Submission of Information on ALTERNATIVES (NON-CONFIDENTIAL)
Submission of information on
Template
for third party submission of information on alternatives for
Applications for Authorisation
non-confidential
Legal name of submitter(s): Finnish Environment Institute
Table of CONTENTS
1. alternative ID and properties 3
2. Technical feasibility 3
3. Economic feasibility 3
4. Hazards and risks of the alternative 3
5. Availability 3
6. Conclusion on suitability and availability of the Alternative 3
7. other comments 3
References 3
APPENDIXES 3
1. alternative ID and properties
Polymeric flame retardant (Emerald, FR-122P etc)
2. Technical feasibility
Polymeric FR is reported to have essentially equivalent flame retardant efficiency to HBCD
when used at equivalent bromine content. According to Great Lakes Solutions, 1.7% of Emerald 3000 (trade name) is required to pass the EN Class E flammability test. The required load is thus comparable to that of HBCD (0.5-2.5% HBCD w/w) in PS foams. Tetrabromobisphenol A bis(2,3-dibromopropyl ether) (TBBPA-DBPE), CAS No: 21850-44-2 with dicumene for XPS and dicumyl peroxide for EPS as usual synergists (i.e. Starflame/GC SAM) is reported to have 20-30% lower flame retardant properties compared to HBCD.
Source: UNEP/POPS/POPRC.8/16/Add.3 at:
http://chm.pops.int/TheConvention/POPsReviewCommittee/Reports/tabid/2301/Default.aspx
3. Economic feasibility
According to the information collected by the Stockholm Convention POPs Review Committee in 2013, “According to one producer of the Polymeric FR, manufacturing flame retarded products with the alternative to HBCD is not anticipated to have any significant impact on the cost competitiveness of EPS or XPS.”
Source: UNEP/POPS/POPRC.8/16/Add.3 at:
http://chm.pops.int/TheConvention/POPsReviewCommittee/Reports/tabid/2301/Default.aspx
4. Hazards and risks of the alternative
USEPA released its comprehensive assessment of HBCD alternatives in June 2014 http://www.epa.gov/dfe/pubs/projects/hbcd/about.htm
5. Availability
The view expressed in the application dossier concerning the availability of the alternative polymeric flame retardant is outdated.
In April 2014 ICL-IP, who is already producing an alternative to HBCD in commercial quantities in the Netherlands, announced it “is currently completing preparations to start up a 10,000MT production facility in Israel whose commencement is scheduled for the third quarter of 2014”.
http://www.prnewswire.co.uk/news-releases/icl-ip-completing-second-production-facility-for-polymeric-flame-retardant-256176891.html
According to our understanding, based on publicly available information, the production of the polymeric flame retardant should exceed 10000 MT by the end of 2014, clearly before the sunset date set for HBCD. While the amount produced in Europe and Israel may not in August 2015 be sufficient to fully replace HBCD, it could replace most of it. Therefore we also strongly feel the authorization should be as limited as possible to those uses that were exempted in the Stockholm Convention decision, i.e. EPS in buildings, not in building applications as applied.
6. Conclusion on suitability and availability of the Alternative
The new alternatives together with limited authorized HBCD use is buildings would in our opinion ensure sufficient supply of flame retardants for those applications where such a property is needed in different countries.
7. other comments
We would like to note that the information provided in the SEA on regulatory requirements for use of flame retardants is from 6 years old (Troitsch, 2008: The relevance of hexabromocyclododecane for polystyrene EPS/XPS foams to meet fire safety requirements for construction products in Europe). This is very relevant for consideration when HBCD must be replaced with a flame retardant and when one can use alternative materials, including PS foams without flame retardant. The information in Troitsch (2008) is not correctly reflecting the regulatory status in Finland.
According to UNEP HBCD Risk Management Evaluation UNEP/POPS/POPRC.7/19/Add.1 “Flameretarded PS foam may be used in some building applications in Finland, Norway, and Sweden, although it is not required. Sweden and Norway, with a performance approach to the final product in their regulations, use much less brominated flame retardants than countries with more specific fire requirements on a material level (KLIF 2011a). In Sweden and Norway, 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.
Furthermore, the need of a chemical alternative may also be avoided by using alternative building techniques and materials. These have been reviewed by the Stockholm Convention POPs Review Committee briefly (please see the reference UNEP/POPS/POPRC.7/19/Add.1 at http://chm.pops.int/TheConvention/POPsReviewCommittee/Reports/tabid/2301/Default.aspx)
For more information, please see
[KLIF] Climate and pollution agency in Norway (2011). Alternatives to the use of flame retarded EPS in buildings. A report by COWI AS Denmark. Authors: Lasses, C., Maag, J., Hoibye, L., Vesterlykke, M., Lundegaard, T. 97 p.
References
http://www.epa.gov/dfe/pubs/projects/hbcd/about.htm
APPENDIXES
[insert consultation number] [insert non-confidential generic name of the alternative substance/mixture or description of the alternative technology] [insert date of submission]
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