ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 1 of 108 

DATA ON MANUFACTURE, IMPORT, EXPORT, USES 

AND RELEASES OF HBCDD 

AS WELL AS INFORMATION ON POTENTIAL 

ALTERNATIVES TO ITS USE 

The technical work on this report has been led by IOM Consulting, 

supported by BRE, PFA and Entec 

under framework contract ECHA/2008/2 (specific contract 

ECHA/2008/02/SR4/ECA.226)
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 2 of 108 

Executive Summary 

Information sources 

The information presented on manufacture import and export and uses and relases 

from uses is based on the RAR with additional data supplied by the HBCD Industry 

User Group in October 2008. This additional data comprises summary data for the 

total sales and consumption of HBCDD across the EU for each year from 2003 until 

2007, a breakdown of the consumption of HBCDD by the two main uses (XPS and 

EPS) and an indication of how many sites manufacture XPS or EPS in each member 

state. 

The information on possible alternatives to HBCDD presented in Work Package 3 has 

been taken from a wide variety of sources including reviews undertaken by both 

industry and regulators that have aimed to identify candidate substances/techniques. 

As agreed with ECHA, this report does not cover cyclododecane as the Member State 

Committee has unanimously agreed that there was not sufficient scientific data to 

justify identification under Article 57 of the REACH Regulation. 

Information on manufacture, import and export and releases from manufacture 

HBCDD is presently only produced at one site in the Netherlands. The production 

volume varies from year to year. In 2006, it was about 6,000 tonnes. The EU-wide 

consumption of HBCDD in 2007 was 11,000 tonnes, implying net imports to the EU 

of about 5,000 tonnes. It is unclear how much HBCDD is actually imported and 

exported to and from the EU. There was a general trend towards increasing use of 

HBCDD between 2003 and 2007. Although, it seems likely that 2008 levels of 

production and importation will be slightly greater than in 2006, the expected 

recession may depress demand in 2009. In the longer term, there are moves to phase 

out the use of brominated compounds in the Nordic countries. 

About 1,000 tonnes per annum are “micronised” in the EU to produce fine particles 

for specific applications. This was undertaken at a plant in Belgium. It is possible that 

micronising is also undertaken at other locations. It is unlikely that the increased use 

of HBCDD in the EU will have created an increased requirement for micronisation 

and the reduced use of HBCDD in textile coating may have led to a reduction in the 

amount being micronised. 

Releases of HBCDD to the environment from manufacturing are small. It is estimated 

that about 3 kg a year are released from the workplace plus a further 2 kg to air and 

0.1 kg to waste water. It is estimated that less than 1 kg per year is released from the 

working environment and that emissions to air are <1 kg/year. The estimated releases 

from manufacturing are based on the RAR. It is possible that, with increased 

production, release rates have increased. 

Information on uses and releases from uses 

HBCDD is solely used as an additive flame retardant. HBCDD is used in four 

principal product types: 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 3 of 108 

• Expanded Polystyrene (EPS) 

• Extruded Polystyrene (XPS) 

• High Impact Polystyrene (HIPS) 

• Polymer dispersion for textiles 

The HBCDD Industry Users Group have been unable to supply information on the 

proportions of HBCDD currently used for different purposes in the EU. Most is used 

in EPS and XPS and in 2006, there was a slightly greater proportion used in XPS than 

in EPS (ratio about 52:48). These products are used widely across the EU in the 

workplace and in consumer products. The use of XPS and EPS insulation products 

increased between 2003 and 2007. As a first approximation, it has been assumed that 

all Masterbatch has been used in XPS manufacture. Masterbatch production accounts 

for 12% of HBCDD use. 

It is believed that the use of HBCDD in HIPS is small, less than 10% of total use and 

that the use in textiles is also small. The use of HBCDD in textiles is believed to have 

fallen substantially in recent years. Although industry initially provided an estimate of 

use in textiles in 2007 as 2% of total use, they subsequently indicated that they were

uncertain as to the reliability of this estimate. In the absence of other information, 

however, we have based our estimates of releases on the estimated use level originally 

provided. Textile formulators are based largely in Belgium, Germany and the UK. 

XPS and EPS are manufactured throughout much of Europe: Austria, Belgium, Czech 

Republic, Finland, France, Germany, Greece, Hungary, Italy, Netherlands, Poland, 

Portugal, Serbia, Spain, Sweden and the United Kingdom. 

