At PFB Corporation, we are concerned with the future of the planet and the effects that modern lifestyles may be having on the environment. At the core of our culture, our beliefs are based on sustainable development principles and we are committed to conducting our operations responsibly and mindful of the economic, environmental and social impacts of our operations. We have always placed environmental protection at the highest level of importance in our products, our processes and our practices. We are working hard to insure that “Better Building Ideas from PFB” meet the needs of the present without compromising the ability of future generations to meet their own needs; both, in the products that we manufacture and in the manner that we conduct all our operations.

Many materials including thermal insulation, textiles, furniture and electronic equipment commonly found in homes and buildings contain flame retardants to reduce the effects of fire on people and property. Expanded polystyrene (EPS) foam products use a very small amount of brominated flame retardant, hexabromocyclododecane (HBCD), in order to meet strict building code fire performance requirements and permit safe handling and storage. Environment Canada and Health Canada recently published a Draft Screening Level Risk Assessment report of HBCD. The report concluded that HBCD is not entering the environment in a quantity or under conditions that constitute or may constitute a risk in Canada to human life or health but that HBCD meets the criteria to be labeled as toxic to the environment.

EPS foam products provide architects, builders, contractors and homeowners with a highly effective choice for insulating homes and buildings. The thermal protection provided by insulating materials reduces the consumption of natural resources for heating and cooling and in turn reduces emissions of greenhouse gases. Risk assessments by the European Union concluded HBCD contained in EPS foam products poses no risk to workers or to consumers during their service life.

PFB recognizes that HBCD has been found in the environment at least in part due to less stringent control practices by the manufacturers and users of HBCD before it was identified as an environmental concern. As part of our commitment to the protection of the environment, our EPS resin facility has implemented best practices to minimize releases of HBCD.

Currently there is no commercially available alternative to HBCD for use in EPS insulation. However, PFB is working with flame retardant suppliers to investigate potential alternatives to replace HBCD. When an alternative flame retardant becomes available PFB will begin the substitution process immediately.

For more than 3 years, PFB has worked with other industry participants within the Canadian Plastics Industry Association (CPIA) and the EPS Molders Association (EPSMA) to supply Environment Canada (EC) with information, research data, and socioeconomic data thereby assisting government scientists to develop the draft screening level assessment. PFB will continue to cooperate with EC in the development and implementation of an appropriate risk management plan for the safe use of HBCD in EPS foam products.

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Why Use Flame Retardant What is HBCD?
Health & Environment Environmental Science of HBCD
Regulatory Status Product Stewardship
   

   Why Use Flame Retardant

CPIA Fact Sheet - Polystyrene Foam Insulation and Green Buildings

All construction materials must adhere to fire safety requirements during their manufacture, transportation and storage. Flame retardant used in EPS insulation allows it to meet building code fire performance requirements for use as a component in building assemblies and permits safe handling and storage. A small amount of highly effective brominated flame retardant is added during the manufacturing of the raw material. Flame retardants work to delay the ignition of polystyrene foam insulation and slow the propagation of flame.


The flame retardant predominately used for expanded polystyrene is hexabromocyclododecane, HBCD (or HBCDD). This ingredient is added by expandable polystyrene resin manufacturers during the polymerization process and is retained within the polymer matrix.


When EPS containing HBCD is exposed to a fire source the HBCD decomposition products cause flame quenching, so that EPS will not continue to burn when the fire source is removed. While overall fire performance cannot be predicted from small-scale laboratory tests due to the complexity of a real fire situation, the limiting oxygen index test required by EPS insulation standards clearly show that it is much more difficult to ignite EPS made with a flame retardant.

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   Health and Environment  

¹Draft Screening Assessment Cyclododecane, 1,2,5,6,9,10-exabromo-Chemical Abstracts Service Registry Number 3194-55-6, Environment Canada & Health Canada, August 2010
²EC. 2008, Risk Assessment hexabromocyclododecane, CAS-No. 25637-99-4, EINECSNo.:247-184-4, final draft May 2008, European Comission, Sundbyberg, Sweden, Swedish Chemicals Agency

HBCD has undergone a thorough risk assessment by Environment Canada and Health Canada. The draft report issued in August 2010 concluded HBCD current usage in Canada does not pose a health risk to humans but is harmful to the environment, in particular to aquatic life (see excerpts from the risk assessment report below);

Based on the information presented in this screening assessment, it is proposed that HBCD is entering the environment in a quantity or concentration or under conditions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity.

