. 

POLYBROMINATED 

DIPHENYL ETHERS: 

RECOMMENDATIONS TO 

REDUCE EXPOSURE IN 

CALIFORNIA 

A Report of the 

Cal/EPA PBDE Workgroup 

February 2006 

California Environmental Protection Agency 

Sacramento, California

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PBDEs: Recommendations to i February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

CAL/EPA PBDE WORKGROUP 

Office of Environmental Health 

Hazard Assessment (lead) 

 

Martha S. Sandy, Ph.D., M.P.H., Chief 

(Workgroup Chair) 

Cancer Toxicology and Epidemiology 

Section 

Reproductive and Cancer Hazard 

Assessment Branch 

Lauren Zeise, Ph.D., Chief 

Reproductive and Cancer Hazard 

Assessment Branch 

Mari Golub, Ph.D. 

Staff Toxicologist 

Reproductive Toxicology and 

Epidemiology Section 

Reproductive and Cancer Hazard 

Assessment Branch 

Air Resources Board 

James Aguila 

Manager 

Substance Evaluation Section 

Air Quality Measures Branch 

Stationary Source Division 

State Water Resources Control 

Board 

Gerald Bowes, Ph.D., Chief 

Toxicology and Peer Review Section 

Division of Water Quality 

Integrated Waste Management 

Board 

Bobbie Garcia 

Senior Integrated Waste Management 

Specialist 

Permitting and Enforcement Division 

Department of Toxic Substances 

Control 

Myrto Petreas, Ph.D., M.P.H., Chief 

Environmental Chemistry Branch 

Hazardous Materials Laboratory 

Jeffrey Wong, Ph.D. 

Deputy Director 

Science, Pollution Prevention, and 

Technology 

Cal/EPA 

Steve Hui 

Special Assistant for Scientific 

Evaluations 

Office of the Secretary 

Department of Health Services 

Michael Lipsett, M.D., Chief 

Exposure Assessment Section 

Environmental Health Investigations 

Branch 

Diana Lee, M.P.H., R.D. 

Research Scientist 

Exposure Assessment Section 

Environmental Health Investigations 

Branch 

Julia Quint, Ph.D., Chief, 

Hazard Evaluation System and 

Information Service Section 

Occupational Health Branch 

PBDEs: Recommendations to ii February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

TABLE OF CONTENTS 

Executive Summary............................................................................ 1 

Introduction......................................................................................... 5 

Background ........................................................................................ 7 

PBDEs: Chemical Identities, Production and Use ...................... 7 

PentaBDEs and OctaBDEs: Concentrations and Toxicity........... 8 

DecaBDE: Concentrations, Toxicity and Breakdown Products .. 9 

Nature and Extent of the PBDE Problem ................................. 13 

Cal/EPA Entities and DHS Past and Ongoing Activities................... 17 

 Air Resources Board ................................................................ 17 

Department of Toxic Substances Control ................................. 18 

Integrated Waste Management Board ...................................... 18 

Office of Environmental Health Hazard Assessment................. 20 

State Water Resources Control Board ..................................... 21 

Department of Health Services.................................................. 21 

Workgroup Recommendations ........................................................ 21 

Outreach and Education ........................................................... 23 

Pollution Prevention Initiatives .................................................. 26 

Measurement and Monitoring ................................................... 27 

Regulatory Initiatives ................................................................ 30 

Summary of Recommended Cal/EPA Actions .......................... 32 

References ....................................................................................... 36 

Appendix I. Summary of ARB PBDE Monitoring Data...................... 40 

Appendix II. The NTP Cancer Bioassay for DecaBDE and 

 Workgroup Cancer Potency Derivation ........................................ 42 

Appendix III. Publications and Presentations by DTSC, OEHHA, 

 and ARB: PBDE Environmental Levels, Exposures and Risks .... 44 

PBDEs: Recommendations to 1 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Executive Summary 

The manufacture, distribution and processing of products containing 

pentabrominated diphenyl ether (pentaBDE) and octabrominated diphenyl ether 

(octaBDE) flame retardants will be prohibited in California as of June 1, 2006 

(California Health and Safety Code Sections 108920 et seq.); only products 

manufactured after June 1, 2006, are subject to the prohibition. This prohibition 

was prompted by findings that exposures to polybrominated diphenyl ethers 

(PBDEs) are widespread, and may pose health risks. However, the

manufacture, distribution and processing of products containing the most 

commonly used PBDE mixture, decabrominated diphenyl ether (decaBDE), has 

not been prohibited. PentaBDEs and octaBDEs are ubiquitous and Californians 

will continue to be exposed to them after June 1, 2006. On May 27, 2005 the 

California Environmental Protection Agency (Cal/EPA) Secretary directed the 

formation of a workgroup of representatives from Cal/EPA Boards, Departments 

and Office (BDO) to consider the nature and extent of the PBDE problem and to 

recommend actions Cal/EPA could take to mitigate exposures to reduce risks of 

potential PBDE health effects. The California Department of Health Services 

(DHS) also contributed expertise and provided representatives to the Cal/EPA 

PBDE Workgroup. This report was prepared in response to the Cal/EPA 

Secretary’s directive. 

The principal focus of this report is to address continuing exposures of 

Californians to PBDEs after June 1, 2006. The report provides information on 

PBDEs and briefly summarizes past and ongoing Cal/EPA BDO and DHS 

activities related to PBDEs. Based on this preliminary evaluation, the Cal/EPA 

PBDE Workgroup proposes specific steps to be taken by Cal/EPA BDOs and 

DHS to reduce PBDE exposures. 

PBDEs have been widely used as flame retardants in home and office building 

materials, motor vehicles, electronics, furnishings, textiles, high-temperature 

plastics and polyurethane foams. The general public is exposed to PBDEs 

through the use of consumer products in homes, offices, cars and schools. 

Exposures to PBDEs in some occupational settings, e.g., in computer recycling 

facilities, can be much higher than those of the general public. As consumer 

products are used and after they are discarded, PBDEs are released into the 

environment where they can bioaccumulate in wildlife and food animals. PBDEs 

have been measured in house and office dust, indoor air, plant and animal-based 

foods, terrestrial and marine animals, and in human breast milk, blood and fat. 

The levels of PBDEs measured in humans in the US and Canada are typically at 

least 10 times higher than those in Europe, and appear to be doubling every few 

years. Cal/EPA scientists have reported the highest tissue concentrations of 

PBDEs measured in the world in California wildlife (shorebird eggs and fish), and 

rapid accumulation of PBDEs in the tissues of San Francisco Bay harbor seals. 
PBDEs: Recommendations to 2 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

PBDEs have structural similarities to polybrominated and polychlorinated 

biphenyls (PBBs and PCBs), and to certain other persistent polyhalogenated 

organic pollutants. In the limited toxicity testing to date, PBDEs have produced 

some of the toxic effects and physiologic changes typical of many persistent 

polyhalogenated organic pollutants, in particular the PBBs and PCBs. These 

effects include developmental and nervous system toxicity, as well as mimicry of 

estrogen and interference with the activity of thyroid hormone. These effects are 

observed in experiments with octaBDE and pentaBDE. DecaBDE has been 

shown in one study in mice to cause similar toxic effects on the developing 

nervous system as pentaBDE. Although PBBs and PCBs are both carcinogenic, 

neither pentaBDEs nor octaBDEs have been tested for carcinogenicity. 

DecaBDE is not affected by the recent legislation and its use and release into the 

environment will continue unabated. Direct exposure to decaBDE appears to 

pose lower human health risks than those of the other PBDEs, due to its lower 

toxicity, absorption, and generally lower environmental concentrations. Still, 

decaBDE is the predominant PBDE measured in house and office dust, and the 

risk from such exposures requires further evaluation. Also, levels of decaBDE 

found in sewage sludge suggest that decaBDE from the indoor environment is 

released through municipal sewage systems into the environment. 

Use of decaBDE may result in human exposure to lower brominated PBDEs of 

greater toxicological concern, such as the pentaBDEs and octaBDEs. Recent 

studies indicate that decaBDE breaks down by the actions of sunlight, heat, and 

bacteria to these and other PBDEs that contain fewer bromine atoms. Such 

compounds are also formed through metabolism in certain animals consumed by 

humans (i.e., fish and chicken). These lower brominated PBDE congeners can 

undergo further debromination. In addition, during combustion of plastics 

containing decaBDE and other PBDEs (e.g., incineration), brominated dioxins 

and related compounds may form. 

After June 1, 2006, exposures in California to pentaBDEs and octaBDEs that 

result from new products should decrease. Nevertheless, exposures due to 

building materials, furnishings, and consumer products produced before June 1, 

2006, containing pentaBDE and octaBDE flame retardants will continue for years 

to come. These releases will result in ongoing exposure to and increased 

bioaccumulation of the prohibited PBDEs by humans and wildlife. The 

workgroup has made numerous recommendations to reduce the continuing 

exposures to PBDEs, including pentaBDEs, octaBDEs, and decaBDEs. The 

main recommendations are given in the table below. 
PBDEs: Recommendations to 3 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Main Recommendations to Reduce PBDE Exposures1

 Outreach and Education 

 Educate key governmental officials and the public about the PBDE 

prohibition and hazards to encourage compliance with the prohibition and 

exposure reduction behavior. This would include development of 

educational materials such as fact sheets. 

 Pollution Prevention 

 Encourage the purchase of PBDE-free products. 

 Measurement and Monitoring2

 

 Conduct human biomonitoring to evaluate the effectiveness of the 

pentaBDE and octaBDE prohibition and other PBDE reduction efforts. 

 Conduct environmental monitoring to identify sources, pathways and 

trends in PBDE levels, and to characterize the environmental fate of 

decaBDE. 

 Regulatory Initiatives 

 Develop health guidance levels (e.g., reference exposure levels) for 

PBDEs to aid in establishing acceptable environmental levels. 

 Assess the need for further regulation, such as the development of 

hazardous waste criteria and management and disposal requirements and 

practices for PBDE contaminated waste, an Airborne Toxic Control 

Measure, the addition of PBDEs to the Air Toxics “Hot Spots” list, and the 

need to limit the use of decaBDE. 

1

Subject to available funding.

2

DTSC will provide guidance to other Cal/EPA BDOs for the sampling and chemical 

 analyses of PBDEs in environmental matrices.

Recommendations include near-term actions intended to reduce PBDE 

exposures through outreach and education, and voluntary pollution prevention. 

Longer-term recommendations include further environmental monitoring of PBDE 

levels to increase the scientific base for decision-making, and consideration of 

specific regulatory actions. All of the Workgroup’s recommendations for Cal/EPA 

action are summarized on page 32. For each recommended action the 
PBDEs: Recommendations to 4 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

estimated timeframe for implementation and the responsible BDOs are indicated. 

