Kemenperin Final Report PBDE - UPOP

REDUCING RELEASES OF
POLYBROMODIPHENYL ETHERS (PBDEs) AND

UNINTENTIONAL PERSISTENT ORGANIC
POLLUTANTS (UPOPs) ORIGINATING FROM THE
UNSOUND WASTE MANAGEMENT AND
RECYCLING PRACTICES AND THE
MANUFACTURING OF PLASTICS IN INDONESIA
MINISTRY OF INDUSTRY
INDUSTRIAL RESEARCH AND DEVELOPMENT AGENCY
2018
Foreword
This report is the responsibility of the compiler as the Senior Specialist for the Report
Compilation under PBDEs-UPOPs Project in accordance with the contract with UNDP
No: UNDP IC/403/2017. Its contents are summaries of activity reports or studies
conducted by eight institutions that handle collaborative activities between UNDP and
the Ministry of Industry, in a project entitled "Reducing Releases of Polybromodiphenyl
Ethers (PBDEs) and Unintentional Persistent Organic Pollutants (UPOPs) Originating
from Unsound Waste Management and Recycling Practices and the Manufacturing of
Plastics in Indonesia". The eight institutions referred to are: Center for Chemistry and
Packaging (BBKK); Central for Material and Technical Products (B4T); Polymer
Technology Center (BPT-BPPT); Universitas Indonesia (UI); Tirtayasa University
(UNTIRTA); Bandung Institute of Technology ((ITB), Sepuluh Nopember Institute of
Technology (ITS); and University of Surabaya (UBAYA).
The output of these activities is grouped into four components, each of which is carried
out by the eight institutions in accordance with their competencies, as follows:
Component 1: Strengthening the national policy and regulatory framework to reduce
UPOPs and PBDE releases from plastics manufacturing, recycling, and
disposal practices
Component 2: Reducing or eliminating the importation and use of PBDE in plastics
manufacturing
Component 3: Reducing UPOPs and PBDEs from Unsound Plastics Recycling
Component 4: Reducing releases of UPOPs and PBDEs from unsound plastics disposal
practices
In an effort to summarize some of the results of the study and the submission of
recommendations, the compilers experienced various obstacles and limitations, but
thanks to the help of various parties, Alhamdulillah this report can be completed
according to the planned time. In particular, thank you, the compiler, conveyed to: Mr.
Dr. Ir. Ngakan Timur Antara, MSc - Head of Industrial Research and Development
Agency - Ministry of Industry, along with staff.
It is realized that in this Report there are still shortcomings and errors, and for this
reason the compilers expect input and criticism that can further improve this Report.
Jakarta, 2017
Ministry of Industry
i
Contents
Foreword ........................................................................................................................... i
Contents ............................................................................................................................ ii
List of Tables .................................................................................................................. vii
List of Figures ............................................................................................................... viii
1 INTRODUCTION .......................................................................................................1
1.1 THE PRESENT CONDITIONS IN INDONESIA .................................................. 3
1.1.1 Institution and Regulations Related to Handling of PBDEs ............................. 3
1.1.2 Plastic Manufacturing Industry ......................................................................... 4
1.1.3 Plastic Recyling Industry .................................................................................. 4
1.1.4 Disposal of Plastic Waste .................................................................................. 5
1.2 EXPECTED CONDITIONS AND ITS EFFORTS .................................................. 6
1.2.1 Strengthening Policies and Regulations for Reducing UPOPs and PBDEs...... 7
1.2.2 Reduced Imports and Use of PBDEs in the Plastic Industry ............................ 8
1.2.3 Reduced UPOPs and PBDEs from the Plastic Recycling Industry ................... 8
1.2.4 Reduced release of UPOPs and PBDEs from Plastic Waste Disposal .............. 9
1.3 OBSTACLES FACED ............................................................................................. 9
1.4 ACTIVITIES DONE THROUGH UNDP ASSISTANCE ..................................... 10
2 POPs, PBDEs, AND INDUSTRIES THAT USE IT .................................................14
2.1 PERSISTENT ORGANIC POLLUTANTS (POPs) AND POLYBROMINATED
DIPHENYL ETHERS (PBDEs) .......................................................................... 14
2.2 PBDEs AS FLAME RETARDANT AND ALTERNATIVE SUBSTITUTES ...... 17
2.2.1 PBDEs as Flame Retardant ............................................................................. 17
2.2.2 Alternative Subtitutes of PBDEs as Flame Retardant ..................................... 19
2.3 EXPOSURE ROUTES, IMPACTS OF HEALTH, ENVIRONMENT AND
GENDER .............................................................................................................. 24
2.3.1 Exposure Routes and Health Impacts.............................................................. 24
2.3.2 Impact on the Environment ............................................................................. 26
2.3.3 Impacts on Gender .......................................................................................... 26
2.4 PRODUCTS CONTAINING PBDEs .................................................................... 28
3 STRENGTHENING THE NATIONAL POLICY AND REGULATORY
ii
FRAMEWORK TO REDUCE UPOPs AND PBDEs RELEASES FROM PLASTIC
MANUFACTURING, RECYCLING, AND DISPOSAL PRACTICES ........................ 32
3.1 POLICIES AND REGULATION OF PBDEs IN SEVERAL REGIONS ..............32
3.1.1 European Initiatives .........................................................................................33
3.1.2 American Initiatives .........................................................................................34
3.1.3 Asian Initiatives ...............................................................................................36
3.1.4 International Policy ..........................................................................................36
3.2 LIMITATION OF PBDEs THROUGH RoHS REGULATION .............................38
3.2.1 RoHS Directive 2002/95/EC (RoHS1) ............................................................38
3.2.2 RoHS Directive 2011/65/EU (RoHS2) ............................................................40
3.2.3 Implementation of RoHS Regulations in Several Countries ...........................43
3.3 ANALYSIS ON THE IMPLEMENTATION OF REGULATORY OF RoHS IN
INDONESIA .........................................................................................................47
3.3.1 International Standards and Indonesian National Standards............................48
3.3.2 Readiness of Internal Conformity Assessment Institution ...............................49
3.3.3 Study of RSNI in the Context of Restricting the Use of PBDEs .....................51
3.4 ROADMAP STUDY ON PBDEs IN INDONESIA ...............................................52
3.4.1 Literature Study and Survey on the PBDEs Roadmap ....................................52
3.4.2 Draft of PBDEs Roadmap in Indonesia ...........................................................53
3.5 EXTENDED PRODUCER RESPONSIBILITY (EPR) CONCEPT
DEVELOPED .......................................................................................................54
3.5.1 Regulation Related to EPR ..............................................................................55
3.5.2 Stakeholders, Scenarios and Financing Schemes ............................................55
3.5.3 Draft Agreement ...............................................................................................57
3.6 MONITORING AND CONTROL OF MATERIALS OF POPs ............................58
3.6.1 POPs and their Law Enforcement Instruments ................................................58
3.6.2 Integrated Monitoring and Control Strategy ....................................................59
3.6.3 Supervisory Teams ...........................................................................................62
3.6.4 Encouraging Industries to Use PBDEs Substitution ........................................62
4 REDUCING OR ELIMINATING THE IMPORTATION AND USE OF PBDEs in
PLASTIC MANUFACTURING ..................................................................................... 64
4.1 SUPPLY-DEMAND AND SUPPLY CHAINS FOR PRODUCTS
CONTAINING FLAME RETARDANT ..............................................................64
4.1.1 Polypropylene (PP) ..........................................................................................65
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4.1.2 Polyethylene (PE) ............................................................................................ 65
4.1.3 Polyurethane (PU) ........................................................................................... 69
4.1.4 Polyethylene Terephthalate (PET)................................................................... 70
4.1.5 High Impact Polystyrene (HIPS)..................................................................... 70
4.2 ALTERNATIVE PBDEs RESEARCH IN ACCORDANCE WITH THE
PRODUCTION PROCESS APPLIED IN INDONESIA..................................... 71
4.3 TESTING RESULTS OF PBDEs CONTENTS IN ELECTRONIC,
AUTOMOTIVE AND RESIN PRODUCTS ....................................................... 75
4.4 IMPLEMENTATION OF FREE PBDEs LABELING FOR PLASTIC-BASED
PRODUCTS IN SEVERAL COUNTRIES AND ITS DESIGNS IN
INDONESIA ........................................................................................................ 77
4.4.1 CE Marking in European Union (EU)............................................................. 77
4.4.2 Labeling scheme in several countries.............................................................. 78
4.4.3 RoHS Marking Design in Indonesia ............................................................... 81
5 REDUCING UPOPs AND PBDEs FROM UNSOUND PLASTIC RECYCLING .82
5.1 PLASTIC RECYCLERS AND PRODUCT RECYCLE USERS MAPPING IN
INDONESIA ........................................................................................................ 82
5.2 GOOD MANUFACTURING PRACTICE (GMP) ON RECYLED PRODUCTS
CONTAINING PBDEs ........................................................................................ 86
5.2.1 Quality Assurance ........................................................................................... 87
5.2.2 Factory Standard ............................................................................................. 89
5.2.3 Quality Control System ................................................................................... 90
5.2.4 Waste Control .................................................................................................. 90
5.2.5 Transport, Storage, and Distribution ............................................................... 91
5.2.6 Traceability ...................................................................................................... 91
5.2.7 Documentation ................................................................................................ 91
5.2.8 Labeling System .............................................................................................. 92
5.3 BAT/BEP Guidelines Development Assesment on Plastic Recycling Activities ... 92
5.4 Dioxin Formation and Test Results in Plastic Recycling Locations ...................... 95
5.4.1 The formation of Dioxin ................................................................................. 95
5.4.2 Sampling and Test Results .............................................................................. 97
5.5 MINI DEPO DESIGN FOR PLASTIC RECYCLING ........................................ 100
5.5.1 Survey Results ............................................................................................... 100
5.5.2 Design of Mini Depo ..................................................................................... 101
6 REDUCING RELEASES OF UPOPs AND PBDEs FROM UNSOUND OF
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PLASTIC DISPOSAL PRACTICES ............................................................................ 104
6.1 Mapping of Plastic Waste Containing PBDEs ......................................................104
6.1.1 Distribution of respondents per area ..............................................................104
6.1.2 Respondent Profiles .......................................................................................105
6.1.3 Types and volumes of waste collected ...........................................................106
6.1.4 Collecting Process and Continuing Treatments .............................................107
6.1.5 Waste Distribution ..........................................................................................107
6.1.6 Knowledge of PDBEs ....................................................................................108
6.2 ROAD MAP ON PLASTIC WASTE CONTAINING PBDEs MANAGEMENT109
6.3 INVENTORY SYSTEM CONCERNING PBDEs PLASTIC WASTE................ 116
6.4 ENVIRONMENTAL EDUCATION MODULE CONCERNING
ENVIROMENTAL AWARENESS ..................................................................... 117
6.4.1 Syllabus of Module 1 ..................................................................................... 117
6.4.2 Syllabus of Module 2 ..................................................................................... 119
6.5 MINI DEPO DESIGN FOR PLASTIC DISPOSAL ............................................123
6.5.1 Definition and Function .................................................................................123
6.5.2 Operational Concept ......................................................................................123
6.5.3 Technical Concepts ........................................................................................126
6.6 GUIDELINES FOR MONITORING PLASTIC INDUSTRIAL WASTE
CONTAINING PBDEs .......................................................................................127
6.6.1 Recycled Plastics............................................................................................127
6.6.2 Plastic Recycling Process...............................................................................128
6.6.3 Monitoring Preparation ..................................................................................129
7 ANALYSIS AND SUGGESTIONS/ RECOMMENDATIONS ............................. 131
7.1 INCREASING AWARNESS AND CARE ON THE DANGER OF PBDEs
AND UPOPs .......................................................................................................131
7.1.1 The Availability of Data and Information about PBDEs and UPOPs ............131
7.1.2 Availability of several Activity Packages that are Ready to Implement ........132
7.1.3 Availability of Government Funds and Assistance ........................................132
7.2 STRENGTHENING THE ABILITY OF GOVERNMENT INSTITUTIONS IN
CONTROL OF PBDEs AND UPOPs OF PLASTIC INDUSTRIES .................133
7.3 PUBLISHED REGULATION RELATED TO PBDEs .........................................134
7.3.1 National Level Regulations ............................................................................134
7.3.2 Regulation in Regional Levels .......................................................................136
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7.4 REDUCING OF USE AND EXPOSURE OF PBDEs IN PLASTIC
MANUFACTURING INDUSTRIES, RECYCLING AND WASTE
DISPOSAL ......................................................................................................... 138
7.4.1 Plastic Industry No Longer Use Products Containing PBDEs ...................... 138
7.4.2 Recyclers No Longer Use Products Containing PBDEs ............................... 138
7.4.3 Decreasing of Waste Dispossal Containing PBDEs ...................................... 139
REFERENCES ..............................................................................................................140
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List of Tables
TABLE 1.1 DUTIES AND RESPONSIBILITIES OF EACH THIRD PARTY 11

TABLE 2.1 PERCENTAGE OF FLAME RETARDANT – LEVEL OF FLAME RETARDANCY OF HIPS, ABS DAN PC 18
TABEL 2.2 USE OF PENTA-, OCTA-, AND DECA-BROMODIPHENYL ETHER IN RESINS, POLYMERS AND
SUBSTRATES (EBFRIP, 1990) 18
TABLE 2.3 USE OF ALTERNATIVE FLAME RETARDANT TO PENTABDE IN SEVERAL MATERIALS AND
APPLICATIONS (STOCKHOLM CONVENTION, 2009) 20
TABLE 2.4 ALTERNATIVE BFR ON SOME TYPES OF PLASTIC ON PRODUCTS FROM WEEE 23
TABLE 2.5 LIST OF A NEW BFR WITH A RETENTION TIME IN A DIFFERENT COLUMN 23
TABLE 2.6 COMMERCIALIZATION OF PENTABDE AND OCTABDE (UNEP, 2012 & SCOTT MASTEN, 2001) 29
TABLE 2.7 FORMER USES OF C-PENTABDE IN MATERIALS, THE APPLICATIONS AND PRODUCTS 29
TABLE 2.8 FORMER USES OF C-OCTABDE IN MATERIALS, THE APPLICATIONS AND PRODUCTS 31
TABLE 2.9 PRODUCTS CONTAINED PBDES (MEUNHOR, 2011) 31
TABLE 3.1 REGULATIONS OF PBDES IN UNITED STATE 35
TABLE 3.2 MATERIALS REGULATED IN THE ROHS2 DIRECTIVE CONCERNING GENERAL USE, HEALTH
IMPACTS AND MAXIMUM PERMISSIBLE CONCENTRATIONS 41
TABLE 3.3 IMPLEMENTATION OF ROHS REGULATION IN SEVERAL COUNTRIES 44
TABLE 3.4 POTENTIAL LABORATORIES IN INDONESIA TO CONDUCT PBDES TESTING 49
TABLE 3.5 MAXIMUM CONCENTRATIONS OF PBDES IN SEVERAL COUNTRIES 51
TABLE 3.6 PBDE RESTRICTIONS FOR SOME PRODUCTS BASED ON SNI 51
TABLE 4.1 IMPORT OF POLYETHYLENE FOR 2009-2015 65
TABLE 4.2 PE IMPORTS WITH HS TYPE (HS CODE 3901.10.12 - 3901.20.00), 2014-2015 66
TABLE 4.3 IMPORT OF POLYETHYLENE (HDPE) ACCORDING TO COUNTRY OF ORIGIN AT 2015 67
TABLE 4.4 FLAME RETARDANT FORMULAS 71
TABLE 4.5 FLEXURE TEST (MPA) 72
TABLE 4.6 UL94 FUEL TEST RESULTS FOR FORMULA A (IN SECOND) 73
TABLE 4.7 UL94 FUEL TEST RESULTS FOR FORMULA B (IN SECOND) 73
TABLE 4.8 TEST RESULTS FOR SCREENING THE CONTENTS OF PBDES IN SOME PRODUCTS 75
TABLE 4.9 LABELING PROCEDURE IN JAPAN 79
TABLE 5.1 DIFFERENCES BETWEEN EACH GMP 86
TABLE 5.2 ANALYTICAL METHOD FOR PBDES (US EPA, 2014) 90
TABLE 5.3 COMBINATION OF SORTING TECHNIQUES, MATERIAL INPUTS, PRODUCTS, DEVELOPMENT
STATUS AND ECONOMIC REVIEW 93
TABLE 5.4 POSSIBLE PROCESS AND SEPARATION PRINCIPLE FOR ELIMINATING BFR 94
TABLE 5.5 MEDIA FOR TESTING 97
TABLE 5.6 TEST RESULTS FOR IDENTIFICATION OF PBDE CONTENT IN ABS PELLET SAMPLES RECYCLE AND
CHILDREN'S TOYS ON THE MARKET 99
TABLE 6.1 FLOW OF PBDES MATERIALS 110
TABLE 6.2 ROAD MAP OF WASTE MANAGEMENT CONTAINING PBDES 112
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List of Figures
FIGURE 1.1 PBDES’S PROBLEMS FROM THE PLASTICS INDUSTRY AND IT’S WASTE 2
FIGURE 1.2 CONDITIONS EXPECTED TO OCCUR IN INDONESIA RELATED WITH UPOPS AND PBDE. 7
FIGURE 2.1 STRUCTURE OF PBDE CONGENERS (EFSA, 2011) 15
FIGURE 2.2 THEORETICAL CONFORMATIONS OF DIPHENYL ETHER (PLANAR AND BUTTERFLY) AND THE
ACTUAL CONFORMATION OF PBDES, SKEW AND TWIST (ESFA, 2011) 16
FIGURE 2.3 CHEMICAL STRUCTURES OF EIGHT PBDE CONGENERS (ESFA, 2011) 16
FIGURE 3.1 CONSUMPTION OF BROMINATED FLAME RETARDANT IN THE WORLD AND ASIAN REGION ON
2001 (KAJIWARA ET AL, 2006) 33
FIGURE 3.2 PBDES ROADMAP IN INDONESIA (DIRUBAH KE ENGLISH GAMBARNYA) 54
FIGURE 4.1 PERCENTAGE OF PLASTIC USE IN INDONESIA (KETERANGAN GB MSH BHS INDO) 64
FIGURE 4.2 SCHEME OF CE-MARKING PROCEDURE 77
FIGURE 4.3 GREEN LOGO ON CHINA ROHS2 78
FIGURE 4.4 ORANGE LOGO ON CHINA ROHS2 79
FIGURE 5.1 PLASTIC RAW MATERIAL DEMAND AND PRODUCT COMPOSITION 82
FIGURE 5.2 PLACTIC CONSUMPTIONS IN INDONESIA 83
FIGURE 5.3 DISTRIBUTION OF PLASTIC RECYCLING INDUSTRIES IN INDONESIA LISTED IN ADUPI 84
FIGURE 5.4 PRODUCT WITH PBDES CURRENT TREATMENT DIAGRAM 85
FIGURE 5.5 THE MECHANISM OF DIOXIN FORMATION IN THE THERMAL-STRESS PROCESS AND
IMPERFECT COMBUSTION 96
FIGURE 5.6 ILLUSTRATION PROCESS IN PLASTIC AND THE DRIVING FORCE OF DIOXIN FORMATION 99
FIGURE 5.7 2-DIMENSION LAY OUT OF MINI DEPO FROM TOP VIEW 103
FIGURE 5.8 3-DIMENSION LAY OUT OF MINI DEPO FROM TOP VIEW 103
FIGURE 5.9 DETAILES OF CRUSHING AND WASHING SECTIONS 104
FIGURE 6.1 DISTRIBUTION OF RESPONDENTS PER AREA 105
FIGURE 6.2 EDUCATIONAL BACKGROUNDS OF RESPONDENTS 105
FIGURE 6.3 THE NUMBER OF RESPONDENT AND TYPES OF GARBACE COLLECTED 106
FIGURE 6.4 WASTE DISTRIBUTIONS AFTER CONTINUING TREATMENTS 108
FIGURE 6.5 PLASTIC CODES (GOOD PRACTICES GUIDE ON WASTE PLASTIC RECYCLING 2011) 128
FIGURE 6.6 PROCESS DIAGRAM IN THE RECYCLED PLASTIC ENUMERATION INDUSTRY 130
FIGURE 6.7 PRODUCTION PROCESS OF PLASTIC RECYCLED RESIN 130
viii
1 INTRODUCTION
Indonesia government has realized and determined to face the challenges of
disruption of public health and the environment by Persistent Organic Pollutants
(POPs). This commitment was shown by the ratification of the Stockholm Convention
on September 28, 2009 and the publication of National Plan for Implementation of
Management for the National Implementation Plan (NIP) on the elimination and
reduction of POPs. In the beginning, NIP has been implemented for 12 POPs including
Dioxin dan Furans (PCDDs/Fs). The government also makes urgent action plans related
to regulation and developing capacity and human resources.
Polybrominated Diphenyl Ethers (PBDEs) is one of nine "new" POPs included in the
amendments to the Stockholm Convention. Material PBDEs are used as flame retardant
in various plastic products. Inadequate management of recycling and disposal of plastic
waste causes exposure of PBDEs and also Unintentional Persistant Organic pollutants
(UPOPs). At present plastic waste disposal in Indonesia is growing rapidly, which is
followed by various problems.
The plastic industry is one of the main industries in the 2010-2014 National
Development Plan and is expected to continue in 2015-2019. Even though the global
economy has weakened, in 2011 the local plastic market expanded 22.4% and continued
to grow even though the rate dropped to 7.75%. In 2012, plastic consumption per capita
is 10 kg per year. This value is still relatively low compared to Thailand that is 56 kg
and Malaysia that is 45 kg, so it is estimated that there are still opportunities to grow
more rapidly.1
The rapid growth of the plastic industry will be accompanied by increasing problems,
among others, caused by the presence of PBDEs that are released into the environment
with various impacts. Comprehensively these problems can be seen in Figure 1.1,
including the direct causes and root causes.
According to the Indonesian Olefin, Aromatic and Plastic Association (INAplas), 85%
of total plastic consumption in Indonesia comes from domestic production, and the
remaining 15% or 523,800 MT is obtained from imports. It is estimated that there are a
total of 38.5 million tons of solid waste produced by 262 million Indonesians each year
or 408 grams / person / day and 21.2 million tons of them coming from Java. In general,
40.1 million people who live in 25 major cities in Indonesia, produce around 14.1
million tons annually. The population of Jakarta alone produces 2.2 million tons every
year. The composition of household waste is 62% organic waste, 14% plastic waste, 9%
paper, 2% glass, 2% rubber and leather, 2% metal and 13% other types of waste.
Nationally, the amount of plastic waste per year is 5.39 million tons.
1 Global Business Indonesia. 2013. Indonesia’s Plastic and Packaging Industry. Detailed information available at:
http://www.gbgindonesia.com/en/manufacturing/article/2012/indonesia_s_plastic_and_packaging_industry.php
1
Development High use and releases of PBDEs and UPOPs in plastics products, plastics manufacturing processes
Challenge and plastics recycling and disposal practices
Recycling practices do not

segregate PBDEs containing Disposal practices do not
Immediate Manufacturing products in their recycled segregate PBDEs containing
Causes companies still
production processes products
use PBDEs in
their production
processes Plastic products that contain PBDEs remain available to consumers
No regulation to No regulation No regulation

Underlying address the issues concerning the concerning the
No technical
guidelines for
Causes of PBDE and its import, distribution PBDEs containing
PBDEs segregation
UPOPs and use of PBDE products
No public pressure (from customers, communities, press, academia, etc.)

Structural/
Root Causes
Low awareness of public on the risk of Limited understanding (knowledge) by stakeholders on the
PBDE and UPOPs to human health and risk of PBDE and UPOPs to human health and the
the environment environment
Figure 1.1 PBDEs’s problems from the plastics industry and it’s waste
Recycled plastic producers are increasing along with the increasing demand for plastic
products. Only in DKI Jakarta, 6,000 tons of waste are produced every day and 14% of
them are in the form of plastic (or 840 MET), as a raw material for the recycled plastic
industry. The recycling process is still very simple because the facilities and
infrastructure are still limited and carried out by the low-income informal sector,
including women and children, so that the business does not meet the economies of
scale.
The Ministry of Industry (MOI) considers that currently the plastics industry and its
recycling industry face challenges related to PBDEs. The Government of the Republic
2
of Indonesia (RI) in collaboration with the United Nations Development Program
(UNDP) has carried out three Workshops; the first in August 2010 was entitled
"Removal of Barriers to Sustainable Management and Reduction of PBDEs, Dioxins
and Furans." The second in December 2012 was entitled "The Reduction of the
Releases of PBDEs and UPOPs from Unlimited Waste Management and Recycling
Practices and the Manufacturing of Plastics in Indonesia”. The third is entitled "
Inception Workshop on Reducing Releases of Polybrominated Diphenyl Ethers (PBDE)
and Unintentional Persistent Organic Pollutants (UPOPs) Originating from Unsound
Waste Management and Recycling Practices and Manufacturing of Plastics in Indonesia
" held on October and November 2013.
1.1 THE PRESENT CONDITIONS IN INDONESIA
1.1.1 Institution and Regulations Related to Handling of PBDEs

Law No: 23/1997 concerning Environmental Management authorizes the Ministry of
Environment (MOE) to manage the environment at the central and regional levels,
including the development of related policies, management of toxic and hazardous
substances (B3) and toxic of hazardous waste (LB3). Based on this Law, Government
Regulation (PP) No: 74/2001 has been issued concerning the prohibition of 10 types of
POPs (aldrin, dieldrin, chlordane, DDT, heptachlor, hepox, endrin, toxaphene, HCBs
and PCBs). In line with that, the Food and Drug Supervisory Agency (BPOM) has been
actively monitoring the contamination of prohibited materials.
The policies and regulations relating to the handlings of PBDEs and POPs at this time
are as follows:
• Regarding PBDEs, there are no national regulations that regulate the use, trade and
monitoring of PBDEs.
• Regarding UPOPs, Ministerial Decree No: 13/1995 has been issued which regulates
the use of rotary kilns in incinerators. Regulations concerning prevention, control,
monitoring and reduction of UPOPs, including regulations that limit PCDDs/Fs in
food or other products, air, water, land, and in residues need to be developed
immediately.
• Regarding the management of household waste and industrial waste, in recent years
the Government's commitment has been quite high and targets have been made that
in the 2014-2019 period there will be a significant reduction in waste volume,
increased recycling and generally improved solid waste management (SWM).
Although in general the legal or regulatory framework for the management and control
of toxic and hazardous chemicals and wastes currently exists in Indonesia, further
guidance and coordination between various institutions is still needed to ensure the
sustainability of environmentally friendly management and monitoring.
3
1.1.2 Plastic Manufacturing Industry
In the plastic manufacturing sector, the government has now made various efforts to
operate and manage environmentally friendly industries.
§ Economy Strategy
As part of the Sustainable Development Plan (2005-2025) the government
carries out a green economy strategy, which among others is supported by
efficient and renewable energy use programs, clean technology and waste
management. Its policies include providing subsidies to the industry and also
incentives to promote environmentally friendly products.
§ Blue Sky Program
It is a clean air program launched by the government since 1996 to control air
pollution in urban areas. In 2010 there were nine industries that received the
Green Industry Award from the Ministry of Industry, which is the
implementation of Government Regulation No: 28/2008 for industries that
implement 4R (reduce, reuse, recycle and recovery) and correct management of
toxic and hazardous substances including POPs.
§ With WHO and SAICM QSP TF (2011) assistance, Indonesia is strengthened its
national capacity in managing priority industrial carcinogens.
§ Continuing to increase awareness and development of policies related to
PBDEs, as a follow-up of two workshops held by the Ministry of Industry and
UNDP, namely:
i) Removal of Barriers for Sustainable Management and Reduction of PBDEs
and PBDDs/PBDFs
ii) Reduction of Releases of PBDEs and UPOPs from unsound waste
management and recycling practices and the manufacturing of plasticss in
Indonesia
§ Financial Incentives
The government assists the private sector for Corporate Social Responsibility
(CSR) financing programs, for example investments in the environmentally
friendly expenditure and management.
§ Implementation, further development and guidance and enforcement of the
Minister of Industry and Trade Decree No: 274/MPP/Kep/6/99 concerning
Limitation and Monitoring of Imports, Distribution and Production of Dioxin
Contaminated Products.
1.1.3 Plastic Recyling Industry

In the plastic recycling sector, the government has also made several efforts to operate
and monitor the environmentally friendly recycling industry, such as:
§ In 2007 the government started and continuously implemented and expanded the
3R program (Reuse, Reduce and Recycle) in 33 provinces to separate waste
(paper, plastic, glass, metal) and its recycling. The target in 2014 is to recycle
75% of plastic waste, utilize 30% of plastic waste which is not currently
recycled, compose 20-30% of household waste, recycle 30% of metal, glass and
4
paper waste and the ultimate goal is achieving 20-30% reduction in waste
volume.
§ Private sector investment and development for the identification and
management of PBDE and reduction of POPs that are exposed to the recycling
industry.
§ Formulation of policies and regulations regarding the processing and disposal of
electronic waste (e-waste). The regulation for e-waste will be focused on sorting
between e-waste and second hand equipment and also the management approach
through:
i) Extended Producer Responsibility (EPR)
ii) Participation of central and regional governments
iii) Economic instruments (incentives and disincentives) and 3R programs
§ Implementation and further development of the Minister of Trade Regulation
No: 63/M-DAG/PER/12/2009 concerning Import of Second-hand Goods for
Reconditioning, Remanufacturing or Re-use (Producer Importer).
§ Implementation and further development of the Minister of Trade Regulation
No: 39/M-DAG/PER/9/2009 concerning the Import of Scrap Waste.
In Indonesia, there has been a significant increase in production and consumption of

plastic products and plastic recycling products; however, on the other hand the practice
of recycling is still at the level of "infancy". The government still needs assistance to
provide adequate facilities and infrastructure as well as increasing awareness of the safe
and environmentally friendly recycling process.
1.1.4 Disposal of Plastic Waste

In the sector of plastic waste disposal, the government has also made several efforts to
operate and monitor its environmentally friendly activities, such as:
§ Further expansion of the 3R program and restrictions on uncontrolled
combustion of waste through the improvement of solid waste disposal sites in
240 cities and the development of gas landfills projects in 24 major cities. In
2014 it is targeted that 15 million tons of hazardous waste will be recycled and
the application of 3R for hazardous waste will increase by 20% per year.
§ Investment in Best Available Techniques / Best Environmental Practices (BAT /
BEP) as a support for waste final disposal containing PBDE by local waste
processing governments.
§ Some big cities have the initiative to obtain methane gas as a source of energy
through an aerobic composting process.
§ Currently there are a number of regulations relating to Municipal Solid Waste
Management (MSWM), including the following:
- Government Regulation No: 18/1999 concerning toxic and hazardous
substances (B3) management including POPs.
- Law No: 18/2008 as a basic policy for the 3R program for the management of
solid waste
- Law No: 32/2009 concerning Environmental Protection and Management
5
- Government Regulation No: 18/2009 concerning Management of Hazardous
Waste
- Decree of the Minister of Environment No: 1/2009 concerning the ADIPURA
award for the Mayor
- Minister of Public Works Decree No: 21/2008 concerning National Policies
and Strategies for Solid Waste Management
- Minister of Environment Decree No: 05/2012 concerning Environmental
Impact Analysis, including the importance of proper combustion / incineration
to control the potential release of UPOPs.
The implementation, enforcement and monitoring of these regulations is very dependent

on the Regency or City, mainly related to the availability of experts and funding sources
for the management of environmentally friendly solid waste, especially hazardous waste
containing POPs. Therefore, further assistance is still needed to manage the waste.
1.2 EXPECTED CONDITIONS AND ITS EFFORTS

By maintaining the consistency of the implementation of the national industrial
development plan, the conditions expected to occur in Indonesia are related to the
dangers or negative impacts of UPOPs and PBDEs are:
i) Strengthening policies and regulations for reducing UPOPs and PBDEs
ii) Reduced imports and use of PBDEs in the plastic manufacturing industry
iii) Reduced UPOPs and PBDEs from improper recycling processes
iv) Reduced exposure of UPOPs and PBDEs from improper disposal of plastic
waste
In general, the expected condition of Indonesia is related to the danger or negative

impact of UPOPs and PBDEs can be seen in Figure 1.2.
6
Figure 1.2 Conditions expected to occur in Indonesia related with UPOPs and PBDE.
1.2.1 Strengthening Policies and Regulations for Reducing UPOPs

and PBDEs
To reach a commitment with the ratification of the Stockholm Convention on reducing
UPOPs, the government must strengthen its policies and regulations. It is necessary to
develop a more detailed new policy and provide incentives to ensure PBDE will not be
imported and used again in Indonesia; while waste management is also done better
Various activities and efforts can be made to achieve this condition, including the
following:
§ Analyzing regulations that apply in the destination countries of Indonesian
product exports, including the Restriction on the use of certain Hazardous
Substances (RoHS) Directive.
§ Develop national standards for maximum PBDEs in a variety of products and
adequate labeling systems.
7
§ Develop and integrate policies and regulations regarding the management of
solid waste containing PBDEs.
§ Adopting regulations and guidelines for reducing POPs/PBDEs from the plastic
manufacturing industry, recycling and waste disposal processes.
§ Develop regulations and policy frameworks related to the import of materials
and goods containing PBDEs.
§ Increasing institutional and technical capacity to control the import of materials
potentially containing PBDEs, including policies for monitoring and monitoring
waste disposal containing PBDEs.
§ Removing obstacles for the application of BAT/BEP with economic instruments
and incentives.
1.2.2 Reduced Imports and Use of PBDEs in the Plastic Industry

Many companies use raw materials from imports, both pure and recycled. Although in
reality there are almost no companies that limit the use of ingredients containing PBDE,
in essence they are aware of the risk of things that are not desirable. To overcome this
condition, various efforts have been made, including the following:
§ Availability of national experts to deal with PBDE problems in the plastic and
recycling manufacturing industry. For this reason, prior mapping or
comprehensive information on the condition of the industry is needed, so that
the technical assistance and expertise neededcan be determined more accurately.
The information also includes the analysis results of PBDE imported and used
by the industry as well as PBDEs substitute material that can be used as an
alternative.
§ Reduction of PBDEs exposure or release to the environment is reduced through
prohibition rules and the introduction of a quality control system that avoids the
use of ingredients containing PBDEs. In addition, communication between
stakeholders needs to be improved, so that individual awareness on the dangers
of PBDEs will increase. Awareness can be further enhanced through the delivery
of general knowledge, understanding, commitment and involvement in efforts to
reduce PBDEs.
1.2.3 Reduced UPOPs and PBDEs from the Plastic Recycling

Industry
Recyclers are expected to produce purer quality products, in sufficient quantities
guaranteeing continuity of supply and at competitive prices. In addition, increasing the
capacity and efficiency of the recyclers will also increase income and create jobs and
reduce waste disposal to landfills that can reduce the costs incurred by the local
government. To achieve the expected conditions, namely the reduction of POPs and
PBDE from the plastic recycling industry, various efforts were made, including the
following:
§ Improve the handling, storage, recycling and disposal of waste containing
PBDEs by introducing BAT/BEP guidelines for plastic recycling.
8
§ Improving the supply chain of raw materials in the form of plastic recycling
products and introducing environmentally friendly disposal methods. It also
includes sorting of plastic waste that cannot be recycled and the appropriate
disposal method.
1.2.4 Reduced release of UPOPs and PBDEs from Plastic Waste

