Hexabromocyclododecane

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Hexabromocyclododecane 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 ............................................................................................................................................................... 4 1.1 Chemical identity of the proposed substance .................................................................................................. 4 1.2. Conclusions of the Review Committee regarding Annex E information .................................................. 6 1.3. Data sources ................................................................................................................................................ 6 1.4. Status of the chemical under international conventions ............................................................................. 8 1.5. Any national or regional control actions taken ........................................................................................... 8 2. Summary information relevant to the risk management evaluation ........................................................................ 9 2.1. Identification of possible control measures ................................................................................................ 9 2.2. Efficacy and efficiency of possible control measures in meeting risk reduction goals ........................... 10 2.3. Information on alternatives (products and processes) where relevant ..................................................... 11 2.3.1 Production of high impact polystyrene (HIPS) plastic ............................................................... 1313 2.3.2 Production of flame retarded textile back-coating .......................................................................... 13 2.3.3 Production of flame retarded expanded and extruded polystyrene (EPS/XPS) ........................ 13 2.4. Summary of information on impacts on society of implementing possible control measures................ 15 2.4.1. Health, including public, environmental and occupational health ............................................ 15 2.4.2 Biota (biodiversity) ..................................................................................................................... 16 2.4.3 Economic aspects, including costs and benefits for producers and consumers and the distribution of costs and benefits .................................................................................................................................. 16 2.5. Other considerations .................................................................................................................................. 18 3. Synthesis of information ..................................................................................................................................... 1918 3.1 Summary of risk profile information ......................................................................................................... 1918 3.2 Summary of risk management evaluation information ................................................................................. 19 3.3 Suggested risk management measures ...................................................................................................... 2019 4. Concluding statement .............................................................................................................................................. 20 References .......................................................................................................................................................................... 21 2 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 (HELCOM) has included HBCD in the list of priority hazardous substances. 3. HBCD is produced 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 in Europe and the US). The main share of the market volume is used in Europe although there is uncertainty regarding more recent use with available information suggesting that use of HBCD may be rising (ECHA 2008a). 4. HBCD has been on the world market since the 1960s. It is used as a flame retardant additive, 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. The main uses of HBCD are in flame-retarded expanded (EPS) and extruded (XPS) polystyrene foam insulation, with smaller scale use in textile applications and electric and electronic appliances (high impact polystyrene/HIPS). In textiles HBCD is used in back-coatings for upholstery and other interior textiles, including automotive applications. The volumes of HBCD flame retarded articles imported and exported globally is generally unknown. 5. Release of HBCD into the environment may occur 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. The European industry has since 2008 taken actions to substantially reduce HBCD emissions from HBCD production and first line use. 6. Emissions of HBCD can be reduced in production of HBCD, in processes where HBCD or articles containing HBCD are used, and during the waste management phase. Emission control techniques at the production sites alone will not be efficient in solving the problem HBCD is posing for the environment and health, since there are diffuse emissions and releases to the water reserves and sewage systems from products containing HBCD. Wastes containing HBCD represent a large source of releases and 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 suggests that HBCD emissions are likely to continue in the future from the installed amount of materials containing HBCD. 7. A number of alternative chemical fire retardants are available to replace HBCD in high-impact polystyrene (HIPS) and textile back-coating. However, there appear to be no drop-in chemical alternatives for flame-retarded EPS/XPS products in all regions. In the USA an alternative chemical flame retardant is used in the production of EPS, but not in Europe. 8. Many Some countries have set standards for building materials with regards to their contribution to fire. Consequently, inherently flammable materials must be treated with a flame retardant to meet certain fire performance criteria, which are required in the country regulations for a specific use. In someHowever, in other 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. HBCD phase-out could include flame retardant substitution, resin/material substitution and product redesign. 9. 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 detailed conditions for HBCD production and uses. Stockpiles and waste containing HBCD would be subject to the waste provisions in Article 6. 3 Persistent Organic Pollutants Review Committee 1. Introduction 10. 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 11. 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
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