                     Latest Use of Decabromodiphenyl Ether
Domestic Manufacturing Estimates
Based on available information, domestic manufacturing of deca has dropped significantly over the last several years, from approximately 51,000,000 lbs in 2010 to less than 25,000 lbs in 2015.  Imports of deca has increased since the domestic phase out, and ranges from 1,000,000 lbs to several million pounds.  
Import Estimates
With weaknesses in the CDR reporting, the only other source of data is from the U.S. Customs and Border Protection.  These data are not reliable. For example, the database lists the St. Louis Group LLC of importing 4,300,000 lbs, and they have not imported deca since 2013.  The database lists Rockland Industries Inc of importing 3,900,000 lbs, but only used around 500,000 lbs in 2016.   It appears the Customs data base is not accurate on amounts of deca imported, and in some situations, by a million pounds.  
ECB is in the process of contacting all the companies in the database to obtain more accurate estimates.   
Traditional Uses
Deca has been used in textiles, flexible polyurethane foams used in upholstery stuffing for furniture and car seats, electronic components, electrical components, and plastics used in the casings of televisions, personal computers, and other electronic equipment.  
Findings of Outreach to Date:
Auto Alliance
Currently working to phase out deca in production of new cars, and working to determine when and when new production can be phased.  Replacement parts could be a challenge since deca not restricted in Asia.  The Auto Alliance is currently surveying members to better define and understand uses in supply chain.  Might want exemptions for articles for aftermarket parts where alternatives aren't developed.  
Intelligent Global Pooling Systems Company via Larry Culleen
This company manufactures and recycles plastic pallets where the plastic they use contain deca.  They do not use any new deca.  Want to be exempted from any action to regulate use of deca.  Currently separate deca containing plastics from virgin plastic pallets. 
LifePort, Inc, Subsidary of Sikorsky Aircraft Corp. 
Currently use hundreds of pounds annually in the manufacture of skins for military, law enforcement and medical evacuation helicopters.  Claim there is no alternative. 

ACC
Do not have any members or user coalitions that rely on deca.  
Aerospace Industries Association
Industry is working to phase out all uses of deca.  Currently examining supply chain to target any remaining uses.  Expects to have information in December on existing uses.  
Boeing
Not using any deca in production of new planes, either passenger or military applications.  They have some existing parts with deca, and will use those as exhausted.   On track to phase out deca in all manufacturing by 2018, including replacement parts.   
Albemarle
Albemarle described their alternative product, Saytex 8010, which is a non-diphenyl oxide flame retardant. The alternative product has completely substituted for deca in all their markets and applications.  The company was not aware of any critical uses for deca. Albemarle does track the imports of deca, which are arriving from China, and believe that as much as 530 tons were imported in 2016.    
Lanxess
Lanxess phased out all domestic manufacturing in 2013.  Would have preferred EPA finalized the SNUR.  Not tracking import or uses.  Feels there are adequate substitutes for their customers. 
DoD
DoD has a few critical uses, totaling less than 100 lbs a year. 
St Louis Group, LLC
Listed in Customs database as importing over 4,300,000 from 2012-2015.   They have not imported any deca since 2013. 
Rockland Industries
Apexical also associated with Rockland
Uses around 650,000 lbs annually for backspraying of black out draperies used in hospitality industry. 
Apexical
Called and left message.  
3N International Inc
Customs database claims 2,100,000 lbs imported from 2012 to 2015.   No recent requests for chemical, and no existing stock.  
RADCO Industries
Emailed Brian.   No response. 
Alexander Morgan, U of Dayton
Explained past and current uses of deca.   Very knowledgeable and great source of use and chemical properties information.  
Association of Home Appliance Manufacturers
Talked on 11/1.   They will check to see if deca is still used and report back by close of comment period. 
National Electric Manufacturers Association
Reached out on Oct 26, emailed on Nov 1. 
Veliscol Chemical and Resnovae Industries
Left message on Oct 24 and Nov 1.  
3N International
Listed in Customs database as importing 2,100,000 lbs.  Owner stated they don't stock deca, and only obtain for special orders for small use in aerospace.  See email response from Sean Guo dated October 23, 2017.

Additional Outreach Underway:
 Consumer Electronics Association
 AIA, Auto Alliance, and Plastics Industry Association (conducting outreach w members)
 Remaining list of importers
 Alexander Morgan, University of Dayton, call on Tuesday
 Mark Buczek, Independent Consult
 Gary Rex, Huber
 Clariat, Alternatives Manufacturer
 Janan Rabiak
 Bob Beaty, TSG Finishing
Additional Outreach Planned: 
 Medical and Imaging Technology Alliance
 National Electrical Manufacturers Association
 American Apparel and Footwear Association
 Motor and Equipment Manufacturers Association
 GE
 Communications sector, wire? 
 Scrap recyclers
Next Steps to Inform SNUR Options
 Continue outreach to better understand uses and sectors that:  
 No longer use deca. 
 Users that are actively phasing it out within the next year, determine dates for last use.  
 Ongoing use with likely substitutes.
 Critical uses.  
Possible Regulatory Options (Examples for discussion purposes only)
Sector and Use
Possible Approach
Plastic Pallets
SNUR any new use; do not SNUR continued use of recycled plastics that contain trace amounts of deca.  
Electronics
SNUR all uses, except trace amounts in HIPS recycled. 
Fabrics
SNUR all uses except black out curtains for hotels
DoD
Identify critical uses, SNUR all others.  
Flexible or rigid polyurethane foam, all industries. 
SNUR all PUF products.  Not intentionally added since 2005, but sometimes can be found in reused or recycled polyurethane foam from association with fabrics or coatings of materials that come in contact with foam.  Include use in SNUR, but exempt trace levels and impurities in recycled or scrap polyurethane foam. 
 
Furniture
SNUR all uses in foam or padding.  
Plastics
SNUR all uses, except those critical in transportation sector.  Include all plastics, such as polystyrene, polyolefin, polyurethane, etc.  Provide exemption for recycled plastics that contain trace amounts of deca from previous uses.
All apparel and textiles, including fire protective apparel
SNUR all uses
Sleep products for children, including pajamas, mattress pads, bedding, etc
SNUR all uses
Paints and coatings
SNUR all uses
Adhesives, sealants and tapes
SNUR all uses
Wire and cable
SNUR all uses, except those identified as on-going by transportation sector.

Key Challenges:
 Large industry sectors have mostly phased out deca.  Challenge will be to identify remaining uses in niche industries, and develop phase-out timeline.
 Niche uses, within small industries, are likely the vast majority or use.  Niche uses are difficult to discover due to complexity of supply chain, lack of trade association representation, and lack of knowledge regarding Section 6(h).
 Very difficult to impossible to identify deca use in imported articles.
 Very difficult to understand exposure scenarios for niche uses.  Data likely does not exist.  Difficult to use 6(h) if nothing known about exposures. 
 Some existing uses are from recycling, e.g. pallets, plastics in electronics.   Agency needs to develop policy to exempt trace levels produced through recycling, or scrap processes. 
 State laws have also impacted PBDEs, with 12 states passing laws to ban penta and octa, with four states banned deca.  Legislation has been introduced in other states to ban PBDEs.  









 
