Environment

2007 New Chinese RoHS effective in March 2007
  German Environmental Protection Agency asks for phase out of decabromo diphenylether in electrical and electronic equipment
  Sustainability conquers the USA: New American "halogen-free" projects
2006 New initiatives for halogen-free printed wiring board materials in the USA
2005 Emissions of Flame Retardants
  The European "Flower" Ecolabel and the use of flame retardants
Flame Retardants in the European Electrical & Electronic Waste Directives
2004 Flameretarded furniture positive for the environment
The new EU Chemicals Policy and its Impact on Flame Retardants
BAM-Study "Emission of Flame Retardants from Consumer Products and Building Materials"

New Chinese RoHS effective in March 2007.

The European Directive on the Restriction of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS, 2002/95/EC) has by now has been transposed into national legislation in Member States of the EU. China has issued corresponding legislation under a law called "Measures for Administration of the Pollution Control of Electronic Information Products", but widely referred to as "Chinese RoHS". It will target the same six hazardous substances which are regulated by the EU law, namely the heavy metals cadmium, lead, mercury, and hexavalent chromium as well as the flame retardants polybrominated biphenyl (PBB) and diphenylethers (PBDE).
The main means of control will be a mark which must be affixed by suppliers to the device sold, or clearly printed in papers accompanying the supplied goods if marking is not possible.

The green e with two arrows chasing each other in a circle is the mark of equipment which is free of the targeted substances. The orange symbol exemplifies the marking of the product's "environmentally friendly use period".

The number in the middle of the circle tells the consumer how long the product can be safely used, without risk to their health or the environment due to the hazardous materials contained in the product.

The marking is required already in March of 2007, but a date for the ban on the hazardous substances is not yet clear. Regulations implementing this aspect of the new law are expected soon. The Chinese law may have a broader reach than the EU directive: For example, the EU only regulates the product if you have to plug it in, while the Chinese draft list of electronic information products includes materials used in the manufacturing process to produce electrical equipment as well.
The Chinese law has left the door open for manufacturers based in China to continue to produce products containing the hazardous substances: as long as they are for export-only.
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German Environmental Protection Agency asks for phase out of decabromo diphenylether in electrical and electronic equipment

In a press release of 26 March 2007, the German Environmental Protection Agency (UBA) demands again the phasing out the flame retardant decabromo diphenylether (DecaBDE) in electrical and electronic equipment like computers and TV-sets.

The European Union initially wanted to phase out all polybrominated biphenyls (PBB) and polybrominated diphenylethers (PBDE) -including DecaBDE - as of July 2006 according to the Directive 2002/95/EC "Restriction of certain Hazardous Substances in Electric and Electronic Equipment (RoHS)".

In the frame of the European Existing Chemicals Directive, in 2004, the Risk Assessment for DecaBDE which took 10 years was completed and no risk reduction measures were proposed. This was the reason why in autumn 2005, against the will of the European Parliament, the European Commission exempted DecaBDE from this restriction before it had come into force. The European Commission may allow exemptions to these restrictions, provided the use of substitutes is technically or scientifically not possible or if the substitutes are more harmful than the initially foreseen substance. According to UBA, both is not the case for DecaBDE, because it is persistent and accumulates in the environment and living organisms. In addition, there are hints that in the environment DecaBDE may partly degrade to the lower brominated and more toxic chemicals penta- and octabromodiphenylether. Denmark and the EU-Parliament are of the same opinion and question the legal basis for the exemption of DecaBDE from the restrictions by the European Commission, and have therefore launched a legal challenge to this Commission Decision in January 2006.

The UBA points out that for many years a number of innovative companies phased out the use of DecaBDE, and some of them plan to replace all brominated flame retardants. Instead, they use e.g. certain halogenfree organic phosphorous compounds, magnesium and aluminium hydroxides, red phosphorous, metal phosphinates, nitrogen-containing flame retardants, or modified equipment design. In Germany, since 1986, members of the Plastics Producers Industry (VKE, now PlasticsEurope) voluntarily abandoned using DecaBDE.