The estimated releases of HBCDD to the environment during the manufacture and 

formulation of HBCDD are 41 kg to air, 60 kg to waste water and 35 kg to surface 

water per year based on consumption figures for 2006 supplied by the HBCD Industry 

Users Group. 

The release of HBCDD from products during end use is small. Some dust containing 

HBCDD will be released during the installation of EPS or XPS insulation and 

ultimately during the refurbishment or demolition of buildings containing these 

products. Most of the HBCDD released is from coating textiles. The estimated annual 

release to the environment is 530 kg to air, 1,140 kg to waste water and 560 kg to 

surface water. The end use releases to waste water and surface water are dominated 

by textile coating. These estimates are based on consumption figures for 2006 

supplied by the HBCD Industry Users Group. The quantities of waste product sent for 

disposal are uncertain. 

Estimated releases of HBCDD during the consumer use of products are highly 

uncertain. Releases from waste disposal are difficult to estimate because of the long 

lifetime of XPS and EPS once installed in buildings (potentially up to 50 years) 

combined with an increasing trend towards the recycling of electrical equipment. The 

release estimates for consumer use are 54 kg to air, 24 kg to wastewater and 5 kg to 

surface water. These estimates are based on the RAR, adjusted for recent consumption 

figures supplied by the HBCD Industry Users Group. They exclude waste disposal. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 4 of 108 

Information on Alternative substances and techniques 

A number of alternative fire retardants are available to replace HBCDD in HIPS but 

they all require to be used at considerably higher loadings. At present, no suitable 

flame retardant is available to replace HBCDD in its main end uses in XPS or EPS as 

the required loadings of alternative flame retardants impair the structure and 

properties of the finished product to the extent that is no longer suitable for use. There 

are however a number of alternative forms of insulation that can be used in place of 

XPS or EPS. These alternative insulation systems have different characteristics to 

XPS and EPS and may be less appropriate for some specific use scenarios or may 

incorporate different environmental issues such as increased energy costs during 

transportation. Given that HBCDD is not widely used in HIPS, it is perhaps 

reasonable to assume that some technically and economically feasible alternatives are 

already on the market, although it is uncertain whether the human health and 

environmental impacts of these alternatives are any less than those associated with 

HBCDD products. 

There are a wide range of different flame retardant formulations in textile coatings 

and, as with HIPS, it seems likely that some technically and economically feasible 

alternatives are already on the market, although it is similarly uncertain whether the 

human health and environmental impacts of these alternatives are any less than those 

associated with HBCDD products. 

The table below summarises the health and environmental information available for 

the suggested alternatives to HBCDD. 

Use Alternative Human health Environment 

Antimony trioxide 

(ATO) 

Potential human 

carcinogen and 

reproductive toxicant 

Not readily biodegradable, low to 

moderate bioaccumulation 

potential 

Decabromodiphenylether/ATO Neurotoxicant Not readily biodegradable, low to 

moderate bioaccumulation 

potential 

Decabromodiphenylethane/ATO Limited data, but likely to 

be of low toxicity 

Not readily biodegradable, may be 

persistent 

Ethylenebis- 

(tetrabromo 

phthalimide)/ATO 

Low toxicity Not biodegradable and is 

persistent. Non-toxic. 

Triphenyl phosphate Chronic toxicant with 

effects on liver 

Readily biodegradable, toxic to 

aquatic organisms 

Resorcinol bis 

(biphenyl phosphate) 

Chronic toxicant with 

effects on liver 

Inherently biodegradable, may be 

persistent and bioaccumulative 

Bis phenol A bis 

(biphenyl phosphate) 

Limited data, likely to be 

of low toxicity 

Poorly biodegradable. Non-toxic 

and is not bioaccumulative 

HIPS 

Diphenyl cresyl 

phosphate 

Chronic toxicant with 

effects on liver, kidney 

and blood. Effects on 

fertility 

Readily biodegradable 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 5 of 108 

Use Alternative Human health Environment 

 Polyethylene with 

Magnesium 

Hydroxide 

Insufficient data but likely 

to be of low toxicity 

Polythene particles are highly 

persistent in the aquatic 

environment and may contribute to 

reduced nutritional intake by 

organisms; the release of large 

quantities of magnesium hydroxide 

to the environment could cause 

localised problems of water/soil 

alkalinity. 

