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End-of-life Considerations for Consumer Products Containing Flame Retardants

Roland WeberPOPs Environmental Consulting, D-73527 Schwäbisch Gmünd, Germany

Green Science Policy SymposiumOrganohalogens in Consumer Products: How Science Can Impact Policy;

Madrid 31.08.2014

•Some end of life considerations on FR polymers/materials in industrial countries.

•Contribution from industry ?•Situation of end of life FR polymers in developing countries.•Listed BFRs in the Stockholm Convention as a chance for

managing FR containing materials in end of life.

Content of Presentation

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• Society need to move to circular economy. Regulation in EU and China on recycling quota. Mac Arthur Foundation: Circular Economy.

• Basel Convention recent paradigm shift: from waste to resources.• Stockholm Convention COP4 decision: The listing of PBDEs includes

exemptions allowing for recycling and the use in articles of recycled materials containing POP-PBDEs.

• Situation end of life HFR containing material flows (WEEE plastic; PUR foam; insulation; textile)? Recycling challenge (risk cycle)?.

What to do with Halogenated Flame Retardants (HFRs) in articles and recycling?

Material flow c-OctaBDE containing articles

Alcock et al. 2003 (with modifications)

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• What is the flow of PBDE/BFR in recycled materials? What articles are contaminated? Risks to human & environment?

• Swiss monitoring showed that not much WEEE plastic is recycled back to EEE today (Bantelmann et al. 2010) likely because of RoHS.

• Higher share recycled WEEE plastic in older EEE (Sindiku et al. 2014)

PBDE/BFRs in video tapes(5/5) (Hirai et al, BFR 2007.)

PBDE in children toys China(Chen et al, ES&T 43, 4200, 2009)

⇒ The recycling flow of PBDE/BFR containing plastic seems largely uncontrolled. Need to control recycling of FR containing articles to protect consumers/human health!

PBDE/BFR Contamination of Recycled Plastic?

Coffee Cup Lids (Samsonek & Puype, FAC, 2013)

• The European WEEE directive require that bromine containing plastic is separated and managed.

• Technologies are developed. However only some facilities in EU can separate BFR plastic. Only Switzerland has sufficient capacity to separate their WEEE plastic. Cost !? Following management ?!!

• The overall WEEE plastic flow even in the EU is unclear (attempt of MFA/SFA for Vienna had challenges Vyzinkarova & Brunner J IndEcol 2013).

• Part of WEEE plastic thermally destroyed. However cost of destruction. • Cheapest solution: Companies export mixed WEEE plastic from

Europe (in addition to the export of WEEE). ⇒ Currently even for industrial countries with regulation in place the

WEEE plastic is only partly appropriately managed (for other materials not regulated or other regions with less regulations less management).

Industrial country situation FR-Polymers

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BSEF (2000). An introduction to BFRs BSEF 19 October 2000.

“This would close the bromine loop, ensuring the sustainability of bromine production”.

• For Ecolable for printer & copy machinesthe EU joint research center suggested to have a requirement of 10% recycledplastic. This was rejected by all EEE producers. Only Xerox mentioned that theycould comply with 5% recycling quota.

•One challenge is BFRs and compliancewith RoHS directive 0.1% PBDE.

•Second challenge is the mix of plastictypes from WEEE which can not berecycled back to high quality productslike TVs. But to toys or coffee cup lids.

⇒Industries (FRs; plastic; EEE) need to takemore responsibility ⇒ EPR needed!

Contribution from FR/plastic/EEE industry

• Voluntary emission control (VECAP) for BFR production and users. Now plan for EoL. (Goosens et al. Dioxin 2014)

• Industry input for E-waste StEP initiative.

• EU FR industry had the aim to recover 70% of bromine by 2004. Until today only pilots.

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WEEE in Africa: Reuse, Refurbishment and ”Recovery” of Materials

PBDEs in human milk: Comparison with some other regions/countries

01020304050607080

USA

Taizhou, C

hina

Canad

aJa

pan

Faroe I

sland UK

Sweden

Malays

ia

Philippines

Korea

Cambodia

Indonesia

Hangzh

ou, China

Vietnam India

Russia

(Burya

tia)

Region/country

PBD

Es (p

g/g

lipid

wt)

BDE-47 BDE-99 BDE-100 BDE-153

Tsydenova, Tanabe et al., Env. Poll. 2006

Taizhou reg

ion

Lin’an

city

Control site: Lin’an city, Hangzhou

E-waste recycling site: Taizhou

Lin’an

city

Global comparison of PBDEs in human milk

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Material flow and stocks of WEEE plastic in Nigeria in major WEEE categories(2000 - 2010) Flows for 2000 to 2010 and for the stocks (in use & landfill/dump) for 2010

( )Open burning/Open burning/

Source: Babayemi et al. 2014; Env Sci Pollut Res. DOI: 10.1007/s11356-014-3228-6

Substance flow/stocks PBDE of WEEE plastic Nigeria in major WEEE categories(2000 - 2010) Flows for 2000 to 2010 and for the stocks (in use & landfill/dump) for 2010

Open burning/Open burning/

Source: Babayemi et al. 2014; Env Sci Pollut Res. DOI: 10.1007/s11356-014-3228-6

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• Open burning: A large share of HFR materials are burned in the open with associated releases and pollution.

