Association (CPIA) as well as the International POPs Elimination Network (IPEN). All in an INF, without editing. submissions are available on the Convention web site. A summary of the submissions is not 19. Brazil reported it does not produce HBCD, and noted the lack of information on emissions and use. In general required for the evaluation. Relevant HBCD is used in electronic equipment, automotive and textiles production. Brazil also provided extensive information information from the country submissions, with a reference, should rather be used in on alternatives to HBCD and HBCD containing products. the evaluation where the different elements 20. Burundi reported it does not produce HBCD. Burundi highlighted the lacking of capacity for monitoring and is discussed. control of chemicals and waste, and noted the need for capacity-building in emergency services, environmentally sound destruction and recycling technologies. 21. Ecuador reported that HBCD is imported into the country only in articles, not as a substance. 22. Canada reported that HBCD is used in flame-retarded PS foams and textiles. In Canada HBCD is used in PS foams in lower concentrations (0.5-1%) than in Europe. Canada also noted the potential for brominated dioxin and furan emissions related to uncontrolled burning of HBCD containing articles. HBCD has been monitored across Canada in landfill leachate since 2009, with varying detection frequency. HBCD has also been monitored in surface water, sediment, air, aquatic biota and wildlife, since 2008. HBCD has been detected in human blood, breast milk, dust and ambient air. 23. China provided information on production of HBCD in the country and supported emission control, improved waste management and HBCD substitution as potential control measures. China also noted that the risks of alternatives to the environment and human health were not yet addressed. 24. Costa Rica and Mauritius reported no production. Costa Rica also noted the lack of information on HBCD use in the country impeding the identification of alternative products. 25. The Czech Republic reported on its ambient air monitoring activities. HBCD isomers were released in the air during storage, manipulation of the mixture and during the PS production process in 2010. The concentrations inside and outside the production facility were hundreds of ng/m3. HBCD was not found in human milk, but in 10% of the liposuction samples. Czech Republic also pointed out that there is no information on import and export of HBCD in the Comment [A14]: True for articles? But EU. is it true for the commercial chemical?
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Persistent Organic Pollutants Review Committee
26. Finland submitted information on emissions and emission control measure effectiveness at a recently closed EPS production facility. The results confirm the need to address production waste (HBCD packages) and emissions to air, sediment and waste water (from polystyrene beads). 11 % of the EPS produced in the country is flame retarded with HBCD. Fire safety regulations do not require use of flame retardant in insulation boards. 27. Germany noted that the use of EPS/XPS insulation boards without flame-retardant is not allowed according to the German fire safety regulations and that there is currently no drop-in chemical substitute for HBCD in this use. Germany expressed the need for a time limited exemption for HBCD use in EPS/XPS production. They also noted the presence of alternative insulation materials to EPS/XPS and that product redesign is technically feasible. 28. Japan reported use of HBCD in XPS, EPS, automotive textiles, and curtain/blind production. In new car-models HBCD fabrics are not used anymore, but the demand for fabric used in older models will continue for some time. XPS, as well as curtain and blinds producers are working towards reducing or eliminating HBCD use, but no available chemical alternatives have been identified. In Japan, EPS waste is collected and recycled fuelfor energy recovery, i.e. Deleted: as RPF (Refuse Paper and Plastic Fuel), and other products in effective recycling systems. Deleted: fuel 29. Nigeria reported no production, but use of HBCD in EPS, XPS, HIPS and polypropylene fibre. Nigeria provided information on alternatives to HBCD in certain uses and supported substitution of HBCD with sustainable flame retardants, use of product stewardship programs to minimize emissions, and introduction of regulations to promote search for the alternatives. Nigeria also stressed the importance of ensuring the safety of the alternative chemicals and building laboratory capacity for chemical measurements.
30. Norway has prepared a risk management exploration proposal to the UNECE CLRTAP POPs Task Force on Comment [A15]: Elements from the HBCD (Exploration of management options for Hexabromocyclododecane (HBCD). Fire regulations allow use of Norwegian Annex F info is missing such as EPS/XPS insulation boards without flame retardants in Norway if thermal barriers are used. The Norwegian producers e.g. the economical consequences of continued HBCD use for the fisheries and provide EPS without flame retardants to the Norwegian market. The imported HBCD, approximately 22 t per year, is aquaculture industry exported to the EU in EPS. There are no other registered uses of HBCD in Norway. Alternatives other than HBCD are used for textiles and furniture. There is no information on amounts of HBCD in imported products and articles. Norway stressed the importance of releases from waste, especially insulation materials. HBCD has been found in the environment both close to EPS production sites and in the remote regions in the Norwegian Arctic. 31. Romania reported use of HBCD in EPS and XPS production. The annual use from 2009 was 134 tonnes for EPS and 50 tonnes for XPS production. With regards to the waste management implications, Romania noted milling and recycling of polystyrene waste. 32. Sweden expressed the need to achieve fire safety without flame retardants by use of alternative materials and product designs, due to the inherent hazardous properties of many flame retardants, and highlighted that alternative solutions are also available. HBCD use in insulation materials is very small in Sweden as fire safety standards do not require EPX/XPS to be flame retarded. HBCD is being monitored by Swedish contaminant monitoring programmes in marine biota, human milk and ambient air. Due to negligible domestic use, the Swedish environmental levels are heavily dependent on HBCD control measures in other countries. 33. Bromine Science and Environmental Forum (BSEF) submitted information on production and uses of HBCD, noting that the only production facility of HBCD in Europe had reduced its total HBCD emissions to the environment Comment [A16]: Can be misinterpreted to less than 2 kg a year. BSEF was also concerned over the effects of potential HBCD restrictions on the market and to account for also producers of different producers, and expressed the industry commitment to continue research to find a chemical alternative to HBCD. articles using HBCD in their process. 34. Plastics Europe/Exiba, representing the HBCD users in the PS industry, reported that HBCD is used in 0.7% content in EPS and an average of 2% in XPS. Plastics Europe/Exiba also highlighted the successful emission reductions programmes (VECAP/SECURE) in 2006-2009, where potential emissions from first line users participating in the programme were reduced by 85 %. To ensure smooth transition once an alternative is available, the industry intends to Comment [A17]: The programme only apply for REACH authorization for the use of HBCD in polystyrene in Europe, before the EU chemicals policy ban includes members of EBFRIP, and not all takes effect in 2015 (see para 40). their members. See info-sheet on VECAP/SECURE programme submitted by 35. IPEN highlighted the need to ban HBCD to reduce the levels in the environment and noted the availability of the industry. alternative materials to replace EPS/XPS. Elimination of flame retardant use in applications where no fire hazard exists could be a starting point (underground applications, non-combustible surfaces, thermal barriers). IPEN also noted the wide availability of chemical and non-chemical alternative flame retardants for use in insulation noting that the chemical substitutes also may have hazardous properties. Special attention should be paid to waste containing HBCD and emissions from burning HBCD containing materials. 36. The North American XPS Industry (XPSA and CPIA) noted that the U.S. and Canadian building codes contain provisions to limit ignition and burning and that insulation is important to reduce CO2 emissions. The use of a flame- retardant such as HBCD was reported necessary for XPS to meet the U.S. requirements of ASTM C-578 and achieve the International Building Code and International Residential Code class A designation for flame spread and smoke 8
Persistent Organic Pollutants Review Committee development per ASTM E-84. Use of a flame-retardant such as HBCD also enables XPS to meet the requirements of CAN/ULC S701 and CAN/ULC S102.2, of the 2005 National Building Code of Canada for foamed plastics in non- combustible construction. The HBCD concentration in XPS produced in the US and Canada is lower than in Europe, on average 0.8% by weight. XPSA and CPIA noted that in production of flame retarded XPS, HBCD releases are possible during transfer from the original packaging to the feeder at the start of the process, in disposal of packaging materials, and during process upsets. 1.4. Status of the chemical under international conventions 37. HBCD is included as part of the brominated flame retardants group in the List of Substances for Priority Action of The Convention for the Protection of the Marine Environment of the North-East Atlantic (the OSPAR Convention). The OSPAR Convention is made up of representatives of the Governments of 15 Contracting Parties and the European Commission. Also the Helsinki Commission (HELCOM) has included HBCD in the list of priority hazardous substances. 38. In December 2009, HBCD was considered by the Executive Body of the UNECE Convention on Long-Range Trans-boundary Air Pollution (LRTAP) based on a technical review (ECE/EB.AIR/WG.5/2009/7) to meet the criteria for POPs as defined under the POPs protocol. In 2010 the possible management options for HBCD were assessed to give a basis for later negotiations. The negotiations are expected to be initiated in December 2011.
1.5. Any national or regional control actions taken Comment [A18]: Only the control actions to regulate the use and production 39. Many countries have set standards for building materials with regards to their contribution to fire. Consequently, of HBCD should be listed here. The other inherently flammable materials must be treated with a flame retardant to meet certain fire performance criteria, which is should be mentiones in chapter 2. required in the country regulations for a specific use. Fire protection requirements for certain articles are laid down in acts, ordinances and regulations as well as in standards. In the legislation, the requirements are normally specified in general terms. To demonstrate that the requirements are met, there are prescribed verifiable criteria, which standardisation bodies such as ISO, CEN and UL often have helped to develop (KEMI 2006). 40. In Europe fire test methods have been harmonised and classification of reaction to fire performance for construction products, excluding floorings, are based on four fire test methods: the non-combustibility test EN ISO Comment [A19]: This Directive is 1182, the gross calorific potential test EN ISO 1716, the single burning item (SBI) test EN 13823, and the ignitability relevant since it regulates the product test EN ISO 11925-2. Building products are divided into seven classes on the basis of their reaction-to-fire properties. standards for construction products, and (SWEREA 2010). In the U.S. there are numerous regulations and standards that apply to insulation used for the defines the essential requirements that has building industry. These regulations and standards may exist at the national, state, county, or municipal level (LSCP to be considered, as fire safety but also health and environment. This is new and are 2006). relevant for the development of the national regulations in EU. HBCD is on the 41. The EU Construction Products Directive (Council Directive 89/106/EEC) specifies hygiene, health and indicative list of substances that should be environment as one of 6 essential requirements to be specified in harmonized product standards, together with the other avoided. requirements; strength and stability, safety in the event of fire, safety in use, protection against noise and energy Comment [A20]: There are information economy and heat retention, as set out in Annex 1 to the Directive. This essential requirement recognizes national in the literature with studies done by legislation relating to dangerous substances, which could be emitted or released from construction products into indoor experts on fire safety regulations and use of air, soil, surface or ground water or which may have an environmental impact. National restrictions shall be listed in the flame retardants. References you could use product standards, and standards for thermal insulation products shall contain such a list. HBCD appears on the is Troitszch 2008 and Klif 2011 (see additional submission from Norway). See indicative list of dangerous substances issued by the EU Commission that should be considered avoided. The directive also Klif 2010 and SWEREA 2010. applies to product properties when installed in a building, i.e. not the manufacturing or demolition or disposal phases (http://ec.europa.eu/enterprise/sectors/construction/documents/legislation/cpd/index_en.htm. Comment [A21]: This have to be 42. There are requirements in some countries regarding the use of flame retardants in PS foam for insulation. Fire explained more. Does the insulation material have to be flame retarded to fulfil safety regulations require that flame retardant must be used in Canada, Austria, Czech Republic, Germany, Hungary, the national fire safety requirements, Netherlands, Slovakia, Slovenia, and Switzerland in all building applications, irrespective of the use. Moreover, flame irrespective of type of insulation material retardants are used to reduce fire risk for warehouses containing EPS before use in buildings/packaging. in UK. Fire and flammability? Or does this only apply regulations and international standards govern the fire safety of polymer applications, but they do not require the use of to EPS and XPs that is highly flammable? a certain flame retardant. In Denmark and Iceland flame retarded EPS is required for use in buildings. In Italy, Portugal Comment [A22]: In Europe this is only and UK flame retarded PS foams are generally used according to the industry. Flame-retarded PS foam may be used in the situation in UK (Klif 2011, 2010 and SWEREA 2010). Are there a reference to some building applications in Finland, Norway, and Sweden, although it is not required. In Sweden and Norway, the this information? industry has voluntarily withdrawn HBCD containing products from the market, which is possible because alternative construction techniques can be used, even with EPS applications. Comment [A23]: This have to be explained more in detail. In Norway 43. The European fire classification system for construction products and material does not set requirements on polystyrene foam have to be flame retarded if used in certain sandwich panels and roof individual material in a building product, but on the fire performance of the complete product in its intended mode of linings to fulfil the fire safety requirements. use. It is however common to have specific national regulations for the fire performance of insulation materials. The Usually other less flammable materials are European countries with such regulations are: Finland, Germany, Poland, France, Italy and UK. In Europe the highest used for those applications. Flame retarded volume demands for brominated flame retardants is in Germany, followed by Italy, UK and France (BizAcumen 2009). imported XPS is used for some applications, though often not required. 9
Persistent Organic Pollutants Review Committee
Germany has the most stringent fire requirements in Europe and has the highest consumption of flame retardants in general and brominated flame retardants in specific. For most applications in these countries EPS/XPS has to be flame retarded if used (Klif 2011). In UK there are no formal regulations that would exclude the use of non-flame retarded EPS/XPS, however, according to the UK plastic industry, almost the entire market share for EPS/XPS in UK is flame retarded products due to requirement from the insurance sector. The use of brominated flame retardants in the rest of Europe is much less, presumably other alternative materials to flame retarded EPS/XPS are used there. Countries like Sweden and Norway with a performance approach to the final product in their regulations use much less brominated flame retardants than countries with more specific fire requirements on a material level (Klif 2011). In Sweden and Norway, the industry has voluntarily withdrawn HBCD containing products from the market, which is possible because alternative construction techniques can be used, even with EPS applications. Other non-combustible alternative materials, as stone and glass wool, are used for some applications, where high fire safety requirements have to be met. 44. In North America (USA; 75840 tons BFRs and Canada; 11670 tons of BFRs), it seems that there are material requirements which mean that flame retarded EPS/XPS would be most common in building applications. In North America other brominated alternatives to the use of HBCDD in EPS are on the market, and the consumption of HBCDD is lower than in EU (Klif 2011). 45. The low volume demand of brominated flame retardants and use of flame retardants in building and constructions for the rest of the world implies that other alternatives may be used here. In Australia there are very low formal requirements concerning fire performance of materials which would not necessarily require the use of flame retarded EPS/XPS. It seems however that if EPS/XPS is used instead of other materials it is flame retarded voluntarily (Klif 2011). 46. The use in the Asian region of brominated flame retardants is dominated by use in electronics and electrical industry (BizAcumen 2009; 298-323 tons). Most of this is used in China (BizAcumen 2009). The use of flame retardants in the building and construction segment in Asia is on the same level as in Europe and North America, but this sector is heavily growing in China (BizAcumen 2009). In Japan, it would appear that EPS/XPS would need to be classified as flame retardant material as it would not be able to attain any of the other classes without the use of flame retardants which would automatically mean that it would be included in this class. This implies also that the majority of EPS/XPS for use in Japan would be expected to be flame retarded. Korea appears to have a similar situation as that in Japan. There have been limited information on the fire safety requirements in China, but flame retarded EPS is reported from the Chinese government to be important in new constructions and buildings. Considering the population in the Asian region compared to the European and North American populations, the use of other alternatives than flame retarded EPS is likely. 47. The EU’s Directive on Waste Electrical and Electronic Equipment (WEEE) (2002/96/EC) requires the removal of plastics containing brominated flame retardants and of printed circuit boards from electrical and electronic equipment prior to recovery and recycling. 48. HBCD has been identified by the EU as a Substance of Very High Concern (SVHC), meeting the criteria of a PBT (persistent, bioaccumulative and toxic) substance pursuant to Article 57(d) in the REACH regulation (ECHA 2008b). In February 2011 HBCD was included in the European Chemicals Agency (ECHA) list of substances subject to authorisation under REACH. Taking effect in 2015, HBCD can no longer be used without authorisation. A proposal on classification and labelling of HBCD as a possible reproductive toxic substance was made within the EU (Proposal for Harmonised Classification and Labelling, Based on the CLP Regulation (EC) No 1272/2008, Annex VI, Part 2 Substance Name: Hexabromocyclododecane Version 2, Sep. 2009) (KEMI 2009). The EU risk assessment committee (RAC) is of the opinion that HBCD should be classified as suspected to damage fertility or the unborn child (Repr.2 HR361), and may cause harm to breast-fed children (Lact. H362) (RAC 2010). 49. In Ukraine HBCD is registered on the hazardous chemical list based on health effects. 50. In Japan HBCD has been designated as a Monitoring Chemical Substance because of its persistence and high bio-accumulation under the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (commonly referred to as the Chemical Substances Control Law "CSCL"). In September 2010, Japanese Ministers of Health, Labour and Welfare, and of Economy, Trade and Industry and of the Environment instructed persons operating the business of manufacturing or importing HBCD to conduct an Avian Reproduction Test (OECD Test Guideline 206) and to report the results thereof by the end of March 2014 under CSCL. 51. In the USA, the EPA anticipates proposing a significant new use rule (SNUR) under section 5(a)(2) of the Toxic Substances Control Act (TSCA) for the use of HBCD in consumer textiles. Such a proposal would indicate that EPA believes such use would constitute a significant new use. The SNUR would require persons who intend to manufacture, import, or process HBCD for the designated significant new use to notify EPA at least 90 days before
10
Persistent Organic Pollutants Review Committee commencing such use. The required notification would provide the EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs. 52. A proposal for a national ban of HBCD is currently under consideration by the Norwegian Ministry of the Environment (Norway 2011). Canada is currently undertaking a risk assessment of HBCD and will be considering control measures when that assessment has been completed, which is expected in 2011.
