HEXABROMOCYCLODODECANE

DRAFT RISK MANAGEMENT EVALUATION

Prepared by the ad hoc working group on

HEXABROMOCYCLODODECANE

Persistent Organic Pollutants Review Committee

April 2011

	

TABLE OF CONTENTS

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc290311016"  Executive
summary	  PAGEREF _Toc290311016 \h  3  

  HYPERLINK \l "_Toc290311017"  1.	Introduction	  PAGEREF _Toc290311017
\h  4  

  HYPERLINK \l "_Toc290311018"  1.1 Chemical identity of the proposed
substance	  PAGEREF _Toc290311018 \h  4  

  HYPERLINK \l "_Toc290311019"  1.2.	Conclusions of the Review Committee
regarding Annex E information	  PAGEREF _Toc290311019 \h  6  

  HYPERLINK \l "_Toc290311020"  1.3.	Data sources	  PAGEREF
_Toc290311020 \h  6  

  HYPERLINK \l "_Toc290311021"  1.4.	Status of the chemical under
international conventions	  PAGEREF _Toc290311021 \h  8  

  HYPERLINK \l "_Toc290311022"  1.5.	Any national or regional control
actions taken	  PAGEREF _Toc290311022 \h  8  

  HYPERLINK \l "_Toc290311023"  2.	Summary information relevant to the
risk management evaluation	  PAGEREF _Toc290311023 \h  9  

  HYPERLINK \l "_Toc290311024"  2.1.	Identification of possible control
measures	  PAGEREF _Toc290311024 \h  9  

  HYPERLINK \l "_Toc290311025"  2.2.	Efficacy and efficiency of possible
control measures in meeting risk reduction goals	  PAGEREF _Toc290311025
\h  10  

  HYPERLINK \l "_Toc290311026"  2.3.	Information on alternatives
(products and processes) where relevant	  PAGEREF _Toc290311026 \h  11  

  HYPERLINK \l "_Toc290311027"  2.3.1 Production of high impact
polystyrene (HIPS) plastic	  PAGEREF _Toc290311027 \h  13  

  HYPERLINK \l "_Toc290311028"  2.3.2 Production of flame retarded
textile back-coating	  PAGEREF _Toc290311028 \h  13  

  HYPERLINK \l "_Toc290311029"  2.3.3	Production of flame retarded
expanded and extruded polystyrene (EPS/XPS)	  PAGEREF _Toc290311029 \h 
13  

  HYPERLINK \l "_Toc290311030"  2.4.	Summary of information on impacts
on society of implementing possible control measures	  PAGEREF
_Toc290311030 \h  15  

  HYPERLINK \l "_Toc290311031"  2.4.1.	Health, including public,
environmental and occupational health	  PAGEREF _Toc290311031 \h  15  

  HYPERLINK \l "_Toc290311032"  2.4.2 	Biota (biodiversity)	  PAGEREF
_Toc290311032 \h  16  

  HYPERLINK \l "_Toc290311033"  2.4.3 	Economic aspects, including costs
and benefits for producers and consumers and the distribution of costs
and benefits	  PAGEREF _Toc290311033 \h  16  

  HYPERLINK \l "_Toc290311034"  2.5.	Other considerations	  PAGEREF
_Toc290311034 \h  18  

  HYPERLINK \l "_Toc290311035"  3.	Synthesis of information	  PAGEREF
_Toc290311035 \h  18  

  HYPERLINK \l "_Toc290311036"  3.1 Summary of risk profile information	
 PAGEREF _Toc290311036 \h  18  

  HYPERLINK \l "_Toc290311037"  3.2 Summary of risk management
evaluation information	  PAGEREF _Toc290311037 \h  19  

  HYPERLINK \l "_Toc290311038"  3.3 Suggested risk management measures	 
PAGEREF _Toc290311038 \h  19  

  HYPERLINK \l "_Toc290311039"  4.	Concluding statement	  PAGEREF
_Toc290311039 \h  20  

  HYPERLINK \l "_Toc290311040"  References	  PAGEREF _Toc290311040 \h 
21  

 

Executive summary

Hexabromocyclododecane (HBCD; also HBCDD) was proposed as a POPs
candidate by Norway in 2008. In 2010, the 6th meeting of the POPs Review
Committee decided that HBCD is likely, as a result of its long-range
environmental transport, to lead to significant adverse human health and
environmental effects, such that global action is warranted.

HBCD was considered by the Executive Body of the UNECE Convention on
Long-Range Trans-boundary Air Pollution (LRTAP) to meet the criteria for
POPs as defined under the POPs protocol. HBCD is included as part of the
brominated flame retardants group in the List of Substances for Priority
Action of The Convention for the Protection of the Marine Environment of
the North-East Atlantic (the OSPAR Convention). Also the Helsinki
Commission (HELCOM) has included HBCD in the list of priority hazardous
substances.

HBCD is produced in China, Europe, Japan, and the USA. The current known
annual production is approximately 23,000 tonnes per year (9,000 to
10,000 tonnes in China, 13,426 tonnes in Europe and the US). The main
share of the market volume is used in Europe. 

HBCD has been on the world market since the 1960s. It is used as a flame
retardant additive, with the intent of delaying ignition and slowing
subsequent fire growth during the service life of vehicles, buildings or
articles, as well as while materials are stored. The main uses of HBCD
are in flame-retarded expanded (EPS) and extruded (XPS) polystyrene foam
insulation, with smaller scale use in textile applications and electric
and electronic appliances (high impact polystyrene/HIPS). In textiles
HBCD is used in back-coatings for upholstery and other interior
textiles, including automotive applications. The volumes of HBCD flame
retarded articles imported and exported globally is generally unknown.

Release of HBCD into the environment may occur during all stages of its
life cycle; production and manufacturing, processing, transportation,
use, handling, storage or containment, point-source discharges,
migratory releases from manufactured product usage and from disposal of
the substance or products containing the substance. The European
industry has since 2008 taken actions to substantially reduce HBCD
emissions from HBCD production and first line use. 

Emissions of HBCD can be reduced in production of HBCD, in processes
where HBCD or articles containing HBCD are used, and during the waste
management phase. Emission control techniques at the production sites
alone will not be efficient in solving the problem HBCD is posing for
the environment and health, since there are diffuse emissions and
releases to the water reserves and sewage systems from products
containing HBCD. Wastes containing HBCD represent a large source of
releases and increasing amounts of HBCD-containing wastes in landfills
and other locations could be a long-term source of HBCD emissions.
Wastes containing HBCD include production wastes, insulation boards,
building and renovation wastes, and from other less-commonly used
applications such as electrical and electronic products and textiles.
The process of remodelling and demolition of buildings suggests that
HBCD emissions are likely to continue in the future from the installed
amount of materials containing HBCD.

A number of alternative fire retardants are available to replace HBCD in
high-impact polystyrene (HIPS) and textile back-coating. However, there
appear to be no drop-in chemical alternatives for flame-retarded EPS/XPS
products in all regions. In the USA an alternative chemical flame
retardant is used in the production of EPS, but not in Europe.

Many countries have set standards for building materials with regards to
their contribution to fire. Consequently, inherently flammable materials
must be treated with a flame retardant to meet certain fire performance
criteria, which are required in the country regulations for a specific
use. In some countries HBCD has effectively already been phased out. In
those countries the fire safety regulations do not require the treatment
with a flame retardant. The same level of fire safety is achieved by
alternative means that are technically feasible and also commercially
available. HBCD phase-out could include flame retardant substitution,
resin/material substitution and product redesign. 

HBCD is an intentionally produced industrial chemical. Under the
Convention, the most adequate control measure is listing in Annex A. To
allow for certain time-limited critical uses of HBCD a specific
exemption for use of HBCD, could be given together with detailed
conditions for HBCD production and uses. Stockpiles and waste containing
HBCD would be subject to the waste provisions in Article 6.

1.	Introduction

On June 18th 2008, Norway, as a Party to the Stockholm Convention,
submitted a proposal to list the brominated flame retardant
hexabromocyclododecane (HBCD; also HBCDD) as a possible Persistent
Organic Pollutant (POP) under Annex A of the Convention
(UNEP/POPS/POPRC.5/INF/16). 

1.1 Chemical identity of the proposed substance

Commercial HBCD is a white solid substance. Producers and importers have
provided information on this substance under two different names;
hexabromocyclododecane (EC Number 247-148-4, CAS number 25637-99-4) and
1,2,5,6,9,10-hexabromocyclododecane (EC Number 221-695-9, CAS number
3194-55-6). The structural formula of HBCD is a cyclic ring structure
with Br-atoms attached (Table 1). The molecular formula of the compound
is C12H18Br6 and its molecular weight is 641 g/mol. Depending on the
manufacturer and the production method used, technical HBCD consists of
70-95 % γ-HBCD and 3-30 % of α- and β-HBCD (European Commission 2008;
Nordic Council of Ministers (NCM) 2008). Each of these stereoisomers has
its own specific CAS number i.e. α-HBCD, CAS No: 134237-50-6; β-HBCD,
CAS No: 134237-51-7; γ-HBCD, CAS No: 134237-52-8. Two other
stereoisomers, δ-HBCD and ε–HBCD have also been found in technical
HBCD in low concentrations. Further information pertaining to the
chemical identity of HBCD is listed in Table 2 and may be found in the
supplementary information to the Risk Profile on HBCD
(UNEP/POPS/POPRC.6/INF/25). 