Disposal
It is hoped that there will be no uncontrolled burning of plastic waste so that the release
of POPs and PBDEs can be reduced. To achieve the expected conditions, namely the
reduction of the release of POPs and PBDEs from the disposal of plastic waste, various
efforts were carried out including the following:
§ Implementing the right collection and sorting procedures for household
waste, by introducing an integrated waste management system in the form of
a Mini Depo in several waste-producing areas.
§ Developing Extended Producer Responsibility (EPR) schemes, namely
expanding producer involvement in their responsibility for environmental
impacts caused.
§ Provide training with certain modules to workers who will manage plastic
waste disposal.
1.3 OBSTACLES FACED

There have been many efforts made to answer and anticipate the issue of UPOPs and
PBDE at the national level, there are still various obstacles. Depending on its nature,
these obstacles can be a regulations, levels of concern, monitoring mechanisms and
institutions.
§ Limited Regulatory Framework

Although there are currently being carried out activities that strengthen the
regulatory framework for handling chemicals, including POPs, they still cannot
support sustainable management of POPs. Even the regulations that regulate
PBDE issues do not yet exist and there are no standards or guidelines regarding
PBDE. In addition, although there are opportunities to develop and implement
the EPR scheme, there are no specific guidelines or rules for controlling PBDE.
§ Inadequate system and institutional capacity

Weakness in coordination, limited cross-sectoral management, inadequate
management of waste and chemicals, and limited collaboration between the
government, the private sector and other stakeholders are still inadequate.
§ Limited professional and technical personnel

At present, approaches and patterns of adequate management of chemicals are
still felt as something new. The expertise and experience related to the
management of chemicals and POPs is still lacking (in terms of developing
9
regulations and administrative aspects). In addition, technical capabilities (such
as laboratory capabilities) are also still felt weak in an effort to measure and
monitor POPs and UPOPs. Likewise, the manufacturing and recycling sector,
operators and responsible people for waste management are still weak in
technical knowledge about POPs.
§ Limited sources of financing

The large-scale manufacturing industry still does not have sufficient funding to
build a sophisticated quality control system to handle the flow of materials
coming and products that come out. This industry will not be much affected
even if they are required to meet the correct chemical management requirements
according to certain standards. On the other hand there are many small-scale
industries, especially recyclers, whose businesses will be threatened if they have
to pay high costs to be able to meet the standard requirements set by the
government. As a consequence, the government has an obligation to facilitate
the establishment of an appropriate and adequate system for this small-scale
recycling industry.
Meanwhile local / city governments in Indonesia face various challenges in the

increasing demands for waste management. They must fulfill these demands
with limited technical capacity and funding sources. To overcome this problem
some local goverments increase levies on collection, transportation, disposal,
separation and recycling activities. Consequently, many people object to the levy
and ignore it. For this reason, they must be given information or knowledge on
how to manage wastes that may contain POPs, because generally they currently
do not handle their waste properly and do not consider the presence or absence
of POPs.
§ Information barrier and levels of concern
In general, many community members have no concern or information about the

dangers of POPs. They have a limited understanding of the impact of POPs on
health and the environment, and also about socio-economic benefits when
applying waste and chemical management properly. There is no clear
information about PBDEs and POPs that should be known to the public. The
plastic manufacturing industry also does not yet have a clear understanding of
the risks of materials or goods containing PBDEs and the possibility of POPs
being released into the environment.
1.4 ACTIVITIES DONE THROUGH UNDP ASSISTANCE

UNDP is working with the Ministry of Industry to carry out activities that are also a
realization of the consequences of the Stockholm Convention ratification, especially in
efforts to reduce the release of UPOPs and PBDEs, as well as strengthening good
chemical and waste management systems to protect human health and the environment
in general.
This activity will help the plastics industry and its recycling industry to ensure that no
10
prohibited PBDEs is used or recycled. In addition, municipal and community waste
management will also be helped to be more environmentally friendly, so that the release
of UPOPs and PBDEs can be reduced. From this activity, the following outputs are
expected to be obtained:
1. Strengthening national policies and regulations to reduce the release of POPs
and PBDEs from the plastic manufacturing, recycling and waste disposal
industries.
2. Reduced/inhibited imports and use of PBDEs in the plastic industry.
3. Reduction of POs and PBDEs from improper recycling of plastic.
4. Reduced release of POPs and PBDEs from improper disposal of garbage/waste.
To realize the achievement of these outputs, several activities or studies have been
carried out by third parties, namely with eight Research & Development Institutions and
Universities. Each is obliged to carry out several activities which all lead to the above
outputs, as shown in Table 1.1.
Table 1.1 Duties and responsibilities of each third party

Third
No Component Subject
Parties
1 Component 1: Analysis on the implementation of regulatory B4T
Strengthening the of RoHS in Indonesia
national policy and
regulatory framework to
reduce UPOPs and
PBDE releases from
plastics manufacturing,
recycling, and disposal
practices
Reviewing of national Conformity Assessment B4T

Body (CAB) competence of RoHS regulation
implementation
Industry mapping that consumes flame B4T

retardant, especially PBDE (electronic,
automotive, resin, etc)
Guidelines analysis on the management of B4T
PBDE in industry
RSNI assessment on the priority B4T
Academic draft in the context of regulation UI
development for manufacturing and recycling
industries
PBDE risk assessment towards health and UI
environment
Assessment and recommendation for UI
information system on POPs in industry
Roadmap study on PBDEs in Indonesia ITS
11
Third
Parties
Extended Producer Responsibility (EPR) ITS
Concept developed
Monitoring and Control of Materials of POPs UNTIRTA
2 Component 2: Supply-Demand and Supply Chain for UNTIRTA
Reducing or eliminating products that contain flame retardant
the importation and use
of PBDE in plastics
manufacturing
Alternative PBDEs research in accordance UNTIRTA

with the production process applied in
Indonesia
Emission test PBDE in industries UNTIRTA
Analyze raw material, process, product and UNTIRTA
emission on users industries of PBDE
Implementation of Free PBDE labeling for B4T
plastic-based products
Knowledge sharing to suppliers associations B4T
Regulation position of Indonesia concerning B4T
PBDE among ASEAN countries
BAT/BEP Guidelines development assessment BTP-BPPT
(selection process in products that contain
PBDEs and non-PBDEs at recyclers)
Products testing that may contain PBDE BBKK
3 Component 3: Good Manufacturing Practices (GMP) on ITB
Reducing Releases recycled products that contain PBDEs
POPs and PBDEs from
Unsound Plastics
Recycling
Plastic recyclers and product recycle users ITB

mapping in Indonesia
Assessment on RSNI for recycled products BBKK
that contain PBDEs
FGD with association of recyclers and BBKK
industries that consume recycled products
(related to PBDEs)
Dioxin test at recyclers in East and West Java BTP-BPPT
Endeavors (recommendations) to reduce BTP-BPPT
dioxin
4 Component 4: Study on mini depo for plastic disposal UBAYA
Reducing releases of
POPs and PBDEs from
unsound plastics
disposal practices
12
Third
Parties
Road map on plastic waste (that contain UBAYA
PBDEs/UPOPs) management
Inventory system concerning PBDEs plastic UBAYA
waste
Environmental education module concerning UBAYA
environmental awareness, and how to
encourage community-based solid waste
management
Mapping on plastic waste that contain PBDEs UBAYA
Road map on developing innovative plastic ITB
waste recycling industries that contain PBDEs
Road map (management) of plastic waste that ITB
contain PBDEs
Control guidelines on plastic waste that BBKK
contains PBDE from domestic industries
13
2 POPs, PBDEs, AND INDUSTRIES THAT USE IT
2.1 PERSISTENT ORGANIC POLLUTANTS (POPs) AND

POLYBROMINATED DIPHENYL ETHERS (PBDEs)
Persistent Organic Pollutants (POPs) are organic compounds that are relatively long-
lasting and accumulate in the environment because they are difficult to degrade through
chemical, biological and photolysis processes. This compound is also semi-volatile so
that it can be in the vapor phase or absorbed in dust particles, so that POPs can travel
long distances in the air (long range air transport) before finally being deposited on
earth (Alberth, 2010).
There are three types of POPs, namely:

1. Pesticides: Dichloro-diphenyl-trichloroethane (DDT), Aldrin, Endrin, Dieldrin,
Chlordane, Heptachlor, Mirex, and Toxaphene
2. Industrial chemicals: Poly Chlorinated Biphenyl (PCB) and Hexa Chloro
Benzene (HCB)
3. Products that are accidentally produced: Poly Chlorinated Dibenzop-Dioxins
(PCDD), Poly Chlorinated Dibenzo Furans (PCDF), Chloro Benzene (HCB)
Hexa and Poly Chlorinated Biphenyl (PCB)
The distribution of POPs concentrations to another areas is influenced by the ability of

POPs to travel long distances in the atmosphere as a result of the nature of their
volatility. POPs that are semi-volatile cause it to move either in the form of gas or in the
form of particles. More volatile POPs, namely organochloride groups, tend to move
easily in the form of gases so that the spread is more limited to areas not too far from
the source of emission, while less volatile POPs such as poliaromatic hydrocarbon
compounds undergo displacement as particles that move together with air mass flow.
Thus, POPs need to be watched out for because of their extensive pollution ability
(Fernández & Grimalt, 2001).
The results of Henny's research, et al. (2010) were carried out around agricultural areas
in Medan and Karo (North Sumatra), Cianjur and Karawang (West Java), Dieng
(Central Java), and Batu (East Java), showing the concentration of DDT compounds and
the derivatives detected in water are in the range of 0.011 - 0.564 ppb, in sediments with
concentrations of 0.50 - 18.7 ppb and in soils with concentrations of 0.23 - 54.9 ppb.
Meanwhile the concentration of other target compounds such as mirex, endrin and
methoxychlor are at concentrations of <10 ppb. The Stockholm Convention in 2009
included a commercial mix of flame retardant pentabromodiphenyl ether (c-pentaBDE)
and octabromodiphenyl ether (c-octaBDE) as part of new resistant organic pollutant that
began to be restricted and socialized in the convention (UNEP, 2010).
14
Regarding the management of POPs in Indonesia, basically the entire life cycle of some
of these POPs is regulated in laws and regulations, such as their existence, import, use,
release and existance in the environment, waste containing POPs, to remediation of
polluted land. However, not all POPs are covered by Indonesian legislation, such as
PFOS, PBDEs include: tetrabromodiphenyl ethers and pentabromodiphenyl ethers (c-
pentaBDEs), and hexabromodiphenyl ethers and heptabromodiphenyl ethers (c-
octaBDEs), including hexabromocyclododecanes (HBCDs) which have been included
in the list of new POPs at the 6th Conference. Law enforcement instruments related to
POPs, such as supervisors and investigators, are also available in Indonesia. Law
Number 32 of 2009 concerning Protection and Management of the Environment and
Law Number 12 of 1992 concerning Pesticides has also regulated sanctions, both
criminal and criminal sanctions. Likewise, monitoring POPs has also been regulated in
various regulations, even though they do not cover all POPs.
Unintentionally produced Persistent Organic Pollutans or commonly referred to as

UPOPs are POPs which are accidentally produced due to incomplete combustion of
chlorinated organic materials such as dioxin, furan, hexachlorobenzene (HCB), and
polychlorinated biphenyl (PCB). Characteristics of UPOPs compounds are basically the
same as the characteristics of POPs compounds which are toxic, difficult to decompose
(persistent), bioacumulation and transported through air, water and species move and
cross international boundaries and are stored far from the release site, where they
accumulate in terrestrial and water ecosystems.
PBDEs are a brominated aromatic compounds consisting of two phenyl rings connected
by ether bonds. There are 209 possible compounds from PBDE congeners, which differ
in the number and position of bromine atoms in two phenyl rings as shown in Figure
2.1. PBDEs form the same number of congeners and substitution patterns that are
identical to congeners of polychlorinated biphenyls (PCB). Therefore, PBDEs use the
same congener numbering system as proposed for PCBs (Ballschmiter et al., 1993).
PBDEs are in the form of conformations from skew to twist (Teclechiel et al., 2008) but
are not planar-confirmed (Figure 2.2). The more bromine substituents in the PBDE
congener, the more oblique the conformation is.
Figure 2.1 Structure of PBDE congeners (EFSA, 2011)
15
Figure 2.2 Theoretical conformations of diphenyl ether (planar and butterfly) and the
actual conformation of PBDEs, skew and twist (ESFA, 2011)
The three PBDE commercial technical mixes are: PentaBDE, OctaBDE and DecaBDE.
They consist of a congener mixture and are named according to the average content of
bromine. To avoid confusion, uppercase names will be used when referring to a
commercial technical mix (eg PentaBDE), while lowercase letters will refer to the
homolog itself (eg pentaBDEs). The chemical structure of the eight PBDE congeners is
shown in Figure 2.3. The eight PBDE congeners are the most abundant compounds in
the three commercial mixtures mentioned above, namely PentaBDE, OctaBDE and
DecaBDE.
Figure 2.3 Chemical structures of eight PBDE congeners (ESFA, 2011)
Most PBDEs produced in the industry contains a mixture of brominated diphenyl ether,
isomer and homolog (Elvers et al., 1992). The PBDE is commercially predominantly
penta (PeBDE), octa (OBDE) and decabromodiphenyl ether (DeBDE). PeBDE is a
mixture of tetra- with tetra-BDE (TeBDE) is the main component (WHO, 1994).
Commercial PBDEs is a stable compound with boiling points ranging between 310 and
425oC. PBDE is a hydrophobic and lipophilic compound.
According to the IPCS (International Program for Chemical Safety) published by the
World Health Organization (WHO, 1994), there are eight major PBDE producers in
Europe, the United States and Japan. WHO states PBDE's annual global consumption is
40000 tons (30000 tons De-BDE, 6000 tons OBDE, 4000 tons PeBDE). Due to the
nature of PBDE that makes it an efficient flame retardant compound, PBDE demand is
16
increasing rapidly and so is PBDE production. According to the UK Department of
Commerce and Industry (DTI, 1999), in Europe the market for flame retardant is around
200000 tons/year, where demand for organobromines is 64,000 tons.
2.2 PBDEs AS FLAME RETARDANT AND ALTERNATIVE

SUBSTITUTES
2.2.1 PBDEs as Flame Retardant

Flame-retardants are a variety of substances that are added to combustible materials to
prevent fires from starting or to slow the spread of fire and provide additional escape
time. There are three four main categories of compounds that use as flame retardant,
namely: inorganic products based on metallic hydroxides, organophosphorus, nitrogen-
based and halogenated hydrocarbons (Vos et al., 2003; WHO, 1997).
For halogenated hydrocarbons, the Brominated Flame Retardant (BFRs) group consists
of chemicals that are different from variations in their physico-chemical properties and
uses. The main BFRs groups include polybrominated: (i) neutral aromatics, (ii) neutral
cycloaliphatic, (iii) phenols (including neutral derivatives), (iv) aromatic carboxylic acid
esters and (v) trisalkyl phosphate. Common compounds in the five groups of BFRs
include tetrabromobisphenol A (TBBPA), PBDEs, hexabromocyclododecanes
(HBCDDs5), decabromodiphenyl ethane (DBDPE), bis (2,4,6 tribromophenoxy) ethane
(BTBPE) and 2,4,6-tribromophenol (WHO, 1997; Orn and Bergman, 2004; Harju et al.,
2009).
PBDEs, TBBPA, tetrabromophthalic anhydrides, dibromoneopentylglycol and

brominated styrene are the most commonly used compounds as flame retardant. PBDEs
are structurally similar to PCBs and polybrominated biphenyls (PBBs) and have the
same properties; they have a large number of congeners depending on the number and
position of bromine atoms on two phenyl rings. The total number of possible congeners
is 209, and the number of isomers for mono-, di-, tri-, tetra-, penta-, hexa-, hepta-, octa-,
nona- and decabromodiphenyl ethers are respectively 3, 12, 24, 42, 46, 42, 24, 12, 3 and
1 (WHO 1994). PBDE has been widely used as a flame retardant since the 1970s,
because their bromine atoms have a high ability to remove free electrons from other
atoms, which is partly what drives the combustion process (Crimmins et al., 2012).
Based on these properties PBDEs are most widely used as flame retardant additives.
In general PBDE is solid (temperature 20 0C, 1 atm), except for pentaBDE, which also
has a liquid or semi-solid phase. In addition to the characteristics of PBDEs, what is
also important to know is the composition of the range of PBDEs uses, the type of resin
generally using PBDEs and the application of plastic using PBDEs as a flame retardant.
In Table 2.1 it can be seen that the main resin using PBDE or Brominated Flame
Retardant (BFR) as FR is ABS and HIPS with the application of Electric Electronic
Equipment, EEE (for types of c-octaBDE) and polyurethane with applications as foam
17
(for type c- pentaBDE).
Table 2.1 Percentage of flame retardant – level of flame retardancy of HIPS, ABS dan
PC
PBDE flame retardant is usually used in resins and polymers. DeBDE and TBBPA are
the two most frequently used for flame retardant as reported by DTI (1999). The main
uses of PBDE are in high impact polystyrene, flexible polyurethane foam, textile
coatings (not clothing), wire and cable insulation, electrical and electronic connectors
and other interior parts as shown in Table 2.2. In the United States, 80-90% of PBDE is
used for this application.
Tabel 2.2 Use of penta-, octa-, and deca-bromodiphenyl ether in resins, polymers and
substrates (EBFRIP, 1990)
PentaBDE is mainly used as an additive in flexible polyurethane foams in coatings and

furniture (DoE, 1992 as quoted by ECB, 2001). It also use as additive in epoxy resins,
phenolic resins, unsaturated polyesters and textiles (WHO, 1994). The four main uses of
polyurethane are: 1) foam-based automotive applications; 2) domestic furniture
including mattresses; 3) foam-based packaging; and 4) components as rigid
polyurethane elastomers casing instruments. PentaBDE is also used in the textile
industry, electronic equipment, hydraulic fluids and rubber. The use of PentaBDE in the
European Union before the ban has been estimated at 300 tons per year.
OctaBDE is mainly used in Europe on acrylonitrile-butadiene-styrene (ABS) at 12-18%

by weight. About 95% of the total OctaBDE provided in the European Union is used in
18
ABS. The remaining 5% consist of high-impact polystyrene (HIPS), polybutylene
terephthalate (PBT) and polyamide. Flame retardant polymer products are usually used
for the production of office equipment and business machinery. ABS is also commonly
used in clean water and sewage pipes. However, no information has been found whether
the ABS used in this application does contain OctaBDE or not.
The use of DecaBDE in the European Union in the mid-1990s was estimated at 8,210
tons per year. In 2001, worldwide demand for DecaBDE was reported to be 56,100 tons
and European market demand was 7,600 tons of which 20% was used in the textile
industry (curtains and furnishings). The remaining 80% is used in different plastics,
electronics and electrical equipment as printed circuit boards and other electronics such
as computers, TVs, laser printers, copiers, fax machines, junction boxes, ropes and
cables. According to the ECB (2007), DecaBDE in 2004 was no longer produced in the
European Union, but was imported by at least three companies.
2.2.2 Alternative Subtitutes of PBDEs as Flame Retardant

There are four categories of flame retardant: inorganic flame retardants,
organophosphorus flame retardants, nitrogen-based flame retardants and halogenated
flame retardants.
1. Inorganic Flame Retardants
Example for this flame retardants are metal hydroxides (such as aluminium
hydroxide and magnesium hydroxide), ammonium polyphosphate, boron salts,
inorganic antimony, tin, zinc and molybdenum compounds, and elemental red
phosphorus. Both aluminium hydroxide, also sometimes called aluminium
trihydrate (ATH), and magnesium hydroxide are used as halogen free
alternatives to brominated flame retardants and they also function as smoke
suppressants. Inorganic phosphorus compounds are widely used as substitutes to
brominated flame retardants. Inorganic flame retardants are added as fillers into
the polymer and are considered immobile in contrast to the organic additive
flame retardants. Antimony trioxide and zinc borate are primarily used as
synergists in combination with halogenated flame retardants. Alternative
synergists include zinc hydroxystannate (ZHS), zinc stannate (ZS), and certain
molybdenum compounds. The whole group of inorganic flame retardants
represents around 50% by volume of the global flame retardant production,
mainly as aluminium trihydrate, which is in terms of volume is the biggest flame
retardant category in use on the market (Stockholm Convention, 2009).
2. Organophosphorus Flame Retardants

Phosphate esters are an example for these kinds of flame retardant. This
category is widely used both in polymers and textile cellulose fibres. Halogen-
free organophosphorus flame retardant, triaryl phosphates (with three benzene
rings attached to a phosphorus-containing group) are used as alternatives to
brominated flame retardant. Organophosphorus flame retardant may in some
cases also contain bromine or chlorine. This flame retardant represent around
19
20% by volume of the total global production (Stockholm Convention, 2009).
3. Nitrogen-based Flame Retardants

These organic flame retardants inhibit the formation of flammable gases and are
primarily used in polymers containing nitrogen such as polyurethane and
polyamide. The most important nitrogen-based flame retardants are melamines
and melamine derivatives and these act as intumescent (swelling) systems
(Stockholm Convention, 2009).
4. Halogenated Flame Retardants

These flame retardants are primarily based on chlorine and bromine. These
flame retardants react with flammable gases to slow or prevent the burning
process. The polybrominated diphenylethers (PBDEs) are included in this group,
where all the isomers of PentaBDE are represented.
The group of halogenated flame retardants represent around 30% by volume of

the global production, where the brominated flame retardants dominate the
international market (Stockholm Convention, 2009). Halogenated flame
retardant can be divided into three classes:
• Aromatic, including PBDEs in general and PentaBDE in particular.
• Cycloaliphatic, including hexabromocyclododecane (HBCDD).
• Aliphatic, globally representing a minor group of substances
PBDEs are one of halogenated flame retardant that is usually used in various
manufacturing process. In details, the variety and optional chemical systems that
can be substitutes for PBDEs as flame retardant, can be seen in Table 2.3.
Table 2.3 Use of alternative flame retardant to PentaBDE in several materials and
applications (Stockholm Convention, 2009)
Phosphorus/
Halogen
Nitrogen Alternative Commercial
Material/ Inorganic organic
organic flame Applicca commodities
polymers/ alternatives alternatives
alternatives retardant -tions for the
resins to PentaBDE to
to PentaBDE materials applications
PentaBDE
Epoxy • Aluminium • Metallic • Tetrabromo • Polyethylene • Circuit • Computers
resins hydroxide phosphinates bisphenol A sulphide boards • Ship
(ATH) • Reactive (reactive) • Protecti- interiors
• Magnesium nitrogen and • Etylenebis ve • Electronic
hydroxide phosphorus (tetrabromo) coatings parts
• Ammonium constituents phalimid
Poly (unspecified)
20
Phosphorus/
Halogen
PentaBDE
phosphate • DOPO
• Red (dihydrooxap
phosphorus hosphaphena
• Zinc nthrene
hydroxyl oxide)
stannate
(ZHS), Zinc
stannate
(ZS) and
ZHS/ZS
coated ATH
Polyvinyl • Aluminium • Tricresyl • Tris • Rigid PVC • Cable • Wire end
chloride hydroxide phospate (dichlorop is flame sheets Cables
(PVC) (ATH) (also rpyl) inherent • Floor mats
• Zinc borate plasticizer) phosphate itself • Industrial
• Zincmolybde • Vynilbrom sheets
-num ide
compounds
(together with
phosphate
esters)
• Zinc
Hydroxystan
nate (ZHS),
Zinc Stannate
(ZS) and
ZHS/ZS
coated ATH
Polyurethan • Ammonium • Melamine • Bromoalkyl • Intume- • Cushio- • Furniture
(PUR) Polyphosphate (nitrogen phosphates scent ning • Sound
• Red based) Tetrabromo systems materials insulation
phosphorus • Dimethyl phtalic • Packagi- packaging
propyl anhydrade ng • Padding
phosphonate • Tris(chloro • Padding Panels
• (DMPP) ethyl) • Wood
Reofos phosphate imitations
(non- (TCPP) • Transporta
halogen (together tion
flame with
retardant) brominated
polyols or
red
phosphorus)
Thermoset • Ammonium • Triethyl • Dibromo- • Intume- •Circuit • Electrical
Unsaturated polyphosphate phosphate styrene scent boards Equipment
polyesters • Aluminium • Dimethyl • Tetrabromo systems •Coatings • Coatings for
(UPE) Hydroxide propyl phtalic chemical
(ATH) phosphonate Anhydride processing
21
Phosphorus/
Halogen
PentaBDE
• Magnesium (DMPP) based diol plants
Hydroxide • Tetrabromo mouldings
• Zinc phtalic • Military and
Hydroxy anhydride marine
stannate • Bis applications
(ZHS), Zinc (tribromophe • Construction
stannate noxy) panels
(ZS) and ethane
ZHS/ZS
coated ATH
Rubber N/A • Alkyl diaryl N/A • Intume- • Trans- • Conveyor
phosphates scent portation belts
(nitril rubber) systems • Foamed
pipes for
insulation
Paints/ N/A • Triaryl • Tetrabrom • Intume- • Coatings • Marine and
lacquers phosphates ophthalate scent industry
(unspecified) diol Systems lacquers
• Tetrabrom • Silicone for protection
ophtalic rubber of containers
anhydride
based diol
• Bis (tri-
bromo
phenoxy)
ethane
Textiles • Aluminium •Tetrakis • Trichloro- • Intume-scent • Coatings • Back
hydroxide hydroxyl- propyl Systems coatings and
• Magnesium methyl phosphate • Aramide impregnation
hydroxide phosphonium fibres for carpets
• Amonium salts, such as (certain • Automotive
compounds chloride protective seating
(unspecified) (THCP) applications) • Furniture in
• Borax or ammonium • Wool homes and
(THPX) • Modacrylic public
•Dimethyl buildings
phosphono • Aircraft
(N-methylol) • Underground
propionamide
•Diguanidine
hydrogen
phosphate
•Aromatic
phosphates
(unspecified)
Textiles N/A • Dimethyl
hydrogen
phosphite
22
Phosphorus/
Halogen
PentaBDE
(DMHP)
• Melamine
(nitrogen
based)
• Phospho
nitrilic
chloride
(PNC)
Hydraulic N/A N/A N/A • Drilling • Off shore
oils oils • Coal
• Hydrau mining
lic
fluids
Referring to the results of Wager et al. (2010) research in 53 plastic mixed samples from
WEEE 15 recycling units in Europe, it was found that plastics with the highest
brominated flame retardant (BFR) fraction content were found in small electronic
products in households used at high temperatures, like CRT monitors and CRT TVs. To
help in testing and identifying the presence or absence of PBDE/BFR in applications
that do require a flame retardant, the information on flame retardant PBDE
replacements used in products that do require anti-flame performance is necessary to
know. Tables 2.4 and Table 2.5 show the alternative FR on the application in the
appropriate plastic resin.
Table 2.4 Alternative BFR on some types of plastic on products from WEEE
Table 2.5 List of a new BFR with a retention time in a different column
23
2.3 EXPOSURE ROUTES, IMPACTS OF HEALTH,
ENVIRONMENT AND GENDER
2.3.1 Exposure Routes and Health Impacts

PBDEs are exposed to air, water and soil due to waste from products contained of
PBDEs. PBDEs in the air are in the form of particles/dust, which will then return to the
soil or water and then settle into dust. The dust will be lifted by rain and will return to
the air again. Cycle changes that occur cannot solve or eliminate the PBDEs. This is due
to the difficulty of the components of the PBDEs to degrade in a short time. In addition
PBDEs have properties that are not easily dissolved in water, so the PBDEs will also
settle below the surface of the water.
Deposition of PBDEs on the surface of the water, such as on the surface of the lake, will
cause contamination of fish and other aquatic biota. These deposits will also continue to
exist for years. Some PBDEs containing lower bromine (for example, tetra and penta-
congeners from PBDE) in water can enter the metabolic system in fish for low
concentrations (around 10 ppt to 1 ppb PDBE per gram of fresh fish). Whereas for
PBDE which contains high bromine, such as decaBDE is not found in fish. Besides
water, PBDEs are also not easily degraded by soil. Degradation the PBDEs in the
ground is very slow, so the PBDEs will still tread on the ground. The sediment in the
soil will be carried by water and will be returned to the aquatic environment.
The way PBDEs enter and leave the human body depends on the chemical structure of
the congener component. Higher types of PBDEs with bromination, especially
DecaBDE (PBDE that is widely used today), react much differently in the body than
low brominated PBDEs. If someone breathes air-containing PBDEs, or swallows food,
water, or soil contaminated with PBDEs, low brominated congeners are far more likely
to enter the body through the lungs and stomach then into the bloodstream compared to
24
DecaBDE.
The exposure of dibrominiated PBDEs in the soil are less likely to be adsorbed through
the skin into the bloodstream. After PBDEs enter a person's body, some congeners can
be transformed into products called metabolites. DecaBDE can stay in a person's body
and change it in its metabolite form, mainly through feces and in very small amounts
through urine, in a few days. Generally tetra, penta- and hexaBDE congeners, can stay
in one's body for years, stored mainly in body fat. Low brominated PBDEs also tend to
be concentrated in milk fat, and can enter the body.
The impact of PBDE exposure on health can occur very seriously, but its toxicity
depends on the compound and the amount of exposure. According to the journal
Polybrominated diphenyl ether as a receptor agonists and antagonists, the LD50 value
of acute toxicity of oral PBDE for pentaDBE = 0.5-5 g/kg body weight in mice. On
chronic exposure, target organs are the liver, kidneys, and thyroid gland, which will also
provide other disorders.
PBDEs are chemically similar to PCBs and both of these compounds have the same
health effects, which are compounds that can be biomagnified and toxic, which means
they will bioaccumulate in the food chain. Laboratory studies in mice show PBDEs to
be neurotoxic chemicals, neurobehavioral toxins, developmental toxins, and
carcinogens. PBDEs have an influence on the thyroid and liver, and interfere with
learning ability, memory, sexual development, and behavior. In addition, PBDEs and
PCBs can survive in the environment and can interact to enhance neurobehavioral
disorder when exposure occurs during critical stages of a baby's brain development.
Problems arising from the use of PBDEs as flame retardants are the use of PBDEs on
products not occurring in chemical reactions, but by physical mixing, this makes
PBDEs able to migrate from products to the environment, there are three stages of
PBDEs migration (Environmental Canada, 2011), namely: a) Manufacturing process; b)
Use and c) Place of disposal
In 2006, the Environment Protection Agency (EPA) summarized studies in animals of

various commercial mixtures and potentially caused liver toxicity, thyroid toxicity,
development of toxicity, and developmental neurotoxicity (EPA, 2006). The results as
follows:
1. Effects on the liver
Studies in mice show the potential for hepatotoxicity in mixed PBDE exposure.
Effects on the liver were observed in studies of various PBDE congeners and
mixtures including alenzymemic microsome induction, liver enlargement, and
degenerative histopathological changes. In mice, dietary exposure reaches 5-10
mg/kg/day (IRDC 1976; IRDC 1977; Norris et al. 1973; Norris et al. 1975; Zhou
et al., 2001; Zhou et al., 2002) and 56 mg/kg/day (Carlson 1980) PBDEs usually
cause enlargement of the liver with or without degenerative changes, and the
incidence and severity of effects are generally related to the dose. More severe
25
effects occur in octaBDE and pentaBDE, as well as the commercial mixture of
DecaBDE (Carlson, 1980; IRDC 1976; IRDC 1977; Norris et al. 1973; Norris et
al. 1975; NTP, 1986; WIL Research Laboratories, 1984; Zhou et al 2001; Zhou
et al, 2002). Several studies show that the commercial mixture of DecaBDE has
several effects on the thyroid. When scientists began studying PBDE, it was
possible that PBDE might have some toxicological similarities with dioxin,
because of the structure of this chemical.
2. Immunological Effects
Disorders of normal immune function can cause the inability of animals to
respond and recover from stress more than recover from disease. Short-term
exposure (14 days) from 18-72 mg/kg/day of commercial pentaBDE mixture in
mice resulted in antibody responses, decreased rat weight (Fowles et al. 1994),
and decreased IgG immunoglobulin production (Thuvander and Darnerud
1999). Short-term exposure of mice of 18 mg/kg/day BDE-47 caused a
significant decrease in the number of lymphocytes and splenocytes (Thuvander
and Darnerud 1999).
3. Effects on reproduction
The EPA Children's Voluntary Chemical Evaluation Program evaluates that
reproductive toxicity is limited to pentaBDE and octaBDE, this data is important
data needed.
4. Cancer
There is some evidence that DecaBDE is carcinogenic in mice. A statistically
significant increase in the incidence of neoplastic liver nodules was seen in male
rats at exposure to 1120 and 2240 mg/kg/day, and in female rats at 2550
mg/kg/day. EPA has classified DecaBDE for possible carcinogens in humans
(US EPA 1995).
2.3.2 Impact on the Environment

TetraBDE, pentaBDE, hexaBDE, heptaBDE, octaBDE, nonaBDE and DecaBDE, which
are found in the form of commercial PeBDE, OBDE, and DBDE enter the environment
in lower concentration that can have direct or long-term effects to the environment or
biodiversity . In the domestic environment, significant PBDE concentrations are
commonly found in foods such as beef, salmon, butter and cheese. PBDEs have also
been found at higher levels, namely indoor dust, sewage sludge, and waste from
wastewater treatment plants. Increased levels of PBDE are detected in the blood of
marine mammals, such as seals.
2.3.3 Impacts on Gender

As said before that PBDEs have been widely detected in breast milk (Deane et al,
2014). PBDE concentrations were reported both as wet weight (picograms per unit
serum) and lipid adjusted (nanograms per gram of lipids). The limits of detection
(LODs) for PBDEs analyses were between 0.2 and 0.7 ng/g lipids for all congeners,
except for BDE-47, which ranged from 0.8 to 2.6 ng/g lipids (Harley et al. 2010). But
26
there are no correlations between breast milk PBDEs with thyroid hormone,
neurodevelopment and reproduction effect. The researchers hypothesized that while
breast milk PBDEs concentrations reflect the accumulated body burden of the mother,
placental PBDEs concentrations may resemble measurements in single blood samples,
reflecting the situation at delivery, but not the long-term exposure.
A study of births from 20 healthy pregnant women in Taiwan found that increased
PBDE (BDE 47, BDE 99, BDE 100, and BDE 209) in breast milk was associated with
significantly reduced infant birth weight, length, and chest circumference (ATSDR,
2015). So we can conclude that PBDEs are affected both in man and woman. But
PBDEs have been shown to affect the male reproductive system (ATSDR, 2015).
However, the research results of female reproductive effects still not consistent. But
PBDEs is more accumulated in breast milk so that it can be transmitted to their children.
Gender mainstreaming is now part of development program policies and planning.

