BSEF newsletter D-dorf inpo

18.10.2001

18:36 Uhr

Page 1

Bromine bulletin

From the Brominated Flame Retardant Industry

Bromine
bulletin

October 2001

A summary of
BSEFs newsletters

Statements About Brominated Flame Retardants

European Commission and OECD

University of Surrey (U.K.)

Orango miljkonsulter AB (Sweden)

modern incinerators do not form

brominated dioxins and furans at high
rates.

None of the available data give any

indication of toxic risk from the use
of deca-BDE in consumer products.

Industry may be under pressure to

replace all types of BFR, even though
some of them may prove to have less
environmental load than the emerging
alternatives, e.g. phosphate esters.

Swedish Fire Testing Institute (SP)

University of Surrey (U.K.)

Based on experimental data, the

presence of the flame retardants do
not prevent plastic recycling.

benefits of many flame retardants

outweigh the risks to human health.

Swedish Fire Testing Institute (SP)

the original postulate that it would
be better to allow things to burn more
often rather than use flame retardants,
is questionable. There is still ample
evidence that the avoidance of large
numbers of fires is important from an
environmental point of view.
Dutch National Institute for Public
Health (RIVM)
no concern about potential emissions
of dibenzodioxins and furans from the
incineration of plastics containing
bromine.

EU Human Risk Assessment of

deca-BDE
consumer exposure is likely to be
negligible, with no resulting risk to
the consumer.
European Commission
EU Risk Assessment preliminary results
of the penta-, octa- and deca-BDE
indicate no need for risk reduction
measures for deca-BDE and octa-BDE.
Penta-BDE is being considered for
classification as dangerous to the
environment.

EU Risk Assessment citing MPI

Research (USA)
a prenatal developmental toxicity
study of deca-BDE conducted under
Good Laboratory Practices reveals
no endocrine disruption effects.

Orango milj konsulter AB (Sweden)

There is little basis, from an environmental perspective, to prohibit the use
of all halogenated flame retardants.

Orango miljkonsulter AB (Sweden)

Industry may be under pressure to
replace all types of BFR, even though
some of them may prove to have less
environmental load than the emerging
alternatives, e.g. phosphateesters.

EU Commission, Environment
Commissioner
National Research Council (USA)
overestimating risks from flame
retardants might result in a net adverse
effect on public health.

emissions of the flame retardants in

the incineration processes will be
near zero.

deca-BDE is not responsible for

a bio-accumulation in the aquatic
environment.

Impact on fire safety

he Directive proposals relating to
Waste Electrical and Electronic
Appliances (WEEE) and Restriction
of Hazardous Substances (RoHS) will
have a major impact on the use of
Brominated Flame Retardants (BFRs)
and therefore on the protection of
European citizens against fire in electrical
appliances. As BFRs are the most
efficient flame retardants, they are
often the best practical option to meet
the highest levels of fire safety.

no health risks from dermal, inhalation,

oral and dermal contact of deca-BDE
in upholstered furniture.

modern incinerators do not form

brominated dioxins and furans at
high rates.

Please do not hesitate to contact us for further details.

BSEF - Secretariat 118 Avenue de Cortenbergh B - 1000 Brussels

Tel. +32 2 733 93 70 Fax: +32 2 735 6063 mail@bsef.com www.firesafety.org www.bsef.com

who, in their blind pursuit of chemicals,

evidently view plastics fire safety as an
overrated issue.

Brominated flame retardants help meet

the highest levels of fire safety. This is
what the public expects. Europe has
only minimum standards of fire safety,
lower than in the United States.
From the early 1990s onwards, under
pressure from environmental campaigners, TV manufacturers started to no
longer use flame retardants in TV set
casings in Europe: TV sets now burn 100
times more frequently in Europe than in
the US.

1,860 lives have been saved over 10

years in the UK alone with the introduction of the use of FRs in furniture. A
Europe without flame retardants would
therefore see a massive increase in
deaths due to fires in the home and
workplace, where flame retardants are
a real necessity in TVs, toasters, computers and many other electrical appliances.

Impact on Fire safety

This issue would like to set the record

straight on the major issues of misunderstanding and false assumptions put
forward by Greenpeace and the EEB

Brominated flame retardants are by far

the most effective flame retardant
available today. They are used in a wide
variety of electrical appliances and
are there solely to prevent fire.