Decabromodiphenylether Neurotoxicant Not readily biodegradable, low to 

moderate bioaccumulation 

potential 

Chlorinated paraffins Reproductive toxicant, 

chronic toxicity with 

effects of liver and 

kidneys, potential 

carcinogen 

LCCPs are considered to 

potentially meet the persistent or 

very persistent criterion. They do 

not meet the toxic or 

bioaccumulative criterion. 

Textiles 

Ammonium 

polyphosphates 

Low toxicity Not an ecotoxicant 

Phenolic Foam Low toxicity in use but 

manufactured from 

materials toxic and 

carcinogenic 

Highly persistent material, long 

term disposal to landfill with 

potential for dust emissions to air 

and surface water, no recycling at 

present 

Polyurethane and 

polyisocyanurate 

products 

May emit toxic fumes if 

burnt, otherwise low 

toxicity in use, but 

manufacture involves the 

use of isocyanates – 

potent respiratory 

sensitisers 

Highly persistent material, long 

term disposal to landfill with 

potential for dust emissions to air 

and surface water, no recycling at 

present 

EPS/XPS 

Alternative insulation 

- Thermal barriers 

- Loose-fill insulation 

- Blanket insulation 

May incorporate 

glass wool, rock 

wool, gypsum board 

Relatively minor health 

issues - Inhalation of low 

toxicity dust generated 

during installation and 

removal; no significant 

emissions while in use in 

buildings 

Materials can be recycled postconsumer use 

This report has been produced according to a format and structure provided by 

ECHA. Draft reports have been reviewed and commented on by ECHA and this final 

report has been accepted by ECHA. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 6 of 108 

INFORMATION ON MANUFACTURE, IMPORT AND EXPORT AND 

RELEASES FROM MANUFACTURE .............................................................8

1.1 Manufacturing sites and manufacturing processes ....................................8 

1.1.1 Production ............................................................................................8 

1.1.1.1 Locations...........................................................................................8 

1.1.1.2 Tonnage.............................................................................................8 

1.1.2 Micronising...........................................................................................8 

1.1.2.1 Process...............................................................................................8 

1.1.2.2 Locations...........................................................................................8 

1.1.2.3 Tonnage.............................................................................................8 

1.2 Import and export of HBCDD on its own or in preparations.....................9 

1.2.1 On own..................................................................................................9 

1.2.1.1 Imports..............................................................................................9 

1.2.1.2 Exports..............................................................................................9 

1.2.2 In preparations.....................................................................................9 

1.2.2.1 Imports..............................................................................................9 

1.2.2.2 Exports..............................................................................................9 

1.3 Import and export of articles containing HBCDD ......................................9 

1.4 Releases from manufacture........................................................................10 

1.4.1 Production ..........................................................................................10 

1.4.1.1 Releases to working environment.................................................10 

1.4.1.2 Releases to environment................................................................11 

1.4.2 Micronising.........................................................................................12 

1.4.2.1 Releases to working environment.................................................12 

1.4.2.2 Releases to environment................................................................12 

1.5 Unintentional formation.............................................................................13 

INFORMATION ON USES AND RELEASES FROM USES .........................14

2.1 Identification of uses...................................................................................14 

2.1.1 Masterbatch........................................................................................14 

2.1.2 Expanded Polystyrene .......................................................................14 

2.1.3 Extruded Polystyrene ........................................................................15 

2.1.4 High Impact Polystyrene...................................................................16 

2.1.5 Textile Coating ...................................................................................17 

2.2 Quantification of uses.................................................................................18 

2.2.1 Inventory Table..................................................................................18 

2.3 Quantification of releases from uses..........................................................20 

2.3.1 Masterbatch........................................................................................20 

2.3.1.1 Releases into working environment .............................................20 

2.3.1.2 Release into environment ..............................................................21 

2.3.1.3 Releases into working environment .............................................22 

2.3.1.4 Release into environment ..............................................................24 

2.3.2 XPS......................................................................................................28 

2.3.2.1 Releases into working environment .............................................28 

2.3.2.2 Release into environment ..............................................................30 

2.3.3 HIPS ....................................................................................................31 

2.3.3.1 Releases into working environment .............................................31 

2.3.3.2 Release into environment ..............................................................32 

2.3.4 Textile coating ....................................................................................33 

2.3.4.1 Releases into working environment .............................................33 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 7 of 108 