Instruction of President No. 9 of 2000 concerning Gender Mainstreaming in National
Development that planning, drafting, implementing, monitoring, and evaluating national
development policies and programs with a gender perspective. Gender mainstreaming
in the environmental sector is important because environment and gender are two things
that cannot be separated, supported by agreements at the international level where
Indonesia has ratified them. Gender mainstreaming is one of the strategies applied in
national development programs, in addition to good governance, participatory
mainstreaming and sustainable development.
Women in their daily lives tend to be closer to the environment and their existence is
also very vulnerable due to exposure to hazardous chemicals in the home environment
which can be sourced from household appliances such as kitchen utensils, furniture
(sofas, pillows & mattresses, chairs), computer equipment, plastic and so on. This is
similar in managing household waste, the availability of clean water and caring for the
garden. Besides that, women also have the ability to influence the lifestyles of their
families and surrounding communities, thus making women potential for environmental
movements. Problems related to women in managing the environment, can be proven
by the increasing use of chemicals in the household, even to the problem of beauty.
Lack of women's access to various information about the environment and hazardous
chemicals such as POPs and PBDE especially those that make women potentially
exposed to these chemicals due to their limited knowledge and understanding of
hazardous chemicals. So that women become more vulnerable to the effects of pollution
and environmental damage.
Most POPs have been banned in Indonesia, but on a small scale are still found, such as
endosulfan in pesticides, PCBs in transformer oil, and PBDE as a flame retardant. The
results of the 2012 Pusarpedal monitoring still contained organochlorine residues
detected in water, sediment and soil. The main exposure pathway for compounds of
27
POPs is through consumption of water and food, so that it is found in many organisms
at the highest food chain level, including in humans. Humans are exposed to POPs
through food contamination and can cause reproductive disorders, growth, behavior,
nerve function, endocrine and immune systems. Women and children are susceptible to
contamination by POPs. Some cases related to women's vulnerability such as
accumulation of POPs (PBDE) in breast milk (ASI) are found in Indonesia and other
countries in Europe and Africa such as in Nigeria.
2.4 PRODUCTS CONTAINING PBDEs

PBDEs are a type of chemical that is generally used as a flame retardant on various
types of products. There are three homologous of commercial PBDEs, namely c-
PentaBDE, c-octaBDE and c-DecaBDE with decaBDE that is the most widely used.
PentaBDE is generally used for furniture industry and found in foams such as
polyurethane foam on car seats and carpets containing 86% to 99% BDE-47, BDE-99,
BDE-100 and BDE-154. OctaBDE that also has function as thermoplastics is generally
used for electrical connections and automotive products with 70% - 80% hepta and
octaBDE. DecaBDE is usually used in computer cases, carpets and textiles with 98%
deca-BDE (BDE-209). In addition, commercial mixed PBDEs are also used in various
applications of industrial products and household appliances such as plastics, casings in
electrical and electronic equipment (computers, mobile phones), wire, cable insulation,
transportation equipment (automotive), furnitures, textiles, carpets and materials
construction.
PBDEs are not permanently bound to the products in which they are used. Some PBDEs
are semi volatile and may be released from the product. Some opinion says that PBDEs
might be released from physical abrasion and deterioration of the product. PentaBDE
and octaBDE are no longer produced in US on 2013, but exposure continues from old
computer, furniture, fabrics, and other consumer sources that were made before the
discontinuation (Washington State, 2006). An approximate distribution of global
pentaBDE use of 36% in transport, 60% in furniture (polyurethane) and a 4% residual
in other articles is considered to be reasonable and is generally consistent with the
analytical data for different waste streams (UNEP, 2012).
PBDEs are a group of industrial bromine compounds produced from 1975 to 2004 as
flame retardant. Among PBDEs in the market (penta, octa-commercial formulations,
and decaBDEs), commercial penta and octaBDEs contain several derivatives of
homologous PBDEs, such as tetra, penta, hexa, and heptaBDE, which have been
included in the list of compounds PBDEs at the Stockholm Convention. The
formulations of commercial PBDEs have been used in various applications for
industrial products and household appliances such as electrical and electronic
appliances, transportation equipment, furniture, textiles and carpets, and construction
materials. Detailed information relating to commercial penta and octaBDEs including
28
names of synonyms, trade names and composition of mixed compounds can be seen in
Table 2.6.
Table 2.6 Commercialization of PentaBDE and OctaBDE (UNEP, 2012 & Scott
Masten, 2001)
Commercial Pentabromodiphenyl ether Octabromodiphenyl ether
products (PentaBDE) (OctaBDE)
Uses Flame retardant is added to Additives for flame retardants
polyurethane foams found in seats, added to polymers, especially
headrests, ceilings, acoustic ABS, HIPS, PBT, Polyamide-
systems, etc. in automotive polymer plastics found in: case of
products (transportation sector). computers, TVs, CRT
Besides that it is also applied to computers/TV monitors, LCD
other sectors such as furniture, monitors, laptops, printers, mobile
mattresses, rebond materials, phones, photocopiers, etc; in
construction materials, rubber, electronic and electrical equipment
drilling operations, textiles products
(clothes, curtains)
Synonym - Pentabromodiphenyl ether - Octabromodiphenyl ether
- Pentabromodi phenyl oxide - Octabromodi pheny oxide
- Penta bromobiphenyl oxide - Octa bromobiphenyl oxide
- Benzene, 1,1-oxybis, pentabromo - Benzene, octabromo derivative;
derivative - Phenyl ether, octabromo
derivative
Trade name - Bromkal 70-5 DE - Bromkal 7908DE
- Bromkal 70 - DE79
- Bromkal G1 - FR143
- DE71 - FR 1208
- Pentabromprop - Tardex 80
- FR 1205/1215 - Adine 404
- Tardex 50 - Saytex 111
- Tardex 50 L
- Saytex 115
Composition TriBDEs (0,5%), HexaBDEs (11%),
TetraBDEs(33%), HeptaBDEs (43%),
PentaBDEs (58%), OctaBDEs (35%),
HexaBDEs (8%), NonaBDEs (10%),
HeptaBDEs(0,5%) DecaBDEs (1%)
The main consumer Amerika Asia, Amerika
Implementation 1975-2004 1975-2004
periode
Table 2.7 Former uses of c-PentaBDE in materials, the applications and products
Applications Products
Materials
29
Materials
Polyurethane (PUR) Bearing materials, packaging, Furniture, transportation, sound
coating materials, construction insulation, packaging
materials, coating panels, hard
polyurethane (rigid), foam
construction
Textile Coating materials Rear lining and carpet
impregnation, upholstery on
automative products, furniture,
airplanes, underground
material coatings
Epoxy Resin Circuit board, protective layer Computer case, ship interior,
some parts on electronics
Rubber Transport sector Conveyor belt, foamed pipes
for insulation
Polyvinylchloride (PVC) Cable sheet Wire, cables, floor mats,
industrial sheets
Unsaturated (Thermoset) Circuit board, coating Electrical equipment, coatings
Polyesters (UPE) for chemical plants moldings,
military and marine equipment,
construction panels
Paints/ lacquers Coatings Marineand industry lacquers
for protection of containers
Hydraulic oils Drilling oil, hydraulic fluid Offshore, coal mining
In 2009, the United Nation Environmental Protection (UNEP) classified the use of
PentaBDE and OctaBDE based on their content in their resins/polymers, applications
and products. The former use of c-pentaBDE can be seen in Table 2.7. The average
content of PentaBDE in PUR foam is about 3-5% (weight%) for coatings, pads,
mattresses, and carpet coating (ENVIRON, 2003; UNEP, 2010a; see table 5) used in
countries that apply flammability standards for these applications (for example, the
United States and the United Kingdom). Polyurethane (PUR) foam in the transportation
sector may be present at low concentrations that are applied to the seat sofa or armrest /
head which is around 0.5-1 wt% (Ludeka, 2011). If it is estimated that 4% of the use of
PentaBDE in PUR foam is 100,000 tons, it is estimated that the total PentaBDE for
foam processing that has been produced is 2.5 million tons. This value is likely to be too
high than the actual value because the main use of PUR foam on transportation in the
United States turns out to only use PentaBDE at a low level. In addition, reprocessing
contaminated PUR foam and mixing it with other PUR foams results in an increase in
the total quantity of PUR foam contaminated with PBDEs.
The main use of c-OctaBDE is in the polymer acrylonitrile-butadiene-styrene (ABS),

which is around 95% c-OctaBDE available in European countries (EU). The processing
of ABS is primarily intended for electrical and electronic components (EEE) products,
such as cathode ray tube (CRT) and office equipment such as photocopier and office-
scale printing machines. Instead of that, c-OctaBDE also use in high impact polystyrene
30
(HIPS), polybutylene terephthalate (PBT), and polyamide polymers. Although the main
use of this polymer is in electronic goods, some are also used in the transportation
sector. In Table 2.8 it can be seen the use of c-OctaBDE in polymers and applications.
Table 2.8 Former uses of c-octaBDE in materials, the applications and products
Materials
Polymer casing/parts on Computer and TV casing
Acrylonitrile Butadiene electrical and electronic (CRTs), office equipment,
Styrene (ABS) appliances other electronic equipment
Polymer casing/parts in CRTs, office equipment
High Impact Polystyrene electrical and electronic
(HIPS) appliances
Cold-resistant layer Refigerator
Polymer casings Electronic appliances
Polybuthylene Terepthalate Transportation sector Connector in vehicles
(PBT) Household appliances Iron
Textile Furniture
Polyamide Constructions Pipe and plastic foil
From the survey and industrial questionnaires conducted, there are several industries
whose products contain flame retardant. Some use flame retardant PBDEs, but some
also use non-PBDES flame retardant. Some products that contain flame retardant
materials include plastic parts, cables, connectors, resins, PVC, and plastic seeds, ABS
(Acrylonitrile Butadiene Styrene), PP (Polypropylene). The types of flame retardants
used include antimony trioxide, which in general is also added to the PBDE and DE-
83R chemicals. Table 2.9 shows products contained PBDEs and its distribution in the
world.
Table 2.9 Products contained PBDEs (Meunhor, 2011)
Types Distribution Global use of PBDE in 2001 (tonnes)

of Products in the world
Americas Europe Asia Others Total
PBDEs (%)
Penta Polyurethane
foam: chair,
cushions of 11 7,100 150 150 100 7,500
couches, and car
seat
Octa Plastics: small elec
trical devices,
circuit boards, 6 1,500 610 1,500 180 3,790
covering of
wiring, and cable
Deca • Hard plastic:
casing of TV
• Backings to 83 24,500 7,600 23,000 1,050 56,150
textile: Curtain
and carpets
31
DecaBDE product is an additive flame retardant used in a variety of polymer
application. It was used at loadings of 10-15% weight in polymers and always
conjunction with antimony trioxide. The major application for decaBDE is in high
impact polyester (HIPS), which is used in the television for cabinet backs. It was also
used in other polymers, such as electrical and electronic equipment like computers,
connectors, electrical boxes, wire, cable, etc). Another examples for major application
of decaBDE are polypropilene (for electronic), acetate copolymer (athylene-vinyl
acetate and the other copolymers for wire and cable), ethylene-propilene-diene
terpolymer (EPDM) and thermoplastic elastomers (for wire and cable), and polyester
resins (for electronics). Other minor uses include styrenic rubber, polycarbonates,
polyamides, and terephthalates are reported to be used in hot-melt adhesives (ATSDR,
2006).
3 STRENGTHENING THE NATIONAL POLICY AND

REGULATORY FRAMEWORK TO REDUCE UPOPs
AND PBDEs RELEASES FROM PLASTIC
MANUFACTURING, RECYCLING, AND DISPOSAL
PRACTICES
3.1 POLICIES AND REGULATION OF PBDEs IN SEVERAL

REGIONS
The consumption of brominated flame retardant (BFR) on 2001 is shown in Figure 3.1.
The figure shows that Asian countries consumed about 40% of the total PBDEs demand
and only 10% was used by Japan. It is plausible that there are some regions significantly
contaminated by PBDEs in Asian developing countries.
32
Figure 3.1 Consumption of brominated flame retardant in the world and Asian region
on 2001 (Kajiwara et al, 2006)
3.1.1 European Initiatives

Internationally, Sweden was the first to initiate a phase-out of PBDEs in the late 1990s,
followed by the European Union—first phasing out penta-BDE and octa-BDE in 2003
and then deca-BDE in 2006. In 2008, Norway banned the use of deca-BDE in new
consumer products.
a. European Commission
Under the European Union (EU) RoHS (Restriction of the Use of Certain
Hazardous Substances in Electrical and Electronic Equipment) Directive
2002/95/EC (European Parliament and Council of the European Union 2003a),
six substances including pentaBDE and octaBDE commercial mixtures have
been restricted within specified electronic and electrical equipment (EEE)
product types since July 1, 2006. As of July 1, 2008, use of decaBDE mixture
has also been restricted. It means that 7 PBDE congener groups (tetraBDE,
pentaBDE, hexaBDEm heptaBDE, octaBDE, nonaBDE, and decaBDE
congeners) are covered under the Directive as of that date. For PBDEs, the
restriction is for content within products greater than 0.1% by weight (European
Parliament and Council of the European Union 2005) at the homogeneous level
of a product. A draft proposal to update the EU RoHS Directive (Commission of
the European Communities 2008) was published in late 2008, aimed at
increasing the number of product groups affected by the Directive, in addition to
changes in labeling requirements and the streamlining of some requirements.
There are currently no exemptions affecting PBDEs in the Directive
(Government of Canada, 2009).
The European Union’s Waste Electrical and Electronic Equipment (WEEE)

Directive 2002/96/EC (European Parliament and Council of the European Union
2003b) has been in force since January 2003 (initially adopted by a number of
EU countries in August 2005). The WEEE directive aims to prevent the
33
generation of electrical and electronic waste and to promote reuse, recycling and
other forms of recovery in order to reduce the quantity of such waste being
disposed of through land filling or incineration. The WEEE Directive requires
EEE industry producers to take back and recycle their products, with targets for
the amount of recycling achieved in addition to various other requirements. A
requirement of WEEE is that plastics containing brominated flame retardants
(including PBDEs) be removed from the EEE waste and necessary measures be
taken to ensure the resulting waste is disposed of without endangering human
health or the environment.
As a consequence of requirements of both the RoHS Directive and the WEEE

Directives, methods have emerged in Europe for the treatment of plastics to
remove BFRs (including PBDEs). These emerging technologies enable the use
of recycled plastics into new EEE products, while still meeting the PBDE
content restriction of the RoHS.
The European Union Directive 2003/11/EC (European Parliament and Council

of the European Union 2003c) has been in force since August 15, 2004. The
Directive prohibits the use of PentaBDE and OctaBDE commercial mixtures in
all manufactured or imported products at concentrations higher than 0.1% by
mass.
b. Other European Countries

Some other European countries that are not part of the European Union,
including Switzerland, Iceland, Liechtenstein and Turkey have also essentially
adopted the EU RoHS regulations, with some country specific variations.
Norway has enacted regulations restricting the use of decaBDE in all

manufactured products, with the exception of transportation applications (the
restriction applies to concentrations > 0.1% by weight, same as in EU RoHS).
The regulations have been in force since April 1, 2008. In addition, in Norway,
products containing more than 0.25% PentaBDE, OctaBDE or DecaBDE
commercial mixtures are classified as hazardous waste when they are discarded.
3.1.2 American Initiatives

In June 2006, the United States Environmental Protection Agency (U.S. EPA) issued a
Significant New Use Rule (SNUR) that requires notification to the U.S. EPA 90 days
prior to US manufacture or import, for any use, of the commercial pentaBDE and
octaBDE mixtures for prior evaluation. Trends in releases of decaBDE are also being
followed by the United States through the Toxics Release Inventory. In June 2008 the
U.S. EPA released the final Integrated Risk Assessment Information System (IRIS)
assessment of decaBDE. The EPA’s Design for the Environment (DfE) Program, which
began in the early 1990’s, works to provide information on substituting safer chemicals
and provides for assessment of alternatives, including alternatives to PBDEs
34
(Government of Canada, 2009).
In the United States, industry voluntarily ended production of penta-BDE and octa-BDE
in 2004, but deca-BDE is still permitted for use in consumer products. In December,
2009 two U.S. producers of deca-BDE and the largest U.S. importer announced
commitments to end production, importation, and sales of deca-BDE for most uses by
December, 2012.56 Washington, Maine, Oregon, and Vermont are currently
discontinuing the use and manufacture of deca-BDE, and 12 states have banned penta-
and octa-BDE, with other states across the nation aiming for similar legislation
(Washington State, 2006).
Laws have been enacted and legislation introduced relating to PBDEs in many U.S.
States (The Toxics Steering Group and Polybrominated Diphenyl Ethers Subcommittee
2008), including California, Maine, Michigan, New York, Hawaii, Washington,
Maryland, Rhode Island, Oregon and Illinois. These legislative initiatives initially
addressed the PentaBDE and OctaBDE commercial mixtures. However, several states
are now proposing restricted uses of DecaBDE as well.Many of the legislative
initiatives concerning DecaBDE are still under discussion by the States in question.
However, two States, Washington and Maine, have signed into law legislation
prohibiting the use of DecaBDE in certain consumer products:
§ The state of Washington has restricted the manufacture, sale, and use of
DecaBDE in mattresses as of January 2008. That restriction has now been
extended to televisions, computers and residential upholstered furniture,
effective January 2011.
§ The state of Maine has restricted the use of DecaBDE in mattresses and
upholstered furniture as of January 1, 2008. The state will be phasing in that
restriction for televisions and other plastic-cased electronics by January 1, 2010.
Regulations of PBDEs in the United States is shown in Table 3.1.
Table 3.1 Regulations of PBDEs in United State

State Bill Proposed action to regulate PBDEs
California AB 302 Bans the use of penta and octa PBDEs by 2008
Hawaii HB 2013 Bans the manufacture, use or sale of product
containing penta or octaPBDEs by 2006
Massachusets H2275/S1268 This bill will establish a pragmatic, gradual
Act for a approach to reducing health impact from ten
Healthy identified toxic chemicals we are exposed to in
Massachusets everyday life where safer alternatives are available.
Penta-BDE is one of the chemical listed
Michigan HB4406 Regulated release of PBDEs (permit to release,
release guidelines set by state agency)
HB4407 Sets sentencing guide line for releasing PBDEs or
filling a false report
Maine LD1790 Would regulate the sale of products containing
35
brominated chemicals, requires labeling, and
permits fees.
New York S5712/A9207 Prohibits manufacture or sale of products with 0.1%
Penta, Octa, or Deca by mass.
Washington -- Legislature authorized $325,000 for program to
phase out persistent, toxic chemicals including
PBDEs.
3.1.3 Asian Initiatives

Japan has a law concerning the reporting of releases of specific chemical substances and
promoting improvements in their management. Under this law, yearly reports are
required on the volumes of the DecaBDE commercial mixture imported and used and
the quantities released to the environment. The documents related to this rule is attached
in Appendix F. China’s Ministry of Information Industries issued the Management
Methods for the Prevention and Control of Pollution Caused by Electronic Information
Products (sometimes referred to as CRoHS). The ministry is taking a phased approach
to managing the same six substances restricted under EU RoHS. The first phase, in
force since March 1, 2007, requires labeling and disclosure of the content of the
substances within EEE products, but imposes no restrictions. The second phase, which
will include restrictions, has yet to be implemented. Korea implemented a law which
covers end-of-life and EU-RoHS-type restrictions on electronic products and vehicles.
Exemptions, limit values and restricted substances are the same as the EU RoHS
Directive. As of July 1, 2008, a restriction similar to EU RoHS, including for PBDEs,
came into force for a subset of the product types included in EU RoHS (Government of
Canada, 2009).
3.1.4 International Policy

International policies related to POPs that are also toxic hazardous materials have been
included into three conventions namely the Basel Convention, the Rotterdam
Convention and the Stockholm Convention. The Basel Convention is an earlier
convention held before the Rotterdam convention and the Stockholm convention.
The Basel Convention was held on March 22, 1989 in Basel, Switzerland, contained
supervision of cross-border toxic and hazardous waste transfers and disposal, and came
into force in 1992. This convention is based on the discovery of toxic and hazardous
waste waste import activities from abroad to Africa and several other developing
countries in the 1980s. This can happen because around 1970 until 1980 there was a
tightening of environmental regulations in the industry to handle toxic and hazardous
waste well and be environmentally friendly. The regulation has led some industries to
find cheaper disposal options for toxic and hazardous waste, namely to Eastern Europe
36
and developing countries where environmental awareness is still low and law and
regulation is still weak. Indonesia has ratified the Basel convention by issuing
Presidential Decree No. 61 of 1993. In addition, Indonesia also actively participates in
the Conference of Parties (COP) and has the Basel Convention Regional Center
(BRRC).
The Rotterdam Convention was held on 10 September 1998 in Rotterdam, Netherlands

and starts to implement on 22 February 2004. The purpose of this convention is to
contribute to the use of environmentally friendly toxic and hazardous materials by
facilitating the exchange of information regarding its characteristics, making decision
making nationally related to the import and export process and disseminating these
decisions to all countries that are members of the convention. This Convention makes
legally binding obligations for implementing prior informed consent (PIC). Indonesia
has ratified through Law Number 10 of 2013 concerning ratification of the Rotterdam
convention and also actively participating in the Conference of the Parties (COP).
The Stockholm Convention is an international convention held on May 22, 2001 in

Stockholm, Sweden. This convention was held due to the awareness of the dangers of
POPs for health, especially the impact on women and future generations. Indonesia has
ratified it through the Law of the Republic of Indonesia Number 19 of 2009 concerning
Ratification of the Stockholm Convention on POPs.
From the results of the 4th COP held in 2009, it could be seen that the PBDEs for
homologous types of tetrabromodiphenyl ether and pentabromodiphenyl ether (c-
pentaBDE) and hexabromodiphenyl ether and heptabromodiphenyl ether (c-octaBDE)
have been included in Appendix to the Stockholm Convention. Both types of PBDE are
included in Annex A in the Appendix of the Stockholm Convention which means that
both types of PBDE compounds may not be used or must be written off. Meanwhile for
commercial products decaBDE has been included in Annex A (elimination) with
specific exemption in 2017. Thus, it can be concluded that currently all PBDE
commercial products have been registered at the Stockholm convention. Resume of
PBDEs regulation in the world is described below.
1. European Region
• 1990s: Sweden initiated a ban on PBDE
• 2002 : European Union prohibiting pentaBDE and octaBDE: EU RoHS
Directive 2002/95/EC
• 2003 : The European Union banned imports of pentaBDE and octaBDE: EU
RoHS Directive 2003/11/EC
• 2006 : European Union prohibits decaBDE
• 2008 : Norway forbids decaBDE
2. Asia Region
37
• Japan : Have law regarding of reporting certain chemical substances
imported and released into environment, decaBDE is one of them.
• China : Ministry of information industry issued a Pollution Prevention and
Control Management Due Electronic Products (CRoHS) 2007
• Korea : Korea implemented a policy similar to EU RoHS 2008
3. American Region
• 1990s : US EPA released the Design for Environment (DIE), which provide
information on alternative materials PBDE.
• 2004 : Industry in the US ends the production of pentaBDE and octaBDE ;
decaBDE is still allowed.
• 2006 : US EPA issued Significsnt New Use Rule (cord), the rules for
commercial pentaBDE and octaBDE.
• 2008 : The Toxic Steering Group and PBDE Subcommittee was release,
including California, Michigan, New York, Hawai, Washington, Maryland, and
Oregon.
• 2009 : US EPA released the Integrated Risk Assessment Information System
(IRIS) for decaBDE.
• 2009 : two decaBDE largest producer in the US end the production
• 2012 : Washington, Maine, Oregon dan Vermont stop the use of decaBDE
and 12 regions prohibit pentaBDE and octaBDE
4. International
• 2004 : The Stockholm Convention binding on 128 countries and agreed that
pentaBDE and octaBDE is a pollutant.
• 2009 : Risk Management for pentaBDE and octaBDE is drafted
3.2 LIMITATION OF PBDEs THROUGH RoHS REGULATION
3.2.1 RoHS Directive 2002/95/EC (RoHS1)

Restriction of Hazardous Substance (RoHS) directive (2002/95/EC) is a guideline for
limiting hazardous materials to electrical and electronic equipment, electric and
electrical equipment (EEE) which was agreed by European Union (EU) countries in
February 2003 and entered into force on July 1, 2006. Each EU country has its own
laws or regulations regarding RoHS guidelines. The guidelines limit the use of six
hazardous materials in the production of various types of electrical and electronic
equipment. The six hazardous ingredients are as follows: Lead (Pb), Mercury (Hg),
Cadmium (Cd), Hexavalent chromium (CrVI), Polybrominated biphenyl (PBB) and
PBDEs.
The RoHS directive issued by the European Union is motivated by the abundant waste
38
of electrical and electronic equipment containing hazardous chemicals in Europe which
reached around 9 million tons in 2005 and is predicted to increase to more than 12
million tons by 20201. The main objective of RoHS guideline is to protect environtment
and human health from hazardous chemicals contained in electrical and electronic
equipment and provide environmentally friendly of electronic waste treatment2. With
the regulations on RoHS directives, manufacturers of electrical and electronic
equipment who wish to market their products to countries in Europe must be able to
fulfill the requirements set by the RoHS guidelines, namely avoiding the use of the six
elements of the hazardous material1. RoHS1 is closely related to the WEEE Directive
(Waste Electric and Electronic Equipment), directive 2002/96/EC which sets out
methods for collecting, recycling and restoring targets for electricity products and is part
of the legislative initiative to solve the problem of increasing the amount of toxic
electronic waste.
In the Directive RoHS 2002/95/EC concerning restrictions on the use of certain

hazardous materials on electrical and electronic equipment, the scope of the EEE
product is included in this directive. The regulated EEE product is category 1, 2, 3, 4, 5,
6, 7, 10 according to what is regulated in Directive No. 2002/96/EC regarding WEEE as
well as electric light bulbs and lighting at home. This RoHS Directive 2002/95/EC does
not apply to spare parts for repairs or reuse of EEEs that are on the market before 1 July
2016. The EEE category regulated in the 2002/95/EC RoHS directive is:3
• Category 1
Large household appliances such as refrigerators / refrigerators, freezers,
washing machines, air conditioners, electric stoves, microwaves, fans
• Category 2
Small household appliances such as vacuum cleaners, carpet cleaners, hair
dryers, coffee makers, iron, electric cutting machines, wall clocks, watches
• Category 3
Communication and IT equipment such as personal or laptop computers (CPU,
mouse, screen and keyboard), notebooks, printers, copiers, handphones,
facsimiles, telex, calculators
• Category 4
Consumer equipment such as televisions, DVDs, radios, video cameras, audio
amplifiers, musical instruments
• Category 5
Lighting equipment such as fluorescent lamps, light bulbs
• Category 6
Electric tools (exceptions to large-scale industrial equipment) such as saws,
weapons, lathes, blowers, grass trimmers, sprayers, drills
• Category 7
2
http://ec.europa.eu/environment/waste/rohs_eee/index_en.htm diakses pada November 2016
3 Directive 2002/95/EC of the European Parliament And of The Council of January 2003 on the
restriction of the use of certain hazardous substances in electrical and electronic equipment , Official
Journal of Europen Union
39
Toys and Sports Equipment such as electric trains, electric cars, treadmills,
video games
• Category 10
Automatic machines such as ATMs, vending machines
Start on 1 July 2006, the new EEE products being marketed from all EU membres, must
do not contain lead, mercury, cadmium, hexavalent chromium, PBB or PBDEs.
However, this does not apply to equipment containing lead, mercury, cadmium and
hexavalent chromium, which is included in the Annex RoHS1. In article 4 paragraph 1
of the RoHS2 (section "prevention"), it is stated that all member countries must ensure
that EEE on the European market includes cables and spare parts for repairs, reuse,
renewal of functions and capacity not containing hazardous ingredients contained in
annex II, namely lead, mercury, cadmium, hexavalent chromium, PBB and PBDEs
along with their maximum concentration (can be seen in table 1). It must also be applied
to medical equipment and monitoring and control instruments marketed from July 22,
2014, in vitro diagnostic medical devices marketed starting on July 22, 2016 and
industrial monitoring and control instruments marketed starting on July 22, 20171.
3.2.2 RoHS Directive 2011/65/EU (RoHS2)

In December 2008, the European Commission (EC) submitted a revision or important
change to the RoHS 2002/95/EC guidelines on electrical and electronic equipment to
overcome the rapid increase in EEE production and the waste formed. The goal is to
increase the amount of electronic waste that can be processed with the right technology
and to reduce the volume of waste discharged into final disposal.
The aim of the RoHS revision is also to reduce the administrative burden and ensure
harmony with new policies and legislation, such as chemicals and a new legislative
framework for marketing products in the European Union. In addition, the main purpose
of the reform of the RoHS1 is to protect human health and the environment.
Amandement in the RoHS1, also known as RoHS 2 (directive 2011/65/EC) and has
been published in the official European Union journal on July 1, 2011 and start to be
used on January 2, 2013. The most important amend that exist in RoHS2 is guidelines
CE marking. CE marking is a confirmation sign that is very important for each product
that will enter the European market segment or more or less the same as the Indonesian
National Standard (SNI) mark in Indonesia. The word CE comes from the French
language Communaute’Europe’enne, which means European conformity. CE marking
indicates that a product is feasible and has met the standards when the product is used
by consumers of European Union countries in terms of safety, environment and health4.
In the RoHS2, the hazardous material included in the annex is the same as the
4Directive 2011/65/EU of the European Parliament And of The Council of 8 Juni 2011 on the restriction
of the use of certain hazardous substances in electrical and electronic equipment
40
hazardous material present in the RoHS1 and there is a maximum concentration value
allowed in the EEE in the Annex II. The maximum concentration of the six hazardous
materials regulated in RoHS2 and their uses and effects on health can be seen in Table
3.21,5. In addition, there are four new hazardous materials to be submitted for inclusion
in the RoHS2 scope, namely6:
1. Hexabromocyclododecane (HBCDD), which is a type of brominated flame
retardant
2. Bis (2-ethylhexyl) phthalate (DEHP), which is commonly used as a plasticizer
3. Butyl benzyl phthalate (BPP), which is commonly used as a plasticizer
4. Dibutyl phthalate (DBP), which is commonly used as a plasticizer
Table 3.2 Materials regulated in the RoHS2 directive concerning general use, health
impacts and maximum permissible concentrations
Maximum
Health
No Materials Function General use concentration
impacts
(ppm)
1. Lead (Pb) - Simplify the - Electronic - Damage to the <1000
printing process Komoponen nervous system
- Simplify - Rubber hardener - Weakness in
fabrication - Paint pigments the fingers of
- Acid resistance - Lubricants the hand / foot
and - Soldering band
electrochemical material - high blood
reaction - Mixed coatings pressure
- Making corrosion - brain and
resistant pipes kidney damage
- Cable sheath - anemia
- Cathode ray tube
glass
- Lead-acid
batteries
2. Mercury (Hg) - Durable and - Fluorescent lamps - Kidney <1000
produces more - Rust pigments damage
lumens per watt - Metals in the - nervous
- Good prisoner production of system damage
- Efficient electrical and - lose weight
thermal electronic - Diarrhea
conductivity equipment that - Stiff muscles
are concentrated - Defects
in batteries
- Paint pigments
- Car battery
- Thermostats
3. Cadmium (Cd) - Stabilizer - on electronic - Indigestion <100
material for equipment - Lung disorders
5 http://ec.europa.eu/environment/chemicals/reach/pdf/publications/chemicals_health.pdf diakses pada

November 2016
6 Directive 2011/65/EU of the European Parliament And of The Council of 8 Juni 2011 on the restriction
41
Maximum
Health
impacts
(ppm)
plastic and - Car battery - Diarrhea
rubber - Paint pigments - Ginkal damage
- Corrosion - Coating / plating - High blood
protection for material pressure
iron / metal - NiCd batteries - liver disease
surfaces - Electrodes
4. Hexavalent - resistance to - Paint - Sneeze <1000
Chromium(Cr VI) heat and rust - Ink - Itchy
- Useful for - Anti-rust - Liver and
pigments - paint dryer kidney damage
- Final process in
iron / metal
- Wood
preservative
5. Polybrominated - Flame retardant - Casing on - Skin disorders <1000
biphenyl (PBB) - Increase plastic electronic and - Damage to the
resistance electronic nervous
equipment system
- Liver and
kidney damage
- Decreased
immune
system
6. Polybrominated - Flame retardant - Casing on - Skin disorders <1000
Diphenyl Ethers - Increase plastic electronic and - Damage to the
(PBDEs) resistance electronic nervous
equipment system
- Liver and
kidney damage
- Decreased
immune
system
7. Bis(2-Ethylhexyl) - Plasticizer - PVC products - Cancer <1000
phthalate (DEHP) - Skin irritation /
allergy
- Impaired
growth and
bone
8. Benzyl butyl phthalate - Plasticizer - PVC products - Cancer <1000
(BBP) - Skin irritation /
allergy
- Impaired
growth and
bone
9. Dibutyl phthalate - Plasticizer - PVC products - Cancer <1000
(DBP) - Skin irritation /
allergy
- Impaired
growth and
bone
42
Maximum
Health
impacts
(ppm)
10. Diisobutyl phthalate - Plasticizer - PVC products - Cancer <1000
(DIBP) - Skin irritation /
allergy
- Impaired
growth and
bone
The scope of electronic products regulated in the RoHS2 is the same as the category
regulated in RoHS1, but there are three additional product categories in Annex I,
namely category 8 for medical equipment, category 9 for monitoring and control
instruments including industrial monitoring and control instruments and category 11 for
other EEE products that are not included in all categories. European Union must ensure
that the EEE outside the scope of the RoHS1 directive, but cannot fulfill the
requirements on the RoHS2 directive can continue it’s marketing until July 22, 20097.
On June 4, 2015, the European Union commission issued a new directive, namely the
Directive (EU) 2015/863 to amend Annex II RoHS2 directive (Directive 2011/65 / EU)
by adding four chemicals of phthalates where three of the phthalates chemicals had
previously been submitted at the beginning of the issuance of the RoHS2. So now, there
are 10 hazardous chemicals regulated in RoHS2.
3.2.3 Implementation of RoHS Regulations in Several Countries