Meanwhile in the USA, in the States of Washington and Maine, there are proposals for Acts relating to phasing out the use polybrominated diphenylethers including DecaBDE.

http://www.umweltbundesamt.de
http://www.nrcm.org
http://www.maine.gov
http://www.legislature.ca.gov

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Sustainability conquers the USA: New American "halogen-free" projects

In the USA, the word "sustainability" may still evoke fuzzy stereotypes of do-gooders putting ideals ahead of reality. However, the growing influence of watchdog groups making clever use of the internet, new environmental regulations with additional, stringent restrictions coming from Europe and spreading over to Asia, create a new perception of sustainability, health and the environment in American companies, associations, authorities, and last but not least, the public opinion. This also concerns the use of flame retardants.

The development of "halogen-free" systems for office and consumer electronics started in Europe and has now reached the USA: Projects from electronics manufacturers and suppliers, as well as from the US Environmental Protection Agency (EPA) focus on printed wiring boards (PWBs).
The International Electronics Manufacturing Initiative iNEMI, an industry-led consortium of approximately 70 electronics manufacturers, suppliers and related organizations, started a Halogen-Free Project last year. The objective is to promote standards development by establishing materials, manufacturing, assembly, and test guidelines for "halogen-free" PWBs based on market segment requirements and technical, commercial, and functional viability. The project results are expected in 2008.
The High Density Packaging User Group International HDPUG is an American non profit trade organization involved in the supply chain of products using high density electronic packages. HDPUG has just started (January 2007) a new Halogen-Free Properties Project:
- A comprehensive "halogen-free" guideline for PWBs and general information about packages, cables and casings will be developed.
- A "halogen-free" PWB Product database allowing suppliers to display their halogen-free PWB product offerings in a uniform concise format will be assembled.

The Design for the Environment (DfE) Program of the EPA works in partnership with a broad range of stakeholders to reduce the risk to people and the environment by preventing pollution. Under the title "Safer Flame Retardants", one DfE project Printed Circuit Board Flame Retardancy Partnership was started in order to improve our knowledge of the environmental, health and safety aspects of commercially available flame retardants that can be used to meet fire safety requirements for the majority of printed circuit boards. Tetrabromobisphenol A (TBBPA) is the largest-volume brominated flame retardant with an annual production of approximately 150 000 tonnes, and is the primary flame retardant for printed circuit boards. Alternative flame retardant materials are becoming available for use in PWBs.
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New initiatives for halogen-free printed wiring board materials in the USA

In the USA, there is an increasing interest in alternatives to the currently used brominated flame retardant systems in electronics, and particularly in printed wiring boards (PWBs). Besides the Environmental Protection Agency (EPA), which has started a Design for Environment project to look at environmental and health properties of alternatives to TBBPA, a major industry association, the International Electronics Manufacturing Initiative (iNEMI) has started a halogen-free initiative beginning of this year. iNEMI is an industry-led consortium of approximately 70 electronics manufacturers, suppliers and related organizations with its headquarters in Herndon, Virginia, USA.

As part of their technology roadmap activities, iNEMI has begun a technical feasibility study of halogen-free electronics. The background is the introduction of the Waste Electrical and Electronic Equipment (WEEE) and the Restriction on the Use of Certain Hazardous Substances (RoHS) Directives in the European Union, requiring the separation of waste containing brominated flame retardants (WEEE) and the restriction on the use of the flame retardants polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs). Although PBBs and PBDEs are not used in PWB materials, stakeholders are beginning to urge the electronics industry to look at halogen-free alternatives to brominated epoxies for circuit board applications.

The objective of the feasibility study is to promote standards development by establishing materials, manufacturing, assembly, and test guidelines for halogen-free PWBs based on market segment requirements and technical, commercial, and functional viability. The study consists of three phases:

  • Phase I: Design
    Will review prior work and make recommendations for testing needed. Investigation will take into account needs of electronic product sectors.
  • Phase II: Test
    Will develop, manage, and execute performance testing.
  • Phase III: Results
    Will compile results, assess significance, make recommendations, and publish a report with a public release foreseen for 2008.

Details, see EPA and iNEM
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Emissions of Flame Retardants

In recent years, the question arose to what extent emissions of flame retardants from building and consumer products take place and whether they pose a health risk. Many studies and research projects were conducted, and they have helped to better understand this phenomenon. All results have shown that emissions of flame retardants are extremely low, and therefore do not pose a health risk.

Emissions are usually measured in indoor air and dust in buildings and automotive interiors. The flame retardants studied are mainly phosphate esters and halogenated phosphate esters, as well as brominated flame retardants, including the polybrominated diphenylethers.

