VECAP V
CONTROLLING EMISSIONSPROTECTING THE ENVIRONMENTCONTINUOUS IMPROVEMENTANNUAL PROGRESS REPORT 2006

The Voluntary Emissions Control
Action Programme for the brominatedflame retardant Deca-BDE

EBFRIP
A SECTOR GROUP OF CEFICVECAP V

Table of Content
3What is VECAP?

5

Why VECAP?

8

Message from the VECAP Team9

How does VECAP work?

11

2004 - 2006 Developments inthe VECAP Programme

15

Providing Support to
VECAP Users

This report aims to introduce VECAP to a wide rangeof audiences, including regulatory authorities,
user industries and the general public as a whole.
It is designed to provide transparent and concise
information on the progress of the VECAP programme in Europe on an annual basis. Any feedback
or comment on the following report is welcome
and would be considered for future editions.

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VECAP V

What is VECAP?
VECAP is a Voluntary Emissions Control
Action Programme established by the brominated flame retardant industry. It was set up
to manage, monitor and minimise industrial
emissions of brominated flame retardants into
the environment through partnership with
Small and Medium-sized Enterprises (SMEs).
As such, it represents advance practice ofwhat the new EU chemicals policy of REACH
will require in future.
Through VECAP, the manufacturers and usersof Deca-BDE are working together to establish
and share best practices on the handling of
Deca-BDE to minimise emissions to the environment. The VECAP Code of Good Practice
can become a benchmark for a wide variety ofindustry sectors.
VECAP is a product stewardship industry
initiative that reinforces the reduction
throughout the manufacturing process byfostering a culture of continuous improvement.

Its early success has motivated the brominatedflame retardant industry to roll out VECAP
globally, and to implement it for other flame
retardants.

"I welcome this voluntary industry
programme to reduce emissions of
the flame retardant Deca-BDE tothe environment. DG Enterprise
supports voluntary industry action
where this can result in environmental improvement hand in handwith economic development. I lookforward to the further expansion of
VECAP with a view to this providing an example of best practicefor other industrial sectors"
Michel Catinat
Head of the Competitiveness Aspects of Sustainable
Development Unit, DG Enterprise, European Commission

THE BROMINATED FLAME RETARDANT INDUSTRY’SCOMMITMENT UNDERPINNING VECAPThe brominated flame retardant industry has voluntarily committed itself to VECAP, serving as a commitment shared by its members, who support all activities which promote:➜ public health and safety➜ transparency with public authorities➜ scientific research➜ responsible care for the environment➜ a commitment to promoting fire safety through the most environmentally sustainable manner

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VECAP V

BEST PRACTICE SHARING: VECAP offers allcompanies - small, medium or large - equal
access to the industry’s expertise in environmental and process performance best practice.
Such access allows benchmarking and drives
continuous improvement.

THE VECAP PROGRAMME IS BASED ON THE
FOLLOWING PRINCIPLES:VOLUNTARY INITIATIVE: it demonstrates thecommitment of the industries involved, tovoluntary act in a manner which supports theinterests of society and the environment.

SAFE USE: VECAP is providing detailed
information ensuring safe and eco-efficientuse of brominated flame retardants.
VECAP CERTIFICATION: an independent third
party VECAP audit procedure, using ISO
9001/14001 principles is under development.

CONTINUAL IMPROVEMENT: recognition that
we can always improve processes further andshould do so if economically justified.
PROMOTING SUSTAINABILITY: reducing
impact on the environment while enhancing
the competitiveness of local industries.
TRANSPARENCY: publishing of reports andinformation for the involved parties collected
via an independent Product Steward.
DIALOGUE: VECAP is promoting open dialogue with all interested bodies at national and
EU level. This dialogue will progress with timeand feedback.

