Roland Weber 1, Alan Watson 2, Tom Webster 3

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1 Roland Weber 1, Alan Watson 2, Tom Webster 3 1 POPs Environmental Consulting, Göppingen, Germany 2 Public Interest Consultants, Swansea, Wales, UK 3 Boston University School of Public Health, Boston, USA

2 he Idea of presenting the current Stockholm Convention activities on PBDE to the POPs science community is: To make the science community more aware on the challeges and knowledge gaps of the Stockholm Convention implementation in respect to PBDE; Possibly get input from science community; Possibly stimulate some research by highlighting where information/data for the assessment of global PBDE exposure, flow and management is missing.

3 Nine new POPs were added to the Stockholm Convention (26. August 2009): Chlordecone Lindane (Gamma HCH) Alpha HCH Beta HCH Pentachlorobenzene Hexabromobiphenyl Commercial-Pentabromodiphenylether Commercial-Octabromodiphenylether Perfluoroctanoyl sulfates Endosulfane listed at COP5 (April ) POPs Candidates: HBCD, SCCP,

4 Commercial-PentaBDE (TetraBDE and PentaBDE) Commercial-OctaBDE (only HexaBDE and HeptaBDE) Commercial-DecaBDE (and Nona/OctaBDE) are not considered as POP (yet). However the issue of debromination is part of the Stockholm Convention POPs Review Committee discussion and acknowledged at POPRC6 10/2010.

5 The Stockholm Convention requires each Party to take appropriate measures to reduce & eliminate production, use, import and export of POPs. Production PBDE POPs: Production of PeBDE and OctaBDE is thought to have stopped worldwide. Therefore the main challenge is the identification and management of PBDE containing products in use and treatment & recycling of existing wastes.

6 COP4 long discussion on PBDE in products and how to address their wastes in the Convention. Stockholm Convention COP decision at COP4: The listing of PBDEs includes exemptions allowing for recycling and the use in articles of recycled materials containing POPs PBDEs.

7 Decision SC-4/18 included specific exemption for use in articles in accordance with the following provisions: 1. A Party may allow recycling of articles that contain or may contain TeBDE and PeBDE (HxPBDE, HpBDE), and the use and final disposal of articles manufactured from recycled materials that contain or may contain TeBDE and PeBDE, provided that: (a) The recycling and final disposal is carried out in an environmentally sound manner and does not lead to recovery of TeBDE and PeBDE for the purpose of their reuse; (b) The Party does not allow this exemption to lead to the export of articles containing levels/concentrations of TeBDE and PeBDE that exceed those permitted to be sold within the territory of the Party; and (c) The Party has notified the Secretariat of its intention to make use of this exemption. (Decision SC-4/14 has substantially identical provisions in respect of HxBDE and HpBDE.)

8 Emission Sources Chlorine/Bromine/ Fluorine Production (e.g. Chlor-alkali, historical processes) Thermal/Indust. (e.g. waste incineration, cement, metal industry, industrial fires) Environmental Transport Atmosphere Exposure Routes Intergenerational Chlorine/Bromine Use (e.g. pulp & paper, water treatm., TiO 2, Magnesium etc.) Organohalogen Production (e.g. Pesticides, PCBs, PERC, PVC, BFRs, PBDE, PFCs PFOS, PFOA) Reservoirs (e.g. landfills, contaminated sites, stockpiles, soil, sediments) Products (e.g. pesticides, PCB in transformers, BFRs and PFCs in EEE, textiles, carpet, plastic, PVC, etc.) Recycled Products Land Aquatic Plants Animals/ Cattle Fish & Shellfish Inhalation Food ingestion Soil ingestion Drinking water Occupational Accidental Indoor Consumer

9 This exemption generated significant discussion if the recycling which is leading to further release of and exposure to PBDE is consistent with the principal objective of the Stockholm Convention to protect human health and the environment from persistent organic pollutants. PBDE

10 Therefore the POP Reviewing Committee was requested to make recommendations to the Conference Of Parties to address these concerns. These recommendations will be based on information gathered from Parties/Observers by a questionnaire. Additionally the SC Secretariat was gathering relevant information by a consultancy (report). Questionnaire was sent to Convention parties & observers in November Information had to be submitted by 05/2010.