In recommending these specific steps for Cal/EPA to reduce PBDE exposures 

and health risks, the Workgroup explicitly did not address the availability of state 

resources for their implementation. The majority of these recommendations 

cannot be acted upon without the provision of additional resources. This 

requirement for additional resources needs to be addressed as Cal/EPA 

evaluates and chooses recommendations to implement. 
PBDEs: Recommendations to 5 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Introduction 

With the passage of Assembly Bill 302 (2003 Legislative Session, chaptered as 

California Health and Safety Code (H&SC) Sections 108920-108923, California 

became the first state in the nation to prohibit the use in commerce of products 

containing pentabrominated diphenyl ethers (pentaBDEs) and octabrominated 

diphenyl ethers (octaBDEs). PentaBDEs and octaBDEs are two of the three 

common commercial mixtures of polybrominated diphenyl ether (PBDE) flame 

retardants. PentaBDEs and octaBDEs were originally scheduled for phase-out in 

California in 2008. In 2004, the Legislature accelerated the timeframe for the 

PBDE phase-out by prohibiting the use of pentaBDEs and octaBDEs as of June 

1, 2006. No product may be manufactured, processed or distributed in 

commerce in California after that date if it contains more than 0.1% of pentaBDE 

or octaBDE; only products manufactured after June 1, 2006, are subject to the 

prohibition. However, use of the third major PBDE mixture, decabrominated 

diphenyl ether (decaBDE), has not been restricted by this or any other legislation 

in California. 

This legislation was prompted by the findings that exposures to PBDEs are 

widespread, and that levels of these compounds have been doubling in human 

tissues and breast milk every few years. Some of the highest levels of PBDEs 

measured worldwide have been in California human and wildlife populations. 

Figure 1 shows the high and increasing levels measured by DTSC in Harbor 

Seals in the San Francisco Bay. 

Figure 1. PBDEs in San Francisco Bay Harbor Seals* 

10

100

1000

10000

1988 1990 1992 1994 1996 1998 2000

Concentration, ng/g fat

 * Source: She et al. 2003 

Exposures to PBDEs in the womb or early in life have affected the developing 

nervous system, and caused thyroid hormone disruption and male and female 
PBDEs: Recommendations to 6 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

reproductive toxicity in animal toxicology studies (McDonald, 2005). PBDEs 

have not been adequately studied for their potential to cause cancer, but some 

evidence suggests they may have carcinogenic potential. Human tissue and 

blood levels of PBDEs measured in the U.S. and Canada during the past few 

years have typically been at least 10 times higher than those in Europe, where 

both the European Union (EU) and Scandinavian countries have prohibited the 

use of pentaBDEs and octaBDEs. Therefore, there is reason for concern about 

their potential health risks in humans. 

Although products containing pentaBDEs and octaBDEs produced after June 1, 

2006, will be prohibited from commerce after that date, exposure to them will 

continue due to their presence in hundreds of consumer products in homes, 

workplaces and motor vehicles. Further, the continued use of decaBDE may 

pose health risks either directly or through breakdown products. The Cal/EPA 

Secretary directed the formation of a workgroup of Cal/EPA Boards, 

Departments and Office (BDO) representatives to consider the nature and extent 

of the PBDE problem and to recommend actions Cal/EPA could take to mitigate 

the exposure to PBDEs. The California Department of Health Services (DHS) 

contributed expertise and provided representatives to the Cal/EPA PBDE 

Workgroup as well. 

This report of the Cal/EPA Workgroup provides information on PBDEs and 

makes recommendations to characterize the extent to which Californians are 

exposed to PBDEs and to reduce those exposures. Specifically the Workgroup: 

 Summarizes what is known about decaBDE toxicity and environmental 

and human tissue concentrations, as well as its potential to breakdown to 

more hazardous chemicals; 

 Summarizes environmental measurements in California of pentaBDEs and 

octaBDEs; 

 Characterizes the problem posed by legacy pentaBDEs and octaBDEs 

and continued use of decaBDE; 

 Outlines ongoing activities of Cal/EPA BDOs and DHS; and 

 Recommends further actions Cal/EPA can take to limit PBDE exposures 

in California. 

This report presents neither a comprehensive literature review nor a risk 

assessment for PBDEs. Rather it summarizes information from the scientific 

literature to provide a context for the recommendations that follow. 

In developing these recommendations, the Workgroup did not address the 

availability of state resources for implementation. The majority of these 

recommendations cannot be acted upon by individual Cal/EPA BDOs without the 

provision of additional resources for this purpose. This is a serious constraint 

that must be addressed as Cal/EPA evaluates, prioritizes and chooses 

recommendations for implementation. 
PBDEs: Recommendations to 7 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Background 

PBDEs: Chemical Identities, Production and Use 

PBDEs are diphenylethers with bromines attached, as illustrated in Figure 2 

below. The number and the placement of the bromine atoms determine the type 

of PBDE. Figure 2 shows a non-substituted diphenyl ether and then as an 

example, one congener with five bromine atoms attached, 2,2',4,4',6-

pentabromodiphenylether. There are 209 individual chemical congeners within 

the chemical class of PBDEs. 

 

Figure 2. Diphenyl ether structure 

O

Br

Br Br Br

Br

2,2',4,4',6-Pentabromodiphenylether

(PBDE-100)

O

Diphenyl ether

The chemical properties depend on the number of bromines, other substituents, 

and their ring positions. PBDEs have been widely used as flame retardants: The 

bromine atoms in the PBDEs quench flames by scavenging electrons. 

Historically, three commercial mixtures of the PBDEs have been manufactured 

and used – the penta, octa, and decaBDE formulations. Among the several 

different PBDE congeners found in the pentaBDE formulation, the average 

number of bromines is five. Similarly, the average number of bromines is eight 

among the congeners present in the octaBDE formulation. DecaBDE (i.e., 

“PBDE 209”) is a diphenylether that is fully substituted with bromines, although 

the commercial decaBDE formulation also contains other congeners. 

PBDEs have been widely used in consumer products, including electronic 

equipment, fabrics, and polyurethane foam. When used as flame retardants, 

PBDEs are not chemically reacted with or bound to the product (e.g., 

polyurethane foam, plastics). Thus, they can and are readily released from these 

products. 

Approximately 67,500 metric tons of PBDEs are manufactured annually 

worldwide, with North America accounting for much of the world’s PBDE use. 

DecaBDE is the most widely used PBDE formulation globally, with annual 

demand of 24,500 metric tons in the American market. The pentaBDE 

formulation has been used almost exclusively in North America, at a rate of 
PBDEs: Recommendations to 8 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

approximately 7,100 metric tons per year. Use of the octaBDE formulation has 

been considerably less than that of the pentaBDE formulation. In the U.S., 

manufacture of the pentaBDE and octa BDE formulations stopped in 2005. 

The pentaBDE formulation contains the four congeners thought to be most 

bioaccumulative (PBDE 47, 99, 100, 153). These four congeners have become 

ubiquitous in the environment worldwide, and are found in wildlife and human 

tissue. 

PentaBDEs and OctaBDEs: Concentrations and Toxicity 

Environmental Levels and Human Exposure to 

 PentaBDEs and OctaBDEs 

PBDEs have become ubiquitous in air, sediments, wildlife and human tissues. 

Levels of pentaBDEs are consistently observed in breast milk, serum and 

adipose tissue throughout the world. The highest levels have been measured in 

the U.S. and Canada. Estimates of the half-lives in humans for these congeners 

range from 3.5 to 7.2 years. This in part explains the steady increase in human 

tissues over time of these PBDE congeners. 

In 2004, the Air Resources Board (ARB) conducted ambient air monitoring for 

PBDEs, including a tetraBDE (PBDE 47) and a pentaBDE (PBDE 99) congener, 

at six urban sites within California (Los Angeles, Oakland, Richmond, Riverside, 

San Jose, and Wilmington). Appendix I summarizes the findings of ARB’s air 

monitoring effort. Concentrations of the tetraBDE ranged from 7-170 pg/m3

. 

Concentrations of the pentaBDE ranged from 3-332 pg/m3

. For comparison, 

outdoor concentrations of various PBDE congeners have been found to range 

from 5-300 pg/m3

 in other parts of the world. 

In 2004, the ARB contracted with the University of California at Davis (UCD) to 

conduct indoor air monitoring for PBDEs inside a computer training room 

containing 13 personal computers manufactured before 2000 (See Appendix I). 

Indoor air concentrations of PBDEs, mostly PBDE 47, ranged from 4-1,600 pg/m3 

in this room. For comparison, other researchers have measured indoor air 

concentrations of PBDEs up to 1,800 pg/m3

 (Hites, 2004). Analysis of dust from 

the room’s carpet indicated that PBDEs were present in the dust at 10 ppm, and 

that decaBDE was the predominant congener. 
PBDEs: Recommendations to 9 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Toxicity of PentaBDEs and OctaBDEs 

Because of the structural similarity between PCBs and PBDEs, toxicological 

studies of PBDEs have focused on endpoints known to be induced by PCBs. For 

one pentaBDE congener, dioxin-like effects of metabolic enzyme induction and 

specific effects on the liver, thymus and immune systems were found to occur 

only at relatively high doses in rats (Fowles et al., 1994). In contrast, effects on 

thyroid are seen at fairly low doses (e.g., 0.8 mg/kg) (Zhou et al., 2001; Fowles et 

al., 1994). Estrogenic activity is also been observed for pentaBDEs and 

hexaBDEs (Meerts et al., 2001), and testicular and ovarian effects have been 

reported at a low dose (0.06 mg/kg) for a pentaBDE (Kuriyama et al., 2005; 

Talsness et al., 2005). The tissue concentration in rodents associated with this 

low dose was relatively close to that observed in some humans. Effects on the 

developing nervous system of mice have been observed after exposure to 

several PBDEs (Viberg et al., 2003a and b; Viberg et al., 2002; Eriksson et al., 

2002). HexaBDE and pentaBDE had greater potency than tetraBDE and 

decaBDE. 

Estimated ratios of tissue concentrations producing effects in rodents compared 

to those in highly exposed people in the U.S. tend to be small for the penta 

isomer PBDE 99 (McDonald, 2004, 2005). In other words, the levels of PBDEs 

detected in the tissues of people most exposed overlap with those seen in 

experimental animals in which toxic effects have been observed. This is in part 

due to its considerably longer half-life in humans compared to rodents (3-7 years 

versus 24-42 days). Several other PBDEs have relatively long half-lives in 

humans. 

Carcinogenicity testing of additional PBDE congeners (PBDE-47, PDBE 153) and 

of the pentaBDE technical mixture is presently in the planning phase at the 

National Toxicology Program (under the auspices of the National Cancer 

Institute). Based on the structural similarities of PBDEs to certain other 

polyhalogenated organic compounds, some pentaBDEs and other PBDEs are 

expected to possess carcinogenic activity. 

 

DecaBDE: Concentrations, Toxicity and Breakdown Products 

Use of decaBDE, the most widely used PBDE, is not addressed by California 

H&SC Sections 108920 et seq. Prohibition of certain uses of decaBDE has been 

proposed within the EU, but thus far the EU has not limited its use. These 

decisions reflect a lower concern for the toxicity of decaBDE, although toxicity 

testing of this congener has been limited and uncertainties remain. DecaBDE 

does break down in the environment to more toxic chemicals; however, the 

identities, rates of formation, and toxicities of decaBDE breakdown products have 

not yet been adequately characterized. What is known about the possible 
PBDEs: Recommendations to 10 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

exposures in California and health risks of decaBDE is summarized below, along 

with information on its breakdown into more hazardous lower brominated 

congeners. 

Environmental Levels of DecaBDE 

In 2004, the ARB conducted ambient air monitoring of decaPBDE at the same six 

urban sites for the two congeners mentioned previously (see Appendix I). 