ABBREVIATIONS
BFRs
BSEF
Deca-BDEEBFRIP
VECAP
PEC
PNEC

Brominated flame retardants
Bromine Science and Environmental Forum
Decabromodiphenyl ether
European Brominated Flame Retardant Industry Panel
Voluntary Emissions Control Action Programme
Predicted Environmental Concentrations
Predicted No-Effect Concentrations

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VECAP V

Why VECAP?
In 2001, BSEF commissioned the Dutch
Fisheries Research Institute (RIVO) to takeenvironmental samples in five EU Member
States (the Netherlands, Belgium, Germany,
Ireland and the UK). The RIVO findings,
published in 2002, showed low detection levelsof Deca-BDE, mainly in sediment. Importantly,
this study showed that the detection levels
were substantially more significant near certain
industrial production sites where Deca-BDE
was used.
The RIVO results prompted the brominatedflame retardant industry to initiate the VECAP
programme. Since Deca-BDE is not manu-

factured in the EU, the emissions of Deca-BDE
into the environment were coming from operations associated with the formulation and use
at downstream production sites. In order tomonitor the success of the VECAP program, thebrominated flame retardant industry embarked
on what has become a ten-year programme todevelop and implement a system for emission
monitoring and control measures. The initial
focus of the programme are the textile andplastics industries in the UK, France, Germany,
Italy, Belgium and the Netherlands, covering
more than 95% of the Deca-BDE EU
consumption.

PEC/PNEC RATIO FOR DECA-BDE

Summarised from EU Risk Assessment Report 2002 demonstrating low environmental risk (all PEC/PNEC ratios < 1)
but greater emissions from textiles application.

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VECAP V

also the source of some environmental concern.
Although Deca-BDE has not been found to beharmful to the environment, there is concern that
due to its persistency levels may build up in theenvironment. In the interest of increased fire
safety and the environment, the relevant stakeholders have come together to ensure that DecaBDE continues to enable high level of public fire
safety in the most sustainable manner.
Measuring VECAP in envionment

As emissions from textile production sites,
which use wet processes with a potential forwater emissions, were higher than at plastics
compounders, which only use dry processes,
textile applications were deemed the firstpriority. EBFRIP joined with the UK Textile
Finishers Association to develop a first-everpilot emission control programme for textile
applications in the UK. With the support of EU
Regulatory Authorities in May 2004, VECAP
was officially started.
While the EU risk assessment on Deca-BDE
concluded that given the latest scientific information there was no need for further risk
reduction measures, it was agreed that a specificaction programme could contribute to control
and reduce emissions into the environment more
effectively and quickly.

This VECAP Europe Annual Progress Report(May 2006) marks the results of the UK pilot
programme and the implementation of the
VECAP programme in five other EU countries.

“Our customers expect us to control
carefully the use of chemicals in
the products we sell. VECAP isjust the type of proactive response
we are looking for our suppliers to
adopt to meet these growing
customer expectations.”
Mike Barry ,Head of Corporate Social Responsibility ,Marks & Spencer

Deca-BDE has proven to have excellent flame
retarding properties, with its persistence being
its strongest asset in providing necessary
long-term fire prevention. This persistence is

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VECAP V

Why VECAP?
VECAP’S FORECASTED
ROLL-OUT IN EUROPE
The VECAP European roll-out is projectedaccording to the following timeframe.

“Ford Motor Company supports theobjectives of this voluntary initiative
to further minimise brominated flame
retardant environmental emissions.
Based on pan-regional rollout of
VECAP, application of the programto Ford's affected supply basewould be encouraged.”
Andy Taylor, Director,
Corporate Citizenship/Sustainability, Ford of Europe.

2007 - 20102005 - 2007
2004 - 2005

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VECAP V

Message from the
VECAP Product Steward
VECAP is about people. The VECAP team would
like to thank the Deca-BDE user companies who
have embraced the VECAP mission, and haveaccepted our interventions and recommendations
almost without fail. The Textile Finishers
Association (TFA) played a pivotal role in carryingout the pilot project in the UK. Each of the EBFRIP
member companies, Albemarle, Chemtura and
ICL-IP, have dedicated customer service
managers to make the continuous improvement
philosophy a reality at the Deca-BDE user level.
The philosophy of VECAP is to show continuous
improvements, and we are only taking our firststeps in that direction. This report provides firstemissions considerations for the plastics andtextiles sectors using Deca-BDE in 6 EU countries.
The year to year market variations in the sales ofDeca-BDE may result in different emissions
pictures. In the coming years our progressive
learning curve will provide a more global andcomplete view. This continuous improvement
cycle will allow us to optimise the resulting data inline with new findings and a more detailed
understanding of the processes involved.
Meanwhile, the future of VECAP is developing
quickly. VECAP is quickly spreading throughout
Germany, France, Italy, Belgium and theNetherlands. We are beginning the project in the
United States and Canada and extending the
VECAP codes of good practice to other brominated flame retardants. Soon we will launch
VECAP for TBBPA and HBCD used in textiles anda similar programme, SECURE for HBCD’s use
in expanded and extruded polystyrene. We aredeveloping an independent, third party auditing

