TSCA Work Plan Chemical 

Technical Supplement - Use and Exposure of the Brominated 

Phthalates Cluster (BPC) Chemicals

Brominated Phthalates Cluster

Flame Retardants

CASRN NAME

26040-51-7 1,2-Benzenedicarboxylic acid, 3,4,5,6-tetrabromo-, 1,2-bis(2-

ethylhexyl) ester

183658-27-7 Benzoic acid, 2,3,4,5-tetrabromo-, 2-ethylhexyl ester

20566-35-2 1,2-Benzenedicarboxylic acid, 3,4,5,6-tetrabromo-, 1-[2-(2-

hydroxyethoxy)ethyl] 2-(2-hydroxypropyl) ester

77098-07-8 1,2-Benzenedicarboxylic acid, 3,4,5,6-tetrabromo-, mixed 

esters with diethylene glycol and propylene glycol

7415-86-3 1,2-Benzenedicarboxylic acid, 1,2-bis(2,3-dibromopropyl) ester

* Confidential A

* Confidential B

* Confidential Business Information

August 2015

United States

Environmental Protection Agency

EPA Document# 740-Q1-5001

August 2015

Office of Chemical Safety and 

Pollution Prevention
Page 2 of 54

TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................. 2

1 PRODUCTION VOLUME AND USES .................................................................................. 4

1.1 PRODUCTION OF TBPH (CASRN 26040-51-7) ....................................................................................................5

1.2 PRODUCTION OF TBB (CASRN 183658-27-7).....................................................................................................5

1.3 PRODUCTION OF CASRN 20566-35-2, 77098-07-8 AND 7415-86-3 ..............................................................5

1.4 IMPORT AND EXPORT OF TBPH AND TBB..............................................................................................................8

1.5 USES OF TBPH AND TBB ...................................................................................................................................8

1.5.1 TBPH and TBB Flame Retardants: Firemaster® Products .......................................................................10

1.5.2 TBPH (CASRN 26040-51-7): Use as a Flame Retardant Plasticizer .........................................................12

1.6 USES OF CASRN 20566-35-2, 77098-07-8 AND 7415-86-3 .............................................................................13

1.6.1 CASRNs 20566-35-2, 77098-07-8 and 7415-86-3: Flame Retardants.....................................................13

1.7 CHEMICAL ALTERNATIVES TO FIREMASTER 550®...................................................................................................14

1.8 REGULATORY STATUS AND FUTURE TRENDS .........................................................................................................16

1.8.1 Standards Relating to Polyurethane Foam.............................................................................................16

1.8.2 Electrical and Electronic Equipment Standards......................................................................................18

1.8.3 Price........................................................................................................................................................22

2 ENVIRONMENTAL EXPOSURE........................................................................................ 23

2.1 MONITORING DATA SUMMARY .........................................................................................................................23

2.2 DATA NEEDS ..................................................................................................................................................25

3 HUMAN EXPOSURE....................................................................................................... 26

3.1 OCCUPATIONAL EXPOSURES TO THE CLUSTER CHEMICALS .......................................................................................26

3.2 OCCUPATIONAL EXPOSURES TO POLYURETHANE FOAMS (PUF) CONTAINING THE CLUSTER CHEMICALS...........................26

3.2.1 Slabstock Polyurethane Foam ................................................................................................................31

3.2.2 Molded Polyurethane Foam ...................................................................................................................31

3.3 OCCUPATIONAL EXPOSURE DURING THE MANUFACTURE OF PRODUCTS CONTAINING POLYURETHANE FOAMS (PUF) .........33

3.4 OCCUPATIONAL EXPOSURE FROM THE USE OF PRODUCTS CONTAINING POLYURETHANE FOAMS (PUF) ...........................33

3.5 CONSUMER EXPOSURE FROM THE USE OF PRODUCTS CONTAINING POLYURETHANE FOAMS (PUF).................................33

3.6 DATA NEEDS ..................................................................................................................................................34

4 ENVIRONMENTAL EXPOSURE........................................................................................ 34

4.1 BACKGROUND AND CONTEXT OF CLUSTER CHEMICAL MANUFACTURE .......................................................................34

4.2 RELEASES TO THE ENVIRONMENT DURING CLUSTER CHEMICAL MANUFACTURE ...........................................................35

4.3 RELEASES TO THE ENVIRONMENT DURING POLYURETHANE FOAMS (PUF) MANUFACTURE ............................................35

4.4 RELEASES TO THE ENVIRONMENT DURING THE MANUFACTURE OF PRODUCTS CONTAINING POLYURETHANE FOAMS (PUF).35

4.5 RELEASES TO THE ENVIRONMENT DURING THE OCCUPATIONAL USE OF PRODUCTS CONTAINING POLYURETHANE FOAMS 

(PUF) 35

REFERENCES ........................................................................................................................ 37

APPENDICES ........................................................................................................................ 46
Page 3 of 54

LIST OF TABLES

Table 1-1: Production Volumes of the Brominated Phthalates Cluster Chemicals........................ 4

Table 1-2: 2012 CDR Production Data for TBPH (CASRN 26040-51-7) ........................................... 6

Table 1-3: 2012 CDR Production Data for TBB (CASRN 183658-27-7)............................................ 6

Table 1-4: CDR Production Data for CASRNs 20566-35-2, 77098-07-8 and 7415-86-3.................. 7

Table 1-5: Industrial and Consumer Use Data for TBPH (CASRN 26040-51-7) from the 2012 CDR9

Table 1-6: Loading Levels of Firemaster® 550 for Household Items............................................ 12

Table 1-7: Industrial and Consumer Use Data for CASRN 20566-35-2, 77098-07-8 and 7415-86-3

....................................................................................................................................................... 15

Table 1-8: Approved and Effective Upholstered Furniture Flammability Performance Standards

....................................................................................................................................................... 19

Table 1-9: Proposed Flammability Performance Standards......................................................... 21

Table 1-10: Flammability Standards for Electronic Products ....................................................... 22

Table 3-1: Summary Table of TBPH Monitoring Data................................................................... 27

Table 3-2: Summary Table of TBB Monitoring Data ..................................................................... 29

Table 4-1: Comparison of Different Polyurethane Foam Products.............................................. 36

LIST OF APPENDIX FIGURES

Figure 3-1: Typical Slabstock Production Line for flexible polyurethane foam (EPA, 2005) ........ 31

Figure 1-2: Typical Molded Foam Production Line for flexible polyurethane foam (EPA, 2005). 32
Page 4 of 54

1 PRODUCTION VOLUME AND USES

This section discusses the production volume and uses of the five brominated phthalates

cluster (BPC) chemicals. The 2006 Inventory Update Reporting (IUR) and 2012 Chemical Data 

Reporting (CDR) production volumes for these chemicals are listed in Table 1-1. Additional 

details on production volume for the chemicals can be found in Sections 1.1 and 1.2 for TBPH

and TBB, respectively. A summary of the available production volume data for the other three 

chemicals in the cluster, CASRNs 20566-35-2, 77098-07-8, and 7415-86-3, is presented in 

Section 1.3. Additionally, export volumes of all the chemicals, as reported to CDR, are found in 

Section 1.1. 

Use information can be found in Section 1.5 for TBPH and TBB and Section 1.6 for the other 

three chemicals in the cluster. Lastly, potential alternatives to TBB/TBPH are discussed in 

Section 1.7 and Section 1.8.3 presents available price information for the chemicals.

Table 1-1: Production Volumes of the Brominated Phthalates Cluster Chemicals

Cluster Member Reporting

TBPH: CASRN 26040-51-7 2006 IUR PV ≥ 10 million pounds

2012 CDR PV = 1 to 10 million pounds

Not on TRI

TBB: CASRN 183658-27-7 2006 IUR CDR National PV information for the chemical 

withheld.

2012 CDR National PV information for the chemical 

withheld.

Not on TRI

TBPA-Diol: CASRN 20566-35-2 2006 IUR PV = no record

2012 CDR PV = 1 to 10 million pounds

Not on TRI

TBPA-Diol (mixed esters): 

CASRN 77098-07-8

2006 IUR PV = 1 to 10 million pounds

2012 CDR National PV information for the chemical 

withheld.

Not on TRI

Bromo Alkyl Ester:

CASRN 7415-86-3

2006 IUR PV = no record

2012 CDR = no record

Not on TRI

Confidential A Consent Order – testing PV not triggered

Confidential B 2012 CDR National PV information for the chemical 

withheld.

IUR = Inventory Update Reporting; CDR = Chemical Data Reporting; PV = Production Volume; TRI = Toxic 

Releases Inventory
Page 5 of 54

1.1 Production of TBPH (CASRN 26040-51-7)

According to the 2012 CDR database, the national production volume of TBPH is between one 

and 10 million pounds (EPA, 2012a): Table 1-2.

Two companies are identified in the CDR database as manufacturing/importing TBPH: Teknor 

Apex and Unitex (now part of LanXess) (EPA, 2012a). Unitex developed bromine-chlorine 

phthalate esters which are part of the company’s Uniplex® product line. These plasticizers are 

most likely combinations of TBPH and dioctyl tetrachlorophthalate oxide and are thought to 

have an improved flame retardancy over TBPH alone (Weil and Levchik, 2009). No trade 

literature has indicated the trade name of Teknor Apex’s TBPH product. For more detailed 

information, see Table 1-2.

Chemtura’s website indicates that it also produces TBPH (Chemtura, 2007a). TBPH has been 

identified as a component of Chemtura’s flame retardant products Firemaster® 550, 

Firemaster® BZ-54, and Firemaster® 552 (Bearr et al., 2010; EPA, 2005; Stapleton et al., 2008a).

1.2 Production of TBB (CASRN 183658-27-7)

EPA’s 2012 publicly available CDR database does not provide any data on the production 

TBB; the national production volume for TBB is withheld and past production volumes are 

confidential business information (CBI), as shown in 

Table 1-3 (EPA, 2012a). However, Chemtura’s Firemaster® 550 webpage acknowledges that TBB 

is the main component of its flame retardant Firemaster® 550 (Chemtura, 2013b). Evidence 

that TBB is manufactured or sold for any other purpose than for Firemaster® products was not 

found.

1.3 Production of CASRN 20566-35-2, 77098-07-8 and 

7415-86-3

According to the 2012 CDR, the production volume of CASRN 20566-35-2 is between 1 and 10 

million pounds per year, as shown in Table 1-4 below (EPA, 2012a). Rubicon and Pelron, Inc. 

are identified in the CDR database as manufacturers/importers of CASRN 20566-35-2 (EPA, 

2012a). 

CDR data identifies Albemarle Corporation as a manufacturer/importer of CASRN 77098-07-8. 

However, national production volumes for CASRN 77098-07-8 are withheld from the 2012 CDR 

and past production volume are reported as Confidential Business Information (CBI)(EPA, 

2012a), as shown below in Table 1-4.

There are no records for CASRN 7415-86-3 in the 2012 CDR database (EPA, 2012a). 
Page 6 of 54

Table 1-2: 2012 CDR Production Data for TBPH (CASRN 26040-51-7)

 

Table 1-3: 2012 CDR Production Data for TBB (CASRN 183658-27-7)

Manufacturing 

Site

Domestic 

Manufacturing

Imported Volume 

Exported 

Volume 

used 

on the 

site

Past 

Production 

Volume 

(2010)

National 

Production 

Volume 

for the 

Chemical

CBI CBI No Data 

Reported

CBI 0 CBI Withheld

Manufacturing 

Site

Domestic 

Manufacturing

Imported Volume 

Exported (lbs)

Volume 

Used on the 

Site (lbs)1

Past Production 

Volume (2010) 

(import+ 

manufacture)

National 

Production 

Volume

(2012)

Teknor Apex 

751 Dupree 

Street 

Brownsville, 

TN 38012-

1708

Withheld Withheld 64,000 0 1,600,000 1 Million to 

10 million 

lbs/year

CBI CBI CBI 311,796 CBI

Unitex 

Chemical 

Corp.