Concentrations of the decaBDE congener ranged from 7-72 pg/m3, with an 

average monitored concentration of 23 pg/m3

. Thus exposure to the general 

population from breathing outdoor air may be low (e.g., <10-5 μg/kg-day). 

Working with UCD, the ARB also found decaBDE as the major component in air 

samples in the vicinity of two facilities: an indoor electronics recycling facility 

without air pollution control equipment, and an outdoor automobile shredding 

facility (see Appendix I). Inside the electronics recycling facility, air 

concentrations of PBDEs, mostly decaBDE, ranged from 5 – 830,000 pg/m3 (the 

highest concentration is associated with a dose of roughly 0.1 μg/kg-day for 

workers in the facility). Outdoor concentrations ranged from 1 – 11,000 pg/m3

. 

For comparison, other researchers have measured up to 200,000 pg/m3

 inside a 

Canadian electronics recycling facility. At the automobile shredding facility, 

fence-line air concentrations of PBDEs, mainly decaBDE, ranged from 0.2 – 

1,900 pg/m3

 (upper bound dose < 0.001 μg/kg-day). The scientific literature does 

not contain any similar studies on autoshredder operations for comparison. 

Additional contract studies with UCD were conducted in 2004 by the ARB, 

measuring PBDE concentrations in the air and carpet dust of a computer training 

room containing 13 personal computers manufactured before 2000 (See 

Appendix I). While PBDE 47 was the predominant PBDE in indoor air samples, 

decaBDE was predominant in carpet dust. The carpet dust contained 10 ppm 

total PBDEs, which is consistent with findings of other researchers (EWG, 2004). 

A new piece of the same type of carpet was analyzed and found to contain 0.1 

ppm of decaBDE. ARB is currently conducting chamber studies to more 

accurately characterize the release of PBDEs from personal computers. 

PBDEs are present in house dust and clothes dryer lint, with the most abundant 

congener found being decaBDE. Young children, and in particular, toddlers, are 

among those most likely to receive the highest exposure to the house dust 

through floor activities and hand-to-mouth behaviors. If one makes high end 

assumptions for dust consumption by toddlers and assumes a dust concentration 

of 10 ppm decaBDE, an estimated dose for toddlers of 0.2 μg/kg-day for 

decaBDE from dust is obtained, which is comparable to occupational exposures 

at the electronics recycling facility noted above. Further assessment of the 

potential for decaBDE exposure via house dust is needed, particularly for young 

children. 
PBDEs: Recommendations to 11 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

DecaBDE has also been found in foods, including fish and soy milk, at relatively 

low levels. DecaBDE has been measured in wildlife throughout the world, 

including birds and bears from polar regions, Swedish peregrine falcon eggs, 

freshwater fish, Belgian foxes, and rats at an urban dump site. These data 

demonstrate the potential for decaBDE to distribute throughout the food web. 

DecaBDE has been measured in non-occupationally exposed individuals’ blood 

and breast milk. Given the relatively short half-life in humans (15 days) 

estimated for decaBDE (Thuresson et al., 2006), these observations suggest that 

exposure to decaBDE occurs on a regular basis in the general population. 

DecaBDE has also been measured in the blood of electronics dismantling 

workers. Still the highest decaBDE level measured in 23 breast milk samples in 

Texas was 8.24 ng/g lipid; decaBDE was not detected in 16 of the samples 

(Schecter et al., 2003). At the highest value measured, the Workgroup estimates 

that a young infant would consume an amount of 0.07 μg/kg-d decaBDE through 

nursing. 

Toxicity studies of DecaBDE 

DecaBDE has been assessed in animal studies investigating potential impacts 

on the developing nervous system and birth defects and other fetal harm. In one 

study, decaBDE given to mice caused irreversible changes in brain function 

which worsened with age. The effect was observed in mice given the compound 

on the third day after birth, but not on the 10th or 19th day after birth. The dose of 

20,100 μg/kg-day caused the effect but not a dose of 2,200 μg/kg. DecaBDE 

was less potent in causing this effect than tetraBDE, hexaBDE or penta BDE 

(Viberg et al., 2003b; Viberg et al., 2002). 

Exposure of pregnant rats to 1,000,000 μg/kg body weight of decaBDE caused 

delayed hardening of bones in their offspring (Norris et al., 1975). Other studies 

of developmental (Hardy, 2002), subchronic and chronic toxicity (National 

Toxicology Program, 1986) essentially reported no non-cancer effects of 

decaBDE when tested at relatively high doses (up to 1,000,000 μg/kg body 

weight). 

Thus, for non-cancer toxicity studies conducted to date, the dose causing an 

effect in the most sensitive study (Viberg et al., 2003b) was 20,100 μg/kg-day 

and no effects were seen at 2,200 μg/kg-day. 

 

Based on the structural similarity of PBDEs with polybrominated biphenyls 

(PBBs) and other structure-activity considerations, decaBDE would be expected 

to be one of the least active congeners with regard to carcinogenicity. Further, 

decaBDE is not readily absorbed by the body, in contrast to the lower brominated 
PBDEs: Recommendations to 12 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

PBDE congeners, which are readily absorbed and also have a longer half-life in 

the body. 

DecaBDE has been tested for carcinogenicity by the National Toxicology 

Program (NTP, 1986) and Dow Chemical (Norris et al., 1975). In the Dow 

Chemical studies in rats no significant tumor findings were observed. In the 

subsequent NTP studies conducted at higher doses, decaBDE induced nonmalignant liver tumors in rats of both sexes, and NTP concluded this provided 

“some evidence” of carcinogenicity in these animals. NTP (1986) concluded that 

there was “equivocal evidence” of carcinogenicity in male mice based on findings 

of thyroid and liver tumors that were marginally significant statistically. In female 

mice, there was little evidence of carcinogenicity. The NTP study is discussed in 

greater detail in Appendix II. 

 

In reviewing the carcinogenicity evidence for decaBDE, the International Agency 

for Research on Cancer concluded that there is “limited evidence” for the 

carcinogenicity of decaBDE in animals (IARC, 1990), essentially due to the 1986 

NTP findings. 

To facilitate screening analyses, the Workgroup calculated an upper bound 

cancer potency for decaBDE from the NTP study (i.e., 0.00108 (mg/kg-day)-1; 

see Appendix II). 

 Screening Level Risk Considerations for Direct DecaBDE Exposures 

While the exposure and toxicity data are limited for decaBDE, it is still instructive 

to compare doses causing effects in the sensitive animal experiments to human 

dose levels from environmental and occupational exposures. For non-cancer 

effects, the decaBDE dose observed to cause no effect in the most sensitive 

experiment to date - that on the developing nervous system (2,200 μg/kg) - can 

be compared to doses associated with human exposures. The experimental 

dose causing no effect is roughly 30,000 times the dose calculated for a day of 

breast feeding by human neonates (0.07 μg/kg-d, see above); the value is 

10,000 times that associated with toddler consumption of dust contaminated at 

10 ppm on a given day. Further characterization of the predicted doses to 

nursing human neonates and dust intake relative to the doses at which toxicity 

was observed in animals would be included in a more detailed assessment. 

Assuming chronic exposures to levels observed in ambient air, inside recycling 

facilities, or outside near recycling facilities results in cancer risk estimates below 

10-6, and large margins of exposure when compared with doses causing effects 

in animal studies. This suggests that, given the current state of scientific 

knowledge, directly breathing decaBDE is not likely to be a significant health 

concern for workers or the general public. Levels received via food or mother’s 

milk also appear to be relatively low. However, a more reliable assessment 
PBDEs: Recommendations to 13 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

comparing tissue concentrations in laboratory animals and humans is needed. 

Also, other exposure scenarios, such as exposures of the general population and 

young children to house dust, require a more in-depth evaluation. 

 

Breakdown of DecaBDE 

The studies of ARB and others establish that consumer products containing 

decaBDE result in release and dissemination of the chemical through the 

environment. Further, a number of studies indicate that decaBDE loses bromine 

atoms in the environment by the action of ultraviolet light, heat, and bacteria, 

forming more persistent and toxic lower brominated compounds, such as 

nonaBDEs, which are further debrominated (Soderstrom et al. 2004; Gerecke et 

al. 2005). Research presented at the Dioxin 2005 Meeting in Toronto indicates 

that decaBDE in sewage sludge may be broken down under anaerobic 

conditions by bacteria to octaBDEs and nonaBDEs. The researchers 

hypothesize that these debromination reactions also occur in sewage treatment 

facilities and in anaerobic soils and sediments. Other studies have 

demonstrated the ability of anaerobic bacteria to debrominate decaBDE to 

nonaBDEs and octaBDEs, and octaBDEs to lower brominated congeners. 

Research also indicates that decaBDE is metabolized in fish, including rainbow 

trout, and in chickens, to lower brominated congeners (e.g., nonaBDEs, 

octaBDEs, and heptaBDEs). Another potential environmental health concern, 

apart from debromination of decaBDE, is the formation of brominated dioxins and 

dibenzofurans from decaBDE during combustion (e.g., disposal via incineration 

of plastics). 

Nature and Extent of the PBDE Problem 

 Continuing Exposures 

PBDEs are ubiquitous substances present in homes, offices, and other buildings, 

and in transportation vehicles, including cars, trucks, planes and mass transit 

vehicles. The general population comes into contact with materials containing 

PBDEs in nearly every indoor microenvironment through the use of PBDEs in 

building materials, carpets, textiles, electronics, flooring, mattresses, foam 

furniture, and high temperature plastics. As a consequence of the pervasiveness 

of PBDEs in the indoor environment, people are directly exposed to these 

bioaccumulative chemicals for that portion of time spent indoors, which has been 

estimated by the ARB to range from 85% - 90% of each day. Thus, these direct 

human exposures make PBDEs strikingly different from other recognized 

persistent bioaccumulative chemicals, for which diet represents the primary route 

of exposure. PBDEs are measured in indoor air, and in house and office dust. 

PBDEs have been detected in some foods, and in ambient air, especially near ewaste recycling and autoshredder facilities. 
PBDEs: Recommendations to 14 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Figure 3. Increasing PBDE Human Serum Levels in the U.S.* 

0

20

40

60

80

100

1982 1987 1992 1997 2002

Collection year

ng/g lipid

Each point 

represents ~200 

people

Each point 

represents ~10 

people

0

20

40

60

80

100

1982 1987 1992 1997 2002

Collection year

ng/g lipid

Each point 

represents ~200 

people

Each point 

represents ~10 

people

 *Source: Sjodin et al., 2003 

Recent scientific reports have shown that PBDEs are rapidly accumulating in 

human tissues (Figure 3). This was first observed in 1998 in Sweden, which has 

a national breast milk monitoring program. Based on several small studies, the 

levels of PBDEs measured in humans in Canada and the US are typically 10 

times or more greater than in Europe (Table 1; Figure 4), and appear to be 

doubling every few years. 

Figure 4. Distribution of PBDE levels among U.S. women* 

*Source: McDonald, 2005 

Biomonitoring data indicate that individuals have measurable levels of decaBDE 

in their blood. Unlike most of the PBDE congeners, the fully brominated 
PBDEs: Recommendations to 15 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

decaBDE does not bioaccumulate. Thus, the finding of decaBDE in blood 

samples obtained from the general population indicates that people experience 

repeated continuous exposures to decaBDE. In addition, Cal/EPA scientists 

have found the highest tissue concentrations of PBDEs in the world in California 

wildlife (shorebird eggs and fish), and have reported rapid accumulation of 

PBDEs in the tissues of San Francisco Bay harbor seals (Figure 1 above). 