2.3.4.2 Release into environment ..............................................................35 

2.3.5 Total emissions...................................................................................38 

INFORMATION ON ALTERNATIVE SUBSTANCES AND TECHNIQUES ..39

3.1 Identification of alternative substances and techniques ...........................39 

3.1.1 Halogenated flame retardants in conjunction with Antimony 

Trioxide 39 

3.1.2 Organic aryl phosphorous compounds............................................39 

3.1.3 Textile alternatives.............................................................................39 

3.1.4 Phenolic Foam and Phenolic Resins.................................................40 

3.1.5 Polyurethane and Polyisocyanurate Products.................................40 

3.1.6 Mineral wools, other mineral products and cellulose fibre............40 

3.1.7 Intumescent systems ..........................................................................41 

3.2 Information on alternatives........................................................................41 

3.2.1 Human health and environmental effects........................................42 

3.2.1.1 Halogenated flame retardants in conjunction with Antimony 

Trioxide 42 

3.2.1.2 Organic aryl phosphorous compounds........................................53 

3.2.1.3 Textile alternatives.........................................................................61 

3.2.1.4 Phenolic Foam................................................................................70 

3.2.1.5 Polyurethane and Polyisocyanurate Products.............................72 

3.2.1.6 Mineral wools and other mineral products.................................74 

3.2.1.7 Cellulose fibre.................................................................................74 

3.2.1.8 Intumescent systems ......................................................................75 

3.2.1.9 Polyethylene with Magnesium Hydroxide...................................75 

3.2.2 Technical and economical feasibility and availability ....................76 

3.2.2.1 Halogenated flame retardants in conjunction with Antimony 

Trioxide 76 

3.2.2.2 Organic Aryl Phosphorous Compounds......................................78 

3.2.2.3 Textile Alternatives........................................................................79 

3.2.2.4 Overview .........................................................................................80 

3.2.2.5 Phenolic Foam................................................................................80 

Polyurethane and Polyisocyanurate Products.............................................81 

3.2.2.6 Mineral wools and other mineral products.................................81 

3.2.2.7 Cellulose fibre.................................................................................81 

3.2.2.8 Intumescent systems ......................................................................81 

3.2.2.9 Polyethylene with Magnesium Hydroxide...................................81 

3.3 Summary table.............................................................................................82 

References...............................................................................................................88 

Disclaimers ..............................................................................................................94 

ANNEX 1: LIST(S) OF INFORMATION REQUIREMENTS FOR PRIORITY 

SETTING AND SPECIFICATION OF CONDITIONS FOR AUTHORISATION

 95

ANNEX 2: ....................................................................................................108
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 8 of 108 

INFORMATION ON MANUFACTURE, IMPORT AND EXPORT AND 

RELEASES FROM MANUFACTURE 

1.1 Manufacturing sites and manufacturing processes 

1.1.1 Production 

The production of HBCDD is a batch-process. Elementary bromine is added to 

cyclododecatriene in the presence of a solvent. The process temperature is 20 to 70°C, 

and the reaction takes place in closed systems. These materials are mixed to form a 

slurry that must be extensively washed in order to generate high purity HBCDD. The 

slurry is centrifuged, the liquids removed for reprocessing and the solid faction is 

dried, stored in a silo and packed. According to one producer, production and 

transportation of the material to silo and the packaging are done in a closed system. 

The product is delivered as powder or pellets. 

The production method as described in general terms in the IUCLID Data Sheet is as 

follows: 

• Loading of raw materials 

• Bromination 

• Filtering 

• Drying 

• Storage in silo 

• Packaging 

1.1.1.1 Locations 

HBCDD is presently only produced at one site in the Netherlands. Two other 

production sites were closed for production in the autumn of 2003 and June 1997 

respectively (RAR, EC 2008a). 

1.1.1.2 Tonnage 

The reported amount of HBCDD produced at the production site in the Netherlands 

varies from one year to another. The total annual (2005) production of HBCDD was 

assumed to be 6,000 tonnes in the RAR (EC, 2008a). 

1.1.2 Micronising 

1.1.2.1 Process 

The HBCDD particles in some applications (e.g. for use in textile back-coating) need 

to be very small. Therefore some quantities of HBCDD are micronised in a grinding 

process. 

1.1.2.2 Locations 

No information on where micronising takes place is available, but is the RAR 

assumed that it occurs at a very limited number of sites. 