2. Summary information relevant to the risk management evaluation Comment [A24]: Here the information to a large extent is focusing on Europe, and 53. HBCD may be released to air, water, soil and sediment. Release of HBCD into the environment may occur information and key findings in the during production and manufacturing, processing, transportation, use, handling, storage or containment, point-source UNEP/POPS/POPRC.6/13/Add.2 is discharges, migratory releases from manufactured product usage and from disposal of the substance or products lacking. containing the substance. In Canada, HBCD has been known to be discharged into various tributaries, watersheds, rivers and lakes resulting in increased levels in sediments, surrounding soils and biota (Environment Canada 2010b). 54. Releases of HBCD to the environment from HBCD production have been considered small in the EU, with only one production facility. In the EU it was estimated that about 3 kg a year are released from the workplace plus a further 2 kg to air and 0.1 kg to waste water. The estimated releases of HBCD to the environment during the manufacture and formulation of HBCD containing products were 41 kg to air, 60 kg to waste water and 35 kg to surface water per year in the EU RAR (ECHA 2008a). The releasereleases of HBCD from products during end use small.are higher. dustDust Deleted: is containing HBCD will be released during the installation of EPS or XPS insulation and ultimately during the Deleted: small refurbishment or demolition of buildings containing these products. The estimated annual release to the environment was 530 kg to air, 1,140 kg to waste water and 560 kg to surface water. According to the EU RAR, the end use releases Deleted: Some to waste water and surface water are dominated by textile coatings. The use of HBCD in textiles is believed to have Deleted: d fallen substantially in recent years. According to the estimated releases in the technical report in EU (ECHA 2008b), Comment [A25]: The releases from the total releases of HBCD from manufacture and use of insulation boards (1627,9 kg/year) and manufacture and use of refurbishement and demolition are not textiles (1498,4 kg/year) are in the same magnitude (Klif 2010, SWEREA 2010). Although the releases from insulation included in the releases of HBCD during boards under their service life was assumed to be low (70 kg/year), the total releases from insulation boards (1627,9 the service life of end products calculated in kg/year) represented more than half of the total releases of HBCD (2555,3 kg/year) in EU in 2006 (Klif 2010 and ECHA 2008. SWEREA 2010). The use of HBCD in textiles is believed to have fallen substantially in recent years in EU because of a Comment [A26]: Is this the total reduction in use of HBCD for textile coating in the European industry. The quantities of waste products sent for releases? In the EU technical report following the RAR they were estimated to disposal are uncertain and it was also noted that estimated releases of HBCD during the consumer use of products are be 665 kg to air, 1,553 kg to waste water highly uncertain (ECHA 2008a). and 925 kg to surface water. The total releases in EU were 3142 kg, where 584 kg 55. Releases from waste disposal are difficult to estimate because of the long lifetime of XPS and EPS once was diffuse releases and 2559 kg was installed in buildings (potentially up to 100 years)) combined with an increasing trend towards the recycling of releases from point sources. However, the electrical equipment. Solid waste containing HBCD may be scrap materials generated during processing operations, releases from waste, and from refurbishement and demolition of buildings, particulates released through aging and wear of end products, and disposal of products at the end of service life. and were not included. Products and materials in landfill sites will be subject to weathering, releasing HBCD particulates primarily to soil, and to a lesser extent, to water and air (Environment Canada 2010b). Comment [A27]: This should be replaced by the language that are more 56. At the end of their service life, products containing HBCD are likely to be disposed of in landfills, incinerated, general and cover more regions in the recycled, or remain as waste in the environment (UNEP/POPS/POPRC.6/13/Add.2)Insulation boards form the majority UNEP/POPS/POPRC.6/13/Add.2 of HBCD containing waste. It is understood that most of this material goes to landfill or incineration. The use of HBCD Comment [A28]: Reference? Life time in insulation boards and the HBCD built into buildings and constructions is increasing. There will be some releases of stated elsewhere are 30-50 years (Plastics Europe 2009) HBCD in dust when buildings insulated with flame retarded insulation boards are demolished. Releases from insulation boards becoming waste were estimated at 8,512 kg HBCD per year in 2006 (ECHA 2008a). It is likely that those Deleted: . releases will be more significant in the future; particularly from about 2025 onwards, as increasing number of buildings containing HBCD will be refurbished or demolished. This turn-over will be different in different regions of the world, and range from 10-50 years. Comment [A29]: Reference: UNEP/POPS/POPRC.6/13/Add.2 57. The life span of polystyrene foam in buildings is reported to be 30-50 years (Plastics Europe 2009, SWEREA 2010). In EU the releases are expected not to be of significance in the presence but to grow in the future, particularly from about 2025 (ECHA 2008b). However, there are over 200 million homes in Europe insulated with polystyrene foam today (Plastic Europe 2009a), the use in buildings started in the beginning of the 1980´s (ECHA 2008b) and will need restauration or will be demolished in the near future. Comment [A30]: From Klif 2010 58. Results from a substance flow analysis performed in Japan (Managaki et al. 2009), indicate that emissions from construction materials will continue for several decades and be potentially long-term sources of HBCD leaching or volatizing to the environment, as well as representing larger releases when demolished or renovated in the future. Additionally, the increasing HBCD stock seen in the study indicates possible problems arising in the recycling of construction materials in the future, when buildings of the present period are renovated or destroyed. This is also 11
Persistent Organic Pollutants Review Committee supported by the results from the substance flow analysis in Switzerland (Morf et al. 2008). The Swiss study also high- lights the stock in waste management and landfills as long-term sources of HBCD releases. The significance of those sources depends however on the waste management strategies chosen in the country, if the waste are incinerated, or disposed off to an uncontrolled or controlled landfill. 59. There are experiments revealing emissions of HBCD from various products like (European Commission 2008, Miyake et al. 2009, Polymer Research Centre 2006 and Kajiwara et al. 2009). There are also several studies showing the occurrence of HBCD in indoor air and house dust (Abdallah et al. 2008a and b, Abdallah 2009, Goosey et al. 2008, Stapleton et al. 2008, Stuart et al. 2008, Takigami et al 2009 a and b) , cabin dust in new and old cars (Harrad and Comment [A31]: From Abdallah 2011). Japan reported use of HBCD in automotive textiles. In new car-models HBCD fabrics are not used UNEP/POPS/POPRC.6/13/Add.2 anymore, but the demand for fabric used in older models will continue for some time. 60. HBCD phase-out could include flame retardant substitution, resin/material substitution and product redesign (LCSP 2006). In addition, re-evaluating fire-safety requirements e.g. in applications where fire hazard is absent (such as underground applications) or otherwise eliminated would reduce the need for flame-retarded insulation materials. Emissions of HBCD can be reduced in processes where HBCD or articles containing HBCD are used, and during the waste management phase. In Sweden and Norway, the industry has voluntarily withdrawn HBCD containing products from the market, which is possible because alternative construction techniques can be used. 2.1. Identification of possible control measures 61. The objective of the Stockholm Convention (Article 1) is to protect human health and the environment from persistent organic pollutants. Under the Convention this may be achieved by listing HBCD in Annex A, with or without specific exemptions, possibly accompanied with detailed actions for production and certain uses of HBCD. Comment [A32]: The reason for this is lacking, and why this will be possible from 62. In the Annex F process, a number of HBCD uses have been identified by Parties and Observers. For many of the the available information. uses alternativesalternative chemical substitutes are already available and currently used in many countries. These uses Deleted: s include production of high impact polystyrene (HIPS) plastic and production of flame retarded textile back-coating. Alternative flame retardants to HBCD in production of flame retarded expanded polystyrene are regionsalready on the Comment [A33]: The new alternative market, but they are not suitable for the production processes. in some regions. An alternative drop-in chemical launched by Chemtura is stated to be substitute for the use of HBCD in PSfoam has been licensed and will be fully commercially available in 2012. The PS technical feasible for the production of polystyrene foam worldwide. foam industry and the bromine industry in Europe is working together and have established a research project in 2008 that are in progress to identify an alternative to HBCD. They are confident that within 5 to 10 years at least one The alternatives used in North America appropriate alternative flame retardant for EPS and XPS foams will be available (PS foam 2011). Also, their health, have been on the market for a longer time. safety, and environmental properties may not be well known. However, alternative insulation materials to the use of According to the industry they are not suitable for the production processes in flame retarded EPS/XPS are already widely used as well as alternative construction methods. These uses and the Europe. We do not know the situation in potential substitutes will be further described in section 2.3. below. Asia or Australia. They use less brominated flame retardants, and less HBCDD, than 63. Emission reduction measures and use of best available technics and best environmental practices would be Europe. Perhaps they use other alternatives, required in the production and manufacture for potential specific exemptions and exempted uses in order to reduce both other drop in chemicals and other HBCD releases to the environment from these exempted uses. Significant reduction in estimated total emissions from alternative materials. production and first line users has been reported by the industry in Europe following voluntary measures. Deleted: being developed and 64. In accordance with Article 6(1)(d)(ii), HBCD containing products (EPS, XPS, HIPS, textiles) should be Deleted: used in some managed in an environmentally sound manner and disposed of in such a way that their POPs content is destroyed. This Deleted: regions will require separation of HBCD containing articles from others upon becoming waste, and the prevention of inappropriate waste management practices leading to recycling of the POP content. Deleted: all Comment [A34]: This is not entirely true. See SWEREA 2010 and Morose 2008. And Chemtura have tested their alternative. 2.2. Efficacy and efficiency of possible control measures in meeting risk reduction goals Deleted: and technical solutions 65. Listing HBCD in Annex A of the Convention without exemptions would effectively reduce the releases of Comment [A35]: This section should be HBCD. This would require either introducing alternative building techniques or insulation material to achieve fire moved after the discussion of alternatives. safety in construction, or the industry phasing in an alternative to HBCD. 66. Based on the submissions from Parties and Observers, there is currently a need for flame retarded insulation materials due to country-specific fire safety requirements in some countries. However, the safety requirements do not identify any specific flame retardant substances or groups of flame retardant substances that have to be used. Some countries have already phased out HBCD in the absence of a substitute chemical flame retardant indicating that there are alternative materials and techniques available on the market already. However, no replacement to HBCD is yet Deleted: viable available for flame retarded EPS and XPS production.full-scale production of flame retarded EPS and XPS in Europe. Deleted: commercially However, this year an alternative and technical feasible drop-in chemical to HBCD in EPS and XPS was licensed for global use, and will be fully commercially available on the global market next year. Some of the producers of PS foam Deleted: production have started to adjust and phase in the new chemical in their production processes. The alternative are carefully 12
Persistent Organic Pollutants Review Committee examined by the industry and found to have better properties for the environment and health than HBCD, and in the same time be able to provide the same level of fire safety. Comment [A36]: This information was submitted by Canada, and is available on 67. Emission control techniques at the production sites alone will not be sufficient to solve the problem HBCD is http://www.dow.com/licensing/news/2011/ posing to the environment and to health, since the diffuse emissions and releases to the water reserves and sewage 20110329a.htm systems from the use and machining of products containing HBCD, as well as releases when becoming waste also is of And http://www.informe.basf.es/group/pressrele significant concern. In addition to listing HBCD in Annex A, waste management measures for materials in use should ase/P-11-230 be introduced to ensure environmentally sound management of HBCD containing insulation materials, plastics, and textiles at the end-of-life stage. This would require identifying materials in which HBCD has been added when Deleted: ¶ buildings are renovated or dismantled to facilitate destruction of the POP content in the waste and to prevent inappropriate management practices leading to recycling or landfilling the POP content. Recycling of HBCD can be significant. According to the Swiss substance-flow analysis, the proportion of HBCD recycled is higher than for material containing other brominated flame retardants, and the recycling percentage of HBCD used in EPS insulation was expected to rise from 30% in 2005 to 60% in 2010 (Geopartner 2007). In the EU in 2007, the share of EPS with flame retardant was 60% of the total EPS demand, and the share of XPS with flame retardant 92% of the total XPS demand (PlasticsEurope/Exiba 2011). In two Swiss studies on electronic and electrical appliances, vehicles and building materials, HBCD was found in 2% and 6% of the studied plastic component samples (BUWAL 2004, BFR 2010 - 486 and 214 samples respectively). Another recent Swiss WEEE study, however, did not find HBCD in any of the 53 samples analysed (EMPA 2010). Measurements in dust from car cabinets and trunks have revealed levels of HBCD (Stavelova et al. 2010, Stuart and Abdallah 2011). A Norwegian study has estimated a content of 30-50 tons of brominated flame retardants in vehicles on the Norwegian market, with 10-17 tons of them being HBCD. 68. Recycled products containing HBCD, including EPS and XPS boards, are potential sources of emissions in the same way as virgin products. Recycling operations for recovery of metals or plastics in electronic products and vehicles are potential sources as well. In controlled waste streams parts containing HBCD could be sorted out, but this will not always be technically feasible. Use of labelling of products or parts of products could be a valuable help in the process Deleted: in the waste stream (KEMI 2006).
