Green Science Policy Symposium

Organohalogens in Consumer Products: How Science Can Impact Policy;

Madrid 31.08.2014

End-of-life Considerations for Consumer Products

Containing Flame Retardants

Roland Weber
POPs Environmental Consulting,
D-73527 Schwbisch Gmnd, Germany

Content of Presentation

Some end of life considerations on FR polymers/materials in

industrial countries.
Contribution from industry ?
Situation of end of life FR polymers in developing countries.
Listed BFRs in the Stockholm Convention as a chance for
managing FR containing materials in end of life.

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 What to do with Halogenated Flame Retardants
(HFRs) in articles and recycling?
Society need to move to circular economy. Regulation in EU and
China on recycling quota. Mac Arthur Foundation: Circular Economy.
Basel Convention recent paradigm shift: from waste to resources.
Stockholm Convention COP4 decision: The listing of PBDEs includes
exemptions allowing for recycling and the use in articles of recycled
materials containing POP-PBDEs.
Situation end of life HFR containing material flows (WEEE plastic;
PUR foam; insulation; textile)? Recycling challenge (risk cycle)?.

Material flow c-OctaBDE containing articles

Alcock et al. 2003 (with modifications)

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 PBDE/BFR Contamination of Recycled Plastic?
What is the flow of PBDE/BFR in recycled materials? What articles
are contaminated? Risks to human & environment?
Swiss monitoring showed that not much WEEE plastic is recycled
back to EEE today (Bantelmann et al. 2010) likely because of RoHS.
Higher share recycled WEEE plastic in older EEE (Sindiku et al. 2014)

PBDE/BFRs in video tapes PBDE in children toys China Coffee Cup Lids (Samsonek
(5/5) (Hirai et al, BFR 2007.) (Chen et al, ES&T 43, 4200, 2009) & Puype, FAC, 2013)

The recycling flow of PBDE/BFR containing plastic seems largely

uncontrolled. Need to control recycling of FR containing articles to
protect consumers/human health!

Industrial country situation FR-Polymers

The European WEEE directive require that bromine containing plastic
is separated and managed.
Technologies are developed. However only some facilities in EU can
separate BFR plastic. Only Switzerland has sufficient capacity to
separate their WEEE plastic. Cost !? Following management ?!!
The overall WEEE plastic flow even in the EU is unclear (attempt of
MFA/SFA for Vienna had challenges Vyzinkarova & Brunner J IndEcol 2013).
Part of WEEE plastic thermally destroyed. However cost of destruction.
Cheapest solution: Companies export mixed WEEE plastic from
Europe (in addition to the export of WEEE).
Currently even for industrial countries with regulation in place the
WEEE plastic is only partly appropriately managed (for other materials
not regulated or other regions with less regulations less management).

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 Contribution from FR/plastic/EEE industry
EU FR industry had the aim to recover 70%
of bromine by 2004. Until today only pilots.
For Ecolable for printer & copy machines
the EU joint research center suggested to
have a requirement of 10% recycled
plastic. This was rejected by all EEE
producers. Only Xerox mentioned that they
could comply with 5% recycling quota.
One challenge is BFRs and compliance
This would close the bromine loop, ensuring the
with RoHS directive 0.1% PBDE. sustainability of bromine production.
Second challenge is the mix of plastic
types from WEEE which can not be
recycled back to high quality products
like TVs. But to toys or coffee cup lids.
Industries (FRs; plastic; EEE) need to take
more responsibility EPR needed!
Voluntary emission control (VECAP) for BFR
production and users. Now plan for EoL.
(Goosens et al. Dioxin 2014)
Industry input for E-waste StEP initiative. BSEF (2000). An introduction to BFRs BSEF 19 October 2000.

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 WEEE in Africa: Reuse, Refurbishment
and Recovery of Materials

Global comparison of PBDEs in human milk

PBDEs in human milk:
Comparison with some other regions/countries

BDE-47 BDE-99 BDE-100 BDE-153

80
PBDEs (pg/g lipid wt)

70 E-waste recycling site: Taizhou

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Control site: Linan city, Hangzhou
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Tsydenova, Tanabe et al., Env. Poll. 2006 Region/country

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 Material flow and stocks of WEEE plastic in
Nigeria in major WEEE categories(2000 - 2010)
Flows for 2000 to 2010 and for the stocks (in use & landfill/dump) for 2010