• Landfilling/dumping: FRs are partly released from landfill.• Developing countries do not have an appropriate destruction and

waste management. • Thermal destruction/recovery: flame retarded materials have

challenges in thermal destruction: • Release of HBr and elemental bromine (challenge even for cement)• Corrosion of facilities• Formation of brominated and brominated-chlorinated PXDD/PXDF

• This situation requires industry & international efforts for control and management of these material flows in developing countries (HFR in WEEE; EoL vehicles; construction, furniture/textiles).

• Science community: more comprehensive documentation.

Considerations: End of life HFR materials in developing countries: open burning & dumping

• Recycling: Still no control of recycling of FRs into a range of (partly sensitive) material streams. More systematic assessment of research community on the extent of affected materials needed.

• Currently no regulation exist for PBDE or other BFR limit except the RoHS limits for EEE – so no legal reason not to recycle and export.

• Standards needed for measuring BFRs in articles and products. • China: Separation of BFR plastic is in place in some facilities (e.g.

MBA polymers – suggestion to recycle BFR plastic in e.g. shoe soles). Basel Convention Center Beijing project on WEEE.

• India (EMPA): WEEE plastic largely in informal sector. BFR plastic normally not separated. In the case that BFR plastic was separated this was for recycling for a company requiring FR plastic.

• Nigeria; Currently approximately 20 polymer recycling facilities are planned – not clear what plastic is recycled and to what is recycled.

Considerations: End of life HFR materials in developing/transition countries: Recycling

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Material flow of Flame retarded PUR

?Alcock et al. 2003 (with modifications)

Source: Stapleton et al. ES&T 42, 3453 (2008)

PBD

E in

ser

umlip

id(n

g/g)

PUR Foamrecyclers

Carpetinstallers

Control(Spouse)

Assessment of Possible Health and Environmental Impact:Recycling of Polyurethane Foam & Human Exposure (US)

POP-PBDE levels in workers recycling Polyurethane Foam (US)

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• Need global assess & management of PUF.

Some Considerations on PUR Foam

• FRs (BFR & CFR) in PUR foam lead to exposure during use phase, recycling and from recycled products.

• Not clear how much PUR foam is impacted globally since only a few countries have flammability standard e.g. for furniture.

• Most of PUR foam is not recycled. If - then largely downcycling. • My experience: PUR foam is partly gathered by scavengers on

landfills – recycling/recovery to which products?

Chemical Pesticides Industrial chemicals

Unintentional production Annex

ChlordeconeLindane Alpha hexachlorocyclohexaneBeta hexachlorocyclohexaneEndosulfan

+++++

By-product of lindaneBy-product of lindane

AAAAA

C-PentaBDECertain congeners c-OctaBDEHexabromobiphenylHexabromocyclohexanePerfluorooctane sulfonic acid (PFOS), its salts and PFOSF +

++++

+

AAAAB

Pentachlorobenzene + + A/C

• The Conference of Parties (COP) to the Stockholm Convention decided to list the first BFRs as POPs in 2009 to 2013.

• Chance to improve global management of FR products/wastes ! (?)

Listing of POP-BFRs in the Stockholm Convention

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Guidance for the inventory of PBDEs listed under the Stockholm Convention

• Appropriate policy and regulations are needed then and can be developed in this frame for the management of FR containing material flows.

http://chm.pops.int/Implementation/NIPs/Guidance/tabid/2882/Default.aspx

• The listing of PBDEs, HBB and HBCD in the Stockholm Convention can be used for global inventories of major FR material streams.

• POPs inventories are used for action plan development and priority setting for the National Implementation Plans for the SC.

Inventory Guidance for POP-PBDEs (Section) 1)

Inventory Steps for POP-PBDEs (Section 3)

Former POP-PBDE production and uses (Section 2)

Electronics (Section 4) Transportation & end-of-life vehicles (Section 5)

Other uses (Section 6)

In use Recycle Waste Furniture Textiles Construction materials

Contaminated sites (Section 7)

Inventory report

Inventory of POP-PBDEs (Sections 4-7)

PBDE inventory guidance – addressing several BFR waste categories

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• Interesting for science community to support assessment & global management of HBCD in the frame of the SC.