Table 1. Information pertaining to the chemical identity of HBCD 

Chemical structure

	Structural formula of HBCD1: 

1Structural formula for 1,2,5,6,9,10-HBCD, i.e., CAS no 3194-55-6. Note
that CAS no 25637-99-4 is also used for this substance, although not
correct from a chemical point of view as this number does not specify
the positions of the bromine atoms. As additional information, the
structures and CAS numbers for the diastereomers making up
1,2,5,6,9,10-HBCD are given below, although these diastereomers always
occur as mixtures in the technical product.

	



Chiral components of commercial HBCD:

	

alpha-HBCD 

CAS No: 134237-50-6	

beta-HBCD 

CAS No: 134237-51-7	

 

gamma-HBCD 

CAS No: 134237-52-8



Table 2. Chemical identity

Chemical identity

	Chemical Name: 	Hexabromocyclododecane and 1,2,5,6,9,10
-hexabromocyclododecane             

EC Number:	247-148-4; 221-695-9

CAS Number:	25637-99-4; 3194-55-6

IUPAC Name: 	Hexabromocyclododecane

Molecular Formula:	C12H18Br6

Molecular Weight: 	641.7

Trade names/ other synonyms:

 SR 103A; Pyrovatex 3887; Great Lakes CD-75P™; Great Lakes CD-75;
Great Lakes CD75XF; Great Lakes CD75PC (compacted); Dead Sea Bromine
Group Ground FR 1206 I-LM; Dead Sea Bromine Group Standard FR 1206 I-LM;
Dead Sea Bromine Group Compacted FR 1206 I-CM.

Stereoisomers and purity of commercial products: 

	Depending on the producer, technical grade HBCD consists of
approximately 70-95% γ-HBCD and 3-30 % of α- and β-HBCD due to its
production method (European Commission, 2008). Each of these has
specific CAS numbers. Two other stereoisomers, δ-HBCD and ε–HBCD
have also been found by Heeb et al. (2005) in commercial HBCD in
concentrations of 0.5 % and 0.3 %, respectively. These impurities are
regarded as achiral at present. According to the same authors,
1,2,5,6,9,10-HBCD has six stereogenic centers and therefore, in theory,
16 stereoisomers could be formed. 



HBCD has been on the world market since the 1960s. Production has been
reported in China, Europe, Japan, and the USA.  The current known annual
production is approximately 23,000 tonnes per year (9,000 to 10,000
tonnes in China, 13,426 tonnes by the BSEF member companies in Europe
and the US).  Japanese production data is not available. No information
on production in other countries or by non-BSEF member companies was
received.

Based on responses from Parties and Observers, it appears that the main
consumption and use of HBCD takes place in Europe. According to the
global demand reported by the industry in 2001, more than half of the
market volume (9,500 of 16,500 tonnes) was used in Europe. Total global
demand for HBCD increased over 28% by 2002 to 21,447 tonnes, and rose
again slightly in 2003 to 21,951 tonnes (BSEF 2006). In the US the sum
of manufactured and imported HBCD is reported to lie between 4,540 to
22,900 tons in 2005 (US EPA 2008). The total volume of HBCD used in the
EU was estimated to be about 11,580 tonnes in 2006. The demand of HBCD
within the EU is bigger than the production there and the net import to
the EU was expected to have been around 6,000 tonnes in 2006 (ECHA
2008a). The authorities in Japan have reported the sum of domestic
production and import of HBCD to be 2,844 tonnes in 2008 and 2,613
tonnes in 2009. Several other national authorities report an import of
HBCD as a pure compound or in products; Canada (100-1,000 tonnes),
Australia (<100 tonnes), Poland (500 tonnes imported from China
annually), Romania (185 tonnes), and Ukraine (BSEF 2011,
UNEP/POPS/POPRC.6/13/Add.2). Available information suggests that use of
HBCD may be rising (ECHA 2008a). There is also evidence that HBCD may be
replacing some polybrominated diphenyl ether (PBDE) flame retardants
(notably the commercial decabromodiphenyl ether formulation)
(Environment Canada 2010a).

HBCD is used as an additive flame retardant, with the intent of delaying
ignition and slowing subsequent fire growth during the service life of
vehicles, buildings or articles, as well as while materials are stored
(BSEF 2010, see UNEP/POPS/POPRC.6/13/Add.2 for overview). The main uses
of HBCD globally are in flame-retarded expanded (EPS) and extruded (XPS)
polystyrene foam insulation (more than 95% in Europe), while the use in
textile applications and electric and electronic appliances (high impact
polystyrene/HIPS) is of a smaller scale (BSEF 2011,
UNEP/POPS/POPRC.6/13/Add.2 and references therein e.g. ECHA 2008a, US
EPA report, OECD 2007, INE-SEMARNAT 2004, Lowell Center For Sustainable
Production (LCSP 2006), BSEF 2010). The use of HBCD in insulation boards
started in the 1980s. HBCD is used in textile back-coating in upholstery
furniture and other interior textiles, including automotive applications
(Japan 2011, LCSP 2006). Some other minor uses have also been reported
by KEMI (2006). 

Based on the responses from the Parties and Observers and ECHA (2009),
the volumes of import and export of HBCD in flame retarded articles is
generally unknown. Polystyrene foams and textiles are usually tailor
made for the local market, and the main share of the production is for
local consumption, and not exported (SWEREA 2010, BSEF 2011). 

1.2.	Conclusions of the Review Committee regarding Annex E information 

At its sixth meeting in October 2010, the POPs Review Committee
evaluated the draft risk profile for HBCD in accordance with Annex E
(UNEP/POPS/POPRC.6/13) and adopted this (UNEP/POPS/POPRC.6/13/Add.2).
The POPRC decided that, “in accordance with paragraph 7 (a) of Article
8 of the Convention, hexabromocyclododecane is likely, as a result of
its long range environmental transport, to lead to significant adverse
human health and environmental effects such that global action is
warranted”. The Committee also decided to establish an ad hoc working
group to prepare a risk management evaluation that includes an analysis
of possible control measures for hexabromocyclododecane in accordance
with Annex F to the Convention for consideration at its next meeting.  

1.3.	Data sources

This risk management evaluation was developed using Annex F information
submitted by Parties and observers, including the industry using and
producing HBCD. 

Sixteen Parties and country Observers submitted information (Brazil,
Burundi, Canada, China, Costa Rica, Czech Republic, Ecuador, Finland,
Germany, Japan, Nigeria, Norway, Mauritius, Romania, and Sweden). Five
non-governmental Observers submitted information – Bromine Science and
Environmental Forum (BSEF), PlasticsEurope/Exiba, Instituto do Meio
Ambiente (IMA) Brazil, Extruded Polystyrene Foam Association (XPSA) and
Canadian Plastics Industry Association (CPIA) as well as the
International POPs Elimination Network (IPEN). All submissions are
available on the Convention web site.

Brazil reported it does not produce HBCD, and noted the lack of
information on emissions and use. In general HBCD is used in electronic
equipment, automotive and textiles production. Brazil also provided
extensive information on alternatives to HBCD and HBCD containing
products. 

Burundi reported it does not produce HBCD. Burundi highlighted the
lacking of capacity for monitoring and control of chemicals and waste,
and noted the need for capacity-building in emergency services,
environmentally sound destruction and recycling technologies.

Ecuador reported that HBCD is imported into the country only in
articles, not as a substance. 

Canada reported that HBCD is used in flame-retarded PS foams and
textiles. In Canada HBCD is used in PS foams in lower concentrations
(0.5-1%) than in Europe. Canada also noted the potential for brominated
dioxin and furan emissions related to uncontrolled burning of HBCD
containing articles. HBCD has been monitored across Canada in landfill
leachate since 2009, with varying detection frequency. HBCD has also
been monitored in surface water, sediment, air, aquatic biota and
wildlife, since 2008. HBCD has been detected in human blood, breast
milk, dust and ambient air. 

China provided information on production of HBCD in the country and
supported emission control, improved waste management and HBCD
substitution as potential control measures. China also noted that the
risks of alternatives to the environment and human health were not yet
addressed.

Costa Rica and Mauritius reported no production. Costa Rica also noted
the lack of information on HBCD use in the country impeding the
identification of alternative products. 

The Czech Republic reported on its ambient air monitoring activities.
HBCD isomers were released in the air during storage, manipulation of
the mixture and during the PS production process in 2010. The
concentrations inside and outside the production facility were hundreds
of ng/m3. HBCD was not found in human milk, but in 10% of the
liposuction samples. Czech Republic also pointed out that there is no
information on import and export of HBCD in the EU.

Finland submitted information on emissions and emission control measure
effectiveness at a recently closed EPS production facility. The results
confirm the need to address production waste (HBCD packages) and
emissions to air, sediment and waste water (from polystyrene beads). 11
% of the EPS produced in the country is flame retarded with HBCD. Fire
safety regulations do not require use of flame retardant in insulation
boards.