( )
Open burning/

Source: Babayemi et al. 2014; Env Sci Pollut Res. DOI: 10.1007/s11356-014-3228-6

Substance flow/stocks PBDE of WEEE plastic

Nigeria in major WEEE categories(2000 - 2010)
Flows for 2000 to 2010 and for the stocks (in use & landfill/dump) for 2010

Open burning/

Source: Babayemi et al. 2014; Env Sci Pollut Res. DOI: 10.1007/s11356-014-3228-6

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 Considerations: End of life HFR materials in
developing countries: open burning & dumping
Open burning: A large share of HFR materials are burned in the
open with associated releases and pollution.
Landfilling/dumping: FRs are partly released from landfill.
Developing countries do not have an appropriate destruction and
waste management.
Thermal destruction/recovery: flame retarded materials have
challenges in thermal destruction:
Release of HBr and elemental bromine (challenge even for cement)
Corrosion of facilities
Formation of brominated and brominated-chlorinated PXDD/PXDF
This situation requires industry & international efforts for control
and management of these material flows in developing countries
(HFR in WEEE; EoL vehicles; construction, furniture/textiles).
Science community: more comprehensive documentation.

Considerations: End of life HFR materials in

developing/transition countries: Recycling
Recycling: Still no control of recycling of FRs into a range of (partly
sensitive) material streams. More systematic assessment of
research community on the extent of affected materials needed.
Currently no regulation exist for PBDE or other BFR limit except the
RoHS limits for EEE so no legal reason not to recycle and export.
Standards needed for measuring BFRs in articles and products.
China: Separation of BFR plastic is in place in some facilities (e.g.
MBA polymers suggestion to recycle BFR plastic in e.g. shoe
soles). Basel Convention Center Beijing project on WEEE.
India (EMPA): WEEE plastic largely in informal sector. BFR plastic
normally not separated. In the case that BFR plastic was separated
this was for recycling for a company requiring FR plastic.
Nigeria; Currently approximately 20 polymer recycling facilities are
planned not clear what plastic is recycled and to what is recycled.

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 Material flow of Flame retarded PUR

?
Alcock et al. 2003 (with modifications)

Assessment of Possible Health and Environmental Impact:

Recycling of Polyurethane Foam & Human Exposure (US)
POP-PBDE levels in workers recycling Polyurethane Foam (US)
PBDE in serum lipid (ng/g)

PUR Foam Carpet Control

recyclers installers (Spouse)
Source: Stapleton et al. ES&T 42, 3453 (2008)

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 Some Considerations on PUR Foam
FRs (BFR & CFR) in PUR foam lead to exposure during use phase,
recycling and from recycled products.
Not clear how much PUR foam is impacted globally since only a few
countries have flammability standard e.g. for furniture.
Most of PUR foam is not recycled. If - then largely downcycling.
My experience: PUR foam is partly gathered by scavengers on
landfills recycling/recovery to which products?
Need global assess & management of PUF.

Listing of POP-BFRs in the Stockholm Convention

The Conference of Parties (COP) to the Stockholm Convention
decided to list the first BFRs as POPs in 2009 to 2013.
Chance to improve global management of FR products/wastes ! (?)
Industrial Unintentional
Chemical Pesticides Annex
chemicals production
Chlordecone + A
Lindane + A
Alpha hexachlorocyclohexane + By-product of lindane A
Beta hexachlorocyclohexane + By-product of lindane A
Endosulfan + A
C-PentaBDE + A
Certain congeners c-OctaBDE + A
Hexabromobiphenyl + A
Hexabromocyclohexane + A
Perfluorooctane sulfonic acid B
+ +
(PFOS), its salts and PFOSF

Pentachlorobenzene + + A/C

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 Guidance for the inventory of PBDEs listed under
the Stockholm Convention
The listing of PBDEs, HBB and HBCD in the Stockholm Convention
can be used for global inventories of major FR material streams.
POPs inventories are used for action plan development and priority
setting for the National Implementation Plans for the SC.