In 2002, the Swiss Federal Health Agency (Bundesamt für Gesundheit = BAG) made a study on "phosphorus-based flame retardants in indoor air" in order to find out the relevance of these compounds. The conclusions were that for 10 widely-used phosphorus-based flame retardants, there is no indication of any health risk related to their use.

In 2003, a study conducted by the German Federal Institute for Materials Research and Testing BAM (Bundesanstalt für Materialprüfung) on the emission of flame retardants from building products and consumer goods (insulating foams, computer equipment, printed circuit boards, upholstered furniture and mattresses), showed that brominated flame retardants and phosphate esters were not detected or only found in extremely low amounts far below a precautionary guiding value of 0.005 mg/m³. For the flame retardant with the highest emissions, trischloroisopropyl phosphate (TCPP), more environmentally friendly alternatives do exist.

A third study on flame retardants and plasticizers emissions in car interiors was carried out by TÜV Nord and the Fraunhofer Wilhelm Kauditz Institute on behalf of the German automotive industry in 2003. Again, the result was that no relevant emissions of flame retardants were found and that no health risks were identified.

There are no compulsory limit values for emissions of flame retardants in Germany and elsewhere in the world at the moment, and no activities planned to introduce emission requirements for flame retardants in the future.

References:
Hartmann P, Bürgi D, Giger W (2004):
Organophosphate flame retardants and plasticizers in indoor air. Chemosphere Vol, 57. pp. 781-787

Kemmlein S, Hahn O, Jann O. (2003): Emissions of organophosphate and brominated flame retardants from selected consumer products and building materials. Texte des Umweltbundesamtes, Berlin, Nr. 55/03, 188 pp.

Sagunski H, Roßkamp E (2002): Richtwerte für die Innenraumluft: Tris (2-chlorethyl)phosphat. Bundesgesundheitsblatt, Vol. 45. pp. 300-306

Salthammer T, Wensing M (2002): Flame retardants in the indoor environment Part IV, Classification of experimental data from house dust, indoor air and chamber tests. Indoor Air 2002 Conference, Monterey, California, Vol. 2. pp. 213-218

StapletonH, Dodder N, Offenberg J, Schantz M, Wise S (2005): Polybrominated Diphenyl Ethers in House Dust and Clothes Dryer Lint. Environmental Science & Technology, Vol. 39, No. 4. pp. 925-931

Wensing M, Pardemann J, Schwampe W (2003): Flame retardants in the indoor environment. Part V: Measurement and exposure evaluation of organophosphate esters from automobile interiors. Proceedings Healthy Building 2003, Singapore.
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The European "Flower" Ecolabel and the use of flame retardants

The European "Flower" Ecolabel is a voluntary scheme designed to encourage businesses to market products that are kinder to the environment and for European consumers - including public and private purchasers - to easily identify them. Criteria are established for individual product groups, such as paper products, textiles, detergents, paints and appliances such as refrigerators or dishwashers.
Some products have to meet national or international fire safety requirements and thus may contain flame retardants. These products are:

  • Appliances, TVs and computers
  • Dishwashers
  • Refrigerators
  • Washing machines
  • Televisions
  • Personal computers
  • Portable computers
  • Furnishings
  • Furniture

Criteria for ecolabels have been published in Official Journal of the European Union for the appliances, TVs and computers listed here. The criteria for flame retardants say that plastic parts which are heavier than 25 grams must not contain decabromobiphenyl and polybrominated diphenylethers, as well as chloroparaffins. In addition, no flame retardants or substances dangerous to health according to various risk phrases (e.g. causing cancer, toxic to aquatic organisms) may be used.

For furniture no EU ecolabel exists at the moment. A feasibility study for an EU furniture ecolabel had been prepared by the German Environmental Agency UBA, and the Dutch Stichting Milieukeur entrusted with establishing the criteria. A report was completed in August 2004. The criteria proposed were eventually rejected by the EU Member States, because the proposed limit values would have precluded the use of PVC and some flame retardants (<600 mg/kg Cl). Nonetheless, the EU Ecolabel Board has now decided to re-start discussions (meeting of 8th December 2004) and many EU Member States are favourable to reviving the project.
Contrary to well-known national ecolabels like the German "Blue Angel", most consumers do not know the European "Flower" Ecolabel yet. It has to be seen whether this will change in future.