69. EPS has an estimated service life of approximately 30-100 years and collecting and recycling used EPS may be Comment [A37]: ? do you have the hindered due to difficulties in separating EPS containing HBCD from others. Some EPS can be recycled and used for reference. the manufacture of bricks where the polystyrene is gasified and leaves a cavity in the center of the brick. In this process HBCD is destroyed. However, it is difficult to separate the HBCD treated PS and HIPS from their HBCD-free counterparts. This greatly complicates the separation of recyclable materials. 70. The exposure and releases of HBCD from recycled products raises concern. Fragmented EPS may be remelted and reused for drainage and soil treatment. Granulated EPS waste is also used to improve the texture of agricultural and horticultural soil (UNEP/POPS/POPRC.6/10, Vogdt 2009). In developing countries, electrical and electronic appliances Comment [A38]: Univ. –Prof. Dr. Ing. containing HBCD and other toxic substances are often recycled under conditions which results in a relatively higher Frank Ulrich Vogdt. 2009. Planung, release of HBCD to the environment and contamination of the sites (Zhang et al. 2009), and exposure of workers (Tue Konstruktion, Ausführung, Kapitel 15: Umwelt und Gesundheit. Kalksandstein – et al. 2010). Open burning and dump sites are common destinations for HBCD-containing articles and electronic wastes Umwelt und Gesundheit. Januar 2009. (Malarvannan et al. 2009, Polder et al 2008c). According to industry the most appropriate treatment recommended for end-of-life HCDD-containing EPS is state-of-the-art incineration with energy recovery (EUMEPS, 2010). Comment [A39]: EUMEPS (2010): Draft Track B lacks thorough review of 71. Controlled incineration is one way to dispose of PS foam containing HBCD (CEFIC 2011, ECHA 2008a). The available information. Comments to flame retardant decomposes in the incineration plant process. In a co-combustion study in a high temperature pilot UNECE Tack B report for HBCDD, 9 April facility (>900°C), the foam added substantially to the Br content in the incinerator, but did not appear to add 2010. EUMEPS-European Association of EPS, Brussels. Accessed May 2011 at: significantly to the overall hazard of raw gas or emissions (APME). Experimental evidence confirms that under some http://www.unece.org/env/lrtap/TaskForce/ conditions HBCD and products containing HBCD form and may release polybrominated dibenzo-p-dioxins (PBDD) popsxg/2010/Comments%20on%20the%20 and dibenzofurans (PBDF) during burning, even in state of the art municipal solid waste incineration facilities (APME, HBCD%20track%20B%20report%20from NCM 2004). However, PBDDs and PBDFs formed from HBCD waste will likely be destroyed by the very high %20the%20PS%20Foam%20Industry.pdf operating temperatures and controlled operating conditions employed in state of the art incinerators. The incineration efficiency and the operating conditions of the flue gas treatment systems are of great importance to the resulting emissions of dioxins (NCM 2004). Hence, there is potential for the release of these substances from uncontrolled burns and accidental fires, pyrolysis/gasification plants, recycling processes, and from incinerators that are not functioning well (Weber and Kuch 2003). Desmet et al. (2005) also documented the formation of bromophenols, known precursors of polybrominated dibenzodioxins and dibenzofurans, during combustion of flame-retarded extruded polystyrene containing HBCD. Bromophenol formation seemed to be inherent to the flame retardant mechanism of HBCD. The study did not investigate the formation of brominated dioxins and furans but noted that it was highly probable that various brominated dioxin isomers would be formed from bromophenols. 72. State of art incineration with energy recovery is expected to be more widely available in the coming years, hence diverting HBCD containing materials from landfill. However, currently in many countries landfilling is the most common way of waste disposal, leading to HBCD containing waste accumulating in the landfills. 13
Persistent Organic Pollutants Review Committee
73. 2.3. Information on alternatives The POPRC has agreed that HBCD is a POP due to its long-range Deleted: (products and processes) environmental transport and significant adverse human health and environmental effects such that global action is where relevant ¶ warranted (UNEP/POPS/POPRC.6/13/Add.2). Hence to reduce the risks to human health and the environment the use Deleted: of HBCD for different applications must be minimized. The target or aim of any risk reduction strategy for HBCD should be to reduce and eliminate emissions and releases taking into consideration the indicative list in Annex F including technical feasibility of possible control measures and alternatives, the risk and benefits of the substances and their continued production and use. In this regard, the replacement of HBCD by another chemical or non-chemical Comment [A40]: This is highlighted in alternative needs to take account of factors such as: the last bulletpoint, no need to repeat it twice. technical feasibility (practicability of applying an alternative technology that currently exists or is expected to Deleted: In considering any strategy for a be developed in the foreseeable future) reduction in such risks, it is important to consider the availability of substitutes in the costs, including environmental and health costs sectors of concern Deleted: .. risk (safety of the alternatives) availability and accessibility of substitutes in the sections of concern
74. Moved down [3]: A discussion of the availability and suitability of substitutes of 75. Available literature and documentation suggests that technically feasible and commercially available alternatives HBCD is provided below. ¶ to the different uses of HBCD are already on the market for all applications, except for EPS production in Europe. In North America the major BFR manufacturers (Albemarle, Chemtura Corporation and ICL-IP) have formed alliances with other companies and started their own development activities for non halogenated flame retardants (SWEREA 2010). Thus a phase-out of the use HBCD in EPS production is in sight but may still take some years. Dow Global Technologies LLC, a subsidiary of The Dow Chemical Company, recently announced the invention and development of a new, high molecular weight brominated Polymeric Flame Retardant (Polymeric FR) (Dow, 2011). The Polymeric Comment [A41]: http://www.dow.com/ FR is expected by Dow to be the ‘next generation industry standard’ flame retardant for use in both extruded news/corporate/2011/20110329b.htm polystyrene (XPS) and expanded polystyrene (EPS) foam insulation applications globally. The development of the new Polymeric FR is the result of Dow’s continuing search for more sustainable products and in this case for a flame retardant that can replace HBCD and will be produced and sold by Great Lakes Solutions, a Chemtura business. To enable formulation optimizations and market qualifications, it is expected that Polymeric FR licensees will have interim quantities available throughout 2011. This will be followed, likely in 2012, by large plant construction by the licensees, making significantly larger commercial volumes available by 2013-2015 that are in line with the current HBCD market demand. This should allow the global polystyrene foam insulation industry to make a smooth transition, as national regulations are implemented. 76. Alternatives to and substitution of HBCD may be achieved in different ways; by flame retardant substitution i.e. substituting HBCD for another flame retardant, resin/material substitution i.e. substituting the resin/ material where HBCD is used with alternative HBCD-free materials, alternative building techniques, by changes in production methods and by product redesign which involves changes to the actual product design to minimize or eliminate the need for flame retardant chemicals. Examples of product redesign include using fire barrier material, as well as separating or reducing the source of heat from the product.
77. The first step when looking for alternatives to HBCD should be to eliminate the use of HBCD and other flame Moved (insertion) [4] retardants in cases where no or limited fire hazard exists A particular effort should furthermore be focused at Deleted: consideration identifying non-chemical alternatives. Concerning which chemical alternatives to consider for HBCD a distinction should be made between halogen containing chemicals and the presumably less harmful halogen-free chemicals Deleted: would (ECHA 2009, SWEREA 2010, Klif 2010). When reviewing chemical alternatives a distinction should also be made Deleted: . between additive flame-retardants and those chemicals that are covalently bound and that may not directly leak into the environment. Moreover, the inherent flammability of the resins/ materials should be taken into account and where Deleted: There are technically feasible possible non combustible insulation materials should be considered as should alternative building techniques. and commercially available alternatives to different uses of HBCD on the market, 78. A discussion of different strategies and the availability and suitability of substitutes of HBCD is provided below although not for EPS production in Europe. along with an overview over technically feasible and commercially available halogen-free alternatives to the use of They include flame retardant substitution, resin/material substitution and product HBCD (Table 3). Additional information is also available in Swerea 2010, Klif, 2011a and Klif 2011c. redesign. Several of them are halogen-free and are therefore considered to be better alternatives for the environment and health in the evaluations done (ECHA 2009, SWEREA 2010, KLIF 2010) (Table 3). However, their other risks may not have been fully studied. Moved (insertion) [3] Deleted: . 14
Persistent Organic Pollutants Review Committee
Table 3. Summary table of technically feasible and commercially available halogen-free alternatives to the use of Comment [A42]: We propose to change HBCD (based on SWEREA 2010). the table and include all the alternatives, with an extra entry on health and Material Application Alternative chemicals Alternative material and product environmental properties. redesign Deleted: Polymer materials 9 HIPS Housings of Arylphosphates such as: Alloys of PPE/HIPS treated with Deleted: s electronic products halogen free flame retardant Resorcinol bis (biphenyl alternatives Wiring parts phosphate)
Bis phenol A bis (biphenyl phosphate) Polymeric biphenyl phosphate Diphenyl cresyl phosphate Triphenyl phosphate
EPS& Insulation of No halogen free ‘drop in’ EPS and XPS without FRs, using Deleted: ¶ foundation, walls replacement chemicals thermal barriers XPS and ceilings commercially available at Phenolic foams present for all production Ground deck, processes and regions Blankets (fiber batts or rolls) that parking deck etc. may contain rock wool, fiber glass, cellulose or polyurethane foam Polyester batts Loose fills that may contain rock wool, fiber glass, cellulose or polyurethane foam Textile Protective clothing Intumescent systems10 that back contain: coatings a dehydrating component, Carpets such as Curtains ammoniumpolyphosphate (APP)
a charring component, such as Upholstered fabrics pentaerythritol (PER) a gas source, often a nitrogen Tents component such as melamine
Interior in public transportation
Other technical textiles
2.3.1 High impact polystyrene (HIPS) plastic Deleted: Production of high 79. HBCD is not widely used in HIPS, and it may thus be reasonable to assume that the alternative flame retardants on the market are technically and economically feasible. In line with this assumption, a number of alternative chemicals Deleted: A are available to replace HBCD as a flame retardant in HIPS (Table 3). The alternatives include both halogenated flame Moved (insertion) [2] Deleted: fire retardants 9 PPE/HIPS: alloy of polyphenylene ether and high impact polystyrene Deleted: Other chemicals that can be used as alternatives to HBCD in HIPS 10 Economical viability has been questioned (BSEF 2011). 15
Persistent Organic Pollutants Review Committee
retardants used in conjunction with antimony trioxide (ATO) and halogen-free organic aryl phosphorus compounds. Deleted: They However, the non-halogen containing chemicals are all required to be used at considerably higher concentrations (ECHA 2009). The halogen containing alternatives on the other hand have the drawback that they may be toxic and Deleted: loadings may pose a risk to human health and the environment (Birnbaum and Bergman, 2010; DiGangi et al. 2010). Available Comment [A43]: The correct way of literature also suggests that halogen-containing flame-retardants may increase fire toxicity through formation of carbon citing this reference would be Blum et al. monoxide, irritant gases, soot, combustion products such as halogenated dibenzodioxins and dibenzofurans and 2010 increased smoke yield and (Dioxin 2010). The polybrominated diphenyl ether decaBDE has been widely used in HIPS Deleted: Deca and also in electronic wire insulation but may not be suitable for use as a substitute for HBCD due to concerns about its Deleted: A number of alternative fire impact on human health and the environment as well as debromination to components of pentaBDE and octaBDE retardants are available to replace HBCD in .Similarly, in the EU, the introduction of the RoHS Directive phased out the use of Deca-BDE. In the US the industry HIPS (Table 3). They are all required to be is voluntarily withdrawing Deca-BDE from most uses by 2013. In Norway, the manufacture, import, export, sale and used at considerably higher loadings (ECHA 2009). Deca- use of substances and preparations that contain 0.1 percent by weight or more of the imports decaBDE was therefore banned along with penta- and octaBDE in 2004. Comment [A44]: Reference missing from this sentence, please include. 