National Research Council (USA)

European Commission and OECD

Ministry of Trade and Industry
(Japan), cited by the Project Group
Flame Retardants in the Netherlands

October 2001

The WEEE and RoHS proposals are

crucial for fire safety. Indeed, the
application of the precautionary principle
can lead only to the continued use of
brominated flame retardants.
Phasing out the major flame retardants
for electronic products would have
major consequences for the protection
of European citizens against fire. It will
be for EU Council and the Parliament to
assess the real danger of loss of life,
compared with the alleged risk for the
environment.

Looking at the science

Bromine is safe

In the environment: only penta-BDE

Breast milk: only penta-BDE

There is no scientific justification for

phasing out all brominated flame retardants (BFRs). BFRs, which are part of the
halogenated flame retardants group,
represent a category of 75 flame retardants each with differing structures and
properties. The only thing each has in
common is the presence of bromine
which is not in itself an environmental
toxin and is used in cough mixture 1.

Only one out of 75 BFRs is widely found

in the environment, and this at declining
levels. This is penta-BDE for which an EU
risk assessment has been completed,
leading to a proposal for phase-out
in 2003.

Penta-BDE is also the only BFR

found in breast milk. There is no
health risk. Levels are reported now
to be decreasing and the highest
levels found were 15,000 times
lower than those expected to be a
risk to children. Again, penta-BDE
is in any case being phased-out.

The industry fully accepts the proposed

phase-out of penta-BDE, as it is based
on a comprehensive risk assessment.

BSEF - Secretariat 118 Avenue de Cortenbergh B - 1000 Brussels

Tel. +32 2 733 93 70 Fax: +32 2 735 6063 mail@bsef.com www.firesafety.org www.bsef.com

BSEF newsletter D-dorf inpo

18.10.2001

18:36 Uhr

Page 2

October 2001

Bromine bulletin

Not endocrine disrupting

BFRs and workers health

Debromination

The evidence indicates that BFRs are

not endocrine-disrupting chemicals.
This has been already confirmed under
the EU risk assessment for deca-BDE.
Tests on another BFR, TBBPA, indicated
that initial results of concern could
not be repeated. TBBPA is also being
risk assessed under the EU risk assessment process.

Only 1 out of 75 BFRs has been traced

in one recycling plants workers. The
levels are 20,000 times below levels of
potential health concern and the substance does not persist in the body. The
trade unions, the recycling company
and the bromine industry are cooperating in assessing the facts.

The theory that octa-BDE and decaBDE could debrominate (degrade down
to form penta-BDE) is now being
assessed under the EU risk assessment.
Results will be available in September
2001.
Fewer toxic gases produced
Flame retardant materials burn less,
producing just a third of the toxic gases
and a quarter of the heat of unprotected
appliances2. Concerns over dioxin and
furan formation during incineration have
been addressed by the advanced incinerator technology now available and
required under EU legislation.

By contrast, PBB, which ceased production in May 2000, is the only BFR
referred to in an initial Commission
list of potential endocrine disrupting
chemicals.
Not bioaccumulating
Octa-BDE and deca-BDE are not classified as dangerous substances and are
not bioaccumulative in other words
they do not stay and accrue in the
human body. PBBs have been found to
be highly bioaccumulative and industry
has ceased their production.

Brominated flame retardants (BFRs) are

necessary for certain plastics to meet
the highest levels of fire safety. The
long experience with BFRs and their
continued evolution and use, means
that plastics containing brominated
flame retardants will be part of the
waste flow, in particular that of
WEEE. The EU should encourage this
waste to be recycled and recovered
rather than enforcing its disposal
through regulatory bans.
BFRs can be and are
already recycled
Certain plastics/BFR combinations are
actually already being specified by
leading manufacturers of photocopiers,
in part because of their comparative
stability in the recycling process.
Recycling is already taking place with

increased by the presence of the

bromine-containing waste, and remains
well below emission limit values in these
processes. The OECD and the European
Commission came to the same conclusions6.

Energy recovery
Incineration tests, pyrolysis and combustion studies have demonstrated
that waste from E&E equipment can
be safely added to todays municipal
solid waste to generate useful energy in an environmentally sound manner.
The formation of dioxins/ furans is not

Fully Compatible
with Metal Recycling
Tests by the metals industry have
shown that the presence of brominated flame retardants does not hinder
the recycling of electronic waste in
metal smelters.

Closing the bromine loop

The presence of plastics containing
brominated flame retardants in the
waste stream provides economic
actors with a wide variety of environmentally sound and economically feasible options for waste recovery and
recycling, instead of simple disposal.
A number of products could be made
from recycling the bromine itself,
including photo-chemicals, swimming
pool disinfectants and, of course,
flame retardants.

What about alternatives

BFRs are not POPs

Emissions insignificant
from electronic equipment
EU risk assessments have concluded
that emissions during production, use
and recycling are insignificant for health
and the environment.