1.1.2.3 Tonnage 

The total amount of HBCDD used for micronising was about 1,000 tonnes per year 

between 2000 and 2004, based on information from the textile industry (RAR). The 

main use for micronised HBCDD was textile coating. The industry has informed us 

that this use has dropped by 80% and it is likely that the production of micronised 

HBCDD has also reduced. Up to date production figures are not, however, available. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 9 of 108 

1.2 Import and export of HBCDD on its own or in preparations 

1.2.1 On own 

1.2.1.1 Imports 

The HBCDD Industry working group has provided data on the consumption of 

HBCDD in the EU that includes all EU27 countries (Table 1.1). 

Table 1.1: Sales and consumption of HBCDD in the EU in 2007 (HBCDD Industry 

Users Group, 2008)

Year Sales in EU Countries 

tonnes 

Estimated EU Consumption 

tonnes 

2003 9,448 9,600 

2004 10,123 9,750 

2005 10,622 11,000 

2006 10,075 11,580 

2007 11,186 11,000 

There was an increase in HBCDD sales between 2003 and 2007 of about 18%. It is 

unclear whether this trend would be likely to continue given the growing concern 

about the presence of brominated fire retardants in the environment and the moves in 

Nordic countries to phase out their use. Production of HBCDD between 2003 and 

2007 was fairly static at 6000 tonnes, implying an increase in net imports of almost 

50% over this period. Estimates of EU consumption are slightly different. They 

imply an increase of almost 15% between 2003 and 2007 with net imports increasing 

by almost 40%. The best estimate of imports of HBCDD in 2006 is 5,580 tonnes. 

1.2.1.2 Exports 

It is unclear whether any HBCDD is exported out of the EU as a simple substance. 

Given the proximity of the production plant to major port facilities, it is likely that 

some HBCDD would be exported outwith the EU as well as transported within the 

EU. 

1.2.2 In preparations 

1.2.2.1 Imports 

It is unclear whether HBCDD is imported into the EU in the form of masterbatch and 

plastic compounds. 

1.2.2.2 Exports 

It is unclear whether HBCDD is exported out of the EU in the form of masterbatch 

and plastic compounds. Some export to other European countries that are not part of 

the EU would seem likely. 

1.3 Import and export of articles containing HBCDD 

HBCDD contained in expanded polystyrene (EPS) and extruded polystyrene (XPS) 

for the construction industry is not likely to be transported long distances due to the 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 10 of 108 

bulkiness of the material. Furthermore, the extrusion and expansion processes are 

relatively straightforward industrial processes, which allow them to be carried out in 

the region where the products are needed. Transport of compounded polystyrene (PS) 

with HBCDD (granules, masterbatch or beads) over long distances cannot be 

excluded, but information on this is lacking. 

Packaging material containing HBCDD (e.g. EPS) to protect sensitive equipment is 

likely to be transported worldwide. High impact polystyrene (HIPS) containing 

HBCDD is likely to be imported to the EU in electrical and electronic equipment, but 

no data on this has been submitted. Textile that is back-coated with a HBCDDcontaining layer is imported from the US and other countries in unknown quantities. 

Import of polymer dispersions for textiles containing HBCDD cannot be excluded. In 

summary, import (and export) of HBCDD in articles is likely to occur but has not 

been possible to quantify. 

No up to date information on the export of HBCDD from the EU is available. 

1.4 Releases from manufacture 

1.4.1 Production 

1.4.1.1 Releases to working environment 

During production of HBCDD, there is potential for exposure to HBCDD during 

packing, compaction (to form granules), when process operators have to enter the 

centrifuge or dryers, and, to a lesser extent, during handling of packaged HBCDD in 

the warehouse. 

Personal exposures to dust and HBCDD were measured in the production facility in 

the Netherlands by Searl and Robertson (2005) using the methods for respirable1 and 

inhalable2 dust described in MDHS 14/3 (UK Health and Safety Executive, 2000). 

The results of the monitoring are summarised in Table 1.2. A total of 10 

measurements of personal exposures were made during packing, compaction process 

operations and warehouse work. In this exercise, compaction gave the highest dust 

and HBCDD concentrations. The plant does not produce HBCDD continuously 

throughout the year and the proportion of shifts on which workers are exposed to 

HBCDD varies from year to year. It is believed that exposure occurs on less than 1 in 

4 shifts. 