80. Alternative materials to HIPS are also on the market, thus circumventing the problem of finding a chemical Deleted: PentaBDE substitute to HBCD. More specifically, in electrical products HIPS can be replaced by various alternative materials, including blends of polycarbonate / acrylonitrile butadiene styrene (PC/ABS), polystyrene / polyphenylene ether Deleted: OctaBDE (PS/PPE) and polyphenylene ether / high impact polystyrene (PPE/HIPS) without flame retardants or with the use of Deleted: . In non-halogenated flame retardants (Brazil 2011, DEPA 2010) . These co-polymer blends have higher impact strength Deleted: and OctaBDE. In and are more resistant to burning because they form an insulating char foam surface when heated (DEPA 2010). Moved up [2]: Other chemicals that can 2.3.2 Flame retarded textile back-coating be used as alternatives to HBCD in HIPS include both halogenated flame retardants 81. HBCD is used as a flame retardant in the back coating of textiles for upholstered furniture, upholstery seating in used in conjunction with antimony trioxide transportation vehicles, draperies, wall coverings, mattress ticking, and interior textiles such as roller blinds (Morose, (ATO) and halogen-free organic aryl 2006; ECHA, 2009, Swerea 2010). The typical concentration of HBCD in textile applications is high compared to other phosphorus compounds. applications. Numbers from CEFIC/EFRA 2006 suggest up to 15% in a polymer. Similar numbers from the US EPA Deleted: . Halogenated flame retardants suggest that the maximum concentration of HBCD (CAS No 3194-55-6) for use in fabrics and textiles and in rubber may also increase the toxicity of the emissions from fire (Dioxin 2010). and plastic products ranges from 1-30% (US EPA, 2006, see US EPA 2010). A Swedish report indicates that the Nevertheless, since HBCD is not widely primary source of release of HBCD in Europe is from textile applications (KEMI, 2006). However, this may not be the used in HIPS, it may be reasonable to case in other regions. Using IUR data, the US EPA found that the volume of HBCD used for textile application in the assume that the alternative flame retardants U.S. is estimated to be < 1 % of the total volume of HBCD produced/imported and hence releases from this use in the on the market are technically and U.S. are expected to be relatively small (as a percentage of overall volume produced/imported) (US EPA 2010). economically feasible. Deleted: In 82. Flame-retardant use in textiles can be avoided if the material itself is non-flammable or has low flammability (Norway 2011; Swerea 2010). This is the case for natural materials such as wool. Natural materials such as wool may Deleted: In therefore be used as barrier materials in furniture (Norway 2011). Also, several chemicals are available that may be Deleted: Production of f used as drop-in alternatives for HBCD in textile applications. For textile back-coating, alternatives to HBCD include Deleted: flame deca-BDE, tetrabromobisphenol A, decabromodiphenyl ethane, ethylene bis(tetrabromophtalimide), brominated polystyrenes, chlorinated paraffins and ammonium polyphosphates (ECHA 2009, Klif 2010a). As noted above, deca- Deleted: The BDE, may pose a risk because it is not readily biodegradable, and has low bioaccumulation potential in the Deleted: , environment (EU 2002). Long chain chloroparaffins are reproductive toxicants to humans, show chronic toxicity with Deleted: 6 effects on liver and kidneys, and are potential carcinogens (ECHA 2009). Deleted: , 6 83. In textiles fire safety may also be achieve by the use of intumescent systems (Klif, 2010). An intumescent Comment [A45]: References: system is a combination of various compounds that in the event of fire react together as a result of the temperature ... [1] increase to form a carbon foam. This foam attains a thickness of 10 to 100 times of the originally applied coating and Deleted: CEFIC/EFRA 2006. insulates the substrate material through its low thermal conductivity. Irrespective of the detailed mechanisms that Comment [A46]: Reference: ... [2] operate for specific intumescent systems the following characteristics are always present: The formation of a thick char Deleted: layer, high carbon concentration, high viscosity of pyrolyzing melt and low penetration capability for propagation of heat, which together make intumescent systems efficient to reduce flammability and the exposure of fume gases Deleted: (CEFIC/EFRA 2006 (Posner 2009). Several intumescent systems linked to textile applications have been on the market for about 20 years, Deleted: Several and have successfully shown their great potential. Intumescent systems include use of expandable graphite impregnated Deleted: ingbacking foams, surface treatments and barrier technologies of polymer materials. Almost all intumescent systems consist of three basic components; a dehydrating component, such as APP, a charring component, such as pentaerythritol (PER) Deleted: and a gas source, often a nitrogen component such as melamine. The main function of APP is to catalyse the Deleted: D dehydration reaction of other components in the intumescent system. It has been shown that in spite of the fact that APP Deleted: Deca 25. functions as a catalyst it has been used in rather large concentrations partly due to its participation in the formation of a char structure. In polyolefin polymers it has been shown that melamine and PER act as synergists to APP. Deleted: Comment [A47]: Reference: 84. ... [3] Deleted: .
Deleted: It is important to note, that... [4] 16
Persistent Organic Pollutants Review Committee
85. HBCD may be found in car dust and is present also in newer car models (Stavelova et al. 2010). According to Comment [A48]: Reference: the Annex F submission from Japan HBCD has been replaced in fabrics used in new car models. However, as Stavelova M, Kalachova K, Pulkrabova J, highlighted by Japan, the demand for fabrics that contain HBCD will continue for some time as such fabrics continue to Hradkova P, Kovar M, Demnerova K, Hajslova J. PBDES, HBCD and other non- be used in older car models (Japan 2010). -PBDES flame retardants in car dust sampled in the Czech Republic in 2009. 2.3.3 Expanded and extruded polystyrene (EPS/XPS) Dioxin 2010. 86. According to the European industry there are currently no commercially or technically viable drop-in chemical Deleted: Production of flame alternatives to HBCD as a flame retardant in polystyrene foam. This is because alternative chemical flame retardants, retarded e with the production methods used in Europe today, impair the structure and properties of the foam, making it unsuitable Deleted: expanded for use (ECHA 2009, BSEF 2011). Deleted: ) 87. The HBCD industry has highlighted the main challenges in the search for alternative flame retardants as the Moved down [5]: However, alternative following (BSEF 2011): halogenated flame retardants are commercially available in the USA for a. Fire performance of the products with the flame retardant over the complete service life, which needs EPS, where the production process used is to meet existing stringent regulations in the relevant countries different. b. Fit to produce foams without undermining the foam properties. In addition, once found and approved Moved (insertion) [6] for fire safety and other regulatory requirements, an alternative will have to be transitioned throughout the complex PS insulation foam market Deleted: T Deleted: . c. Consumer safety for the end product, which needs to be similar to HBCD in PS foams Deleted: . d. Environmental profile, which needs to be superior to HBCD. Fit to produce foams without increasing safety risks for workers. Deleted: In April 2011 Great Lakes Solutions announced investing in a facility 88. Nonetheless, the polystyrene industry is in the process of finding an alternative to HBCD jointly with flame- to produce a brominated polymeric flame retardant suitable for EPS and XPS. Little is retardant producers and a phase-out of HBCD from the production of EPS/XPS can be closer than anticipated. known about the environmental and health 89. In the USA, where the production process used in the production of EPS is different from that in Europe, two properties of these substances. alternative halogenated flame retardants tetrabromocyclooctane and dibromoethyldibromo-cyclohexane for use in EPS Moved (insertion) [5] production are already commercially available (LSCP 2006, BSEF 2011). However, there are concerns about the Deleted: However, a environmental or health properties of these substances: Deleted: in the USA for EPS, where the Tetrabromocyclooctane is structurally related to tetrabromocyclohexane which was identified in modelling production process used is different. Brominated chemicals other than HBCD studies as structurally similar to known Arctic contaminants and/or have partitioning properties that suggest are commercially available as flame that it is a potential Arctic contaminant. retardants for use in EPS applications in North America. These are Dibromoethyldibromo-cyclohexane is found in beluga whales in the Arctic; modelling studies identify it as tetrabromocyclooctane and likely to be persistent and bioaccumulative; and it was found to be a strong androgen agonist and mutagenic to dibromoethyldibromo-cyclohexane (LSCP mammalian cells in vitro. 2006, BSEF 2011). In addition to these two chemicals, a new chemical alternative is on its way. As previously stated above, in March Moved (insertion) [12] 2011, Dow Global Technologies LLC, announced the invention and development of a new, high molecular weight Moved (insertion) [13] brominated Polymeric Flame Retardant (Polymeric FR) (Dow, 2011). The Polymeric FR, developed as a replacement Moved (insertion) [14] for HBCD, is stated by the company to provide a fire safety solution for EPS and XPS foams. The product is also said to be a stable, high molecular weight, non-PBT (Persistent, Bioaccumulative, Toxic) substance, and it has been Deleted: There are also subjected to an extensive and robust Environment, Health & Safety (EH&S) testing regimen and evaluation that Moved (insertion) [15] confirms that the substance has a more sustainable profile. The product will be on the market from 2011, and Comment [A49]: We propose to put this commercial volumes that are in line with the current HBCD market demand are anticipated to be available by 2013- in a table. 2015. Deleted: ¶ <#>Types of alternative insulating materials include polyisocyanurate foams, 90. The Japanese EPS industry is aiming at replacing HBCD in the production processes by the end of 2012 and also and phenolic foams:¶ <#>Polyisocyanurate foams include the industry producing XPS is working towards reduction in HBCD use by reconsidering HBCD content but also the modified urethane foams that utilize need for HBCD in the product (Japan 2011). Interestingly, the European industry appears to use higher amounts of chemical flame retardants such as tris HBCD than North American producers to meet the fire safety requirements. monochloropropyl phosphate (TCMPP) and tris chloroethyl phosphate (TCEP). TCMPP is poorly characterized toxicologically but... in [5] 91. Moved (insertion) [16] a. Comment [A50]: Move this section to b. paragraph 2. This may be considered ... [6] Moved up [6]: The HBCD industry has c. highlighted the main challenges in the... [7] 17
Persistent Organic Pollutants Review Committee
d. Flame retarded EPS and XPS foam used for building insulation can also be replaced by alternative insulation materials which may equally rigid to or more flexible than EPS/XPS. Such materials include polyisocyanurate foams, phenolic Deleted: flexible foams, blanket insulation, fibreglass, polyester batts, sheep wool and reflective insulation systems including foils, films, or papers (Swerea, 2010, see Table 4), and also encompass insulation products such as polyurethane foams and loose- Comment [A51]: See comment on fill insulation that can be poured in place, spray-applied or blow-into the building structure during construction. Loose- preparing a new table below fill insulation consists of small particles of fiber, foam, or other materials (US Department of Energy, 2010). These Comment [A52]: Reference: small particles form an insulation material that can conform to any space without disturbing any structures or finishes. http://www.energysavers.gov/your_home/in This ability to conform makes loose-fill insulation well suited for retrofits and for places where it's difficult to install sulation_airsealing/index.cfm/mytopic=116 other types of insulation. The most common types of materials used for loose-fill insulation include cellulose, 50) fiberglass, and mineral (rock or slag) wool. All of these materials are produced using recycled waste materials. Cellulose is primarily made from recycled newsprint. Most fiberglass contains 20%–30% recycled glass. Mineral wool is usually produced from 75% post-industrial recycled content. Loose-fill insulation can also be produced from materials such as vermiculite or perlite. The different materials available on the market all have different thermal insulation properties, areas of use and require their own installation methods (US Department of Energy, 2010, Klif Comment [A53]: Reference: 2011c). They also vary with regards to fire-safety properties ( Klif 2011c). http://www.energysavers.gov/your_home/in sulation_airsealing/index.cfm/mytopic=116 92. Types of alternative insulating materials include polyisocyanurate foams, and phenolic foams: 50) a. Polyisocyanurate foams include modified urethane foams that utilize chemical flame retardants such Moved (insertion) [7] as tris monochloropropyl phosphate (TCMPP) and tris chloroethyl phosphate (TCEP). TCMPP is Deleted: Technical alternatives to HBCD poorly characterized toxicologically but in the TCEP manufacturing process ethylene oxide (a containing EPS/ XPS include: blown-in or carcinogen) is used, it appears to be a reproductive toxicant, is found in the Arctic indicating long- spray-applied insulation materials such as rock wool, fiber glass, cellulose, or range transport, and is considered a carcinogen by the California Office of Environmental Health polyurethane foam. Loose-fill cellulose Hazard Assessment. Due to the chlorinated and brominated flame retardants used in the manufacture insulation is commonly manufactured from of polyisocyanurate insulation products, these cannot be considered to be preferable alternatives recycled newsprint, cardboard, or other because of their health effects (LCSP 2006). forms of waste paper. The blown-in loose- fill insulation can provide additional b. Phenolic foams are in use in roofing, cavity board, external wall board, and floor insulation. They are resistance to air infiltration if the insulation is sufficiently dense. Loose-fill insulation mostly used to bind glass fiber to make insulation products. One concern over their use is that can also be poured in place by using formaldehyde, a human carcinogen, is used for making phenolic resins monomer. Formaldehyde is materials such as vermiculite or perlite. listed by the International Agency for Research on Cancer (IARC) as a known human carcinogen These materials are produced by expanding (Morose 2006). This has to be considered at the production sites, using available emission control naturally occurring minerals in a furnace (LCSP 2006)¶ techniques and safety restrictions securing the workers. ¶ c. Blanket insulation is as much a technical alternative as an alternative material. It is usually made of Comment [A54]: We propose to put this fiber glass or rock wool and can be fitted between studs, joists, and beams. It is available in widths in a table, Table 4. suited to standard spacings between wall studs or floor joists. Continuous rolls can be hand cut and trimmed to fit various spaces. The blankets are available with or without vapour retardant facings. Batts with special flame resistant facing are available where the insulation will be left exposed. d. Fiberglass is a synthetic vitreous fiber. Loose-fill insulation is typically blown into place or spray- applied by special equipment. It can be used to fill existing wall cavities and for irregularly shaped areas. e. Reflective insulation systems include foils, films, or papers that are fitted between studs, joists, and beams and commonly used to prevent downward heat flow in roof applications. Common materials include foil-faced paper, foil-faced polyethylene bubbles, foil-faced plastic film, and foil-faced cardboard. f. Other commonly used insulation materials include polyester batts and sheep wool which can be fitted between studs, joists, and beams.