HBCD relevant for other material flows• HBCD is listed in Stockholm Convention. Become effective 26.11.2014. • Large volume of HBCD treated polystyrene (XPS/EPS) were and are

used in insulation of buildings. SC exemption for HBCD use in XPS/EPSin construction. If HBCD is used in XPS/EPS then labelling is needed.

• The recycling of HBCD containing materials is not exempted in the Stockholm Convention. What are recycling activities of XPS/EPS (China) and how can HBCD be controlled in XPS/EPS (sensitive use in food packaging; frozen fish boxes etc). Relevance for textile recycling?

• Destruction of EPS/XPS challenge (logistic & bromine)

Guidance on BAT/BEP for recycling & disposal of PBDE/BFR containing materials/articles

• The allowance of reuse and recycling of articles containing POP-PBDEs results in the need to define Best Available Technology (BAT) and Best Environmental Practices (BEP) to carry out the recycling and the final disposal in an environmentally sound manner (ESM).

• Guidance (Draft) was developed considering the recommendations made by COP5 for the management of POP-PBDE containing materials.

• The guidance can be used to manage other BFR containing articles. Can be updated when new technologies emerge.

http://chm.pops.int/Implementation/NIPs/Guidance/tabid/2882/Default.aspx

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Pro

duct

ion

Management transport sector (5)

Production c-PentaBDE (stopped) Production c-OctaBDE (stopped)

Transport sector

Energy/material recovery (7)

Incineration (7.2) Cement (7.2) Melting (7.4) Pyrolysis (7.5) Metal industry (7.6)

Management PUR foam (6)

Flexible PUR foam

Electrical & Electronic Equipment (EEE)Mattresses

ABSMinor uses: Textile, PWB, rubber, construction

Disposal in landfill (8 and annex D)

Management EEE/WEEE & Plastic* (4)

Furniture

Recovery of bromine** (annex E)

Dis

posa

lU

se&

Re-

use

Rec

yclin

gR

ecov

ery

PBDE screening technologies (3.6)

Generic BAT/BEP (3.5)

Other polymersHIPS

*Bromine recovery is not operated in full scale yet.Reuse of Articles (e.g. cars, electronics, furniture) .

• The size of the arrow indicate major use or major flows of POP-PBDEs or POP-PBDE-containing materials.• Dashed arrows indicate non-preferred routes **POP-PBDE separation is not available yet in full scale

Material flow of POP-PBDE-containing goods & Structure of BAT/BEP Guidance

http://chm.pops.int/Implementation/NIPs/Guidance/tabid/2882/Default.aspx

Chance: Inventory & policy & management of HFR containing materials in the life cycle

• With the inventory development of POP-BFRs along the material flow, countries will start to visualize/monitor the material flows containing FRs.

• Based on these assessments, policy/management instrument to control these material flows can be developed to control life cycle of FRs/PBTs in products and end-of-life.

• Chance for the industry (HFR & polymer) for real extended producer responsibility? !

Import

Use

End-of-Life Articles/Stockpiles

Recycling Landfill.

Biosolids/sewage sludge

Export

PARTY/COUNTRY

Thermal treatments

Production - chemicals- products- articles

Trade & Sales

Re-use

Production and use phase Waste Management

Multiple Sources Multiple Sources

Import

Use

End-of-Life Articles/Stockpiles

Recycling Landfill.

Biosolids/sewage sludge

Export

PARTY/COUNTRY

Thermal treatments

Production - chemicals- products- articles

Trade & Sales

Re-use

Production and use phase Waste Management

Multiple Sources Multiple Sources

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The challenges in end of life with HFR products request solutions. Substitution considering sustainable production might be 1st choice !

• The SC POP reviewing committee has developed documents on alternatives to POPs including alternatives to listed BFRs. Currently a publication is developed compiling information on alternatives to current POPs in articles including tools helping to make informeddecissions on sustainable substitution. (Monday we have session on „Sustainable production and use“ (10.45-12.45 Dublon) and furtherdiscussion e.g. on the role of stakeholders (13.45-15.25 Escudo).

• Policy makers to establish the regulatory frames (science advice).• We should give our support as scientists (and for consumers) to the

most sustainable chemicals („Green/Sustainable Chemistry“) and sustainable products („Benign by Design“) on the market.

• This is a sustainable business field - chance for innovative industries!

(Part of) Solution: Shift to more benign chemicals, materials and products by substitution approach

.

Thank you for your attention!Thank you for your attention!