GPEC 2010 - Flame Retardant Regulatory Status & Future Development

Flame Retardant Regulatory Status and Future Development GPEC 2010 – March 9, 2010 Susan D. Landry Raymond B. Dawson Advisor, Fire Safety & Advocacy Global Director, Advocacy susan.landry@albemarle.com ray.dawson@albemarle.com

Why are Flame Retardants Needed? Non flame Flame retarded retarded to UK-standard Flame retardants are used to help: Prevent ignition Delay the spread of fires Delay the time of flashover to enable people time to escape Extract from a Dutch TV documentary, RTL 5, 2000 It is estimated that escape times can be up to 15 times longer when flame retardants are present, providing increased chances of survival “Fire-Hazard comparison of fire retarded and non fire retarded products,” NIST 1988, http://fire.nist.gov/bfrlpubs/fire88/art003.html Toronto, Canada, August 2, 2005: Flame retardants were credited with increasing escape times for all 309 passengers from this jet, which was ultimately completely consumed by fire. Washington Post, Aug. 5, 2005

Why are Flame Retardants Needed? Fire prevention is essential from a number of perspectives: Protection of life Protection of property and the environment Prevention of immediate local pollution to air and water Prevention of lesser-known long-term environmental effects Results of a 2009 study, performed by Greenstreet Berman Ltd for the UK Department of Business, Innovation and Skills, has shown that the UK furniture fire safety regulations account for 54 fewer deaths per year 780 fewer non-fatal casualties per year 1065 fewer fires per year (A statistical report to investigate the effectiveness of the Furniture and Furnishings (Fire) (Safety) Regulations 1988, December 2009) The introduction of voluntary flammability standards made possible by the use of flame retardant plastics in the TV enclosures and accessories led to a significant reduction in the number of TV-initiated fires, even with a sharp increase in the total number of TV sets per household. It is estimated that 190 lives are saved annually through the use of brominated flame retardants in TV enclosures. F. Clarke, “The life safety benefits of brominated flame retardants in the United States,” Final Report to the Chemical Manufacturers Association Brominated Flame Retardant Industry Panel, Benjamin/Clarke Associates, 1997

Combustion Gases Generated In Fires Typically items involved in fires are a complex mixture of materials (furniture, electronics, building materials, household cleaners, etc…) Combustion Gases generated regardless of whether or not flame retardants are present “Clearly, fire gases are dangerous to fire fighters and other citizens who could be exposed, independent of the presence or absence of flame retardants [2] ” “Combustion gases contain very high concentrations of acutely toxic substances [3] ” Combustion gases generated during fires that contribute to acute toxicity include CO, HCN, HCl, and acrolein [1] The acute toxicity of fire gases is controlled by carbon monoxide (CO) – responsible for over 90% of fire deaths [1] 1) Troitzsch, J, “Fire Gas Toxicity and Pollutants in Fires – The Role of Flame Retardants,” FR2000 Conference, London, 8th-9th February 2000 2) “Review of Fire Emissions from Products with and without BFRs and the Hazard of Exposure for Fire Fighters and Clean-up Crews”, SP Report 2007:74 3) Rechenbach, P, Troitzsch, J, “Smoke Toxicity and Pollutants from Fires”, Kunststoffe 89 (1999) 9, pp. 132-134

Pollutants Generated In Fires Pollutants generated regardless of whether or not flame retardants are present Polycyclic Aromatic Hydrocarbons (PAHs) and polyhalogenated dibenzodioxins and furans (PHDDs/PHDFs) are the most important pollutants generated in fires [1] Compared to PAHs, the impact of PHDDs/PHDFs on our health is negligible [1] In the Lengerich fire (Germany in 1992), measurements and their respective cancer risk and relationship showed that the PAHs have an up to 500 times higher cancer risk than the PHDDs/PHDFs [1] PAHs are generated in all fires [1] There are several hundred different substances in the PAH family [1] Many PAHs generated in fires are carcinogenic compounds, including benzo[a]pyrene (BaP) [1] PAHs are found in high amounts in the soot after fires [1] 1) Troitzsch, J, “Fire Gas Toxicity and Pollutants in Fires – The Role of Flame Retardants,” FR2000 Conference, London, 8th-9th February 2000