Based on the adequacies of the margins between estimated exposures to HBCD and critical effect levels, it is concluded that HBCD is not entering the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health

It is therefore proposed that HBCD meets one or more of the criteria set out in section 64 of CEPA 1999. In addition, HBCD meets the criteria for persistence and bioaccumulation potential as set out in the Persistence and Bioaccumulation Regulations (Canada 2000).1

HBCD has undergone a thorough risk assessment for environmental and human health in Europe by the ECHA, the European Chemicals Agency2. The conclusions of this scientific assessment identified no risk to consumers or the general public. HBCD is not classified as a human carcinogen, mutagen or reprotoxic. Concerns surrounding HBCD are related to its toxicity to certain species in the aquatic environment and the degree to which it may bioaccumulate and persist in the environment.

Current information available indicates that HBCD is retained within the EPS polymer matrix and as such does not represent a risk to the environment during the service life of EPS foam products.

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    Regulatory Status  

Reference: 1. Draft Screening Assessment Cyclododecane, 1,2,5,6,9,10-exabromo-Chemical Abstracts Service Registry Number 3194-55-6, Environment Canada & Health Canada, August 2010
2. Risk Management Scope for Cyclododecane,1,2,5,6,9,10 – hexabromo-(Hexabromocyclododecane; HBCD) Chemical Abstract Service Registry Number (CAS RN): 3194-55-6, Environment Canada & Health Canada, August 2010
3. EC. 2008. Risk assessment hexabromocyclododecane, CAS-No.: 25637-99-4, EINECSNo.: 247-148-4, final draft May 2008. European Commission. Sundbyberg, Sweden. Swedish Chemicals Agency.

Canada
I
n Canada, a draft screening level risk assessment concluded HBCD is toxic to the environment and recommends addition of HBCD to Schedule 1of the CEPA 1999.1 The report concludes that HBCD meets the criteria for virtual elimination. The next step for Canadian regulators will be development of a risk management plan to prevent HBCD from entering the environment. Environment Canada published a Risk Management Scope for HBCD2 which outlines the steps for moving forward.

There is currently no technically and commercially feasible alternative flame retardant for EPS. PFB Corporation is committed to proactively working with regulatory bodies to ensure appropriate risk management protocols are adopted to ensure environmentally sound use of HBCD until appropriate sustainable alternatives can be identified and commercialized.

Europe
European risk assessment completed by Sweden in 2007 concluded HBCD met the persistent, bioaccumulative and toxic (PBT) criteria. The risk assessment report concluded there is no risk to humans from HBCD contained in polystyrene foams.3 The ECHA has recommended HBCD be added to list of priority substances subject to authorization under REACH. Final decision on authorization of HBCD under REACH is expected sometime in 2011.

International
The UNECE Convention on Long-Range Transboundary Air Pollutants (LRTAP) protocol on Persistent Organic Pollutants (POP) have added HBCD to the candidate list for addition to the POP (persistent organic pollutants) list.

Japan
HBCD concluded to be persistent (P) and bioaccumulative (B) but not toxic (T) and is classified as a Type 1 Monitoring Substance. Japanese authorities believe emission controls in the polystyrene foam industry are effective.

Ref. 2. HBCD Factsheet, June 2009, BSEF

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   What is HBCD?

BSEF HBCD Fact Sheet

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HBCD (or HBCDD), hexabromocyclododecane is a brominated organic flame retardant used for polystyrene thermal insulation and for some textile products. HBCD flame retardant is not manufactured in Canada.

Polystyrene containing HBCD is used in Canada to produce value added thermal insulation materials for the construction industry.

HBCD is a cycloaliphatic organobromine compound that is a solid at room temperature with very low solubility in water.

View a video that explains Brominated Flame Retardants a little more indepth.