Germany noted that the use of EPS/XPS insulation boards without
flame-retardant is not allowed according to the German fire safety
regulations and that there is currently no drop-in chemical substitute
for HBCD in this use. Germany expressed the need for a time limited
exemption for HBCD use in EPS/XPS production. They also noted the
presence of alternative insulation materials to EPS/XPS and that product
redesign is technically feasible.

Japan reported use of HBCD in XPS, EPS, automotive textiles, and
curtain/blind production. In new car-models HBCD fabrics are not used
anymore, but the demand for fabric used in older models will continue
for some time.  XPS, as well as curtain and blinds producers are working
towards reducing or eliminating HBCD use, but no available chemical
alternatives have been identified. In Japan, EPS waste is collected and
recycled as fuel, i.e. RPF (Refuse Paper and Plastic Fuel), and other
products in effective recycling systems. 

Nigeria reported no production, but use of HBCD in EPS, XPS, HIPS and
polypropylene fibre. Nigeria provided information on alternatives to
HBCD in certain uses and supported substitution of HBCD with sustainable
flame retardants, use of product stewardship programs to minimize
emissions, and introduction of regulations to promote search for the
alternatives. Nigeria also stressed the importance of ensuring the
safety of the alternative chemicals and building laboratory capacity for
chemical measurements. 

Norway has prepared a risk management exploration proposal to the UNECE
CLRTAP POPs Task Force on HBCD (Exploration of management options for
Hexabromocyclododecane (HBCD). Fire regulations allow use of EPS/XPS
insulation boards without flame retardants in Norway if thermal barriers
are used. The Norwegian producers provide EPS without flame retardants
to the Norwegian market. The imported HBCD, approximately 22 t per year,
is exported to the EU in EPS. There are no other registered uses of HBCD
in Norway. Alternatives other than HBCD are used for textiles and
furniture. There is no information on amounts of HBCD in imported
products and articles. Norway stressed the importance of releases from
waste, especially insulation materials. HBCD has been found in the
environment both close to EPS production sites and in the remote regions
in the Norwegian Arctic. 

Romania reported use of HBCD in EPS and XPS production. The annual use
from 2009 was 134 tonnes for EPS and 50 tonnes for XPS production. With
regards to the waste management implications, Romania noted milling and
recycling of polystyrene waste.

Sweden expressed the need to achieve fire safety without flame
retardants by use of alternative materials and product designs, due to
the inherent hazardous properties of many flame retardants, and
highlighted that alternative solutions are also available. HBCD use in
insulation materials is very small in Sweden as fire safety standards do
not require EPX/XPS to be flame retarded. HBCD is being monitored by
Swedish contaminant monitoring programmes in marine biota, human milk
and ambient air. Due to negligible domestic use, the Swedish
environmental levels are heavily dependent on HBCD control measures in
other countries.

Bromine Science and Environmental Forum (BSEF) submitted information on
production and uses of HBCD, noting that the only production facility in
Europe had reduced its total HBCD emissions to the environment to less
than 2 kg a year. BSEF was also concerned over the effects of potential
HBCD restrictions on the market and producers, and expressed the
industry commitment to continue research to find a chemical alternative
to HBCD. 

Plastics Europe/Exiba, representing the HBCD users in the PS industry,
reported that HBCD is used in 0.7% content in EPS and an average of 2%
in XPS. Plastics Europe/Exiba also highlighted the successful emission
reductions programmes (VECAP/SECURE) in 2006-2009, where potential
emissions from first line users were reduced by 85 %. To ensure smooth
transition once an alternative is available, the industry intends to
apply for REACH authorization for the use of HBCD in polystyrene in
Europe, before the EU chemicals policy ban takes effect in 2015 (see
para 40).

IPEN highlighted the need to ban HBCD to reduce the levels in the
environment and noted the availability of alternative materials to
replace EPS/XPS. Elimination of flame retardant use in applications
where no fire hazard exists could be a starting point (underground
applications, non-combustible surfaces, thermal barriers). IPEN also
noted the wide availability of chemical and non-chemical alternative
flame retardants for use in insulation noting that the chemical
substitutes also may have hazardous properties. Special attention should
be paid to waste containing HBCD and emissions from burning HBCD
containing materials.

The North American XPS Industry (XPSA and CPIA) noted that the U.S. and
Canadian building codes contain provisions to limit ignition and burning
and that insulation is important to reduce CO2 emissions. The use of a
flame-retardant such as HBCD was reported necessary for XPS to meet the
U.S.  requirements of ASTM C-578 and achieve the International Building
Code and International Residential Code class A designation for flame
spread and smoke development per ASTM E-84. Use of a flame-retardant
such as HBCD also enables XPS to meet the requirements of CAN/ULC S701
and CAN/ULC S102.2, of the 2005 National Building Code of Canada for
foamed plastics in non-combustible construction. The HBCD concentration
in XPS produced in the US and Canada is lower than in Europe, on average
0.8% by weight. XPSA and CPIA noted that in production of flame retarded
XPS, HBCD releases are possible during transfer from the original
packaging to the feeder at the start of the process, in disposal of
packaging materials, and during process upsets.

1.4.	Status of the chemical under international conventions 

HBCD is included as part of the brominated flame retardants group in the
List of Substances for Priority Action of The Convention for the
Protection of the Marine Environment of the North-East Atlantic (the
OSPAR Convention). The OSPAR Convention is made up of representatives of
the Governments of 15 Contracting Parties and the European Commission.
Also the Helsinki Commission (HELCOM) has included HBCD in the list of
priority hazardous substances.

In December 2009, HBCD was considered by the Executive Body of the UNECE
Convention on Long-Range Trans-boundary Air Pollution (LRTAP) based on a
technical review (ECE/EB.AIR/WG.5/2009/7) to meet the criteria for POPs
as defined under the POPs protocol. In 2010 the possible management
options for HBCD were assessed to give a basis for later negotiations.
The negotiations are expected to be initiated in December 2011. 

1.5.	Any national or regional control actions taken

Many countries have set standards for building materials with regards to
their contribution to fire. Consequently, inherently flammable materials
must be treated with a flame retardant to meet certain fire performance
criteria, which is required in the country regulations for a specific
use. Fire protection requirements for certain articles are laid down in
acts, ordinances and regulations as well as in standards. In the
legislation, the requirements are normally specified in general terms.
To demonstrate that the requirements are met, there are prescribed
verifiable criteria, which standardisation bodies such as ISO, CEN and
UL often have helped to develop (KEMI 2006).

In Europe fire test methods have been harmonised and classification of
reaction to fire performance for construction products, excluding
floorings, are based on four fire test methods: the non-combustibility
test EN ISO 1182, the gross calorific potential test EN ISO 1716, the
single burning item (SBI) test EN 13823, and the ignitability test EN
ISO 11925-2. Building products are divided into seven classes on the
basis of their reaction-to-fire properties. (SWEREA 2010). In the U.S.
there are numerous regulations and standards that apply to insulation
used for the building industry. These regulations and standards may
exist at the national, state, county, or municipal level (LSCP 2006).

There are requirements in some countries regarding the use of flame
retardants in PS foam for insulation. Fire safety regulations require
that flame retardant must be used in Canada, Austria, Czech Republic,
Germany, Hungary, Netherlands, Slovakia, Slovenia, and Switzerland in
all building applications, irrespective of the use. Moreover, flame
retardants are used to reduce fire risk for warehouses containing EPS
before use in buildings/packaging. Fire regulations and international
standards govern the fire safety of polymer applications, but they do
not require the use of a certain flame retardant. In Denmark and Iceland
flame retarded EPS is required for use in buildings. In Italy, Portugal
and UK flame retarded PS foams are generally used according to the
industry. Flame-retarded PS foam may be used in some building
applications in Finland, Norway, and Sweden, although it is not
required. In Sweden, the industry has voluntarily withdrawn HBCD
containing products from the market, which is possible because
alternative construction techniques can be used, even with EPS
applications. 

The EU’s Directive on Waste Electrical and Electronic Equipment (WEEE)
(2002/96/EC) requires the removal of plastics containing brominated
flame retardants and of printed circuit boards from electrical and
electronic equipment prior to recovery and recycling. 

HBCD has been identified by the EU as a Substance of Very High Concern
(SVHC), meeting the criteria of a PBT (persistent, bioaccumulative and
toxic) substance pursuant to Article 57(d) in the REACH regulation (ECHA
2008b). In February 2011 HBCD was included in the European Chemicals
Agency (ECHA) list of substances subject to authorisation under REACH.
Taking effect in 2015, HBCD can no longer be used without authorisation.
A proposal on classification and labelling of HBCD as a possible
reproductive toxic substance was made within the EU (Proposal for
Harmonised Classification and Labelling, Based on the CLP Regulation
(EC) No 1272/2008, Annex VI, Part 2 Substance Name:
Hexabromocyclododecane Version 2, Sep. 2009) (KEMI 2009). The EU risk
assessment committee (RAC) is of the opinion that HBCD should be
classified as suspected to damage fertility or the unborn child (Repr.2
HR361), and may cause harm to breast-fed children (Lact. H362) (RAC
2010). 

In Ukraine HBCD is registered on the hazardous chemical list based on
health effects. 