Table 1. Mean Concentrations of PBDEs in Humans in the U.S. and Three 

European Countries 

Country Mean PBDE body 

burden (ng/g lipid) 

References 

United States 90.3 McDonald 2005 

Sweden 6.03 Bavel et al. 2002 

Spain 4.12 Meneses et al. 1999 

Finland 2.30, 11.7 Strandman et al. 1999, 2000 

With the coming prohibition in California of products manufactured on or after 

June 1, 2006 containing pentaBDEs and octaBDEs, exposures to these PBDEs 

should decrease over time but will nonetheless continue for many years through 

the continued use of existing building materials, furnishings, and consumer 

products. Recycling and disposal of materials containing pentaBDEs and 

octaBDEs will also result in continuing exposures. 

It should be noted that the June 1, 2006 prohibition, while banning the 

introduction of new sources of pentaBDEs and octaBDEs into the state, will not 

alter exposures arising from materials and consumer products currently in use. 

In fact, exposures will continue for years. Moreover, it is possible that new 

sources of pentaBDEs and octaBDES will continue to be introduced into 

California after the effective data of the ban because California H&SC Sections 

108920 et seq. do not specify how the pentaBDE and octaBDE prohibition will be 

enforced. In such cases, the Attorney General’s Office usually assumes the 

responsibility of enforcement; however, at this time it is not clear whether the 

Attorney General’s Office has the resources to enforce the relevant statutory 

provisions. Nor is it clear whether the Attorney General’s Office would require the 

technical assistance of any of the Cal/EPA BDOs in this regard. As noted above, 

tissue PBDE concentrations producing effects in rodents overlap with existing 

human tissue concentrations, indicating the potential for human health effects 

and an urgent need to reduce human exposure. 

DecaBDE is not affected by any legislation and its use and release into the 

environment will continue unabated. Preliminary analyses suggest that 

breakdown of decaBDE to more toxic forms is a more important concern than 

direct exposure to decaBDE, although this requires further study. While 
PBDEs: Recommendations to 16 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

exposures to decaBDE are continuous in the indoor air in homes and offices, the 

airborne concentrations are quite low. Exposure to dust in these settings may 

result in higher doses to, for example, young children, as described above. 

Further characterization of dust as a source of exposure requires a more detailed 

assessment. Levels of decaBDE found in sewage sludge suggest that decaBDE 

from the indoor environment and perhaps laundering finds its way into municipal 

sewage systems and is further dispersed in the environment. This is an example 

whereby decaBDE enters the outdoor environment, and moves into the food 

chain and into aquatic and terrestrial wildlife, along with the debrominated forms 

it gives rise to. A growing body of data indicates that decaBDE undergoes 

debromination to lower brominated forms through sunlight, heat, bacteria, and 

through metabolism as it progresses through the food web. Several of these 

lower brominated forms are bioaccumulative. 

Co-Exposures to PCBs and similar classes of chemicals 

PBDEs have structural similarity to PBBs, PCBs, and certain other persistent 

polyhalogenated organic pollutants. In the limited toxicity testing to date, PBDEs 

have produced some of the toxic effects and physiologic changes seen with 

many persistent polyhalogenated organic pollutants, in particular the PBBs and 

PCBs. These effects include developmental and nervous system toxicity, as well 

as mimicry of estrogen and interference with the activity of thyroid hormone. 

These observed similarities in the toxicological profiles suggests that PBDEs, 

PBBs, PCBs, and certain other persistent polyhalogenated organic pollutants 

may induce toxic effects via common mechanisms of action. The general 

population is exposed on a daily basis not only to PBDEs, but also to these other 

chemicals, primarily via their presence in the diet. Given this, there are concerns 

that co-exposures to PBDEs and certain of these other persistent 

polyhalogenated organic pollutants may be additive, and that total levels of 

exposure to these compounds may be close to the point where frank 

developmental toxicity may occur in more highly exposed individuals (McDonald, 

2005). To date, only one study has investigated the effect of co-exposures in 

animals. In this study a greater than additive effect of PBDE 99 and PCB 52 was 

observed for effects on the developing nervous system (Eriksson et al., 2003). 

Waste Disposal/Recycling Issues 

Assembly Bill 2587 (2004 Legislative Session, chaptered as California H&SC 

Sections 108920-108923) does not restrict the disposal of waste containing 

PBDEs. Other countries that have restricted the use of PBDEs have not 

addressed waste disposal. To date, the Workgroup has not identified any 

measures or procedures that have been implemented for PBDE waste disposal 

by other countries. California should continue to monitor future activities of 

others with regard to PBDE waste disposal. 
PBDEs: Recommendations to 17 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Nonetheless, there is a need to identify the waste streams containing PBDEs, 

and determine which contribute to release of PBDEs into the environment. 

Measurement and monitoring studies are needed to investigate this. While 

Assembly Bill 2587 prohibits the processing of products manufactured on or after 

June 1, 2006 that contain more than one-tenth of one percent pentaBDEs or 

octaBDEs, it does allow metallic recyclables containing PBDEs (pentaBDEs and 

octaBDEs) to be processed for recycling or reuse, which includes automobiles, 

metal furniture, major appliances, and electronic products. Studies to date 

suggest that e-waste recycling facilities are significant sources of PBDEs 

released into the ambient air. Autoshredder facilities have also been shown to 

release PBDEs into the ambient air. California should characterize these 

exposure pathways more fully. 

Another need is to investigate the fate and transport of PBDEs via municipal 

waste water systems and the use of sewage sludge, especially regarding 

releases into the aquatic environment. 

In addition to autoshredder and e-waste, PBDEs released from the processing 

and disposal of a variety of products should also have their exposure pathways 

characterized. PentaBDEs are found in mattresses, foam packaging, cushioned 

furniture, and carpet padding; octaBDEs acrylonitrile butadiene styrene (ABS) 

plastic, housings for fax machines, computers and other electronic equipment, 

telephone handsets, small electronics parts, and electric cable; decaBDE is 

found in housings for TVs, and other electronics, textile backings (curtains, 

upholstery covering), electrical boxes, wiring, and high impact polystyrene (HIPS) 

plastic. 

In summary, exposures of the general public to PBDEs occur through the use of 

consumer products and furnishings in homes, offices, cars and schools. As 

these consumer products are used and after they are discarded, PBDEs are 

released into the environment where they can bioaccumulate in wildlife and food 

animals. 

Cal/EPA Entities and DHS Past and Ongoing Activities 

Air Resources Board 

As described in Appendix I and elsewhere in this report, ARB has conducted air 

monitoring to aid the characterization of PBDE pathways of exposure and the 

extent of exposure to total PBDE and the different PBDE congeners. ARB has 

reviewed its regulatory authority and found that PBDEs fall within the class of 

polycyclic organic matter, which has been designated as a Toxic Air Contaminant 

under H&SC sections 39660 et seq. 
PBDEs: Recommendations to 18 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Department of Toxic Substances Control 

DTSC’s Hazardous Materials Laboratory has pioneered measurements of 

PBDEs in human tissue and wildlife in the U.S. DTSC first reported the 

exponential increase of PBDEs in harbor seals from the San Francisco Bay that 

occurred between 1988 and 1998 (She et al. 2002). Moreover, DTSC reported 

that levels of PBDEs in California human adipose and serum samples obtained in 

the late 1990s were 30 times higher than human tissue levels reported during the 

same time period from Europe and Japan (Petreas et al. 2003). The absence of 

PBDEs in California serum dating from the 1960s reflects the recent introduction 

of PBDEs into commerce and the environment (Petreas et al. 2003). Because 

PBDE concentrations did not correlate with PCB concentrations, that study also 

suggested that other exposure pathways, such as indoor air may be significant. 

Additionally, DTSC reported that levels of PBDEs measured in California marine 

fish and seabird eggs are among the highest in the world (Holden et al. 2004; 

She et al. 2004; Brown et al. 2006). Currently, DTSC is completing a study of 

breast milk, the first such study specifically designed to identify PBDE sources of 

exposure. In addition, in an effort to identify major waste streams of concern, 

DTSC is measuring PBDEs in e-waste and autoshredder waste (Petreas et al. 

2005) as well as consumer products, using both chemical methodologies and an 

XRF screening tool (Petreas et al. 2006). DTSC has been hosting a Technical 

Working Group where scientists from government, industry, and nongovernmental organizations present and discuss the latest information on PBDEs 

and other brominated flame retardants. DTSC publications on PBDEs are 

included in Appendix III. 

DTSC plans to: 

 

 Complete ongoing PBDE research 

 Seek/obtain funds for further research 

 Develop integrated research plan with DTSC regulatory programs 

 Define waste stream management alternatives 

 Define/assess current PBDE disposal/destruction options 

 Explore changes in regulations to define PBDEs as hazardous waste 

 Develop an integrated approach to biomonitoring with Cal/EPA and DHS 

Integrated Waste Management Board 

The CIWMB has authority to regulate nonhazardous solid waste handling, 

transfer, composting, transformation, and disposal. The CIWMB does not 

characterize waste and does not restrict the handling and disposal of waste 

containing PBDEs. DTSC determines if a waste is hazardous and what 

management standards are required. The SWRCB/RWQCB determines if any 

constituents of concern contained in a waste would affect water quality and if 

specific management standards are required. At this time, no restrictions have 
PBDEs: Recommendations to 19 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

been identified by DTSC and the SWRCB/RWQCB for wastes containing 

PBDEs. 

Because PBDEs are ubiquitous substances that have been used for more than 

30 years as flame retardants in home and office building materials, motor 

vehicles, electronics, furnishings, textiles, high temperature plastics and 

polyurethane foams, they are common in the waste stream. The presence of 

PBDEs in waste materials cannot be readily discerned by solid waste facility 

operators. Should the disposal of wastes containing PBDEs eventually be 

restricted, some method for identification would need to be devised to let the 

solid waste facility operator know if the waste contains PBDE. This is especially 

important in light of the fact that diverting waste from landfills through reuse and 

recycling is a major requirement of the Integrated Waste Management Act (Act), 

and the operator needs to be able to discern when a waste has restricted 

handling. 

Nonhazardous solid waste landfills are prohibited from accepting hazardous 

wastes with few exceptions. One exception is treated wood waste, which can be 

disposed in a composite-lined portion of a solid waste landfill. Another exception 

is asbestos containing waste, which can be disposed in a designated disposal 

area at a landfill. Asbestos containing waste is cradle-to-grave manifested; 

treated wood waste is not manifested or labeled, which has the potential to be a 

problem for operators who cannot readily discern if the waste is treated or nontreated wood waste. Neither asbestos containing waste nor treated wood waste 

can be processed prior to disposal. To conserve landfill space, most landfill 

operators divert wood materials from disposal and typically ground and screen 

the wood before marketing it for reuse as a landscape product, compost 

feedstock, biomass fuel, etc. Because operators may have difficulty in discerning 

whether a waste is treated wood waste or not, treated wood waste could end up 

being processed even though this activity is prohibited. 

Used oil and electronic waste consisting of CRTs and monitors have been 

classified by DTSC as hazardous wastes and cannot be disposed in 

nonhazardous solid waste landfills, but they can all be recycled. The handling 

and management of these wastes, including recycling, fall under the authority of 

DTSC. 