Further information on the EU ecolabels may be found here.
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Flame Retardants in the European Electrical & Electronic Waste Directives

Two EU Directives, 2002/96/EC on waste electrical and electronic equipment (WEEE) and 2002/95/EC on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS), were published in 2003. The transposition into national law was due for August 2004, however, there have been delays in many Member States (e.g. Germany passed its "Elektrogesetz" in March 2005).

The purpose of the WEEE directive is the prevention, reuse, recycling and recovery of waste. The Directive prescribes the separation of electrical and electronic waste containing plastics with brominated flame retardants prior to recycling, energy recovery or disposal.

The purpose of the RoHS directive is to contribute to the protection of human health and the environmentally sound recovery and disposal of WEEE. Member States shall ensure that from 1 July 2006 new E&E equipment put on the market does not contain certain heavy metals, flame retardants like polybrominated biphenyls (PBB) and the polybrominated diphenylethers penta-, octa-, and decabromo (deca-BDE) diphenylether. While penta- and octa-BDE have been banned in the meantime, in the light of the positive risk assessment results for deca-BDE, the European Union has supported moves to exempt this flame retardant from the RoHS Directive and thus allow its continued use.

On 22 April 2005, a majority of EU member states voted to exempt deca-BDE from the restrictions in the Directive. However, the proposal did not reach the necessary majority (72.3% of the votes) to be adopted immediately. Therefore, the proposal was sent to the EU Council of Ministers that will have a maximum of three months to adopt a decision. To reject the Commission proposal, the Council would have to oppose it by more than 70% of the vote.

In June 2005, six environment ministers have reiterated their opposition to exempt deca-BDE from the ban on hazardous substances in the RoHS Directive. In a letter sent to environment commissioner Stavros Dimas, ministers from Belgium, Denmark, Finland, Norway, Portugal and Sweden say uncertainty still surrounds deca-BDE, and complain that existing alternatives have not been considered in the Commission's proposal to exempt the chemical. Swedish officials say the letter is aimed at persuading the Commission to reconsider its position if the council fails to reach a qualified majority for or against exemption. The Commission must adopt its proposal unilaterally if the council fails to act. Deca-BDE's opponents still hope to withdraw this chemical from the E&E market.back to top>>>

Links:
http://europa.eu.int
http://environment.ministry.se
http://www.bsef.com

Flameretarded furniture positive for the environment

A life cycle assessment (LCA) including the effects of fire on upholstered furniture has been performed by SP, the Fire Testing and Research Institute in Boras, Sweden. Other "Fire-LCAs" have already been applied to TV-sets and cables.
In the UK, since 1989 the "Furniture and Furnishings Fire Safety Regulations" require upholstered furniture privately used has to be flame-retarded in order to pass a cigarette, small flame and a woodcrib test, reflecting ignition sources of increasing energy.

The number of fire deaths and injuries has dramatically decreased since. In other European countries, only voluntary requirements apply and most furniture sold meets the cigarette test, which basically does not require the use of flame retardants. If here too, more demanding fire tests where used, the number of fatalities and injuries from upholstered furniture fires could substantially be reduced.
The objective of the furniture fire-LCA project was to assess the total emissions and the environmental impact from a non-flame retarded sofa that meets the European mainland requirements with those from two sofas flame retarded with phosphorous and brominated flame retardants that meet the British requirements. They considered emissions of carbon monoxide and dioxide (CO and CO2), cyanide (as HCN), nitrogen oxides (NOx), hydrochloric acid (HCl), polycyclic aromatic hydrocarbons (PAH), and chlorinated and brominated dioxin equivalents (TCDD, TBDD) during manufacture, use, end-of-life disposal, and in accidental fires.
The results showed that for certain substances (e.g. CO, NOx and CO2) the presence or absence of flame retardants had little effect on the total emissions. The non flame retardant European mainland sofa produced significantly higher HCN and PAH emissions, while the flame retarded UK sofas produced more HCl and dioxin equivalents.In addition, a comparison of the relative cancer risk from the PAH and the dioxin equivalents was made.
It showed that the PAH emissions constituted a considerably higher risk: the cancer risk from the non flame retarded sofa was found to be more than 250 times higher than that of the flame retarded sofas.
The overall conclusion of the furniture Fire-LCA study is therefore that the flame retarded UK sofas help to reduce fire fatalities and injuries, and represent a lower environmental risk than the non flame retarded European mainland sofa. back to top>>>

The new EU Chemicals Policy and its Impact on Flame Retardants

The European Commission adopted its White Paper, "Strategy for a future Chemicals Policy", in February 2001, setting out the strategy for future community regulations for chemicals.