In Japan HBCD has been designated as a Monitoring Chemical Substance
because of its persistence and high bio-accumulation under the Act on
the Evaluation of Chemical Substances and Regulation of Their
Manufacture, etc. (commonly referred to as the Chemical Substances
Control Law "CSCL"). In September 2010, Japanese Ministers of Health,
Labour and Welfare, and of Economy, Trade and Industry and of the
Environment instructed persons operating the business of manufacturing
or importing HBCD to conduct an Avian Reproduction Test (OECD Test
Guideline 206) and to report the results thereof by the end of March
2014 under CSCL.

In the USA, the EPA anticipates proposing a significant new use rule
(SNUR) under section 5(a)(2) of the Toxic Substances Control Act (TSCA)
for the use of HBCD in consumer textiles. Such a proposal would indicate
that EPA believes such use would constitute a significant new use.  The
SNUR would require persons who intend to manufacture, import, or process
HBCD for the designated significant new use to notify EPA at least 90
days before commencing such use.  The required notification would
provide the EPA with the opportunity to evaluate the intended use and,
if necessary, to prohibit or limit that activity before it occurs.

A proposal for a national ban of HBCD is currently under consideration
by the Norwegian Ministry of the Environment (Norway 2011).  Canada is
currently undertaking a risk assessment of HBCD and will be considering
control measures when that assessment has been completed, which is
expected in 2011.

2.	Summary information relevant to the risk management evaluation

HBCD may be released to air, water, soil and sediment.  Release of HBCD
into the environment may occur during production and manufacturing,
processing, transportation, use, handling, storage or containment,
point-source discharges, migratory releases from manufactured product
usage and from disposal of the substance or products containing the
substance. In Canada, HBCD has been known to be discharged into various
tributaries, watersheds, rivers and lakes resulting in increased levels
in sediments, surrounding soils and biota (Environment Canada 2010b).

Releases of HBCD to the environment from HBCD production have been
considered small in the EU, with only one production facility. In the EU
it was estimated that about 3 kg a year are released from the workplace
plus a further 2 kg to air and 0.1 kg to waste water. The estimated
releases of HBCD to the environment during the manufacture and
formulation of HBCD containing products were 41 kg to air, 60 kg to
waste water and 35 kg to surface water per year in the EU RAR (ECHA
2008a). The release of HBCD from products during end use is small. Some
dust containing HBCD will be released during the installation of EPS or
XPS insulation and ultimately during the refurbishment or demolition of
buildings containing these products. The estimated annual release to the
environment was 530 kg to air, 1,140 kg to waste water and 560 kg to
surface water. According to the EU RAR, the end use releases to waste
water and surface water are dominated by textile coatings. The use of
HBCD in textiles is believed to have fallen substantially in recent
years. The quantities of waste products sent for disposal are uncertain
and it was also noted that estimated releases of HBCD during the
consumer use of products are highly uncertain (ECHA 2008a). 

Releases from waste disposal are difficult to estimate because of the
long lifetime of XPS and EPS once installed in buildings (potentially up
to 100 years) combined with an increasing trend towards the recycling of
electrical equipment. Solid waste containing HBCD may be scrap materials
generated during processing operations, particulates released through
aging and wear of end products, and disposal of products at the end of
service life. Products and materials in landfill sites will be subject
to weathering, releasing HBCD particulates primarily to soil, and to a
lesser extent, to water and air (Environment Canada 2010b).

HBCD phase-out could include flame retardant substitution,
resin/material substitution and product redesign (LCSP 2006). In
addition, re-evaluating fire-safety requirements e.g. in applications
where fire hazard is absent (such as underground applications) or
otherwise eliminated would reduce the need for flame-retarded insulation
materials. Emissions of HBCD can be reduced in processes where HBCD or
articles containing HBCD are used, and during the waste management
phase. In Sweden, the industry has voluntarily withdrawn HBCD containing
products from the market, which is possible because alternative
construction techniques can be used. 

2.1.	Identification of possible control measures

The objective of the Stockholm Convention (Article 1) is to protect
human health and the environment from persistent organic pollutants.
Under the Convention this may be achieved by listing HBCD in Annex A,
with or without specific exemptions, possibly accompanied with detailed
actions for production and certain uses of HBCD. 

In the Annex F process, a number of HBCD uses have been identified by
Parties and Observers. For many of the uses alternatives are already
available and currently used in many countries. These uses include
production of high impact polystyrene (HIPS) plastic and production of
flame retarded textile back-coating. Alternative flame retardants to
HBCD in production of flame retarded expanded polystyrene are being
developed and used in some regions, but they are not suitable for all
production processes. Also, their health, safety, and environmental
properties may not be well known. However, alternative insulation
materials and technical solutions to EPS/XPS are already widely used as
well as alternative construction methods. These uses and the potential
substitutes will be further described in section 2.3. below.

Emission reduction measures and use of best practices would be required
in the production and manufacture for potential specific exemptions and
exempted uses in order to reduce HBCD releases to the environment from
these exempted uses. Significant reduction in estimated total emissions
from production and first line users has been reported by the industry
in Europe following voluntary measures.

In accordance with Article 6(1)(d)(ii), HBCD containing products (EPS,
XPS, HIPS, textiles) should be managed in an environmentally sound
manner and disposed of in such a way that their POPs content is
destroyed. This will require separation of HBCD containing articles from
others upon becoming waste, and the prevention of inappropriate waste
management practices leading to recycling of the POP content. 

2.2.	Efficacy and efficiency of possible control measures in meeting
risk reduction goals

Listing HBCD in Annex A of the Convention without exemptions would
effectively reduce the releases of HBCD. This would require either
introducing alternative building techniques or insulation material to
achieve fire safety in construction, or the industry phasing in an
alternative to HBCD. 

Based on the submissions from Parties and Observers, there is currently
a need for flame retarded insulation materials due to country-specific
fire safety requirements in some countries. However, the safety
requirements do not identify any specific flame retardant substances or
groups of flame retardant substances that have to be used.  Some
countries have already phased out HBCD in the absence of a substitute
chemical flame retardant indicating that there are alternative materials
and techniques available on the market already. However, no viable
replacement to HBCD is yet available commercially for flame retarded EPS
and XPS production. 

Emission control techniques at the production sites alone will not be
sufficient to solve the problem HBCD is posing to the environment and to
health, since the diffuse emissions and releases to the water reserves
and sewage systems from the use and machining of products containing
HBCD, as well as releases when becoming waste also is of significant
concern. 

In addition to listing HBCD in Annex A, waste management measures for
materials in use should be introduced to ensure environmentally sound
management of HBCD containing insulation materials, plastics, and
textiles at the end-of-life stage. This would require identifying
materials in which HBCD has been added when buildings are renovated or
dismantled to facilitate destruction of the POP content in the waste and
to prevent inappropriate management practices leading to recycling or
landfilling the POP content.  Recycling of HBCD can be significant.
According to the Swiss substance-flow analysis, the proportion of HBCD
recycled is higher than for material containing other brominated flame
retardants, and the recycling percentage of HBCD used in EPS insulation
was expected to rise from 30% in 2005 to 60% in 2010 (Geopartner 2007).
In the EU in 2007, the share of EPS with flame retardant was 60% of the
total EPS demand, and the share of XPS with flame retardant 92% of the
total XPS demand (PlasticsEurope/Exiba 2011). In two Swiss studies on
electronic and electrical appliances, vehicles and building materials,
HBCD was found in 2% and 6% of the studied plastic component samples
(BUWAL 2004, BFR 2010 - 486 and 214 samples respectively).  Another
recent Swiss WEEE study, however, did not find HBCD in any of the 53
samples analysed (EMPA 2010). 

Recycled products containing HBCD, including EPS and XPS boards, are
potential sources of emissions in the same way as virgin products.
Recycling operations for recovery of metals or plastics in electronic
products and vehicles are potential sources as well. In controlled waste
streams parts containing HBCD could be sorted out, but this will not
always be technically feasible in the waste stream. Use of labelling of
products or parts of products could be a valuable help in the process
(KEMI 2006).

EPS has an estimated service life of approximately 30-100 years and
collecting and recycling used EPS may be hindered due to difficulties in
separating EPS containing HBCD from others. Some EPS can be recycled and
used for the manufacture of bricks where the polystyrene is gasified and
leaves a cavity in the center of the brick. In this process HBCD is
destroyed. However, it is difficult to separate the HBCD treated PS and
HIPS from their HBCD-free counterparts.  This greatly complicates the
separation of recyclable materials. 

Controlled incineration is one way to dispose of PS foam containing HBCD
(CEFIC 2011, ECHA 2008a). The flame retardant decomposes in the
incineration plant process. In a co-combustion study in a high
temperature pilot facility (>900°C), the foam added substantially to
the Br content in the incinerator, but did not appear to add
significantly to the overall hazard of raw gas or emissions (APME). 
Experimental evidence confirms that under some conditions HBCD and
products containing HBCD form and may release polybrominated
dibenzo-p-dioxins (PBDD) and dibenzofurans (PBDF) during burning, even
in state of the art municipal solid waste incineration facilities (APME,
NCM 2004).  However, PBDDs and PBDFs formed from HBCD waste will likely
be destroyed by the very high operating temperatures and controlled
operating conditions employed in state of the art incinerators. The
incineration efficiency and the operating conditions of the flue gas
treatment systems are of great importance to the resulting emissions of
dioxins (NCM 2004). Hence, there is potential for the release of these
substances from uncontrolled burns and accidental fires,
pyrolysis/gasification plants, recycling processes, and from
incinerators that are not functioning well (Weber and Kuch 2003). 
Desmet et al. (2005) also documented the formation of bromophenols,
known precursors of polybrominated dibenzodioxins and dibenzofurans,
during combustion of flame-retarded extruded polystyrene containing
HBCD. Bromophenol formation seemed to be inherent to the flame retardant
mechanism of HBCD. The study did not investigate the formation of
brominated dioxins and furans but noted that it was highly probable that
various brominated dioxin isomers would be formed from bromophenols. 