The substitution of HBCD for building and construction purposes may also be aided by product redesign i.e. by technical solutions and changes in building and construction practice. Non-flame retarded EPS boards are used in a number of countries in combination with other construction materials which protect the EPS from catching fire (COWI, 2011) Examples of product redesign include using fire barrier material and other strategies to separate and reduce the source of heat from the product. These design changes could be implemented by the end-product manufacturer (LCSP 2006; Morose 2006). By using thermal barriers it is possible to fulfil fire safety requirements without the use of flame retarded EPS/XPS. Thermal barriers are fire resistant coverings or coatings that separate the insulation material from the building interior. These include: gypsum boards, gypsum or cement plasters, perlite boards, spray-applied cellulose, use of mineral fiber or gypsum coatings and selected types of plywood. All these materials are currently in common use 18
Persistent Organic Pollutants Review Committee
in domestic and commercial building construction (LCSP 2006, SWEREA 2010). To create a thermal barrier the Moved (insertion) [8] insulation material may for example be placed between two non-combustible wall surfaces such as stone or concrete or between building foundations and soil (LCSP 2006). Thermal barriers are subject to country-specific building code Deleted: These uses include placement of requirements (SWEREA 2010), and are currently used in Finland, Norway, Sweden and Spain where the national fire Deleted: insulation between two non- safety requirements are fulfilled by building codes. By considering also technical aspects and solutions such as the use combustible wall surfaces such as stone or concrete and uses where insulation is placed of thermal barriers and how the insulation is implemented in the building construction, the building codes in these between building foundations and soil. countries specify which insulation products may be used and for which type of construction. Hence fire safety may be These design changes could be achieved even when using non-flame retarded EPS/XPS. implemented by the end-product manufacturer (LCSP 2006). ¶ Several alternative insulation materials that are available on the market today and that are used in many countries worldwide have fire-properties to meet country specific fire-safety requirements and are generally comparable in their Deleted: ¶ properties to EPS (Klif 2011c). However, the alternative insulation materials/techniques may have characteristics that Deleted: good enough are different from XPS and EPS and that are more or less appropriate for some specific use scenarios (ECHA 2009, US Comment [A55]: Will be published in Department of Energy, 2010). Use of alternative insulation materials/techniques may also incorporate different mid june 2011. environmental issues such as increased energy costs during transportation, and may come with their own unique set of Comment [A56]: Alternatives to flame health- and/ or environmental risk which in most instances are not too well known. Fiberglass, glass wool, and mineral retarded EPS in buildings. A project by wool which are considered synthetic vitreous fibers may for example have occupational health effects. When these COWI AS Denmark. Climate and pollution fibers are suspended in air they can cause irritation of the eyes, nose, throat, and parts of the lung. Animal studies show agency (Klif) 2011. that repeatedly breathing air containing synthetic vitreous fibers can lead to inflammation and fibrosis of the lung. Deleted: Another strategy would be to (ATSDR 2004). Protective clothing and equipment (face masks, goggles, gloves etc.) should be used by construction apply the flame retardancy function through workers to avoid irritations from contact and breathing in the fibres. reactions after handling polyurethane foam the use of fire resistant coverings or coatings that act as thermal barriers. insulation, according to the sources at the Center for Polyurethanes. When release to the outer environment is not Thermal barriers are fire resistant coverings considered, the health effects of any given insulation material is primarily of importance in the work environment, since or coatings that separate the insulation the insulation material is built inside the wall, foundation and ceilings in the buildings and constructions. material from the building interior. These include: gypsum board, gypsum or cement plasters, perlite board, spray-applied cellulose, mineral fiber, or gypsum coatings, and selected types of plywood. All 93. Replacing EPS/XPS insulation with other materials can furthermore affect overall product cost and performance, these materials are currently in common use and may additionally require a different approach during building and construction. However, current building practice ... [8] from Sweden and Norway, where most of the EPS and XPS used is HBCD-free, suggests that fire-safety of building Deleted: <#>By using thermal barriers it is possible to fulfil fire safety requirements materials and buildings can be obtained at a reasonable cost without the use of HBCD and without altering traditional ... [9] building and construction techniques to a great extent. Deleted: There are also alternative insulation materials available on the ...market [10] Deleted: <#>Alternative insulation 94. The properties of EPS make it especially feasible for insulation of exterior walls, flat roofs, floors and sandwich materials to EPS/ XPS are available for... [11]all elements. Technical feasible alternatives for the key uses of flame retarded EPS are commercially available and Moved up [12]: <#>Brominated common insulation materials used worldwide. They are stone wool, glass wool, PUR/PIR, phenolic foam and non- chemicals other than HBCD are ... [12] flame retarded EPS. Cellular glass, perlite and wood fibre insulation boards is considered to be as technical feasible as Moved up [13]: <#> These are EPS for all the key uses except for sandwich panels. Cost and their environmental and health properties have been tetrabromocyclooctane and ... [13] assessed in a recent Norwegian report (Klif 2011c). Moved up [14]: <#>There are also concerns about the environmental or health ... [14] Moved up [15]: <#>Tetrabromocycl 95. ooctane is structurally related to ... [15] 96. . Deleted: <#> ¶ ... [16] 97. Moved up [16]: <#>The Japanese EPS industry is aiming at replacing HBCD... in [17] the 98. Deleted: <#>.¶ 99. Moved up [4]: The first consideration would be to eliminate use of HBCD and 100. ... [18] Moved up [8]: These uses include placement of insulation between two... non- [19] Deleted: <#>¶
Deleted: Alternatives to EPS/XPS¶... [20] Moved up [7]: <#>Technical alternatives to HBCD containing EPS/... XPS[21] Deleted: <#>occurring minerals in a furnace (LCSP 2006).¶ ... [22] Moved down [9]: Fiberglass, glass wool, and mineral wool are considered... [23] 19
Persistent Organic Pollutants Review Committee
Moved (insertion) [9] 2.4. Summary of information on impacts on society of implementing possible control measures Deleted: <#>Fiberglass, glass wool, and mineral wool are considered synthetic vitreous fibers. They also may have occupational health effects. When these 101. As the persistent, bioaccumulative and toxic properties of HBCD as well as its potential for long-range fibers are suspended in air they can cause transboundary transport were shown in the risk profile agreed by the POPRC of the Stockholm Convention, a positive irritation of the eyes, nose, throat, and parts impact on globally sustainable development from an elimination of HBCD is to be expected. If production and use of of the lung. Animal studies show that repeatedly breathing air containing HBCD with persistent, bioaccumulative and toxic properties is not managed, and were to continue or increase, then synthetic vitreous fibers can lead to levels in the environment including in humans and animals will likely continue to rise, even in locations distant from inflammation and fibrosis of the lung. production and use. (ATSDR 2004). Protective clothing and equipment (face masks, goggles, gloves etc.) is available and used by construction workers to avoid irritations from contact 2.4.1. Health, including public, environmental and occupational health and breathing in the fibres. This will only be of importance in the working 102. A positive impact on human health and on the environment can be expected from reduction or elimination environment, since the fibrous material is control measures on HBCD on a global scale. In humans HBCD is found in blood, plasma and adipose tissue. The main built inside the wall, foundation and sources of exposure presently known are contaminated food and dust. Imposing control measures would likely ensure ceilings in the buildings and constructions.¶ that the levels of HBCD in agricultural products like farmed (and wild) fish, milk/milk products and various meat Deleted: , especially in relation to blood products level off. In the short term, the most positive effect would be anticipated to be on the indoor environment; with levels HBCD levels in dust being completely eliminated or dramatically reduced as a consequence of a ban. A positive outcome of this would be reduced exposure to humans, particularly children, who have been shown to ingest more dust than adults (UNEP/POPS/POPRC.6/13/Add.2). Comment [A57]: Exposure of workers and exposure through food should also be 103. Though information on the human toxicity of HBCD is to a great extent lacking, embryos and infants have been highlighted here – see identified as vulnerable groups that could be at risk (UNEP/POPS/POPRC.6/13/Add.2, RAC 2010), particularly due to UNEP/POPS/POPRC.6/13/Add.2 the observed neuroendocrine and developmental toxicity of HBCD observed in animal studies. Phase-out or elimination Deleted: ). of HBCD would also be particularly beneficial to Arctic indigenous peoples who depend on traditional native foods and therefore are at much greater risk of exposure than other communities. The particular risks posed by POPs to Arctic ecosystems and indigenous communities are acknowledged in the preamble to the Convention.
104. ). A phase out of HBCD in articles and waste is essential to reduce the exposure of the environment and wild Deleted: In developing countries, life, humans exposure through contaminated food and water and the direct exposure to workers from recycling and electrical and electronic appliances operations, or at the dump sites as well as open burning of HBCD containing waste in developing countries containing HBCD and other toxic substances are often recycled under (Malarvannan et al., 2009, Polder et al., 2008Tue et al., 2010, Zhang et al., 2009). conditions which result in a relatively high release of HBCD to the environment and 105. HBCD and other brominated flame retardants (BFRs) may also increase fire toxicity and lower survival by contamination of the sites (Zhang et al., augmenting the release of carbon monoxide and soot and production of halogenated dibenzodioxins and dibenzofurans 2009), and exposure of workers (Tue et al., (see Dioxin (2010). The prevalence of certain kinds of cancer in fire fighters may be linked to an elevated exposure to 2010). Open burning and dump sites are brominated and chlorinated dioxins and furans and this warrants further attention. The overall fire safety benefit of common destinations for HBCD-containing articles and electronic wastes (Malarvannan regulations requiring flame retardants has been questioned since they can increase the release of toxic gases and soot et al., 2009, Polder et which are the cause of most fire deaths and injuries (DiGangi et al 2010, Stec & Hull 2010). Combustion of materials containing HBCD or other halogenated flame retardants during accidental fires and burning flame-retarded waste Moved down [10]: Malarvannan et al., 2009, Polder et al., 2008 increases the toxicity of fire effluents by increasing the release of carbon monoxide, acid gases such as hydrogen bromide, and brominated and chlorinated dioxins and furans (Shaw et al 2010). An overall reduction of flame-retarded Moved (insertion) [10] materials may therefore lead to a smaller risk of health problems for the general public and fire fighters, if fire safety can be achieved by other means.