The main objective of the new chemical strategy is to ensure a high level of protection for human health and the environment while ensuring the efficient functioning of the internal market and stimulating innovation and competitiveness in the chemical industry.
On 29th October 2003 the EU Commission published finalised proposals after a public
internet consultation on an initial draft during the summer of 2003. Now it is the European Parliament's turn to discuss and approve the draft. There are some 100 000 substances which were declared by manufacturers in 1981 as "existing substances" on the market in Europe, because they were already being produced before that date.
These include about 2 700 high production volume (HPV) substances (substances that are produced in volumes of more than 1 000 metric tons a year) which account for a large part of the entire chemical production in the European Union (EU). Up to now, it has been possible to market these existing substances without formal registration or notification.

For new substances, however, it has been necessary to submit extensive data sets since 1981. The notification procedure involves a great deal of effort and has been largely responsible for only about 2,800 new substances being brought onto the market in Europe in the last 22 years.
This is roughly 10 times less than in the United States during the same time. Therefore, a uniform and simplified assessment system for both existing and new substances should be encouraged.

The REACH concept forms the basis of the proposed legislation as a single system for produced or imported existing and new substances:

REACH =
Registration of 30 000 substances > 1t/a/manuf. Import.
Evaluation of 5 000 substances > 100 t/a
Authorisation of 1 350 substances of "very high concern"
Chemicals
The European Chemical Industry supports the political objectives of the White Paper, but advocates a legislative framework that still enables it to remain competitive at the global level. The Commission claim that changes made between the initial proposal and its final proposal will cut implementation costs for industry by 80%. Costs and effects on business are only two of a number of contentious issues.

The question is whether it is possible to create a system which is workable and where costs and benefits in terms of human health and the environment are well balanced. Otherwise we build up a huge bureaucracy, generate a lot of paperwork, sacrifice many animals for toxicity tests and spend a lot of money on other tests without really improving the environment or our health.

In our global economy it also vital to take into account the effects on international competitors - will it become more favourable to produce chemicals or even finished articles outside the EU and import them instead of producing here?

Will big chemical companies shift their production outside of Europe?
Links:
http://europa.eu
http://europa.eu.int
Document Downlaod at Cefic
PDF Download at Cefic

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BAM-Study "Emission of Flame Retardants from Consumer Products and Building Materials"

On behalf of the German Federal Environmental Agency UBA, the Federal Establishment for Materials Research and Testing BAM has studied the emission behaviour of flame retardants in building products and consumer goods.

The product groups tested were insulation and assembly foams, upholstered furniture and mattresses as well as IT devices and circuit boards. The project focussed on brominated flame retardants like hexabromocylododecane (HBCD) and Tetrabromobisphenol A (TBBA), halogenated tris(2-chloroisopropyl) phosphate (TCPP) and halogenfree phosphoric acid esters like triphenylphosphate (TPP), bisphenol A-bis(diphenyl)phosphate (BDP) and Resorcinol-bis(diphenyl)phosphate (RDP) as well as chloroparaffins. The testing of the single products took place in test chambers of varying sizes under standard conditions.
To simulate real-life conditions, potential flame retardant emissions were measured under operating conditions and at elevated temperatures. The procedures used are well suited to detect the emission of organophosphorus compounds both qualitatively and quantitatively.

For a German Class B2 to DIN 4102 polyurethane assembly foam with TCPP, a concentration of 3 g m-3 TCPP was found in the air of the emission chamber. For other assembly foams, the concentrations amounted to 10 and 15 g m-3 TCPP. Due to their low volatility, the other flame retardants could not be detected or only as surface specific emissions in the (by a factor of one thousand lower) nanogram range.

According to the results of this research project, no increased risk for health and the environment could be identified for flame retardant emissions from consumer goods and building products in room interiors.

The 248 pages study "Emission of Flame Retardants from Consumer Products and Building Materials" was published inthe series TEXTE of the German Federal Agency UBA as No. 55/03. <<< back

It is available from Werbung und Vertrieb
Ahornstraße 1 - 2
10787 Berlin
Phone +49 (0)30/2 11 60 61
Fax: 2 18 13 79.

It is also available as a download in English under www.umweltbundesamt.de.
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