system, using ISO 9001/14001 principles. Other
industry sectors are looking to our programme
for guidance in setting up their own productstewardship and emission control measures.
This programme has been made possible bymany individuals who believed in the programme
when it was merely a concept. There were some
who preferred to remain sceptical as to whether
a largely SME-based industry chain would be
prepared to act voluntarily to reduce emissions ofa chemical for which no risk reduction measures
had been deemed necessary by the EU authorities.
But such voices were in a minority. I would like tothank the encouragement provided by regulatory
authorities across Europe who have given us
the chance to prove that voluntary emissions
reduction is possible and can lead to results far
more quickly than risk reduction. Above all, I
salute the Deca-BDE user chain which hasembraced VECAP. I am proud to be part of anindustry of such committed individuals. It is withgreat pleasure that I share these initial results inthis report.

Paul Adriaenssens
VECAP Product Steward

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How Does VECAP work?
THE VECAP PROCESSThe VECAP process is structured to support the
principle of continuous improvement, with thesix steps moving in a cyclical manner:
1 ➜ COMMITMENT TO THE VECAPCODE OF GOOD PRACTICEThe VECAP system starts with the user’scommitment to the programme, adopting theIndustry’s Code of Good Practice and implementing these principles into the procedures
and work instructions of daily operations.
2 ➜ SELF AUDITIn a self-audit, the company identifies the
production flow sheet of involved Deca-BDE
production processes.
3 ➜ MASS BALANCE APPROACH

The company determines the needed data tocomplete and close the mass balance as accurately as possible (signaling the gap in amountof Deca-BDE entering and leaving the production
processes based on a worst case scenario).

DECA-BDE
STOCK➜

PRODUCTIONPROCESS➜ MANUFACTUREDPRODUCTVECAP is a process ofcontinuous improvement.
In repeating the process
cycle, the user checks tomake sure that the changes
made have resulted in
the expected emission
reductions and looks forfurther changes to reducesignificant emissions.
4 ➜ BASELINE EMISSIONS SURVEY

The company uses the obtained mass balance
results as a baseline to demonstrate the actual
process emission performance and to determine
future opportunities for emissions reduction.
5 ➜ EMISSIONS IMPROVEMENT PLAN

An emission improvement plan is determined inaccordance with the company’s own objectives
and policies.
6 ➜ IMPLEMENTATION AND

CONTINUOUS IMPROVEMENTWASTE with
DECA-BDE

EMISSIONS with
DECA-BDEVECAP Europe - Annual Progress Report 2006
9 ➜Once the improvement plan is implemented,
operational results are evaluated and potential
for further emission reductions investigated,ensuring effective continuous improvement.

VECAP V

THE VECAP PROCESS
Continuous Improvement
VECAP
Commitment

1
User
Procedures

2

6
User
Self-audit

Improvement
Implementation

Supplier
Support3

5
Mass
Balance

Improvement
Plan

4
Emission
ReportThird party
Audit

External
Reporting

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VECAP V

2004-2006 Developmentsof the VECAP programme
COMMITMENTS TO APPLYVECAP PRINCIPLES

PLASTICS:
48 vol.% of Deca-BDE usage for plastics in
Belgium, France, Germany, Italy, the Netherlands
and the UK is now covered by user commitments
to VECAP Code of Good Practice principles.
Initial baseline estimates are currently being
evaluated.

Commitment to VECAP is defined as a DecaBDE user formally implementing the principles
in the Code of Practice. The company thencompletes a baseline assessment of Deca-BDE
emissions from the production facility. This
forms the basis for future emission reduction
and continuous improvement.

"It is clear from the enthusiasm
and commitment which our members
have shown in implementing the
VECAP process that this is a
simple and practical scheme
which can provide immediateand significant benefits."

TEXTILES:
79 vol.% of the Deca-BDE textile users in thesix priority Member States - Belgium, France,
Germany, Italy, the Netherlands and the UK have commited to VECAP and are applying the
VECAP Code of Good Practice principles indaily operations.

