Illinois EPA

Report on Alternatives to the Flame Retardant DecaBDE: Evaluation of Toxicity, Availability, Affordability, and Fire Safety Issues

A Report to the Governor and the General Assembly

Executive Summary and Recommendations

In 2006, the Illinois Environmental Protection Agency (Agency) issued A Report to the General Assembly and the Governor in Response to Public Act 94-100, “DecaBDE Study: A Review of Available Scientific Research.” This report presented the Agency’s findings on five issues raised in Public Act 94-100 regarding the flame retardant chemical Decabromodiphenyl ether (DecaBDE). The Agency found that DecaBDE is bioaccumulating in the environment and that levels are increasing in some samples. We also found that humans are exposed to DecaBDE, mainly from the diet, workplace, and home. We were not able to fully determine what health effects could result from exposure, whether DecaBDE breaks down into more harmful chemicals, and if safer alternatives are available that still maintain fire safety, due to uncertainties from insufficient data. Regarding these last three issues, we were able to report that liver, thyroid, reproductive/developmental, and neurological effects are the most important effects seen in animal studies with DecaBDE and other polybrominated diphenyl ethers (PBDEs); that DecaBDE breaks down to other chemicals under some conditions; and that effective alternatives exist for most DecaBDE uses but their toxicity databases contain gaps.

In response to this report, Governor Blagojevich sent a letter to the Agency requesting a follow-up study to answer the critical issues remaining from the 2006 report, and to determine whether safer and affordable alternatives to DecaBDE are available that still meet fire protection standards. The following provides the Agency’s findings and recommendations regarding potential replacements for DecaBDE’s uses.

Findings

In this report, we have updated significant issues that were found to have insufficient information in our 2006 report, reviewed the toxicity data for selected alternatives to DecaBDE, and assessed the affordability and availability of DecaBDE alternatives. These topics are summarized as follows.

Update of significant issues – In our 2006 report, we were not able to fully answer whether DecaBDE breaks down into more harmful chemicals, what health effects could result from exposure to DecaBDE, and whether DecaBDE alternatives were available that are safer than DecaBDE and still meet fire protection standards. Since issuing the 2006 report we have reviewed additional information regarding these issues, and now find:

• Evidence continues to accumulate that DecaBDE can be broken down by light and microbial organisms under certain conditions, and we are now confident that animals can metabolize it into a variety of breakdown products; there is still uncertainty about whether the breakdown by light and microbes occurs under conditions normally occurring in the environment (temperature, moisture levels, etc.) and which of the many breakdown products might be the most abundant and most important toxicologically.
• Regarding the health effects of the PBDEs, we now have additional evidence that DecaBDE, certain DecaBDE breakdown products, and other PBDEs can cause thyroid, reproductive/developmental, and neurological effects; although there is still uncertainty about DecaBDE’s role in these effects, our level of uncertainty has decreased from the 2006 report, and further justifies an in-depth evaluation of potential alternative flame retardants for products still using DecaBDE.

Toxicity of DecaBDE alternatives – There are a number of ways to flame-retard for products that do not require chemicals and for which toxicity is not a concern. Examples include redesigning products to be less fire-prone, and the use of inherently fire-resistant fibers and light-weight metals. For a description of such DecaBDE alternatives, see Section 6 of the 2006 DecaBDE report.

With respect to chemical alternatives, we evaluated those which are currently in widespread use or are expected to be in the future. We developed a scoring approach that ranked the health and environmental effects data for chemical alternatives to DecaBDE as being of high, moderate, low, or no concern, and then grouped them into “bins” of overall level of concern: Potentially Unproblematic, Potentially Problematic, Insufficient Data, and Not Recommended. There is insufficient toxicity data available for the alternatives to say with certainty that they pose little or no risk and are therefore “safe” to use as flame retardants. However, some of the chemical alternatives do appear to be safer than DecaBDE.

Affordability and availability of DecaBDE alternatives – In order to gauge the relative affordability and availability of DecaBDE alternatives, the Agency undertook a widespread review of information relevant to these issues including direct contact with several electronics and transportation industry trade groups/associations, product manufacturers, and large retailers. Based on our evaluations, it appears that there are only a few current DecaBDE uses for which the alternatives still have affordability and/or availability concerns, while there are many uses/products for which a phase-out of DecaBDE is substantially complete or is in progress. Our findings include:

• Consumer electronics – No significant affordability issues, with phase-out of DecaBDE substantially complete; some manufacturers just beginning phase-outs may need additional time to complete fire protection tests and product re-design studies.
• Other electrical applications and electronic products (particularly wiring, cable, and electronic assemblies) – No significant affordability issues, with phase-out of DecaBDE substantially complete; some additional, minimal product performance testing may still be required to complete the transition.
• Medical devices – Moderate affordability issues, extensive product testing still to be accomplished before phase-out possible.
• Textiles and foams – Affordability issues remain, but only for use in the transportation sectors; many affordable options are available to replace DecaBDE uses in furniture, mattresses, draperies and other textiles applications.
• Transportation – Significant affordability issues, related to performance and fire protection standards required by regulations and manufacturer’s specifications; significant time still needed to complete product performance and fire safety testing of plastics, electrical wiring, electronics, fuel systems and upholstery.

Recommendations

From the findings discussed above, the Agency now believes there is reason for concern regarding the continued use of DecaBDE in many products. This concern is based on:

• the widespread occurrence of DecaBDE in the environment
• the uncertainty surrounding the ultimate fate of DecaBDE in the environment and in organisms, and
• the growing database of toxic effects attributed to DecaBDE, its metabolites, and other PBDEs.

Because of these concerns and the fact that a significant number of alternatives are affordable, available and have better toxicity rankings than DecaBDE, the Agency recommends that the Governor support a managed state-level phase-out of several DecaBDE’s uses. This approach should include the following elements:

• Establish a realistic target, possibly by year-end 2010, for the phase-out of DecaBDE, focusing on uses and industrial applications where there are available, affordable and potentially less toxic alternatives. Focus initially on DecaBDE used in electronics and textiles (excluding textiles used in the transportation sectors).
• Provide exemptions/extensions for those uses where alternatives are demonstrated not to be feasible.
• The managed phase-out could be accomplished through voluntary actions, negotiations, rules, and/or legislation.

In addition, the State should:

• Continue discussions with manufacturers, industry associations, environmental advocates, etc., to evaluate additional information pertaining to fire safety/flame retardants.
• Explore the creation of a clearinghouse among state environmental agencies as a central repository for information regarding flame retardants that can be made available to interested parties.
• Modify state purchasing decisions to favor purchase of DecaBDE-free products.