State of art incineration with energy recovery is expected to be more
widely available in the coming years, hence diverting HBCD containing
materials from landfill. However, currently in many countries
landfilling is the most common way of waste disposal, leading to HBCD
containing waste accumulating in the landfills. 

2.3.	Information on alternatives (products and processes) where relevant


The POPRC has agreed that HBCD is a POP due to its long-range
environmental transport and significant adverse human health and
environmental effects such that global action is warranted
(UNEP/POPS/POPRC.6/13/Add.2). The target or aim of any risk reduction
strategy for HBCD should be to reduce and eliminate emissions and
releases taking into consideration the indicative list in Annex F
including technical feasibility of possible control measures and
alternatives, the risk and benefits of the substances and their
continued production and use. In considering any strategy for a
reduction in such risks, it is important to consider the availability of
substitutes in the sectors of concern. In this regard, the replacement
of HBCD by another chemical or  non-chemical alternative needs to take
account of factors such as: 

technical feasibility (practicability of applying an alternative
technology that currently exists or is expected to

be developed in the foreseeable future)

costs, including environmental and health costs

risk (safety of the alternatives)

availability and accessibility   

A discussion of the availability and suitability of substitutes of HBCD
is provided below. 

There are technically feasible and commercially available alternatives
to different uses of HBCD on the market, although not for EPS production
in Europe. They include flame retardant substitution, resin/material
substitution and product redesign. Several of them are halogen-free and
are therefore considered to be better alternatives for the environment
and health in the evaluations done (ECHA 2009, SWEREA 2010, KLIF 2010)
(Table 3). However, their other risks may not have been fully studied. 



Table 3. Summary table of technically feasible and commercially
available halogen-free alternatives to the use of HBCD (based on SWEREA
2010). 

Polymer materials	Applications	Alternative chemicals	Alternative
material and product redesign

HIPS	Housings of electronic products

Wiring parts	Arylphosphates such as:

Resorcinol bis (biphenyl phosphate)

Bis phenol A bis (biphenyl phosphate)

Polymeric biphenyl phosphate

Diphenyl cresyl phosphate

Triphenyl phosphate	Alloys of PPE/HIPS treated with halogen free flame
retardant alternatives



EPS

&

XPS	Insulation of foundation, walls and ceilings

Ground deck, parking deck etc.	No halogen free ‘drop in’ replacement
chemicals commercially available at present for all production processes
and regions	EPS and XPS without FRs, using thermal barriers

Phenolic foams

Blankets (fiber batts or rolls) that may contain rock wool, fiber glass,
cellulose or polyurethane foam

Polyester batts

Loose fills that may contain rock wool, fiber glass, cellulose or
polyurethane foam

Textile back coatings	Protective clothing

Carpets

Curtains

Upholstered fabrics

Tents

Interior in public transportation

Other technical textiles	Intumescent systems that contain:

a dehydrating component, such as ammoniumpolyphosphate (APP)

a charring component, such as pentaerythritol (PER)

a gas source, often a nitrogen component such as melamine

	

2.3.1 Production of high impact polystyrene (HIPS) plastic 

A number of alternative fire retardants are available to replace HBCD in
HIPS (Table 3). They are all required to be used at considerably higher
loadings (ECHA 2009).  Deca-BDE has been widely used in HIPS and also in
electronic wire insulation but may not be suitable for use as a
substitute for HBCD due to concerns about its impact on human health and
the environment as well as debromination to components of PentaBDE and
OctaBDE.  In the EU, the introduction of the RoHS Directive phased out
the use of Deca-BDE.  In the US the industry is voluntarily withdrawing
Deca-BDE from most uses by 2013.  Other chemicals that can be used as
alternatives to HBCD in HIPS include both halogenated flame retardants
used in conjunction with antimony trioxide (ATO) and halogen-free
organic aryl phosphorus compounds.  Halogenated flame retardants may
also increase the toxicity of the emissions from fire (Dioxin 2010). 
Nevertheless, since HBCD is not widely used in HIPS, it may be
reasonable to assume that the alternative flame retardants on the market
are technically and economically feasible. 

In electrical products HIPS can be replaced by various alternative
materials, including blends of polycarbonate / acrylonitrile butadiene
styrene (PC/ABS), polystyrene / polyphenylene ether (PS/PPE) and
polyphenylene ether / high impact polystyrene (PPE/HIPS) without flame
retardants or with the use of non-halogenated flame retardants (Brazil
2011, DEPA 2010) .  These co-polymer blends have higher impact strength
and are more resistant to burning because they form an insulating char
foam surface when heated (DEPA 2010).  

2.3.2 Production of flame retarded textile back-coating

The typical concentration of HBCD in textile applications is high
compared to other applications, 6 to 15% in a polymer (CEFIC/EFRA 2006).
Several chemicals may be used as drop-in alternatives for HBCD in
textile applications.  For textile backing, alternatives to HBCD include
deca-BDE, chlorinated paraffins and ammonium polyphosphates (ECHA 2009).
Deca-BDE is not readily biodegradable, and has low bioaccumulation
potential in the environment. Long chain chloroparaffins are
reproductive toxicants to humans, show chronic toxicity with effects on
liver and kidneys, and are potential carcinogens (ECHA 2009). 

It is important to note, that flame-retardant use in textiles can be
avoided if the material is non flammable, such as wool. It can also be
used as barrier materials in furniture (Norway 2011). 

According to the submission from Japan HBCD has been replaced in fabrics
used in new car models. However, the demand for fabrics that contain
HBCD will continue for some time as such fabrics continue to be used in
older models (Japan 2010).

Production of flame retarded expanded and extruded polystyrene (EPS/XPS)

According to the European industry there are currently no commercially
or technically viable drop-in chemical alternatives to HBCD as a flame
retardant in polystyrene foam. This is because alternative chemical
flame retardants impair the structure and properties of the foam, making
it unsuitable for use (ECHA 2009, BSEF 2011).  However, alternative
halogenated flame retardants are commercially available in the USA for
EPS, where the production process used is different. The polystyrene
industry is in the process of finding an alternative to HBCD jointly
with flame-retardant producers. In April 2011 Great Lakes Solutions
announced investing in a facility to produce a brominated polymeric
flame retardant suitable for EPS and XPS. Little is known about the
environmental and health properties of these substances.

The HBCD industry has highlighted the main challenges in the search for
alternative flame retardants as the following (BSEF 2011): 

Fire performance of the products with the flame retardant over the
complete service life, which needs to meet existing stringent
regulations in the relevant countries

Fit to produce foams without undermining the foam properties. In
addition, once found and approved for fire safety and other regulatory
requirements, an alternative will have to be transitioned throughout the
complex PS insulation foam market

Consumer safety for the end product, which needs to be similar to HBCD
in PS foams 

Environmental profile, which needs to be superior to HBCD. Fit to
produce foams without increasing safety risks for workers.

There are also alternative insulation materials available on the market
that meet the fire-safety requirements in many countries facilitating
HBCD phase-out for this application. Alternative insulation materials to
EPS/ XPS are available for all uses, with the exception of some
demanding XPS use in moist or freeze/thaw sensitive applications in
North America (XPSA/CPIA 2011). These alternative insulation systems
have different characteristics to XPS and EPS and may be less
appropriate for some specific use scenarios or may incorporate different
environmental issues such as increased energy costs during
transportation (ECHA 2009).

Alternatives to HBCD

Brominated chemicals other than HBCD are commercially available as flame
retardants for use in EPS applications in North America. These are
tetrabromocyclooctane and dibromoethyldibromo-cyclohexane (LSCP 2006,
BSEF 2011). There are also concerns about the environmental or health
properties of these substances:

Tetrabromocyclooctane is structurally related to tetrabromocyclohexane
which was identified in modelling studies as structurally similar to
known Arctic contaminants and/or have partitioning properties that
suggest that it is a potential Arctic contaminant.  

Dibromoethyldibromo-cyclohexane is found in beluga whales in the Arctic;
modelling studies identify it as likely to be persistent and
bioaccumulative; and it was found to be a strong androgen agonist and
mutagenic to mammalian cells in vitro.

The Japanese EPS industry is aiming at replacing HBCD in the production
processes by the end of 2012 and also the industry producing XPS is
working towards reduction in HBCD use by reconsidering HBCD content but
also the need for HBCD in the product (Japan 2011). Interestingly, the
European industry appears to use higher amounts of HBCD than North
American producers to meet the fire safety requirements.