2.4.2 Biota (biodiversity)
106. A phase-out of HBCD is essential to avoid an increase of levels in wildlife already at risk. HBCD is considered Deleted: A positive impact on biota from very toxic to aquatic organisms. There is a risk of adverse effects in marine mammals and fish in the vicinity of point a ban of HBCD can be expected.expected sources and in regions with elevated background levels. The measured concentration levels in biota exceed the PNEC for secondary effects of 5 mg/kg wwt in the EU risk assessment of HBCD (European Commission 2008). Levels in birds from European regions with elevated back ground levels or near local point sources are concluded to lie near the Comment [A58]: Those risks should threshold levels for adverse effects. Further indications for concern come from recent preliminary data obtained with also be included, see captive American kestrels which suggest a risk for reproductive and developmental effects also in wild birds in remote UNEP/POPS/POPRC.6/13/Add.2 regions (UNEP/POPS/POPRC.6/13/Add.2). Deleted: The scientific literature has identified that HBCD is very toxic to 2.4.3 Economic aspects, including costs and benefits for producers and consumers and the distribution of costs aquatic organisms. In avian species, data and benefits from recent studies report effects such as reduced eggshell thickness, growth and survival. 20
Persistent Organic Pollutants Review Committee
107. A ban of HBCD in the absence of a drop-in alternative can have a negative impact on the EPS and XPS industry Moved down [11]: The cost for in Europe. and the workforce in this sector (Plastics Europe/Exiba 2011, XPSA/CPIA 2011). However, the use of non developing countries of a phase out of flame retarded EPS and XPS can currently be used in some applications, and other alternative chemical substitutes to HBCD uses should be limited, as the majority of the HBCD use takes place in HBCD in EPS and XPS is already commercially available and are in the progress of being phased in for a full scale Europe. production (Chemtura 2011, BASF 2011), or are in progress to be commercially available for a full scale production of PS foam in 2017 (European Commission 2011). The insulation market is increasing because of a higher demand of Deleted: According to BSEF, aa insulation, especially on the Asian market (Klif 2011b, BizAcumen 2009, European Commission 2011). A ban with a Deleted: would severely harm time limited exemption for use in PS foam would make the economic impact less. However, pressures from consumers Comment [A59]: This is not true for the and national legislations are already forcing the industry to change to less hazardous flame retardants (SWEREA 2010). Norwegian producer of HBCD free foam. A ban would have a positive impact for the health of those consumers and for the industry sectors that produce Comment [A60]: This is a statement alternative flame retardants and materials nationally and worldwide (Klif 2010). The cost for developing countries of a that is not documented. phase out of HBCD uses should be limited, as the majority of the HBCD use takes place in Europe. Deleted: and drastically impact the 108. Specialized waste management and disposal related to HBCD (buildings and articles) could be costly especially economics also for non-HBCD containing for developedcountries dominating the consumption of HBCD globally, and the cost is highly dependent on the phase PS foam. out time of HBCD. The waste accumulation per year will increase with the phase out time and the waste amounts and Moved (insertion) [17] costs will be correspondingly larger in the future. The situation in EU illustrates the challenges the HBCD waste will Deleted: A ban on HBCD can have generate in the future in developed countries. The accumulation of waste has been estimated to approximately 1,196 consequences for EPS and XPS producers tons/year in EU in a recent report (European Commission 2011). Construction and demolition waste and textiles in relation to represent the majority of the waste in EU at the present (EPS for construction 68.82 tons/year, XPS for construction Moved (insertion) [11] 75.8 tons/year, EPS/XPS other than construction 3.9 tons/year, HIPS 181 tons/year and HBCD from textiles 866.7 Deleted: In addition, s tons/year). It is, however, important to notice, that a significant amount of HBCD is each year incorporated into new flame retarded products in the EU (e.g. 10,431 tons/year in 2010), which will become waste in the future. The Deleted: both corresponding HBCD waste amount in 2010 is approximately 32,930 tons/year from the investigated sources. The Deleted: and developing waste figures are expected to significantly increase, due to huge amounts of HBCD incorporated into new EPS/XPS Deleted: . products for construction purposes and the relatively long life times of the products. By 2017 the total relevant waste quantity is estimated to be about 23 million tons of HBCD. The estimated life time used in the estimations was 50 (±25 Comment [A61]: Reference: years). The HBCD waste flow is expected to increase from 32,931 tons in 2010 to more than 380,000 tons in 2040, Nordic Council of Ministers 2004. Cost of reaching its maximum around 2050. However, the amount becoming waste after 2010 is based on the hypothetic Late Action - the Case of PCB. TemaNord assumption that the consumption declines continuously after 2013 and that from 2017 the consumption will be zero. If 2004:556, Copenhagen. the phase out time is longer, the waste accumulation will be increased and the waste amounts even larger. Comment [A62]: This is not documented to be a consequence. 109. The lessons learned from the legacy POP, PCB, shows that lack of awareness about the environmental and Comment [A63]: This is only true for health consequences of one chemical, like PCB, has caused substantial costs to EU Member states. The estimated cost one application: Cold storage and the in EU for late action and phase out of PCB, has been estimated to be between EUR 15 and 75 billion depending on the recommendation is based on an old level of ambition. The consumption was estimated to around 450,000 – 550,000 tonnes of PCB within EU25 1971-2018 survey from 1998. It does not say (Nordic Council of Ministers 2004). . anything about the level of fire safety needed, and the building codes does not 110. Among all dietary samples, the highest HBCD concentrations (up to 9.4 ng/g w/w) are reported for fish require HBCD as the only possible flame (Knutsen et al. 2008, Remberger et al. 2004, Allchin and Morris 2003). Hence fish, particularly fatty carnivorous fish retardant in North America. There are also other alternative brominated flame placed at the higher end of the food chain, is an important source for human exposure (Polder et al., 2008a, Thomsen et retardants available and commonly used. al., 2003). The phase-out of HBCD could thus have a positive impact on fisheries and aquaculture and could in addition be of general benefit to consumers. Fisheries and aquaculture is an important industry worldwide. This industry depend Ref: “The Environmental and Societal on a clean environment to be able to deliver clean sea food products of high quality, and any suspicion of the fish being Value of Extruded Polystyrene Foam Insulation”, Barbara A. Fabian et al, contaminated with environmental pollutants can be economically harmful to the industry.. Earth Technology Forum, Washington, April 27, 2004. Available at: 111. http://www.xpsa.com/enviro/PDFs/Fabia n_Hoffee_Herrenbruck_Earthtech_2004. 112. According to information from XPSA and CPIA a ban of HBCD would prevent the use of XPS products pdf containing the substance, end the current practices of the XPS industry in the US and Canada, and cause difficulties since for many applications XPS is the only product recommended and accepted by current building codes. The recent Comment [A64]: This is only true for progress in finding a polymeric chemical alternative, although brominated, may alleviate these concerns. one application: Frost protected Shallow Foundations (FPSF), and the building 113. Emission reduction measures and use of best practices would be required in the production for potential specific code does not require the use of HBCD, exemptions and use therein to reduce HBCD releases to the environment from these uses. European HBCD and as the flame retardant in the XPS. Since polystyrene manufacturers have in 2006 initiated emission reduction programmes, which are targeted at eliminating the use is underground in especially... cold[24] emissions from first line users of HBCD (Self-Enforced Control of Use to Reduce Emissions (SECURE) and Voluntary Comment [A65]: Move to 2.3 about Emissions Control Action Programme (VECAP)). Most of the European PS foam industry implements those risk alternatives. reduction measures (EBFRIP 2009a). Implementing best practices in handling reduced the total potential releases from ... [25] 2,017 kg/year in 2008 to 309 kg/year in 2009 in the survey. The costs of emission reduction programmes initiated by Comment [A66]: Should be moved to European HBCD and polystyrene manufacturers are highly dependent on the company operations (BSEF 2011). Also 2.2 the Japanese curtain and blind industry has developed a coagulation-sedimentation method in the dyeing process to Comment [A67]: Should be moved to reduce HBCD emissions to water (Japan 2011). chapter 2.2 21
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114. In accordance with Article 6(1)(d)(ii), HBCD containing products (EPS, XPS, HIPS, textiles) should be managed in an environmentally sound manner and disposed of in such a way that their POPs content is destroyed or irreversibly transformed so that they do not exhibit the characteristics of POPs. This will require separation of HBCD containing articles from others upon becoming waste and the prevention of inappropriate waste management practices leading to recycling of the POP content. Comment [A68]: Should be moved to chapter 2.2 115. For drop-in chemical substitutes, two main types of costs have to be considered concerning the switch from one flame retardant to another (SWEREA 2010); a. The switching cost, which is the cost of reformulation, in other words the cost of the development work or equipment change. Manufacturing and processing facilities may need to invest in new equipment in order to shift to alternative flame retardants. This cost is difficult to estimate, and usually contains the cost of those research and development endeavours which did not succeed in finding an efficient flame retardant alternative. This is a cost which is generated at the beginning of a product life cycle. b. The operating cost which reflects the price of the flame retardant (raw) material cost. In addition, daily operation costs may be different for the new process steps required to manufacture other flame retardant chemicals. To ensure economic viability, flame retardants must be easy to process and cost- effective for what most of the time high-volume manufacturing conditions are necessary. The costs of manufacturing are heavily dependent on the costs of raw materials, but the degree of this dependency varies among the flame retardants.
116. Deleted: Following this, the PS foam industry must adapt to the new flame 117. In spite of those costs mentioned above, movement to alternatives already exists implying that the costs are retardant alternatives. acceptable and not critical, although not yet fully known. In 2003 the EPS sector group and the European XPS Moved up [17]: A ban on HBCD can producers in Europe initiated projects to find alternatives to HBCD for use in EPS and XPS and to share the costs have consequences for EPS and XPS connected with the development of new alternatives with the flame retardant producers (HBCD industry working group producers in relation to the workforce in 2009). At this time HBCD was undergoing risk assessment under the Existing Substance Regulation (EC) 793/93 in the this sector (Plastics Europe/Exiba 2011, EU, and the manufacturers of EPS and XPS were highly concerned about the outcome of the environmental profiling, XPSA/CPIA 2011). the future regulatory situation and the resulting impact on producers and users (HBCD Industry Working Group 2009). Deleted: ¶ The HBCD industry working group reported to the UNECE/CLRTAP process in 2010 that current estimations from the two projects underway were that an alternative would be available on the market in 5-10 years. This included the registration of the alternatives under REACH in the EU. 118. In North America the major brominated flame retardant manufacturers (Albemarle, Chemtura Corporation and ICL-IP) have formed alliances with other companies (forming the North American Flame Retardant Alliance (NAFRA) under the umbrella of ACC) to promote and defend a broad range of flame retardants. The three companies have inorganic phosphor based flame retardants in their portfolio in addition to the brominated flame retardants. Other brominated flame retardants for use in EPS are already on the United States market as alternatives to HBCD (LCSP 2006). They are however not applicable to the European industry which uses different processes for manufacture of EPS and XPS. However, there is a recent announcement by Great Lakes Solutions on preparations to start production of Comment [A69]: Repetition and some a directly applicable alternative to HBCD. of the more detailed information should be moved to the 2.3. section. We could not 119. thermal barriers will not represent an extra cost, since thermal barriers used are common materials and find the ongoing joint research programme relatively cheap. EPS and XPS without flame retardants are commercially and technically feasible alternatives today in EU on alternatives to HBCD in PS foam and do not represent a higher cost to the manufacturer. EPS and XPS insulation boards are recommended by the in the text under 2.3. Please include where producers to be covered by other materials in buildings and constructions to improve the insulation and thermal relevant properties, as well as fire resistance, even if flame retarded (Klif 2011c) . This is also commonly done in buildings and Deleted: EPS and XPS insulation boards constructions. Using 30 % of EPS in Europe are not flame retarded (European Commission 2011). The market in are most often covered by other materials in Scandinavia is dominated by polystyrene boards without flame retardants. This is accomplished by fire safety buildings and constructions. Using regulations not requiring treatment with a flame retardant, acquiring the same level of protection through other means Comment [A70]: Klif 2011c. and relies to a lesser extent on flame retardants (SWEREA 2010). Alternatives to use of flame retarded EPS in buildings. Written by COWI. 120. Consequences for the elimination of HBCD through legislation will influence markets with a substantial Deleted: In this region, only producers production and use of HBCD flame retarded EPS insulation boards (Europe), but to a lesser extent markets that are less manufacturing EPS and XPS for export, dependent on HBCD due to use of other processes of EPS manufacture using other brominated flame retardants (the like in Norway, will be affected by a ban on US). The ongoing initiatives in the polystyrene foam sector to find alternatives for use of HBCD (North America and HBCD. Europe) are accomplished by sharing the costs and investments in voluntary projects between the flame retardant Deleted: As there are currently no known producers and the polystyrene foam manufacturers (HBCD Industry working group 2009). For regions where HBCD is chemical alternatives for XPS, HBCD largely phased out (Scandinavia) the cost will be low. Conclusively, the cost implications for producers are considered elimination will affect production of flame retarded XPS in all regions, unless a to be low to moderate, and a switch to other flame retardants will stimulate some producers (KLIF 2010). suitable alternative can be phased in in a timely manner. 22
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121. For the EU, the total incremental costs at the production level of replacing the HBCD in HIPS in all EEE have Deleted: Increase in cost for been estimated in the range of 1-10 million €/year if HBCD is replaced with other brominated flame retardants and 5-25 manufacturers of HIPS and textile coatings million €/year if the HIPS/HBCD is replaced by copolymers with non-halogenated flame retardants. The costs may is expected to be low since substitutes are already in use. decrease over the years as a result of a larger market for the alternatives (DEPA 2010). 122. In controlled burning of waste, the control measures and application of BAT/BEP to address other by-products Comment [A71]: Does not say anything about the actual costs for the alternatives to from incineration reduce by-product emissions of HBCD and brominated dioxins and furans. There are no extra costs HBCD involved for the industry. Deleted: Flame-retardants that are either 123. more expensive per kg or require more flame retardant per unit polymer mass (or 124. In several countries in the EU the fire safety requirements are performance based. HBCD or any other flame volume) to meet the fire safety standards retardant are not required to fulfil the fire safety regulations, but if non-flame retarded EPS/XPS boards are used the will increase the raw material costs. Large differences between flame retardant fire-safety requirements call for structural applications where the fire-safety is achieved with non-combustible barrier chemicals’ prices do not necessarily have material. In some countries lining of walls and roofs needs flame retarded polystyrene foam if used. Usually other any impact on relatively expensive end insulation materials are used for this purpose. In a few European countries only special applications require polystyrene products (SWEREA 2010). When used as foam to be treated with a high performance flame retardant. In other countries retarded EPS and XPS is used due to an additive in PS foams, HBCD total content by weight varies between 0.5% storage and insurance reasons and not due to the fire safety regulations. Several countries have stringent fire safety (EPS) and 2.0% (XPS) (XPSA/CPIA 2011, requirements on the insulation boards themselves used in buildings and constructions and in those countries EPS and CEFIC 2011). XPS have to be treated with a flame retardant such as HBCD. Deleted: 125. For several countries the use of EPS and XPS without flame retardants will require an adjustment of policies and Comment [A72]: This does not say a change in the way of implementation of fire safety standards. This will take time, and costs are considered to be anything about costs or benefits of a HBCD moderate. In the EU there are already initiatives to harmonize the fire safety regulation standards, and HBCD is on the ban. Move to section 2.2 indicative list of hazardous substances that should be avoided for use for fire protection in buildings and constructions. Deleted: , from classifying the building This would also be an important drive to change the fire regulations. (KLIF 2010). materials as components of the construction elements, to classifying the construction 2.5. Movement towards sustainable development elements themselves 126. Controlling the risks posed by chemicals is an important part in working towards a sustainable society. Increased Deleted: Other considerations knowledge about fires enables better decision making in order to ensure a high level of protection from fires as well as Comment [A73]: This text does not from dangerous substances. (KemI Report 1/06). To move away from halogenated flame retardants to halogen free give any information. If something should chemical alternatives or non-chemical alternatives (alternative materials/product redesign) is a more sustainable be included stated on those websites it approach, since it represents less hazard for health and environment. This will also represent a lower cost for the society should be explicit mentiones instead with a reference to the website in the reference list. on a longer term and the development of a green economy, avoiding the cost associated with hazardous chemicals (cost for waste management, reduced health, cost of remediation of contaminated sites etc.) and stimulation of the industry Comment [A74]: This text does not give any information. If something should sectors with sustainable production and use. There are initiatives taken in a joint effort between authorities and industry be included stated on those websites it to move to a more sustainable use of flame retardants. The Green Flame is a voluntary system for simultaneously should be explicit mentiones instead with a assessing products, in relation to environment and health quality, when involved in fires reference to the website in the reference list. (www.sp.se/en/index/services/greenflame). It is open for all kinds of different products and will create incentives for manufacturers who design products that perform better than the standards applicable to them. The intention is that the Deleted: <#>For more information about Green Flame system will provide competitive advantages to the companies that possess the competence and industry innovations regarding HBCD alternatives please see the following determination to develop consumer products that represent a major improvement in fire safety and environmental websites: quality. Deleted: <#> 127. HBCD monitoring information is available from Europe, North America and Asia. To follow the effectiveness http://chemtura.investorhq.businesswire.co of the potential actions, HBCD should be added to the existing POP monitoring activities. m/press-release/company-news/chemtura- corporation-first-sign-license-agreement- 3. Synthesis of information dow-chemical-company-po ¶ <#>The industry voluntary actions to 128. reduce emissions of HBCD in Europe are described at: 3.2 Summary of risk management evaluation information Deleted: <#>¶ ... [26] 129. HBCD is produced in China, Europe, Japan, and the USA. The known current annual production is Deleted: More information about product approximately 23,000 tonnes per year (9,000 to 10,000 tonnes in China, 13,426 tonnes by the BSEF companies in redesign and fire safety is available at: Europe and the US, Japan not known). The main share of the market volume is used in Europe. HBCD has been on the www.sp.se/en/index/services/greenflame. world market since the 1960s. It is used as a flame retardant additive, with the intent of delaying ignition and slowing Comment [A75]: Move to section 2.2 subsequent fire growth during the service life of vehicles, buildings or articles, as well as while materials are stored. Comment [A76]: The conclusion is The main uses of HBCD globally are in flame-retarded expanded (EPS) and extruded (XPS) polystyrene foam stated in the beginning of this document... [28] insulation, while the use in textile applications and electric and electronic appliances (HIPS) is of a smaller scale. The Deleted: 3.1 Summary of risk profile use of HBCD in insulation boards started in the 1980s. In textiles HBCD is used in back-coating used for upholstery information¶ ... [27] furniture and other interior textiles, including automotive applications. Comment [A77]: Please incorporate the main points resulting from new information provided and other changes in the previous... [29] 23
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130. A number of alternative fire retardants are available to replace HBCD in HIPS and textile back-coating. However, there are no drop-in chemical alternatives for certain flame-retarded EPS/XPS production. In some countries there is a need for flame retarded insulation materials due to the country-specific fire safety requirements. In some countries HBCD has effectively already been phased out. In those countries the fire safety regulations do not require treatment with a flame retardant, and the same level of fire safety is achieved by other alternatives, that are technically feasible and also commercially available. HBCD phase-out could include flame retardant substitution, resin/material substitution and product redesign. Emissions of HBCD can be reduced in the processes where HBCD or articles containing HBCD are used, and during the waste management phase. 131. HBCD may be released to air, water, soil and sediment during all stages of its life cycle; production and manufacturing, processing, transportation, use, handling, storage or containment, point-source discharges, migratory releases from manufactured product usage and from disposal of the substance or products containing the substance. European producers and manufacturers have successfully taken measures to reduce emissions from production and first line use. Emission control techniques at the production sites will not prevent HBCD emissions, since there are diffuse emissions and releases to the water reserves and sewage systems from products containing HBCD during use or upon becoming waste. 132. HBCD is an intentionally produced industrial chemical. Under the Convention, the most adequate control measure is listing in Annex A. To allow for certain time-limited critical uses of HBCD, a specific exemption for use of HBCD could be given together with a description of the conditions for production and these uses. Wastes containing HBCD are a concern because they will represent a large source of releases and because increasing amounts of HBCD- containing wastes in landfills and other locations could be a long-term source of HBCD emissions. Wastes containing HBCD include production wastes, insulation boards, building and renovation wastes, and from other less-commonly used applications such as electrical and electronic products and textiles. The process of remodelling and demolition of buildings leads to concerns that installed building materials containing HBCD will continue emissions in the future, unless properly managed by future generations. Stockpiles and waste containing HBCD would be subject to the provisions in Article 6. 3.3 Suggested risk management measures 133. Listing HBCD in Annex A of the Convention would prohibit the manufacture, use, import and export of HBCD (except as allowed under the Convention for environmentally sound disposal) and could be linked with specific exemptions that specify deadlines for the eventual elimination of remaining HBCD manufacturing and use. Such listing could also be coupled to other decisions that would describe in more detail such uses of HBCD and appropriate conditions for their manufacturing and use. When assessing whether specific exemptions would be appropriate, among other considerations identified in Annex F to the Convention, factors such as exposure; production volume; and societal costs and the ubiquitous contamination of humans, the environment and possible impact on future generations should be considered. 134. The suggested control measure is that HBCD be listed in Annex A, with or without specific exemptions, and if with exemptions accompanied with detailed conditions for HBCD uses. 135. Listing of HBCD in Annex A would be consistent with the POPs properties of this intentionally produced substance. Such a listing would send a clear signal that production and use of HBCD must be phased out. Such a listing may have implications for countries in light of ongoing uses where alternative substances or alternative methods need to be phased in. Stockpiles and waste containing HBCD would be subject to the provisions in Article 6. 4. Concluding statement 136. Having decided that hexabromocyclododecane (HBCD) is likely, as a result of long-range environmental transport, to lead to significant adverse effects on human health and/or the environment such that global action is warranted; Comment [A78]: The conclusion from the risk profile should be used here. 137. Having prepared a risk management evaluation and considered the management options; 138. The Persistent Organic Pollutants Review 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 hexabromocyclododecane and 1,2,5,6,9,10 -hexabromocyclododecane in Annex A as described above.