Since 2006, other countries outside the European Union have adopted RoHS
regulations, which are referred to as RoHS-like in California and New Jersey in the
United States, China, South Korea, Japan, India, and Turkey. The application of RoHS
regulations in several countries can be seen in Table 3.3.
7Directive 2011/65/EU of the European Parliament And of The Council of 8 Juni 2011 on the restriction
43
Table 3.3 Implementation of RoHS regulation in several countries
Name of RoHS- Start from
No. Country Informations
like
1. California, USA California RoHS8 January 1, 2007 - Limiting 4 hazardous
(Senate Bill 20 dan chemicals with their
Senate Bill 50) maximum concentration,
namely:
1. Lead: 0.1%
2. Mercury: 0.1%
3. Minimum: 0.01%
4. Hexavalent Chromium:
0.1%
- There are 8 EEE scopes
regulated in Senate Bill (SB)
20 including CTR devices,
CTRs, monitor computers
containing CRT, LCD, LCD
and desktop, CRT TV, LCD
TV, Plasma TV
- In SB 50, the scope of EEE is
regulated more broadly for
products produced for retail
sales
2. New Jersey, USA New Jersey’s January 1, 2011 - Limiting four hazardous
“ Electronic Waste metals, the same as those in
Recycling Act the EU directive RoHS on
(EWRA)” (Senate EEE
- This regulation requires TV
Bill 2144)9 companies, computers and
computer monitors to pay fees
and sends a plan to the
Department of Environmental
Protection (DEP) which
details how the company will
recycle EEE produced and
sold
3. China China RoHS10 - RoHS1 start - In China, there is an increase
from March 1, in the scope of EEE products
200711 from RoHS2, namely that
electronic information
- RoHS2 start products (EIP) will initially be
from July 1, expanded into electrical and
2016 electronic products (EEP).
- Hazardous materials regulated
8
California’s RoHS Law dari website https://doclib.ul.com/.../california-rohs-law_07_0
diakses pada Januari 2017
9
RoHS in Other Countries dari web www.sgs.com/-/.../sgs-crs-ee-rohs-brochure-2pag...
10 http://www.chemsafetypro.com/Topics/Restriction/China_RoHS_2_vs_EU_RoHS_2.html diakses pada
Januari 2017
11 http://www.rohsguide.com/rohs-future.htm diakses pada Januari 2017
44
like
on China RoHS2 are the same
as China RoHS1, namely:
1. Lead: 0.1%
2. Mercury: 0.1%
3. Minimum: 0.01%
4. Hexavalent Chromium:
0.1%
5. UN: 0.1%
6. PBDE: 0.1%
The six hazardous materials
are the same as EU RoHS.
- There are two steps to be
taken in implementing China
RoHS2, namely:
1. The first step is that all
regulated EEEs will self-
declare information on
chemicals that are restricted
based on relevant standards.
2. The second step, EEP that is
registered in the compliance
management inventory must
meet the chemical threshold
according to the relevant
standards. The inventory of
regulated EEP has not been
published and will be
published in the future.
4. Japan J-MOSS (The July 1, 2006 - J-Moss regulation regulates
Marking of that some electronic products
Presence of the with concentrations of
hazardous substances
Specific Chemical
contained in them exceeding
Substance for the regulated concentration
Electrical and must be given a "warning
Electronic label".
Equipment) 12 - J-MOSS does not limit the
use of hazardous chemicals
(RoHS) but through this
regulation has spurred
Japanese manufacturers to
label "lead free" in
accordance with the EU
Directive RoHS
5. South Korea The Act for Januariy 1, 2008 - This regulation limits some
Resource Recycling and has been hazardous chemicals for EEE
of Electrical and amend on 2011 and vehicles.
Electronic the same as EU - EEE that is regulated are TVs,
refrigerators, mobile devices,
12 RoHS in Other Countries dari web www.sgs.com/-/.../sgs-crs-ee-rohs-brochure-2pag... diakses pada
Januari 2017
45
like
Equipment and Directive household washing machines,
Vehicles (Korean RoHS2 computers, audio equipment,
RoHS)13 air conditioners, printers,
copiers and fax machines.
- The scope of regulated
vehicles is passenger cars,
vans and trucks less than 3.5
tons.
- In the scope of EEE, the
Korean RoHS regulates the
limitation of six hazardous
chemicals as well as the EU
directive RoHS and their
concentrations.
- On vehicle scopes, the Korean
RoHS regulates four metal
restrictions in accordance
with EU directive RoHS,
namely:
1. Cadmium: 0.01%
2. Mercury: 0.1%
3. Lead: 0.1%
4. Hexavalent chromium:
0.1%
- Producers and importers of
EEE and vehicles are required
to make a self-declaration of
their self-compliance with the
threshold of hazardous
substances or the so-called
"Declaration of Compliance".
The method of declaration is
to notify product information
to the electricity and
electronic guarantee system
(www.ecoas.or.kr) or publish
a declaration on the
company's webpage.
6. India India RoHS14 October 1, 2016 - The objective of this
regulation is to create
effective mechanisms to
regulate the production,
collection, storage,
transportation, import, export,
environmentally friendly
recycling, processing and
disposal of e-waste.
- Specifically this regulation
13 http://www.chemsafetypro.com/Topics/Korea/Korea_RoHS_WEEE.html diakses pada Januari 2017

Januari 2017
46
like
contains a chapter on limiting
hazardous chemicals (RoHS)
in EEE manufacturing. This
regulation regulates
information technology and
telecommunications
equipment as well as
electrical and electronic
consumers. However, lead
acid batteries and radioactive
waste are excluded.
7. Turkey Turkey’s For EEE start on - This regulation prohibits the
Regulation on the 2009 and May production and import of EEE
restriction of 2012 for WEEE containing six hazardous
chemicals regulated in the EU
hazardous
directive RoHS.
substances in EEE - Manufacturers must keep
(Turkey RoHS)15 documentation for 5 years
indicating products sold to the
market comply with
applicable regulations.
Manufacturing also has to
send declasration of
conformity / compliance to
the Turkish government every
year.
3.3 ANALYSIS ON THE IMPLEMENTATION OF REGULATORY

OF RoHS IN INDONESIA
Conformity assessment is the process of evaluating the suitability of a product against
applicable regulations, before the product is allowed to circulate in the market. This
conformity assessment must meet all regulations in force in the country and cover the
testing, inspection and certification processes. The procedure for each product is
determined in the regulations for the product. The conformity assessment aims to show
that the product complies with all requirements in the applicable regulations. In
addition, it is also intended that the applicable procedures ensure consumer trust, public
authority and manufacturing with regard to product conformity.
In practice, product regulation describes procedures for conformity assessment for each
product and manufacturing or industry can choose between different conformity
assessment procedures. In addition, the assessment is carried out by manufacturers and
if applicable regulations require conformity assessment, the Conformity Assessment
15 https://chemicalwatch.com/14164/global-regulation-of-substances-in-electronics diakses pada Januari
2017
47
Body is needed in the process of evaluating the suitability of a product. The Conformity
Assessment Body (CAB) in several European countries for RoHS are three, namely:
Product Certification Institute, Laboratory and Authorized Body. For electronic
products, there are Indonesian National Standards, namely SNI IEC 62321: 2015, which
regulates the procedure for measuring six RoHS hazardous chemicals one of which is
PBDEs. The SNI also regulates the requirements for laboratory testing facilities that
must be met.
3.3.1 International Standards and Indonesian National Standards

The International Electrotechnical Commission (IEC) 62321:2008 is an international
standard that specifically determines/measures the level of lead (Pb), mercury (Hg),
cadmium (Cd), hexavalent concentration of chromium (Cr VI) contained in organic and
inorganic compounds and two bromintaed flame retardant types, namely
polybromintaed biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs)
contained in electrotechnical products. This standard refers to samples as objects to be
processed and measured. The nature of the sample and how to obtain it is defined by the
entity that performs the testing and not by this standard.
In Indonesia, the IEC 62321:2008 standard has been adopted as the Indonesian National
Standard, namely SNI IEC 62321:2015. This standard regulates the procedure for
measuring six hazardous substances in electrotechnical products, one of which is
polybrominated diphenyl ethers (PBDEs). The instrument used for PBDEs testing is
Gas Chromatography-Mass spectrometry (GC-MS) for the determination of
monobrominated to decabrominated diphenyl ethers in electrotechnical product
polymers, which have PBDEs content in the range of 100 mg/kg to 2,000 mg/kg and as
high as 100,000 mg/kg for decaBDE. This method has been evaluated for PS HAI
(synthetic rubber, high impact, ABS, and a mixture of PC and ABS. PBDEs compounds
are determined using Soxhlet polymer extraction by separation using GC -MS
according to quality and quantity using single or selected SIM monitoring16.
Standards can be accepted if using a quadrupole density spectrometer. A high resolution

GC-MS will require the use of other suitable standard substances, which have a mass
and time elution similar to that of an analyte. 13C-labeled nonaBDE and 13C-labeled
decaBDE are recommended for high mass PBDE. The recommended standard is
sufficient for measuring mono-octaBDE concentrations. Because of its low mass and
high volatility, this standard may not be sufficient for measuring decaBDE and
nonaBDE concentrations. Up to now, the best calibration standard for certain analytes is
13
C-labeled decaBDE or one of 13C-labeled nonaBDE1.
Some laboratories, which operate at high volumes and low price, can find this labeled
16 Standar Nasional Indonesia (SNI) IEC 62321 : 2015 Produk Elektronika, Penentuan kadar enam unsur
yang diregulasi (timbal, merkuri, kadmium, kromium heksavalent, bifenil polinrominat, eter difenik
polibrominat
48
material too expensive. A potential cheaper material is decaBB (BB 209). BB 209 has a
high mass (943.1 g/mol vs. 959.1 g/mol for decaBDE or 864.2 g/mol for nonaBDE),
which elutes just before three nonaBDEs in a typical DB-5 column. The existence of a
significant amount of decaBB in the sample can be easily determined by monitoring the
peak area of this standard, and comparing it with what is expected from the number of
decaBBs. The use of recommended labeled standards or decaBB must be limited only to
the analysis where only the analytes to be considered are decaBDE and or nonaBDEs.
With additional experiments it is possible to identify alternative standards that have high
mass and low volatility that need to quantify nonaBDE and decaBDE17.
3.3.2 Readiness of Internal Conformity Assessment Institution

In general, Conformity Assesment Body (LPK) is divided into two groups, namely
Product Certification Body (LSPro) and Testing Laboratories. From a total of 51
accredited LSPro, currently the Center for Materials and Technical Products (B4T) has
been accredited by RoHS certification by the National Accreditation Committee (KAN).
Surveys have been carried out in several laboratories in Indonesia to verify PBDE
testing facilities contained in the laboratory along with its accreditation status. Based on
the survey results, the ability of the laboratory to conduct PBDE testing with facilities
and methods in accordance with SNI IEC 62321: 2015 standards can be seen in Table
3.4.
Table 3.4 Potential laboratories in Indonesia to conduct PBDEs testing

No. Laboratorium Accreditation status Ability
Able to do PBDE testing with

1. PT. SGS Indonesia Accredited
continuous samples received
PT. Sucofindo SBU Able to do PBDE testing with

2. Accredited
Laboratorium Cibitung continuous samples received
PBDE testing is used for

PT. Panasonic
3. Accredited screening purposes so that it has
Manufacturing Indonesia
not followed the IEC method
Able to do PBDE testing, but at
Pusat Pengujian Mutu
4. Accredited this time PBDE is not within the
Barang
scope of testing services
Has the main instrument for
5. PT. Intertek Utama Services Accredited
PBDE testing
Laboratorium Pengujian
Produk Garmen, Tekstil dan Able to test PBDE with in house
6. Accredited
Hardline PT Intertek Utama method
Services
17 Standar Nasional Indonesia (SNI) IEC 62321 : 2015 Produk Elektronika, Penentuan kadar enam unsur
yang diregulasi (timbal, merkuri, kadmium, kromium heksavalent, bifenil polinrominat, eter difenik
polibrominat
49
No. Laboratorium Accreditation status Ability
Laboratorium Kimia
7. Instrumen Jurusan Kimia Not accredited
PBDE testing
UPI Bandung
Laboratorium Balai Besar Has the main instrument for
8. Accredited
Tekstil PBDE testing
Balai Besar Pulp dan In the process of Has the main instrument for
9.
Kertas accreditation PBDE testing
Doesn’t have the main
10. Baristand Surabaya Accredited instrument for PBDE testing
Laboratorium
11. Instrumentasi ITB Jurusan Not accredited
PBDE testing
Teknik Kimia
UPT Laboratorium
Lingkungan Badan In the process of re- Has the main instrument for
12.
Pengendalian Lingkungan accreditation PBDE testing
Hidup Kabupaten Bandung
Pusat Penelitian dan Doesn’t have the main
13. Accredited
Pengembangan Pemukiman instrument for PBDE testing
14. PT. Syslab Accredited
PBDE testing
15. PT. ALS Indonesia Accredited
PBDE testing
Balai Besar Kulit dan Doesn’t have the main
16. Accredited
Plastik instrument for PBDE testing
Balai Besar Kerajinan dan Has the main instrument for
17. Accredited
Batik PBDE testing
Balai Besar Kimia Has the main instrument for
18. Accredited
Kemasan PBDE testing
In the process of re- Has the main instrument for
19. Balai Besar Industri Agro
accreditation PBDE testing
Balai Besar Pencegahan Doesn’t have the main
20. Accredited
Pencemaran Industri instrument for PBDE testing
21. BP Batam Not accredited
PBDE testing
In the process of re- Has the main instrument for
22. PT.Mattel Indonesia
accreditation PBDE testing
Accredited (as a
PUSARPEDAL (Pusat
National Referral Has the main instrument for
23. Sarana Pengendalian
Environment PBDE testing
Dampak Lingkungan)
Laboratory)
The main instrument needed for PBDE testing is GC-MS and 90% of the laboratories
surveyed have it. However, from 23 laboratories, only 4 laboratories were declared
capable of fully conducting PBDE testing, namely PT. Intertek Utama Servis, PT. SGS
Indonesia, PT. Sucofindo and BP Batam. For the Central Laboratory of Material and
Technical Products (B4T) and BBPK, PBDE testing can be carried out but is limited to
screening. The main obstacle faced is the availability of expensive standard PBDE
50
chemicals. In addition there are no regulations that encourage the implementation or
testing of PBDE so that for some laboratories that conduct PBDE testing, the sample is
waited until it reaches a certain number and can only be tested.
Even voluntary regulations cannot encourage producers to carry out Quality Assessment
(QA) on their products. Trends that occur, namely the laboratory will complement the
equipment if the market demands completeness. From the Focus Group Discusiion
(FGD) I that has been done, suggestions from participants are to multiply the test
laboratories that can facilitate PBDE testing because usually the testing time is long
(around 3 months). However, what needs to be emphasized is that the price of local
products will not be much more expensive (less competitive) with imported products
because testing must be done first.
3.3.3 Study of RSNI in the Context of Restricting the Use of PBDEs

3.3.3.1 Maximum Concentrations of PBDEs Implemented in Several Countries
Regulation about maximum consentration of PBDEs has been implemented in several
countries related to RoHS regulations that have been regulated in the country. This is
because PBDE is one of the chemicals in the RoHS in the regulation of EU RoHS
directive and the directive is also adopted by most other countries. Most countries set
the maximum PBDE concentration standards available in EEE products, which is equal
to 0.1% as stipulated in the EU RoHS2 directive. In Table 3.5 can be seen the
implementation of PBDE standards that are applied in several countries.
Table 3.5 Maximum concentrations of PBDEs in several countries

Maximum concentration of
No. Country Regulation about PBDEs PBDE in the products
1. China China RoHS 0,1 % (1000 ppm)
2. South Korea The Act for Resource Recycling of 0,1 % (1000 ppm)
Electrical and Electronic
Equipment and Vehicles (Korean
RoHS)
3. India India RoHS 0,1 % (1000 ppm)
4. Turkey Turkey’s Regulation on the 0,1 % (1000 ppm)
restriction of hazardous substances
in EEE (Turkey RoHS)
5. Thailand Thailand RoHS 0,1 % (1000 ppm)
6. Singapura Singapura RoHS 0,1 % (1000 ppm)
7. Vietnam Vietnam RoHS 0,1 % (1000 ppm)
3.3.3.2 Identification of PBDEs Limit based on the National Standardization Agency

The results of the study of the Indonesian National Standard (SNI) related to the
limitation of the use of PBDE have been stated in SNI for several products shown in
Table 3.6.
Table 3.6 PBDE Restrictions for some products based on SNI
51
No. Products Information
Almost all electronic products: audio, video and electronics, are equipped
with compliance with safety requirements. Based on SNI 04-6253-2003,
1. Electronics one of the safety requirements needed for fire safety when there is a short
circuit. Therefore on an electronic product a flame retardant is added to
inhibit the fire when a short circuit occurs.
Same with electronic products, electrical products are also equipped with
safety requirements, one of them if there is a fire trigger, then the
2. Electrical electricity product must be able to minimize the fire. Therefore, in the
electrical product flame retardant is added to inhibit flame if there is a
source of ignition
3. Fire retardant Fire retardant paints will certainly use materials that make the product
paint resistant to fire. One of them is using flame retardant chemicals that can
inhibit flame if there is a trigger for the emergence of fire.
4. Wood paint Furniture made from wood is one product that is easy to burn. Therefore,
(furniture) in this furniture, paints used are usually flame retardants which aim to
reduce the risk of fire if there is a source of ignition.
5. Plastic products In general, plastic products including food grade are flammable products.
(food grade) Therefore, it is necessary to add flame retardant that can inhibit flame if
there is a source of ignition.
6. Automotive Some automotive components that already have SNI are the main lights
interior (car) for cars and motors vehicles, rear view mirrors, tires, and safety glass.
For safety requirements, this automotive interior is equipped with
components that contain flame retardant.
7. Textile based Textile-based products are flammable products. Because of this in the
product production process, flame retardant is added.
8. Electric toys At present, electric toy products for security requirements are regulated
by SNI IEC 62115: 2011. One of the security requirements that must be
fulfilled is heat and fire resistance. Therefore, in this product flame
retardant is added to inhibit the flame/fire.
9. Foaming Foaming products such as car seat are made of foam and also textile
product materials that are flammable if there is a source of ignition. Therefore, in
this car seat product flame retardant is added to inhibit flame if there is a
source of ignition.
3.4 ROADMAP STUDY ON PBDEs IN INDONESIA
3.4.1 Literature Study and Survey on the PBDEs Roadmap

The results of the literature study and internal meetings indicate that there is no
information on the amount of production, use, export and import of commercial
pentaBDE and octaBDE obtained. The cumulative estimation of PBDEs content
resulting from the calculation of the imports of CRTs plus local production and reduced
total exports in 1975-2012 was 112,197 kg for heptaBDE and 28,702 kg for hexaBDE.
52
The estimated content of PBDEs is based on data on the number of domestic car sales in
1975-2004 and the number of imported used cars is 19,697 kg for tetraBDE, 34,619 kg
for pentaBDE, 4,775 kg for hexaBDE and 298.7 kg for heptaBDE (KemenLH, 2014).
Literature study indicates that there is no information about contaminated locations and
waste of PBDEs in Indonesia. However, the final place for electronic waste storage (e-
waste) such as recycling sites, waste disposal containing electronic waste, and CRT TV
and computer dust can be a potential location for contamination of PBDEs. The results
of laboratory analysis show that CRT TV casings and polymer acrylonitrile butadiene
styrene (ABS) taken from locations handling electronic waste have detected PBDEs
(114 mg/kg on ABS polymer, and 320−330 mg/kg on CRTs TVs for heptaBDE)
(Sudaryanto and Ilyas, 2014).
Regarding regulations and guidelines on the release of PBDEs from contaminated

locations including the study of disposal of piles, until now there has been no specific
guidance aimed at PBDEs management policies in Indonesia. Also, there is no
established threshold for comparing the threshold of PBDEs in the environment, biota
and humans.
From the results of surveys that have been conducted for vendors and the plastic and
electronics industry, it can generally be said that all companies visited all said that they
did not use PBDEs as a flame retardant and did not know about PBDEs. However, when
we looked at the types of raw materials used such as: PP, PS, and PVC, they are all raw
materials contained of PBDEs. Only at PT. Bali Foam Nusa Megah, which says it uses a
flame retardant, but not PBDEs that is used but the type of FIROL, which is a
Phosphorous based-flame retardant.
3.4.2 Draft of PBDEs Roadmap in Indonesia

From the literature study to date, in general the PBDE roadmap in Indonesia is shown in
Figure 3.2, where legislation on the basis of EPR preparation and PBDE reduction
already exists, namely PP No. 74 of 2001, Law No. 18 of 2008, and Law No. 19 of
2009. Then data for PBDE use only existed from 1975-2012. For now until 2022 the
EPR concept will be created and socialized to stakeholders and will be implemented in
2022. The targets to be achieved after the implementation of EPR are made in a 5-year
period, as follows:
1. First five years (2022-2027)
• There is no products with the addition of virgin pentaPBDE
• The EPR concept scenarios 2 and 3 are already running
2. The second five years (2027-2032)

• There is no use of the product with the addition of virgin okta-PBDE •
• The EPR concept scenarios 2 and 3 are already running
53
Figure 3.2 PBDEs roadmap in Indonesia (dirubah ke English gambarnya)
3.5 EXTENDED PRODUCER RESPONSIBILITY (EPR) CONCEPT

DEVELOPED
A study and analysis has been conducted on the application of the Extended Producer
Responsibility (EPR) by Institut Teknologi Sepuluh Nopember (ITS), Surabaya with
East Java region as the case. EPR is an environmental protection strategy through
reducing the impact of the existence of PBDEs from a product, involving product
makers (producers) responsible for the overall product life cycle and especially for
recovering, recycling and final disposal. EPR is a strategy designed in an effort to
integrate environmental costs into the production process of an item until the product
cannot be used anymore so that environmental costs become a component of the market
price of the product. With the EPR strategy, producers must be responsible for the entire
life cycle of the product and/or packaging of the products they produce. Companies that
sell and/or import products and packaging that have the potential to produce waste must
be responsible, both financially and physically, for products and/or packaging whose
useful life is over.
Types of Waste are grouped into: 1.) electronic waste originating from used products or
packaging, containing PBDEs, and 2.) plastic raw materials derived from used products
or packaging, containing PBDEs. Based on the producers, studies were conducted on
electronic producers containing PBDEs, cable producers and producers of products
suspected of containing PBDEs. In determining which producers must implement EPR,
there are several obstacles, such as: 1) companies do not want to be open when filling
out questionnaires that they use PBDEs or not; most said they did not know and did not,
although in the literature it was said that the product used PBDEs; 2) there has been no
54
testing laboratory that able to measure PBDEs content in the product suspected of
containing PBDEs. So far there has only been a screening result that these products
contain bromine (Br).
3.5.1 Regulation Related to EPR

Regarding waste handling by producers, Article 14 and 15 of Law No. 18 of 2008
concerning Waste Management explicitly mentions the roles and responsibilities of
producers in waste management. The two articles are the legal basis for the government
to ask the roles and responsibilities of producers in efforts to reduce and handle waste.
Through the products and packaging of the products produced, is one of the sources of
waste production.
• Article 14: Every producer must include labels or signs relating to the reduction
and handling of waste on their packaging and/or products.
• Article 15: Producers must manage packaging and/or product which cannot or
are difficult to decompose by natural processes.
Article 15 of Law No. 18 of 2008 is the legal basis required (mandatory basis) for the
implementation of EPR for products or packaging that will be processed further. In this
law it can be seen that the government has stressed that waste management is not only a
government obligation. Producers of waste have a responsibility in managing waste.
Example for the implementation of this Law is consumers can reimburse or request
repayment from the initial expenditure for the purchase of a product that leaves useless
items such as plastic waste. However, until now there has been no preparation for the
implementation of this Law. Until now the condition of waste management in Indonesia
still does not meet expectations. There are problems in waste collection, lack of public
awareness to manage waste from the source, and the weakness of the government in
managing and supervising, especially supervising producers of products that are
difficult to decompose by nature, it cannot be denied that this country is full of waste.
For this reason, there needs to be evaluation and corrective steps in implementing this
Law.
3.5.2 Stakeholders, Scenarios and Financing Schemes

3.5.2.1 Stakeholders
Stakeholders in implementing EPR concepts and their respective roles can be described
as follows:
1. Manufacturer: Association of plastic entrepreneurs or importers/distributors,
which functions as an intermediary in facilitating producer compliance.
2. Government/Ministry: issue regulations, conduct audits and monitoring
3. City government: regulates and oversees the formation of collection points
(“depo”) and local collection processes
4. Waste operator (“TPS/TPA” manager): is the main part of EPR implementation
5. Department of Industry and Trade (“Disperindag”): which has a list of producers
and information about sales volumes, information about waste collection, and
55
determining the obligations of each producer.
6. Retailers (stores): provide sales volume information
7. Plastic Recycling Entrepreneurs: need information about how does a healthy
recycling process
8. Indonesian Plastic Recycling Association (ADUPI): coordination, socialization
and gathering, financial sharing needed
9. NGO Environment and Consumer protection: Observer, socialization and give
suggestion.
3.5.2.2 Scenarios
There are three types of scenarios for implementing EPR in Indonesia as describe as
follows:
1. Evaluation and re-management of the production process followed by substitution
of flame retardant containing PBDEs with those not containing PBDEs
a. The company immediately replaced the use of flame retardants containing
PBDEs with other retardant materials that do not contain PBDEs
b. Imports of electronic are required not to contain PBDEs
2. EPR individually from the company concerned: withdrawing products and/or
packaging that are expired and managed through reuse and recycle, or used as a
source of energy (take back, trade in)
3. EPR is collectively integrated with EPR for e-waste, with special incentives for E-
waste containing PBDEs with several possibilities:
a. Companies provide incentives to scavengers/collectors so that their products
can return to the company or be destroyed properly
b. Delegating these responsibilities to third parties/associations/NGOs
From those three scenarios it cannot be said which scenario is better, because the
application is different from each other. For example for the first scenario, this is more
about research and development (R&D) and can be applied to all industries that use
PBDEs. They must looking for substitution of PBDEs or change the production process.
For the second scenario, this can be done by industries that already have their own
product recycling schemes or in collaboration with third parties. For example, what
already exists in Indonesia is a system of trade in of certain electronic products. While
the third scenario, this can be applied to e-waste that has been circulating; it cannot be
sorted by brand but can be grouped by type. For example CRT TV does not need to be
grouped by brand but enough all types of CRT TV are put together. Thus all CRT TV
manufacturers are jointly responsible for the e-waste. So the three scenarios need to be
done together in an effort to reduce the use and distribution of PBDEs in the
environment.
Of the three EPR concepts above, several countries in the world have implemented
these three scenarios. For in Indonesia, the first scenario is rather difficult to implement
because we have to look for another flame retardant and need research if we want to
change the process production. For the second scenario, producers/companies need to
56
have awareness and sense of responsibility to implement it. The third scenario is most
likely to be carried out in Indonesia, because in Indonesia there are many collectors and
several garbage banks and plastic recycling entrepreneurs.
3.5.2.3 Financing Scheme

The financial requirements for implementing EPR electronic waste (e-waste) are as
follows:
1. Cost of monitoring the presence of e-waste that contains PBDEs including cost for
testing PBDEs contains in e-waste.
2. Incentives to encourage scavengers/collectors to pay more attention to electronic
waste containing PBDEs
3. Other social costs for public awareness about the existence of PBDEs in used
products or packaging. For example cost to conduct workshop about PBDE, cost
for advertising, etc.
These costs should come from companies/vendors who sell products that contain
PBDEs. The amount of costs for incentives can be determined from the difference in
price differences between various used plastics. In the table below (table tdk ada),
examples of prices of used plastic for various types of plastic.
3.5.3 Draft Agreement

Draft Agreement between users, vendors, and the government regarding the
implementation of EPR in Indonesia has been drafted, which can be used as a basis for
drafting regulations on the use of PBDE in Indonesia.
The basic considerations used are:

1. Law of the Republic of Indonesia No. 18 of 2008 concerning Waste Management
2. Law of the Republic of Indonesia No. 19 of 2009 concerning Ratification of the
Stockholm Convention on Persistent Organic Pollutants (POPs)
3. Government Regulation of the Republic of Indonesia No. 74 of 2001 concerning
Management of Hazardous and Toxic Materials.
The government will issue technical regulations for the EPR implementation of plastic
waste, while specifically those containing PBDEs are needed proposals from the public
so that the danger of PBDEs can be prevented. Companies that currently use flame
retardant containing PBDE must plan to reduce or eliminate them by replacing fire
retardants that do not contain PBDEs gradually within five years.
Companies that use PBDEs in their products or packaging to participate in being

responsible for the existence of their products through:
1. Providing information to the public about the dangers of PBDEs through user
manuals, or other forms of socialization.
2. Take back used products or used packagings directly through trade in for those
that containing PBDEs.
57
3. Allocate fund, to provide incentives to scavengers/collectors so that their used
products/waste can be recycled with repurchases at attractive prices.
The articles for the implementation of EPR in Indonesia consist of:

• Article 1 contains definitions from stakeholders, from the government to plastic
recycling entrepreneurs
• Article 2 contains the rights, duties and obligations of each of these
stakeholders.
3.6 MONITORING AND CONTROL OF MATERIALS OF POPs
3.6.1 POPs and their Law Enforcement Instruments

Persistent Organic Pollutants (POPs) are pollutants in the form of toxic chemicals, are
very difficult to degrade so that they have a long half-life, bioaccumulative, can move
through water and air and move species, across international boundaries, can experience
accumulation in the region which is very far from the place of exposure and can
accumulate in terrestrial ecosystems and aquatic ecosystems.
Basically, the entire life cycle of POPs chemicals and pesticides is regulated in various
laws and regulations in Indonesia. Starting from the presence of POPs, imports, use,
release and fate in the environment, waste containing POPs, to remediation of polluted
land. However, not all POPs chemicals and pesticides are covered by the laws and
regulations in Indonesia. Existing regulations govern only a number of POPs chemicals
and pesticides. At least there are three types of POPs whose overall life cycle aspects
have not been regulated. The three POPs are PFOS, PBDEs (including commercial
pentabromodiphenyl ether: tetrabromodiphenyl ether and pentabromodiphenyl ether,
and commercial octabromodiphenyl ether: hexabromodiphenyl ether,
heptabromodiphenyl ether), and hexabromocyclododecane (HBCD).
Law enforcement instruments related to POPs are also available in Indonesia.

Supervisors and investigators, both from the police and from civil servants have carried
out enforcement, including enforcement of chemicals and POPs pesticides. In terms of
sanctions, Law Number 32 of 2009 concerning Environmental Protection and
Management regulates sanctions in detail about pollution that can reach pollution due to
chemicals and POPs pesticides. This regulation explicitly states that environmental
pollution is a crime. Law No. 12 of 1992 explicitly regulates sanctions on pesticides,
including: (a) using methods and/or facilities for protecting plants that disrupt health
and threaten human safety or cause environmental damage, (b) distribute pesticides that
are not registered or not in accordance with the label, and (c) not destroy pesticides
which are prohibited from distribution, do not meet quality standards, are damaged or
not registered. Both of these regulations govern criminal sanctions (prison) and criminal
penalties.
58
Although not all POPs are included, monitoring of POPs and chemical pesticides is
regulated through various regulations, including:
1. Monitoring the use and quality of POPs pesticides is regulated in Minister of
Agriculture Regulation No. 42 of 2007 concerning Pesticide Control
2. Monitoring the release of POPs in hazardous and toxic waste incinerators is
regulated in the Decree of the Head of the Indonesian Enviromental Impact
Management Agency (Bapedal) Number 03 of 1995 concerning Technical
Requirements for the Treatment of Hazardous and Toxic Substances
3. Monitoring of hazardous and toxic material containing landfilled POPs is
regulated in the Decree of the Head of Bapedal Number 04 of 1995 concerning
Procedures for Requirement for Stockpiling of Processing Products,
Requirements for Existing Processing Sites, and Location of Former Hazardous
and Toxic Waste Stockpiling
4. Monitoring of the presence of POPs in water bodies is regulated in Government
Regulation Number 82 of 2001 Management of Quality and Control of Water
Pollution; Central Laboratory for Environmental Impact Management Facilities
(Pusarpedal) KLH (Ministry of Environtment, Indonesia) has periodically
monitored this type
5. Monitoring the POPs threshold in the workplace air is regulated in Minister of
Manpower and Transmigration Regulation No. 13 of 2011 concerning Threshold
Value of Physical Factors and Chemical Factors in the Workplace
PBDEs have been used extensively since the 1970s; however, there are concerns about
its persistence in the environment and its tendency to decompose in the food chain
(EPA, 2014). PBDEs is one of the pollution problems that is of concern to the world,
because the results of the study show PBDEs can accumulate and have the potential to
threaten health (Tarja, 2008)
3.6.2 Integrated Monitoring and Control Strategy

The strategy in carrying out integrated supervision and control of raw materials consist
of of POPs/PBDEs in the plastic and electronic resin industry consists of several stages,
namely: production, packaging and labeling, storage and distribution and waste
management as describe as follows:
1. Production
Production is the process of processing raw materials into products as expected. To
produce products that are in accordance with the expected specifications, the production
process must be controlled. When the production process is abnormal, it has the
potential to cause environmental pollution. The plastic industry is one of the main
industries, because it is related to the main needs of humans. The goods around us are
mostly made of plastic, which in addition to having a positive impact on meeting human
needs, there are also negative impacts. To reduce the negative impact of plastic,
supervision and control are needed starting from raw materials, production processes to
the waste that will be generated.
59
Plastic resin products used to meet human needs include: Polyethylene (PE) (three types
of PE: LDPE, LLDPE, HDPE) and Polypropylene (PP). Plastic materials in general are
divided into two groups, namely thermoplast and thermoset plastic. The difference,
thermoplast plastic can be printed repeatedly with heat treatment, while thermoset
plastic is plastic that cannot be reprinted because the polymer is in the form of three-
dimensional tissue. The types of thermoplast plastic are PE, PP, polystyrene (PS), ABS,
Styrene Acrylonitrile (SAN), nylon, polyethylene terephthalate (PET), Polyacetal
(POM), Polycarbonates (PC). While the type of thermoset plastic is PU (Poly
Urethene), UF (Urea Formaldehyde), MF (Melamine Formaldehyde), polyester, epoxy.
Making plastic materials depends on market requirements; so many additive additions

depend on the nature of the raw material and the nature of the product desired by
consumers. Additives in the process generally consist of plasticizers, stabilizers,
lubricants, fillers, colorants, antistatic agents, blowing agents and flame retardant.
Regarding the use of flame retardant materials in the plastic resin industry, which will
be used for the electrical and electronic industries, it is necessary to monitor and control
the use of flame retardant, especially those containing halogen.
At the Stockholm convention there were several new POPs compounds including hexa,
hepta, tetra and penta bromodiphenyl ether and heptabromodiphenyl ether. These
materials are flame retardant used for the chemical, textile and plastic industries, but
these hazardous materials have not been listed in Indonesian legislation. Even though
flame retardant containing halogens are included in the RoHS (Restriction of Hazardous
Substances Directive), which issues restrictions on the use of six hazardous substances
in the production of various types of electronic components.
The Indonesian government must immediately issue laws that limit/minimize or even
prohibit the use of halogen-type flame retardant and replace the use of flame retardant
that are more environmentally friendly. Government regulation that must be done
immediately is to monitor and control the use of PBDEs from raw materials,
manufacturing processes to waste from processes and products, especially for the plastic
industry that uses flame retardant, because products containing PBDEs can be added to
raw materials or during manufacturing.
2. Packaging and Labelling

The process of monitoring and controlling the packaging and labeling of raw materials
and electronic products that contain flame retardants both containing halogen and non
halogen, refers to government regulations regarding packaging and labeling of
hazardous chemicals. In the packaging system, a labeling system for hazardous
materials is needed. In addition to packaging, the product should be labeled.
Electrical and electronic waste contains many valuable materials, can reach 60
components in the periodic table. An example is a computer in which there is a cathode
ray tube. Computer monitors contain many valuable but poisonous components, such as
60
cadmium used in rechargeable computer batteries. Cadmium is accumulated in the
environment and is very toxic to humans, especially kidneys and bones. This is also one
of the six toxic components and is prohibited in the RoHS.
Companies must provide clear signs of hazardous chemicals on products, packaging,

stickers or books related to EEE products. For companies that use websites to inform
the content of hazardous chemicals that are restricted in EEE products, they must
provide a clear website address on products, packages/products, stickers or product
usage manuals.
3. Storage and Distribution