Despite the misleading accusations of

some lobbyists such as Greenpeace,
BFRs do not appear on the list of the
most dangerous Persistent Organic
Pollutants to be phased-out under a
UNEP Convention.

Recycling
Combining fire safety and
recyclability

tics. The bromine industry is working

with recyclers to ensure that worker
exposure to BFRs is minimised
through implementation of standard
safety techniques.

30% of some new copiers containing

recycled plastic with brominated flame
retardants3. This is feasible for large
appliances in a closed loop of ownership and would not be helped by the
required separation of all plastics containing BFRs. The proposed inclusion
of plastics containing BFRs in Annex
II of the WEEE Directive thus represents an unjustified stigma against
these materials.

Consequently, amendments requesting a separation of BFRs on the false

basis that recyclability would be
undermined are completely unjustified.

higher quantities often required

In order to achieve the same level of
fire protection compared to brominated flame retardants, higher quantities of alternative flame retardants
often need to be used. Nonetheless,
there are practical limits how much
flame retardant can be added to a
material before it unduly affects the
materials integrity and strength. In
essence, Greenpeace and EEB are
actually advocating increased use of
flame retardant volumes by calling
for a ban on the most efficient flame
retardants.
Alternatives: not always available

Plastics with BFRs:

superior recyclability
Several studies, such as the recent
one by Techno Polymer in Japan,
concluded that ABS plastics containing
BFRs was superior to other plastics in
terms of recyclability4. Indeed plastics
containing BFRs can be recycled five
times in full compliance with the strict
dioxin/furan emission limit values of
the German Dioxin Ordinance, the
strictest legislation in the world 5.

Alternatives:

Photocopier with 30% recycled plastic (Ricoh, Japan)

Full compliance with worker health

and safety legislation
All tests show that workers are not
exposed to elevated levels of BFRs in
the course of recycling WEEE plas-

In certain plastics like HIPS, ABS and

PBT, there are currently no effective
alternative flame retardants which
can meet even minimum fire safety
standards while maintaining good
mechanical properties. Environmental
NGOs are not experts in fire safety.
Who will be responsible if alternatives do not work? Imagine the
response to a citizens complaint,
but Greenpeace assured us there
were fire safety alternatives.
Alternatives: less well understood
By comparison to detailed studies of
brominated flame retardants in the
last 10 years, the toxicology and
environmental effects of alternative

flame retardants are relatively poorly

understood. Indeed, no flame retardants have been more thoroughly
tested than brominated flame retardants. What if alternatives are moreharmful to the environment and
health than BFRs ?
BFRs are being risk assessed
The EU risk assessment process wasdesigned to provide the regulator
with a scientific process by which to
assess the need for risk reduction
measures concerning individual chemical
substances. Being science-based, it
takes time to amass and analyse the
scientific data. It is therefore fortunate that the WEEE & RoHS
Directives come at time when one of
the major groups of BFRs the 3
PBDEs flame retardants is soon to
be the subject of finalised conclusions under the EU risk assessment
process. While finalised conclusions
are expected for September 2001,

preliminary conclusions indicate that

there is no need for risk reduction
measures as concerns the main
PBDEs used in E&E applications,
deca-BDE and octa-BDE.
Concerns related primarily to the
presence of one PBDE flame retardant
in the environment and in biota,
penta-BDE, have been taken into
account, and penta-BDE will be subject
to a phase-out.
1Orango Milj Konsulter, Brominated Flame Retardants,
- a Global Status Report, press release March 2001.
2SP Swedish Testing and Research Institute,
Testing and Research (P&F), No 1 1999.
3 A practical study to compare recyclability between non-halogen PC/ABS (HIPS) alloy and FR-ABS flame retarded by brominated epoxy oligomer, Takateru Imai, Techno Polymer Co. Ltd.
4 Studies led by Dr. S. Hamm GfA (Gesellschaft fr Arbeitsplatzund Umweltanalytik) mbH, September 1999.
5 "Ideal Resin Reclaiming Process Learned from Office
Automation (OA) Equipment", Nikkei Mechanical, no. 542,
November 1999.
6 Techno-Economic Study on the Reduction of Industrial
Emissions to Air, Discharges to Water and the Generation of
Wastes from the Production Processing and Destruction (by
incineration) of BFRs ISBN 92-827-5577-0, European
Commission, 1995

BSEF - Secretariat 118 Avenue de Cortenbergh B - 1000 Brussels

Tel. +32 2 733 93 70 Fax: +32 2 735 6063 mail@bsef.com www.firesafety.org www.bsef.com