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Available Annex F info listed in alphabetical order by submitting country/ or organization Deleted: References Formats for submitting information specified in Annex F of the Convention pursuant to Article 8 of the Stockholm Convention are available for review on the Stockholm Convention website: www.pops.int/poprc Brazil 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Burundi 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Canada 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Colombia 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, March 2011. China 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Costa Rica 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Czech Republic 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Ecuador 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Finland 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Germany 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Japan 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, March 2011. Nigeria 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Norway 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Mauritius 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Romania 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Sweden 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. [BSEF] 2011. Bromine Science and Environmental Forum (BSEF). Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. PlasticsEurope/Exiba 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Instituto do Meio Ambiente (IMA) Brazil 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. [XPSA/CPIA] Extruded Polystyrene Foam Association (XPSA) and Canadian Plastics Industry Association (CPIA). Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. [IPEN] International POPs Elimination Network 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011.
References Deleted: Other references:
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[APME] Asscociation of Plastics Manufacturers in Europe (APME), European Extruded Polystyrene Insulation Board Association (Exiba), European Isocyanate Producers Association (Isopa) (no date). Co-combustion of Building Insulation Foams with Municipal Solida Waste. Summary report. Authors: Vehlow, J., Mark, F.E. 4 p. [ATSDR] Agency for Toxic Substances and Disease Registry 2004. Synthetic vitreous fibers. Division of Toxicology ToxFAQs. http://www.atsdr.cdc.gov/tfacts161.pdf [BFR] 2010. Brominated Flame Retardants in Products: Results of the Swiss Market Survey 2008. Authors: Bantelmann, E., Ammann, A., Näf, U., Tremp, J. Abstract at BFR 2010 conference. 4 p. [BSEF] (Bromine Science and Environmental Forum). About Hexabromocyclododecane (HBCD). 2006. http://www.bsef.com/our-substances/hbcd/about-hbcd/ (accessed January 2008). BSEF] Bromine Science and Environmental Forum. About Hexabromocyclododecane (HBCD). 2010. http://www.bsef.com/our-substances/hbcd/about-hbcd/ (accessed June 2010). [BUWAL] Bundesamt für Umwelt, Wald und Landschaft 2004. Bromierte Flammschutzmittel in Kunststoffprodukten des Schweizer Marktes. Authors: Kuhn, E., Arnet, R., Känzig, A. and Frey, T. 53 p. [CEFIC/EFRA] European Chemical Industry Council. European Flame Retardants Association 2006. Flame Retardants Fact Sheet. Hexabromocyclododecane (HBCD). 3 p. http://www.cefic-efra.com/Objects/2/Files/HBCDFactsheet.pdf [DEPA] 2010. Inclusion of HBCDD, DEHP, BBP, DBP and additive use of TBBPA in annex IV of the Commission’s recast proposal of the RoHS Directive, COWI A/S. Danish Ministry of Environment, Environmental Project No. 13172010. Authors Maag J, Brandt K, Mikkelsen S, Lassen C. 87 p. DiGangi J, Blum A, Bergman A, de Wit CA, Lucas D, Mortimer D, Schecter A, Scheringer M, Shaw SD, Webster TF (2010). San Antonio statement on brominated and chlorinated flame retardants, Environ Health Perspect 118:516 - 518 DIOXIN 2010. PBDEs and their replacements: Does the benefit justify the harm? Dioxin 2010, 1-6. Authors: Blum, A., Shaw, S. & Birnbaum, L. Desmet K, Schelfaut M, Sandra P. 2005. Determination of bromophenols as dioxin precursors in combustion gases of fire retarded extruded polystyrene by sorptive sampling-capillary gas chromatography-mass spectrometry. J Chromatogr., A 1071(1 2):125–129. Dumler R, Thoma H, Lenoir D, Hutzinger O. 1989. PBDF and PBDD from the combustion of bromine containing flame retarded polymers: a survey. Chemosphere 19(12):2023–2031. ECHA European Chemicals Agency 2008a. Data on manufacture, import, export, uses and releases of HBCDD as well as information on potential alternatives to its use. 108 pp [ECHA] (European Chemicals Agency) 2008b. Member state committee support document for identification of hexabromocyclododecane and all major diastereoisomers as a substance of very high concern. 43 pp. Available at: http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp [ECHA] European Chemicals Agency 2009. Data on Manufacture, Import, Export Uses and Releases of HBCDD as well as Information on Potential Alternatives to Its Use. December 1, 2009. http://echa.europa.eu/doc/consultations/recommendations/tech_reports/tech_rep_hbcdd.pdf [EMPA] Swiss Federal Laboratories for Materials Science and Technology 2010. RoHS substances in mixed plastics from Waste Electrical and Electronic Equipment. Final Report September 17, 2010. Authors: Wäger,P., Schluep, M. and Müller, E. 99 p. [Environment Canada]. Draft Screening Assessment Cyclododecane, 1,2,5,6,9,10-hexabromo- Chemical Abstracts Service Registry Number 3194-55-6. Environment Canada. Health Canada. August 2010a. 114 p. [Environment Canada]. Risk Management Scope for Cyclododecane,1,2,5,6,9,10 – hexabromo- (Hexabromocyclododecane; HBCD). Environment Canada. Health Canada. August 2010b. 12 p. [European Commission] 2008. Risk assessment hexabromocyclododecane, CAS-No.: 25637-99-4, EINECS No.: 247- 148-4, Final Report May 2008. 492 pp. http://ecb.jrc.ec.europa.eu/documents/Existing- Chemicals/RISK_ASSESSMENT/REPORT/hbcddreport044.pdf [Geopartner] GEO Partner AG Resource Management 2007. Dynamic Substance Flow Analysis Model for Selected Brominated Flame Retardants as a Base for Decision Making on Risk Reduction Measures (FABRO). Final report. Authors: Morf, L., Buser, A., Taverna, R. 165 p.
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[HBCD Industry Working Group]. Update on research programmes on alternatives to HBCD for polystyrene insulation foams. Submission to ECHA public consultation (2009) and to UNECE (February 2010) 7 p. Heeb NV, Schweizer WB, Kohler M and Gerecke AC. Structure elucidation of hexabromocyclododecanes - a class of compounds with a complex stereochemistry. Chemosphere 2005; 61: 65-73. [KEMI] Swedish Chemicals Agency 2006. Survey and technical assessment of alternatives to TBBPA and HBCDD. Author: Posner, S. [KEMI] Swedish ChemicalsAgency 2008. Proposal for Harmonised Classification and Labelling Based on the CLP Regulation (EC) No 1272/2008, Annex VI, Part 2. Substance Name: Hexabromocyclododecan. Dossier submitted to the European Commission 2009; 49 pp. [KLIF] Climate and Pollution Agency in Norway. 2010. Exploration of management options for Hexabromocyclododecane (HBCD). 18 August 2010 (updated version). Author: Säll, L. 48 p. Heeb NV, Schweizer WB, Kohler M and Gerecke AC. Structure elucidation of hexabromocyclododecanes - a class of compounds with a complex stereochemistry. Chemosphere 2005; 61: 65-73. INE-SEMARNAT Instituto Nacional de Ecología, Secretaría de Medio Ambiente y Recursos Naturales. Las sustancias tóxicas persistentes en Mexico. Report. Authors: Bremauntz AF,Yarto Ramírez MY, Díaz JC. 2004, 261 pp. [LCSP] Lowell Center For Sustainable Production. An Overview of Alternatives to Tetrabromobisphenol A (TBBPA) and Hexabromocyclododecane (HBCD). Report prepared for The Jennifer Altman Foundation. University of Massachusetts , 2006. Author: Morose G. 32 pp. [NCM] Nordic Council of Ministers. Emission measurements during incineration of waste containing bromine TemaNord. Nordic Council of Ministers 2004:529 0903-7004 Corporate Author: Nordic Council of Ministers. 55 p. [NCM] Nordic Council of Ministers. Hexabromocyclododecane as a possible global POP. Nordic Chemicals Group and Nordic Council of Ministers, Author: Peltola-Thies J. 2008, 91 pp. http://www.norden.org/en/publications/publications/2008-520 Malarvannan, G., Kunisue, T., Isobe, T., Sudaryanto, A., Takahashi, S., Prudente, M., Subramanian, A. & Tanabe, S. 2009. Organohalogen compounds in human breast milk from mothers living in Payatas and Malate, the Philippines: levels, accumulation kinetics and infant health risk. Environ Pollut, 157, 1924-32. OECD Organization for Economic Co-operation and Development. SIDS Initial Assessment Profile for Cas. No. 25637-99-4, 3194-55-6, Hexabromocyclododecane (HBCDD). SIAM 24, 19-20 April 2007. Available from: http://webnet.oecd.org/Hpv/UI/handler.axd?id=ea58ac11-e090-4b24-b281-200ae351686c Polder, A., Venter, B., Skaare, J. U. & Bouwman, H. 2008. Polybrominated diphenyl ethers and HBCD in bird eggs of South Africa. Chemosphere, 73, 148-154. RAC] Committee for Risk Assessment RAC. Opinion proposing harmonised classification and labeling at Community level of hexabromocyclododecane (HBCDD). European Chemicals Agency (ECHA), 2010 RAC] Committee for Risk Assessment RAC. Annex 1. Background Document to the Opinion proposing harmonized classification and labelling at Community level of Hexabromocyclododecane (HBCDD). European Chemicals Agency (ECHA), 2010. [Stec A & Hull R.] Fire toxicity.Woodhead publishing Limited, Oxford. 728 p. ISBN 1 84569 502 X Shaw SD, Blum A, Weber R, Kurunthachalam K, Rich D, Lucas D, Koshland CP, Dobraca D, Hanson S, Birnbaum L (2010) Halogenated flame retardants: Do the fire safety benefits justify the risks? Reviews on Environ Health 25:261 - 305 [SWEREA] Exploration of management options for HBCDD. Report. Authors: Posner S, Roos S, Olsson E. 2010. 84 pp. Tue, N. M., Sudaryanto, A., Tu, B. M., Isobe, T., Takahashi, S., Pham H. V. & Tanabe, S. 2010. Accumulation of polychlorinated biphenyls and brominated flame retardants in breast milk from women living in Vietnamese e-waste recycling sites. Science of The Total Environment, 408, 2155-2162. US EPA US Environmental Protection Agency. Initial Risk-Based Prioritization of High Production Volume Chemicals. Chemical/Category: Hexabromocyclododecane (HBCD). Risk-Based Prioritization Document 3/18/2008 Weil E.D., Levchik, S.V. 2008. Flame Retardants in Commercial Use or Development for Textiles. Journal of Fire Sciences May 2008 vol. 26 no. 3 243-281 27
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Weber R, Kuch B. 2003. Relevance of BFRs and thermal conditions on the formation pathways of brominated and brominated-chlorinated dibenzodioxins and dibenzofurans. Environment International 29: 699 -710. Zhang, X. L., Yang, F. X., Luo, C. H., Wen, S., Zhang, X. & Xu, Y. 2009. Bioaccumulative characteristics of hexabromocyclododecanes in freshwater species from an electronic waste recycling area in China. Chemosphere, 76, 1572-1578.