11 Size of problem: types/quantities of articles in use & recycled articles containing PBDEs Extent of recycling Methods to identify presence and level of PBDEs in articles and recycled articles Options for environmentally sound disposal Identification of remediation methods for contaminated sites

12 Questionnaire response from countries: About 40 countries (from 172 parties) responded Countries reported mainly that they were not producing PentaBDE or OctaBDE Several reported former use of PBDEs in products. Former PBDE producing countries have not reported details on former production volumes and use. Only one country reported on measurements of PBDE levels in plastic for recycling (Austria). No information on PBDE in recycled materials No information on remediation of contaminated sites

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14 The information from these survey and the information from scientific literature and others were compiled in a report compiling also relevant information on: Assessment of the possible health and environmental impacts of recycling articles containing PBDEs. Identification of the best available techniques and best environmental practices for the recycling of articles containing PBDE. Review of the long-term environmental desirability of the recycling of articles containing PBDE.

15 For several of the issues mentioned above the research community has already provided valuable inputs over the last two decades. However for several of these topics there is a need for further contribution. We compiled information for POP Reviewing Committee which was forwarded to COP5 (April ) UNEP/POPS/POPRC6.2 UNEP/POPS/POPRC6/INF/6

16 What is the flow of PBDE/BFR in recycled materials? What articles are contaminated? What are risks to human and the environment? BDE/BFRs in video tapes (5/5) Hirai et al, BFR 2007.) PBDE in children toys South Chin (Chen et al, ES&T 43, 4200, 2009 The recycling flow of PBDE/BFR containing plastic seems largely uncontrolled. Hence further allowance of recycling of PBDE containing articles (currently) increases the environmental and health risks in an uncontrolled manner!

17 PBDE/BFR in video tape casings imported to Japan (from China and Korea) had 0.1 to 0.7% BFR (Hirai et al BFR 2007).

18 Screening on contamination levels of PBDE and other critical pollutants (e.g. HBCD, PFOS, PFCs) in the recycling flow and recycled products and related human exposure and final sinks. Fate of debromination of DecaBDE to POPs PBDEs in the technical processes and end of life treatment including landfills (& the environment and in biota).

19 One important issue which needs to be urgently clarified is the level of PBDE contamination above which a material should be regulated as POPs by the Stockholm Convention (the Low POPs Content ). (waste plastic & goods). One existing limit for PBDE in products is 0.1% defined by the EU RoHS regulation which is not based on health or environmental risk but is rather a monitoring level. EU has set POPs limit for PBDE TeBDE, PeBDE. HxBDE For PCB and (POPs Pesticides) the current provisional low POPs limit recommended by the Open Ended Working Group of the Basel Convention is 50 ppm (pending the determination of a methodology to establish final levels). POPs research community should be stakeholder for determining low POPs limits.

20 BDE levels in workers recycling Polyurethane Foam PBDE in serum lipid (ng/g) PUF recyclers ource: Stapleton ES&T 42, 3453 (2008) Carpet installers Control (Spouse)

21 Knowledge gaps research needs: Further studies on carpet recycling in the US Extent of such recycling in other countries and associated exposure? PBDD/PBDF formation, release and exposure from such operations? Technologies avoiding occupational exposure? Levels of consumer exposure to the articles made from recycled materials?

22 Recycling of PBDE containing PUF to carpet padding in the US:

23 Largest producer and user (until 2004) of PeBDE and OctaBDE was USA ( reservoir ). Substance Flow?? 173 Parties ratified the Stockholm Convention (05/)

24 China received 50-80% of all E-waste exports (2006 legisl) Other importers: India, Pakistan, Vietnam, Philippines, Ghana, Nigeria etc. Large share waste plastic EU (others?) is exported to China Recycling & end of life treatments here? UNEP Newsletter 2006 (BAN investigation 2004)

25 End of life treatment and material/energy recovery (printed circuit board, plastic, polyurethane foam etc.) in metal industry, cement plants, incinerators and others.