Common Flame Retardant Classes Mineral Others… Halogenated Brominated Chlorinated Phosphorus Based on natural elements There are many different flame retardants in each of these classes Each individual flame retardant has it’s own unique set of environmental, human health, physical, and chemical properties The distinct nature of individual flame retardants requires that each be treated on it’s own merits

European Union (EU) Risk Assessment The EU Regulation 793/93 - EU Risk Assessment was one such assessment process adopted in 1993 The most comprehensive assessment of a materials environmental and human health characteristics Products were assessed individually, not as a class Determined the need for further testing to fill in data gaps Determined if there was a need to limit risks This process: Examined mammalian toxicology Acute, chronic Established acceptable human exposure limits: Predicted No-Effect Conc. (PNEC) Examined environmental fate and toxicology Established acceptable environmental exposure limits: PNEC Examined all releases to water, soil, air, from all operations throughout lifecycle Volumes, processing, uses, waste streams Established human and environmental exposures: Predicted Environmental Concentrations (PEC) Evaluated risk: Exposures versus limits Determined if exposure is above or below established limits

Summary of FR EU Risk Assessments Flame Retardant Status Next Steps Risks Identified Conclusions Classification Risk Assessment Banned in EU as of Penta-BDE Concluded --- Unfavorable Aug 2004 --- Banned in EU as of Octa-BDE Concluded --- Some risks identified Aug 2004 --- Additional tests, - Safe for continued monitoring, and use Deca-BDE Concluded emissions control in None - Emissions control None progress program active - Not restricted for any ENV: risk identified applications ENV: Finalized at one additive user - Authorities have TBBPA HH: Finalized None plant only emission requirements R50/53 - Emissions control HH: None program active Classified a PBT ENV: Finalized Transferred to REACH On the SVHC Risks identified, PBT HBCD HH: Finalized Candidate List status debate – new - on the SVHC R50/53 Candidate List science ENV = Environmental Sections, R38 = irritating to skin, HH = Human Health Sections, R40 = Carcinogenic category 3, limited evidence of a carcinogenic, PBT = Persistent, Bioaccumulative, and Toxic effect, C&L = Classification and Labeling, SVHC – Substance of Very High concern, N - Dangerous to the Environment, T = Toxic, R22 = Harmful if swallowed, Xn = Harmful, R50/53 = Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment, R51/53 = Toxic for aquatic environment, may cause long-term adverse effects in the aquatic environment, R60 = Toxic to reproduction category 2 (CMR category 2), ATP = Adaptation to Technical Progress

Summary of FR EU Risk Assessments Flame Retardant Status Next Steps Risks Identified Conclusions Classification ENV: finalized Reprotox + chronic Transferred to REACH On the SVHC T, N, R51/53, R22, R60, TCEP HH: finalized Candidate List tox + Carc, several - on the SVHC R40 exposure scenarios Candidate List ENV: finalized REACH registration, TCPP will be sold with Reprotox, dermal, TCPP HH: finalized C& L decision production the same existing Xn, R22 labels Chronic tox + Carc, ENV: Finalized REACH registration, TDCP will be sold with dermal, production & TDCP HH: Finalized C& L decision flexible PU foam the same existing N, R51/53, R40 labels manufacturing Antiblaze® TL-10 ENV: Finalized Antiblaze® TL-10 successfully completed V-6 HH: Finalized successfully completed None registration (REACH None REACH registration Registration # 01- 2119419991-33-0000 ENV: risks identified for sediments at a few plants ENV: finalized Risk Assessment Transferred to the (Sb2O3) HH: finalized transferred to REACH HH: no risks REACH R38, R40 identified at current stage –discussions in progress ENV = Environmental Sections, R38 = irritating to skin, HH = Human Health Sections, R40 = Carcinogenic category 3, limited evidence of a carcinogenic, PBT = Persistent, Bioaccumulative, and Toxic effect, C&L = Classification and Labeling, SVHC – Substance of Very High concern, N - Dangerous to the Environment, T = Toxic, R22 = Harmful if swallowed, Xn = Harmful, R50/53 = Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment, R51/53 = Toxic for aquatic environment, may cause long-term adverse effects in the aquatic environment, R60 = Toxic to reproduction category 2 (CMR category 2), ATP = Adaptation to Technical Progress