John Lambert,
Secretary of the UK Textile Finishers’ Association

DECA-BDE USER COMMITMENTS TO VECAPCountry

TextilesPlastics

Present

June 2007

Present

June 2007

United Kingdom

95%

95%

73%

80%

Belgium

71%

90%

89%

90%

Netherlands

No usage

No usage

100%

100%

Germany

88%

90%

38%

80%

France

34%

90%

29%

80%

Italy

In progress*

80%

59%

80%

Above EU-6 Member
States

79%

90%

48%

85%

*Textiles < 5% Deca consumption

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RESULTSCOMMITMENT TO VECAP - TEXTILESCOMMITMENT TO VECAP - PLASTICS

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2004-2006 Developmentsof the VECAP programme
BASELINE EMISSIONSSURVEY RESULTS
Once a user has accepted the VECAP commitment, a baseline of its actual process emissions
will be determined. The objective of the baseline
is to collect data for an evaluation of the environmental performance and to obtain a reference allowing the measurement of future
improvements.

"The Environment Agency (Englandand Wales) is pleased to see
chemical producers working so
effectively with their downstream
users to introduce a process tomonitor and control emissions.
Had VECAP been a regulatory
measure, with overall UK emission
reductions of 75% in its firstyear, it would have been hailed
as a major success. That it wasachieved as an industry voluntarycommitment means that this levelof environmental protection was
attained far faster and with greatsavings. We look forward to thenext year's developments."
England and Wales Environment Agency

VECAP Europe - Annual Progress Report 2006
13 ➜TEXTILES:
United Kingdom: The UK’s Textile Finishers’
Association, TFA, carried out a baseline emissions
survey in 2004 and a second survey in 2005. In
the 2004 VECAP Survey, emission reductions of
90% were recorded in some plants compared topre-survey data. Preliminary reports from the subsequent 2005 VECAP Survey indicate an overall
75% reduction of emissions to water compared tothe baseline established by the 2004 Survey, thus
resulting in a significant overall reduction.
Belgium: 65% of Deca-BDE’s usage in the textiles
industry is now covered by VECAP in the form ofsigned commitments to the Code of Practiceprinciples. In addition, a baseline emissions survey
was completed in Q1 of 2006 covering 65% ofDeca-BDE’s usage.
France: Work with textile users of Deca-BDE isprogressing with a commitment of 34% based on
given information to determine the baseline
values.
Germany: German textile Deca-BDE users havestrongly committed to the VECAP programme,with already 88% of the total usage signed up to
the VECAP principles. 21% of the volume usedhave completed a baseline emissions survey.
Italy: Initial contacts have been made with DecaBDE users and we expect to be able to reportsignificant progress in terms of commitment andbaseline surveys. Note that textiles usageaccount for no more than 5% of total Deca-BDE
consumption in Italy.
The Netherlands: No usage of Deca-BDE has been
identified for textiles in the Netherlands

VECAP V

PLASTICS:Work on baseline surveys is underway in each of
the six selected Member States so as to provide
data by the end of 2006.
United Kingdom: In 2005, 73% of Deca-BDE
usage in the plastics sector was covered by abaseline emissions survey. These baseline estimates indicate that emissions per tonne of Deca-BDE
used are far lower (>10x) than those for theequivalent textile sector.
Belgium: 89% of the Deca-BDE usage have signed
up to the commitment to applying the VECAP
principles and techniques. A baseline emissions
survey has been completed for 52% of the volumeof Deca-BDE used.
Italy: 59% of Italian plastics usage of Deca-BDE
is signed up to the principles of the VECAP
programme. Work is under way for completion ofa Deca-BDE plastics baseline emissions survey.

Cooperation is already in progress with the
Italian plastics federation (PlasticsEurope Italia)
to further increase the % of user commitment.
France: Discussions with Deca-BDE plastic users
have recently started in France with 29% of DecaBDE usage signed up to VECAP. We expect to beable to report a first baseline survey figure after
the summer 2006.
Germany: Discussions with Deca-BDE plastic
users have recently started in Germany. 38% ofGerman plastics usage has signed up to theprinciples of the VECAP programme. Work isunder way for completion of a Deca-BDE plastics
baseline emissions survey.
The Netherlands: 100% of Deca-BDE’s plastic
usage is signed up to the VECAP principles andtechniques. All of the Deca-BDE usage in plastics
in The Netherlands has completed a baseline
emissions survey.