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Page 16: [1] Comment [A45] Forfatter References:
US EPA. 2006. U.S. Environmental Protection Agency. Toxic Substance Control Act (TSCA) Chemical Substance Inventory. 2006 Inventory Update Rule Public Database. Office of Pollution and Prevention of Toxics: Washington, D.C., 2006.
Hexabromocyclododecane (HBCD) Action Plan, U.S. Environmental Protection Agency 8/18/2010
Page 16: [2] Comment [A46] Forfatter Reference: Hexabromocyclododecane (HBCD) Action Plan, U.S. Environmental Protection Agency 8/18/2010
Page 16: [3] Comment [A47] Forfatter Reference: European Union Risk Assessment Report Volume 17 Bis(Pentabromophenyl)Ether CAS No: 1163-19-5 Einecs No: 214-604-9 Luxembourg Office for Official Publications of the European Communities, 2002
Page 16: [4] Deleted Forfatter It is important to note, that flame-retardant use in textiles can be avoided if the material is non flammable, such as wool. It can also be used as barrier materials in furniture (Norway 2011). 1.
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Types of alternative insulating materials include polyisocyanurate foams, and phenolic foams:[A1] Polyisocyanurate foams include modified urethane foams that utilize chemical flame retardants such as tris monochloropropyl phosphate (TCMPP) and tris chloroethyl phosphate (TCEP). TCMPP is poorly characterized toxicologically but in the TCEP manufacturing process ethylene oxide (a carcinogen) is used, it appears to be a reproductive toxicant, is found in the Arctic indicating long-range transport, and is considered a carcinogen by the California Office of Environmental Health Hazard Assessment. Due to the chlorinated and brominated flame retardants used in the manufacture of polyisocyanurate insulation products, these cannot be considered to be preferable alternatives because of their health effects (LCSP 2006). Phenolic foams are in use in roofing, cavity board, external wall board, and floor insulation. They are mostly used to bind glass fiber to make insulation products. One concern over their use is that formaldehyde, a human carcinogen, is used for making phenolic resins monomer. Formaldehyde is listed by the International Agency for Research on Cancer (IARC) as a known human carcinogen (Morose 2006). This has to be considered at the production sites, using available emission control techniques and safety restrictions securing the workers. Blanket insulation is as much a technical alternative as an alternative material. It is usually made of fiber glass or rock wool and can be fitted between studs, joists, and beams. It is available in widths suited to standard spacings between wall studs or floor joists. Continuous rolls can be hand cut and trimmed to fit various spaces. The blankets are available with or without vapour retardant facings. Batts with special flame resistant facing are available where the insulation will be left exposed. Fiberglass is a synthetic vitreous fiber. Loose-fill insulation is typically blown into place or spray-applied by special equipment. It can be used to fill existing wall cavities and for irregularly shaped areas. Reflective insulation systems include foils, films, or papers that are fitted between studs, joists, and beams and commonly used to prevent downward heat flow in roof applications. Common materials include foil-faced paper, foil-faced polyethylene bubbles, foil-faced plastic film, and foil-faced cardboard. Other commonly used insulation materials include polyester batts and sheep wool which can be fitted between studs, joists, and beams.
Page 17: [6] Comment [A50] Forfatter Move this section to paragraph 2. This may be considered background information and can be used as an introduction to the whole chapter.
Page 17: [7] Moved to page 17 (Move #6) Forfatter 2. The HBCD industry has highlighted the main challenges in the search for alternative flame retardants as the following (BSEF 2011): a. Fire performance of the products with the flame retardant over the complete service life, which needs to meet existing stringent regulations in the relevant countries b. Fit to produce foams without undermining the foam properties. In addition, once found and approved for fire safety and other regulatory requirements, an alternative will have to be transitioned throughout the complex PS insulation foam market c. Consumer safety for the end product, which needs to be similar to HBCD in PS foams d. Environmental profile, which needs to be superior to HBCD. Fit to produce foams without increasing safety risks for workers.
Page 19: [8] Deleted Forfatter Another strategy would be to apply the flame retardancy function through the use of fire resistant coverings or coatings that act as thermal barriers. Thermal barriers are fire resistant coverings or coatings that separate the insulation material from the building interior. These include: gypsum board, gypsum or cement plasters, perlite board, spray-applied cellulose, mineral fiber, or gypsum coatings, and selected types of plywood. All these materials are currently in common use in domestic and commercial building construction (LCSP 2006, SWEREA 2010). Thermal barriers are subject to country-specific building code requirements (SWEREA 2010). 3.
Page 19: [9] Deleted Forfatter By using thermal barriers it is possible to fulfil fire safety requirements in most of the uses in construction and buildings with EPS and XPS without a fire retardant. This has been reported to be an available alternative on the market by Finland, Norway, Sweden and Spain. The national fire safety requirements are achieved by the building codes specifying the different uses of insulation products in buildings and construction, through the use of thermal barriers and hence the use of flame retardant is not required to achieve fire safety even when using EPS/XPS.
Page 19: [10] Deleted Forfatter There are also alternative insulation materials available on the market that meet the fire-safety requirements in many countries facilitating HBCD phase-out for this application. 4.
Page 19: [11] Deleted Forfatter Alternative insulation materials to EPS/ XPS are available for all uses, with the exception of some demanding XPS use in moist or freeze/thaw sensitive applications in North America (XPSA/CPIA 2011).). These alternative insulation systems have different characteristics to XPS and EPS and may be less appropriate for some specific use scenarios or may incorporate different environmental issues such as increased energy costs during transportation (ECHA 2009). Alternatives to HBCD 5.
Page 19: [12] Moved to page 17 (Move #12) Forfatter Brominated chemicals other than HBCD are commercially available as flame retardants for use in EPS applications in North America. 6.
Page 19: [13] Moved to page 17 (Move #13) Forfatter These are tetrabromocyclooctane and dibromoethyldibromo-cyclohexane (LSCP 2006, BSEF 2011). 7. Page 19: [14] Moved to page 17 (Move #14) Forfatter There are also concerns about the environmental or health properties of these substances: 8.
Page 19: [15] Moved to page 17 (Move #15) Forfatter Tetrabromocyclooctane is structurally related to tetrabromocyclohexane which was identified in modelling studies as structurally similar to known Arctic contaminants and/or have partitioning properties that suggest that it is a potential Arctic contaminant. 9.
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Dibromoethyldibromo-cyclohexane is found in beluga whales in the Arctic; modelling studies identify it as likely to be persistent and bioaccumulative; and it was found to be a strong androgen agonist and mutagenic to mammalian cells in vitro.
Page 19: [17] Moved to page 17 (Move #16) Forfatter The Japanese EPS industry is aiming at replacing HBCD in the production processes by the end of 2012 and also the industry producing XPS is working towards reduction in HBCD use by reconsidering HBCD content but also the need for HBCD in the product (Japan 2011). Interestingly, the European industry appears to use higher amounts of HBCD than North American producers to meet the fire safety requirements 10.
Page 19: [18] Moved to page 14 (Move #4) Forfatter The first consideration would be to eliminate use of HBCD and other flame retardants in cases where no fire hazard exists. 11.
Page 19: [19] Moved to page 19 (Move #8) Forfatter 12. These uses include placement of insulation between two non-combustible wall surfaces such as stone or concrete and uses where insulation is placed between building foundations and soil. These design changes could be implemented by the end-product manufacturer (LCSP 2006). 13. Another strategy would be to apply the flame retardancy function through the use of fire resistant coverings or coatings that act as thermal barriers. Thermal barriers are fire resistant coverings or coatings that separate the insulation material from the building interior. These include: gypsum board, gypsum or cement plasters, perlite board, spray-applied cellulose, mineral fiber, or gypsum coatings, and selected types of plywood. All these materials are currently in common use in domestic and commercial building construction (LCSP 2006, SWEREA 2010). Thermal barriers are subject to country-specific building code requirements (SWEREA 2010). 14. By using thermal barriers it is possible to fulfil fire safety requirements in most of the uses in construction and buildings with EPS and XPS without a fire retardant. This has been reported to be an available alternative on the market by Finland, Norway, Sweden and Spain. The national fire safety requirements are achieved by the building codes specifying the different uses of insulation products in buildings and construction, through the use of thermal barriers and hence the use of flame retardant is not required to achieve fire safety even when using EPS/XPS.
Page 19: [20] Deleted Forfatter Alternatives to EPS/XPS Flame retarded expanded and extruded polystyrene foam (EPS and XPS) used for building insulation can also be replaced by alternative materials. This is a more complex approach than simple flame retardant substitution because it has a greater effect on overall product cost and performance. This change could be implemented by the polymer processor/compounder or the end-product manufacturer (LCSP 2006).
Page 19: [21] Moved to page 18 (Move #7) Forfatter Technical alternatives to HBCD containing EPS/ XPS include: blown-in or spray-applied insulation materials such as rock wool, fiber glass, cellulose, or polyurethane foam. Loose-fill cellulose insulation is commonly manufactured from recycled newsprint, cardboard, or other forms of waste paper. The blown-in loose-fill insulation can provide additional resistance to air infiltration if the insulation is sufficiently dense. Loose-fill insulation can also be poured in place by using materials such as vermiculite or perlite. These materials are produced by expanding naturally occurring minerals in a furnace (LCSP 2006).
Page 19: [22] Deleted Forfatter occurring minerals in a furnace (LCSP 2006). When alternative building insulation materials or EPS and XPS without flame retardants are used the necessary flame protection can be provided by use of a thermal barrier. Thermal barriers are fire resistant coverings or coatings that separate the insulation material from the building interior. Thermal barriers can be used to increase the fire retardant performance for various types of insulation. Thermal barriers are subject to current building code requirements. Commonly used thermal barriers include: gypsum board, gypsum or cement plasters, perlite board, spray-applied cellulose, mineral fiber, or gypsum coatings, and select plywood’s. By using thermal barriers it is possible to fulfil fire safety requirements in most of the uses in construction and building applications using EPS and XPS without a flame retardant. This has been reported to be an available alternative on the market by Norway, Sweden and Spain (SWEREA 2010).
Page 19: [23] Moved to page 20 (Move #9) Forfatter Fiberglass, glass wool, and mineral wool are considered synthetic vitreous fibers. They also may have occupational health effects. When these fibers are suspended in air they can cause irritation of the eyes, nose, throat, and parts of the lung. Animal studies show that repeatedly breathing air containing synthetic vitreous fibers can lead to inflammation and fibrosis of the lung. (ATSDR 2004). Protective clothing and equipment (face masks, goggles, gloves etc.) is available and used by construction workers to avoid irritations from contact and breathing in the fibres. This will only be of importance in the working environment, since the fibrous material is built inside the wall, foundation and ceilings in the buildings and constructions.
Page 21: [24] Comment [A64] Forfatter This is only true for one application: Frost protected Shallow Foundations (FPSF), and the building code does not require the use of HBCD, as the flame retardant in the XPS. Since the use is underground in especially cold and harsh climates, the fire safety requirements is less than for other applications.
Ref: “The Environmental and Societal Value of Extruded Polystyrene Foam Insulation”, Barbara A. Fabian et al, Earth Technology Forum, Washington, April 27, 2004. Available at: http://www.xpsa.com/enviro/PDFs/Fabian_Hoffee_Herrenbruck_Earthtech_2004.pdf
Page 21: [25] Comment [A65] Forfatter Move to 2.3 about alternatives.
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http://www.bsef.com/our-substances/hbcd/voluntary-emissions-reduction-programme-vecap-and-secure http://www.vecap.info/
Page 23: [27] Deleted Forfatter 3.1 Summary of risk profile information The commercially available brominated flame retardant hexabromocyclododecane (HBCD) is lipophilic, has a high affinity to particulate matter and low water solubility. Depending on the manufacturer and the production method used, technical HBCD consists of 70-95% γ-HBCD and 3-30 % of α- and β-HBCD. HBCD is used as a flame retardant additive in polystyrene and textile products. Its main use is in the production of expanded and extruded polystyrene (EPS and XPS). It is also used in the production of high impact polystyrene (HIPS) and as a textile coating. HBCD is reported to be produced in the United States of America, Europe, and Asia. Approximately half of the market volume is used in Europe. In biota, HBCD has been found to bioconcentrate, bioaccumulate and to biomagnify at higher trophic levels. High concentrations have been identified in Europe and Japan and in coastal waters of south China, near production sites of HBCD, manufacturing sites of products containing HBCD and waste disposal sites including those whose processes include either recycling, landfilling or incineration. HBCD is persistent in the air and is subject to long-range transport. HBCD is found to be widespread in remote regions such as the Arctic, where concentrations in the atmosphere and top predators are elevated. HBCD is very toxic to aquatic organisms. In mammals, studies have shown reproductive, developmental and behavioural effects. Recent advances in the knowledge of HBCD-induced toxicity includes a better understanding of the potential of HBCD to interfere with the hypothalamic-pituitary-thyroid (HPT) axis, its potential ability to disrupt normal development, and to affect the central nervous system. In humans HBCD is found in blood, plasma and adipose tissue. Human breast milk data from the 1970s to 2000 show that HBCD levels have increased since HBCD was commercially introduced as a brominated flame retardant in the 1980s. 15.
Page 23: [28] Comment [A76] Forfatter The conclusion is stated in the beginning of this document and relevant information from the risk profile is included elsewhere.
Page 23: [29] Comment [A77] Forfatter Please incorporate the main points resulting from new information provided and other changes in the previous chapters. So that this part coheres more with the information in the document, and makes the back ground for the conclusion more transparent.