Restriction of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive 2002/95/EC - came into force July 1, 2006 Restricts the placing on the EU market new electrical and electronic equipment containing certain levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB), and polybrominated diphenyl ether (PBDE) flame retardants Review of the RoHS Directive is now ongoing: European Commission proposal (December 2008): No addition of new substances New Annex III with list of substances for priority review including HBCD & 3 phthalates REACH / RoHS alignment to avoid contradiction European Parliament (November 2009): The Green Political Party has the lead on the discussions = “rapporteur” Their current proposal is to ban all BFRs & other substances Not endorsed by a number of MEPs - too extreme Discussion around open scope for RoHS

RoHS Revision – current status European Council Main focus is on alignment between REACH & RoHS No discussion on addition of substances yet but discussion on need of criteria &/or methodology for inclusion of new substances Discussion around open scope for RoHS The RoHS revision is still under discussion by the European Institutions & nothing is decided yet Most industry associations do not agree to add further substances to the RoHS Directive

Registration, Evaluation, Authorization and Restriction of Chemical Substances (REACH) REACH is a new European Community Regulation on chemicals and their safe use (EC 1907/2006) - entered into force on 1 June 2007 Registration, Evaluation, Authorization and Restriction of Chemical substances All manufacturers and importers of chemicals in the EU must identify and manage risks linked to the substances they manufacture and market REACH replaces about 40 pieces of EU legislation Industry must bear most responsibilities to manage the risks posed by chemicals and provide appropriate safety information to their users REACH calls for the progressive substitution of the most dangerous chemicals when suitable alternatives have been identified

REACH – Registration timelines 06/2007 06/2008 12/2010 06/2013 06/2018 P R REACH Entry into force E - R > 1000 tpa > 1 tpa (CMR cat. 1 & 2, E Registration PBT, vPvB) G > 100 tpa (N; R 50/53) I S > 100 tpa T Registration R A T > 1 tpa I Registration O N Not pre-registered / non phase-in substances CMR = Carcinogen, Mutagen, Reprotoxic, N - Dangerous to the Environment , tpa = tonnes per annum per company, PBT = Persistent, Bioaccumulative, and Toxic, R 50/53 = Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment, vPvB = very Persistent and very Bioaccumulative

REACH – Evaluation Duties of registrants : Update with undue delay and with relevant new information (uses, hazard information, tonnage band) Update submission on examined testing proposals, Submission of registration requirements of compliance checks and (by registrant) other requirements set by Authorities Additional fees for each update Completeness Check Registration for dossier and fee (by ECHA) No. assignment Dossier Evaluation Substance Evaluation (by ECHA) (by MS) Check of Testing Check of Compliance Check Proposals (by ECHA) Substance properties (by ECHA) OUTPUT : Decision on further information requirements Information for stakeholders Restrictions

REACH – Authorization Substances targeted by authorization are Substances of Very High Concern (SVHCs): CMR (Carcinogen, Mutagen, Reprotoxic) cat. 1 and 2 PBT (Persistent, Bioaccumulative, and Toxic) vPvB (very Persistent and very Bioaccumulative) Substances with equivalent concern (e.g. endocrine disruptors) There are reporting, notification, and information obligations for suppliers of SVHC substances, and preparations and articles containing them The Authorization process comprises three stages: Identification of SVHC (Candidate list) - This triggers notification and communication obligations for candidate list in articles, with possible black list effects HBCD listed on the first candidate list published by ECHA October 2008 TCEP added to the candidate list Inclusion of candidate substances in the list of substances subject to authorization (Annnex XIV) Decisions on applications for authorization

REACH – Authorization Potential Options for Authorization SUBSTANCES of VERY HIGH CONCERN RISK IS NOT ADEQUATELY CONTROLLED : RISK IS ADEQUATELY CONTROLLED : CMRs 1 & 2 CMRs 1 & 2 + + OTHER substances with threshold limits OTHER substances with threshold limits + PBTs, vPvBs Suitable alternative YES NO YES Socio-economic benefits YES AUTHORIZATION NO SUBSTITUTION Time-limited review on case-by-case basis BAN

REACH Flame Retardant Summary Pre-registration / Registration Albemarle pre-registered all its flame retardants Consortia formation and registration dossiers gathering ongoing Risk assessed substances are already data-rich TL-10ST Albemarle’s TL-10ST (2,2-Bis(chloromethyl)trimethylene bis(bis(2-chloroethyl)phosphate)) has successfully completed registration (REACH Registration # 01- 2119419991-33-0000)

REACH Flame Retardant Summary HBCD (Hexabromocyclododecane) Classified as a PBT - On the 1st Candidate List for Authorization Used in EPS & XPS, with no available alternatives Authorization is being sought for this application due to the importance of insulating foam Application for Authorization due mid-2012 Current sunset date is late 2013 for all applications without Authorization TCEP (Tris(2-chloroethyl) phosphate) Classified CMR cat. 1-2 after EU risk assessment Not sustainable under REACH - alternatives available for all uses

HBCD – Other Issues HBCD (Hexabromocyclododecane) UNECE POP HBCD classified as a POP Dec 2009 Q1 2010 - Risk management Questionnaire Q4 2010 - Risk management will be decided Q4 2011 - Potential POP listing unless exemption is granted Industry is actively co-operating with the UNECE process to ensure exemption for EPS & XPS use UNEP POP (Stockholm Convention) May 2013 - Potential POP listing unless exemption is granted

Deca-BDE Phase-Out The three major producers of Deca-BDE have entered into a “partnership” with EPA to phase out production and importation of Deca-BDE Other Deca-BDE importers/distributors are encouraged to join the partnership Our commitments to EPA include the following: We will stop manufacturing Deca-BDE by December 31, 2013 Deadline for completion of End-Use Application Deca-BDE phase-out Wire & Cable December 31, 2010 (except transportation or military) All other uses December 31, 2012 (except transportation or military) Transportation and military uses December 31, 2013 We will submit to EPA annual progress reports After the phase-out period, EPA intends to impose additional Deca-BDE testing requirements on remaining producers/importers After the phase-out period, EPA intends to impose a “significant new use rule” or SNUR on Deca-BDE and articles containing Deca-BDE

NA Activity State-by-state regulations - limited number of flame retardants Potential TSCA Reform EPA “Chemicals of Concern” Action List announced Dec 2009 Include phthalates, short-chain chlorinated paraffins, polybrominated diphenyl ethers (PBDEs), and perfluorinated chemicals, including PFOA Process could lead to risk reductions actions under section 6 of TSCA EPA also announced that three companies agreed to phase out Deca-BDE Reinforcing the Deca-BDE phase-out – with requirements to ensure that any new uses of PBDEs are reviewed by EPA prior to returning to the market. “Polybrominated Diphenyl Ethers (PBDEs) Project Plan” High Production Volume (HPV) Challenge (~2200 HPV chemicals) Design for Environment (DfE) program Partnership with a broad range of stakeholders - Several have and are currently including flame retardants California Green Chemistry Initiative Encourage the development of “green chemistry” solutions Canada - Implementation of Chemical Substances Plan

Informed Substitution

Safety & Sustainable Use of Flame Retardants Flame Retardant Selection Physical, Mechanical, and Flammability Properties; Stability; and Recyclability of Polymer Formulations Commercial Availability of FR Cost Human Health and Environmental Criteria Meets Current Regulations Meets Anticipated Regulations ? How do you measure environmental impact of various FR’s in use? Life Cycle Assessment Carbon Footprint, Global Warming, Energy Consumption, Ozone Depletion, Air Acidification, etc…

Sustainability Fire Safety is important for the good of society We are a fire safety company Albemarle will provide the right solution; we do not limit ourselves to particular products or chemistries The choice of technology used to achieve fire safety should be based on sound principles Full life-cycle analysis Non-toxic, non-bioaccumulative products Consideration of environmental and societal impacts We must solve the end-of-life problem for products Products should enable recyclability

To Achieve This • Our new product development will focus on Polymeric solutions, big molecules Reactive products that become bound to the final polymer Non-toxic small molecules Mineral products • Releases of all products to the environment must be minimized We will champion the implementation of measures throughout the supply chain to minimize emissions of persistent compounds Engage distributors, customers, and competitors in programs such as VECAPTM to eliminate all product emissions from the environment

The next generation of eco-friendly fire safety • First product in our family of green solutions • non-bioaccumulative • superior toxicity profile • excellent recycle capability • exceptionally broad application profile • Polymeric flame retardant • Highly stable product lends itself to efficient recycling of plastics. • Emissions to the environment are minimized, when combined with other good practices such as the Voluntary Emissions Control Action Program. earthwise™ A division of ALBEMARLE®

Eliminating Emissions To The Environment Is Of The Utmost Importance For Sustainability Voluntary Emissions Control Action Program Voluntary – producer and user implemented Emissions – identify sources of BFR emissions Control – reduce, minimize and where possible eliminate emissions Action – dynamic, continuous process Program – focus on best practices to eliminate emissions TM VECAP VECAP™ is an Industry Program that can be applied to all polymer additives to prevent potential emissions and save valuable raw material

Reduce Levels of Environmental Emissions of Flame Retardants VECAP addresses many stages of the Life-Cycle Manufacturing Processing Waste disposal Production Dust from unloading and Residues in packaging Packaging feed operations Poorly treated wastewater Shipping Leaks in feed equipment from system wash-outs Improper clean-up of spills Waste not reprocessed

We are asking users to: Perform self assessment Commit to VECAP and Mass Balance; Code of Good develop baseline Practice emissions to ensure progress is measurable Drive to Reduce Emissions Create and implement Utilize third-party emissions reduction verification audits as plan needed

VECAP in Action – Best Available Practices for Handling Packaging Problem • Discarded packaging can retain small amounts of product • Product has the potential to get into the environment, depending on end-of-life practices for empty packaging Solution VECAP Best Available Technique (BAT) for Emptying Packaging Document and Poster These techniques can be applied to all polymer additives to prevent potential emissions and save valuable material for use, rather than waste

Support of VECAP Wildlife Habitat Council GM "It was a pleasure to be introduced to the innovative Voluntary “VECAP is a good example of effective cooperation Emission Control Action Program (VECAP) designed to reduce and throughout the whole supply chain. In line with GM’s where possible eliminate avoidable emissions of brominated flame commitment to environmental excellence, the retardants into the environment from manufacturing processes. The programme ensures that the chemicals included in Wildlife Habitat Council supports voluntary efforts by industry to go our products are safely managed. Moreover, as it beyond regulatory requirements and adopt management practices, allows a better management of substances, VECAP such as VECAP. We look forward to working with this industry sector is particularly relevant in the context of REACH and of and help them improve their overall sustainable management practices the development of the new chemical regulation in to include wherever possible management strategies that promote the US.” wildlife habitat improvement and on site conservation education for the Dr. Pat Beattie, Director Chemical Risk Management, benefit of the local community.“ General Motors Corporation Robert H. Loftur-Thun, Vice President External Affairs, Marketing, & Dave Mattis, Global Technology Engineering, General Development, Wildlife Habitat Council Motors Corporation Marks & Spencer “VECAP is a great example of how chemicals need to be managed in the 21st Century, true producer responsibility. Here is a sector of the chemical industry that has been under more pressure than most but has responded to the challenges before it by developing a ground breaking model for control. VECAP’s strength lies in its focus on the use of brominated flame retardants across the whole value chain, not just at one stage within it. It is based on the use of common sense best practice; often small things that added together can make a real difference. Of course it doesn't just rely on words on paper but brings things to life on the factory floor with good practice guides, training and audits. Finally VECAP does not duck the challenge of debate with those stakeholders who may criticize the performance of the industry, nor has it hidden from the need to back up the claims for its potential with evidence of real year on year improvement in reducing emissions. Put together this value chain approach, best practice, training, measurement and debate and we have a model that shows how a sector of the chemical industry can go beyond compliance with legislation and develop a far more sustainable approach to doing business.” Mike Barry, Head of Corporate Social Responsibility, Marks & Spencer

Eagle Performance Products Receives Environmental Award for Use of VECAP Eagle Performance Products has implemented 5 initiatives that have reduced waste both in-house and with customers. These waste reduction initiatives have resulted in savings of approximately 6,000 Kg/yr of formulated material and 11,500 Kg/yr of plastic additives at the Eagle Performance Products plant and approximately 36,000 Kg/yr of formulated product at their customer’s facilities.

Conclusions Flame Retardants provide a valuable role in our society Prevent ignition Delay the spread of fires Delay the time of flashover to enable people time to escape It is important that Flame Retardants are safe in use Regulations that are being developed worldwide provide the platform to achieve this goal with a level of confidence Albemarle’s EarthwiseTM family of products will focus on sustainable offerings GreenArmorTM is the first product in this family of sustainable solutions

For More Information… www.albemarle.com www.earthwiseinside.com www.vecap.info www.bsef.org www.ebfrip.org

GPEC 2010 - Flame Retardant Regulatory Status & Future Development

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GPEC 2010 - Flame Retardant Regulatory Status & Future Development Presentation Transcript