Factors that must be considered in the storage of hazardous and toxic chemicals are
segregation aspects, levels of hazard risk (multiple hazards), labeling, storage facilities,
secondary containers, expired materials, inventory, and hazard information. Monitoring
and controlling the storage of raw materials and products containing flame retardant
referring to safety rules in the storage of hazardous chemicals. Storage of hazardous
chemicals must know the physical and chemical properties of the stored material and
also the dangers that can cause fires, blasting and removing toxic gases/vapors/dust.
Supervision and control of distribution of raw materials and electronic and electrical
products containing flame retardant refers to the use and distribution of hazardous
chemicals. Supervision in the distribution or distribution of hazardous chemicals in
principle for security and safety, so that the government has made regulations in Law
No. 22 of 2009 concerning road traffic and Government Regulation No. 41 of 1993,
Decree of the Minister of Transportation Number KM 69 of 1993, Decree of Director
General of Land Transportation Number SK 725/AJ/302/DRJ.
4. Waste Management
Waste management refers to Government Regulation No. 101 of 2014 concerning
management of hazardous and toxic waste. Waste of electrical and electronic equipment
is waste originating from damaged electrical or electronic appliance or those that are no
longer used. Most of the electrical and electronic waste is categorized as hazardous and
toxic waste because of the components contained and made from hazardous
components such as lead, mercury, cadmium and others.
Electrical and electronic waste has many types, but the European Union Parliament
through its instructions in No.2002/96/EC classifies several types of electrical and
electrical waste, namely:
• Large household appliances such as: air conditioning machines, washing
machines, refrigerators, and ovens.
• Small household appliances such as fans, stoves, blenders, toasters, and vacuum
cleaners.
• Communication and information technology equipment (IT &
telecommunications equipment, ICT labeled), such as: computers, laptops,
61
printers, telephones, modems, mobile phones, fax machines, scan engines,
batteries, and calculators.
• Electronic entertainment equipment (Consumer Equipment, with CE label);
namely TV, radio, DVD/VCD player.
• Lighting equipment with Lighting labels.
• Electrical and electronic tools, with the exception of large-scale stationary
Industrial tools, with E&E tools labeled.
• Electronic toys and sports equipment (Toys, leisure and sports equipment, with
label Toys).
• Medical devices (Medical devices with the exception of all implanted and
infected products, with Medical Equipment labels).
• Monitoring and control tools (Monitoring and control instruments, with M&C
labels).
3.6.3 Supervisory Teams

Indonesia does not yet have rules regarding the use of PBDEs, especially in the
electrical and electronic industries. The industry only uses the prohibition rule on the
use of PBDEs when its products are exported abroad that have implemented a ban on
the use of PBDEs. Regulations on the prohibition on the use of PBDEs in Indonesia
must be immediately issued through government regulations and several government
agencies related to the use of PBDEs can form a Supervisory Team for the use of
PBDEs in the electronic and electrical industries. The roles of each member of the
Supervisory Team are as follows:
1) Ministry of Industry: relating to overseeing the regulation of raw materials,
processes and products from electrical and electronic products as well as the
composition contained in the labeling of these products
2) Ministry of trade: relating to the regulation of export-import of electrical and
electronic materials and raw materials needed for the industry
3) Ministry of the environment: relating to the management of electrical and
electronic goods waste
4) Directorate General Customs and Excise: relating to overseeing the export and
import of raw materials, and electrical and electronic products.
If all institutions work together to suppress or eliminate the use of PBDEs in the
electrical and electronic industries, the use of PBDEs can be minimized or even
prohibited for being use in Indonesia.
3.6.4 Encouraging Industries to Use PBDEs Substitution

At present the Indonesian government has not issued the ban on the use of PBDEs. Due
to the danger posed and the prohibition on the use of PBDEs abroad, the government
should immediately issue a ban on the use of PBDEs and replace PBDEs with other
types of flame retardants that do not contain halogen.
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Before the issuance of the prohibition regulation, the use of PBDEs can be disseminated
to industries using halogen-type flame retardant to replace them with halogen-free flame
retardant. Socialization can be done with seminars, focus group discussions (FGD) by
inviting industries that use flame retardant, especially electrical and electronic
industries.
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4 REDUCING OR ELIMINATING THE IMPORTATION
AND USE OF PBDEs in PLASTIC
MANUFACTURING
4.1 SUPPLY-DEMAND AND SUPPLY CHAINS FOR PRODUCTS
CONTAINING FLAME RETARDANT
The plastic and packaging sector is growing very fast in Indonesia because of the
increasing needs of consumers. The food packaging industry is the largest consumer of
plastic industry in 2015 in Indonesia. However, the infrastructure and automotive
sectors grew rapidly after 2015, which was quite large to help increase sales of plastic
products. The Indonesian Olefin, Aromatic and Plastic Association (INAplas) said that
plastic sales in 2015 grew 3% compared to 7-8% growth in the previous year. Plastic
consumption per capita in Indonesia per year is 10 kg and is still relatively low
compared to other ASEAN countries such as Malaysia and Thailand, which reach 45
and 56 kg per year, respectively. Based on this, INAplas estimates that plastic sales in
Indonesia will increase to 7 million tons in 2018.
Plastics are widely used in industries such as food and beverage packaging that reaches
60%, buildings and household needs 15%, and the automotive sector 8% and the rest
are agriculture and horticulture. INAplas said that in 2015 the infrastructure sector
consumed 600,000 tons of plastic, an increase of 7% compared to 2014.
7%
PP
14%
PE
32%
PET
16%
PVC
31%
PS
Figure 4.1 Percentage of plastic use in Indonesia
Currently Indonesia still imports 50% of plastic raw materials such as polyethylene and
polypropylene from the Middle East, Singapore, China and South Korea. The local
petrochemical industry, such as PT Chandra Asri Petrochemical Tbk, can only meet two
thirds of its needs with a capacity of 800,000 tons of ethylene per year due to limited
supply of naphtha from Pertamina. Polyethylene imports in 2015 reached 500,000 tons
compared to 400,000 tons in the previous year, valued at USD 600 million. The types
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of plastic that are widely used in Indonesia are Polypropylene (PP), Polyethylene (PE),
Polyethylentherphthalate (PET), Polyvinylchloride (PVC) and Polystyrene (PS). In
Figure 4.1 can be seen the percentage of plastic use in Indonesia.
4.1.1 Polypropylene (PP)

Polypropylene (PP) is a semi-crystalline polymer that is very widely used due to its
superior properties, inexpensive and easily processed. All PP grades are neutral
polymers and are quite resistant to oxidation. Other additives such as lightening agents,
nucleating agents, antiskid, UV stabilizers, silica, talc, and calcium carbonate are added
according to the needs of their functions and applications. PP homopolymers are made
from PP polymerization, random copolymers made from propylene and other mononers
(eg ethylene), or impact copolymers made by dispersing rubber in the PP matrix. PP can
be processed by various fabrication techniques, such as film/sheet extrusion,
multifilament, not webbing, press printing, blow molding, and extrusion.
4.1.2 Polyethylene (PE)

Currently in Indonesia there are two producers of polyethylene (PE), which operate
with a total installed capacity of 790,000 tons per year. The biggest polyethylene factory
is PT. Lotte Chemical Titan Nusantara, whose factory is located in Merak, has an
installed capacity of 450,000 tons per year and has been operating since 1993. The
second largest polyethylene plant is PT. Chandra Asri Petrochemical (CAP) Tbk with an
installed capacity of 340,000 tons per year. This factory in Anyer Banten has been
operating commercially since 1995.
The increase in PE production in 2015 was caused by a high increase in imports,

reaching a value of 828,524 tons, the highest increase compared to previous years. The
growth in the volume and value of imported PE during 2010-2015 tended to increase,
reaching 19.20% and 23.62% per year. In 2009, the import volume of PE reached
296,030 tons with a value of US $ 344,536 thousand, then in 2010 it increased quite
high to 419,581 tons with a value of US $ 481.134 thousand, the highest increase in the
past 6 years, reaching 41.74%.
In 2011, import of PE continued to increase to 507,113 tons with a value of US $

784,286 thousand, in 2012 to 60,259 tons with a value of US $ 868,029 thousand, and
in 2015 it had reached 828,524 tons with a value of US $ 1,105,138 thousand, the
highest increase compared to previous years. The import value of polyethylene can be
seen in Table 4.1.
Table 4.1 Import of Polyethylene for 2009-2015
65
Import Growth (%)
Year Volume (Ton) Value (US$ 000) Volume Value
2009 296,030 344,536
2010 419,581 579,295 41.74 68.14
2011 507,113 784,286 20.86 35.39
2012 602,259 868,029 18.76 10.68
2013 670,002 1,105,138 11.25 27.32
2014 713,216 1,158,029 6.45 4.79
2015 828,524 1,105,138 16.17 -4.57
Average Growth (%) 19.20 23.62
Of the total PE imports in 2015, the largest volume was HDPE, which was recorded at
363,183 tons worth US $ 475,157 thousand, an increase compared to 2014 which was
283,271 tons worth US $ 454,603 thousand. Other large imports occurred in 2015,
namely LDPE recorded at 242,850 tons worth US $ 310,813 thousand, an increase
compared to the previous year at 184,316 worth US $ 279,539 thousand. Data of PE
imports with HS type in 2014-2015 can be seen in Table 4.2.
Table 4.2 PE imports with HS type (HS Code 3901.10.12 - 3901.20.00), 2014-2015
2015 2014 Unit/Ton/US$, 000
Description
Ton US$, 000 Ton US$, 000 2014 2015
HDPE 363,183 475,157 283,271 454,603 1,308 1,605
LDPE <0.94 242,850 310,813 184,316 279,539 1,280 1,517
LDPE 182,323 249,341 204,839 342,015 1,368 1,670
Others LDPE 15,550 27,343 17,206 35,225 1,758 2,047
LLDPE 2,795 3,769 1,885 3,253 1,348 1,726
Others LLDP 21,871 38,715 21,699 43,394 1,770 2,000
Total PE 828,572 1,105,138 713,216 1,158,029 1,334 1,624
Source: Central Bureau of Statistics
HDPE supply for the domestic market can be seen from total production plus imports,
which is then reduced by exports. Based on these illustrations, it can be seen that the
supply of PE in 2009 reached 718,662 tons. In 2010, the supply of PE increased to
822,336 tons and then increased in 2011 to 956,450 tons or in 2012-2015 it continued to
increase significantly from 983,125 tons in 2012 to 1,372,726 tons in 2015.
Imported products still dominates the domestic PE markets even the ratio of imported
products currently controls almost 60% of the total PE market. In general, there are
three types of PE, namely HDPE (High Density PE), LDPE (Low Density PE) and
LLDPE (Linear Low PE). HDPE is a type of PE with a density exceeding or equal to
0.941 g/cm3. HDPE has a low level of consequences and has very high strength between
molecules and tensile strength. HDPE can be produced with chromium/silica catalysts,
Ziegler-Natta catalysts or metallocene catalysts. HDPE is used as an ingredient in milk
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bottles, detergent packaging, lubricating oil packaging, margarine packaging, water
pipes, and garbage. The largest volume and import value of HDPE in Indonesia in 2015
came from 15 countries including Malaysia, Singapore, Thailand, Saudi Arabia and
others as shown in Table 4.3.
Table 4.3 Import of Polyethylene (HDPE) according to country of origin at 2015

2015 Share
No Country of Origin
Ton US$,000 (%)
1 Malaysia 200,120 258,016 24.12
2 Singapore 199,253 266,062 24.01
3 Thailand 152,592 207,947 18.39
4 SaudiArabia 106,316 134,213 12.81
5 Kuwait 41,875 45,481 5.05
6 Korea, Republic Of 25,944 40,735 3.13
7 UnitedArabEmirates 24,291 32,569 2.93
8 Qatar 20,496 25,622 2.47
9 Japan 16,591 29,418 2.00
10 Philippines 9,679 11,812 1.17
11 Taiwan 7,227 11,065 0.87
12 United States 6,767 12,065 0.82
13 Germany, Fed. Rep. Of 5,355 9,864 0.65
14 China 4,076 7,553 0.49
15 Canada 3,102 3,728 0.37
Others 6,171 8,991 0.74
Total 829,853 1,105,138 100.00
The biggest consumption of HDPE in Indonesia is the plastic bag industry. This can be
seen from the number of plastic bag manufacturers, which reached thousands because
the production process is relatively simple using only one or two extruder machines and
semi-automatic processes and the raw material requirements are also quite large every
year. However, not all plastics bag manufacturers use PE as raw material, there are also
those who use PP but the objects of research is those that use PE as raw material. The
report also discusses companies in the industrial scale category that have at least two
shifts per day, with a capacity of 250 tons per year.
From the results of Indochemical research, most plastic bags produced in Indonesia use
raw materials from high-density poliethylene (HDPE) grades. So far, the use of PE as a
raw material for plastic bags is more than PP. Despite a decline in production in 2009,
the production of PE plastic bags in Indonesia tended to increase during 2010 to 2015
with a growth of 12.3% per year.
The plastic industry that produces household appliances in Indonesia has been growing
since the 60s and currently the number of manufacturers has reached more than one
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hundred units of companies including large, medium and household industries.
However, it is listed in the category of large and medium industries, with around 150
companies with installed capacities reaching around 398,010 tons per year.
Household products that use HDPE include tuppleware, trays, mugs, pumpkins, plates,
plastic stools, and so on. According to Indochemical records, in 2009 the total
production of household appliances made of PE plastic reached 156,742 tons, so next
year it increase to 192,373 tons and reached 314,122 tons in 2015. From Indochemical's
record, currently in Indonesia there are more than 100 companies engaged in the plastic
bottle and jerry cans industry with a total capacity of 277,904 tons, which consists of
bottle industry capacity of 263,102 tons per year and jerry can industry of 14,892 tons.
Among the companies classified as large capacity are PT. PETindo Jaya Sakti, reaching
33,100 tons of bottles per year, followed by PT. Dynaplast has a capacity of 15,000 tons
per year, PT. Aqua has a capacity of 13,000 tons per year, and PT. Indo Daisun Jaya has
a capacity of 10,000 tons per year.
During the period of 2009-2015, the production of plastic bottles made in PE resin in
Indonesia experienced a significant growth of 14.20% per year. This growth is driven by
the rapid growth of the food and soft drink industry that uses plastic packaging and
plastic bottles that grow around 11-12% per year. The high demand for plastic bottles
has triggered a rise in domestic production of PE plastic bottles. In 2009, the production
of PE plastic bottles was 41,830 tons, then in 2010 it reached 51,852 tons and in 2015 it
increases from 12.21% to 101,086 tons.
Currently in Indonesia operates around 55 companies that produce cables with a

capacity of 326,660 tons, including 277,000 tons of electricity cables and 49,660 tons of
telephone cables. The big cable manufacturer is PT. Sumi Indokabel Tbk, with a
capacity of 60,000 tons, then PT. Sucaco 31,800 tons, PT. Jembo Cable 22,550 tons and
PT. Kabelindo Murni each has 22,500 tons per year.
The cable consists of copper wire and is coated by HDPE plastic compounds. The
results of Indochemical's study of several cable products illustrate that the proportion of
compounds in cable products is around 39.65% of the average cable product, while the
HDPE resin content in the compound is around 92.7%. In 2010, PE-made cable
production reached 109,308 tons, the following year it increased to 144,188 tons, and in
2015 reached 224,370 tons. HDPE pipes are often used for pipelines with special
characteristics. Suitable for use in distribution channels for pressurized drinking water
applications because it is made of PE. The advantages of material properties are: having
a low crack rate, resistance to high pressure, and high elasticity so that it has a usage
range of more than 50 years.
In Indonesia, there are not many companies that make HDPE pipes. Plastic pipe
factories such as PT. Pralon Indonesia, PT Wavin Indonesia, PT. Maspion Kencana, PT.
Rusli Vinilon, PT. Indo Pipe, PT. Tyco Eurapipe Indonesia, and PT. Sinar Nusantara,
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already producing HDPE pipes. But there are also some companies that produce HDPE
based on orders. From the results of Indochemical investigation, it is estimated that the
total HDPE pipe production capacity reaches 356,664 tons; utilization of its capacity is
only 20%.
From the analysis above, it can be seen that in 2016-2020, the industry sector that
absorbs the most HDPE resins is the plastic bag industry (56%), followed by the
household appliances industry (20%), plastic bottle industry (6%), industry cable (5%),
filament industry, and molding industry each by 3% and the rest (7%) consumed by
other industries.
Low Density Poly Ethylene (LDPE) has a density of 0.910-0.940 g/cm3. LDPE has a
short and long branching chain, meaning it will not change the crystal structure. This
shows that LDPE has a low strength among molecules, which causes LDPE to have low
tensile strength. LDPE is produced by free radical polymerization and used as a rather
strong container and application of plastic films such as plastic bags and plastic wrap.
Linear Low Density Poly Ethylene (LLDPE) has a density between 0.915-0.925 g/cm3.
LLDPE is a significant number of branched short chain linear polymers. LLDPE is
generally made with alpha-olefin short-chain ethylene copolymerization (1-butene, 1-
hexene, 1 octene, and so on). LLDPE has a higher tensile strength than LDPE, and has a
higher resistance to pressure. LLDPE is used as a cable wrap, toys, packaging caps,
buckets, containers and pipes. LLDPE is mainly used for plastic film applications
because of its toughness, flexibility and relative transparency.
One type of PE that is also quite extensive is cross linked PE (XLPE). This type of PE is
currently widely used with 1KV-10KV voltages insulation such as cables on electric
poles along the road, water pipes replacing PVC pipes, faucets, fittings and others.
XLPE's strengths are anti-rust, leak-proof, flexible, strong, durable, high pressure
resistant, and stable.
4.1.3 Polyurethane (PU)

Polyurethane consists of flexible foam polyurethane and rigid foam polyurethane.
Flexible foam are used as insulators, including textile laminates for winter clothing, car
protective panels, upholstery, beds, basic carpets, synthesis sponges, and vehicle
components (which cover exterior parts and interiors such as bumpers, body panels, and
seats), heat insulation, sound absorbers, cold dampers and are used to maintain room
temperature to avoid wasteful use of air conditioning (temperature insulation),
zincalume roof applications, onduline roofs, not concrete, gypsum ceiling, GRC board,
wall etc. While polyurethane spray foam is sprayed directly on the media to be
insulated, so that there is no blemish that can propagate heat or spray into parts of walls,
roofs, walls, floors, concrete, directly to the desired part, thus creating an insulation
without a gap, in the process, as well as functions as a temperature guard around the
room. Rigid foam polyurethane is used in refrigerator insulation or soundproof
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insulation.
Polyurethane elastomers have scratch resistance, are strong, are resistant to oil and the
hardness level is quite good so that it is widely used to coat materials subjected to
continuous mechanical pressures such as tire threads, gears, shoe soles, and roller
coatings on paper making machines. Polyurethane fibers have elastic properties that are
quite good so they can replace latex rubber thread in divers' garment manufacturing
industries.
4.1.4 Polyethylene Terephthalate (PET)

Polyethylene Terephtalate (PET) is a product produced by the polymer industry better
known as polyester. PET is formed from the results of the esterification reaction and
polycondensation reaction, with the raw material terephthalic acid with ethylene glycol.
PET is very widely used in our daily lives, such as packaging bottles, plastic bags,
threads, clothing, and ship screens. The use of 60% of world PET is for synthetic fibers
and 30% is used as raw material for plastic beverage bottles. In each packaged bottled
waters sold, almost 70% is the selling price of packaging. The use of PET is very much
because PET or can be abbreviated as PETE has safe and recyclable properties. Because
of its excellent properties compared to other types of plastic, the plastic derived from
PET/PETE is labeled 1.
In Indonesia PET have good prospects to be developed both in terms of the potential of
raw materials and the industries that use them. But until now the sector has not been
developed even though the demand tends to increase. With this sector not yet explored,
importing has fulfilled Indonesia’s needs on PET.
PET needs in Indonesia from year to year continue to increase. This increase occurred
because of the growing downstream industry of PET, namely the development of the
textile industry in Indonesia. PET demand in Indonesia in 2012 was around 156,000
tons and is estimated to increase to 177,000 tons in 2013. Meanwhile, PET production
in 2012 was 417,000 tons and 467,000 tons in 2013. Three companies under the
Indorama Group, namely PT Indorama Synthetic Tbk, PT Indorama Ventures Indonesia,
and PT Polypet Karyapersada, control around 70% of the domestic PET market.
Indorama exports up to 40% of its products. Although PET factories already exist in
Indonesia, however, the existing factories in the country are not enough to meet PET
needs from Indonesia so that PET imports from outside are needed. The majority of
PET used in the food and beverage industry is domestic products, which is around 70%,
while imported PET is only 30%. PET imports include Singapore, Taiwan, China and
South Korea.
4.1.5 High Impact Polystyrene (HIPS)

Polystyrene is another polymer named polyvinyl benzene has advantages that are easy
to form, resistant to impact, easy to print and easy to color. The use of polystyrene type
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plastic increases every year, so the plastic and household appliances industry is growing
rapidly.
Polystyrene is divided into 3 namely General Purpose Polystyrene (GPPS), Expendable

Polystyrene (EPS), and High Impact Polystyrene (HIPS). GPPS has the form of
transparent and rigid granules in pellet shape. HIPS has a white pellet shape. The
advantages of HIPS compared to EPS and GPPS are that they are relatively cheap and
easy to manufacture. The usefulness of HIPS is not only as household appliances, but
also as a place to wrap food, insulators and furniture. Therefore, the community's need
for polystyrene is increasing. The need for Indonesian polystyrene is based on 2015 The
Central Bureau Statistic data of 49,784 thousand tons and in 2017 it is predicted that its
needs will increase to 70,000 thousand tons.
4.2 ALTERNATIVE PBDEs RESEARCH IN ACCORDANCE WITH

THE PRODUCTION PROCESS APPLIED IN INDONESIA
Tirtayasa University - Serang has carried out research on PBDEs substitution as a flame
retardant, which was carried out in the Research & Development Laboratory of one of
the chemical industries.
4.2.1.1 Materials and Equipment

Table 4.4 Flame retardant formulas
Component Formula A (%) Formula B (%)
Polymer HDPE The rest The rest
Antimony Trioxide 15 -
Decabromodiphenyl Ethane 45 -
Amonium Polyphosphate - 20
Triazine - 5
Antioxidant 0.1 0.1
In this study flame retardant formulas were divided into two formulas, namely formula
A for flame retardant halogen and formula B for non-halogen flame retardant. In Table
4.4 can be seen the formula used. The research equipments used are high kinetic mixer,
twinscrew machine, extruder and injection molding machine.
4.2.1.2 Methods
Both types of formulas use HDPE melt flow 18. Each formula is mixed in a high kinetic
mixer for 3 minutes with the total weight is 6 kg. The mixture of high kinetic mixer is
included in the twin-screw (TS) extruder with a diameter of 20 mm for compounding.
The results of the TS extruder are pellets. Pellets for formula A become masterbatches
and injected into injection molding with concentrations of 5 phr, 8 phr, 10 phr and 12
phr in PP melt flow 10. Whereas for formula B using all compound results and 10 phr in
PP melt flow 10 The results of injection molding for formulas A and B were analyzed to
determine the mechanical properties and tested UL 94.
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4.2.1.3 Results and Discussion
1. Mechanical property
The choice of plastic material depends on the balance of stiffness, toughness,
process capability and price. The addition of flame retardant will directly change
the mechanical properties of the polymer used. The following Tables 4.5 is the
results of testing the mechanical properties of adding flame retardant to
polypropylene.
Table 4.5 Flexure test (MPa)
Flexure test (MPa) Tensile strength
Formula
(MPa)
PP 100% 1,318.53 565.55
Formula A 1,542.28 111.76
(10 phr in PP)
Formula B 1,443.20 735.41
(10 phr in PP)
Formula B 100% 821.1 58.83
Flexure test
The flexure test used to measure the value of the tensile stress resulting from the
ratio between the bending moment and its cross section. The results showed that
the addition of a flame retardant would affect the flexure properties; formula A with
the addition of 10 phr decabromodiphenyl ethane as flame retardant has a higher
flexure value compared to pure polypropylene and formula B with the addition of
10 phr non halogen flame retardant containing ammonium polyphosphate.
The smallest flexure value is in formula B 100% compound, this shows that
formula B is a more brittle compound compared to formula A (10 phr in PP) and
formula B (10 phr in PP). The smallest flexure value will be a consideration for
applications in the electronics industry because it will easily to form crack or break
if hit by an impact. For formula A with 10 phr in PP it has a high flexure value, so it
can be considered for application in the electronics industry because in addition to
containing a flame retardant to slow down the flame also has a high flexibility
value even higher than pure polypropylene (PP).
Tensile test
Tensile strength is the maximum strength of a material or structure to withstand
loads. Measuring tensile strength to determine the magnitude of the force achieved
to achieve maximum strength in each unit area for stretching or extending (Krochta
and Mulder-Johnston, 1997).
High tensile strength shows good ratings and, on the contrary, low tensile strength
shows a poor rating. The test results show the tensile strength for formula A,
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formula B and pure polypropylene with 10 melt flow show that formula B with the
addition of flame retardant 10 phr has the highest tensile strength value compared
to formula A (10 phr in PP), formula B 100% and pure polypropylene (PP 100%).
The results of this tensile strength test are inversely proportional to the flexure test,
where the highest flexure value is obtained in formula A while for this union tensile
strength formula A is smaller than the formula B.
2. Flammability test
The standard for Safety of Flammability of Plastic Materials for Device and
Equipment Testing (UL-94), is a standard for combustibility of plastic, which is
issued by Underwriters Laboratories (UL) in the United States. This standard
determines the tendency of the material to extinguish or spread fire once the
specimen is turned on. UL-94 is now harmonized with IEC 60707, 60695-11-10
and 60695-11-20 and ISO 9772 and 9773 (http://industries.ul.com/plastics-and-
components/plastics/plastics-testing).
In this fuel test all samples in formula A with several variations of flame retardant
concentration and formula B for the addition of 10 phr and formula B 100%
(compound). UL94 fuel test results can be seen in Table 4.6 for formula A and
Table 4.6 for formula B.
Table 4.6 UL94 fuel test results for formula A (in second)
No 100% PP 5 phr in PP 8 phr in PP 10 phr in PP 12 phr in PP
1 > 50 > 50 > 50 0 0
2 > 50 32 3 > 50 0
3 > 50 13 7 0 0
4 > 50 4 4 7 0
5 > 50 > 50 18 0 0
In Table 4.2 it can be seen that the addition of a flame retardant for formula A is a flame
retardant containing halogen is very effective, where at the concentration of 12 phr the
PP results are V0 or not burned at all. Unlike the pure polypropylene, which is burned
out. Changes in the concentration of flame retardant additions affect the fuel test. At 5
phr concentrations, all 5 samples tested were still burnt even though there was a sample
that burned and the fire was extinguished under 30 seconds. The higher the
concentration of flame retardant addition, the shorter the burn time until it doesn't burn
at all.
Table 4.7 UL94 fuel test results for formula B (in second)
No 100% B 10 phr in PP
1 3 >50
2 0 >50
3 0 >50
4 0 >50
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5 0 >50
From Table 4.7 it can be seen that the addition of 10 phr ammonium polyphosphate-
based flame retardant has not shown good results, where the sample is still burning up
to 50 seconds and if continued the sample will burn out. While for formula B 100% in
the form of a non-combustible compound or V0 even though there is a sample that
burns up to 3 seconds, but it is still under 10 seconds so that it is classified as V0. The
use of 100% formula B will be a consideration of economic value because formula
100% B is still compounded so it will be expensive and not economical if used in the
plastic industry.
In this study the type of flame retardant used is polibromo diphenyl ethane, a type of
flame retardant that still allowed to be used because it is not included in the Stockholm
convention. While the flame retardant, which is prohibited according to the Stockholm
convention is PBDEs (polybromo diphenyl ethers). Based on the results of research
conducted that the type of polypromo diphenyl ethane flame retardant is as effective in
inhibiting combustion.
Halogen-based flame retardant mechanisms such as chlorinated and brominated exhibit

thermal degradation and release of hydrogen chloride and hydrogen bromide or if used
in the present of such as antimony trioxide, antimony halide. This reacts with H• and
OH•, which are very reactive in flame, resulting in inactive molecules and Cl• or Br•.
Halogen radicals are much less reactive compared to H• or OH•, and therefore have a
much lower potential for spreading radical oxidation reactions from combustion.
The use of halogen-based flame retardant is very dangerous because it is toxic, cannot
be degraded and will continue to accumulate if it enters the body. Therefore non-
halogen flame retardant is used for several electronic, electrical and textile products.
One of the alternative groups of flame retardant is phosphorus-based such as: resorcinol
bis (diphenylphosphate) or RDP, Tris (Chlorpropyl) phosphate or TCPP, ammonium
polyphosphate and Red phosphorus (Red P).
There are two interesting facts from a chemical point of view: First, the phosphorus
content in this molecule varies greatly, from almost 100% (red P) to 9.5% (TCPP) and
this does not always correlate with the flame retardant efficiency of certain substances.
Second, phosphorus atoms are found in all oxidation states, which may be between 0
and +5. This shows that unlike halogen flame retardant, the effect of flame retardant
from phosphorus products cannot be explained by a single mechanism. Usually,
phosphorus-based flame retardant is designed to develop its activity in combination
with the initial decomposition of the specific polymer it uses. This can offer a partial gas
phase contribution to the fire extinguishing effect that is comparable to flame retardant
bromine or chlorine. However, its main feature is char forming activities, sometimes
combined with the emergence of foam (intumescence), which then forms a protective
top layer on the plastic surface (Le Bras, et al., 1998).
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3. Economic analysis
Based on economic calculations by assuming flame retardant prices in the market and
adjusted to the needs of the number of flame retardant based on the results of the study,
it is clear that flame retardant halogens are less costly than non-halogen flame
retardants. The amount of money that must be spent to replace the flame retardant from
halogen-based with non-halogen is almost 10 times greater. This will have an impact on
operational production costs, which will increase significantly.
4.3 TESTING RESULTS OF PBDEs CONTENTS IN

ELECTRONIC, AUTOMOTIVE AND RESIN PRODUCTS
In the laboratorium of Balai Besar Bahan dan Barang Teknik (B4T) has been done
screening test for ten types ol electronics, automotive products such as: CRT, air
conditioner (AC), lamp, iron, capasitor, helmet, children’s toys, water pump, washing
machine, rear view mirror, etc. Samples are products from local and national electronic
companies. The preparation of the samples is by cutting plastic inside those samples in
size of 2 x 4 cm. Experimental results show in Table 4.8. Total samples are 559 with
bromium (Br) as tested parameter.
It can be seen that as much as 79.96% of the samples screened is pass, which means that
the Br value of the product is < 700 ppm, as much as 5.37% is doubtful (inconclusive)
which means Br > 700 ppm, and 14.67% fails, which means that the Br value for that
product is > 1000 ppm. In this screening method, the presence of Br that does not meet
the assumptions can come from Br contents which are not derived from PBDE and
derived from recycled material.
Table 4.8 Test results for screening the contents of PBDEs in some products
Number
No Samples of Pass Inconclusive Fail Fail Note
samples
1 TV 22 1 0 21 95% Fail = Br > 1000 ppm
2 AC 14 14 0 0 0%
3 Lamp 35 3 0 32 91% Fail = Br > 1000 ppm
4 Iron 9 8 0 1 11% Fail = Br > 1000 ppm
5 Capasitor 5 3 0 2 40% Fail = Br > 1000 ppm
6 Helmet 3 3 0 0 0%
7 Children’s 36 35 1 0 0% Inconclusive= Br >
toys 700 ppm
8 Water pump 20 12 6 2 10% Inconclusive = Br >
700 ppm, Fail = Br >
1000 ppm
9 Washing 19 7 5 7 37%
machine
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Number
No Samples of Pass Inconclusive Fail Fail Note
samples
10 Rear mirror 3 3 0 0 0%
11 Etc (foam, 200 182 9 9 5% Fail = Br > 1000 ppm
DVD, Rice
Cooker)
12 PT Cosmos 47 41 6 0 0%
13 PT Sanken 36 34 1 1 3% Inconclusive = Cd ≈
100 ppm, Fail = Br >
1000 ppm
14 PVC sills 2 0 0 2 100% Fail = Pb > 1000 ppm
15 Lasdop 2 0 2 0 0% Inconclusive = Br >
1000 ppm
16 PT Yasunli 25 22 0 3 12% Fail = Br > 1000 ppm
17 PT Dharma 16 15 0 1 6% Fail = Pb > 1000 ppm
Poliplast
18 Automotive 10 9 0 1 10% Fail = Pb > 1000 ppm
components
19 CV Triona 11 11 0 0 0%
Multi
Industri
20 Citra 44 44 0 0 0%
Plastindo
Indonesia
Total Sampel 559 447 30 82
79,96 14,6
5,37%
% 7%
For electronic products that are screened, CRT TVs and lamps are products that are
about 90% -100% containing Br and are suspected it comes from flame retardant.
Because CRT TV products are categorized as having to meet the requirements of class
V-0, which has a flash time of less than 10 seconds in accordance with IEC 600695
standards. To meet the IEC requirements, the electronics industry needs to add flame
retardant to the intended product.
The electronics or automotive industry that applies RoHS compliance controls the use
of RoHS/PBDE in incoming materials. For the resin products themselves, there are
several customers specifically related to food, proof of conformity to RoHS is required.
When viewed from upstream, the addition of PBDE or flame retardant is not carried out
in the resin manufacturing process, but in the intermediate level of industry. At present
there are several industries that are using flame retardant based on PBDE (ether).
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4.4 IMPLEMENTATION OF FREE PBDEs LABELING FOR
PLASTIC-BASED PRODUCTS IN SEVERAL COUNTRIES
AND ITS DESIGNS IN INDONESIA
4.4.1 CE Marking in European Union (EU)

The labeling system applied by the European Union is called CE-marking. CE-Marking
regulations are contained in EU Directive 2011/65/EU (RoHS2). CE-Marking is a very
important confirmation sign for each product that will enter the European market
segment or more or less the same as the SNI mark in Indonesia. All electronic products
that will be marketed in Europe must follow the CE-Marking. CE-Marking designation
shows conformity of product (suitability of product) to regulations that have been set.
The word CE comes from the French language Communaute’Europe’enne, which
means European conformity. CE marking indicates that a product is feasible and has
met the standards when the product is used by consumers of European Union countries
in terms of safety, environment and health.
Manufacturers submit technical documents to

