In a press release dated July 30, EPA says it has identified 33 substitutes to the flame retardant decabromodiphenyl ether (decaBDE), which will be phased out of production by December 2013. Despite the headline, however, EPA does not say that any of them are unambiguously safer than decaBDE. Thus, manufacturers that currently use decaBDE cannot simply switch to one of these substitutes.
For each chemical, EPA’s report (PDF) provides a “screening level hazard summary” for 16 different adverse effects divided into the following categories, the boundaries of which are not defined which except in a handful of cases:
- VL = Very Low hazard
- L = Low hazard
- M = Moderate hazard
- H = High hazard
- VH = Very High hazard
Still, no substitutes are identified as dominant even at the qualitative level of EPA’s worst-case classification system. That is, even if performance and cost are ignored, there is no chemical that EPA concludes is a superior substitute. Ultimately, manufacturers must make complicated and risky tradeoffs across multiple dimensions. The practical value of the report is thus limited, except insofar as it highlights potential substitutes that EPA is not going to like (e.g., substitutes that it ranks as High or Very High hazards).
None of these tradeoffs were taken into account by EPA when it negotiated the impending ban on decaBDE.
The alternatives listed alphabetically in the draft report are:
- Aluminum Diethylphosphinate
- Aluminum Hydroxide
- Ammonium Polyphosphate
- Antimony Trioxide
- Bis(hexachlorocyclopentadieno) Cyclooctane
- Bisphenol A Bis-(diphenyl phosphate), BAPP
- Brominated Epoxy Resin End-Capped with Tribromophenol
- Brominated Polyacrylate
- Brominated Polystyrene
- Confidential Brominated Epoxy Polymer #1
- Confidential Brominated Epoxy Polymer #2
- Confidential Brominated Epoxy Polymer Mixture #1
- Confidential Brominated Epoxy Polymer Mixture #2
- Confidential Brominated Polymer
- Decabromodiphenyl Ethane
- Decabromodiphenyl Ether
- Ethylene Bis-Tetrabromophthalimide (EBTBP)
- \Magnesium Hydroxide
- 4-329 Melamine Cyanurate
- Melamine Polyphosphate
- N-alkoxy Hindered Amine Reaction Products
- Phosphonate Oligomer
- 4-452 Polyphosphonate
- Red Phosphorus
- Resorcinol Bis-Diphenylphosphate
- Substituted Amine Phosphate Mixture
- Tetrabromobisphenol A Bis (2,3-dibromopropyl) Ether
- TBBPA Glycidyl Ether, TBBPA Polymer
- Triphenyl Phosphate
- Tris(tribromoneopentyl) Phosphate
- Tris(tribromophenoxy) Triazine
- Zinc Borate
- Human Health
- Acute toxicity
- Repeated Dose
- Skin Sensitization
- Respiratory Sensitization
- Eye Irritation
- Dermal Irritation
- Endocrine Activity [narrative]
- Aquatic Toxicity
- Environmental Fate
AN ALTERNATIVES ASSESSMENT FOR THE FLAME RETARDANT DECABROMODIPHENYL ETHER (DecaBDE)
DRAFT FOR PUBLIC COMMENT
U.S. EPA DESIGN FOR THE ENVIRONMENT PROGRAM
6.4 Performance Considerations
The [Design for the Environment] DfE approach allows companies to examine hazard profiles of potential replacement chemicals so they can consider the human health and environmental attributes of a chemical in addition to cost and performance considerations. This is intended to allow companies to develop marketable products that meet performance requirements while reducing hazard. This section identifies some of the performance attributes that companies should consider when formulating or selecting a flame retardant, in addition to health and environmental consideration. Performance attributes are critical to the overall function and marketability of flame retardants and should be considered along with other factors. Chapter 2 includes a detailed discussion of the categories of materials, sectors, and products relevant to the chemicals in this assessment, along with a discussion of relevant flammability standards.
The ability of a product to meet required flammability standards is an essential performance consideration for all flame retardant chemicals. The fire safety requirements influence the amount and type of flame retardant, if any, that needs to be added to a resin. Formulations are optimized for cost and performance, so that in some instances it may be equally viable to use a small quantity of an expensive, highly efficient flame retardant or a larger quantity of a less expensive, less efficient chemical.
In addition to flame retardancy properties, the flame-retarded product must meet all required specifications and product standards (e.g., rigidity, compression strength, weight). The polymer/fire retardant combination used in many of the products which contain decaBDE may be complex chemical formulations. In some instances, replacements exist which could allow for relatively easy substitution of the flame retardant. However, a true “drop-in” exchange of flame retardants is rare; some adjustment of the overall formulation, product re-design, or use of inherently flame retardant (IFR) materials is usually required. An alternative with similar physical and chemical properties such that existing storage and transfer equipment as well as flame retardant manufacturing technologies could be used without significant modifications. Unfortunately, chemicals that are closer to being “drop-in” substitutes generally have similar physical and chemical properties, and therefore are likely to have similar hazard and exposure profiles.
Those seeking alternatives to decaBDE should work with flame retardant manufacturers and/or chemical engineers to develop the appropriate flame retardant formulation for their products.
This section identifies economic attributes that companies often consider when formulating or selecting a flame retardant. Economic factors are best addressed by decision-makers within the context of their organization. Accurate cost estimations must be company-specific; the impact of substituting chemicals on complex product formulations can only be analyzed in-house; and a company must determine for itself how changes will impact market share or other business factors. Cost considerations may be relevant at different points in the chemical and/or product lifecycle. These attributes are critical to the overall function and marketability of flame retardants and flame retarded products and should be considered jointly with performance attributes, social considerations, and human health and environmental attributes.