The first consideration would be to eliminate use of HBCD and other
flame retardants in cases where no fire hazard exists. These uses
include placement of insulation between two non-combustible wall
surfaces such as stone or concrete and uses where insulation is placed
between building foundations and soil. These design changes could be
implemented by the end-product manufacturer (LCSP 2006).  

Another strategy would be to apply the flame retardancy function through
the use of fire resistant coverings or coatings that act as thermal
barriers. Thermal barriers are fire resistant coverings or coatings that
separate the insulation material from the building interior. These
include: gypsum board, gypsum or cement plasters, perlite board,
spray-applied cellulose, mineral fiber, or gypsum coatings, and selected
types of plywood. All these materials are currently in common use in
domestic and commercial building construction (LCSP 2006, SWEREA 2010).
Thermal barriers are subject to country-specific building code
requirements (SWEREA 2010). 

By using thermal barriers it is possible to fulfil fire safety
requirements in most of the uses in construction and buildings with EPS
and XPS without a fire retardant. This has been reported to be an
available alternative on the market by Finland, Norway, Sweden and
Spain. The national fire safety requirements are achieved by the
building codes specifying the different uses of insulation products in
buildings and construction, through the use of thermal barriers and
hence the use of flame retardant is not required to achieve fire safety
even when using EPS/XPS. 

Alternatives to EPS/XPS

Flame retarded expanded and extruded polystyrene foam (EPS and XPS) used
for building insulation can also be replaced by alternative materials.
This is a more complex approach than simple flame retardant substitution
because it has a greater effect on overall product cost and performance.
This change could be implemented by the polymer processor/compounder or
the end-product manufacturer (LCSP 2006). 

Types of alternative insulating materials include polyisocyanurate
foams, and phenolic foams:

Polyisocyanurate foams include modified urethane foams that utilize
chemical flame retardants such as tris monochloropropyl phosphate
(TCMPP) and tris chloroethyl phosphate (TCEP). TCMPP is poorly
characterized toxicologically but in the TCEP manufacturing process
ethylene oxide (a carcinogen) is used, it appears to be a reproductive
toxicant, is found in the Arctic indicating long-range transport, and is
considered a carcinogen by the California Office of Environmental Health
 Hazard Assessment. Due to the chlorinated and brominated flame
retardants used in the manufacture of polyisocyanurate insulation
products, these cannot be considered to be preferable alternatives
because of their health effects (LCSP 2006).

Phenolic foams are in use in roofing, cavity board, external wall board,
and floor insulation. They are mostly used to bind glass fiber to make
insulation products. One concern over their use is that formaldehyde, a
human carcinogen, is used for making phenolic resins monomer.
Formaldehyde is listed by the International Agency for Research on
Cancer (IARC) as a known human carcinogen (Morose 2006). This has to be
considered at the production sites, using available emission control
techniques and safety restrictions securing the workers.

Blanket insulation is as much a technical alternative as an alternative
material.  It is usually made of fiber glass or rock wool and can be
fitted between studs, joists, and beams. It is available in widths
suited to standard spacings between wall studs or floor joists.
Continuous rolls can be hand cut and trimmed to fit various spaces. The
blankets are available with or without vapour retardant facings. Batts
with special flame resistant facing are available where the insulation
will be left exposed. 

Fiberglass is a synthetic vitreous fiber. Loose-fill insulation is
typically blown into place or spray-applied by special equipment. It can
be used to fill existing wall cavities and for irregularly shaped areas.

Reflective insulation systems include foils, films, or papers that are
fitted between studs, joists, and beams and commonly used to prevent
downward heat flow in roof applications. Common materials include
foil-faced paper, foil-faced polyethylene bubbles, foil-faced plastic
film, and foil-faced cardboard.

Other commonly used insulation materials include polyester batts and
sheep wool which can be fitted between studs, joists, and beams.

Technical alternatives to HBCD containing EPS/ XPS include: blown-in or
spray-applied insulation materials such as rock wool, fiber glass,
cellulose, or polyurethane foam. Loose-fill cellulose insulation is
commonly manufactured from recycled newsprint, cardboard, or other forms
of waste paper. The blown-in loose-fill insulation can provide
additional resistance to air infiltration if the insulation is
sufficiently dense. Loose-fill insulation can also be poured in place by
using materials such as vermiculite or perlite. These materials are
produced by expanding naturally occurring minerals in a furnace (LCSP
2006).

When alternative building insulation materials or EPS and XPS without
flame retardants are used the necessary flame protection can be provided
by use of a thermal barrier. Thermal barriers are fire resistant
coverings or coatings that separate the insulation material from the
building interior. Thermal barriers can be used to increase the fire
retardant performance for various types of insulation. Thermal barriers
are subject to current building code requirements. Commonly used thermal
barriers include: gypsum board, gypsum or cement plasters, perlite
board, spray-applied cellulose, mineral fiber, or gypsum coatings, and
select plywood’s. By using thermal barriers it is possible to fulfil
fire safety requirements in most of the uses in construction and
building applications using EPS and XPS without a flame retardant. This
has been reported to be an available alternative on the market by
Norway, Sweden and Spain (SWEREA 2010).

Fiberglass, glass wool, and mineral wool are considered synthetic
vitreous fibers. They also may have occupational health effects. When
these fibers are suspended in air they can cause irritation of the eyes,
nose, throat, and parts of the lung. Animal studies show that repeatedly
breathing air containing synthetic vitreous fibers can lead to
inflammation and fibrosis of the lung. (ATSDR 2004). Protective clothing
and equipment (face masks, goggles, gloves etc.) is available and used
by construction workers to avoid irritations from contact and breathing
in the fibres. This will only be of importance in the working
environment, since the fibrous material is built inside the wall,
foundation and ceilings in the buildings and constructions.

2.4.	Summary of information on impacts on society of implementing
possible control measures

As the persistent, bioaccumulative and toxic properties of HBCD as well
as its potential for long-range transboundary transport were shown in
the risk profile agreed by the POPRC of the Stockholm Convention, a
positive impact on globally sustainable development from an elimination
of HBCD is to be expected. If production and use of HBCD with
persistent, bioaccumulative and toxic properties is not managed, and
were to continue or increase, then levels in the environment including
in humans and animals will likely continue to rise, even in locations
distant from production and use.

2.4.1.	Health, including public, environmental and occupational health

A positive impact on human health and on the environment can be expected
from reduction or elimination control measures on HBCD on a global
scale, especially in relation to blood levels. In humans HBCD is found
in blood, plasma and adipose tissue. The main sources of exposure
presently known are contaminated food and dust. Imposing control
measures would likely ensure that the levels of HBCD in agricultural
products like farmed (and wild) fish, milk/milk products and various
meat products level off. In the short term, the most positive effect
would be anticipated to be on the indoor environment; with HBCD levels
in dust being completely eliminated or dramatically reduced as a
consequence of a ban. A positive outcome of this would be reduced
exposure to humans, particularly children, who have been shown to ingest
more dust than adults (UNEP/POPS/POPRC.6/13/Add.2). 

Though information on the human toxicity of HBCD is to a great extent
lacking, embryos and infants have been identified as vulnerable groups
that could be at risk (UNEP/POPS/POPRC.6/13/Add.2, RAC 2010),
particularly due to the observed neuroendocrine and developmental
toxicity of HBCD observed in animal studies. Phase-out or elimination of
HBCD would also be particularly beneficial to Arctic indigenous peoples
who depend on traditional native foods and therefore are at much greater
risk of exposure than other communities. The particular risks posed by
POPs to Arctic ecosystems and indigenous communities are acknowledged in
the preamble to the Convention. 

In developing countries, electrical and electronic appliances containing
HBCD and other toxic substances are often recycled under conditions
which result in a relatively high release of HBCD to the environment and
contamination of the sites (Zhang et al., 2009), and exposure of workers
(Tue et al., 2010). Open burning and dump sites are common destinations
for HBCD-containing articles and electronic wastes (Malarvannan et al.,
2009, Polder et al., 2008).

HBCD and other brominated flame retardants (BFRs) may also increase fire
toxicity and lower survival by augmenting the release of carbon monoxide
and soot and production of halogenated dibenzodioxins and dibenzofurans
(see Dioxin (2010). The prevalence of certain kinds of cancer in fire
fighters may be linked to an elevated exposure to brominated and
chlorinated dioxins and furans and this warrants further attention. The
overall fire safety benefit of regulations requiring flame retardants
has been questioned since they can increase the release of toxic gases
and soot which are the cause of most fire deaths and injuries (DiGangi
et al 2010, Stec & Hull 2010). Combustion of materials containing HBCD
or other halogenated flame retardants during accidental fires and
burning flame-retarded waste increases the toxicity of fire effluents by
increasing the release of carbon monoxide, acid gases such as hydrogen
bromide, and brominated and chlorinated dioxins and furans (Shaw et al
2010). An overall reduction of flame-retarded materials may therefore
lead to a smaller risk of health problems for the general public and
fire fighters, if fire safety can be achieved by other means. 

2.4.2 	Biota (biodiversity)

A positive impact on biota from a ban of HBCD can be expected. The
scientific literature has identified that HBCD is very toxic to aquatic
organisms. In avian species, data from recent studies report effects
such as reduced eggshell thickness, growth and survival. Further
indications for concern come from recent preliminary data obtained with
captive American kestrels which suggest a risk for reproductive and
developmental effects also in wild birds in remote regions
(UNEP/POPS/POPRC.6/13/Add.2).