Product Certification Agency
After the suitability is stated, labeling

recommendations are issued
Authorized Body does labeling
Figure 4.2 Scheme of CE-Marking procedure
Not all products must have CE-Marking when it will be marketed in the European
Union. CE-Marking is only compulsory for EEE products regulated in EU directive
2011/65/EU (RoHS2). There is a ban on the use of CE-Marking on products other than
those regulated. Also, it should be noted that the CE-Marking does not indicate that the
product has been approved as a safe product by the European Union or other
institutions. The scheme of the CE-Marking procedure is as shown in Figure 4.2.
There are four parties who are required to apply CE-Marking, namely producers
(manufacturers), importers, representatives and distributors. An official supplier or
representative in the state of the European Union has an obligation in the CE-Marking
and makes a declaration of conformity. Proof is carried out by collecting/storing
technical files that are requested at any time by the supervisory authority so that in the
CE-Marking there is also the role of the supervisory authority which serves as the
supervision of the implementation of CE-Marking.
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4.4.2 Labeling scheme in several countries
Identifying new products containing POPs is a requirement to conduct good
environmental management. Product labeling is a representation to ensure that the POPs
content in the product is clearly shown and disseminated throughout the supply chain to
stakeholders or parties who can then apply the management steps to the product
appropriately. The labeling scheme must also take into account that stakeholders can be
in different countries because of the global nature of the product supply chain.18 Here
are some labeling schemes that have been carried out by several countries.
1. China
China RoHS2 requires that all electrical and electronic products sold in the People's
Republic of China (PRC) must be marked or labeled with one of the two logos in
Figure 4.3 and Figure 4.4 depending on the presence or absence of hazardous
chemicals contained therein.
§ Green label with the letter "e" means that the product does not contain hazardous
chemicals and is an environmentally friendly product that can be recycled.
§ The orange label with numbers in it means the product contains dangerous chemicals
and can be used safely during the period of environmental protection (represented by
the numbers in the logo) and must be included in the recycling system after the
period of use of its environmental protection ends. The validity period of
environmental protection indicates the time or period during which hazardous
chemicals contained in EEE products will not suddenly leak/leak during normal
operating conditions and will not produce serious environmental pollution or cause
injury / injury to users during use of the EEE products.
Figure 4.3 Green Logo on China RoHS2
18 UNEP-POPS-GUIDE-NIP-2012, Labelling of products or articles that contain POPs - Initial

considerations
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Figure 4.4 Orange Logo on China RoHS2
If the product contains certain hazardous chemicals that exceed the regulated
concentration limit, the validity period of environmental protection (in units of years)
must be determined and labeled. The date of manufacture or production of the
product must also be stated. In addition, producers and importers should provide the
name and content of hazardous chemicals in the product instructions / guidebook
(not marked on the product itself) and mark/label the part containing the hazardous
chemicals (Pb, Hg, Cd, Cr- VI, PBB and PBDE).
2. Japan
EEE product labeling in Japan is done by giving an orange label with the letter "R" or a
green label with the letter "G" for EEE products with six hazardous chemicals contained
in it exceeding the regulated concentration limit or not. The hazardous chemicals
referred to are associated with the six hazardous chemicals regulated in RoHS. If one of
the hazardous chemicals in the EEE product is in excess of the maximum concentration
limit, the concentration of the contents must be disclosed or uploaded on the website in
Japan in accordance with Japan Industrial Standard (JIS) regulations. Information
relating to the concentration of hazardous chemicals with the procedure for labeling and
upload information can be seen in Table 4.9.
Table 4.9 Labeling procedure in Japan

Status Labeling and upload information
1. Some of the six hazardous chemicals that § The presence of hazardous chemicals in
are regulated exceed the maximum the product must be uploaded on the
concentration limit website in Japan
§ Place the label "R" on products, catalogs
and packaging.
2. Some of the six hazardous chemicals that § The presence of hazardous chemicals in
are regulated exceed the maximum the product must be uploaded on the
concentration limit. However, the website in Japan
product meets JIS C-9502008 in Annex § No need to label "R" on products,
B, which is an exception. packages and catalogs.
§ Can provide a green label "G" on
packagoing or catalog products.
3. None of the concentrations of hazardous § No need to upload information on the
chemicals contained in the product presence of hazardous chemicals
exceed the maximum concentration § There is no need to put an orange "R"
limits set label on products, packages and catalogs.
§ Can put a green label "G" on products,
packages or catalogs.
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3. Korea
The Korea RoHS does not regulate the procedures and requirements for labeling
hazardous chemicals on regulated EEE (RoHS green label) products. However, all
producers and importers of EEE and vehicles must make a declaration of compliance or
a statement of fulfillment of compliance by making self-declaration of compliance or
compliance with the maximum concentration limits of hazardous chemicals contained
therein19.
In the case of EEE waste and vehicles recycling, producers and importers of EEE or
contractors to recycle waste must treat their waste according to the recycle method and
standards based on product categories as described by the Korean Ministry of
Environment. EEE manufacturers and importers must collect and recycle their waste
individually or together with the Recycling Aid Association1.
4. Singapura
Just like Korea, the Singapore RoHS also does not regulate the procedures and
requirements for labeling hazardous chemicals on regulated EEE products. But before
selling products in Singapore, every local producer or importer is asked to send or make
a declaration of conformity to control the EEE to the National Environmental Agency
(NEA). If the products sold by producers are not compliant with Singapore RoHS, then
these products are not permitted to be sold in the local market. Companies or industries
must request licenses from NEA to export these products.
5. Taiwan
EEE product labeling regulations in Taiwan are carried out in two ways, namely filling
the table of hazardous chemical content and Commodity Inspection Mark.
a. Labeling/marking of hazardous chemicals
Labeling or marking procedures of hazardous chemicals contained in EEE products
have been prepared. Companies must clearly provide clear signs in the table
containing hazardous chemicals on products, packages, stickers or books related to
EEE products. For companies/industries that use websites to inform the content of
hazardous chemicals that are limited in EEE products, they must provide a clear
website address on products, packages, stickers or product usage manuals.
b. Commodity Inspection Mark
For EEE products that are required to be inspected under the Commodity Inspection
Act, BSMI (Taiwan's Bureau of Standards, Metrology, and Inspection) can add RoHS
compliance requirements to a mandatory conformity assessment scheme. On August 25,
2016, the following are products that must comply with CN15663:
• Starting December 1, 2016: drinking fountains or watertab
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• Starting July 1, 2017: IT equipment, including automatic data processing
machines, printers, copiers, TVs and monitors. Also submitted for this date are
projectors and lighting equipment, such as fluorescent lamps
• Starting January 1, 2018: typewriter and cash register (43 items), keyboard,
mouse and scanner (48 items)
4.4.3 RoHS Marking Design in Indonesia

In the RoHS marking in Indonesia, the agency that issued the mark is the Product
Certification Agency. The chosen scheme is planned to use type tests and markings that
are carried out in harmony with the Indonesian National Standard (SNI). This is because
in Indonesia the marking of products uses SNI mark. The current conditions and
situation of Indonesia in the regulation and standardization of the electronics and
electricity sector are as follows:
a. The number of types of electrotechnic equipment regulated related to user
safety is still very small compared to the number of SNIs regarding the safety
requirements of electrical electronic products that have been determined by
adopting identical IEC standards.
b. There is no technical regulation that determines limits on the content of
hazardous materials in electronic and electrical equipment, and SNI is
available which regulates the determination of the levels of six elements
determined by adopting identical IEC 62321:2008.
c. There are no technical regulations that determine immunity limits and EMC
emissions from electronic equipment and electricity, SNI which regulates
immunity requirements and EMC emissions (electromagnetic compatibility),
along with related test methods have been determined by adopting identically
relevant IEC standards.
In Government Regulation Number 102 and National Accreditation Committee (KAN)

403 guidelines, the following are signs of provisions concerning SNI marks:
• The SNI mark is accompanied by SNI Number (complete with the year of SNI
issuance) that is referenced and the Accreditation Number of the Product
Certification Agency that provides sub-licenses for the use of SNI mark
• The initial assumption of each product becomes an object of one SNI
• Applies equally well to SNI which is enforced compulsorily by the government
and SNI that is applied voluntarily by business actors
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5 REDUCING UPOPs AND PBDEs FROM UNSOUND
PLASTIC RECYCLING
5.1 PLASTIC RECYCLERS AND PRODUCT RECYCLE USERS
MAPPING IN INDONESIA
The extent of PBDEs usage in plastic products in Indonesia can be identified through
mapping of plastic consumption and recycling industries. As already known PBDEs is a
hazardous component in certain plastic products so that the processing of the waste
should not be made arbitrarily. By knowing the result of mapping plastic recycling
industries, it can be known indirectly how developed waste management of products
containing PBDEs in Indonesia.
Indonesia raw material demand for plastic production currently reaches 4.93 million
tons per year. The demand is met by supplies from domestic production by 2.31 million
tons, import by 1.67 million tons, and recycled plastic by 0.95 million tons. This figure
shows that recycled plastic is accounted for 18% of total plastic raw material supply. As
for the plastic product types, plastic goods such as container, household items, textile, is
the majority of plastic product used in Indonesia with accounted for 40% of total plastic
products followed by packaging 30% and construction 15%. Details of plastic raw
material demand as well as the plastic products usage in Indonesia are shown in Figure
5.1.
Figure 5.1 Plastic raw material demand and product composition
Consumers of recycled plastic can be differentiated as intermediate product industries,

end product industries, and direct users. Intermediate product industries could process
recycled plastic into plastic sheets to textile industries for example. End product
industries would produce products that can be used by users directly such as tableware
or home utensils. Furthermore, some plastic recycling industries also could produce end
82
product such as tableware. Based on these, mapping of recycled plastic consumers
could be differentiated by kind of products rather than industries. The map can be seen
in Figure 5.2.
Figure 5.2 Plactic consumptions in Indonesia
As can be seen in Figure 5.2 packaging and plastic products dominate most
consumption of recycled plastic in Indonesia. It is quite plausible because most of
material used for packaging is plastic. Even some plastic products are packaged by
plastic packaging. Plastic products like tableware or textile are also widely consumed
because they are related to daily necessities.
In 2014, Indonesia’s per capita plastic consumption averaged 19,6 kg according to

INAplas. However, Indonesia’s middle class is expected to double to 141 million people
within the next five years, and plastic consumption is anticipated to grow in tandem
with the development of a larger consumer market and increased demand for packaged
goods. According to BPS, food packaging accounts for 30% of plastic consumption.
Meanwhile, Inaplas has set a 6% growth in domestic demand for the plastics sector, in
the wake of an improving gross domestic products (GDP), pegged at 5.3% in 2016, and
backed by the upbeat food and beverage and agribusiness sectors.
The amount of plastic waste produced by Indonesia reached 5 million tons per year
when imported plastic products and imported plastic waste are taken into account.
Based on data provided by INAplas, there are three ways of plastic waste handling is
83
currently carried out in Indonesia, reuse, recycle and disposal as trash. Plastic waste in
Indonesia is largely used as a material reuse (72%). Plastic waste that goes into the
recycling industry is accounted for 19% while the remaining 9% is goes to disposal. The
majority of plastic waste disposal is carried out with Landfill while the rest are
unidentified.
Figure 5.3 Distribution of Plastic Recycling Industries in Indonesia listed in ADUPI
Another way to map plastic consumption is to look at plastic waste distribution. Java is
the biggest plastic user as well as plastic waste producer in Indonesia. Java waste
production contributes to 55% of the total waste generated, followed by the Sumatran
region with 23% while the remaining 22% are spread across other regions. From Figure
5.3, we know that plastic recycling industry is almost entirely concentrated in Java.
Based on data provided by the Association of Plastic Recycling Industry (ADUPI),
roughly 91% of total recycling industry is located in Java with 41% of the industry are
located in western part, 39% are located the eastern part, and 20% are located in central
part. This data shows that Java is the center of plastic recycling industry in Indonesia.
Data shows that Java plastic recycling capacity (880.000 final shelter) is far exceeding
its own plastic recycle waste production (521.000 final shelter). Plastic recycling
industries in Java recycle waste produced not only from Java region but also recycle
waste produced from other regions. Plastic waste from Sumatra and western parts of
Kalimantan are recycled by plastic recycling industries in western part of Java. As for
the eastern region of Indonesia, almost all the plastic waste is recycled by plastic
recycling industries in eastern part of Java.
Plastics recycling industries are generally located in Java due to better infrastructure and
better access to product market. Infrastructure such as electricity and transportation are
important factors for the plastic recycling industry whose business economics is highly
84
dependent on the production efficiency. Java as the biggest plastic products market in
Indonesia, allows cheaper distribution cost to market recycling products thus reduces
the selling price of the products in order to remain competitive in the market. With
uncertain economic margin of the industry, which is currently happen due to various
price fluctuations and regulations, plastic waste recycling industries are difficult to grow
outside the island of Java.
In addition to domestic produced plastic waste, Indonesia were also imported plastic
waste from other countries. Majority of imported waste came from United States
(46.867 tons), Australia (16.027 tons), and United Kingdom (10.120 tons). Other
countries who also export a significant volume of plastic waste to Indonesia are South
Korea, Mexico, Netherlands, Singapore, and New Zealand. Most of imported waste are
landed and processed in Batam. The types of plastic waste that imported by Indonesia
are PET (Polyethylene terephthalate), PS (Polystyrene), and PVC (Polyvinyl chloride).
They were processed to produce pellet and reselled to export market. Besides Batam,
Imported plastic wastes were also found mainly in Jakarta and East Java.
Figure 5.4 Product with PBDEs current treatment diagram
Current treatment for waste containing PBDEs in Indonesia is shown in Figure 5.4. In
Indonesia, the products containing PBDEs that can be recycled are still used without
special treatment so the PBDEs can emits to human. The products that can’t be recycled
incinerated conventionally so the flue gas still contain PBDEs.
85
5.2 GOOD MANUFACTURING PRACTICE (GMP) ON RECYLED
PRODUCTS CONTAINING PBDEs
Good Manufacturing Practice (GMP) is a system for ensuring that products are
consistently produced and controlled according to quality standards. This GMP
reference document is intended to provide guidance on how to fulfil the requirements of
the GMP regulation in the manufacturing, recycling, and exermintation of product
plastic containing PBDEs. The differences between each GMP are listed ini Table 5.1.
Table 5.1 Differences between each GMP

GMP of Plastic GMP of Recycle Plastic GMP for
Difference Containing Containing PBDEs Exermination Plastic
PBDEs Industry Industry Containing PBDEs
Product recall There are products There are product recall in There are no product
recall in this GMP this GMP recall in this GMP
Standard Standard Standards and Standard of

Operational manufacture is specifications covering exermination
provided in IPC plastics waste recovery, (incinerator) provided
Standard including recycling is in chapter 2.11.5 in
provided in ISO this report (Report
15270:2008. yg mana)
Transport Needed to protect Needed to protect the No needed to protect

the products from products from fire or the products from fire
fire or weather weather or weather
In Indonesia, in recycling industry both of men and women involve but mostly by men.
Plastic recycling process that can be done by women is sorting plastic as raw material.
There are contact between humans and plastics in that process. As we know in Chapter
2, PBDEs can enter the human body through skin and breathe. So there is the possibility
that PBDEs get into the human body in sorting process. Another that, the pelletizing
process is possible to expose PBDEs through the process. The PBDEs emission from
the pelletizing process can enter to human body through our breath. So we can say that
PBDEs is possible to expose by the recycling plastic industry for both men and women.
GMP document in this chapter are sourced from International GMP Standard and be
adapted by the data of PBDEs. The contents of this document for manufacturing,
recycling, and exermination of product plastic containing PBDEs is almost similar for
each other. These GMP are provided for both men and women staff in factory. The
difference is on the standard used for specification product and standard operation.
Quality management standard is provided in ISO 9001:2015. This document contains
quality assurance, quality control system, Factory standard, Waste control,
Transportation, Storage and Distribution, Traceability, and Documentation. Contents of
GMP are listed below.
86
5.2.1 Quality Assurance
5.2.1.1 Hazard Inventory
1. The mill shall make an inventory of the hazards relevant to this standard in its
plant that can affect consumer safety and product integrity.
2. The hazard inventory shall be based on the range and the intended use of
products that are manufactured.
3. The mill shall be able to demonstrate that appropriate controls and preventive
measures for the identified hazards, as described in this standard, are
established. Important preventive measures shall be indicated as points of
attention.
4. A review of the hazard inventory should be carried out at least onceper year or
when any process changes (FEFCO, 2006)
5.2.1.2 Risk Analysis

In a risk analysis, every step of the process, from procurement of raw materials to
delivery of products, is categorized for production and contamination hazards, which
could affect the safety of the end product and thus pose a potential risk. All identified
potential hazards must be described and then undergo a risk assessment. This risk
assessment is based on the likelihood of the occurrence of the hazard and the effect the
hazard might have on consumer health if it occurred. The combination of these two
underlined factors gives the risk (CEPI, 2010). The decisions taken in the risk analysis,
and the reasons, including when the effect/occurrence is seen as negligible or will be
eliminated in a next process step, have to be documented in the hazard inventory
overview (CEPI, 2010).
The hazard inventory and risk analysis have to be carried out by qualified persons. The
validity of the risk analysis shall be reviewed regularly, at least once per year and
always when a major process change takes place. Depending upon the result of the
review (which should be ocumented), a repeated risk analysis may be required either in
part, in full or it may not be needed at all.
5.2.1.3 Management Responsibility and Organisation

Mill management has the ultimate responsibility for the GMP system and must take
steps to ensure that it is fully integrated into the quality management system. They must
also ensure that correct systems are set up, maintained, reviewed and documented and
that appropriate personnel are trained and given responsibilities under the system
(CEPI, 2010). Some poins about GMP of Management Responsibility and Organisation
is described bellow:
1. Senior management shall define the Mill’s Quality and Safety policy ensuring
that the mill meets its obligation to manufacture safe product in accordance with
the relevant legislation. This policy shall be documented, implemented,
maintained and communicated to all employees;
87
2. The controls and procedures, resulting from the hazard inventory, shall have
Senior Management commitment, and shall be implemented through the mill’s
documented management systems;
3. The mill shall have a person who is responsible for maintaining the safety and
quality system;
4. The mill shall periodically review customer complaints, claims, audit results and
corrective actions;
5. The mill should implement a system for continuous improvement;
6. The policy shall be regularly reviewed;
7. The mill shall include duties related to this standard in the job descriptions of the
staff (FEFCO, 2006)
5.2.1.4 Specification
Operators must produce and maintain specifications, according to relevant legislation
and the requirements for the finished product, for all raw materials and additives
(functional and process) used in the production plastic product containing PBDEs.
Existing standard is provided in ISO 15270:2008. Documented procedures must be in
place to ensure that those raw materials are used in a way, which is consistent with the
requirements of the end use of theplastic product. Specifications should also be
prepared for warehouses and transport facilities (CEPI, 2010). Some poins about GMP
on specification is described bellow:
1. The mill shall ensure that appropriate specifications exist for incoming materials
and finished goods and that these specifications are adequate and accurate;
2. Specifications shall, where appropriate, be formally agreed with relevant parties;
3. The mill shall operate a specification review procedure (FEFCO, 2006).
5.2.1.5 Complaint Handling

1. The mill shall have a system for the management of complaints;
2. Actions appropriate to the seriousness and frequency of the problems identified
shall be carried out promptly and effectively;
3. Complaint data shall, where appropriate, be used to implement on going
improvements to safety and quality and action taken to seek actively to avoid
recurrence (FEFCO, 2006)
5.2.1.6 Product Recall

1. The mill shall have an effective product recall procedure for all products;
2. The mill shall provide written guidance to relevant staff regarding the type of
event that would constitute an incident and a documented incident reporting
procedure shall be in place;
3. Procedures shall exist to ensure that customers are notified should an incident
take place which has potentially contaminated the product that has been
delivered to the customer;
88
4. All non-conforming products shall be handled or disposed of according to the
nature of the problem and/or specific requirements of the customer;
5. There shall be a person responsible for ensuring that corrective action including
the review of all records of incidents are taken together with preventative action
(FEFCO, 2006)
5.2.1.7 Supllier Monitoring

The written procedures for the approval and monitoring of suppliers, described in the
ISO 9001 management system, should be extended, if necessary, to cover the demands
in the Framework Regulation and the GMP Regulation. The mill should ensure that the
relevant suppliers work according to these regulations (CEPI, 2010).
The mill should demand that the suppliers immediately inform the mill, and update the
plasctic documentation (e.g. certificates), whenever a modification of the raw material
and/or additives is done or when changes have occurred in the regulations which are
referred to in the certificates (CEPI, 2010). Some poins about GMP of supplier
monitoring is described bellow:
1. The Mill shall operate procedures for the approval and monitoring of its
suppliers. This shall include suppliers of materials, transport, warehousing and
services to the Mill, where appropriate, to the requirements of this Standard
(FEFCO, 2006)
2. Where appropriate, suppliers of materials shall comply with a Standard that
meets the same objectives as this standard (FEFCO, 2006)
5.2.2 Factory Standard

5.2.2.1 Site and Premises
1. The site boundaries shall be clearly defined (FEFCO, 2006)
2. Measures necessary to protect the site from any potential contaminants should
be in place and periodically reviewed to ensure they continue to be effective
(FEFCO, 2006)
3. Both inside and outside the premises, suffi cient space shall be left between
walls, furniture, equipment and products to enable effi cient cleaning (FEFCO,
2006)
5.2.2.2 Equipment and Material

1. Maintenance equipment shall be cleared away after use and stored in
designated areas or lockers
2. A planned preventive maintenance programme for plant and machinery shall
be in place and shall address the risks from contamination. Compressed air
that comes into contact with the product should be filtered to prevent any
contamination (FEFCO, 2006)
3. Production tools used shall be clean and shall be stored in a designated area;
89
4. Maintenance work shall be followed by a documented clearance procedure
which demonstrates that contamination hazards have been removed from
machinery and equipment where there is a risk of contamination to people or
environtment (FEFCO, 2006)
5. Where appropriate, equipment shall be available for the effective ventilation
of odours, smoke and vapour
6. Materials handling equipment that comes into direct contact with the product
shall be kept in good condition (FEFCO, 2006)
7. Temporary engineering and modification using adhesive tape, cardboard or
similar materials shall not be permitted, except in emergencie (FEFCO,
2006).
5.2.2.3 Standard Operational

Standards and specifications covering plastics waste recovery, including recycling is
provided in ISO 15270:2008. It also establishes the quality requirements that should be
considered in all steps of the recovery process, and provides general recommendations
for inclusion in material standards, test standards and product specifications.
5.2.3 Quality Control System

Existing procedures in an ISO 9001 (or equivalent) system should be amended, if
necessary, to integrate the monitoring and documentation of the implementation and
achievement of GMP and identify measures to correct any failure to achieve GMP
(FEFCO, 2006).
5.2.4 Waste Control

1. There is routine analize for checking PBDEs in waste and in the air, sediment
and water in mill area. The analytical method to meausure PBDEs content
shows in Table 5.2.
2. Systems shall be in place to minimise the accumulation of waste in production
areas (FEFCO, 2006)
Table 5.2 Analytical Method for PBDEs (US EPA, 2014)

No Analytical Method for PBDEs
1 Analytical methods used for PBDEs detection include gas chromatography (GC)-mass
spectrometry (MS) for air, sewage, fish and animal tissues; capillary column
GC/electron capture detector (ECD) for water and sediment samples; GC/high
resolution MS (HRMS) for fish tissue; and liquid chromatography (LC)-GC-MS /flame
ionization detector (FID) for sediments (ATSDR 2004).
2 Analytical methods for PBB detection include GC-ECD for commercial samples, soil,
plant tissue, water, sediment, fish, dairy and animal feed; high resolution GC (HRGC)
/HRMS for fish samples; GC-FID/ECD for soil; and LC-GC-MS/FID for sediment
90
(ATSDR 2004).
3 EPA Method 1614 uses isotope dilution and internal standard HRGC/HRMS to detect
PBDEs in water, soil, sediment and tissue (EPA 2007).
5.2.5 Transport, Storage, and Distribution

1. All transport shall be suitable for the purpose, well maintained;
2. Ongoing contractual arrangements with transport companies shall include
requirements for safety;
3. When the material transported is susceptible to weather damage, arrangements
shall be made to protect the material;
4. The Company shall have a procedure for checking vehicles transporting
finished products;
5. Incoming and outgoing vehicles shall be registered and nonconformities
recorded;
6. Contracted transport, storage and distribution shall be undertaken in such a way
as to prevent raw materials or product being exposed to the risk of
contamination of volatile mateer containin PBDEs;
7. Storage including off site storage shall be controlled to ensure no cross
contamination and setting to room temperature;
8. No manufactured products shall come in direct contact with fire (FEFCO,
2006).
5.2.6 Traceability
1. The company shall adequately identify all incoming materials and be able to
trace work in progress and finished product at all stages during manufacture,
storage, despatch and, where appropriate, distribution to the customer;
2. The storage times for the various production records shall be appropriate to the
traceability requirements and the lifetime of the product (FEFCO, 2006).
5.2.7 Documentation
1. The company shall establish and maintain documented procedures to control all
documents and data that relate to the requirements of this Standard;
2. Records shall be maintained in order to prove that technical and he procedures have
been followed. Records shall be kept for an appropriate period;
3. All documents in use shall be properly authorised and be the current version;
4. All changes and amendments to documents critical to product safety or quality
system procedures and covered by the Standard’s requirements shall be recorded
(FEFCO, 2006).
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5.2.8 Labeling System
Labeling systems of flame retardant in plastic materials used in articles approach (ISO
1043-4, 1999) provides uniform symbols for flame retardants added to plastic materials
throughout the supply chain. It is especially relevant for recycling of plastics that could
contain commercial pentaBDE and commercial octaBDE. Key elements include:
§ It provides voluntary industrial guidelines harmonized for industry worldwide
through the International Organization for Standards (ISO) standard.
§ It is a preventive system informing recyclers, in particular, of the composition of
the plastic based on specific markings on the materials.
§ It involves industry markings (in effect a “label”) with the use of code numbers,
e.g. code-18 is pentaBDE and octaBDE; code-20 is polybrominated biphenyls
(hexabromodiphenyl).
§ Code markings apply to chemical contents more than 1% for flame retardant
(FR) 18.
§ The government is not involved.
The ISO standard, while based on an international approach by industry, applies only to
specific flame retardant in plastic materials used for specific purposes. The following
modification for ISO 1034-4 could enable the identification of all POPs added to plastic
components of articles in the supply chain or included in plastic from waste electrical
and electronic equipment (WEEE) destined to be recycled to new articles (recyclate):
§ Industry prepares a list of all POPs that could be contained in plastics, and the
ISO norm is added. The list could be based on Table A of the JIG.
§ Each POP gets a code number and the POP identifier is “POP and code
number”. The cut-off concentration of the POP below which no label is
necessary could be 0.1%.
§ Marking is as visible as possible, and performed by moulding on to the product.
“POP0” with “0” placed after the POP means “no POP”; marking is not
necessary for mass concentrations of 0.1% or less (cut-off level).
§ The content of POP in recycled materials could be marked by adding the
concentration value in % to the POP identifier, e.g. “POP and code number
10%”.
5.3 BAT/BEP Guidelines Development Assesment on Plastic

Recycling Activities
To be able to conduct a BAT/BEP guideline study (the process of sorting products
containing PBDE and non PBDE at recyclers), it is necessary to understand things
related to the term BAT / BEP and proven technology, types and characteristics of
PBDE / Non PBDE, brominated flame retardant (BFR), plastic and its products that use
PBDE / non PBDE that will be sorted, the intended plastic recycling industry players.
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a. Definition of BAT/BEP
• BAT is the most effective and advanced stage in the development of activities
and their methods of operation, which indicate the practical, which indicate the
practical suitability of particular techniques.
• BEP describes the application of the most appropriate combination of
environmental control measures and strategies.
Based on these definitions, the study of the BAT / BEP guidelines in the process of
separating products containing PBDE / non PBDE in recycling businesses will be
directed based on the combination of existing technology status (results of literature
review) and status of local wisdom conditions for BAT / The BEP will be expected to be
applied effectively, practically and in accordance with existing conditions.
b. Sorting PBDEs/non PBDEs

Sorting can be carried out effectively including if it is known the characteristics of the
sorted material and its sorting technique. In Guidance on the BAT for Environmental
Practices for Recycling and Disposing of the Stockholm Convention on POPs, 2012
from UNIDO, sorting techniques can be describe as follows:
§ Manual sortir of POPs/PBDEs
The recycling industry that manages CRT monitor housing is based on
experience on polymer types & FR types (Guidance p. 37). The case in Sweden
manually combined with using XRF for spot checks, it is claimed that the
method meets conformity according to European directive. The case of Japan &
Europe, based on the year of production (since 1990, POP-PBDE has been
phased out gradually).
§ The techniques and methods of possible polymer separation contain BFRs from
WEEE. Table 5.3 shows combination technique on sorting techniques.
Table 5.3 Combination of sorting techniques, material inputs, products,

development status and economic review
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Based on this data, the sampling on the product with the suspected BFR content in this
way can be used as a preliminary proof in sorting efforts through sorting methods based
on the origin of the product. Because most informal recycling industry players still
prioritize low-cost processes, even if possible without additional costs, and require a
simple process that is able to absorb a lot of labor, then the selection of BAT/BEP as far
as possible according to the conditions.
Easy and relatively inexpensive sorting techniques in the implementation are sink &
float methods. Recycling agents in Batam has used this, although the separation is not
specific to the sorting of plastic containing BFR but plastic in general. Table 5.4 shows
possible processes and separation principles for eliminating BFR.
By knowing the approximate range of use of the flame retardant composition, the type
of flame retardant and density in the type of polymer used, the approximate range of
mixture density can be estimated. This can help estimate the density of liquid media
used in the technical separation of polymer waste based on the sink and float method.
Table 5.4 Possible process and separation principle for eliminating BFR
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5.4 Dioxin Formation and Test Results in Plastic Recycling
Locations
5.4.1 The formation of Dioxin

Dioxins are environmental pollutants that are categorized as POPs and toxic. Dioxin is
classified as a chlorine-containing compound, namely Polychlorinated dibenzo dioxin
(PCDD) and Polychlorinated dibenzo furan (PBDF). In plastic recycling, the potential
for dioxin formation is greater if polymeric materials are subjected to thermal processes
such as thermal stress (Extrusion and Molding) and incomplete combustion. The
thermal process in plastic products containing BFR has the potential to produce
polybrominated dibenzo dioxin (PBDD) and Polybrominated dibenzo furan (PBDF) by-
products; or Poly Brominated-clorinated dibenzo dioxin (PXDDs) and brominated-
clorinated dibenzo furan poly (PXDFs), which can be seen in Figure 5.5.
Based on the results of the literature review, dioxin can be reduced in the recycling
industry if the conditions that trigger dioxin formation can be prevented or avoided,
including:
1. Processing time
2. Temperature process
PBDD / PBDF can be formed at temperatures of 100 - 300 ° C accompanied
by mechanical stress.
2. The presence of precursors.
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Figure 5.5 The mechanism of dioxin formation in the thermal-stress process and
imperfect combustion
In thermal stress conditions (production or recycle process), products containing PBDEs

will be very easy to form PBDD/PBDF while other PBBDs/TBBPA, Brominated
styrene or brominated phenoxyethan) have not been observed PBDD/PBDF. Therefore,
coding on products containing PBDE in recycling industries, handling in the process
(both thermal stress and incomplete combustion) with due regard to conditions that can
trigger dioxin formation is very important. Because the number of dioxin products
formed on the ppm scale and the constraints of limitations were able to measure dioxin
identification during the process, verification of the main variables influencing the
formation of dioxins in the laboratory was not carried out.
In uncontrolled combustion, the factors that influence the formation of dioxins are the
presence or absence of BFR in the waste to be burned. In another literature it is stated
that the presence of several metals in combustion reactions or thermal stress processes
in materials containing bromine in environments containing chlorine (such as PVC,
HCl, chlorophenol, chlorobenzene, chlorinated aliphatic, PCB) can trigger dioxin. The
metals indicated to function as catalysts include: Cu, Fe, Zn, Al, Cr and Mn.
It can be concluded that to reduce dioxin formation in the recycling industry it is
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necessary to do this:
1. Efforts to understand the material and dangers of dioxin and things that can
encourage its formation.
2. Further data on potential products that use PBDE in the recycling industry and
derivative products that have been recycled in the utilization of other products.
3. The government's participation in localizing products in the recycling industry
which is known to contain PBDE and compensation for the localization of these
products in order to avoid process treatment that triggers dioxin formation.
5.4.2 Sampling and Test Results

Determining sampling locations is important. The guidelines for sampling are as
follows:
1. Does the recycling location do thermal processes or combustion?
2. Type of polymer material to be recycled → Does the polymer material contain
BFR?
3. Are the BFRs used as PBDEs?
4. What is the condition (temperature and time) of the thermat process?
Sampling can be done on several media, which can be seen in Table 5.5. Whereas for
sample handling, the condition of the sample needs to be stored at 4 ° C until the test is
carried out. Tests are carried out using the Gas Chromatography-High Resolution Mass
Spectrum (GC-HRMS) or atmospheric-pressure chemical ionization tandem mass
spectrometry (APGC-MSMS) with measurement levels up to ppb level. Testing of soil
dioxin (solid) refers to the standard method of EPA 1613 B while for testing on oil
(solution) refers to the standard method EN 16215: 2012.
Table 5.5 Media for testing

Media Sample size
Solution 1-2 liter
Solid 1-4 atau 8 ons botol
Body tissue 50-100 g (frozen)
Ambient air PUF Catridge
Stack air XAD-2 Resin Trap
To conduct surveys and sampling to the perpetrators of the plastic recycling industry
process in order to obtain test samples for testing dioxins, several attempts have been
made as follows:
a. Communication with the third party PBDE (UBAYA) project, information was
obtained that the recycling industry in Banyuwangi collected plastic waste not
only from East Java but also from outside East Java such as Bali, Kalimantan
and Sulawesi. Collectors only do enumeration and do not do processing.
b. Communication with APDUPI was conveyed by industries that did processing,
but did not get permission for visits to the company. However, we obtained
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samples in the form of pellets, intermediate products that experienced thermal
processes from the recycling industry built by APDUPI. Screening testing for
identification of BFR / PBDE content using GC-MS, no PBDE (tetra-deca BDE)
content was found. So that the test for dioxin content is not done.
c. Communication with APDUPI: Discussion and submission of proposals for visits
to the APDUPI target industry in the context of survey and sampling for dioxin
testing.
d. Survey of the recycling industry in Cianjur: Based on the results of a literature
study related to dioxin formation, the output of item 2 is in the form of testing
dioxin in the recycling industry which begins with surveys and sampling carried
out taking into account the conditions that trigger its formation. Noting the
results of visits in Batam and Cianjur and information on the results of surveys
of other LoA recipient teams in the recycling industry, it can be concluded that
the potential waste products containing PBDE (EEE applications) are mostly
only as collectors and do not process themselves / directly. This is related to the
amount, which is far less than the number of commodity plastic waste products,
while different materials sometimes require the characteristics of different
process equipment and processing in small quantities through substitution with
other materials requires regulation and cleaning between processes that require
more treatment. Therefore many of the recycling actors related to the ABS
material for this EEE application are only collectors.
Due to the difficulty to survey and sampling the plastic recycling processing industry,
the dioxin testing carried out as follows:
1. Sampling was not carried out on recycling industries that process material that
has the potential to contain PBDE (ABS, HIPS, PUR); however, it was done at
the location of used plastic collectors which burned PUR materials used in
automotive applications that were no longer used. The sample is in the form of
soil and cooking oil taken around the location of the recycling agent. Test results
on the land of the location of a special combustion that was not mixed with
household waste in the recycler (collector), obtained dioxin (PCDD/F) content
of 1489.46 pg (WHO-PCDD/F TEQ/g). At the location of non-special
combustion, mixed with household waste, dioxin (PCDD/F) content of 453.01
pg (WHO-PCDD/ F TEQ/ g) was found. Whereas in cooking oil samples taken
nearby, dioxin (PCDD/F) content of 0.7572 pg (WHO-PCDD/F TEQ/g) was
obtained (maximum limit of 1.82 pg (WHO-PCDD/F TEQ /g).
2. Based on the potential for dioxin formation, the testing of dioxin content can be
done on plastic resin material that has not been processed, after the process and
its products and in the environment around the process. Therefore, testing was
carried out on ABS samples in the form of pellets received from the APDUPI
target industry and product samples on the market suspected of using ABS resin.
The test begins with testing the type of resin and PBDEs content (testing at
STP). If the resin is known to contain PBDE, then the next test will be followed
by testing the dioxin content (testing in Saraswanti). The test results are
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summarized in Table 5.6 in the test sample in the form of pellet samples and
product samples. (cara baca hasil testnya??? ND, MD, TBB????) In Figure
5.6 can be seen illustrating the process in plastic and the driving force of dioxin
formation. In Figure 5.6 can be seen illustrating the process in plastic and the
driving force of dioxin formation.
Table 5.6 Test results for identification of PBDE content in ABS pellet samples recycle
and children's toys on the market
Test results
GCMS
Code Types of Production
No Product Tetra-
No. company year
Deca RT
BDE
Mainan Anak -
1 4042716 PMDN > 2009 ND MD
Rubik
Pellet ABS-
2 4042717 PMDN > 2009 ND 8,2 (TBB)
recycle
Figure 5.6 Illustration process in plastic and the driving force of dioxin formation
In conclusion, the implementation of activities on the output of item 2 (CEK tugasnya