DECA BDE BASELINE DETERMINATIONCountry

TextilesPlastics

Present

January 2007

United Kingdom

95%**

3rd mass balance** 73%

80%

Belgium

65%

80%

52%

70%

Netherlands

No usage

No usage

100%

100%

Germany

21%

60%

In progress

40%

France34%

75%

In progress

30%

Italy

In progress

*

5%

40%

Above EU-6 Member
States

66%

75%

11%

45%

Present

January 2007

*No specific target **UK Textiles, Textile Finishers Association data
Note that these values only consider the production emissions. Other potential emissions such as waste or damaged packaging are not incorporated

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Providing Support
to VECAP users
VECAP COMPETENCE CENTRE
Companies are improving their production
processes allowing better environmental performance and helping to meet the Code ofGood Practice commitments. In order toassist Deca-BDE user companies, a need for
a competence centre was detected.
The VECAP competence centre aims toprovide answers to questions such as:
To check the effectivity of waste water
treatment, analysing Deca-BDE
concentrations might be needed,
but how should this be done?
What is the best and most representative
sampling method taking into account thatthe solubility of Deca-BDE in water isvery low?
What is the best analytic method?
What laboratories are qualified to do suchan analysis?
How should I treat wastewater in orderto remove Deca-BDE?
What is the best technology?
Should filters be used?
What is the preferable disposal option
for packaging waste?
What is an effective filter system
to prevent air emissions?

VECAP Europe - Annual Progress Report 2006
15 ➜This competence centre will be established in
2006-2007. It will be equipped not only withthe capacity to support VECAP users inaddressing their specific needs, but also tofurther improve the VECAP system itself as
it evolves and to promote operational
implementation of this pratice.

"The EOC group will certainly
benefit from VECAP, which will
ensure that everyone who is
working with flame retardantfinishing will receive the most
updated information on Deca-BDE
and the flame retardant compound.
Moreover it will strenghten the
EOC group’s environmental philosophy on emission management
and process improvement"
Wim Duyvejonck
Product Manager for EOC GROUP(Belgian textiles company)

VECAP V

VECAP TOOLKITEBFRIP has developed a toolkit to assist the
Deca-BDE downstream users to perform theself-audit and draw a mass balance. It also provides general principles to monitor and control
emissions. The toolkit is available in English,
French, Italian and German and consists of thefollowing elements:
CODE OF GOOD PRACTICE
This document includes working proceduresand good housekeeping measures aimed atcontrolling and reducing emissions
SELF-CONTROL GUIDANCE DOCUMENT
Supports users in defining where they stand inrespect of the Code provisions

Certification
External certification by an independent third
party will become operational for interested
users during 2007.
The following schedule indicates the major
milestones to achieve this target:
Technical Reference
Ready end 2006
Test audits
January – February 2007
Final adjustment of Reference& Control Plan
April – May 2007
Certification operational
Mid-2007Q&A VECAPPROCESS FLOW CHART
Assists the user to identify where the potential
material losses can occur within the processes

A Questions and Answers document will beavailable mid June 2006 via the website
http://www.bsef.com/vecap

MASS BALANCE SHEET
Indicates which data should be measured,
recorded and managed

Product Steward support

Consult http://www.bsef.com/vecap
to download the above materials.

For individual assistance to introduce VECAP
contact the VECAP Product Steward,
Paul Adriaenssens at qualipa@skynet.beor +32 475 74 34 41

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Contacts
EBFRIP Secretariat at Cefic
Avenue E. van Nieuwenhuysen 4, bte 2
B-1160 Brussels - Belgium
Tel: +32 2 676 73 38
Fax: +32 2 676 73 01
E-mail: rmo@cefic.be

BSEF Secretariat
118 Avenue de Cortenbergh1000 Brussels - Belgium
Tel. +32 2 733 93 70
Fax. +32 2 735 60 63
E-mail: mail@bsef.com
1801 K Street, NW
Suite 1000 - L
Washington DC 20006
Tel. +1 202 530 48 47
Fax. +1 202 530 45 00
E-mail: mail@bsef.com

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For further information:
contact the VECAP Product Steward,
Paul Adriaenssens at qualipa@skynet.beor visit www.vecap.info
VECAP is a voluntary initiative of the European
Brominated Flame Retardant Industry Panel - EBFRIP
together with the industry’s global organisation, theBromine Science and Environmental Forum - BSEF,
and with the support of the European Plastics
Converters - EUPC (www.eupc.org) and the European
Apparel and Textiles Organisation - Euratex(www.euratex.org).

EBFRIP
A SECTOR GROUP OF CEFIC