2.4.3 	Economic aspects, including costs and benefits for producers and
consumers and the distribution of costs and benefits 

The cost for developing countries of a phase out of HBCD uses should be
limited, as the majority of the HBCD use takes place in Europe.
According to BSEF, a ban of HBCD in the absence of a drop-in alternative
would severely harm the EPS and XPS industry in Europe and drastically
impact the economics also for non-HBCD containing PS foam. In addition,
specialized waste management and disposal related to HBCD (buildings and
articles) could be costly for both developed and developing countries.
According to information from XPSA and CPIA a ban of HBCD would prevent
the use of XPS products containing the substance, end the current
practices of the XPS industry in the US and Canada, and cause
difficulties since for many applications XPS is the only product
recommended and accepted by current building codes. The recent progress
in finding a polymeric chemical alternative, although brominated, may
alleviate these concerns.

Emission reduction measures and use of best practices would be required
in the production for potential specific exemptions and use therein to
reduce HBCD releases to the environment from these uses. European HBCD
and polystyrene manufacturers have in 2006 initiated emission reduction
programmes, which are targeted at eliminating emissions from first line
users of HBCD (Self-Enforced Control of Use to Reduce Emissions (SECURE)
and Voluntary Emissions Control Action Programme (VECAP)). Most of the
European PS foam industry implements those risk reduction measures
(EBFRIP 2009a). Implementing best practices in handling reduced the
total potential releases from 2,017 kg/year in 2008 to 309 kg/year in
2009 in the survey. The costs of emission reduction programmes initiated
by European HBCD and polystyrene manufacturers are highly dependent on
the company operations (BSEF 2011). Also the Japanese curtain and blind
industry has developed a coagulation-sedimentation method in the dyeing
process to reduce HBCD emissions to water (Japan 2011).

In accordance with Article 6(1)(d)(ii), HBCD containing products (EPS,
XPS, HIPS, textiles) should be managed in an environmentally sound
manner and disposed of in such a way that their POPs content is
destroyed or irreversibly transformed so that they do not exhibit the
characteristics of POPs. This will require separation of HBCD containing
articles from others upon becoming waste and the prevention of
inappropriate waste management practices leading to recycling of the POP
content. 

For drop-in chemical substitutes, two main types of costs have to be
considered concerning the switch from one flame retardant to another
(SWEREA 2010);

The switching cost, which is the cost of reformulation, in other words
the cost of the development work or equipment change. Manufacturing and
processing facilities may need to invest in new equipment in order to
shift to alternative flame retardants. This cost is difficult to
estimate, and usually contains the cost of those research and
development endeavours which did not succeed in finding an efficient
flame retardant alternative. This is a cost which is generated at the
beginning of a product life cycle.

The operating cost which reflects the price of the flame retardant (raw)
material cost. In addition, daily operation costs may be different for
the new process steps required to manufacture other flame retardant
chemicals. To ensure economic viability, flame retardants must be easy
to process and cost-effective for what most of the time high-volume
manufacturing conditions are necessary. The costs of manufacturing are
heavily dependent on the costs of raw materials, but the degree of this
dependency varies among the flame retardants. 

Following this, the PS foam industry must adapt to the new flame
retardant alternatives. In spite of those costs mentioned above,
movement to alternatives already exists implying that the costs are
acceptable and not critical, although not yet fully known. 

A ban on HBCD can have consequences for EPS and XPS producers in
relation to the workforce in this sector (Plastics Europe/Exiba 2011,
XPSA/CPIA 2011). In 2003 the EPS sector group and the European XPS
producers in Europe initiated projects to find alternatives to HBCD for
use in EPS and XPS and to share the costs connected with the development
of new alternatives with the flame retardant producers (HBCD industry
working group 2009). At this time HBCD was undergoing risk assessment
under the Existing Substance Regulation (EC) 793/93 in the EU, and the
manufacturers of EPS and XPS were highly concerned about the outcome of
the environmental profiling, the future regulatory situation and the
resulting impact on producers and users (HBCD Industry Working Group
2009). The HBCD industry working group reported to the UNECE/CLRTAP
process in 2010 that current estimations from the two projects underway
were that an alternative would be available on the market in 5-10 years.
This included the registration of the alternatives under REACH in the
EU.

In North America the major brominated flame retardant manufacturers
(Albemarle, Chemtura Corporation and ICL-IP) have formed alliances with
other companies (forming the North American Flame Retardant Alliance
(NAFRA) under the umbrella of ACC) to promote and defend a broad range
of flame retardants.  The three companies have inorganic phosphor based
flame retardants in their portfolio in addition to the brominated flame
retardants.  Other brominated flame retardants for use in EPS are
already on the United States market as alternatives to HBCD (LCSP 2006).
They are however not applicable to the European industry which uses
different processes for manufacture of EPS and XPS. However, there is a
recent announcement by Great Lakes Solutions on preparations to start
production of a directly applicable alternative to HBCD.

EPS and XPS insulation boards are most often covered by other materials
in buildings and constructions. Using thermal barriers will not
represent an extra cost, since thermal barriers used are common
materials and relatively cheap. EPS and XPS without flame retardants are
commercially and technically feasible alternatives today and do not
represent a higher cost to the manufacturer. The market in Scandinavia
is dominated by polystyrene boards without flame retardants. This is
accomplished by fire safety regulations not requiring treatment with a
flame retardant, acquiring the same level of protection through other
means and relies to a lesser extent on flame retardants (SWEREA 2010).
In this region, only producers manufacturing EPS and XPS for export,
like in Norway, will be affected by a ban on HBCD.

Consequences for the elimination of HBCD through legislation will
influence markets with a substantial production and use of HBCD flame
retarded EPS insulation boards (Europe), but to a lesser extent markets
that are less dependent on HBCD due to use of other processes of EPS
manufacture using other brominated flame retardants (the US). As there
are currently no known chemical alternatives for XPS, HBCD elimination
will affect production of flame retarded XPS in all regions, unless a
suitable alternative can be phased in in a timely manner. The ongoing
initiatives in the polystyrene foam sector to find alternatives for use
of HBCD (North America and Europe) are accomplished by sharing the costs
and investments in voluntary projects between the flame retardant
producers and the polystyrene foam manufacturers (HBCD Industry working
group 2009). For regions where HBCD is largely phased out (Scandinavia)
the cost will be low. Conclusively, the cost implications for producers
are considered to be low to moderate, and a switch to other flame
retardants will stimulate some producers (KLIF 2010). 

 the range of 1-10 million €/year if HBCD is replaced with other
brominated flame retardants and 5-25 million €/year if the HIPS/HBCD
is replaced by copolymers with non-halogenated flame retardants. The
costs may decrease over the years as a result of a larger market for the
alternatives (DEPA 2010).

In controlled burning of waste, the control measures and application of
BAT/BEP to address other by-products from incineration reduce by-product
emissions of HBCD and brominated dioxins and furans. There are no extra
costs involved for the industry.

Flame-retardants that are either more expensive per kg or require more
flame retardant per unit polymer mass (or volume) to meet the fire
safety standards will increase the raw material costs. Large differences
between flame retardant chemicals’ prices do not necessarily have any
impact on relatively expensive end products (SWEREA 2010). When used as
an additive in PS foams, HBCD total content by weight varies between
0.5% (EPS) and 2.0% (XPS) (XPSA/CPIA 2011, CEFIC 2011). 

In several countries in the EU the fire safety requirements are
performance based. HBCD or any other flame retardant are not required to
fulfil the fire safety regulations, but if non-flame retarded EPS/XPS
boards are used the fire-safety requirements call for structural
applications where the fire-safety is achieved with non-combustible
barrier material. In some countries lining of walls and roofs needs
flame retarded polystyrene foam if used. Usually other insulation
materials are used for this purpose. In a few European countries only
special applications require polystyrene foam to be treated with a high
performance flame retardant. In other countries retarded EPS and XPS is
used due to storage and insurance reasons and not due to the fire safety
regulations. Several countries have stringent fire safety requirements
on the insulation boards themselves used in buildings and constructions
and in those countries EPS and XPS have to be treated with a flame
retardant such as HBCD.  

For several countries the use of EPS and XPS without flame retardants
will require an adjustment of policies and a change in the way of
implementation of fire safety standards. This will take time, and costs
are considered to be moderate. In the EU there are already initiatives
to harmonize the fire safety regulation standards, and HBCD is on the
indicative list of hazardous substances that should be avoided for use
for fire protection in buildings and constructions. This would also be
an important drive to change the fire regulations, from classifying the
building materials as components of the construction elements, to
classifying the construction elements themselves. (KLIF 2010).