520 Broome 

Road

Greensboro, 

NC 27406-

3799

Withheld Withheld 781,125 0 3,483,600

1The total volume (domestically manufactured and imported) of the chemical used at the reporting site. This number 

represents the volume of the chemical that did not leave the manufacturing site. 

CBI = Confidential Business Information
 

Page 7 of 54

Table 1-4: CDR Production Data for CASRNs 20566-35-2, 77098-07-8 and 7415-86-3

CASRN Chemical Name Manufacturing 

Site

Domestic 

Manufacturing

Imported Volume 

Exported 

(lbs)

Volume 

Used on 

the Site 

(lbs)1

Past 

Production 

Volume (2010) 

(import+ 

manufacture)

National 

Production 

Volume

(2012)

20566-35-2 1,2-

Benzenedicarboxylic 

acid, 3,4,5,6-

tetrabromo-, 1-

bis[(2-(2-

hydroxyethoxy)ethyl] 

2-(2-hydroxypropyl)

ester

Rubicon, LLC

9156 Hwy 75

Geismar, LA

70734

Withheld CBI CBI CBI CBI 1 Million to 

10 million 

lbs/year

CBI Withheld Withheld CBI CBI CBI

Pelron, Inc.

7847 West 47th

St.

Lyons, IL

60534

CBI Withheld 0 CBI 19,793

77098-07-8 1,2-

Benzenedicarboxylic 

acid, 3,4,5,6-

tetrabromo-, mixed 

esters with 

diethylene glycol and 

propylene glycol

Albemarle 

Corporation

725 Cannon 

Bridge Road

Orangeburg, SC

29115

CBI Withheld CBI CBI CBI Withheld

7415-86-3 1,2-

Benzenedicarboxylic 

acid, 1,2-bis(2,3-

dibromopropyl) ester

No reports No reports No 

reports

No 

reports

No 

reports

No reports No reports

1The total volume (domestically manufactured and imported) of the chemical used at the reporting site. This number represents the volume of the chemical 

that did not leave the manufacturing site.

CBI = Confidential Business Information
 

Page 8 of 54

1.4 Import and Export of TBPH and TBB

CDR data do not indicate whether either TBPH or TBB is imported (EPA, 2012a). The only 

reported product containing TBB is Firemaster® 550; when Chemtura began manufacturing 

Firemaster® 550, it did so at the company’s El Dorado, AR plant (Tullo, 2003). According to the 

2012 CDR, Teknor Apex exported 64,000 lbs of TBPH and Unitex exported 781,125 lbs (see

Table 1-2). 

Pelron, Inc. reported that it did not export CASRN 20566-35-2 and withheld reports on import 

volumes; import and export data for Rubicon are reported as CBI (EPA, 2012a). 

The CDR database does not provide any data on the import or export of CASRN 77098-07-8. 

There is no CDR record for CASRN 7415-86-3 (EPA, 2012a).

1.5 Uses of TBPH and TBB

The 2012 CDR provide data on the industrial and consumer uses of TBPH (EPA, 2012a). These

data are summarized in Table 1-5 which presents the percent of each site’s production volume 

used in a specific industrial or commercial and consumer use category. As stated in the 

Instruction for the 2012 TSCA Chemical Data Reporting (EPA, 2012a) the percentage of 

production volume for the industrial sector is the amount that is attributable to the unique 

combination of type of processing, industrial sector and industrial function1. Alternatively, the 

percentage of production volume for consumer/commercial use is the percent of the 

production volume is attributed “to each specific consumer and commercial end use carried 

out”. Note that the industrial uses and consumer uses are exclusive of one another. 

Sites must report industrial processing and use information for each chemical substance 

manufactured (including imported) in an amount of 100,000lbs or more in the reporting year 

2011. To identify industries using a chemical in the CDR data EPA used 48 Industrial Sectors (IS) 

Codes adapted from the European Union’s (EU’s) “Guidance on Information Requirements and 

Chemical Safety Assessment”. 

The CDR also collected data on consumer and commercial uses of chemicals. Commercial use is 

defined as the use of a chemical substance or a mixture (including as part of an article) in a 

commercial enterprise providing saleable goods or a service. A consumer use, on the other 

hand, means the use of a chemical substance or a mixture (including as part of an article) when

sold to or made available to consumers for their use (EPA, 2012a) (p4-34). 

Definitions of the consumer use categories are provided in Appendix B. 

 

1 Note, industrial function is not displayed in the tables below.
 

Page 9 of 54

Table 1-5: Industrial and Consumer Use Data for TBPH (CASRN 26040-51-7) from the 2012 CDR

Industrial Use Data Consumer Use Data

Manufacturing

Site

Type of 

Processing

Sector

(NAICS Code)

Industrial 

Use

Percent of 

Production 

Volume

Consumer Use 

Product 

Category

Commercial 

or Consumer 

Use

Percent of 

Production 

Volume

Teknor Apex 

751 Dupree Street 

Brownsville, TN 

38012-1708

Processingincorporation into 

formulation, mixture, 

or reaction product

Custom 

Compounding of 

Purchased 

Resins

(325991)

Plasticizer 100 Electrical and 

Electronic 

Products

Both 100

CBI Processingincorporation into 

formulation, mixture, 

or reaction product

Furniture and 

Related Product 

Manufacturing

(337)

Flame 

retardants

90 Furniture and 

Furnishings not 

covered 

elsewhere

Commercial 90

Construction

(23)

Flame 

retardants

10 Building/

Construction 

Materials not 

covered 

elsewhere

Commercial 10

Unitex Chemical 

Corp.

520 Broome Road

Greensboro, NC 

27406-3799

Processingincorporation into 

formulation, mixture, 

or reaction product

Electrical 

Equipment, 

Appliance, and 

Component 

Manufacturing

(335)

Plasticizer 50 Electrical and 

Electronic 

Products

Both 100

Flame 

retardants

50
 

Page 10 of 54

1.5.1 TBPH and TBB Flame Retardants: Firemaster® Products

TBPH (CASRN 26040-51-7) and TBB (CASRN 183658-27-7) are two components of Chemtura’s 

flame retardant Firemaster® 550, an additive flame retardant (Chemtura, 2013b; Stapleton et 

al., 2008a). Additive flame retardants are incorporated into polymers via physical mixing, and 

are not chemically bound to the polymer. This is contrary to reactive flame retardants which 

are incorporated into polymers via chemical reactions and must be incorporated at an early 

stage of manufacturing. Since additive flame retardants can be incorporated into the product 

up until the final stages of manufacturing, it is usually easier for manufacturers to use additive 

flame retardants than reactive flame retardants. Additionally, reactive flame retardants have a 

greater effect on the chemical and physical properties of the polymer into which they are 

incorporated than do additive flame retardants.

The ratio of TBB to TBPH in this product is 4:1 (CECBP SGP, 2008). The formulation of 

Firemaster® 550 comprises TBPH, TBB and two phosphates: triphenyl phosphate (TPP; CASRN 

115-86-6) and isopropylated triphenyl phosphate (ITPP; CASRN 68937-41-7 (Chemtura, 2010).

Bearr, et al. (Bearr et al., 2010) states that Firemaster® BZ-54 is made up of the same TBB-TBPH

formulation as is in Firemaster®550. The product’s technical data sheet describes it as a 

“tetrabromophthalic anhydride derivative,” with a bromine content of 54% (Chemtura, 2007b).

According to one source, Firemaster® 552 also has the same components as Firemaster® 550

(EPA, 2005). Chemtura began marketing Firemaster® 552 in 2003 for use in mechanically 

cooled, flexible polyurethane foam and for improved processing efficiency (Plastics Additives 

and Compounding, 2003).

Firemaster® 550 is a liquid flame retardant for flexible polyurethane applications. Polyurethane 

foams are the reaction products of a polyol and an isocyanurate. Polyurethane foams can vary 

in stiffness and are broken into two categories – flexible and rigid: attributes that may be 

imparted by the use of other additives and/or mechanical processes during manufacture. 

Flexible foam, the type of foam in which Firemaster®550 is typically used, is made using toluene 

diisocyanate (TDI) as the isocyanurate (Global Insight, 2006; Polyurethane Foam Association, 

1991a). Most flexible foams have an open-cell structure, which allows for the movement of air 

within the foam (North Star Polymers, 2013). Flexible foam is most often used in cushioning 

applications (Polyurethane Foam Association, 1991b). Flexible foams can be divided into many 

subsets, including molded, slabstock and viscoelastic and can vary widely by density and pore 

size, see Appendix B for more details on these foam types. 

EPA could not find any indication that TBB/TBPH is used in rigid foam. It replaces 

pentabromodiphenylether (pentaBDE), which was the most widely used flame retardant for 

furniture foams, that are flexible, in the United States before being phased out at the end of 

2004 (Chemtura, 2007b, 2007c; Tullo, 2003; Utech, 2007). Firemaster® 550 is mainly applied to 

furniture containing polyurethane foam, such as couches, ottomans and chairs. According to 
 

Page 11 of 54

the 2008 End-Use Market Survey on the Polyurethane Industry in the US, Canada, and Mexico, 

230 million pounds of flexible slabstock2 was used in furniture in the United States in 2008, of 

which 210 million pounds was used in residential furniture and 20 million pounds was used in 

non-residential furniture (ACC, 2009). However, the percentage of this market that utilizes 

Firemaster® products is unknown. Firemaster® BZ-54 is also used for flexible polyurethane foam 

applications and can be blended with alkyphenyl diphenyl phosphate or used alone (Chemtura, 

2007b; Weil and Levchik, 2009).

Firemaster® 550 assists furniture manufactures in meeting the State of California Department 

of Consumer Affairs Bureau of Home Furnishings and Thermal Insulation’s Technical Bulletin 

117 (California TB117), which requires that polyurethane foam in upholstered furniture sold in 

the State of California withstand exposure to a small open flame for 12 seconds (California 

Department of Consumer Affairs, 2000; Stapleton et al., 2011). Baby products that are 

considered juvenile furniture must also comply with California TB117 (Stapleton et al., 

2011).These products include rocking chairs, portable mattresses, changing table pads, and car 

seats (Stapleton et al., 2011). See Section 1.8 for further discussion of TB117 and the regulatory 

status of flame retardants in upholstered furniture. Table 1-6 shows the concentrations of 

Firemaster 550® detected in furniture foam and baby products. 

TBPH and TBB have also been detected in gymnastics equipment, including foam pit cubes, 

landing mats, sting mats, and vault runway carpets (Carignan et al., 2013). These chemicals may 

therefore possibly be found in other facilities containing foam pits or equipment. Further, 

Firemaster® 550 can also be used in high resiliency (HR) polyurethane foam (Chemtura, 2007b) . 

HR foams are flexible polyurethane foams, with applications including high-quality mattresses 

(Dimaflex, 2009). Different additives are used in these types of foam to increase heat transfer, 

bounce back time, etc. so many HR foam formulae exist and are generally proprietary formulae.

Information on the specific HR foam products that Firemaster® 550 is used in could not be 

located.

Although flexible polyurethane foam applications include mattress foam, trade associations and 

personal communication with industry have indicated that it is unlikely that TBPH and TBB are 

used in mattresses. Mattress manufacturers use barrier technologies rather than flameretardant-treated foam to meet fire safety standards (Polyurethane Foam Association, 1992a; 

Trainer, 2013). Additionally, full scale burn tests have shown that the ignitability and rate of 

burning can be reduced by certain foam fillers, cover materials and inter-liners and therefore 

flame-retardants are not needed (Randall and Lee, 2010).

PentaBDE was also known to be used in carpet, but current literature does not indicate that 

Firemaster® 550 is added intentionally to carpet backing. However, carpet cushions are 

manufactured largely from flexible polyurethane slabstock foam scraps and recycled foam (EPA, 

2005) and have lifespans of five to 15 years (Luedeka, 2012). Given that carpet backing is often 

 

2 The main type of polyurethane foam used in furniture.
 

Page 12 of 54

manufactured from recycled foam scrap, carpet backing may have the same amount of 

TBB/TBPH as furniture foam if the scrap foam is from a manufacturer that uses Firemaster® 

550 (Polyurethane Foam Association, 2012). The recovery of foam scraps to make carpet 

cushions is practiced mainly in the United States, Canada, and Mexico, and, to a lesser extent, 

exported by China to the United States (Luedeka, 2012). According to the Polyurethane Foam 

Association, in 2010, 212 million pounds of slabstock foam were produced for use in US

manufactured upholstered furniture, and 50 million pounds of foam scrap were recovered for 

use in US manufactured carpet cushions (Luedeka, 2012). 

1.5.2 TBPH (CASRN 26040-51-7): Use as a Flame Retardant Plasticizer

Typical polyvinyl chloride (PVC) emits its ester plasticizers when strongly heated, and these 

plasticizers are flammable. One solution to this problem is to use less flammable or 

nonflammable plasticizers, such as TBPH (CECBP SGP, 2008; Weil and Levchik, 2009). According

to the CDR TBPH is manufactured for use as a plasticizer by two companies. These two 

companies state that TBPH ends up in consumer and commercial electrical and electronic 

products that are mainly made of PVC (EPA, 2012a). TBPH is usually used in combination with 

other additives, such as antimony trioxide. It can also be used with phosphate esters, zinc 

borates, and Ongard® 2, which is a composition from Chemtura containing magnesium oxide 

and zinc oxide (Weil and Levchik, 2009). Additionally, chemical manufacturers claim that TBPH

is also used as a flame retardant additive for EPDM (ethylene propylene diene monomer (Mclass) rubber), styrene-butadiene rubber (SBR), and neoprene (Chemtura, 2007a; Unitex, 2009). 

The use of TBPH in these polymers constitutes a minor portion of the total PV.

Table 1-6: Loading Levels of Firemaster® 550 for Household Items

Household Item Firemaster® 550 

Loading Amount 

(i.e., the amount of 

chemical within the 

foam)

Chemicals 

Representing 

Firemaster ® 550

Source

Couches 19.76 mg/g

(5.18-36.85 mg/g)

TPP, TBB, TBPH (Stapleton et al., 2012)

Novel and high use flame 

retardants in US couches 

reflective of the 2005 

pentaBDE phaseout. 

4.2% by weight TBB, TBPH (Stapleton et al., 2009)

Detection of 

organophosphate flame 

retardants in furniture 

foam and US house dust. 

Resilient foama 3.3 % (3.1-3.5) or 

6.0% (5.5-6.2) 

depending on the foam 

sample.

TPP, tri(propylphenyl) 

phosphate, octyl 

tetrabomobenzoate

(Cobb and Chen, 2005)

Analysis of FR 

Chemicals Added to 
 

Page 13 of 54

Household Item Firemaster® 550 

Loading Amount 

(i.e., the amount of 

chemical within the 

foam)

Chemicals 

Representing 

Firemaster ® 550

Source

Foams, Fabric, Batting, 

Loose Fill and Barriers.b

Children’s 

productsc

18.51 mg/g (5.85 mg/g 

- 42.5 mg/g)

TBB,TBPH (Stapleton et al., 2011)

Identification of flame 

retardants in polyurethane 

foam collected from baby 

products. 

a The types of products that the foam studied in this report was taken from is unclear.

b This report is cited as the basis for the amount of Firemaster® 550 used in the CPSC risk assessment of Flame 

Retardant Chemicals in Upholstered Furniture Foam (Babich, 2006), which used a loading level of 6%.

c The products which contained TBB and TBPH included rocking chairs, portable mattress, changing table pad 

and car seat. Products which were examined that did not contain TBB and TBPH include sleep positioners, 

nursing pillow, baby carrier, high chair, infant bath mat, baby walkers, stroller, bath toy, car seat pillow, Bumbo 

chair, nap mat, and toilet seat. 

1.6 Uses of CASRN 20566-35-2, 77098-07-8 and 7415-86-3

The 2012 CDR data for industrial and consumer uses of CASRN 20566-35-2 and CASRN 

77098-07-8 are summarized in Table 1-7 below. CASRN 7415-86-3 was identified as potentially 

used as a flame retardant in polyester fibers [textiles; (WHO, 1997)]. However, there are no 

records for CASRN 7415-86-3 in the CDR database (EPA, 2012a).

1.6.1 CASRNs 20566-35-2, 77098-07-8 and 7415-86-3: Flame Retardants

CASRN 20566-35-2 is listed as an ingredient in Elé Corporation’s PEL-RON 9457-LE, a flame 

retardant in polyurethane (Ele Corporation, 2013). The type of polyurethane this flame 

retardant can be used in was not specified by Elé Corporation’s website.

CASRN 77098-07-8 can be used as a reactive flame retardant in rigid polyurethane foam, as 

well as in polyurethane reaction injection molding, elastomers, coatings, adhesives, and fibers 

applications (GLCC, 2010). These foams, elastomers, and coatings are often used in building 

insulation and specialty coatings (Albemarle - GLCC, 2004). CASRN 77098-07-8 flame retardants 

are applied to polyurethane in concentrations of 5-15% (Albemarle - GLCC, 2004). Great Lakes 

Chemical Corporation lists CASRN 77098-07-8 as an ingredient in its PHT4-DiolTM flame 

retardant. In addition, Albemarle manufactures a similar product, Saytex® RB-79, which is also 

used in rigid polyurethane foams (Weil and Levchik, 2009). 

EPA could not located evidence of where CASRN 7415-86-3 may be used as a flame retardant. 
 

Page 14 of 54

1.7 Chemical Alternatives to Firemaster 550®

EPA’s Design for the Environment program recently updated the Alternative Assessment for 

flame retardants in furniture foam (To be published). In this analysis they identified nineteen 

flame retardants which may be used any upholstered consumer product containing flexible 

polyurethane foam. Information on some of the alternative is listed below. For a list of flame 

retardants which may be used in flexible polyurethane foam in upholstered consumer products 

see Appendix A. 

 Tris (1,3-dischloroisopropyl) phosphate (TDCPP), known to be a major FR in FPUF and 

produced in a volume between 10 and 50 million pounds per year, was listed by 

California as a Proposition 65 chemical in late 2011 for concerns about carcinogenicity 

(EPA, 2012a; OEHHA, 2011). The Proposition 65 listing is expected to have an impact on 

the marketplace, even though TDCPP need not be labeled outside of California. TDCPP 

was identified by Stapleton et al (2012) in more than half of samples tested since 2005. 

In 2012, the major US manufacturer of TDCPP announced a voluntary phase-out of 

TDCPP production by 2015 (Betts, 2013). 

 There has been recent opposition from consumer and environmental groups to the use 

of halogenated FRs, and this opposition may shape the market suitability of these FRs, 

regardless of hazard data. For example, the New York State Assembly passed a bill 

prohibiting the use of halogenated FRs in furniture; the bill has not passed the upper 

house of the Legislature as of this writing, and appears stalled (NY State Assembly 2013). 

Some shift away from halogenated FRs appears to have already occurred. While the 

2005 FFRP report assessed a number of brominated FRs, the two brominated 

components of Firemaster 550 (2-ethylhexyl-2,3,4,5-tetrabromobenzoate, or TBB, and 

bis (2-ethylhexyl)-2,3,4,5-tetrabromophthalate, or TBPH) are the only brominated FRs 

included in the current update report (although several chlorinated FRs were assessed). 

 Although TCEP was previously not thought to be used in foam, it has been identified in 

upholstered FPUF products (Stapleton et al., 2011). TCEP is a TSCA work plan chemical 

for 2013-14, so the DfE AA process is a useful contribution to other EPA activities on this 

compound (EPA, 2013).
Page 15 of 54

Table 1-7: Industrial and Consumer Use Data for CASRN 20566-35-2, 77098-07-8 and 7415-86-3

Industrial Use Data Consumer Use Data

CASRN Chemical Name Manufacturing 

Site

Type of 

Processing

Sector Industrial 

Use

Percent of 

Production 

Volume

Consumer 

Use Product 

Category

Commercial 

or 

Consumer 

Use

Percent of 

Production 

Volume

20566-35-2 1,2-

Benzenedicarbo

xylic acid, 

3,4,5,6-

tetrabromo-, 1-

[2-(2-

hydroxyethoxy)

ethyl] 2-(2-

hydroxypropyl) 

ester

Rubicon, LLC

9156 Hwy 75

Geismar, LA

70734

N/A N/A N/A N/A Building/

Construction 

materials not 

covered 

elsewhere

Commercial 100

Pelron, Inc. 

7847 West 47th

St.

Lyons, IL

60534

N/A N/A N/A N/A Withheld Withheld Withheld

CBI N/A N/A N/A N/A Withheld Withheld Withheld

77098-07-8 1,2-

Benzenedicarbo

xylic acid, 

3,4,5,6-

tetrabromo-, 

mixed esters 

with diethylene 

glycol and 

propylene glycol

Albemarle 

Corporation

725 Cannon 

Bridge Road

Orangeburg, SC

29115

Processingincorporation 

into 

formulation, 

mixture, or 

reaction 

product

Construction Flame 

retardants

100 Building/

Construction 

materials not 

covered 

elsewhere

Both 100

7415-86-3 1,2-

Benzenedicarbo

xylic acid, 1,2-

bis(2,3-

dibromopropyl) 

ester

No Reports No Reports No Reports No Reports No Reports No Reports No Reports No Reports

N/A = Not Applicable
Page 16 of 54

 tris(2-Carboxyethyl)phosphine (TCPP) and melamine are the major FRs used in the 

United Kingdom to meet the stringent “Crib 5” standard, but use of this mixture is not 

known to be common in the United States. However, since TCPP was identified in FPUF 

products by Stapleton et al (2011), it is included in this report.

 The larger molecule “V6” (CAS 38051-10-4) has been used in automobile foam, due to 

its lower volatility, but was also identified by Stapleton et al (2011) in baby products. V6 

is a dimer of TCEP, and contains TCEP as an impurity.

There is a lack of reactive or polymeric flame retardants for flexible polyurethane foam. 

Reactive/polymeric products would be expected to have lower volatility, lower mobility out of 

the product, and greatly reduced bioavailability; concerns about impurities and breakdown 

products prevent making a general conclusion about hazard. DfE’s alternatives assessment for 

decaBDE included a number of polymeric flame retardants. In the flexible polyurethane foam 

market, however, reactive/polymeric flame retardants present technical challenges, in part 

because of the extremely small nozzle size typically used in mixing the polyols, and more 

generally because of their limited viscosity and flexibility.

1.8 Regulatory Status and Future Trends

In order to understand the potential future trends of flame retardant chemicals it is important 

to understand the standards and regulations which require and or ban their use. 

1.8.1 Standards Relating to Polyurethane Foam

California Technical Bulletin (TB) 117 has been an influential standard driving the use of flame 

retardants in furniture manufacturing, as no federal performance standard currently exists to 

regulate the flammability of upholstered furniture (CPSC, 2013). California remains the only 

state to have passed a performance standard; however, because manufacturers prefer to 

produce one product for the entire U market, TB117 subsequently became the de facto 

standard for upholstered furniture manufacturers nationwide. TB117 required residential 

upholstered furniture foam to withstand an “open flame test,” in which an open flame is 

applied to uncovered foam for 12 seconds. Although the standard did not explicitly require the 

use of flame retardants, the most cost effective way to meet this standard was often to add a 

flame retardant to the furniture foam. However, it has been argued that applying an open 

flame to an uncovered piece of polyurethane foam does not accurately measure the fire 

resistance of furniture (DiGangi et al., 2010). This is because the open flame standard only tests 

uncovered foam and does not account for the ability of many fabrics covering the foam to 

withstand the flame. A flame large enough to ignite the furniture fabric and reach the foam 

beneath will most likely be larger than the flame used in the open flame test, which in effect 

renders the open flame standard ineffective (CPSC, 2012).
Page 17 of 54

Given this information, California recently revised the open flame requirement for upholstered 

furniture manufactured and sold in the state. The new regulation, TB117-2013, only requires 

residential furniture to pass a “smolder test.” In this test, a small assembly of cover fabric, 

barrier materials, and filling materials must withstand a smoldering cigarette (Cal/DCA 2013). It 

is anticipated that most fabrics will be able to meet this standard without the addition of any 

flame retardants.

However, TB 117-2013 only addresses the flammability of residential furniture. California 

TB133, which pertains to furniture manufactured and sold for use in public buildings (e.g. 

dormitories, hospitals), is a more rigorous test that requires assembled furniture to withstand a 

large open flame, provided by a gas burner, for 80 seconds (Polyurethane Foam Association, 

1992b). Other states, including Massachusetts, Illinois, Minnesota, North Carolina, and Ohio, 

have adopted TB133 as the standard for their own public furniture flammability regulations 

(see Table 1-8). Given the large open flame standard, it is likely that manufacturers are adding 

flame retardants to their products to meet the test requirements. 

In addition to TB117, the Upholstered Furniture Action Council (UFAC), US National Fire 

Protection Association (NFPA), and ASTM International have all developed voluntary smolder 

test standards. Although UFAC states that 90% of industry has adopted its standard, this is likely 

due to manufacturers complying with TB117, which exceeds the requirements of the voluntary 

standards. Since 2008, the Consumer Product Safety Commission (CPSC) has also been 

developing a federal furniture flammability requirement (CPSC, 2008). Although the initial 2008 

standard proposes a smolder test applied to cover materials, in March 2013 CPSC posted a 

notice in the Federal Register requesting comments on introducing an open flame standard 

(CPSC, 2013). See Table 1-8 for a summary of approved and effective upholstered furniture 

flammability performance standards. 

It is unclear how the introduction of TB 117-2013 will affect the furniture and flame retardant 

industries. With the growing health and environmental concerns about flame retardants, 

manufacturers may choose to introduce furniture without flame retardants to this “green” 

market; however, it is uncertain how wide-spread this market will be. Whether manufacturers 

will switch to foams that are not treated with flame retardants will also depend on state and 

local regulations. Many states and local entities reference or model their standards after TB117. 

For example, in Massachusetts and Illinois, furniture in public buildings equipped with a 

sprinkler system must meet TB117 standards (State of Illinois, No date; State of Massachusetts, 

1994). Thus, the update to TB117 will not have an effect in these locations unless they revise 

their own regulations. If they do choose to update their standards to match TB117-2013, it may 

be a number of years before any legislation is passed. 

New York and New Jersey are also proposing their own flammability performance standards for 

residential furniture (New Jersey Assembly, 2012; New York Senate, 2013). Because both bills 

currently include an open flame test, if either passes it is possible that the open flame will once 

again become the de facto nationwide standard. Manufacturers will also need to consider a 

possible CPSC national standard. Whether a federal regulation is passed and whether that 
Page 18 of 54

standard will be based on a smolder or open flame test will largely influence the future use of 

flame retardants in residential furniture. In addition, the strict standards of TB133 and similar 

public fire codes will necessitate the continued use of flame retardants in public occupancy 

furniture. Furthermore, furniture manufacturers may choose to continue using flame 

retardants to protect themselves against possible liability if a fire were to spread due to 

furniture ignitability. 

In addition to the standards which have been approved several states are currently discussing 

bills to enact flammability standards and ban specific flame retardants. Both New Jersey and 

New York have proposed residential flammability performance standard bills (see Table 1-9). A 

number of other states also have proposed or enacted legislation prohibiting commercial flame 

retardants such as TCEP, TDCPP and TCPP in children’s products and residential upholstered 

furniture. Because TBB and TBPH are not currently prohibited under any state or national law, 

the banning of TCEP, TDCPP, and TCPP in children’s products and upholstered furniture may 

result in the substitution of these chemicals for Firemaster® 550. 

1.8.2 Electrical and Electronic Equipment Standards

The predominant standard driving flame retardant use in electronic products is Underwriters 

Laboratories (UL) 94. UL 94 is a voluntary flammability standard which requires plastic materials 

in devices and appliances to withstand a small scale ignition source (UL, 2013). It determines 

the material’s tendency to either extinguish or spread the flame once it has been ignited. 

Components are classified based on how long they continue to burn after ignition. V-0 

classifications are the most rigorous, requiring electrical components to self-extinguish within 

10 seconds of ignition (UL IDES, No Date). V-1 and V-2 classifications each allow the test 

specimen to burn up to 30 seconds after ignition (UL IDES, No Date). While the standard does 

not require the use of flame retardants, they are often used in electronic components to meet 

the high levels of flame resistance specified by the more stringent classifications such as V-0 

ratings (Pure Strategies Inc and Lowell Center for Sustainable Production, 2005).

For polymeric materials used in electrical equipment the relevant standard is UL 746C and for 

printed wiring boards the relevant standard is UL 796. These product standards are based on 

the requirements of UL 94 (ACC, 2014; UL, 2004, 2013b). See Table 1-10 for further details.

International regulations restricting or requiring reporting of the use of certain flame retardant 

chemicals include the European Union’s Restriction of Hazardous Substance (RoHS) in electrical 

and electronic equipment and Registration, Evaluation, Authorisation, and Restriction of 

Chemicals (REACH). The RoHS directive requires that polybrominated biphenyl (PBB) and 

polybrominated diphenyl ether (PBDE) chemicals be substituted by safer alternatives. RoHS 

does not require the substitution of any of the workgroup chemicals (EC, 2014). 

There are currently no state bans on any of the workgroup chemicals for use in electrical and 

electronic equipment. 
Page 19 of 54

Table 1-8: Approved and Effective Upholstered Furniture Flammability Performance Standards

Standard Test Requirement Notes Sources

Residential

CA TB117 Open flame test (12 sec) 

applied to uncovered foam

Cal/DCA (2000)

CA TB117-2013 Smolder test applied to 

miniature assembly of cover 

fabric, barrier materials, and 

filling materials. Fabric 

materials failing the smolder 

test can still be used if a fire 

barrier layer is added

Approved and will become effective on 1/1/2014 compliance 

mandatory by 1/1/2015. Uncertain what effect new rule will have 

on FR use in foam. Whether manufacturers will switch to non-FR 

foam will also depend on state and local regulations and/or 

possible CPSC standard.

Cal/DCA (2013)

US National Fire 

Protection Association 

(NFPA) 260 and 261

Smolder test applied to 

furniture mock-up

Similar to ASTM 1353 and UFAC standard. Due to changes to 

TB117, NFPA held an August 2013 meeting reviewed a request to 

consider establishing an open flame standard for upholstered 

furniture. NFPA is currently accepting public comments on the 

need for a new standard, available resources, and organizations 

involved in furniture flame retardant standards. Estimated to take 

2-3 years to develop. This would be a voluntary standard.

Durso (2013)

NFPA (2013)

ASTM E1352 Smolder test applied to 

furniture assemblies

Similar to NFPA 260 and UFAC standard ASTM 

International 

(2008)

Consumer Product 

Safety Commission 

(CPSC)

(1) Smolder test applied to 

cover materials; or

(2) Smolder and open flame 

test for fire barriers (interliners)

First proposed in 2008. In March 2013, CPSC requested comments 

on a large open flame standard which would be more stringent 

than the 2008 proposal. Held an April 2013 meeting barrier and 

other safety technologies.

CPSC (2008)

CPSC (2013)

Upholstered Furniture 

Action Council (UFAC)

Smolder test Voluntary industry standard. 73 manufacturers have taken UFAC 

pledge to adhere to smolder testing and has generally been 

adopted across the country (~90% of industry), despite being a 

voluntary program. However, this is most likely due to 

manufacturers adhering to the more rigorous CA TB 117 standard.

Durso (2013)

(US Senate, 

2012)

British Standard BS5852 Smolder and open flame test Typically met with combination of additive flame retardants UK Parliament 

(1998)
Page 20 of 54

Standard Test Requirement Notes Sources

Public Occupancy

CA TB133 Large open flame (80 sec) 

applied to assembled piece of 

furniture

PFA (1992b)

ASTM E1537 Open flame test Voluntary standard ASTM 

International 

(2013)

Massachusetts State Furniture must meet CA TB133 

or ASTM 1537. If occupancy 

equipped with automatic 

sprinklers, furniture can meet 

CA TB133 or TB117

Only applies to furniture used in public buildings Massachusetts 

Board of Fire 

Prevention 

Regulations 

(1994)

Boston Fire Code Furniture must meet CA TB133 

or ASTM E1537 

Only applies to public occupancy furniture sold in the city of 

Boston

Boston Fire 

Department 

(1995)

Illinois State Furniture must meet CA TB133 

(or CA TB117 if protected by an 

automatic sprinkler system)

Illinois 

Administrative 

Code, Title 41 

pt. 300.20

Minnesota State Furniture must meet CA TB133; 

upholstery fabric and filling 

must meet CA TB117

Only applies to furniture used in public buildings Minnesota State 

Fire Marshal 

(2006)

North Carolina State Furniture must meet CA TB133 

or ASTM E1537 heat release 

rate standards. Furniture must 

resist ignition by cigarettes 

following NFPA 260 or 261

Only applies to furniture used in public buildings North Carolina 

State Fire 

Marshal’s 

Association 

(2012)

Ohio State Furniture must meet CA TB133 

or ASTM E1537 heat release 

rate standards. Must resist 

ignition by cigarettes following 

NFPA 260 or 261

Only applies to furniture used in public buildings Ohio 

Administrative 

Code, 1301:7-7-

08
Page 21 of 54

Table 1-9: Proposed Flammability Performance Standards

State Bill Regulation Status Notes Source

New Jersey A2823 Residential and public upholstered 

furniture required to meet the 

combustibility requirements specified in CA 

TB116, 117, and 133

Introduced 

5/10/2012. 

Referred to 

Assembly Housing 

and Local 

Government 

Committee

New Jersey 

Assembly 

2823 (2012)

New York A06557/S047

80

Prohibits sale of residential upholstered 

furniture containing intentionally-added 

halogenated chemical flame retardants. 

Beginning 12/1/16, furniture sold in NY 

must meet open flame standard

Passed in 

Assembly, 

proposed in 

Senate, and 

reported to finance 

committee 

5/30/2013

Would take effect 7/1/2014 New York 

Senate Bill 

4780 (2013)

Texas HB2682 Upholstered furniture sold in the state to 

be made with filling that is burn resistant to 

an open flame

Business & 

Industry

committee report 

sent to Calendars 

Committee 

4/15/2011. Never 

voted on by House 

or Senate.

The House Calendars Committee 

holds the authority to place a bill on 

the House agenda for a vote. 

HB2682 was reported favorably by 

the Business & Industry Committee 

and the bill has not been explicitly 

rejected. However, because 

HB2682 was sent to Calendars over 

2 years ago, it appears unlikely that 

it will be scheduled for a vote. 

Texas House 

Bill 2682 

(2011)
 

Page 22 of 54

Table 1-10: Flammability Standards for Electronic Products

Standard Test Requirement Notes Sources

UL 94 V-0 rating: Vertical test. Flame is 

applied to specimen for 10 seconds. 

Specimen cannot burn for more than 

10 seconds after ignition

Voluntary standard. 

Small scale ignition 

resistance test 

(short circuit or 

candle) for 

electronic 

enclosures. 

UL, 2013a; UL 

IDES, No Date

V-1 rating: Flame is applied to 

specimen for 10 seconds. Vertical 

test. Specimen cannot burn for more 

than 30 seconds after ignition and 

must not drip flaming particles

V-2 rating: Flame is applied to 

specimen for 10 seconds. Vertical 

test. Specimen cannot burn for more 

than 30 seconds after ignition but 

can drip flaming particles

HB rating: Horizontal test. Flame is 

applied to specimen for 30 seconds, 

and specimen must stop burning 

before flame reaches 4 inch mark and 

a burning rate less than 1.5 in./min. 

UL 746C References UL 94. polymeric material 

in electronics and electrical parts

Voluntary standard UL, 2004

UL 796 Standard for printed wiring boards. 

References UL 94

Voluntary Standard UL, 2013b

1.8.3 Price

Chemtura has increased the price of Firemaster® 550 several times since the product’s 

introduction (Amdursky, 2008; ICB, 2005). For instance, the company increased the price of 

Firemaster® 550, 552, 500, and 602 by $0.30/lb, effective August 18th, 2008, citing the rising 

cost of elemental phosphorous and other raw materials (Amdursky, 2008). It also announced a 

price increase of all its bromine based products by up to 25% on March 29, 2010, due to the 

rising cost of bromine (Yacomeni, 2010). Data on the base price of TBB/TBPH could not be 

located. 

Chemtura introduced Firemaster® 800 in 2007, which is a modified version of Firemaster® 550. 

The company developed the product because Firemaster® 550 was too expensive for the 

Chinese market. Firemaster® 800 is lower in dosage than Firemaster ® 550, requiring less 

product (Hilgers, 2007). However, Firemaster 800 is not listed on Chemtura’s website and we 

cannot confirm if it is being produced at this time.

Data on the prices for the other three chemicals in the cluster could not be located. 
 

Page 23 of 54

2 ENVIRONMENTAL EXPOSURE

There has been a rapid increase in the number of monitoring studies that have reported the 

occurrence of TBPH and TBB at significant levels in various media (See Table 3-1 and Table 3-2). 

The additive flame retardant use of TBPH and TBB as an alternative to polybrominated diphenyl 

ethers within a variety of products has expanded over time. Detection of TBPH/TBB in sludge, 

sediment and indoor dust indicate a potential for exposures to the environment. Detection of 

TBPH in biota and environmental media indicates exposures have occurred and that global 

transport is occurring as well. A significant mass of these chemicals are added to many 

products we use every day such as couches, chairs and other upholstered furniture, etc. 

Additional data are needed to understand how, at what rate, and in what form TBPH and TBB

migrate out of many types of products. Source characterization, migration rates, and 

monitoring data are needed to demonstrate how the use of TBPH, TBB and Confidential A in 

certain products may result in subsequent exposure through migration of these chemicals into 

indoor and outdoor environments. More information on these data needs can be found in 

Section 2.1.

TBPH, TBB and CASRN 7415-86-3 are additive flame retardants while the other cluster 

members are reactive flame retardants. The nature of Confidential A and Confidential B cannot 

be disclosed.

Additive flame retardants are incorporated and dispersed throughout a product, but are not 

chemically bound to it. Additive flame retardants are more likely than reactive flame 

retardants to migrate from products or articles. Emissions from a single product or article may 

be small. However, combined emissions from all sources within various indoor 

microenvironments, residences, schools, public and commercial buildings, cars, trains, 

airplanes, may be significant. These chemicals may be released into dust and then into 

household waste water. It is predicted that once in the waste water treatment plant effluent, 

TBPH and TBB will partition to sludge. If the sludge is then used as biomass on farm lands and 

forests then releases would be widespread.

The TBPA-diols are reactive chemicals. Because these chemicals are chemically bound to the 

polymer, it is far less likely they will migrate from products or articles unless there is excess 

chemical present due to an incomplete polymerization reaction. The reactive members of the 

BPC, including the primary degradation product tetrabromophthalic acid, have not been 

reported in literature as being present in environmental or biological media.

2.1 Monitoring Data Summary

Levels of TBPH and TBB in the environment and biota are comparable to each other. 

Occurrence of both chemicals follow a similar pattern with higher levels found in sludge, 

sediment, and indoor dust and a similar amount and distribution of non-detects (ND). 
 

Page 24 of 54

Concentrations of TBPH and TBB were reported in indoor dust at levels ranging from ND to 

75,000 μg/kg. TBPH and TBB have been detected in indoor dust from homes, schools, 

commercial office buildings, cars, and airplanes (See Table 3-1 and Table 3-2). There is likely a 

correlation between reported dust concentrations and the total amount of TBPH and TBB 

contained within source products. The total contribution from all these sources, many of which 

are polyurethane foam articles of various kinds, contributes to the variety of dust 

concentrations reported from these different microenvironments. The rate and likelihood of 

migration of these additives from the wide variety of different polyurethane foams is an 

important data need to understand the relationship of product use and environmental 

concentrations. There are 11 data sources reporting TBB in dust (Table 3-1) and 13 data 

sources reporting TBPH in dust (Table 3-1). TBPH was detected in 100% of all dust samples for 

all studies reviewed to date. Two studies detected TBPH and TBB in indoor air. Detectable 

levels of TBPH and TBB in indoor air are likely to be present as suspended particles which will 

ultimately deposit to indoor dust over time. Dust can be suspended via many common 

mechanisms, such as vacuuming, sweeping and the relationship between suspended particles 

and settled dust is important for understanding exposures over time. 

There are five data sources that characterize TBPH (Ma et al., 2012; Moller et al., 2012; 

Schlabach et al., 2011; Shoeib and Jantunen, 2013; Xiao et al., 2012) and TBB (Bradman et al., 

2012; Ma et al., 2012; Moller et al., 2012; Schlabach et al., 2011; Shoeib and Jantunen, 2013; 

Xiao et al., 2012) levels in ambient air at reported concentrations up to 3e-1 μg/m3. Levels are 

expected to vary spatially. Two of these studies (Moller et al., 2012; Xiao et al., 2012) sampled 

only extremely remote locations with no known sources of TBPH and TBB in close proximity, 

indicating the potential for long-range transport. However, there is not enough data yet 

available to characterize how levels of TBPH and TBB may vary spatially or in proximity to 

centralized or diffuse sources. TBPH and TBB are generally found in the air associated with

particulates, which would be available for human exposure and would be expected, over time, 

to deposit to terrestrial and aquatic ecosystems. 

Biosolids or Sludge treated at industrial and municipal wastewater treatment plants have 

shown significant concentrations up to 89,900 μg/kg for TBB and 33,500 μg/kg for TBPH (Davis 

et al., 2012). The high logKOW of these chemicals means they are more likely to absorb onto 

particles and be removed from the water during wastewater treatment. The relative source 

contribution of these chemicals into wastewater treatment plants is believed to be from nonpoint sources since point sources should be controlled. The likely very small down the drain 

loading from several hundred thousand source residential and public and commercial buildings 

every day may result in the relatively high concentrations reported in the literature. 

There are five data sources that characterize TBPH and TBB (Klosterhaus et al., 2012; La 

Guardia et al., 2012; La Guardia et al., 2013; Schlabach et al., 2011; Zhu et al., 2013) levels in 

aquatic environments. These chemicals are not expected to be present in surface water, and 

instead partition to sediment. These studies report concentrations in sediment ranging from 

ND to 13,900 for TBB (Table 3-2) and ND to 19,200 for TBPH (Table 3-1), with more typical 
 

Page 25 of 54

concentrations in the tens and hundreds of μg/kg. Higher concentrations were reported near 

Wastewater Treatment Plants and in urban areas. 

There were only 12 studies available that characterized levels of TBPH (Table 3-1) and TBB

(Table 3-2) in one or more of the following biota: terrestrial animals, aquatic animals, fish, birds, 

vegetation, and humans. For comparison, there were 13 articles summarizing TBPH dust levels. 

Some biota, such as vegetation, human blood, and terrestrial organisms were only represented 

by one or two studies. For Human blood, a TBPH concentration of 260 μg/kg was reported in a 

2011 pooled blood sample of 30-39 year old Females in China (He et al., 2013). TBPH was not 

detected in the same study from two pooled 2007 samples (He et al., 2013). TBPH and TBB

have recently been detected in a wide range of biota samples ranging from cat hair, dog hair, 

arctic fox liver, guillemot bird eggs, cormorant bird eggs, peregrine falcon bird eggs, ring billed 

gull bird liver, black legged kittiwake bird liver, common eider bird liver, and polar bear blood 

plasma for terrestrial animals and several species of fish muscle and fish liver, freshwater blue 

mussels, freshwater clams, freshwater gastropods, ringed seal liver, dolphin blubber, porpoise 

blubber, and harbor seal blubber for aquatic animals. The highest reported concentration of 

TBB was in a freshwater clam at 2220 μg/kg and the highest reported concentration of TBPH

was in porpoise blubber at 3589 μg/kg. Table 3-1 provides a summary of available monitoring 

data for TBPH and Table 3-2 provides a summary of available monitoring data for TBB. 

Summary of each individual data sources are provided in Appendix A.

2.2 Data Needs

1) Source Characterization 

a. Type of Foam (with clear definition) and type of end-use product (with clear 

definition). Explicitly and clearly link these. Review definitions included in 

Appendix B - Definitions

b. Percent weight of chemical within the product 

c. Based on the type of foam, what are the properties of those foams: density, 

rigidity, and structure 

2) Migration of Additive chemicals out of Polyurethane Products

a. Thickness of product

b. Surface area exposed

c. Diffusion coefficient

d. Partition Coefficient

e. Migration rate of FR over time

3) Monitoring Data

a. Indoor environments, homes, commercial buildings, cars, trains, where high 

concentrations of polyurethane products are present

b. Environmental samples: Soil, sludge, sediment 

c. Biota samples, human blood of highly exposed individuals who spend significant 

amounts of time in close proximity to products containing TBB and TBPH 

chemicals, vegetation grown on amended soil with land applied sludge, 

earthworm, sediment dwelling aquatic organisms 
 

Page 26 of 54

3 HUMAN EXPOSURE 

3.1 Occupational Exposures to the Cluster Chemicals

The chemicals in this cluster are not on the Occupational Safety and Health Administration’s 

(OSHA) list of regulated chemicals (OSHA, 2013). There is some non-confidential Chemical Data 

Reporting (CDR) information on the number of manufacturing workers and concentrations

(EPA, 2012a). Based on the physical-chemical properties (e.g., liquid with low vapor pressure 

ranging from <1E-6 Torr [estimated to <1.0 E-3 Torr at 25 oC] and available information on 

manufacturing process, workers in the chemical manufacturing sector are not expected to be 

exposed to the chemicals via inhalation.

3.2 Occupational Exposures to Polyurethane Foams (PUF) 

Containing the Cluster Chemicals

Limited information is available on occupational exposure to polyurethane foam during foam 

manufacturing. 

Polyurethane foams (PUF) vary widely in their stiffness, but are generally considered as either 

flexible or rigid types (EPA, 2005). Flexible PU foams can be shaped easily by cutting and 

molding with a variety of densities. They are typically used behind other materials in products 

such as the upholstery in furniture, or in flexible plastics. The total amount of flame retardant 

as percentage of volume of foam is approximately 5 percent (Cobb and Chen, 2005; Stapleton 

et al., 2009).

Flexible PUF can be divided into two type (EPA, 2005); slabstock and molded foam.

Slabstock foam components are poured onto flat surfaces and expand into a slab shape.

Molded foam components are poured into a mold. They are typically used in the automotive 

industry. Although no exposure information is available, based on the vapor pressure and 

available information on manufacturing, EPA expects that inhalation exposure is negligible.

No exposure information is available and EPA is unable to address this potential occupational 

exposure scenario.
 

Page 27 of 54

Table 3-1: Summary Table of TBPH Monitoring Data

Media Number 

of Data 

Sources

Number 

of 

overall 

Samples

Number 

of nondetects

(ND)*

% 

Samples 

not ND

Range Median 

(Mean) of 

quantifiabl

e samples+

References

Environmental Media

Dust 13 83 0 100% 1 to 47,110 

μg/kg

133 

(2,200) 

μg/kg

(Ali et al., 2012; Allen et al., 2013a; Allen et al., 

2013b; Bradman et al., 2012; Dodson et al., 

2012; Gheorghe et al., 2013; Johnson et al., 

2013; Kopp et al., 2012; Sahlstrom et al., 2012; 

Shoeib et al., 2012; Springer et al., 2012; 

Stapleton et al., 2008a; Stapleton et al., 2009; 

Stapleton et al., 2008b; Van den Eede et al., 

2012)

Indoor Air 2 6 1 83% ND to 0.007 

μg/m3

** (Bradman et al., 2012; Schlabach et al., 

2011)

Ambient 

Air

5 76 15 80% ND to 0.29 

μg/m3

5.3e-4 

(8.1e-3) 

μg/m3

(Ma et al., 2012; Moller et al., 2012; 

Schlabach et al., 2011; Shoeib and 

Jantunen, 2013; Xiao et al., 2012)

Biosolids/S

ludge

4 36 5 86% ND to 33,500 

μg/kg

40 (2,040) 

μg/kg

(Davis et al., 2012; de Wit et al., 2011; 

La Guardia et al., 2010; Schlabach et 

al., 2011)

Sediment 5 75 33 56% ND to 19,200 

μg/kg

93 (792) 

μg/kg

(Klosterhaus et al., 2012; La Guardia et 

al., 2012; La Guardia et al., 2013; 

Schlabach et al., 2011; Zhu et al., 2013)

Surface 

Water

1 1 1 0% ND ** (Schlabach et al., 2011)

Biological Media

Terrestrial 

animals

2 10 2 80% ND to 1.6 

μg/kg

** (Ali et al., 2013; Sagerup et al., 2010)
 

Page 28 of 54

Media Number 

of Data 

Sources

Number 

of 

overall 

Samples

Number 

of nondetects

(ND)*

% 

Samples 

not ND

Range Median 

(Mean) of 

quantifiabl

e samples+

References

Aquatic 

animals

5 65 37 43% ND to 3,590 

μg/kg

** (de Wit et al., 2011; La Guardia et al., 

2012; Sagerup et al., 2010; Schlabach 

et al., 2011; Sühring et al., 2013)

Fish 2 17 6 65% ND to 0.7 

μg/kg

** (Sagerup et al., 2010; Schlabach et al., 

2011)

Birds 5 21 7 66% ND to 465 

μg/kg

** (Gentes et al., 2012; Guerra et al., 

2012; Klosterhaus et al., 2012; Sagerup 

et al., 2010; Schlabach et al., 2011)

Vegetation 1 3 2 33% 0.039 μg/kg ** (Schlabach et al., 2011)

Human 

Blood

1 12*** 11 9% 260 μg/kg ** (He et al., 2013)

TOTAL 394 117 70%

 +

“quantifiable samples” do not include samples identified as non-detects

 * non-detects conservatively include all samples reported as ND, <Level of Detection, <Level of Quantification, <Minimum Detection Limit, and less than

 a number which was generally small and was either one of the numbers above or a slightly larger number

 ** not a sufficient sample size to estimate summary statistics for this media

 *** pooled samples several hundred individuals. 10 pooled samples from 2011, and 2 pooled samples from 2007. Quantifiable sample was from 2011. 
 

Page 29 of 54

Table 3-2: Summary Table of TBB Monitoring Data

Media Number 

of Data 

Sources

Number 

of 

overall 

Samples

Number 

of nondetects 

(ND)*

% Samples 

not ND

Range Median 

(Mean) of 

quantifiabl

e 

samples**

References

Environmental Media

Dust 11 73 12 84% ND to 

75,000 

ug/kg

91 (3,880) 

ug/kg

(Ali et al., 2012; Allen et al., 2013a; Allen et al., 

2013b; Bradman et al., 2012; Dodson et al., 2012; 

Gheorghe et al., 2013; Johnson et al., 2013; Kopp et 

al., 2012; Sahlstrom et al., 2012; Shoeib et al., 2012; 

Springer et al., 2012; Stapleton et al., 2008a; 

Stapleton et al., 2009; Stapleton et al., 2008b; Van 

den Eede et al., 2012)

Indoor Air 2 6 2 66% ND to 

0.007 

ug/m3

*** (Bradman et al., 2012; Schlabach et al., 

2011)

Ambient 

Air

6 74 25 66% ND to 5.5e2 ug/m3

3.8e-4 

(2.6e-3) 

ug/m3

(Ma et al., 2012; Moller et al., 2012; 

Schlabach et al., 2011; Shoeib and 

Jantunen, 2013; Xiao et al., 2012)

Biosolids/

Sludge

4 34 12 65% ND to 

89,900 

ug/kg

1.8

(5,800) 

ug/kg

(Davis et al., 2012; de Wit et al., 2011; La 

Guardia et al., 2010; Schlabach et al., 2011)

Sediment 5 74 20 74% ND to 

13,900 

ug/kg

150 (557) 

ug/kg

(Klosterhaus et al., 2012; La Guardia et al., 

2012; La Guardia et al., 2013; Schlabach et 

al., 2011; Zhu et al., 2013)

Biological Media

Terrestrial 

animals

1 4 0 100% 0.9 to 415 

ug/kg

*** (Sagerup et al., 2010)
 

Page 30 of 54

Media Number 

of Data 

Sources

Number 

of 

overall 

Samples

Number 

of nondetects 

(ND)*

% Samples 

not ND

Range Median 

(Mean) of 

quantifiabl

e 

samples**

References

Aquatic 

animals

6 44 13 70% ND to 

2,220 

ug/kg

*** (Bradman et al., 2012; Klosterhaus et al., 

2012; La Guardia et al., 2012; Sagerup et al., 

2010; Schlabach et al., 2011; Villaverde-deSáa et al., 2013)

Fish 3 18 9 50% ND to 203 

ug/kg

*** (Klosterhaus et al., 2012; Sagerup et al., 

2010; Schlabach et al., 2011)

Birds 4 14 4 71% ND to 39 

ug/kg

*** (Gentes et al., 2012; Klosterhaus et al., 2012; 

Sagerup et al., 2010; Schlabach et al., 2011)

Vegetatio

n

1 2 2 0% ND *** (Schlabach et al., 2011)

TOTAL 312 97 69%

 * non-detects conservatively include all samples reported as ND, <Level of Detection, <Level of Quantification, <Minimum Detection Limit, and less than 

 a number which was generally small and was either one of the numbers above or a slightly larger number

 **“quantifiable samples” do not include samples identified as non-detects*** not a sufficient sample size to estimate summary statistics for this media
 

Page 31 of 54

3.2.1 Slabstock Polyurethane Foam

The slabstock manufacturing process is a continuous process that produces long, rectangular, 

continuous slabs of foam, called “buns”. Buns are cut into the desired configuration for an 

application, such as in furniture padding, bedding, automobile padding and seats, packaging 

materials, and carpet padding.

The typical commercial process for slabstock foam production consists of a single

unit operation, operated in batches (Figure 3-1).

Figure 3-1: Typical Slabstock Production Line for flexible polyurethane foam (EPA, 2005)

3.2.2 Molded Polyurethane Foam

Molded foam is produced when the foam polymerization reaction occurs in a closed mold 

resembling the final product. Molded foam is used in the transportation industry for seat 

cushions and interior trim, furniture, bedding, packaging materials, toys, and novelty items. 
 

Page 32 of 54

The typical commercial process for molded foam production consists of a circular production 

line containing multiple molds and process stations. Figure below (Figure 1-2) presents a 

diagram of this process.

Raw materials for molded foam are similar to those used in slabstock foam production, 

including polyol, diisocyanates, water, catalyst, surfactant, and other additives (e.g., flame 

retardants). The raw materials are pumped to a common mix head above the production line. 

Many ingredients are premixed to minimize the streams being fed to the head and to ensure 

precise measurement. The mix head dispenses a measured amount of the mixture into each 

mold and the molds are then heated to accelerate foam curing. Heating takes place either by 

passing the mold through a curing oven or passing heated water through tubes in the mold. 

Then, the mold is opened and emptied. The mold continues through the process line to be 

conditioned for the next product. After removal from the mold, the foam is further processed 

into the final desired shape. These activities include curing, trimming, and gluing.

Figure 1-2: Typical Molded Foam Production Line for flexible polyurethane foam (EPA, 2005)

There is no readily available information on the environmental releases of the chemicals in this 

cluster during the manufacture of PU foams. An existing generic scenario for PU flexible foam 

manufacturing can be used to estimate releases and occupational exposures.
 

Page 33 of 54

3.3 Occupational Exposure during the Manufacture of 

Products containing Polyurethane Foams (PUF) 

Foam containing one or more of the chemicals in this cluster is used during manufacture of the 

products described in Sections 1.5 and 1.6 of this report.

No data are available on occupational exposure during the manufacture of products containing 

PU foam. Based on OSHA’s Particulates Not Otherwise Regulated (inhalable and respirable 

dust) standards, a “high-end" exposure-based scenario could be used to determine the 

potential exposure to foam particulates during the manufacture of products containing PU 

foam. 

3.4 Occupational Exposure from the Use of Products 

containing Polyurethane Foams (PUF) 

No exposure information is available and EPA is unable to address this potential occupational 

exposure scenario. 

3.5 Consumer Exposure from the Use of Products containing 

Polyurethane Foams (PUF) 

The exposure potential of TBPH and TBB is influenced by several parameters of the source 

material to which these chemicals are added. One of the major sources of exposure is 

considered to be certain types of polyurethane foam (PUF) products based on the following 

criteria as compared to other product end uses: major use-based production volume, higher 

percent of flame retardant chemicals within the product, long service life/product use within 

indoor environments, diverse set of large articles with large surface areas exposed, and 

multiple sources present within various indoor environments. Differences in density, rigidity, 

and structure (closed vs. open cells) dictate which types of foams can be used in various 

products (see Figure 1.1 Property Matrix of Polyurethanes in Huntsman Polyurethanes Book). 

Polyurethanes can be broken into four broad categories: 

1) Low Density Flexible Foams- Open Cell

2) Low Density Rigid Foams- Open Cell and Closed Cell –

3) High Density Flexible Foams (microcellular foams) –Open Cell and Closed Cell 

4) Solid Polyurethanes (Coatings (paints), Adhesives, Sealants, Elastomers)-

Differences in density, rigidity, and structure (closed vs. open cell) along with the thickness of 

the product and its exposed surface area influence the likelihood of migration and associated 

exposure potential of TBB and TBPH over time. Lower density, thinner, open-cell flexible 

foams, with large amounts of exposed surface area have may have greater potential for 

additive migration over time. However, it is not clear if there may threshold values for one or a 

combination of these factors that could influence migration and exposure potential. Definitions 
 

Page 34 of 54

of polyurethane foam types and product end uses are provided in Appendix B and comments 

on these definitions as well as on which products are likely to be major contributors based on 

available, or collected data is of interest. 

3.6 Data Needs

1) Source Characterization 

a. Type of Foam (with clear definition) and type of end-use product (with clear 

definition). Percent weight of chemical within the product 

b. Percent weight of chemical within product

c. Based on the type of foam, what are the properties of those foams: density, 

rigidity, and structure 

2) Migration of Additive chemicals out of Polyurethane Products

a. Thickness of product

b. Surface area exposed

c. Diffusion coefficient

d. Partition coefficient

e. Migration rate of FR over time

3) Monitoring Data

a. Indoor environments, homes, commercial buildings, cars, trains, where high 

concentrations of polyurethane products are present

b. Environmental samples: Soil, sludge, sediment 

c. Biota samples, human blood of highly exposed individuals who spend significant 

amounts of time in close proximity to products containing TBB and TBPH

chemicals, vegetation grown on amended soil with land applied sludge, 

earthworm, sediment dwelling aquatic organisms 

4 ENVIRONMENTAL EXPOSURE 

4.1 Background and Context of Cluster Chemical 

Manufacture

The chemicals in this cluster have similarities in structure. One notable similarity is that the 

various alkyl esters are attached to the main tetrabromophthalate structure. 2-Ethylhexyl2,3,4,5-tetrabromobenzoate (TBB) is manufactured by reacting tetrabromophthalic anhydride 

with appropriate alcohol in the presence of decarboxylation catalyst. This reaction proceeds 

through rapid esterification of anhydride, followed by decarboxylation to yield the 

tetrabromobenzoate. Depending on which alkyl group is attached to the alcohol being used, 

one or more chemicals in this cluster are produced (Albemarle - GLCC, 2004; Hill et al., 1997).
 

Page 35 of 54

4.2 Releases to the Environment during Cluster Chemical 

Manufacture

The chemicals in this cluster are not on the Toxic Release Inventory (EPA, 2012a), and no readily 

available public information on releases from manufacturing was found. Non-CBI (Confidential 

Business Information) Chemical Data Reporting (CDR) production volumes are available for two 

of the member chemicals of this cluster: CASRN 26040-51-7 and CASRN 20566-35-2 (EPA, 

2012a). The reported production volumes for 2011 were between 1 to 10 million lbs for TBPH

(CASRN 26040-51-7) and 2-(2-hydroxyethoxy) ethyl 2-hydroxy propyl 3,4,5,6 

tetrabromobenzene dicarboxylate (CASRN 20566-35-2). The release of TBB to water from 

manufacturing and processing is regulated by EPA (40 CFR Section 721.2925). 

4.3 Releases to the Environment during Polyurethane Foams 

(PUF) Manufacture

There is no readily available information on the environmental releases of the chemicals in this 

cluster during the manufacture of PU foams. An existing generic scenario for polyurethane 

flexible foam manufacturing can be used to estimate releases and occupational exposures. The 

release of TBB to water from manufacturing and processing is regulated by EPA (40 CFR Section 

721.2925). 

4.4 Releases to the Environment during the Manufacture of 

Products containing Polyurethane Foams (PUF) 

There is no readily available information on the environmental releases of the chemicals during 

the manufacture of products containing PU foam. EPA can use estimates following the 

approach taken in the New Chemicals Program to prepare a screening-level assessment based

on a selected number of industries/exposure scenarios for the two chemicals for which data are 

available (TBPH and CASRN 20566-35-2). 

4.5 Releases to the Environment during the Occupational Use 

of Products containing Polyurethane Foams (PUF)

No release information is available and EPA is unable to assess release from the uses of 

products containing PU foam.
 

Page 36 of 54

Table 4-1: Comparison of Different Polyurethane Foam Products
 

Page 37 of 54

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APPENDICES

Appendix A Summary of Monitoring Data Sources

A-1 Indoor Environments

Dust samples from the living rooms, bedrooms, and vacuum bags were collected from homes in 

Boston. Detection rates were 100% for TBPH and ranged from 86% to 100% for TBB. 

Concentrations ranged from 1.5 to 10,360 μg/kg for TBPH and ranged from ND to 15,030 ug/kg 

for TBB. Concentrations of dust were generally higher in the main living room areas of the 

homes (Stapleton et al., 2008a). 

 

A pooled sample of 50 TBB and TBPH dust samples taken over five years from Boston Homes 

was reported in 2009. The concentration of TBB in dust ranged from ND to 75,000 μg/kg and 

the concentration of TBPH ranged from ND to 47,110. It is noteworthy, that the 75,000 μg/kg 

value is the highest reported concentration (Stapleton et al., 2009). 

Thirty-four living room dust and sixteen mattress vacuum dust samples were taken from New 

Zealand homes. TBB was detected at concentration ranging from <2 to 2,285 μg/kg and TBPH

in the range of <2 to 640 μg/kg. There was a correlation (p < 0.05) between floor and mattress 

dust concentrations in each house for TBPH (Ali et al., 2012). 

Dust samples from 19 airplanes were collected in two locations: vacuumed carpet and 

vacuumed air return vents from the airplane wall. TBB and TBPH were detected in 100% of the 

40 samples. Dust Concentrations of TBB ranged from 200 to 3,000 μg/kg on the floor and 300 

to 5,000 μg/kg in vents. Dust Concentrations of TBPH ranged from 400 to 1,600 μg/kg on the 

floor and 350 to 3,600 μg/kg in vents (Allen et al., 2013b).

Sixteen paired samples of dust were taken from California homes in 2006 and then again in 

2011. Decreases in dust concentrations of PBDEs and increased dust concentrations of TBB and 

TBPH were reported. It was reported that these trends were likely due to changes in product 

composition within homes over this time period; that is the substitution of TBB and TBPH for 

PBDEs. In 2006, concentrations of TBB ranged from 4 to 740 μg/kg g and in 2011 

concentrations increased and ranged from 45 to 5900 μg/kg. In 2006, concentrations of TBPH

ranged from 36 to 1900 μg/kg and in 2011 concentrations increased and ranged from ND to 

3800 μg/kg. Median concentrations also increased by a factor of 2. The authors reported that 

there was a significant statistical association (p<0.05) between reduced PBDE concentrations 

and participant-reported new product installation in three homes, suggesting that replacement 

of articles can reduce exposure (Dodson et al., 2012). 

Samples were collected from apartments in Romania. TBB and TBPH concentrations were 

similar, with a median value reported for TBPH of 31 μg/kg. The authors note that carpet, as 

opposed to hard surface floors, may be an important reservoir for dust (Gheorghe et al., 2013).
 

Page 47 of 54

Thirty-eight samples from vacuum bags in the United States detected TBB and TBPH at 47% and 

63% respectively. The concentrations of TBB ranged from ND to 72,460 ug/kg and the 

concentrations of TBPH ranged from ND to 47,110 μg/kg (Johnson et al., 2013). 

Samples were collected from vacuum cleaner bags from German homes. Concentrations of 

TBB in dust ranged from 3 to 8 μg/kg and concentrations of TBPH in dust ranged from 24 to 535 

μg/kg (Kopp et al., 2012).

TBB and TBPH were measured in six apartments in Sweden. The concentrations of TBB ranged 

from 25 to 330 μg/kg and the concentrations of TBPH ranged from 260 to 950 μg/kg (Sahlstrom 

et al., 2012).

Vacuum bag dust samples were collected from homes in Vancouver Canada. 96% of 116 

samples detected TBB and 100% of 116 samples detected TBPH. Concentrations of TBB ranged 

from ND to 18,000 μg/kg and concentrations of TBPH ranged from 0.1 to 6400 μg/kg (Shoeib et 

al., 2012). 

Reported TBPH dust concentrations were significantly different in residences, offices, and cars. 

Dust samples were collected in Boston, MA after 10 minutes of vacuuming in each different 

microenvironment. TBPH was detected in: 74% of house dust with a median concentration of 

150 μg/kg (range LOD to 12,400 μg/kg, 100% of office dust with a median concentration of 410 

μg/kg (range 95 to 15,500 μg/kg), and 90% of car dust with a median concentration of 400 

μg/kg (range LOD to 830 μg/kg) (Springer et al., 2012). 

Twelve vacuum cleaner dust samples were taken from indoor residences in Europe (Belgium). 

All the samples for TBB were below the level of quantification for the analytical method used in 

this study (9 μg/kg). The concentrations of TBPH ranged from 2.4 to 12.7 μg/kg (Van den Eede 

N et al., 2011).

Three indoor air samples of TBB and three indoor air samples of TBPH were collected in Oslo, 

Norway. Indoor air sampling volumes were approximately 5 m3 and the sampling time was one 

week. It was reported that levels of brominated ethers and esters were higher in the indoor air 

samples compared to outdoor air from this study (Schlabach et al., 2011).

A 2012 study of childcare environments in California prepared for California Air Resources 

Board measured TBB and TBPH in the dust and indoor air of childcare environments. TBB and

TBPH were both detected in 100% of dust samples. TBB concentrations ranged from 85.2 to 

14,812 μg/kg and TBPH concentrations ranged from 28.8 μg/kg to 7489 μg/kg. TBB was 

detected in 15% of 40 of indoor air samples with concentrations ranging from ND to 0.016 

μg/m3, and TBPH was detected in 17% of samples with concentrations ranging from ND to 

0.005 μg/m3(Bradman et al., 2012). 
 

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A-2 Ambient Air

An extensive monitoring study was conducted at six sites around the Great Lakes Region with 

502 air samples collected between 2008 and 2010. TBB and TBPH were detected in the particle 

phase only in over half of the samples. Urban areas tended to show higher concentrations, and 

air concentrations tended to increase over the sampling timeframe. The maximum 

concentration of TBB was 5.5e-2 and the maximum concentration for TBPH was 2.9e-1μg/m3

(Ma et al., 2012).

Vapor and Particulate ambient air samples were taken above the ocean on a cruise from 

Southeast Asia toward the Antarctic. Despite the remote location, TBB and TBPH were 

detected in the particulate phase, with maximum concentrations of TBB up to 2.1e-4 μg/m3 and 

concentrations of TBPH up to 2.8e-3 μg/m3(Moller et al., 2012).

TBB was one of the substances most frequently detected in ambient air in a 2011 study of 

Nordic countries. The maximum reported ambient air concentrations for TBB and TBPH were 

similar and were both collected in Oslo Norway. The maximum concentration for TBB was 1.4e3 μg/m3 and the maximum concentration for TBPH was 1.7e-3 μg/m3

(Schlabach et al., 2011).

About 500 m3 of high volume air samples were collected over 24 hours in the ambient air over 

the Great Lakes. TBB and TBPH were detected less frequently and at lower levels than other 

flame retardants at concentrations up to 1.8-3 μg/m3(Shoeib and Jantunen, 2013). 

Over the course of approximately one year, ambient air samples were taken in the Tibetan 

Plateau and the Canadian High Arctic. Both of these sites are extremely remote. The authors 

note that TBB and TBPH were detected at concentrations similar to Brominated Diphenyl 

Ethers. The maximum ambient air concentration for TBB was 2.2e-3 μg/m3, and the maximum 

ambient air concentration of TBPH was 1.5e-3 μg/m3(Xiao et al., 2012).

A 2012 study of childcare environments in California prepared for California Air Resources 

Board measured TBB and TBPH in ambient air near childcare centers. TBB and TBPH were both 

detected in 12.5% of 40 samples. TBB concentrations ranged from ND to 0.001 ug/m3 and 

TBPH concentrations ranged from ND to 0.004 μg/m3(Bradman et al., 2012). 

A-3 Sludge/Biosolids

Sewage sludge from the drying lagoons was collected from a Mid-Atlantic treatment plant 

between 2002 and 2008. The reported concentration of TBB ranged from 3430 to 89,900 μg/kg 

of total organic compounds (TOC), and the reported concentration of TBPH ranged from 64 to 

33,500 μg/kg TOC. The authors suggest that domestic sources may be responsible for a large 

percentage of TBB and TBPH detected in sewage sludge (La Guardia et al., 2010). 
 

Page 49 of 54

Sewage sludge was collected from eight wastewater treatment plants. TBB was detected in 

two of the eight plant’s sewage sludge at concentrations of 128 and 2491 ng/g dw. TBPH was 

detected in all but one of the plant’s sewage sludge at concentrations that ranged from 206 to 

1631 ng/g dw. The authors suggest that migration out of consumer products and during the 

wastewater treatment process is related to observed concentrations of TBB and TBPH in 

sewage sludge. 

Concentrations of TBB in sewage sludge from a wastewater treatment plant in San Francisco 

ranged from 40 to 1,412 ug/kg and concentrations of TBPH ranged from 57 to 515 μg/kg 

(Klosterhaus et al., 2012).

TBPH had a high frequency of detection and also had the highest concentration in sludge when 

compared to all other flame retardants measured during this study with a concentration of 

1,420 μg/kg in sludge. TBB was also detected with high frequency and concentrations in sludge 

ranged from ND up to 2.6 μg/kg (Schlabach et al., 2011). 

A-4 Aquatic Environments

Several sediment samples were taken near and downstream from a waste water treatment 

plant (WWTP) that processed both industrial and municipal wastewater in North Carolina. 

Concentrations for both TBB and TBPH were highest at the outfall of the WWTP and decreased 

with distance. Concentrations of TBB at outfall were 38,500 μg/kg and decreased to 80 μg/kg 

40 km downstream. Concentrations of TBPH at outfall were 19,200 μg/kg and decreased to 

2,000 μg/kg 40 km downstream (La Guardia et al., 2012). 

Forty-five sediment samples were detected in urban waterways in South Africa. TBB was 

detected in 91% of samples and concentrations ranged from ND to 13,900 ug/kg with a mean of 

545 μg/kg. TBPH was detected in 60% of samples and concentrations ranged from ND to 899 

μg/kg with a mean of 96 μg/kg (La Guardia et al., 2013).

Ten sediment samples were taken in San Francisco Bay in 2012. TBB and TBPH were not 

detected in these samples. However the authors report that detection may have been 

compromised by matrix interferences in all samples (Klosterhaus et al., 2012).

A Nordic study found a low frequency of detection for TBPH (3 out of 12) and TBB (2 out of 12) 

in sediment. The concentration of TBB ranged from 0.04–0.2 μg/kg. TBPH concentrations were 

higher and ranged from 0.2 to 3 μg/kg. The highest concentration was found in sediment close 

to a WWTP outlet in Sweden (Schlabach et al., 2011).

 

TBPH was detected in six samples of riverine sediment in the Yangtze River of China, with a 

mean concentration of 1 μg/kg and a range of 0.5 to 3 ug/kg. TBB was detected in two samples 

with a mean concentration of 0.4 μg/kg and a range of ND to 1 μg/kg. Both TBPH and TBB were 

not detected in 24 marine sediment samples (Zhu et al., 2013).
 

Page 50 of 54

A-5 Aquatic Animals and Fish

Several samples of bivalves and gastropods were taken near and downstream from a WWTP 

that processed both industrial and municipal wastewater in North Carolina. Concentrations of 

TBB in bivalves at outfall were 2220 μg/kg and were not detected at any distance downstream, 

and concentrations in gastropods at outfall were 1740 μg/kg at outfall and were not detected 

at any distance downstream. Concentrations of TBPH in bivalves at outfall were 1370 μg/kg 

and decreased to 37 μg/kg 40 km downstream, and concentrations in gastropods were 380 

μg/kg at outfall and decreased to 36 ug/kg 40 km downstream (La Guardia et al., 2012).

Seventeen dolphins and thirty-three porpoises were sampled in South China. All the dolphin 

samples had TBB concentrations below the level of quantification (LOQ) which was 0.04 μg/kg 

lipid weight. The average concentration of TBB in porpoises was 5.6 μg/kg with a range of 

<LOQ to 70 μg/kg. TBPH was detected in dolphins with an average concentration of 0.51 μg/kg 

and a range of <LOQ to 5.3 μg/kg. The average concentration of TBPH in porpoises was 342 

μg/kg with a range of <LOQ to 3859 μg/kg, which also is the highest reported concentration of 

TBPH in biota. The authors report a lack of knowledge of the sources, distribution, and fate of 

TBB and TBPH and recommend additional research to determine exposure pathways (Lam et 

al., 2009).

TBB was detected in 21 samples of porpoise blubber from the UK in 2008. Samples ranged 

from ND to 3.44 μg/kg wet weight (Law et al., 2013).

TBB was not detected in a small number of samples of white croaker, perch, and adult and pup 

harbor seal blubber collected in San Francisco Bay in 2012. TBPH was not detected in a small 

number of samples of cormorant eggs. However the authors report that detection may have 

been compromised by matrix interferences in all samples (Klosterhaus et al., 2012).

Seven different species in Scandinavia were sampled for a variety of flame retardants including 

TBB and TBPH. Two of these species were aquatic. The Capelin is a smelt fish that is an 

important food source for other fish. Ten samples were collected for each species. TBB was 

detected in 100% of samples with a mean whole fish wet weight concentration of 0.37 μg/kg. 

TBPH was detected in 90% of samples with a mean whole fish wet weight concentration of 0.72 

μg/kg. Ten ringed seal liver samples were collected. TBB was detected in 100% of samples with 

a concentration of 0.43 μg/kg. TBPH was detected in 60% of samples with concentration of 

0.57 μg/kg (Sagerup et al., 2010). 

Five samples of fish liver, nine samples of fish muscle, and three samples of mussel were 

sampled for TBB and TBPH as well as several other flame retardants in Norway. The 

concentration of TBPH in fish liver ranged from ND to 0.049 μg/kg. The concentration of TBPH 

in fish liver ranged from ND to 0.46 μg/kg, and the concentration of TBPH in mussels ranged 

from 0.009 to 0.057 μg/kg. The concentration of TBB in fish liver ranged from ND to 0.12 μg/kg. 
 

Page 51 of 54

The concentration of TBB in fish muscle ranged from ND to 0.022 μg/kg, and the concentration 

in mussels ranged from 0.0041 to 0.0049 μg/kg (Schlabach et al., 2011). 

TBB was not detected in raft cultured mussel, clam, or cockle samples, but was detected in wild 

mussel samples with a concentration of 0.06 μg/kg (Villaverde-de-Sáa et al., 2013).

A-6 Terrestrial Animals, Vegetation and Birds

Samples were taken from the serum and hair of twenty cats and sixteen dogs in Pakistan. TBB

was detected in approximately one-half of hair samples at levels up to 1μg/kg in cats and 

1.25 μg/kg in dogs. TBPH was also detected in approximately one-half of hair samples at levels 

up to 1.65 μg/kg in cats and 0.8 μg/kg in dogs. TBB and TBPH were not detected in serum 

samples (Ali et al., 2012).

TBB was detected in 11% of 28 ring bill gull liver samples collected from the St. Lawrence River, 

Canada with concentrations ranging from ND to 1.55 μg/kg wet weight and ND to 38.6 μg/kg 

lipid weight. TBPH was detected in 89% of 28 ring bill gull liver samples with concentrations 

ranging from ND to 17.6 μg/kg wet weight and ND to 465 μg/kg lipid weight. The average 

concentration of TBPH was 2.16 μg/kg wet weight and 58.3 μg/kg lipid weight. TBB and TBPH

were not detected in 30 plasma samples of ring bill gulls (Gentes et al., 2012).

TBPH was detected in 4 of 12 peregrine falcon eggs in Canada ranging from <LOD to 4.5 μg/kg 

lipid weight. TBPH was detected in 1 of 13 peregrine falcon eggs from Spain at a concentration 

of 1.2 μg/kg lipid weight (Guerra et al., 2012).

TBB was not detected in a small number of samples of cormorant eggs collected near the San 

Francisco Bay area in 2012. However the authors report that detection may have been 

compromised by matrix interferences in all samples (Klosterhaus et al., 2012).

Seven different species in Scandinavia were sampled for a variety of flame retardants including 

TBB and TBPH. Five of these species were aquatic. Ten samples were collected for each species. 

Three bird species were sampled: common eider liver, Guillemot eggs, and Kittiwake liver. TBB

was detected in: 100% of common eider liver samples with a mean concentration of 0.86 ug/kg, 

90% of guillemot eggs with a mean concentration of 1.21 ug/kg, and 90% of kittiwake liver 

samples with a concentration of 0.73 μg/kg. TBB was also detected in two mammals: the arctic 

fox and polar bear. TBB was detected in: 90% of arctic fox liver samples with a concentration of 

0.97 μg/kg, and 90% of polar bear plasma samples with a concentration of 3.46 ug/kg. TBPH

was not detected in the arctic fox or polar bear samples. TBPH was detected in: 60% of 

common eider liver samples with a mean concentration 1.65 μg/kg; 70% of guillemot eggs with 

a mean concentration of 1.79 μg/kg; and 50% of kittiwake liver samples with a concentration of 

0.8 μg/kg (Sagerup et al., 2010). 

TBB and TBPH were detected in bird eggs and one moss sample in Scandinavia. The frequency 

of detection in bird eggs and other biota was high when compared to moss. Concentrations of 
 

Page 52 of 54

TBB in bird eggs ranged from ND to 0.18 μg/kg and concentrations of TBPH ranged from ND to 

0.021 μg/kg. Only one sample detected TBB in moss at a concentration of 0.039 μg/kg

(Schlabach et al., 2011). 

A-7 Human Blood 

For human blood, a TBPH concentration of 260 μg/kg was reported in a 2011 pooled blood 

sample of 30-39 year old Females in China. TBPH was not detected in the same study from two 

pooled 2007 samples. The authors note that the pooled sample may have included individuals 

who could have been occupationally exposed, but does recommend further biomonitoring to 

understand possible trends of TBPH occurrence in human serum for the study area (He et al., 

2013). 

Appendix B Definitions

B-1 Overall types of Polyurethane (2)

- Open cell: structure of foam which allows for the movement of air throughout (North Star 

Polymers, 2013).

- Closed cell: unbroken and tightly packed foam cells and is thus largely impermeable to air and 

liquid (North Star Polymers, 2013).

- Flexible foam: An open cell polyurethane foam type made using toluene diisocyanate (TDI) as 

the isocyanurate, most often used in cushioning applications (Global Insight, 2006; 

Polyurethane Foam Association, 1991a). 

- Semi-rigid (or semi-flexible) foam: a type of flexible foam. The difference between standard 

flexible foam and semi-rigid foam is the molecular weight per cross-link, the equivalent weight 

and functionality of the polyol and the type and functionality of the isocyanate (Ashida and 

Iwasaki, 1995). Semi-rigid foams possesses higher load-bearing, impact resistance, and 

compression recovery properties than flexible foam (Ashida and Iwasaki, 1995). Additionally, 

semi-rigid foam has a higher hydroxyl number3.

- Subsets of standard flexible polyurethane foam:

- Molded foam: formed by pouring foam reaction products into a mold and allowing the 

contents to react and expand. Molded foam is often used for automotive cushions 

(Uhlig, 1999). 

- Slabstock foam: formed by pouring flexible foam reaction products onto a flat surface 

and allowing it to react and expand into a slab shape. Once the foam cures, it is 

subsequently cut into desired shapes (Uhlig, 1999).

- Viscoelastic foam (also known as memory foam): a closed-cell flexible polyurethane 

foam that traps in air and/or gas. Viscoelastic foam is characterized by its slow recovery 

 

3 A measure of the concentration of the hydroxyl groups on the polyol
 

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to its original configuration after compression, as well as its low resiliency (i.e., high 

energy absorption)(Polyurethane Foam Association, 2003). 

-

-Rigid foam is a hard, closed-cell foam. Rigid foam exhibits low flexibility and permanent 

deformation after compression (Ashida and Iwasaki, 1995; North Star Polymers, 2013). It is

mainly used in insulation applications (Ashida and Iwasaki, 1995) and is always made using 

methylene diphenyl diisocyanate (MDI) (Markets and Markets, 2011). 

B-2 CDR Use Categories for Brominated Phthalate Cluster

Industrial Use

-Plasticizer: Chemical substances used in plastics, cement, concrete, wallboard, clay bodies, or 

other materials to increase their plasticity or fluidity. Examples include phthalates, trimellitates, 

adipates, maleates, and lignosulphonates (EPA, 2012e). 

-Flame Retardants: Chemical substances used on the surface of or incorporated into 

combustible materials to reduce or eliminate their tendency to ignite when exposed to heat or 

a flame for a short period of time. Examples include inorganic salts, chlorinated or brominated 

organic compounds, and organic phosphates/phosphonates (EPA, 2012e). 

Consumer Use

-Electrical and electronic products: Chemical substances contained in electrical and electronic

products that are intended for consumer or commercial use are reported under this code. 

Examples of electrical and electronic products include computers, office equipment, appliances, 

electric lighting, electrical wire and cables, radios, televisions and monitors, telephones, multimedia devices, digital cameras, adapters, alarms (burglar, fire, smoke), and communication 

equipment (EPA, 2012e). 

-Furniture and furnishings not covered elsewhere: Chemical substances contained in furniture 

and furnishings made from metal, wood, leather, plastic or other materials that are intended 

for consumer or commercial use are reported under this code. Examples of products include 

movable and installed furniture such as tables, chairs, benches, desks, cabinets, shelving, stools, 

television stands, display cases, book cases, and storage units. This code does not include foam 

seating and bedding products (EPA, 2012e). 

-Building/construction materials not covered elsewhere: Chemical substances contained in

building and construction materials not covered elsewhere that are intended for consumer or 

commercial use are reported under this code. Examples of products include insulation materials 

such as foams and fibers, roofing and gutters, ceiling products, exterior siding, drywall, 

concrete, masonry and cement, building hardware, fencing, decking, hardware and fasteners 

(nuts, bolts, screws, nails, and tacks), plumbing, duct work, abrasive and sanding products,

sheet metal, plaster, weather stripping, wire or wiring systems, and bricks (EPA, 2012e).
 

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B-3 Applications/End-uses of Polyurethanes 

- Furniture

- Construction

- Footwear

- Transportation

- Flooring Underlay

- Bedding

- Furniture

- Packaging

- Textiles

- Other