In the area of pollution prevention, the CIWMB encourages the procurement of 

products that do not contain PBDEs. Examples of this include the following: 

o The CIWMB, working with the Department of General Services (DGS) on 

Strategically Sourced Statewide Contracts, added specification language as 

provided below: 

 Office Equipment: copiers and associated services; awarded July 

2005; estimated value of contract $36 million – Specification language: 
PBDEs: Recommendations to 20 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Requirement that digital copier shall contain no polybrominated 

biphenyls (PBB) or diphenyl ethers (PBDE). 

 Computer Hardware: desktop computers and workstations, notebook 

computers, printers, monitors, and peripherals; awarded June 2005; 

estimated value of contract $116 million – Specification language: 

points awarded for meeting environmental requirement that electronics 

manufacturers should demonstrate that they are complying globally 

with European Union’s Directive – Restriction of Hazardous 

Substances – which includes the phase out of certain PBDEs by 2006. 

o The CIWMB adopted the Electronic Product Environmental Assessment 

Tool (EPEAT) rating system as environmental purchasing criteria in June 

2005, which can be used by State agencies to identify electronic devices 

with reduced environmental impacts. The CIWMB has requested that the 

DGS issue a Broadcast Bulletin on the use of EPEAT by State agencies 

once EPEAT certified products are available. 

EPEAT is an environmental procurement tool that is designed to help 

institutional purchasers in the public and private sectors evaluate, compare 

and select desktop computers, laptops and monitors based on their 

environmental attributes. EPEAT was initiated through a cooperative 

agreement between the Zero Waste Alliance and US EPA Region 10. To 

qualify for EPEAT, a product must conform to 22 mandatory criteria, 

including compliance with provisions of the European Directive for the 

Restriction on use of certain Hazardous Substances in electronic products 

(RoHS Directive) that requires less than 1000 ppm PBDE within 

homogeneous materials. 

o The CIWMB is working with DGS on implementing the recently developed 

environmentally preferable purchasing (EPP) standards for carpet, called 

“the California Gold EPP Carpet Criteria.” The specifications include a 

requirement that the carpet contain no PBDE. 

Office of Environmental Health Hazard Assessment 

OEHHA has followed the emerging scientific information on the toxicity of 

PBDEs, and OEHHA staff have published several reviews and analyses of the 

available toxicity data in scientific journals. Evaluation of the available toxicity 

data on the PBDEs, including decaBDE, is ongoing, and an assessment of the 

health risks from exposures to PBDEs is underway. 
PBDEs: Recommendations to 21 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

State Water Resources Control Board 

The SWRCB has reviewed its authority and that of the Regional Boards to 

regulate PBDEs. Bioaccumulative chemicals that are harmful to aquatic 

organisms at detected levels can be regulated by the Regions. Chemicals in 

waters at levels harmful to humans can also be regulated. Further, PBDEs are 

listed in DHS’ draft groundwater recharge regulations with a number of other 

emerging chemicals because they are endocrine disruptors, found in wastewater 

treatment plant effluents (i.e., the source of recharge water), and are ubiquitous. 

The identification of acceptable sampling and analytical protocols for PBDEs 

would facilitate SWRCB efforts, as well as values for maximal allowable 

concentrations in drinking water and ground and surface waters. 

Department of Health Services 

Activities of DHS have included the following: 

 Developing over the past two years a proposal to establish a human 

biomonitoring program in California, with a strong emphasis on PBDEs. 

 Along with DTSC staff, preparing and presenting a briefing on PBDEs to 

the Secretary of Cal/EPA and senior management of the Cal/EPA BDOs. 

 Assisting Kaiser’s Women’s Health Research Institute in developing 

Developmental Toxicants and Healthy Childbearing, a physician’s guide 

that includes information on health effects, exposure sources, and 

exposure prevention recommendations for PBDEs, and other toxicants. 

The purpose of the guide is to increase physicians’ awareness of 

developmental toxicants and to assist them in taking relevant histories, 

and in addressing their patients’ concerns. 

 Participated in the Technical Working Group on PBDEs convened by 

DTSC’s Hazardous Materials Laboratory. 

 Conducted a qualitative assessment of workplace exposures to lead, 

PBDEs and other toxicants at a computer recycling facility. 

Workgroup Recommendations 

The Workgroup identified a number of recommendations that should lead to 

reductions in exposures to PBDEs as well as facilitate compliance with California 

H&SC Sections 108920 et seq. For each of the recommendations identified, 

estimated timeframes for implementation are provided. In instances where 

completion of one recommendation is necessary before other recommendations 

can be implemented, this is noted. 

In developing these recommendations, the Workgroup explicitly did not address 

issues related to the availability of sufficient state resources for implementation. 
PBDEs: Recommendations to 22 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

The Workgroup notes that the majority of these recommendations cannot be 

acted upon without the provision of additional resources. This is a serious 

constraint that must be considered and addressed as Cal/EPA evaluates which 

of these recommendations to implement. It should be noted that some of these 

recommendations would also require the involvement of DHS as well as the 

BDOs of Cal/EPA. The main recommendations are given in the table below. 

More detailed recommendations follow. 

Table 2. Main Recommendations to Reduce PBDE Exposures1

Outreach and Education 

 Educate key governmental officials and the public about the PBDE 

prohibition and hazards to encourage compliance with the prohibition and 

exposure reduction behavior. This would include development of 

educational materials such as fact sheets. 

Pollution Prevention 

 Encourage the purchase of PBDE-free products. 

Measurement and Monitoring2 

 Conduct human biomonitoring to evaluate the effectiveness of the 

pentaBDE and octaBDE prohibition and other PBDE reduction efforts. 

 Conduct environmental monitoring to identify sources, pathways and 

trends in PBDE levels, and to characterize the environmental fate of 

decaBDE. 

Regulatory Initiatives 

 Develop health guidance levels (e.g., reference exposure levels) for 

PBDEs to aid in establishing acceptable environmental levels. 

 Assess the need for further regulation, such as the development of 

hazardous waste criteria and management and disposal requirements and 

practices for PBDE contaminated waste, an Airborne Toxic Control 

Measure, the addition of PBDEs to the Air Toxics “Hot Spots” list, and the 

need to limit the use of decaBDE. 

1

Subject to available funding.

2

DTSC will provide guidance to other Cal/EPA BDOs for the sampling and chemical 

 analyses of PBDEs in environmental matrices.
PBDEs: Recommendations to 23 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Outreach and Education 

1. Educate key governmental officials and the public about the PBDE 

prohibition and hazards and work with them to encourage compliance with 

the prohibition and exposure reduction behavior. 

This would involve working with and educating state and local 

government, industry, public interest groups, and the general public about 

the PBDE prohibition and environmental concerns about PBDEs. 

Targeted state officials would include the State Fire Marshal and the 

Attorney General’s Office, as well as staff in General Services and other 

agencies responsible for developing and implementing policies related to 

purchasing and recycling. Local officials could include county health 

officers, environmental health officers and purchasing officials. 

Timeframe: These activities would begin immediately, and would continue 

as long as there are significant amounts of PBDEs in commerce or in the 

state’s waste streams. 

Departments involved: DTSC, ARB, OEHHA, SWRCB, IWMB, DHS. 

a. Develop practical information on the prohibition of the use in 

commerce of products containing pentaBDEs and octaBDEs. 

Timeframe: Fact sheets and similar documents would be completed 

and distributed/available to target audiences within six months. This 

would include development and distribution of educational materials for 

businesses, government entities, and the public regarding product 

purchasing, use and disposal. Written information would be reviewed 

and updated as needed. 

Departments involved: DTSC, ARB, OEHHA, SWRCB, IWMB, DHS. 

b. Identify at-risk workers and develop a health hazard advisory/alert for 

workers and employers. Conduct outreach and education for workers 

and employers. 

Identify and target dissemination of a worker Health Hazard Advisory 

or Alert on PBDEs to PBDE-exposed workers, including computer 

recyclers, janitors, foam fabricators, computer technicians, and to their 

unions and community-based organizations, employers, and health 

care providers. Develop a Health Hazard Advisory or Alert on PBDEs 

for workers and employers that provides practical information on health 

effects, exposure sources, safe substitutes, industrial hygiene controls, 

the prohibition of the use in commerce of products containing 

pentaBDEs and octaBDEs, and additional information resources. 

Publicize the Health Hazard Advisory or Alert by issuing a press 

release. 
PBDEs: Recommendations to 24 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Obtain California customer lists from manufacturers, importer, and 

distributors of PBDE-containing products and increase targeted 

dissemination of the Alert. 

Timeframe: Initiate educational outreach to identified groups within 

one year, and continue educational outreach as needed. 

Department involved: DHS 

c. Identify especially at-risk communities and other groups in the general 

population. Develop health hazard advisories for dissemination to 

these groups. 

High risk groups in the general public are identified through 

collaboration with community and other public interest groups, and 

targeted for dissemination of health advisories. Develop a health 

advisory on PBDEs that provides practical information on health 

effects, exposure sources, and safe substitutes, the PBDE prohibition, 

and additional information resources. 

Timeframe: Work completed within two years. 

Departments involved: OEHHA, DHS 

2. Develop building operation and maintenance “best practices” guidelines 

for PBDEs for residential and business use. Incorporate these into 

guidelines for the public, schools, businesses, state and local agencies. 

Ensure that guideline information is reflected in pertinent State indoor air 

quality programs. 

Timeframe: One year timeframe after fact sheets completed under 

“Outreach and Education,” 1.a, and update as needed. 

Departments involved: DTSC, ARB, OEHHA, IWMB, Cal/EPA, DHS 

a. Develop a set of guidelines designed to reduce PBDE exposures 

indoors. 

Based on information developed by DTSC, it appears that indoor 

exposure to dust adds appreciably to PBDE body burdens. ARB could 

develop a set of guidelines designed to reduce PBDE exposures 

indoors. Conceptually, the guidelines could contain recommendations, 

including more effective cleaning methods and vacuuming techniques 

and equipment to reduce exposure to PBDEs that adhere to dust. 

These “best practices” guidelines could be used as a model for the 

public, government agencies, businesses, and schools. 
PBDEs: Recommendations to 25 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Timeframe: Will be completed within 18 months. 

Departments involved: ARB, OEHHA, DHS 

b. Work with the Collaborative for High Performance Schools (CHPS) to 

incorporate the new PBDEs “best practices” information developed 

under 2.a above into the Best Practices Manual for green buildings for 

schools. 

CHPS, which is comprised of several state agencies, public utilities 

and other organizations, has developed a very comprehensive Best 

Practices Manual for schools on green buildings. There are multiple 

volumes to the Manual that include sections on design, purchasing, 

operations, maintenance and cleaning. The ARB could work with the 

Collaborative to have the new information on PBDEs incorporated into 

these guidelines. While the next update is scheduled for 2008, ARB 

could work to get this information included in the ongoing revisions to 

the design and construction manual to raise awareness. In addition, 

the ARB could also include the information in the Relocatable 

Classrooms volume when developed, and in training, e-bulletins, and 

other resources that CHPS publishes. (available at www.chps.net, see 

“publications”). 

Timeframe: Ongoing, but revisions to Best Practices Manual 

completed within one year. 

Departments involved: ARB, OEHHA, IWMB 

c. Work with the Sustainability Manager and the Real Estate Services 

Division of the Department of General Services (DGS) to incorporate 

the new PBDEs “best practices” information developed under 2.a 

above into DGS Management Manuals as a requirement for buildings 

to achieve the Silver level of certification. 

DGS is developing guidelines and policies, called Management 

Manuals, to facilitate the implementation of Executive Order S-20-04, 

which calls for buildings to achieve the Silver level of certification, 

according to the U.S. Green Building Council’s green building rating 

system, “Leadership in Energy and Environmental Design (LEED).” 

The IWMB could work with DGS’s Sustainability Manager and the Real 

Estate Services Division to have information on PBDEs incorporated 

into this effort. 

Timeframe: Complete within one year after fact sheets are completed 

under “1.a” above. 

Departments involved: OEHHA, IWMB, Cal/EPA 
PBDEs: Recommendations to 26 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Pollution Prevention Initiatives 

1. Encourage institutions, state and local agencies (e.g., in cities and 

counties) to buy PBDE-free products by posting fact sheets on DTSC’s 

and DGS’s Environmentally Preferable Purchasing (EPP) Web sites that 

provide examples of PBDE-free products and manufacturers, including 

information on where such products can be purchased. 

DTSC and IWMB could work with DGS to have the fact sheets posted on 

the state’s EPP Web site, which will help assure that state and local 

procurement officials know about PBDEs. 

The information used in the fact sheets would be derived from products 

completed under “Outreach and Education,” 1.a, above. 

Timeframe: Complete within one year after fact sheets completed under 

“Outreach and Education,” 1.a, and update lists as needed. 

Departments involved: DTSC, ARB, IWMB 

2. Evaluate the use of incentives for “PBDE-free” products and product 

labeling by manufacturers. 

Timeframe: Complete within one year. 

Departments involved: DTSC 

3. Offer “Environmental Leadership” awards for phase-out of PBDEs. 

Timeframe: Offer first set of awards within one year. 

Departments involved: DTSC, Cal/EPA 

4. Compile a list of safer alternatives that have been identified by other 

entities (e.g., Consumer Affairs, U.S. EPA Region IX, IWMB Household 

Hazardous Waste (HHW) safer alternatives brochure and website). 

The list of alternatives could be promoted through the activities identified 

for recommendations under “Outreach and Education” and “Pollution 

Prevention Initiatives.” 

Timeframe: Complete within one year, and update as needed. 

Departments involved: DTSC, ARB, OEHHA 

5. Work with Department of General Services (DGS) and Prison Industry 

Authority (PIA) to encourage the purchase of PBDE-free products by all 

state agencies. 
PBDEs: Recommendations to 27 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

DTSC and IWMB could work with DGS to have information on PBDE-free 

products included on DGS’s Environmentally Preferable Purchasing (EPP) 

Web site, which is part of the “Green CA” Web site, and in product 

catalogs used by purchasing agents. DTSC and IWMB could also work 

with PIA to encourage the latter organization to purchase PBDE-free 

products, since state agencies are required to purchase furniture and 

other office supplies made by the PIA. 

Timeframe: Continue ongoing effort after fact sheets completed under 

“Outreach and Education,” 1.a. 

Departments involved: DTSC, IWMB 

Measurement and Monitoring 

 

1. Initiate and implement an environmental measurement program to assess 

the effectiveness of PBDE pollution prevention measures, remediation 

activities, and regulations. 

a. Convene an Inter-Agency PBDE Exposure Workgroup to facilitate 

implementation and coordination of the environmental measurement 

and monitoring conducted by Cal/EPA. This group would assist in the 

identification of sources and pathways of exposures, identify data 

gaps, and provide guidance and input to other exposure assessment 

activities of Cal/EPA BDOs and DHS. 

Timeframe: Initiate within three months, and continue as long as 

PBDE concentrations pose an environmental health threat. 

Departments involved: DTSC, ARB, OEHHA, SWRCB, IWMB, DHS

b. Develop guidance on acceptable sampling methods and testing 

protocols for identifying PBDEs in environmental matrices. 

In the short term, DTSC will provide guidance on acceptable sampling 

methods and testing protocols for identifying PBDEs in environmental 

matrices of concern to the SWRCB. The SWRCB has requested this 

guidance in order to implement the Cal/EPA PBDE Workgroup 

recommendations on monitoring and measurement in environmental 

matrices. 

Identification by ARB and DTSC of acceptable sampling and analytical 

protocols for PBDEs in matrices of interest to Cal/EPA BDOs (e.g., air, 

ambient water, sludge, sediment, treatment plant influent, effluent). 

ARB and DTSC will help to ensure that the PBDE measurement and 

monitoring data are collected and analyzed appropriately. This 

guidance on PBDE sampling and analytical protocols will assist BDOs 
PBDEs: Recommendations to 28 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

in evaluating the reliability and comparability of current and future 

California PBDE measurement and monitoring data. 

The Environmental Laboratory Accreditation Program (ELAP) within 

DHS can use this guidance to develop a procedure to certify 

laboratories as competent in PBDE analyses. SWRCB and regional 

water boards require such certification of laboratories for PBDE 

analyses before they institute monitoring requirements for PBDEs. 

However, there currently are no certification programs in the U.S. for 

PBDEs. Therefore, the workgroup may have to develop certification 

criteria in conjunction with the State and Regional Water Boards, and 

ELAP. 

Timeframe: Complete within six months to one year. 

Departments involved: DTSC, ARB, SWRCB

c. Identify sources and pathways of PBDE exposure , including the 

importance of decaBDE. 

The Inter-Agency PBDE Exposure Workgroup would assess existing 

information on the extent of environmental PBDE contamination in 

California, identify data needs, prioritize data collection, and 

recommend additional sampling in a pilot project, to be implemented 

by Cal/EPA BDOs and DHS. The pilot project would address data gaps 

with measurements and monitoring of PBDEs, and would include 

investigation into the role decaBDE plays as a source of lower 

brominated PBDEs present in environmental matrices. This would be 

used by the Inter-Agency PBDE Exposure Workgroup to characterize 

sources and pathways of exposure. Workplace exposures to PBDEs in 

targeted industries/workplaces could be investigated using the DHS’s 

right-of-entry mandate (H&SC 105175). 

Timeframe: Complete within one to three years.

Departments involved: DTSC, ARB, OEHHA, SWRCB, DHS 

d. Characterize temporal and spatial in-situ PBDE levels, including 

decaBDE. 

A monitoring program would be implemented to track in-situ levels of 

PBDEs, including decaBDE and its breakdown products, to assess the 

effectiveness of PBDE exposure mitigation measures. For example, 

the ARB could seek funding to conduct additional outdoor and indoor 

air monitoring to better characterize temporal and spatial trends in 

PBDE concentrations throughout the state and in different indoor 

settings. This monitoring could include collecting additional PBDE data 

from ARB’s network of air toxics monitoring sites, additional near-
PBDEs: Recommendations to 29 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

source monitoring adjacent to probable sources of PBDEs, and 

additional indoor air monitoring in public buildings, schools, and 

homes. DTSC could seek funding to systematically characterize trends 

in waste streams (e.g., autoshredder, ewaste). DTSC could seek 

funding to expand its studies of PBDEs in human milk, adipose tissue, 

serum and wildlife. 

Timeframe: Complete within one to three years.

Departments involved: DTSC, ARB, OEHHA, SWRCB 

e. Archive environmental and biological samples to evaluate temporal 

trends, hotspots, and new chemicals. 

Timeframe: Initiate within one year, and continue thereafter.

Departments involved: DTSC, ARB, SWRCB 

f. Examine potential environmental and public health risks of alternatives 

and substitutes, based on biological and environmental monitoring 

data. 

In examining alternatives and substitutes for PBDE flame retardants, 

consider information on toxicity, persistence, bioaccumulation, and 

potential for environmental release. Alternative flame retardants may 

already be in use. Consider the utility of conducting pilot biomonitoring 

and environmental monitoring studies to evaluate the presence and 

persistence of these alternatives in the environment. 

Timeframe: Initiate within one year, and continue thereafter.

Departments involved: DTSC, ARB, OEHHA 

2. Provide for a systematic, representative human biomonitoring of PBDEs in 

California, which would provide for systematic collection and chemical 

analysis of human biological samples to assess exposure trends and the 

effectiveness of the exposure reductions. This may also eventually aid in 

evaluating whether such exposures are associated with specific chronic 

diseases and, where appropriate, to inform public policy intended to 

prevent such diseases. 

The value of biomonitoring has been demonstrated in other parts of the 

world, as well as in the United States. For example, biomonitoring 

programs in Europe found decreasing levels of dioxins, probably reflecting 

implementation of pollution prevention measures and emission controls. 

Timeframe: Initiate within one to three years, and continue and expand 

thereafter.

Departments involved: DTSC, OEHHA, DHS 
PBDEs: Recommendations to 30 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

3. Encourage the University of California Toxic Substances Research and 

Teaching Program (UC TSR&TP) to emphasize research on the fate and 

transport of PBDEs, especially decaBDE. 

The UC TSR&TP is a University of California Multicampus Research Unit 

supporting research on toxic substances in the environment and teaching 

graduate students through funding of grants, fellowships, and lead 

campus programs. 

Timeframe: Initiate within one year, and continue as needed.

Departments involved: DTSC 

Regulatory Initiatives 

1. Develop health values (e.g., chronic Reference Exposure Levels (cRELs)) 

for PBDEs. 

Completion of this recommendation is necessary before implementation of 

recommendations 2 and 3 can occur. 

Timeframe: Will be completed by summer 2007.

Departments involved: OEHHA 

2. Determine if there is a need to establish (1) hazardous waste criteria, and 

(2) management and disposal requirements and practices for PBDEcontaminated waste. 

Timeframe: Complete within three years.

Departments involved: DTSC 

3. Conduct a Needs Assessment to determine the appropriateness of 

developing an Airborne Toxic Control Measure (ATCM) for PBDEs, which, 

as polycyclic organic matter (POM), are already identified as Toxic Air 

Contaminants (TACs). 

Under H&SC Sections 39666 et seq., ARB could evaluate sources of 

PBDE emissions that could be controlled through development of ATCMs. 

In this case, ARB would prioritize sources, based on exposure and health 

risk characterization, and develop appropriate ATCMs to reduce exposure 

to PBDEs. However, before ATCMs could be developed, health values 

are needed to characterize health risk and allow ARB to determine the 

need for controls. OEHHA would develop health values. 

Timeframe: Complete within three to four years.

Departments involved: ARB 
PBDEs: Recommendations to 31 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

4. Consider adding PBDEs to the Air Toxics “Hot Spots” list of chemicals. 

 

The Air Toxics “Hot Spots” regulation (H&SC Sections 44300 et seq.) 

applies to stationary sources and requires self-reporting. ARB could 

conduct a rulemaking to add PBDEs to the Hot Spots list of chemicals. 

Upon implementation, this may require facilities to report use and/or 

emissions of PBDEs. 

Timeframe: Proposed rulemaking in 2006. 

Departments involved: ARB 

5. Examine evidence of toxicity and environmental fate of PBDEs, especially 

deca-BDE; evaluate the need for regulation or legislation. 

DHS could consider recommending an occupational health standard for 

the deca congener to Cal/OSHA, if warranted. 

Timeframe: Complete within one to three years.

Departments involved: DTSC, ARB, OEHHA, DHS 

6. Survey aquatic toxicity data and determine research needs for 

considerations of development of water quality standards. 

A critical prerequisite for implementation of this recommendation is for 

Cal/EPA to identify acceptable sampling and analytical protocols for 

PBDEs in matrices of interest (e.g., ambient water, sludge, sediment, 

treatment plant influent, effluent). Identification of critical pathways and 

waste streams contributing to PBDE contamination is also a prerequisite. 

Adequate funding and staff resources and Agency support would also be 

necessary before embarking on development of a regulatory program. 

Set up a contract with the Southern California Coastal Water Research 

Project (SCCWRP) to survey existing aquatic toxicity literature for PBDEs, 

identify data useful for developing standards, and recommend projects 

aimed at filling data gaps. 

Timeframe: Complete within one to three years.

Departments involved: DTSC, SWRCB 
PBDEs: Recommendations to 32 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Summary of Recommended Cal/EPA Actions 

Departments Actions 

DTSC ARB OEHHA SWRCB IWMB DHS 

Outreach and Education

1. Educate key governmental officials and the 

public about the PBDE prohibition and 

hazards and work with them to encourage 

compliance with the prohibition and exposure 

reduction behavior. (continuing timeframe) 

X X X X Lead X 

a. Develop practical information on the 

prohibition 

(6 month timeframe, update as needed) 

X X X X Lead X 

b. Identify at-risk workers, develop a health 

hazard advisory/alert, and conduct 

outreach and education for workers and 

employers (1 yr timeframe, with continuing 

outreach) 

 Lead

c. Identify especially at-risk groups in the 

general population. Develop health hazard 

advisories for dissemination to these 

groups. 

(2 yr timeframe) 

 Lead X 

2. Develop building operation and maintenance 

“best practices " guidelines for PBDEs. 

(1 yr timeframe after fact sheets completed 

under “Outreach and Education,” 1.a, and 

update as needed.)

X Lead X X X 

a. Develop guidelines to reduce PBDE 

exposures indoors, incorporating this 

guidance into “Best Management 

Practices” guidelines for operating and 

maintaining buildings. 

 (Will be completed within 18 months.)

 Lead X X 

b. Work with the Collaborative for High 

Performance Schools to have the 

information on PBDEs incorporated into 

the Best Practices Manual (BPM) for green 

buildings for schools 

 (Ongoing, but revisions to BPM within one 

year.) 

 Lead X X 
PBDEs: Recommendations to 33 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Summary of Recommended Cal/EPA Actions (continued) 

Departments 

Actions 

DTSC ARB OEHHA SWRCB IWMB DHS 

Outreach and Education (continued)

2c. Work with DGS to incorporate new best 

practices information on PBDEs into DGS 

Building Manuals as a requirement to 

receive Silver level certification. 

(Completed after one year of completion 

of fact sheets – per 1.a above)

 (Agency level involvement needed) 

 

X Lead 

Pollution Prevention Initiatives 

1. Encourage institutions, state and local 

agencies (e.g., in cities and counties) to buy 

PBDE-free products by posting fact sheets on 

DTSC and DGS Environmentally Preferable 

Purchasing Web sites 

(1 yr timeframe after fact sheets completed 

under “Outreach and Education,” 1.a, and 

update lists as needed) 

CoLead X

 

CoLead 

2. Evaluate the use of incentives for “PBDEfree” products and product labeling by 

manufacturers 

(1 yr timeframe) 

Lead 

3. Offer “Environmental Leadership” awards for 

phase-out of PBDEs 

(Lead: Cal/EPA) 

(1 yr timeframe)

X 

4. Compile list of safer alternatives that have 

been identified by other entities 

(1 yr timeframe, update as needed) 

X X Lead 

5. Work with Department of General Services 

and Prison Industry Authority to encourage 

purchase of PBDE-free products by all state 

agencies 

(Continue ongoing effort after fact sheets 

completed under “Outreach and Education,” 

1.a, and update lists as needed.)

CoLead  CoLead 
PBDEs: Recommendations to 34 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Summary of Recommended Cal/EPA Actions (continued) 

Departments 

Actions 

DTSC ARB OEHHA SWRCB IWMB DHS 

Measurement and Monitoring 

1. Initiate and implement an environmental 

measurement program to assess 

effectiveness of PBDE pollution prevention 

measures, remediation activities, and 

regulations. (continuing timeframe) 

Lead X X X 

 

X 

a. Convene an Inter-Agency Exposure 

Workgroup to facilitate Cal/EPA 

environmental monitoring and 

measurement (initiate within 3 months)

X X Lead X X X 

b. Develop guidance on acceptable sampling 

methods and testing protocols for 

identifying PBDEs in environmental 

matrices. (six to 12 month timeframe) 

Lead X X 

c. Identify sources and pathways of 

exposure, including the importance of 

decaBDE (1-3 yr timeframe)

Lead X X X X 

d. Characterize temporal and spatial in-situ 

PBDE levels, including decaBDE 

(1-3 yr timeframe)

Lead X X X 

e. Archive environmental & biological 

samples to evaluate temporal trends, 

hotspots & new chemicals 

(1 yr timeframe to initiate)

Lead X X 

f. Examine potential environmental and 

public health risks of alternatives and 

substitutes, based on biological and 

environmental monitoring data 

(1 yr timeframe to initiate, continuing as 

needed)

X X Lead 

2. Provide for a systematic, representative 

human biomonitoring program of PBDEs in 

California. (1-3 yr timeframe) 

X Lead X 

3. Encourage the University of California Toxic 

Substances Research and Teaching Program 

(UC TSR&TP) to emphasize research on 

PBDE fate and transport, especially 

decaBDE. 

 (initiate within 1 yr)

Lead 
PBDEs: Recommendations to 35 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Departments 

Actions 

DTSC ARB OEHHA SWRCB IWMB DHS 

Regulatory Initiatives 

1. Develop health values (e.g., cRELs) for 

PBDEs 

(Summer 2007)

 

Lead 

 

2. Determine if there is a need to establish (1) 

hazardous waste criteria, and (2) 

management and disposal requirements and 

practices for PBDE-contaminated waste 

(3 yr timeframe)

Lead 

3. Conduct a Needs Assessment to determine 

the appropriateness of developing an ATCM 

for PBDEs, which, as POMs, are identified as 

Toxic Air Contaminants 

 (3-4 yr timeframe) 

 Lead 

4. Consider adding PBDEs to the Air Toxics 

"Hot Spots" list of chemicals 

(2006)

 Lead 

5. Examine evidence of toxicity and 

environmental fate of PBDEs, especially 

deca-BDE; evaluate the need for regulation or 

legislation 

(1-3 yr timeframe)

X CoLead  CoLead  X 

6. Survey aquatic toxicity data and determine 

research needs for consideration of 

development of water quality standards 

(1-3 yr timeframe)

X Lead 
PBDEs: Recommendations to 36 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

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PBDEs: Recommendations to 40 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

Appendix I: 

Summary of ARB PBDE Monitoring Data 

During 2004, ARB measured PBDEs in ambient air, near two recycling facilities 

(“near-source”), and indoors. The results of these monitoring efforts are 

summarized below. 

Ambient 

ARB operates a network of air toxics monitoring sites in urban areas within 

California. During 2004, ARB conducted monitoring for PBDEs at six of these 

sites (Los Angeles, Oakland, Richmond, Riverside, San Jose, and Wilmington). 

At each site, integrated monthly samples for three PBDE congeners were 

collected. The samplers operated for five days followed by two days with the 

sampler shut off, for four weeks. The samples were analyzed by a contract 

laboratory. Below is a summary of the 2004 data from the six monitoring sites. 

 Congener Range Average 

 (pg/m3) (pg/m3) 

PBDE 47 (tetra) 7-170 53 

 PBDE 99 (penta) 3-332 52 

 PBDE 209 (deca) 7-72 23 

For comparison, outdoor concentrations of various PBDE congeners have been 

found to range from 5 – 300 pg/m3

 in different parts of the world. 

Near-source 

Due to the growing concerns about PBDEs, ARB contracted with a group at the 

University of California, Davis to conduct near-source and indoor air monitoring. 

Near-source air monitoring was conducted at two facilities: an electronics 

recycling facility and an automobile shredding facility. 

Several electronics recycling facilities were evaluated as possible locations for 

near-source air monitoring. At least one facility had installed air pollution control 

equipment. An electronics recycling facility without air pollution control 

equipment was selected for monitoring. Recycling activity consisted of shredding 

old electronics for metal recovery and compacting of old plastic cases. Air 

samples of eight-hours in duration were collected on three days during operating 

hours. Indoor air samples were collected near the shredding and compacting 
PBDEs: Recommendations to 41 February 2006 

Reduce Exposure in California Cal/EPA PBDE Workgroup

equipment. Near-source air samples were collected upwind and downwind of the 

facility at a distance of 15-20 meters. Indoor concentrations ranged from 15 – 

830,000 pg/m3

, mostly decaBDE. Outdoor concentrations ranged from 1 – 

11,000 pg/m3

, also mostly decaBDE. For comparison, other researchers have 

measured up to 200,000 pg/m3

 inside a Canadian electronics recycling facility. 

Near-source monitoring was also conducted upwind and downwind of an 

automobile shredding facility. This entire operation is outdoors. Shredded metal 

and shredded plastics and foam (referred to as auto shredder fluff) is piled onsite following shredding, prior to removal from the facility for uses as recycled 

materials. Air samples of 24-hours in duration were collected on three days at 

the facility’s fenceline (the facility operated 24 hours per day). Samples were 

collected at a distances of 150 – 300 meters from the shredder and piles of 

shredded materials. Fenceline air concentrations ranged from 0.2 – 1,900 pg/m3

, 

mostly decaBDE. The scientific literature does not contain any similar studies on 

autoshredder operations for comparison. 

Indoor 

Finally, indoor air samples were collected inside a computer training room that 

contained 13 older model personal computers (i.e., manufactured before 2000). 

Air samples of 24 hours in duration were collected on six days with the 

computers on and two days with the computers off. Concentrations ranged from 

4 – 1,600 pg/m3

, mostly tetraBDEs. For comparison, other researchers have 

measured indoor air concentrations of PBDEs up to 1,800 pg/m3

. 

The carpet within the computer training room was vacuumed for analysis of 

carpet dust. The carpet dust contained 10 ppm total PBDEs (mostly in the form 

of decaBDE), which is consistent with findings of other researchers regarding 

dust samples. A new piece of the same type of carpet was analyzed and found 

to contain 0.1 ppm of decaBDE. 
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Appendix II: 

The NTP Cancer Bioassay for DecaBDE and 

Workgroup Cancer Potency Derivation 

The National Toxicology Program (NTP, 1986) tested decaBDE for 

carcinogenicity in rats and mice of both sexes by administering the compound in 

the diet for two years. Absorption from the gastrointestinal tract in these studies 

was minimal (i.e., <1 to 2%). Male rats received average daily doses of 1,120 or 

2,240 mg/kg body weight, female rats received average daily doses of 1,200 or 

2,550 mg/kg body weight. The average daily doses for male mice were 3,200 or 

6,650 mg/kg body weight, and for female mice were 3,760 or 7,780 mg/kg body 

weight. In rats, dose-dependent increases in liver neoplastic nodules 

(hepatocellular adenomas) were observed in males [1/50, 7/50 (p=0.003), and 

15/49 (p<0.001), test for trend p <0.001] and females [1/50, 3/49, and 9/50 (p = 

0.008), trend test p=0.002]. Based on these findings, NTP (1986) concluded that 

there was “some evidence” of carcinogenicity in male and female rats. In male 

mice, a statistically significant dose-dependent increase in hepatocellular 

adenomas and carcinomas (combined) was observed [8/50, 22/50 (p=0.002), 

18/50 (p=0.02), trend test p=0.02, for control, low- and high-dose, respectively]. 

