PBDEs: Update on Current Issues

NAHMMATacoma, Washington

September 22, 2005

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Ann Blake, Ph.D.

• Work with local government, industry, NGOs to find viable alternatives to toxic chemicals in manufacturing and consumer products

• From Policy to Implementation: legislation, policy papers, EPP standards, research on alternatives

• Molecular biology research background• Hazardous waste regulation and Pollution Prevention

California EPA, Dept of Toxic Substances Control• Currently work with the City of San Francisco, health &

environment NGO coalitions• Precautionary Principle implementation• National and international chemicals policy

Context

• Chemicals Policy Reform• What does a sustainable chemicals policy look like?

• Precautionary Principle• What does putting PP into practice look like?

• Body burden and bio-monitoring• What information do we need for decision-making?

• Toxics reduction strategies• State legislation, local policy • Change manufacturing (P2)• Educate consumers (Market Campaigns)• Create markets for less toxic products (EPP)

PBDEs and Brominated Flame Retardants:A Brief History

• What are the PBDEs?• Subclass of brominated flame retardants, which also include

TPPBA, HBCD• 175 FRs commonly in use; 25% are halogenated (Br & Cl)

• Why do we use them?• Increased fire hazard with increased volume of flammable consumer

products

• What’s the concern?• Detected in human breast milk, ubiquitous in the environment• Potential harmful effects• Routes of exposure remain largely unknown

• What’s happening?• Voluntary & Legislated Phase-outs • Alternatives & Chemicals Policy Reform

Current Research

• Routes of exposure• Food• Indoor air, dust

• Concern as levels increase• Approaching levels that cause neurological damage in

laboratory animals» Swedish peregrine falcons» Highest 5% of North American breast milk

• Northwest Environment Watch/ Cal/EPA HML study (Dioxin 2005) now exceeding concentrations of PCBs in breast milk

• Summaries:• IPEN: http://www.oztoxics.org/ntn/bfrs.html (Sept 2004, April

2005)• HCWH: http://www.noharm.org/ (June 2005)

Status

• State bans (CA, WA, NY, MI, MD, IL, HI)• DfE project on alternatives to penta in furniture• US EPA

• TSCA SNUR: Significant New Use Rule for penta and octa-BDE

• Nominated for elimination under LRTAP and POPS treaties (penta and octa)

• EU: deca toxicity still under discussion• Broad mainstream coverage of toxics in

consumer products, body burden

Implementation Issues

• Regulatory expansion into products• Authority and personnel has not caught up

• Impacts on recycling markets• Consumer electronics plastic• Carpet cushion

• No clear alternatives for penta-BDE in furniture foam

Next Steps

• Exposure: identify exposure routes of concern

• Food, house dust, elsewhere?

• Implementation: work with industry to identify barriers to change; e.g.,

• DfE furniture partnership • Carpet Cushion Council,

carpet recyclers?

Policy Reform

• Case study for inadequacies of current chemicals management approach

• Grossly inadequate data before chemicals put on market» 85,000 chemicals in use, with 1,000 added every year

• No data on interactions with other chemicals• No systematic assessment of potential persistence, bio-

accumulative properties, long-range transport, breakdown, etc.

• Need:• Better ongoing monitoring of humans, environment• Better data PRIOR to putting chemicals on the market

– Europe: “No data, no market”– Implementing Precautionary Principle

• Alternatives, alternatives, alternatives

Beyond Policy

• Leverage institutional purchasing to create market where alternatives already exist

• Automotive maintenance• Janitorial cleaners• Low mercury light bulbs

• Demand full disclosure in purchasing or no deal (“No data, no market” at home)

• E.g., PBT-free purchasing

• Harmonize “green” purchasing standards• Center for New American Dream

– Institutional Purchasing Program• GreenSeal, Scientific Certification Systems

Beyond Pollution Prevention

• Figure out barriers to implementing toxics reduction

• Common ones include:• Lack of information about current use, alternatives

– Inventory!

• Misperceptions about cost, performance– Demo it!

• Purchasing structures• Resistance to change

Some Successful Partnerships

• Hospitals:• HCWH/ Hospital purchasing• Green Guide to Health Care

• Hospitality Industry:• Hotel Janitorial Project / Green Business Program,

San Francisco

• Local Government• Wet cleaning demonstration projects in LA, SF Bay

Area• Regional, state EPP groups

Trends

• Coalition-building between environment and public health and new partners in industrial/ service sectors, labor

• Multi-stakeholder policy discussions• National Chemicals Policy Meeting, April 2005

» Lowell Center for Sustainable Production

• Upcoming California Chemicals Policy meeting, Jan-Feb 2006

» Based on paper to CA legislature assessing chemicals policy options

Haz Mat & Beyond

• PBDE & other bans address products, not waste

• Regulatory authority lacking or unclear

• Changing chemicals policies locally and globally

• What will haz mat encompass in 2010, 2020?

Environmental and Public Health Consulting

510-769-7008annblake@comcast.net