Substituting chemicals can involve significant costs, as industries must adapt their production processes, and have products re-tested for all required performance and product standards. Decision-makers are advised to see informed chemical substitution decisions as long-term investments, and to replace the use of decaBDE with a chemical they anticipate using for many years to come. This includes attention to potential future regulatory actions motivated by adverse human health and environmental impacts, as well as market trends. One goal is to choose from among the least hazardous options to avoid being faced with the requirement to substitute again.
Flame retardants that are either more expensive per pound or require more flame retardant per unit area to meet the fire safety standards will increase raw material costs. In this situation, a product manufacturer substituting away from decaBDE may pass the cost of a more expensive flame retardant on to customers (e.g., a television manufacturer), who subsequently may pass the cost on to retailers and consumers. In some cases the price premium significantly diminishes over the different stages of the value chain. However, market conditions, competing technologies, and intellectual property issues may influence flame retardant selection when replacing decaBDE.
Handling, disposal, and treatment costs, as well as options for mechanical recycling, may be important considerations when evaluating alternatives. Inherently high hazard chemicals may require special engineering controls and worker protections that are not required of less hazardous alternatives. Disposal costs for high hazard chemicals may also be much higher than for low hazard alternatives. High hazard chemicals may be more likely to result in unanticipated and costly clean-up requirements or enforcement actions should risk management protections fail or unanticipated exposures or spills occur. Also, some chemicals may require specific treatment technologies prior to discharge through wastewater treatment systems. These costs can be balanced against potentially higher costs for the purchase of the alternative chemical. Finally, initial chemical substitution expenses may reduce future costs of mitigating consumer concerns and perceptions related to hazardous chemicals.
It should be noted that, while some assessed alternative chemicals included in this report are currently manufactured in high volume, not all are currently available in quantities that would allow their widespread use immediately. However, prices and availability may change if demand increases.
EPA Identifies Substitutes for Toxic Flame Retardant Chemical
WASHINGTON – In its quest to identify possible substitutes for a toxic flame retardant chemical known as decabromodiphenyl ether (decaBDE), the U.S. Environmental Protection Agency (EPA) has released a draft report on alternatives. This comprehensive assessment, developed with public participation under EPA’s Design for the Environment (DfE) program, profiles the environmental and human health hazards on 30 alternatives to decaBDE, which will be phased out of production by December 2013.
DecaBDE is a common flame retardant used in electronics, vehicles, and building materials. It can cause adverse developmental effects, can persist in the environment and can bioaccumulate in people and animals. This technical assessment can help manufacturers identify alternatives to decaBDE. In addition, EPA will continue to work with manufacturers to investigate both chemical and non-chemical alternatives for flame retardants.
“EPA is using all of its tools to reduce the use of hazardous flame retardant chemicals like decaBDE and identify safer, functional substitutes to protect people’s health and the environment,” said Jim Jones, acting assistant administrator for EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP). “Virtually everyone agrees that EPA needs updated authority under the Toxic Substances Control Act (TSCA) to more effectively assess and regulate potentially harmful chemicals like flame retardants. As EPA continues to stress the need for comprehensive legislative reform to TSCA, we are also targeting actions on a broader group of flame retardants to reduce human and environmental risks.”
Today’s draft report is the latest in a series of actions the agency is taking to address flame retardants made with bromine. Other actions include:
- On June 1, 2012, EPA released a TSCA work plan of 18 chemicals which the agency intends to review and use to develop risk assessments in 2013 and 2014, including three flame retardant chemicals. EPA is currently developing a strategy, scheduled for completion by the end of this year that will address these three and a broader set of flame retardant chemicals. This effort will aid the agency in focusing risk assessments on those flame retardant chemicals that pose the greatest potential concerns. EPA anticipates initiating the risk assessments on this category of chemicals in 2013.
- On April 2, 2012, EPA proposed actions under TSCA that will require manufacturers, importers, and processors of polybrominated diphenyl ether (PBDE) flame retardants to submit information to the agency for review before initiating any new uses of PBDEs after Dec 31, 2013. Those who continue to manufacture, import, or process after December 31, 2013, would be subject to a testing requirement under TSCA. EPA is accepting comments on this proposal until July 31, 2012.
- In 2009, EPA developed action plans on PBDEs (including pentaBDE, octaBDE, and decaBDE) and hexabromocyclododecane (HBCD) that summarized available hazard, exposure and use information; outlined potential risks; and identified the specific steps the agency is pursuing under the TSCA. The alternatives analysis for decaBDE was included in the action plan.
The alternatives to decaBDE characterized in the report are already on the market and will be used increasingly as decaBDE is phased out. The alternatives have differing hazard characteristics and are associated with trade-offs. For example, some alternatives that appear to have a relatively positive human health profile may be more persistent in the environment. Some alternatives appear to be less toxic than decaBDE. Preliminary data suggests that these flame retardants may have a lower potential for bioaccumulation in people and the environment. It is important to understand that these health and environmental profiles are largely based on computer-model generated estimates, and that the models are limited in their ability to predict concern. Laboratory testing and ongoing environmental monitoring is necessary to fully understand the potential for concern associated with these chemicals.
EPA’s Design for the Environment Alternatives Assessment Program helps industries choose safer chemicals and offers a basis for informed decision-making by providing a detailed comparison of the potential public health and environmental impacts of chemical alternatives. Throughout the partnership, stakeholders, including chemical suppliers, product manufacturers, and non-government organizations have provided valuable information to support the development of these draft reports. EPA is seeking stakeholder and public input on this draft report for 60 days.
More information on the DfE Alternatives Assessment Program and the draft report: http://www.epa.gov/dfe
More information on other actions on brominated flame retardants: