PBDEs: Update on Current Issues

1. PBDEs: Update on Current Issues NAHMMA Tacoma, Washington September 22, 2005

2. 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

3. 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)

4. 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

5. 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)

6. 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

7. 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

8. 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?

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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?

15. Environmental and Public Health Consulting 510-769-7008 annblake@comcast.net