Appropriate policy and regulations are

needed then and can be developed in this
frame for the management of FR containing
material flows.

http://chm.pops.int/Implementation/NIPs/Guidance/tabid/2882/Default.aspx

PBDE inventory guidance addressing

several BFR waste categories
Inventory Guidance for POP-PBDEs (Section) 1)

Former POP-PBDE production and uses (Section 2)

Inventory Steps for POP-PBDEs (Section 3)

Inventory of POP-PBDEs (Sections 4-7)

Electronics (Section 4) Transportation & end-of-life Other uses (Section 6)

vehicles (Section 5)

In use Recycle Waste Furniture Textiles Construction materials

Contaminated sites (Section 7)

Inventory report

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 HBCD relevant for other material flows
HBCD is listed in Stockholm Convention. Become effective 26.11.2014.
Large volume of HBCD treated polystyrene (XPS/EPS) were and are
used in insulation of buildings. SC exemption for HBCD use in XPS/EPS
in construction. If HBCD is used in XPS/EPS then labelling is needed.
The recycling of HBCD containing materials is not exempted in the
Stockholm Convention. What are recycling activities of XPS/EPS
(China) and how can HBCD be controlled in XPS/EPS (sensitive use in
food packaging; frozen fish boxes etc). Relevance for textile recycling?
Destruction of EPS/XPS challenge (logistic & bromine)
Interesting for science community to support assessment
& global management of HBCD in the frame of the SC.

Guidance on BAT/BEP for recycling & disposal of

PBDE/BFR containing materials/articles
The allowance of reuse and recycling of
articles containing POP-PBDEs results in
the need to define Best Available
Technology (BAT) and Best
Environmental Practices (BEP) to carry
out the recycling and the final disposal in
an environmentally sound manner (ESM).
Guidance (Draft) was developed
considering the recommendations made
by COP5 for the management of POP-
PBDE containing materials.
The guidance can be used to manage
other BFR containing articles. Can be
updated when new technologies emerge.

http://chm.pops.int/Implementation/NIPs/Guidance/tabid/2882/Default.aspx

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 Material flow of POP-PBDE-containing goods & Structure of BAT/BEP Guidance
Production

Production c-PentaBDE (stopped) Production c-OctaBDE (stopped)

Minor uses: Textile, Flexible PUR foam HIPS ABS Other polymers
Disposal Recovery Recycling Use & Re-use

PWB, rubber, construction

Mattresses Furniture Transport sector Electrical & Electronic Equipment (EEE)

Generic BAT/BEP (3.5)

PBDE screening technologies (3.6)

Management PUR foam (6) Management transport sector (5) Management EEE/WEEE & Plastic* (4)

Energy/material recovery (7)

Incineration (7.2) Cement (7.2) Melting (7.4) Pyrolysis (7.5) Metal industry (7.6)

Recovery of bromine** (annex E)

Disposal in landfill (8 and annex D)

The size of the arrow indicate major use or major flows of POP-PBDEs or POP-PBDE-containing materials.
Dashed arrows indicate non-preferred routes
**POP-PBDE separation is not available yet in full scale
Reuse of Articles (e.g. cars, electronics, furniture) . *Bromine recovery is not operated in full scale yet.

http://chm.pops.int/Implementation/NIPs/Guidance/tabid/2882/Default.aspx

Chance: Inventory & policy & management of

HFR containing materials in the life cycle
With the inventory development of POP-BFRs along the material flow, countries will
start to visualize/monitor the material flows containing FRs.
Based on these assessments, policy/management instrument to control these material
flows can be developed to control life cycle of FRs/PBTs in products and end-of-life.
Chance for the industry (HFR & polymer) for real extended producer responsibility? !
PARTY/
Production and use phase COUNTRY Waste Management

Trade & Sales Export

Import
Production End-of-Life Articles/Stockpiles
- chemicals
- products
- articles
Use
Thermal
Recycling Landfill.
treatments
Re-use

Multiple Sources Biosolids/sewage sludge Multiple Sources

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 (Part of) Solution: Shift to more benign chemicals,
materials and products by substitution approach
The challenges in end of life with HFR products request solutions.
Substitution considering sustainable production might be 1st choice !
The SC POP reviewing committee has developed documents on
alternatives to POPs including alternatives to listed BFRs. Currently a
publication is developed compiling information on alternatives to
current POPs in articles including tools helping to make informed
decissions on sustainable substitution. (Monday we have session on
Sustainable production and use (10.45-12.45 Dublon) and further
discussion e.g. on the role of stakeholders (13.45-15.25 Escudo).
Policy makers to establish the regulatory frames (science advice).
We should give our support as scientists (and for consumers) to the
most sustainable chemicals (Green/Sustainable Chemistry) and
sustainable products (Benign by Design) on the market.
This is a sustainable business field - chance for innovative industries!

Thank
Thank you
you for
for your
your attention!
attention!

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