2.5.	Other considerations

For more information about industry innovations regarding HBCD
alternatives please see the following websites:

  HYPERLINK
"http://chemtura.investorhq.businesswire.com/press-release/company-news/
chemtura-corporation-first-sign-license-agreement-dow-chemical-company-p
o" 
http://chemtura.investorhq.businesswire.com/press-release/company-news/c
hemtura-corporation-first-sign-license-agreement-dow-chemical-company-po
 

The industry voluntary actions to reduce emissions of HBCD in Europe are
described at:

 HYPERLINK
"http://www.bsef.com/our-substances/hbcd/voluntary-emissions-reduction-p
rogramme-vecap-and-secure"
http://www.bsef.com/our-substances/hbcd/voluntary-emissions-reduction-pr
ogramme-vecap-and-secure  

 HYPERLINK "http://www.vecap.info/" http://www.vecap.info/  

More information about product redesign and fire safety is available at:
 HYPERLINK "http://www.sp.se/en/index/services/greenflame"
www.sp.se/en/index/services/greenflame . The Green Flame( is a voluntary
system for simultaneously assessing products, in relation to environment
and health quality, when involved in fires. It is open for all kinds of
different products and will create incentives for manufacturers who
design products that perform better than the standards applicable to
them. The intention is that the Green Flame( system will provide
competitive advantages to the companies that possess the competence and
determination to develop consumer products that represent a major
improvement in fire safety and environmental quality. 

HBCD monitoring information is available from Europe, North America and
Asia. To follow the effectiveness of the potential actions, HBCD should
be added to the existing POP monitoring activities.

3.	Synthesis of information

3.1 Summary of risk profile information

% γ-HBCD and 3-30 % of α- and β-HBCD. HBCD is used as a flame
retardant additive in polystyrene and textile products. Its main use is
in the production of expanded and extruded polystyrene (EPS and XPS). It
is also used in the production of high impact polystyrene (HIPS) and as
a textile coating. HBCD is reported to be produced in the United States
of America, Europe, and Asia. Approximately half of the market volume is
used in Europe. 

In biota, HBCD has been found to bioconcentrate, bioaccumulate and to
biomagnify at higher trophic levels. High concentrations have been
identified in Europe and Japan and in coastal waters of south China,
near production sites of HBCD, manufacturing sites of products
containing HBCD and waste disposal sites including those whose processes
include either recycling, landfilling or incineration. 

HBCD is persistent in the air and is subject to long-range transport.
HBCD is found to be widespread in remote regions such as the Arctic,
where concentrations in the atmosphere and top predators are elevated.

HBCD is very toxic to aquatic organisms. In mammals, studies have shown
reproductive, developmental and behavioural effects. Recent advances in
the knowledge of HBCD-induced toxicity includes a better understanding
of the potential of HBCD to interfere with the
hypothalamic-pituitary-thyroid (HPT) axis, its potential ability to
disrupt normal development, and to affect the central nervous system. 

In humans HBCD is found in blood, plasma and adipose tissue. Human
breast milk data from the 1970s to 2000 show that HBCD levels have
increased since HBCD was commercially introduced as a brominated flame
retardant in the 1980s. 

3.2 Summary of risk management evaluation information

HBCD is produced in China, Europe, Japan, and the USA. The known current
annual production is approximately 23,000 tonnes per year (9,000 to
10,000 tonnes in China, 13,426 tonnes by the BSEF companies in Europe
and the US, Japan not known). The main share of the market volume is
used in Europe. HBCD has been on the world market since the 1960s. It is
used as a flame retardant additive, with the intent of delaying ignition
and slowing subsequent fire growth during the service life of vehicles,
buildings or articles, as well as while materials are stored. The main
uses of HBCD globally are in flame-retarded expanded (EPS) and extruded
(XPS) polystyrene foam insulation, while the use in textile applications
and electric and electronic appliances (HIPS) is of a smaller scale. The
use of HBCD in insulation boards started in the 1980s. In textiles HBCD
is used in back-coating used for upholstery furniture and other interior
textiles, including automotive applications.

A number of alternative fire retardants are available to replace HBCD in
HIPS and textile back-coating. However, there are no drop-in chemical
alternatives for certain flame-retarded EPS/XPS production. In some
countries there is a need for flame retarded insulation materials due to
the country-specific fire safety requirements. In some countries HBCD
has effectively already been phased out. In those countries the fire
safety regulations do not require treatment with a flame retardant, and
the same level of fire safety is achieved by other alternatives, that
are technically feasible and also commercially available. HBCD phase-out
could include flame retardant substitution, resin/material substitution
and product redesign. Emissions of HBCD can be reduced in the processes
where HBCD or articles containing HBCD are used, and during the waste
management phase.

HBCD may be released to air, water, soil and sediment during all stages
of its life cycle; production and manufacturing, processing,
transportation, use, handling, storage or containment, point-source
discharges, migratory releases from manufactured product usage and from
disposal of the substance or products containing the substance. European
producers and manufacturers have successfully taken measures to reduce
emissions from production and first line use. Emission control
techniques at the production sites will not prevent HBCD emissions,
since there are diffuse emissions and releases to the water reserves and
sewage systems from products containing HBCD during use or upon becoming
waste. 

HBCD is an intentionally produced industrial chemical. Under the
Convention, the most adequate control measure is listing in Annex A. To
allow for certain time-limited critical uses of HBCD, a specific
exemption for use of HBCD could be given together with a description of
the conditions for production and these uses. Wastes containing HBCD are
a concern because they will represent a large source of releases and
because increasing amounts of HBCD-containing wastes in landfills and
other locations could be a long-term source of HBCD emissions. Wastes
containing HBCD include production wastes, insulation boards, building
and renovation wastes, and from other less-commonly used applications
such as electrical and electronic products and textiles. The process of
remodelling and demolition of buildings leads to concerns that installed
building materials containing HBCD will continue emissions in the
future, unless properly managed by future generations. Stockpiles and
waste containing HBCD would be subject to the provisions in Article 6.

3.3 Suggested risk management measures

Listing HBCD in Annex A of the Convention would prohibit the
manufacture, use, import and export of HBCD (except as allowed under the
Convention for environmentally sound disposal) and could be linked with
specific exemptions that specify deadlines for the eventual elimination
of remaining HBCD manufacturing and use. Such listing could also be
coupled to other decisions that would describe in more detail such uses
of HBCD and appropriate conditions for their manufacturing and use. When
assessing whether specific exemptions would be appropriate, among other
considerations identified in Annex F to the Convention, factors such as
exposure; production volume; and societal costs and the ubiquitous
contamination of humans, the environment and possible impact on future
generations should be considered.

The suggested control measure is that HBCD be listed in Annex A, with or
without specific exemptions, and if with exemptions accompanied with
detailed conditions for HBCD uses.

Listing of HBCD in Annex A would be consistent with the POPs properties
of this intentionally produced substance. Such a listing would send a
clear signal that production and use of HBCD must be phased out. Such a
listing may have implications for countries in light of ongoing uses
where alternative substances or alternative methods need to be phased
in. Stockpiles and waste containing HBCD would be subject to the
provisions in Article 6.

4.	Concluding statement

Having decided that hexabromocyclododecane (HBCD) is likely, as a result
of long-range environmental transport, to lead to significant adverse
effects on human health and/or the environment such that global action
is warranted;

Having prepared a risk management evaluation and considered the
management options;

The Persistent Organic Pollutants Review Committee recommends, in
accordance with paragraph 9 of Article 8 of the Convention, the
Conference of the Parties to the Stockholm Convention to consider
listing and specifying the related control measures of
hexabromocyclododecane and 1,2,5,6,9,10 -hexabromocyclododecane in Annex
A as described above. 



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0 D, Hanson S, Birnbaum L (2010) Halogenated flame retardants: Do the
fire safety benefits justify the risks? Reviews on Environ Health 25:261
- 305

[SWEREA] Exploration of management options for HBCDD. Report. Authors:
Posner S, Roos S, Olsson E. 2010. 84 pp.

Tue, N. M., Sudaryanto, A., Tu, B. M., Isobe, T., Takahashi, S., Pham H.
V. & Tanabe, S. 2010. Accumulation of polychlorinated biphenyls and
brominated flame retardants in breast milk from women living in
Vietnamese e-waste recycling sites. Science of The Total Environment,
408, 2155-2162.

(US EPA( US Environmental Protection Agency. Initial Risk-Based
Prioritization of High Production Volume Chemicals. Chemical/Category:
Hexabromocyclododecane (HBCD). Risk-Based Prioritization Document
3/18/2008

Weil E.D., Levchik, S.V. 2008. Flame Retardants in Commercial Use or
Development for Textiles. Journal of Fire Sciences May 2008 vol. 26 no.
3 243-281

Weber R, Kuch B. 2003. Relevance of BFRs and thermal conditions on the
formation pathways of brominated and brominated-chlorinated
dibenzodioxins and dibenzofurans.  Environment International 29: 699
-710.

Zhang, X. L., Yang, F. X., Luo, C. H., Wen, S., Zhang, X. & Xu, Y. 2009.
Bioaccumulative characteristics of hexabromocyclododecanes in freshwater
species from an electronic waste recycling area in China. Chemosphere,
76, 1572-1578.

 0.5-0.7 % HBCD w/w

 0.8-2% HBCD w/w

 10-15% HBCD w/w

 1-7 % HBCD w/w

 PPE/HIPS: alloy of polyphenylene ether and high impact polystyrene

 Economical viability has been questioned (BSEF 2011).

Persistent Organic Pollutants Review Committee

Persistent Organic Pollutants Review Committee

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