UBAYA) is taken based on a limited number of test samples due to conditions:
1. Some survey locations in the recycling industry do not carry out heat processing
from the origin of EEE products made from ABS resin but only as collectors.
Products from collectors are then sold directly or chopped first before being sold
to other recycling industry players who carry out the process. But industry
processors are not willing to visit. The results of testing the identification of
content in pellet samples (having undergone a thermal stress process) ABS
material obtained from the Apdupi assisted recycling industry, PBDEs (Tetra -
DecaBDE) was not found, so dioxin testing was not carried out.
2. Testing of dioxin in soil samples and cooking oil from the location of the recycling
industry that does combustion on PUR-based foam products that have not been
used is obtained:
a. The original land of the location of a special incinerator, which is not mixed with
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household waste: dioxin (PCDD/F) content of 1489.46 pg (WHO-PCDD/F
TEQ/g).
b. The land from the location of the incinerator is not special, mixed with household
waste, found dioxin (PCDD/ F) content of 453.01 pg (WHO-PCDD/F TEQ/g).
c. In the cooking oil sample taken nearby, dioxin (PCDD/F) content of 0.7572 pg
(WHO-PCDD/F TEQ/g) was obtained (maximum limit of 1.82 pg (WHO-
PCDD/F TEQ/g).
5.5 MINI DEPO DESIGN FOR PLASTIC RECYCLING

To reduce PBDEs and UPOPs emissions to the environment due to uncontrolled
disposal of waste, especially indicated plastic waste can release hazardous materials, it
is necessary to make a waste dump (mini depo) that serves to sort and process the waste
into products that can be recycled (recycle). The purpose of this activity is to develop a
concept for the design of the construction of a hazardous and non-recyclable plastic
waste dump (Mini Depo) and all its components in East Java.
Mini depo is designed as a place for separating and processing waste/garbage,

especially plastic waste. Some things that need to be considered and carried out in the
mini depo development plan are as follows:
1. Literature study on mini-depo and local government regulations.
2. Field surveys in several existing waste disposal sites.
3. Survey of several locations that will be used as waste dumps (mini depo).
4. Perform mini depo design by taking into account the type, composition and
capacity of the waste to be processed, product specifications to be produced
and the development of processes and equipment used.
5.5.1 Survey Results

To make a mini depo design in the recycling industry, the activities that have been
carried out are surveys to collectors and the plastic recycling industry. In general,
collectors are only involved in the process of separating plastic waste by type, for
example PP, PE, PS, and so on. Furthermore, the plastic that has been collected based
on their respective types will be distributed to the recycling industry.
In Yogyakarta there are quite a lot of garbage banks, because Enviromental Agency in
Yogyakarta has a waste reduction program that goes into the landfill by making a
garbage bank in each RW. Every garbage bank is only open once a week on
predetermined days. For example the Surolaras Waste Bank receives waste only on
Mondays. All activities were only carried out on Monday and assisted by 6 employees
consisting of 4 female employees and 2 men. Female employees are in charge of sorting
and men have the duty to lift up.
From the recycling industry that has been visited, generally they only recycle until the
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enumeration stage. After plastic waste is grouped according to its type then the plastics
go into the chopping machine and then to the washing then dried. After drying, the
plastic count is ready to be distributed to the next industry. In Malang Waste Bank, the
waste received is grouped by type and has been neatly arranged in place. After being
grouped by type, there are several types of garbage such as beverage bottles which are
recycled by being chopped and then washed and dried.
The results of the analysis of well water and plastic waste water in the Mojokerto area
showed that solid dissolved and turbidity from plastic waste water waste exceeded the
standards of clean water according to Minister of Health Regulation No. 416 of 1990.
While the content of these parameters in wastewater has increased compared to well
water, and the portion is almost close to the maximum limit specified. The parameters
that experience an increase in its content are: iron, hardness, chloride, manganese,
nitrate, zinc, sulfate, detergent, and organic substances.
5.5.2 Design of Mini Depo

INPUT
The type of waste that will be processed in this Mini Depo is plastic waste from
collectors. The waste capacity to be processed is planned for 5-10 tons / day. Some
types of plastic received especially those indicated contain PBDE materials such as
ABS and HIPS types and other types of plastic such as PP, PE, PET, PS, PVC and
HDPE
OUTPUT
The products produced from this mini depot are mainly pellets from ABS and HIPS
types., while other types of plastic in the form of plastic chopped.
PROCESSES
The process or activities carried out at the Mini Depo include: preliminary processes,
sorting, physical processing, cleaning, forming recycled products and packaging.
1. Pretreatment process
The preliminary process is the initial stage of separation of waste according to the
type of waste that enters the collector and knows the amount by means of
weighing. Before further processing, this waste is temporarily stored in the
reception room for plastic waste.
2. Sorting Process
The sorting process is done mechanically by using conveyor belts and human
power to simplify and speed up the sorting process. Special mixed plastic waste
can be sorted according to type (ABS, HIPS, PP, PE, PET, PS, PPVC and
HDPE). The results of pilahan from various types of plastic are stored directly in
a storage space of 8 spaces located along the conveyor belt used.
3. Physical processing
In this process plastic waste, which has been sorted according to its type, is
carried through a conveyor belt to the crusher machine to do size reduction. The
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chopper machine is used with a capacity of 300 kg / hour with a production
capacity of 3 tons/day with 10 hours of operation per day.
4. Cleaning Process
Plastic flakes come out of the crusher then enter the washing water bath to be
washed so that clean plastic counts are produced. Laundry water is then
processed in the waste treatment area, while plastic chopped is dried in an open
area with the help of sunlight. Furthermore, it is packaged in a bag with a certain
weight and stored in a plastic storage room and ready to be marketed.
5. Product Formation Process
This stage is only done specifically on ABS and HIPS types. Cleaned plastic is
formed into pellet granules using the Extruder tool. Furthermore, this pellet form
product is packaged in the packaging process with a certain weight according to
the needs and stored in a plastic pellet storage room.
LOCATION
The Mini Depo will be built in East Java are located in Mojokerto and Malang because
in the area there are many plastic waste collectors and garbage banks and there are still
large areas of vacant land with relatively cheap prices.
LAYOUT
The size of the mini depot area needed is approximately 40 x 50 m2, which can be seen
in the lay out (Figure 5.7-5.9) which consists of:
1. Plastic waste reception room (loading)
2. Eight (8) spaces for storing various types of plastic
3. Crushing place
4. Peletizing room
5. Waste treatment unit
6. Plastic and pellet storage space
7. Belt conveyor
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Figure 5.7 2-Dimension lay out of Mini Depo from top view
Figure 5.8 3-Dimension lay out of Mini Depo from top view
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Figure 5.9 Detailes of crushing and washing sections
6 REDUCING RELEASES OF UPOPs AND PBDEs

FROM UNSOUND OF PLASTIC DISPOSAL
PRACTICES
6.1 Mapping of Plastic Waste Containing PBDEs

To find out the management system and distribution flow (displacement) of plastic
waste, especially in the "downstream" section, namely in plastic waste collection
activities, a survey has been carried out with waste collector respondents. The purpose
of the survey was to find out how garbage collectors treat the garbage they collect. This
data can inform potential PBDEs and POPs emissions at the level of garbage collectors.
The survey was conducted in six districts/cities in East Java, namely Surabaya,
Sidoarjo, Malang, Mojokerto, Gresik, and Banyuwangi. Sampling is done randomly in
two ways, first coming to the respondent at the location of his business, and inviting
respondents to the discussion program held in conjunction with the related instant.
6.1.1 Distribution of respondents per area

The survey was conducted on garbage collectors in Surabaya, Sidoarjo, Mojokerto,
Gresik, Banyuwangi, and Malang. In total there are 90 respondents whose distribution
of numbers in each area can be seen in Figure 6.1.
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surabaya sidoarjo malang
mojokerto gresik banyuwangi
20%
29%
5%
7%
12%
27%
Figure 6.1 Distribution of respondents per area
6.1.2 Respondent Profiles

Ninety survey respondents consisted of 73 men and 17 women aged between 20 - 68
years, with an average of 39.5 years. His educational background also varies, from
elementary to undergraduate (Figure 6.2).
Elementary school
6%
7%
Junior high school
28%
Senior high
school/vocational high
school
40%
19% Diploma
Bachelor
Figure 6.2 Educational backgrounds of respondents
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6.1.3 Types and volumes of waste collected
The types of garbage collected are categorized into six, namely:
1. Plastic packaging: plastic for food packaging, disposable drinking bottles,
plastic bags, disposable plastic cups
2. Electronic plastics: fans, computers, irons, dispensers, electrical cable insulation,
microwaves, rice cookers, washing machines, refrigerators, TVs, VCDs / DVD
players, copy machines, air conditioners, radios, motorbikes
3. Non electronic plastics: foam foam, carpet, plastic chairs / tables, plastic
cabinets, plastic hoses, thermos, PVC, crates, helmets
4. Plastic container: jerry cans, water tanks, plastic drums, gallons, buckets, tubs,
etc.
5. Container chemicals: cans, glass bottles, iron drums, glue containers, lubricating
containers, shampoo bottles, etc.
6. Other: factory-left plastic, scrap metal, glass bottles, paper, iron, cardboard,
glass, straw, duplex, rubber, sacks, paper, aluminum, organic waste, etc.
The number of respondents and the type of waste collected can be seen in Figure 6.3.
70
63
60
60
50
42
39
40
30 25
20
10
10
0
Packaging Electronic Non Plastic Container Etc
electronic container for chemical
materials
Figure 6.3 The number of respondent and types of garbace collected
The type of waste suspected to contain PBDE is electronic plastic waste and non-
electronic plastic waste (including the car dashboard, children's toys). Of the total 90
respondents there were 48 respondents (53.3%) who collected one or both types of
waste. If viewed from the area, it can be seen that Surabaya, Malang, and Banyuwangi
occupy the 3 largest numbers of garbage collectors suspected of containing PBDE.
Therefore the PBDE hazard awareness program for the first year of the program began
in the three cities. This can also be one of the considerations for choosing a mini depot
construction site.
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The data above can be confirmed again with data on the volume of waste collected.
There is a slight difference between the respondent's answer about the type of waste that
is accommodated and the volume of each. This difference may occur due to two
reasons, first, almost all respondents answered the survey questions based on memory
without written data, second because some types of waste were not routinely
accommodated. The first reason shows that there are still many respondents who do not
have a good recording system. This makes it difficult for the team to track the presence
of garbage suspected of containing PBDEs. So it is offered a computer-based inventory
system (PC), which will be explained further at the end of this report.
In general, the respondents did not know for certain the volume of waste collected in the
same unit because some types of waste were weighed and several others were calculated
per unit; like electronic plastic waste and glass bottles. There is even one respondent
who only receives plastic bottles of beverage packaging whose volume is calculated per
unit, which is 10,000 bottles / day. The total volume of waste collected by 90
respondents was 189,668.2 kg/day and 300 iron drums, 700 glass bottles, and 10,000
plastic bottles of beverage packaging. Of the total daily waste volume, 21.36% is the
type of waste suspected to contain PBDEs, namely electronic and non-electronic plastic
waste.
Some respondents were unable to provide detailed data on the volume of waste because
they did not do the sorting of garbage collected, or did not start operating their business.
Each respondent made waste sorting based on their own interests; some sort by
function, type, size and color. There is also a sort based on smell after being burned,
plastic type, and selling feasibility.
6.1.4 Collecting Process and Continuing Treatments

Respondents collect garbage in several ways. Some collect themselves, work together
with scavengers, use the waste bank system, and others. Some respondents conducted
more than one method of garbage collection. Furthermore, the garbage collected is
sorted according to type, size, color, function, odor, and selling feasibility. Then some
respondents gave further treatment such as washing, stripping, counting, drying and
packaging. There were 7% of respondents doing special solvent washing. The solvents
used are soap, salt, sospen, marlon, and tepel soap. Garbage is stored in special areas
with zinc roofs, roof tiles, asbestos, or plastic, and cement/tile/ceramic or earthen beds.
6.1.5 Waste Distribution

Waste that has received further treatment is then sold to industries or larger collectors,
disposed of, burned, stockpiled, exchanged, or recycled. The proportion of each can be
seen in Figure 6.4.
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Thrown stockpiled
away 8%
Sold 13%
6%
Burned Sold to
15% larger
Others collector
7% 5%
Sale to barter
industry 1%
51% Recycled
1%
Figure 6.4 Waste distributions after continuing treatments
6.1.6 Knowledge of PDBEs

Before the socialization of PBDEs, almost all respondents did not know about PBDE. A
small number of respondents whose knew, got information about PBDE from friends,
officials, articles, previous workplaces, packaging labels, or directly from an incident.
In addition to through survey activities, data collection and information related to the
presence of plastic waste suspected of containing PBDEs is also obtained through
observation and interviews in the recycling industry. The industry chosen is the industry
that receives and processes "solid" type of plastic waste, which is a type of plastic that is
widely used as raw material for electronic packaging and children's toys.
There are three companies in Banyuwangi, which are data sources, of which two still
process plastic waste while the other does not process plastic type waste. From the
results of the interview, the following information is obtained:
• Solid type plastic waste is obtained as an inseparable part from collectors. For
Banyuwangi, plastic waste is mostly from Bali.
• The amount of plastic waste is around 10-20% of the total plastic waste received
by the company. This correlates with total production; for example, two
companies that still process plastic waste at home each produce an average of 20
tons/month of total plastic chopped production of 200 tons/month; and 30
tons/month from the total production of plastic chopped 150 tons/month
• The type of plastic waste treatment process requires more complex efforts,
including related to the sorting system (it is not enough to only be based on
visuals but need additional methods, namely the common one is floatation
technique) and the need for a sharper type of knife
• Production (chopped) of type plastic waste is sent/exported abroad, where China
becomes the main absorbent country (for boxes of companies in Banyuwangi
that are still operating, the products are all sent to China)
• The price of plastic type garbage is not as good as other types of plastic (eg PET,
PP), so there are not many business people who want to process it.
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• Even though it is no longer processing hard type plastic waste, the supply of raw
material (plastic waste) still allows it to be mixed. In industries that no longer
process hard type plastic waste, this type of waste is left to accumulate without
further processing. Usually there are other collectors who want to buy and then
deposit it to the processing industry. If this does not occur, the type of plastic
waste will still be piled up (without a special protected place).
From the surveys and field observations that have been carried out, several important
things are related to efforts to prevent PBDE and UPOP emissions, especially from the
process of plastic waste disposal. These things are:
1. The presence of plastic waste suspected of containing PBDE (such as electronic
packaging, cables, children's toys) is in the garbage collection place. This
category of plastic waste is known as "kerasan" plastic waste (for the East Java
case).
2. The average portion of the type of plastic waste is 20% of the total plastic waste
collected by the waste collector or received by the recycling industry that
processes it.
3. In industries that are still processing plastic waste at home, the products
produced so far have been exported (the main destination country is China)
4. The sorting process by the waste collector is carried out by reference to the type
of plastic, which correlates with the economic value.
5. The process of collecting/storing plastic waste is still carried out in very simple
conditions. Facilities to prevent possible PBDE emissions into the environment
are minimal.
6. Knowledge of PBDE is still very common for the recycling collector and waste
collector businesses.
6.2 ROAD MAP ON PLASTIC WASTE CONTAINING PBDEs

MANAGEMENT
With an indication of the presence of plastic waste containing PBDE, a structured effort
is needed to achieve the goal of "PBDE-free" as also the final target of the Stockholm
Convention. Apart from being structured, this effort must also be carried out in an
integrated manner, starting from the initial chain of PBDE material distribution to the
"downstream" part, namely in the waste management process.
Table 6.1 shows the flow of PBDEs material while providing information about current
conditions and potential emissions that may occur at each stage. The PBDEs material
management road map is outlined in the form of a strategy divided by implementation
time, short term (0 - 2 years), medium term (up to 5 years) and long term (up to 10
years). The road map table is shown in Table 6.2.
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Table 6.1 Flow of PBDEs materials
Import Upstream industry Distributor Consumen Waste Collector Recycling industry
Raw materials/ Final products Sampah Terpilah

Produk Jadi
intermediate products (Tercacah)
Sampah
Final Products
Recycled products
Export
Present Condition
• There is no policy • Not fully have an • Not fully have an • Do not have access • Not yet fully • Not yet fully
related to prevent/ understanding of the understanding of to product knowledgeable knowledgeable about
control raw materials/ impact of using the impact of information that about the impact of the impact of PBDE
products containing PBDEs material using PBDE contains PBDE PBDE on the on the environment
PBDEs (especially those who material on the material environment and and health
• There is no adequate do not have a RoHS environment and • Not yet fully health • Not all have the
knowledge and certificate) health knowledgeable • Not all have the correct PBDE-based
capacity in the • There are industries • Not yet have a about the impact of correct PBDE- waste collection/
relevant agencies to that still use PBDEs- good storage PBDE on the based waste storage system
control PBDEs based raw materials in system to prevent environment and collection/ storage • Most of them has not
110
material distribution their production PBDE material health system yet implemented a
processes emissions • The Inventory safe and effective
• Do not have system is still work process (BAT /
knowledge about manual and not BEP)
alternative materials stored properly
• Don't know /apply the • The work system
BAT/BEP concept is still not friendly
to workers' health
protection
Potential PBDE Emission Sources
• Ineffective / safe • Ineffective / • Contact with • Unsafe garbage • Ineffective/ unsafe
warehouse systems unsafe warehouse household devices collection / warehouse systems
• Ineffective / efficient systems that contain PBDE storage systems • Unsafe production
production process • Ineffective / (example: carpets, processes
(not implementing unsafe furniture,
BAT / BEP) distribution electronics)
• Inadequate waste method
management system
Activity to prevent the emission of PBDEs
• Preparation of policies • Access information • Information • Information about • Environmental • Environmental
related to restrictions/ about the impact of about the impact products awareness training awareness training
prohibitions on the using PBDE of using PBDE containing PBDE with a focus on with a focus on the
import of PBDE- (training) and and technical material the introduction of introduction of
based raw materials/ alternative materials training • Environmental PBDE-containing PBDE-containing
products • Technical training on regarding awareness and materials and their materials and their
• Provision of access to identifying PBDE- identification wisdom training in impact on the impact on the
information about containing materials efforts the selection of environment and environment and
alternative materials • Perform gradual • Implementation environmentally health health
for PBDE reimbursement of of the right friendly products • Training regarding • Technical training
• Preparation of policies PBDE material storage system to (PBDE free) correct sorting and on the storage and
related to incentives / • Develop and minimize / storage in order to handling of PBDE-
rewards for industries implement the BAT / prevent possible minimize / prevent containing materials
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that use alternative BEP program to PBDE emissions possible PBDE that are good and
materials as an effort prevent / minimize emissions correct in the
to eliminate the use of PBDE emissions to recycling process
PBDE materials the environment • Training related to
• Training in (including the efforts to implement
identification of appropriate waste the BAT / BEP
PBDE and similar management system) concept in the
materials for relevant recycling industry
agencies in order to
prevent entry
Table 6.2 Road Map of waste management containing PBDEs

Short Term (2 years) Medium Term (5 years) Long Term (10 years) Information
Adaptation and early isolation Isolation stage Elimination/Dextruction Stage
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stage
Material / plastic waste containing
This stage is the preparation stage At this stage, it is targeted that PBDE that has been isolated and
where some of the tools needed plastic waste containing PBDE can cannot be recycled will be destroyed
such as structured informations, be isolated, especially in the Mini with appropriate technology /
skills, policies and physical Depo. facilities. So that the potential
infrastructure will be held. The potential for PBDE material emissions from PBDE / UPOPs
The target of this stage is that emissions and UPOPs in the material can be reduced / eliminated
technical readiness and policy are industry can also be prevented by
produced, PBDE material from the application of BAT / BEP
abroad cannot enter Indonesia and
the ability to isolate containable
plastic waste at the preliminary
level is achieved
Strategy
Compile and disseminate a list of Compile and implement policies
PBDE replacement materials regarding the prohibition on the use
of PBDE material
Compile and disseminate a list of Develop and implement policies Short-term: it is a summary of the
PBDE-based plastic waste related to the system of results of laboratory analysis of
"punishment & rewards" for PBDE content for several types of
industry related PBDE material plastic waste (priority on e-waste)
suspected of having PBDE content
Establish a Mini Depo facility as a Multiplication the procurement of Hold facilities to decompose PBDE Long term: Incinerator facilities
unit to isolate PBDE-based plastic Mini Depo facilities in several material in plastic waste (for can be combined with TPA or Mini
waste locations, especially in big cities example: incinerators) and / or Depo
permanently isolate it (eg secure
landfill)
Compile and implement policies
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related to the prohibition of
importing raw materials /
supporting materials / finished
products that contain PBDE
Develop technical guidelines for
identifying the existence of PBDE
material
Dissemination of environmental Diseminasi pendidikan lingkungan
education related to issues of terkait isu UPOPs dan PBDE
UPOPs and PBDE, including kepada stakeholder lain/pendukung
techniques for identifying PBDE to (masyarakat umum melalui, LSM,
key stakeholders (recycling industry perangkat desa, sekolah)
players, relevant government
agencies)
Prepare BAT / BEP technical Dissemination and application of Encourage and facilitate the
guidelines specifically for plastic BAT / BEP to industries, especially establishment of recycling industries
recycling industry players the recycling industry with the aim in Indonesia so that the absorption of
of preventing PBDE emissions and plastic waste is increasing. In
UPOPs addition, the presence of domestic
industries will make it easier to
control the existence / involvement
of PBDE material in products / raw
materials
Develop policies related to the Implementing the policy of
management of electronic waste electronic waste management (e-
(e-waste) waste), where one of the
important implementations is the
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ability to isolate this type of
waste in the Mini Depo
Implement an inventory system

for waste collector and / or
recycling industry to obtain
information (detect) the presence
/ amount of plastic waste
containing PBDE
115
6.3 INVENTORY SYSTEM CONCERNING PBDEs PLASTIC
WASTE
From the survey results, it is suspected that the waste recyclers and garbage collectors
are still less orderly in terms of recording commodities. This can be seen from the
inconsistency of response to several related questions. For this reason, a computer-
based system (PC) is created that can help recyclers and garbage collectors put their
administration in order.
The making of this system begins with studying the process that occurs at the place
where the garbage collectors are. From the results of observations and interviews, there
are three major processes, namely when waste comes, the waste is processed and the
waste is ready to be distributed (sold). When the garbage comes, it will be sorted first
before weighing and the purchase price per kilogram per type is determined. After the
agreement is reached, the transaction is carried out. Furthermore, the sorted waste is
finely sorted again, for example the beverage-packaging bottle will be separated from
the lid, label and lid. Then the sorting results are weighed back to determine the wages
of the workers who process them. Sorted waste will be ready to enter the next process.
This process depends on the scale of the business of garbage collectors. Small-scale
garbage collectors will directly sell their sorting results to larger collectors. While larger
collectors will be proceed to the process of enumeration or grinding. In each process
reconsideration will always be carried out to ensure the number of transactions in
accordance with reality.
Based on these observations a system has been created with features that are in
accordance with the process described previously. The system will start on the home
page that contains various features provided. Users can view, add, change consumer
lists, list products before grinding or after grinding. Users can also record sales and
purchase transactions that will automatically adjust the volume record of the related
item, for example when the user records a bottle purchase transaction of 10 kg the bottle
data will increase by 10 kg. Users can also make adjustments to data storage in the
event of shrinkage by pressing the adjustment button. Users can also see transaction
recapitations on the report feature.
This compiled Inventory System has been introduced to the waste collector community,
Waste Bank and Recycling Industry in the cities of Banyuwangi, Malang and Surabaya.
Through the group discussion forum some feedback has been collected and used as a
basis for improvements to the system. The interest in implementing this system in the
waste collection business unit is very large. It is expected that with the application of
this system, regular monitoring and recording of plastic waste can be carried out. Thus,
in addition to the administrative benefits for the manager itself, this system can be a tool
to find out the amount of plastic waste produced and can be reused. More specifically,
with this system monitoring and measurement of plastic waste suspected of containing
PBDE (type of "hardness") can be done. This will greatly help the development of
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strategic efforts in order to prevent possible PBDE material emissions.
6.4 ENVIRONMENTAL EDUCATION MODULE CONCERNING

ENVIROMENTAL AWARENESS
The environmental education module is based on two sources, namely
literature/bibliography/references and from observations in the field. In addition,
discussions with several non-governmental organizations and institutions that made
environmental conservation efforts in Surabaya were carried out to enrich the content.
The modules that have been compiled have two parts, each of them:
1. Module 1 (Environmental Awareness) is a module that provides a general
description of the conditions of plastic management in Indonesia.
2. Module 2 (Information about PBDEs). The second module is more specific
about PBDE information.
A detailed description of the environmental education module that has been made can
be seen in the syllabus below:
6.4.1 Syllabus of Module 1

1. Identity
Program : Reducing Releases of PBDE and UPOPs Originating from
Unsound Waste Management & Recycling Practices & The
Manufacturing of Plastics in Indonesia (UNDP Project)
Name of activity : Environmental Education Module Concerning on Plastic
waste
Modul duration : 90 menit
2. General description
This material is intended for collectors and recycling industries that illustrate how
the conditions of plastic waste management exist in Indonesia. There are several
topics that will be given in this study. The first topic about the fact of plastic waste
in Indonesia, which discusses the amount of plastic waste produced and its
management is still poor so that it pollutes the environment. The source of plastic
waste will also be discussed in this learning. As known, the sources and types of
plastic waste are increasingly diverse so that better management of plastic waste is
needed.
The negative impact of plastic waste provides knowledge about what the
consequences of managing plastic waste are bad for the environment and human
health. Furthermore, what can be done is to apply methods or ways to reduce the
amount of plastic waste produced, one of which is recycling. Recycling can reduce
the amount of plastic waste produced to approximately 15% but there are several
characteristics of plastic waste that make it difficult in the recycling process.
Collectors and recycling industries play an important role in reducing the amount
of plastic waste thrown into the environment. Indirectly the existence of collectors
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and the recycling industry has helped preserve the environment and prevent
environmental damage due to plastic waste disposal.
3. Learning Outcomes
Participants understand their role in preserving the environment and preventing the
disposal of plastic waste through the collection and utilization of plastic waste.
4. Module 1 Specific Learning Topics
Learning Learning Teaching

Indicator Study materials Time
outcomes methods materials
Participants know 1. Participants 1. Facts about Lecture 20 Power
the facts can explain plastic waste minutes Point
regarding plastic the facts produced in
waste in regarding Indonesia
plastic waste 2. Plastic waste
Indonesia and in Indonesia is a source of
how the waste 2. Participants environmental
pollutes the are able to pollution
environment explain how
plastic waste
is a source of
environmental
pollution
Participants 1. Participants 1. Source of Lecture 25 Power
learned about the are able to plastic waste minutes point
source of plastic mention the in the world
waste and the source of and in
Indonesia
negative impact plastic waste
2. Type of plastic
of poor and types of waste
management of plastic waste 3. The negative
plastic waste in Indonesia impact of bad
2. Participants management
are able to of plastic
mention the waste on the
environment
negative
and humans
impact of poor
management
of plastic
waste
1. Participants 1. Participants 1. How to Lecture 30 Power
know how to can explain reduce plastic minutes Point
reduce plastic how to reduce waste
waste plastic waste 2. Difficulty in
2. Participants 2. Participants recycling
know the can mention plastic waste
difficulty in the difficulty 3. The role of
recycling in recycling collectors and
plastic waste plastic waste the recycling
3. Participants 3. Participants industry in
know the role can explain
environmental
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of collectors the role of conservation
and the collectors and related to
recycling the recycling plastic waste
industry industry disposal
6.4.2 Syllabus of Module 2

1. Identitas
Program : Reducing Releases of PBDE and UPOPs Originating from
Unsound Waste Management & Recycling Practices & The
Manufacturing of Plastics in Indonesia (UNDP Project)
Name of activity : Environmental Education Module Concerning on PBDEs
Substance
Modul duration : 90 menit
2. General Description
The module is part of the UNDP project activities in an effort for "Reducing
Releases of PBDE and UPOPs Originating from Unsound Waste Management &
Recycling Practices & The Manufacturing of Plastics in Indonesia". This module
contains topic related to the role of the plastic recycling industry in efforts to
preserve the environment, especially in reducing the chain of dissemination of
PBDE substances and UPOPs in Indonesia. This module will provide knowledge
about plastic waste and its additive content, the effects of plastic waste and
additives on the environment, especially related to PBDEs and UPOPs, their
characteristics, and efforts that can be made to reduce the impact on environment
and health of humans and living things. All knowledge provided in this module will
be useful in increasing awareness and concern of business people in the field of
plastic recycling towards conservation efforts and increasing awareness of aspects
of public health, especially the direct impact on human resources working in the
plastic recycling industry.
This module is intended to provide knowledge for industry players and/or personal
related to the recycling industry to understand about plastic substances and
additives in it, especially PBDE and UPOPs so that they can carry out appropriate
handling systems so that negative impacts on the environment and human health
from substance - these substances can be minimized. The outputs to be obtained
from this activity are 1) increasing the knowledge of the participants regarding the
substance, characteristics and correct handling of plastics and additives in it,
especially PBDEs and UPOPs; 2) increasing knowledge from participants
regarding increased awareness of the recycling industry players re-plastic and/or
personal related in this field to the proper plastic waste handling system; 3)
Increased knowledge from participants regarding the impact of PBDEs on human
health and the environment.
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3. Learning Outcomes
Participants are able to protect themselves from PBDEs exposure from plastic
products that are suspected of containing PBDEs and are able to properly handle
these products.
4. Module 2 Specific Learning Topics

Participants 1. Participants can Plastic and Lecture 20 Power
know the term explain about additive minutes Point
polymer polymers substances
materials, 2. Participants are 1. Polymers
able to explain
plastic plastic ore and 2. Plastic ores
materials and mention the and their types
additives types 3. Additives and
correctly 3. Participants are their types
able to explain 4. The
the additives mechanism of
and their types
the process of
4. Participants are
able to explain adding
the mechanism additives in
of adding plastic
additives in the 5. Additives in
polymer matrix plastic
5. Participants are structures
able to explain
the polymer
matrix that
contains
additives
Participants 1. Participants are Stockholm Lecture 10 Power

know about the able to explain Convention minutes point
Stockholm about the 1. Types of
convention and Stockholm compounds
the compounds convention including
included in the 2. Participants are POPs
POPs list well able to name the 2. PBDE
types of compounds in
compounds the list of
included in the POPs at the
POPs category Stockholm
3. Students are convention
able to explain
PBDE as part of
a compound at
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the Stockholm
convention
1. Participants 1. Participants can 1. What is PBDE Lecture 20 Power
know about explain about 2. PBDE as a minutes Point
PBDE, its PBDE flame retardant
chemical 2. Participants can 3. The
structure explain about mechanism of
and its PBDE as an anti- the anti-flame
properties flame additive material
2. Participants 3. Participants can 4. Types of
know the explain the products with
products mechanism of PBDE content
that contain the anti-flame 5. Naming and
PBDE material in the chemical
additives product structure of
correctly 4. Participants can PBDE
mention products 6. Nature of
containing PBDE PBDE
additives
5. Participants can
explain the
naming and
chemical
structure of
PBDE
6. Participants can
mention the
characteristics of
PBDE
Participants 1. Participants can Impact of PBDE Lecture 20 Power

know the explain the on human health minutes Point,
effects of mechanism for and Video
PBDE on distributing environmental
human health PBDE to the damage
(women, men environment 1. The mechanism
and children) 2. Participants can of
develop the dissemination
distribution and to the
impact of the environment
PBDE from 2. Development
time to time of the
3. Participants can distribution
explain the and impact of
effects of PBDE from
PBDE on time to time
121
human health 3. Impacts of
(women, men PBDE on
and children) human health
4. Participants can (women, men
explain the and children)
mechanism of
PBDE
inhibiting fetal
brain
development
Participants 1. Participants can The mechanism Lecture 10 Power

knew the explain the for the exposure minutes Point
mechanism of mechanism for of PBDE
the distribution the exposure of 1. The mechanism
of PBDE and PBDEs and for the exposure
POPs in the POPs in the of PBDEs in the
waters and land waters waters (sea,
areas strait, river)
2. Participants are 2. The mechanism
able to explain for the exposure
the mechanism of PBDEs in
for the land areas
exposure of (industrial
PBDEs and estates,
POPs in the commercial
mainland areas,
settlements,
garbage
disposal)
1. Participants 1. Participants can Things that need Lecture and 10 Power
know and mention the to be done to discussion minutes Point
apply the use types of minimize the
of personal personal exposure of the
protective protective PBDEs
equipment equipment 1. Self-protection
and clean and needed to avoid by using PPE
healthy exposure of 2. Self-protection
living habits PBDEs at work by establishing
that need to 2. Participants can a clean and
be done to mention clean healthy life
minimize and healthy 3. Handling
exposure to habits to ingredients
PBDE minimize that are
compounds PBDEs suspected to
into the body exposure contain
122
2. Participants 3. Participants can PBDEs
know and explain how to correctly
apply the handle and
process of store
handling and ingredients
storing with PBDEs
ingredients content
with PBDE
content
correctly so
that it does
not spread to
the
environment
6.5 MINI DEPO DESIGN FOR PLASTIC DISPOSAL
6.5.1 Definition and Function

Mini Depo is a plastic waste management place that still has economic value (golden
waste). In this place, collecting, sorting and processing plastic waste is carried out. The
Mini Depo has function as an intermediate post for waste management in an area is very
important, because it able to:
• Prevent the exposure/releasing of dangerous pollutants (for example: PBDEs) into
the wider environment.
• Increase the use value of certain recyclables (plastic waste).
• Provide economic benefits for managers of the Mini Depo by selling waste that still
has use value (especially plastic waste).
• Extend the life of landfills, because the amount of waste transferred to Final
Disposal Sites will be much reduced.
• Become a learning center that is effective in increasing community environmental
awareness.
6.5.2 Operational Concept