The incidence of hepatocellular tumors was not increased above historical 

controls, however. Increases in thyroid gland follicular cell adenomas or 

carcinomas (combined) were observed in male [0/50, 4/50, and 3/50; trend test 

p=0.08] and female mice [0/50, 3/50, 3/50, trend test p = 0.06], but did not reach 

statistical significance at the p = 0.05 level. Based on these findings, NTP 

(1986) concluded that there was “equivocal evidence” of carcinogenicity in male 

mice and “no evidence” in female mice. 

The dose response data from the NTP studies in male and female rats can be 

used to derive upper bound estimates of human cancer potency. For regulatory 

purposes, the lifetime probability of dying with a tumor (p) induced by an average 

daily dose (d) is often assumed to be: 

 p(d) = 1 - exp[-(q0 + q1d + q2d2

 + ... + qjdj)] 

with constraints, 

 qi ≥ 0 for all i. 

The qi are parameters of the model, which are taken to be constants and are 

estimated from the data. The parameter q0 represents the background lifetime 

incidence of the tumor. The parameter q1, or some upper bound, is often called 

the cancer potency, since for small doses it is the ratio of excess lifetime cancer 

risk to the average daily dose received. Here cancer potency will be defined as 

q1*, the upper 95% confidence bound on q1, estimated by maximum likelihood 

techniques. When dose is expressed in units of mg/kg-day, the parameters q1

and q1* are given in units of (mg/kg-day)-1. 
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In the NTP studies which form the basis for the estimation of the cancer 

potency, the decaBDE was administered in feed, and NTP estimated the doses 

in units of mg/kg-day. These dose estimates are used in the potency derivation 

here. 

Once a potency value is estimated in animals, human potency is estimated. In 

the absence of detailed pharmacokinetic or other data indicating otherwise, a 

dose in units of milligram per unit surface area is often assumed to produce the 

same degree of effect in different species. Under this assumption, scaling to the 

estimated human potency (qhuman) can be achieved by multiplying the animal 

potency (qanimal) by the ratio of human to animal body weights (bwh/bwa) raised to 

the one-third power when animal potency is expressed in units (mg/kg-day)-1: 

 qhuman = qanimal • (bwh / bwa)

1/3

From the male rat bioassay data, an upper bound estimate of cancer potency is 

0.000200 (mg/kg-day)-1. Assuming a bodyweight of 450 grams for test animals 

(see NTP, 1986, p. 33), and 70 kg for humans, the interspecies scaling factor is 

5.39. The resulting upper bound estimate for human cancer potency is 0.00108 

(mg/kg-day)-1. For the female rat, the upper bound potency estimate is 9.55 × 

10-5, corresponding to an upper bound human cancer potency estimate of 5.9 × 

10-4 (mg/kg-day)-1 (assuming a body weight of 300 grams for female rats [NTP, 

1986, p. 34] and an interspecies factor of 6.16). 
PBDEs: Recommendations to 44 February 2006 

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Appendix III: 

Publications and Presentations by DTSC, OEHHA, and ARB: 

PBDE Environmental Levels, Exposures and Risks 

Air Resources Board (ARB). "Report to the California Legislature- Indoor Air 

Pollution in California", July 2005 

http://www.arb.ca.gov/research/indoor/ab1173/finalreport.htm 

Brown FR, Winkler J, Visita P, Dhaliwal J, Petreas M. Levels of PBDEs, PCDDs, 

PCDFs, and Coplanar PCBs in Edible Fish from California Coastal Waters. 

Chemosphere, In Press, 2006 

Brown FR, O Kalantzi, Winkler J, Dhaliwal J, Petreas M. Combined PBDE/PCB 

analysis using GSMS with ECNCI detection. Organohalogen Compounds, 

67:129-131, 2005 

Charles MJ, Groskova D, Cahill TM. "Near-Source Ambient Air Monitoring of 

Polybrominated Diphenyl Ethers", UC Davis Department of Environmental 

Toxicology, Report prepared for the California Air Resources Board, 

Project Number 01-407, 2005

Geyer HJ, Schramm KW, Darnerud PO, Aune M, Feicht EA, Fried K, Henkelman 

B, Lenoir D, Schmid P, McDonald TA. Terminal elimination half-lives 

(T1/2H) of the brominated flame retardants TBBPA, HBCD, and lower 

brominated PBDEs in humans. Organohalogen Compounds, 66:3867-

3871, 2004 

Holden A., She J., Tanner M., Lunder S., Sharp M., and Hooper K. PBDEs in the 

San Francisco Bay Area: Measurement in Fish. Organohalogen 

Compounds, 61, 255 – 258, 2003 

Hooper K, McDonald TA. The PBDEs: An emerging environmental challenge and 

another reason for breast-milk monitoring programs. Environ Health 

Perspect, 108:387-392, 2000 

Hooper K, She J. Lessons from the polybrominated diphenyl ethers (PBDEs): 

Precautionary principle, primary prevention, and the value of communitybased body burden monitoring using breast milk. Environ Health Perspect, 

111:109-114, 2003 

Hooper K, Holden A, She J. Deca-BDE: Old myths, new realities. Proceedings of 

the Third International Workshop on the Brominated Flame Retardants, 

Toronto, CA June 6-9, 2004 
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Hooper K, McDonald TA. The PBDEs: An emerging environmental challenge 

and another reason for breast-milk monitoring programs. Environ Health 

Perspect, 108:387-392, 2000 

Kalantzi O, FR Brown, C Erdman, M Caleffi, R Goth-Goldstein, M Petreas. PBDEs 

in human breast adipose tissue from Brazil. Organohalogen Compounds, 

67: 479-481, 2005 

McDonald TA. Polybrominated Diphenylether levels among United States 

Residents: Daily Intake and Risk of Harm to the Developing Brain and 

Reproductive Organs. Integrated Environmental Assessment and 

Management, 1(4):343-354, 2005 

McDonald TA. A perspective on the potential health risks of PBDEs. 

Chemosphere, 46:745-755, 2002 

McDonald TA. Distribution of PBDE levels among U.S. women: Estimates of 

daily intake and risk of developmental effects. Proceedings of the Third 

International Workshop on Brominated Flame Retardants. (BFR2004); 

2004 June 6 - June 9; Toronto (ON) Canada pp. 443-446, 2004 

Petreas M, C Li, P Visita, K Thakore, H Romine, J Garcha. Polybrominated 

diphenyl ethers (PBDEs) in building materials and consumer products: 

Screening tools for exposure assessment. Accepted for presentation at the 

Healthy Buildings Conference, Lisbon, 2006 

Petreas M, C Li, P Visita, S Gill, M Gill, J Garcha. Autoshredder and e-waste as 

sources of PBDE exposures in California. Organohalogen Compounds, 67: 

1012:1015, 2005 

Petreas M, J She, FR Brown, J Winkler, G Windham, E Rogers, G Zhao, R Bhatia, 

MJ Charles. High body burdens of 2,2’,4,4’-brominated diphenyl ether in 

California women. Environ Health Perspect, 111:1175-79, 2003 

Petreas M, J She, P Visita, J Winkler, M McKinney, FR Brown, J Dhaliwal, G 

Denison, M Mok. Trends in persistent contaminants in California biota. 

Proceedings of the 221st Annual ACS Conference, San Diego, CA, 2001 

Petreas M, J Garcha, B Simmons. E-waste: Consumer electronics exceed 

hazardous waste criteria. Proceedings of the 229th Amer Chem Soc 

National Meeting, San Diego, CA, 2005 

Petreas M, D Smith, S Hurley, S Jeffrey, D Gilliss, P Reynolds. Distribution of 

persistent, lipid-soluble chemicals in breast and abdominal adipose tissues: 
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Lessons learned from a breast cancer study. Cancer Epi Biomark & 

Prevention, 13:416-424, 2004 

Petreas MX. Temporal and Spatial Trends in Persistent Organic Pollutants. Envir 

Sci & Pollut Research, (Special Issue 3):103-104, 2002 

Petreas M, E Rogers, G Zhao, G Windham, R Bhatia, MJ Charles. 

Organohalogen Body Burdens in California Women. Organohalogen 

Compounds, 55:259-262. 2002 

Petreas M, J She, FR Brown, J Winkler, P Visita, C Li, D Chand, J Dhaliwal, E 

Rogers, G Zhao, MJ Charles. High PBDE Concentrations in California 

Human and Wildlife Populations. Proceedings of the 22nd International 

Dioxin Conference, Barcelona, Spain, 2002 

Rogers E, M Petreas, JS Park, G Zhao, MJ Charles. Evaluation of four capillary 

columns for the analysis of organochlorine pesticides (OCPs), 

polychlorinated biphenyls (PCBs), and polybrominated diphenyl ethers 

(BDEs) in human serum for epidemiologic studies. J Chromatography B, 

813:269-285, 2004 

She J, MX Petreas, J Winkler, P Visita, M McKinney, D Kopec. Polybrominated 

Diphenyl Ethers (PBDEs) In the San Francisco Bay Area: Measurements in 

Harbor Seal Blubber and Human Breast Adipose Tissue. Chemosphere, 

46:697-707, 2002 

She J, Holden A, Tanner M, Adelsbach T, Schwarzbach S, Thompson CS, 

Mahaffy M, Petreas M, Simmons BP, Hooper, K. High PBDE levels in 

Piscivorous seabird eggs from the San Francisco Bay and Washington 

state. Organohalogen Compounds, 61:33 -36, 2003 

She J, A Holden, M Tanner, M Sharp, T Adelsbach and K Hooper. Highest PBDE 

Levels (max 63 ppm) Yet Found in Biota Measured in Seabird Eggs from 

San Francisco Bay. Organohalogen Compounds, 66:3889 – 3892, 2004 

She J, A Holden, M Sharp, M Tanner, C Williams-Derry, and K Hooper. Unusual 

Pattern of Polybrominated Diphenyl Ethers (PBDEs) in US Breast Milk. 

Organohalogen Compounds, 66:3895– 3900, 2004 

She J, A Holden, M Sharp, M Tanner, C Williams-Derry, and K Hooper. PBDEs 

are Higher than PCBs in Thirty Percent of Breast Milk Samples from the 

Pacific Northwest. Organohalogen Compounds, 67:647-650, 2005 

She J, A Holden, M Tanner, M Sharp, T Adelsbach and K Hooper. Time Trends of 

PBDEs in Shorebird Eggs from San Francisco Bay. Organohalogen 

Compounds, 67:607-609, 2005 
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She J, A Holden, M Sharp, M Tanner, C Williams-Derry, and K Hooper. PBDE 

Congener Pattern is an Indicator of Human PBDE Exposure in North 

America. Organohalogen Compounds, 67:525-528, 2005