 
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   Environmental Science of HBCD  

References
References
1. SCHER Opinion on the risk assessment report on hexabomocyclododecane (HBCD),
environmental part, CAS 25637-99-4, 6 May 2008
2.Law RJ, Bersuder P, Barry J, Wilford BH, Allchin CR, Jepson PD. 2008. A significant downturn in levels of hexabromocyclododecane in the blubber of harbor porpoises (Phocoena phocoena) stranded or bycaught in the UK: An update to 2006. Environmental Science & Technology 42: 9104-9109.
3. Arnot Jon, McCarthy L, Armitage J, Toose_Reid L, Wania F, Cousins I. An evaluation of hexabromocyclododecane (HBCD) for Persistent Organic Pollutant (POP) properties and the potential for adverse effects in the environment, Submitted to European Brominated Flame Retardant Industry Panel (EBFRIP). May 26, 2009
4. EC. 2008. Risk assessment hexabromocyclododecane, CAS-No.: 25637-99-4, EINECSNo.: 247-148-4, final draft May 2008. European Commission. Sundbyberg, Sweden. Swedish Chemicals Agency.

Regulatory agencies assess chemical substances based on three criteria; persistence, bioaccumulative and toxicity. Persistence refers to how long a compound, if released, will take to degrade in the terrestrial (land) and aquatic environments. Bioaccumulative refers to the degree to which a compound will remain in living organisms and build up over time. Toxicity refers to the degree to which a chemical has or may have a harmful effect on living organisms.

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Persistence (P)
Low concentrations of HBCD have been found in the tissues of marine mammals and fish species and in aquatic sediments. European risk assessment concluded HBCD meets persistence (P) criteria however recent data does not support this conclusion1. Environment Canada and Health Canada draft screening level risk assessment report concluded HBCD meets the persistence criteria as per the Persistence and Bioaccumulation Regulations under CEPA 1999.

Although risk assessment reports have concluded HBCD meets presistance criteria, a decline in levels of HBCD in the environment as a result of emission controls in recent years questions persistence (P) designation. 2, 3

Bioaccumulative (B)
Canadian risk assessment report concluded HBCD meets bioaccumulative (B) criteria as per the Persistence and Bioaccumulation Regulations under CEPA 1999.

Toxicity (T)
HBCD is not a carcinogen, mutagen or a reprotoxin. European risk assessment concluded HBCD meets toxicity criteria due to its toxicity to aquatic species. European risk assessment concluded no risk to human health for workers or consumers. 4

The risk assessment found HBCD within polystyrene foam insulation does not pose a threat to consumers who use these products or occupy buildings employing these energy saving insulation materials.

Canadian risk assessment concluded HBCD may have a harmful effect on the environment and therefore is considered to meet the toxicity criteria. The Canadian risk assessment also concluded that HBCD is not entering the Canadian environment in quantities which pose a risk to human health.

 

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   Product Stewardship

VECAP
About VECAP
Reference
1. Law RJ, Bersuder P, Barry J, Wilford BH, Allchin CR, Jepson PD. 2008. A significant downturn in levels of hexabromocyclododecane in the blubber of harbor porpoises (Phocoena phocoena) stranded or bycaught in the UK: An update to 2006. Environmental Science & Technology 42: 9104-9109

During the manufacture of EPS resin, emissions of HBCD are controlled to prevent significant impact on the environment. HBCD currently found in the environment was released in the past due to poor control practices and aging equipment by HBCD producers and users.

In Europe HBCD producers and consumers have implemented significant changes to equipment and processes to eliminate emissions of HBCD to the environment. Emission reduction programs such as SECURE (Self Enforced Control of Use to Reduce Emissions) and VECAP (Voluntary Emissions Control Action Programme) have been implemented in Europe and Japan. These emission reduction programs appear to be having a positive impact and recent studies indicate reductions in HBCD found in the environment.1 By employing strict product stewardship practices, emissions can be virtually eliminated to prevent any potential impact on the environment.

PFB Corporation has applied the VECAP principles in our single Canadian EPS resin manufacturing plant and we continue to measure the effectiveness of these emission controls.

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