In conjunction with waste containing PBDEs, the Mini Depo will be a place to receive
plastic waste (mainly electronic waste, e-waste, golden waste), sorting it out based on
indications of the PBDE's presence to then distribute it to the destroyed PBDE material
(if detected) and to the recycling industry. The operational concept in the Mini Depo
planned for this program, is explained as follows:
A. INPUT
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1. Mini Depo accepts solid-type plastic waste (ABS, HIPS) from various sources
(industry, offices, communities / households, waste collector)
2. The acceptance mechanism that is carried out is:
• Buy, at competitive prices according to market prices that apply to this type
of waste (the concept of a Waste Bank)
• Accept only, especially for electronic plastic waste (e-waste) which will be
regulated in government regulations (policy)
3. The Mini Depo also accepts elements / parts of electronic waste that have been
sorted by the waste collector and has no use (suspected of having PBDE
content - examples of cable waste)
B. PROCESS
1. Dismantle, especially for garbage that comes in a bulk condition
2. Sorting, which is intended to separate between plastic waste containing PBDE
and those that do not.
3. The sorting process will be carried out with assistance:
• List of plastic waste containing PBDE (as will be prepared based on the
results of laboratory analysis - see table road map, Table 5.2.
• Technology, sensor devices to detect the presence of PBDE (XRF System,
can be in the form of a handheld unit)
4. Further sorting, especially for waste that does not have PBDE content, is done
based on color (white, color, etc.) or other parameters that are in accordance
with the demands of the recycling industry
5. The sorting process is carried out by passing electronic waste into the
conveyor belt, where several operators will stand on the left/right of the
conveyor belt lane. This operator will have special tasks, namely:
• sorting out PBDE-based waste
• sorting non PBDE waste according to the criteria requested by the recycling
industry
6. Processing, waste that does not have PBDE content will be processed further
through the following process:
• cutting, to reduce the size of the garbage. Can be done manually with the
help of cutting tools (knives / machetes)
• enumeration, using a chopper
• final sorting, to separate the desired type of plastic waste (eg ABS) from the
impurities. The final sort can be done using the "float & sink" technique
• drying
• packaging
7. Impurity material obtained from the final process, collected separately
C. OUTPUT
1. The output of the process carried out in the Mini Depo is:
• Waste containing PBDE
• Non PBDE plastic waste that can be recycled
• Dirt trash from final sorting results
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2. PBDE-containing waste will be sent to the destruction facility (incinerator) or
to secured landfill (please refer to table 3 for the procurement plan for the
facility)
3. Waste sorting from final sorting is also sent to the same facility (incinerator /
secured landfill)
4. Recyclable plastic waste will be sold to the recycling industry with a price
mechanism according to the market
D. SUPPORTING FACILITIES
1. Government policy related to electronic waste management, which directs the
type of waste to be sent / managed in the Mini Depo
2. Support, in the form of dissemination of information to all parties about the
existence and function of the Mini Depo
3. Transportation equipment to pick up electronic waste, especially from the
community / household / housing with the conditions specified (eg pickup will
be carried out if it meets the minimum amount)
4. Technical support facilities such as XRF units, belt conveyors, pilahan garbage
racks
5. Training, especially those related to PBDE identification techniques, sorting
techniques, techniques for using existing supporting tools
6. Information about the existence of a recycling industry that treats solid waste
types (ABS, HIPS). In the road map section, it is also mentioned the
importance of encouraging the growth of the recycling industry (especially for
types of hard plastics), not only to absorb raw materials but also to facilitate
control so that PBDE material is no longer used as a mixture. More broadly,
the existence of this industry will strengthen domestic economic activity.
7. Supporting facilities, especially for PBDE material elimination / destruction
processes. As stated in Table 5.2, the existence of incinerators (for example
destruction units) and secured landfills (as a means of permanently isolating
PBDE) can be coordinated with relevant agencies (KLHK, Local
Government)
8. Transportation equipment for transporting / sending PBDE-containing waste
and impurities to waste facilities
E. MINI DEPO SUSTAINABILITY
1. At the beginning of the operation, the Mini Depo has a dual function, namely
as a means to isolate PBDE-containing plastic waste and as a plastic
processing industry (type of ABS - ABS, HIPS; which does not contain
PBDE). Processing is carried out as limited to enumeration and drying, then
the material is sold to the recycling industry (which converts to pellets and / or
finished products).
2. The priority for the first 5 years of the Mini Depo operation is as a unit to
conduct isolation, so that all materials / waste that are PBDE-containing
materials are expected to be held in this unit. With this position, the Mini Depo
operation is still not profit oriented.
3. Following the function of time, the presence of waste / PBDE-containing
125
material in the community will decrease (targeted within 5 years has shown a
significant decline), this is caused:
• There is no longer any material / finished product containing PBDE that is
permitted to enter Indonesia (for this reason, policies related to the prohibition
of importing PBDE material and prohibiting the use of PBDE as additional
material in the production process - as also explained in the road map, Table
5.2)
• PBDE-containing plastic waste has been isolated in the Mini Depo (therefore
the construction of the Mini Depo, especially in big cities must be realized -
also included in the road map)
4. With conditions as explained in point (3) - the plastic waste containing PBDE
that enters the Mini Depo will also decrease. In other words, the portion of the
amount of plastic that can be processed for recycling will increase. In this
condition the Mini Depo function will shift more to the business entity (plastic
processing industry)
5. Based on observations in the field, especially in 3 companies in Banyuwangi
(which have the scope of work as planned in the Mini Depo), then at least 1
ton of plastic must be processed for profit. Economic potential will be even
greater if the Mini Depo will also be operated as a recycling industry whose
scope of work is to produce pellets and / or finished products.
6.5.3 Technical Concepts

Considering the above, the existence of a Mini Depo in a region with a large population
(medium to very dense) is needed. The Mini Depo design is arranged on the basis of the
availability of land of 600 m2. Based on the consideration of its essential functions and
conditions that support the operation process in the place and enriched with the results
of observations in the field, the Mini Depo design made has the following important
components:
1. Mobile Golden Waste Separation
Plastic waste that will be sorted is moved / flowed in the conveyor belt and officers
will sort it based on the presence / absence of PBDE and plastic type, during the
movement. Apart from being related to the effectiveness of sorting, this system is
very good for maintaining aspects of worker hygiene (contact of workers with
garbage is directly minimized). The results will be put into an easy-to-move mobile
rack to transport the car that will carry PBDE-containing plastic waste to the
destruction facility or bring non PBDE plastic waste to the next processing location
(enumeration).
2. Waste Bank Office
The Mini Depo is equipped with a Waste Bank service facility where industries,
offices, surrounding communities and / or small-scale Waste Banks can deposit / sell
electronic waste / plastic waste at home produced or which have been sorted
themselves. This is based on the existence of policies related to management of
electronic waste and the concept of education where the public is given an
126
understanding that waste still has economic value.
3. Dining Room, Changing Room, Toilet
Health aspects are important things that must be included in the operation process.
Even though what is managed is garbage, the working conditions are made so that
they are healthy and attractive. Dining rooms are made isolated so that workers have
a healthy and clean condition. Change rooms and toilets are provided adequately to
meet the needs of both male and female workers.
4. Top View Office
The Mini Depo operational office is located at the top (2nd floor) so that it will
greatly facilitate supervision and control of working conditions.
5. Green Parks / Areas
The green area is also an important part of the Mini Depo's existence because in
addition to functioning aesthetically, it will also be a natural barrier that prevents
nuisance or odor material that may appear to enter / enter the Mini Depot area
6. Liquid Waste Tank
To accommodate liquid waste that may exist along the waste management process,
liquid waste tanks need to be prepared.
6.6 GUIDELINES FOR MONITORING PLASTIC INDUSTRIAL

WASTE CONTAINING PBDEs
The main objective of this document is to provide guidance for the government in
monitoring plastic waste containing PBDEs in the plastic recycling industry. In addition,
this guideline is to assist the plastic recycling industry in carrying out internal
monitoring. This guideline includes monitoring the content of PBDEs from plastic used
as raw material, plastic counting to recycled resin products in the plastic recycling
industry.
6.6.1 Recycled Plastics

Based on the type Plastic can be grouped into seven types, namely PET, HDPE, Vinyl or
PVC, LDPE, PP, PS, and others (Figure 6.5). The plastic is included in the type of
thermoplastic plastic so that it can be recycled by the heating method using an extruder
to then be formed into a resin using a pelletizer. The recycled resin can be reused
according to the needs based on the type of plastic properties.
Code 1: PET (Polyethylene Terephthalate), safe and recyclable (examples of use in
packaging bottles, PET plastic bags, threads, and shipments).
Code 2: HDPE (High Density Polyethylene), safe and recyclable (example of use in
plastic bags, household appliances, cables, filaments, and molding industries)
Code 3: Vinyl or PVC (Polyvinyl Chloride), not good for recycling and not commonly
recycled like other types of plastic because it has a long usage period. Can be
recycled chemically to recover chlorine elements (examples of use in pipes,
fitting faucets)
Code 4: LDPE (Low Density Polyethylene), safe and recyclable (example of use in
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cables, toys, packaging caps, buckets, containers and pipes)
Code 5: PP (Polypropylene), amand and can be recycled (examples of use on food
packaging, plastic bags, milk bottles, household appliances)
Code 6: PS (Polystyrene), can be recycled but the cost of making products using
recycled PS material is more expensive than virgin PS (example use in food
packaging, drinks)
Code 7: others, including PC, ABS, can be recycled.
Figure 6.5 Plastic codes (Good Practices Guide on Waste Plastic Recycling 2011)
6.6.2 Plastic Recycling Process

The process of utilizing plastic waste into chopped and recycled plastic resins begins
with the collection process, then compressed / pressed to reduce the volume, and packed
neatly by collectors. Plastic waste has been separated by type of plastic by looking at
the plastic code. The plastic waste is then sent to the recycling center / industry. In the
recycling industry, the plastic waste is sorted to be cleaned from the impurities and then
chopped using a chopper into plastic pieces (flakes with a size of approximately 8-10
mm).
The chopped is then washed thoroughly. If the plastic count includes thermoplastic
types, it can proceed to the melting process will be a pellet or granule called resin.
Making resin uses a heating device to melt the plastic using an extruder, which then
melts the plastic into a pellet or granule with a size of approximately 4-6 mm using a
pelletizer. The recycled plastic resin can be reused for plastic products from recycled
materials.
Thermoset type plastic chops cannot be processed using a melting process so that this
type of plastic only reaches the form of chopped and then reused as a product of
recycled material. Plastic waste collectors can be in the form of a Waste Bank in
collaboration with the Regional Government and collectors with small to large stalls.
Collectors then sent plastic waste to the plastic waste processing industry to be chopped
into plastic chopped. Furthermore, plastic counts are processed into recycled plastic
resins by the recycled plastic resin industry.
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6.6.3 Monitoring Preparation
6.6.3.1 Object and Monitoring Team
Monitoring of recycled plastic waste containing PBDE is carried out on: Raw materials
in the form of chops; and recycled products in the form of chopped and / or resin.
Monitoring includes administrative and technical aspects. Administrative aspects,
namely the completeness of the permit / business legality. As for the technical aspects,
monitoring of:
a. Raw materials
• Origin of raw materials
• Type of raw material (type of plastic).
• Types of plastic waste (electronic plastic waste, food / beverage packaging,
furniture, automotive accessories).
b. Process
• Enumeration.
• Manufacture of recycled resin.
c. Products
• Chopped plastics
• Recycled resin
6.6.3.2 Monitoring Location

The location of monitoring is carried out in the plastic recycling industry as shown in
Figure 5.6. Meanwhile sampling in the industry of recycled plastic resin can be seen in
Figure 5.7.
Sortir plastik
Pembongkaran Pencucian Pencacahan

bale plastik plastik plastik
Pengeringan Pemisahan plastik Pembilasan Pencucian

berdasarkan berat jenis
cacahan plastik cacahan plastik cacahan plastik
Pengemasan Titik
cacahan plastik Sampling
(Gambar )
129
Figure 6.6 Process diagram in the recycled plastic enumeration industry
Titik Sampling
Cacahan plastik
Pencucian Pembilasan Pencucian

cacahan plastik cacahan plastik cacahan plastik
Pengemasan Pembuatan Pelelehan Pengeringan

resin plastik resin plastik cacahan plastik cacahan plastik
daur ulang daur ulang dengan
dengan ekstruder
Titik Sampling
Figure 6.7 Production process of plastic recycled resin
6.6.3.3 Monitoring Officer

Authorized officials in monitoring the circulation and use of PBDE on plastics in the
plastic recycling industry assign to the Product Standard Supervisory Officer (PPSP) or
Civil Servant Investigation Officer or Green Industry Standard Auditor or staff who
have competencies according to the requirements.
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7 ANALYSIS AND SUGGESTIONS/
RECOMMENDATIONS
In this Chapter, the level of achievement of conditions as expected in Chapter 1, which
refers to the Project Document, will be presented, accompanied by analysis and
suggestions / recommendations for follow-up. The intended level of achievement is
only based on data and information or the results stated in the Report of the eight
Institutions appointed to carry out UNDP activities. The expected conditions are:
increased awareness and concern for the dangers of PBDEs and UPOPs; strengthening
the ability of government institutions to control PBDEs and UPOPs from the plastic
industry; issued and implemented relevant laws and regulations; reduced use and
release of PBDEs in the plastic manufacturing, recycling and plastic waste disposal
industries. Each of these conditions will be described further.
7.1 INCREASING AWARNESS AND CARE ON THE DANGER OF

PBDEs AND UPOPs
In Result Tree that encourages awareness of the dangers of PBDEs and UPOPs
indicated by: the availability of data, information and package activities on PBDEs and
UPOP; and the availability of government funds and assistance.
7.1.1 The Availability of Data and Information about PBDEs and

UPOPs
Although the eight institutions appointed to carry out the UNDP activities have different
assignment focus, each of them submits data and information about PBDEs and UPOPs.
The data and information available include:
• POPs and PBDEs
• Chemical structure of PBDEs
• Physico-chemical properties of PBDEs
• Use of PBDEs in Industry
• Products containing PBDEs
• Applications, compositions, types of products, resins and recycled products
related to PBDEs
• Type of PBDEs and minor content on commercial PBDE products
• PBDEs mechanism as a Flame Retardant
• Source of Brominated Flame Retardants in Household Products
• Negative impacts of products containing PBDEs
• PBDE contamination in Indonesia
• Exposure Routes and Health Effects of PBDEs
• PBDEs toxicity
• Health & Environmental Risk Assessment
• Study of the Impact of PBDEs on Gender
• Production and replacement of PBDEs as a Flame Retardant
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Based on the availability of data and technical information collected, it can be said that
this expected condition has been reached.
7.1.2 Availability of several Activity Packages that are Ready to

Implement
In addition to the availability of data and information above, other efforts have also
been made to increase awareness and concern for the dangers of PBDEs and UPOPs.
The results that have been obtained from these efforts include the compilation of several
Activity Packages as follows:
• Environmental Education Module on PBDEs.
• (This material is intended for plastic waste collectors and their recycling
industries)
• Plastic Waste Processing Inventory System that Contains PBDEs
• Mini Depo Design for Plastic Recycling
• Mini Depo Design for Plastic Waste Processing
• GMP for Plastic Recycling that Contains PBDEs
• Study Results for BAT / BEP Guidelines for Plastic Recycling Activities that
Contain PBDEs
• Guide to Monitoring Plastic Waste that Contains PBDEs
Based on various technical considerations, some of these results have actually
experienced adjustments or decreased levels of the initial targets stated in the LoA with
UNDP, for example:
• GMP for Recycling Plastic Containing PBDEs is expected to be a package of
activities that are ready to be carried out operationally, no longer too normative.
• BAT / BEP Guidelines are not in the form of studies but are in the form of
packages that are ready to operate, at least for certain conditions or for certain
regions.
• The expected guidance is actually a Guide to Control, not just the Monitoring
Guide.
Suggestions that need to be followed up are how to make the available materials and
package of activities available and implemented to related parties, which vary in level
(from Manufacturing Industry to Collectors and Recyclers). In addition, it must also be
formulated how to finance and how to measure its effectiveness.
7.1.3 Availability of Government Funds and Assistance

In general, the government of the Republic of Indonesia has allocated funds or budgets
related to efforts to control PBDEs and UPOPs, which are spread across various
Ministries and other Non-Ministry Institutions. The available budget may not mention
PBDEs and UPOPs explicitly, but are broader in nature but implicitly they are also
related to PBDEs and UPOPs. From the results of the activities of the eight institutions
appointed to carry out UNDP activities, currently no detailed and accurate data on funds
is available for the control of PBDEs and UPOPs, both based on the Ministry's approach
and activities. The same applies to the availability of data and information about aid
funds, both Bilateral and Multilateral, which are used specifically for the activities of
controlling PBDEs and UPOPs.
132
To measure the effectiveness of the use or allocation of budgets for PBDEs and UPOPs
control activities it is recommended that funds or budgets that have been issued and
analyzed be compared to the results obtained. Furthermore, this data can be used as
material for consideration in the allocation of funds or the next budget for similar
activities.
7.2 STRENGTHENING THE ABILITY OF GOVERNMENT

INSTITUTIONS IN CONTROL OF PBDEs AND UPOPs OF
PLASTIC INDUSTRIES
The ability of government institutions to be analyzed in scope is extended to the
application of RoHS regulations (Restriction on the use of certain Hazardous
Substances), which includes controlling PBDEs and UPOPs. Several major countries
and ASEAN member countries have implemented RoHS, which he calls RoHS-like.
The analysis is more emphasized on technical capabilities, among others, indicated by
the availability of Conformity Assessment Institutions (Certification Bodies and Test
Laboratories), Standards, Technical Guidelines and monitoring equipment or testing.
The results of the UNDP study conducted by the Center for Material and Technical
Products (B4T) included the following:
• Out of 51 Product Certification Institutions (LSPro) that have been accredited by
KAN, only B4T has been accredited for RoHS implementation. This is partly
due to the fact that RoHS-related SNI has not yet been compulsory.
• Of the 23 laboratories that have been accredited by KAN, only four were
declared capable of fully testing PBDEs, namely: Intertek, SGS, Sucofindo and
BP Batam. Actually there are two who are also capable, namely B4T and the
Center for Chemistry and Packaging (BBKK), the only problem being the
availability of standard chemicals for PBDEs are expensive.
• About 90% of the accredited laboratories actually have the main equipment for
PBDE analysis, namely GC-MS. The absence of regulations for implementing
or testing PBDE has caused some laboratories to delay until the sample meets
the minimum amount.
To realize the condition as expected, but at this time it has not yet been reached, some
suggestions / recommendations are submitted.
1. Preparation for the implementation of SNI related to PBDE and RoHS
regulations so that they are intensified, so that their application can be
accelerated compulsorily, as has been done by several ASEAN member
countries and other major countries, in the form of RoHS-like.
2. Physical support facilities such as laboratory equipment and chemicals needed
need to be assisted by the improvement of its equipment. Thus, if SNI has been
enforced compulsorily, the testing laboratory is ready too. In line with that, the
133
knowledge and technical capabilities of the personnel also need to be improved.
3. Along with strengthening the capacity of Government Institutions, the role or
involvement of stakeholders in efforts to control PBDEs also needs to be
improved, including:
a. Industry: by intensifying the implementation of the Extended Producer
Responsibility (EPR) program
b. Local Government: by facilitating the implementation of the package of
activities that have been prepared by UNDP and the relevant Institutions that
compiled them.
2. Increased technical capability to be idle or not functioning / effective if it is not
accompanied by regulations or regulations for implementation. The regulation
includes mainly obligations, but at the initial stage it is also recommended to be
given incentives.
7.3 PUBLISHED REGULATION RELATED TO PBDEs

The first country that issued the use of PBDEs was Sweden, namely in the late 1990s,
followed by European Union member countries through a RoHS agreement which was
implemented starting in 2006 and subsequently also by European countries not
members of the European Union. In the Asian region, in 2006 Japan followed China in
2007 and Korea in 2008 was published a regulation similar with RoHS and called
RoHS-like. Standard PBDEs that have been implemented in some of these countries are
in accordance with RoHS provisions, namely the standards set by PBDE in EEE
products of 0.1% or equal to those stipulated in RoHS2 EU Directive.
Indonesia has also issued a number of related regulations, which among others, began
with the ratification of the Stockholm agreement through Act No. 19 of 2009.
Furthermore, several related departments or Ministries have also issued existing
regulations and programs that are approved using RoHS. From the studio activities
carried out by UNDP along with the Lack of R & D and Higher Education institutions,
regulations related to PBDEs have been approved, and data or information can be used
as a basis or support for existing and need for assistance. Regulations that can be
grouped according to national and regional regulations.
7.3.1 National Level Regulations

Activities related to the use of PBDEs can be started from upstream, namely the
manufacturing industry up to the downstream, namely the recycling industry and the
processing of plastic waste. Regulations for controlling or limiting PBDEs can be
applied from upstream to downstream. At the upstream level, namely the plastic
manufacturing industry, restrictions in the context of controlling PBDEs can be in the
form of national-level regulations, which regulate the use of raw materials, both locally
produced and imported. At the level of use includes trade and distribution activities; and
in the downstream part are regulations for recycling and processing of plastic waste,
which can be in the form of local regulations or in the form of Regional Regulations.
134
From the results of the UNDP study together with eight R & D Institutions and
Universities, reported:
• Law enforcement instruments related to POPs are available in Indonesia; supervisors
and investigators have carried out their enforcement functions. In terms of sanctions,
Law No. 32 of 2009 concerning Environmental Protection and Management has
arranged it in detail.
• For restrictions on PBDEs, there are no regulations that regulate them because
they are still in the preparation stage. The rapid growth of various types of
plastic industries that use local and imported raw materials, are not matched by
the speed of drafting regulations that limit the use of materials containing
PBDEs.
• Surveys conducted for vendors and the plastic and electronics industry, indicate
a lack of socialization and understanding, because in general all companies
visited said 'not using PBDE' as a flame retardant and also 'don't know about
PBDE'.
• There is no reported regulation or regulation that explicitly limits the use of
PBDEs as raw materials, as well as restricting PBDEs in the final product. What
has been done, for example by the Ministry of Industry, is only at the stage of
implementing three Workshops in 2010-2013. The follow up of the Workshops
is also just up to the stage of raising awareness and developing policies related
to PBDEs.
• Some SNI for electrical and electrical products (EEE) such as TV and household
appliances, have been enforced compulsorily, but the parameters of the
requirements are not specified specifically limiting the PBDEs.
• In preparation for issuing regulations related to import restrictions, the results of
the B4T study have also carried out several preparatory activities, including:
- Analysis of RoHS implementation and application of compulsory SNI as
well as strengthening of relevant institutions for its implementation.
- Design of a RoHS scheme for the application of a labeling system; The
scheme chosen is planned to use a type test and marking carried out in
harmony with the Indonesian National Standard (SNI).
- For the implementation of the RoHS, a Draft RoHS Policy Manual has been
prepared.
• UNTIRTA has conducted a study of substitute material for PBDEs in its function
as a flame retardant and an application experiment has also been carried out.
suggestions / recommendations are submitted as follows:
1. Preparation of regulations limiting the use of PBDEs must be realized faster than
the rapid growth of the plastic industry, which still uses ingredients containing
PBDEs. The schedule is aligned with the Roadmap for the Use of PBDEs that
has been compiled.
2. Published regulations must be more strict in setting obligations and setting time
135
tolerance, for example:
• Companies / plastics industries or those who use plastic products and the like
are not allowed to use fire retardants containing PBDEs.
• Plastic companies / industries are required to regularly report the use and
import of materials containing PBDEs, and the use of substitute materials
that do not contain PBDEs.
• Companies that currently use fire retardants containing PBDE must plan
their reduction or disappearance and replace them with materials that do not
contain PBDEs in stages at least five years.
• Companies that have used fire retardants instead of PBDEs must continue to
guard against switching to the use of materials containing PBDEs.
• Imports of materials containing PBDEs must be prohibited, for example
through the RoHS-like implementation scheme or RoHS adoption.
• For industries that no longer use materials containing PBDEs, they can be
given incentives in the form of incentives, which will encourage more
industries to do so.
3. Draft RoHS Policy Guidelines compiled by B4T can be used as initial capital for
the realization of RoHS-like implementation or adoption of RoHS.
4. Dissemination of other materials as an alternative to PBDEs needs to be
programmed and intensive and monitored for their level of development.
5. The implementation of the above activities requires comprehensive planning
with adequate budget support and it must also be designed how to measure the
effectiveness of its achievements periodically. Therefore, a financing plan must
be designed through the Government budget or assistance.
7.3.2 Regulation in Regional Levels

Regulations for the regional level are aimed more at limiting the use and release or
emission of PBDEs and UPOPs in the recycling and disposal of plastic / waste
industries. From the study activities carried out by UNDP with the relevant Institutions,
several data and information were obtained including:
§ As a basis for regulations there are several relevant laws and PPs, including Law
no. 18 of 2008 concerning Waste Management, Law no. 19 of 2009 concerning
Ratification of the Stockholm Convention and PP no. 74 of 2001 concerning
Management of Hazardous and Toxic Materials.
§ Article 15 of Law no. 18 is the legal basis for the mandatory implementation of
the Extended Producer Responsibility (EPR). Nine stakeholders have been
identified with each of their functions, and three scenarios have been prepared
for their implementation.
§ A Draft Agreement has been drawn up between users, vendors, and the
Government regarding the implementation of EPR in Indonesia, which can be
used as a basis for drafting regulations on the use of PBDEs in Indonesia.
§ The results of the literature study indicate that there is no information about
contaminated locations from PBDEs waste in Indonesia. However, the final
place for electronic waste storage (e-waste) such as recycling sites, waste
136
disposal containing electronic waste, and CRT TV and computer dust can be a
potential location for contamination of PBDEs.
§ Regarding regulations and guidelines on PBDEs emissions from contaminated
locations including the study of dumping disposal, until now there has been no
specific guidance aimed at PBDEs management policies in Indonesia.
§ To reduce PBDE and UPOP emissions to the environment due to uncontrolled
disposal of waste, especially plastic waste which is indicated to be able to
release these hazardous materials, ITS has made a design of a mini-depot which
functions to sort and process the waste into products that can be recycled.
§ From the activities carried out by UBAYA some results were obtained,
including:
- Mini Depo Design to pilot so that plastic waste that still has economic
value (golden waste) can be managed better.
- Computer-based inventory system (PC) that can help recyclers and garbage
collectors put their administration in order.
- Roadmap for PBDE-Based Plastic Waste Management, which is grouped
into Short-Term (2 years): early stages of adaptation and isolation;
Medium Term (5 years); isolation stage; and Long Term (10 years):
elimination / destruction stage.
suggestions / recommendations are submitted, as follows:
1. Companies that use PBDEs in their packaging or products to participate and be
responsible for the existence of their products, by:
• provide information to the public about the dangers of PBDEs through
User manuals, or other forms of socialization.
• withdraw used packaging or used products directly through trade in or
takeback from used products containing PBDEs.
• allocate funds, to facilitate or provide incentives to scavengers /
collectors so that their product waste can be recycled, in the form of
repurchases at attractive prices.
2. The Mini Depo design and Inventory System program that has been compiled by
UBAYA for plastic waste management, needs to be followed up on its
realization and its phasing is aligned with the PBDEs Containable Plastic Waste
Roadmap.
3. Mini depots designed by ITS and by UBAYA can be studied further to be
integrated and made into a kind of Pilot Project. For this reason, it is necessary
to approach the stakeholders and local governments from the chosen location, so
that their respective contributions are clearer and certainty is obtained for the
sustainability of the Mini Depo.
137
7.4 REDUCING OF USE AND EXPOSURE OF PBDEs IN
PLASTIC MANUFACTURING INDUSTRIES, RECYCLING
AND WASTE DISPOSAL
The success or expected impact of the enactment of regulations or legislation related to
limiting the use of PBDEs can be measured from several indicators, including: no use of
materials containing PBDEs by the plastic industry; no use of products or waste / waste
containing PBDEs by recyclers; and reduced waste disposal containing PBDEs.
7.4.1 Plastic Industry No Longer Use Products Containing PBDEs

Not used, or at least reduced use of materials containing PBDEs by the plastic industry,
among others, can be seen and followed from periodic reports in the form of:
• Developments in the level of use of raw materials containing PBDEs
• Developments in the level of imports of raw materials containing PBDEs
• Developments in the level of use of alternative ingredients that do not contain
PBDEs
These figures can be obtained in an orderly, fast and accurate manner if a regulation has
been issued requiring plastic companies / industries to report the use and import of
ingredients containing PBDEs and the use of substitute materials that do not contain
PBDEs. While national regulations have not been issued, each region must take the
initiative to obtain the data, and the format can be assisted by the relevant Ministry or
Service.
The level of decline is compared to the Roadmap for Decreasing Use of Containers of
PBDEs that have been prepared, so that if the rate of decline is not in line with the
roadmap then it must be immediately analyzed, the root cause of the problem and the
corrective action taken.
7.4.2 Recyclers No Longer Use Products Containing PBDEs

To measure the level of use of products containing PBDEs by recyclers, data can be
used from areas where plastic waste recycling activities are carried out. This
measurement is carried out for areas that are estimated to be the center or center of
plastic waste recycling activities and areas where the Mini-Depo location is located. The
results are compared and at the same time an overview of the effectiveness of the Mini-
Depo is obtained. Given the Mini-Depo currently located in East Java, the comparison
location should be taken in West Java or Central Java.
Theoretically it is expected that the rate of decline in the use of materials containing
PBDEs in areas where Mini-Depo is located will be faster than in other regions. If it
turns out the results are the same or maybe even Mini-Depo is lower, then don't justify
that the Mini-Depo concept is not effective, but it must be studied more carefully where
the root of the problem is. Thus the Mini-Depo can always be improved and can be
138
replicated in other areas.
7.4.3 Decreasing of Waste Dispossal Containing PBDEs

If the Mini-Depo manages plastic waste and the Inventory System Design is
implemented, it is expected that plastic waste that still has economic value (gold waste)
can be managed better. To see the benefits of the Mini-Depo and the implementation of
the Inventory System, it is necessary to compare the performance of the Mini-depo with
the performance of plastic waste treatment plants carried out in the usual (regular) way.
Waste processing sites can be selected from areas in West Java or Central Java.
The Mini-Depo performance can be used, among others, through the amount (tons) of
processed plastic waste compared to the amount (tons) that can be utilized and the
amount (tons) transported to landfill or landfills. The remaining amount (tons) is
garbage that has been collected because it contains PBDEs, which must be disposed of
to a special place that manages B3 waste. The results obtained are compared with the
results. The place to process waste is organized by measuring the same parameters.
What is certain is that waste management is not carried out containing PBDEs.
The parameters used to measure Mini-Depo's performance to compare with the

performance of ordinary waste processing, is only one alternative, because other
parameters can still be developed.
Suggestions / recommendations:
1. To measure or obtain an indication that the plastic industry has a tendency to no
longer use PBDEs, regular monitoring and analysis of data is needed: the use of
raw materials containing PBDEs, import of raw materials containing PBDEs, and
the use of alternative BFR materials that do not contain PBDEs .
2. To obtain an indication that the ITS Mini-Depo can reduce the use of products
containing PBDEs in the recycling process, it is necessary to compare them with
the recycler's performance in West Java or Central Java.
3. To obtain an indication that UBAYA's Mini-Depo can manage plastic waste
containing PBDEs better, it is necessary to do a comparison with a regular
garbage processor.
139
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1 http://ec.europa.eu/environment/chemicals/reach/pdf/publications/chemicals_health.pdf diakses pada

November 2016


1
California’s RoHS Law dari website https://doclib.ul.com/.../california-rohs-law_07_0
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REDUCING RELEASES OF

POLYBROMODIPHENYL ETHERS (PBDEs) AND

TABLE 1.1 DUTIES AND RESPONSIBILITIES OF EACH THIRD PARTY 11

Recycling practices do not

No regulation to No regulation No regulation

No public pressure (from customers, communities, press, academia, etc.)

1.1 THE PRESENT CONDITIONS IN INDONESIA

1.1.1 Institution and Regulations Related to Handling of PBDEs

1.1.3 Plastic Recyling Industry

In Indonesia, there has been a significant increase in production and consumption of

1.1.4 Disposal of Plastic Waste

The implementation, enforcement and monitoring of these regulations is very dependent

1.2 EXPECTED CONDITIONS AND ITS EFFORTS

In general, the expected condition of Indonesia is related to the danger or negative

1.2.1 Strengthening Policies and Regulations for Reducing UPOPs

1.2.2 Reduced Imports and Use of PBDEs in the Plastic Industry

1.2.3 Reduced UPOPs and PBDEs from the Plastic Recycling

1.2.4 Reduced release of UPOPs and PBDEs from Plastic Waste

1.3 OBSTACLES FACED

§ Limited Regulatory Framework

§ Inadequate system and institutional capacity

§ Limited professional and technical personnel

§ Limited sources of financing

Meanwhile local / city governments in Indonesia face various challenges in the

§ Information barrier and levels of concern

In general, many community members have no concern or information about the

1.4 ACTIVITIES DONE THROUGH UNDP ASSISTANCE

Table 1.1 Duties and responsibilities of each third party

Reviewing of national Conformity Assessment B4T

Industry mapping that consumes flame B4T

Alternative PBDEs research in accordance UNTIRTA

Plastic recyclers and product recycle users ITB

2.1 PERSISTENT ORGANIC POLLUTANTS (POPs) AND

There are three types of POPs, namely:

The distribution of POPs concentrations to another areas is influenced by the ability of

Unintentionally produced Persistent Organic Pollutans or commonly referred to as

Figure 2.1 Structure of PBDE congeners (EFSA, 2011)

Figure 2.3 Chemical structures of eight PBDE congeners (ESFA, 2011)

2.2 PBDEs AS FLAME RETARDANT AND ALTERNATIVE

2.2.1 PBDEs as Flame Retardant

PBDEs, TBBPA, tetrabromophthalic anhydrides, dibromoneopentylglycol and

PentaBDE is mainly used as an additive in flexible polyurethane foams in coatings and

OctaBDE is mainly used in Europe on acrylonitrile-butadiene-styrene (ABS) at 12-18%

2.2.2 Alternative Subtitutes of PBDEs as Flame Retardant

2. Organophosphorus Flame Retardants

3. Nitrogen-based Flame Retardants

4. Halogenated Flame Retardants

The group of halogenated flame retardants represent around 30% by volume of

2.3.1 Exposure Routes and Health Impacts

In 2006, the Environment Protection Agency (EPA) summarized studies in animals of

2.3.2 Impact on the Environment

2.3.3 Impacts on Gender

Gender mainstreaming is now part of development program policies and planning.

2.4 PRODUCTS CONTAINING PBDEs

The main use of c-OctaBDE is in the polymer acrylonitrile-butadiene-styrene (ABS),

Table 2.9 Products contained PBDEs (Meunhor, 2011)

Types Distribution Global use of PBDE in 2001 (tonnes)

3 STRENGTHENING THE NATIONAL POLICY AND

3.1 POLICIES AND REGULATION OF PBDEs IN SEVERAL

3.1.1 European Initiatives

The European Union’s Waste Electrical and Electronic Equipment (WEEE)

As a consequence of requirements of both the RoHS Directive and the WEEE

The European Union Directive 2003/11/EC (European Parliament and Council