26 Risk assessment for chemicals largely focus on production and use phase. The risk assessment for the end of life phase is not (or at least not adequately) developed. However the development of robust risk assessment scenarios for recycling and end of life are becoming more & more important considering that material recycling and close material cycles globally increase. At BFR 2010 Prof. Richard Hull (key note speaker on FR material) highlighted that he was wondering why there are not more contributions on BFRs in the material flow because this is currently the largest reservoir of BFRs.

27 BFR Production (e.g. PentaBDE, OctaBDE, DecaBDE, HBB, HBCD, HBBz 70 other BFRs.) BFR Use (e.g. plastic E&E, PUF, textiles, ) Emission Sources Thermal (e.g. incineration, metal industry, recycling accidential fires) Reservoirs (landfills, contaminated sites, stockpiles sludges, soils, sediments) Products (e.g. Electronics, furniture, cars, plain, train, textiles, mattresses etc.) Recycled Products Environmental Transport Atmosphere Land SSl Aquatic Plants Animals/ Cattle Fish & Shellfish Exposure Routes Intergenerational Inhalation Food ingestion Occupational Accidental Indoor (dust, air)

28 E-waste is one major PBDE/BFR containing waste stream often processed with primitive technologies with high exposure and huge environmental contamination. Open burning of e-waste, Accra, Ghana (Photo: Kate Davison, Greenpeace) Ashes from e-waste burning covered with sand and dumped a Langjiang river Guiyu, China (Photo: Basel Action Network)

29 PBDEs + 75 other BFRs on market, PhosphorFR, Phthalates, PCBs etc. PCDD/Fs; PBDD/Fs, PXDD/Fs, OHPBD PAHs; X-PAHs, Heavy Metals Total TOXICITY? Associated Risks? A range of POPs, upops, heavy metals and other toxic contaminants make these areas complex polluted site. Photos by CIES, 2004

30 Risk assessment of recycling scenarios and end of life treatments in industrial and developing countries considering multiple pollutants. Global substance flow analysis of PBDE (other critical BFRs and PBTS) in products and recycling. PBDE (BFR) contaminated sites from production, application and end of life treatment. External cost estimates/calculations of harm caused by PBDE/BFRs to humans and biota. Life Cycle Assessment of PBDE alternatives (other flame retardants and alternative technologies).

31 If independent science assists a better understanding of the hazards associated with PBDEs in the whole Life Cycle resulting in an awareness of a necessity for substitution of PBTS by safer chemicals, then this PBDE exercise could serve as examples of benefits of a science guided phaseout of critical chemicals from use in consumer products. More positive application of the principles of substitution of PBTS would reduce risks of damage to health and the environment over the whole life cycle of a product (including control/guide of recycling flow). This would also guarantee reduced life cycle costs and safer recycling with associated economic benefits. This would be an important contribution to sustainable production and consumption.

32 Evil Endosulfan The dirty dozen PCDD PCDF PCBs Aldrin Dieldrin Chlordane DDT Dieldrin Endrin HCBs Heptachlor Toxaphene Mirex The nasty nine alpha-, beta-, gamma-hch, ecb, Chlordecone, PeBDE, OBDE, HBB, PFOS ww.pops.int ; ttp:// More dirt! PFOA, PFXSi, PFHx DeBDE, HBCD, PBB PBDD/F, HBBz, PBP TBBPA, TBPAE, SCCP, MCCP, LCCP PCN, HCBD, OCS, PAHs, Nitro-PAH Halogenated PAHs PCP, PCNB, TCNB PT-Pesticides PT-Biocides PT-Pharmaceuticals PT-Siloxanes Sn-Organics Hg, Cd. Pb et al.

33 Has anybody in this room been approached by his/her government to contribute to the Stockholm Convention PBDE and PFOS questionaire the last 15 months? or asked to support or contribute to the national implementation plan on POPs now to be updated?