Table 1.2: Personal exposure concentrations measured for workers producing 

HBCDD

Dust concentration 

(mgm-3) 

HBCDD concentration 

(mgm-3) 

All Production Workers 

Respirable Inhalable Respirable Inhalable 

Mean (Standard deviation) 0.4 (0.2) 3.2 (1.2) 0.18 (0.16) 1.23 (0.76) 

Median 0.25 2.50 0.05 0.89 

90th Percentile 0.70 4.29 0.40 1.86 

 

1

 That part of airborne dust that can be deposited within the gas-exchange region of the lung 

2

 That part of airborne dust that can deposited within the respiratory system 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 11 of 108 

Dermal exposure during production was assessed in the RAR (EC, 2008a) using the 

EASE occupational exposure model (Tickner et al., 2005). It is assumed that exposure 

at the manufacture of HBCDD occurs principally during packing and compaction of 

the product. It was assumed that both hands are exposed. The calculated dermal 

exposure was 840 mg/day when handling powders and 84 mg/day when handling 

granules which are coarser and less dusty. Protective suits and gloves are reported to 

be used in these production processes (Searl and Robertson, 2005) and it is reasonable 

to reduce these exposures by a factor of 5 to 170mg/day and 17 mg/day to take 

account of the protection offered by the protective gloves. 

1.4.1.2 Releases to environment 

Site-specific information on the annual release of HBCDD to air and wastewater is 

available for the one remaining manufacturing site in the EU, located in the 

Netherlands. 

The annual release 2001 was 6.2 kg mainly via wastewater to a STP (Sanders, 2002). 

The annual release to wastewater has been reported to be 0.73 kg (2002), 0.13 kg 

(2003) and 0.20 kg (2004) (Tange, 2005). The highest release figure (0.73 kg/year) 

from year 2002-2004 was taken in the RAR as a reasonable measure of the emissions 

to wastewater from this site. It is not clear whether the increase in sales in the EU 

comes from increased production or greater imports. From the RAR (EC, 2008) the 

emissions from the production site to water decreased over the period 2002 to 2004, 

during which time the sales of HBCDD increased. As a worst case estimate the 

emissions from the risk assessment report could be retained. 

The emission to air is 21.7 kg/year, according to site-specific data (Tange, 2003). The 

site has installed an “absolute filter” for outgoing air. First measurements indicate that 

particulate emissions to air now are lower than 0.03 mg/m3. Using a worst-case 

assumption (assuming all dust would be HBCDD) this would correspond to less than 

2 kg/year emissions to air. 

No information has been submitted on the formation of solid waste containing 

HBCDD, but information is provided noting that waste from the production, including 

sludge from the STP, is disposed of by incineration or reused in the process. 

Since there is only one active producer in the EU, the emissions from this site were 

used in the RAR for the estimation of regional background concentrations. The 

resulting total, regional and continental emissions from production of HBCDD are 

given in Table 1.3. 

Table 1.3: Total, regional and continental emissions from production of HBCDD. 

Total 

(kg/year) 

Regional 

(Netherlands) 

(kg/year) 

Continental (kg/year) 

Air 2 2 0 

Wastewater 0.73 0.73 0 

Surface 

water 

0 0 0 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 12 of 108 

1.4.2 Micronising 

1.4.2.1 Releases to working environment 

Searl and Robertson (2005) measured personal exposures to HBCDD during 

micronising in one plant. Dust exposure occurred mainly during the loading and 

unloading of the grinding rig and when spills were cleaned up using a brush and 

shovel. The plant handled a variety of materials and micronising HBCDD was only 

one of several activities undertaken by workers. Exposure to HBCDD therefore did 

not occur on every shift, although no quantitative information about the proportion of 

shifts on which HBCDD was handled is available. It is believed that exposure is likely 

to occur on less than 1 in 4 shifts. 

Four samples were collected and the measured personal exposure concentrations of 

inhalable dust and HBCDD were high, with inhalable HBCDD concentrations 

averaging 22.7 mgm-3 (Table 1.4). HBCDD accounted for virtually all the inhalable 

dust. Only a small proportion of inhalable dust was within the respirable size fraction. 

Table 1.4: Personal exposure concentrations for workers involved in grinding HBCD 

Dust concentration (mgm-3) HBCD concentration (mgm-3) 

Respirable Inhalable Respirable Inhalable 

Mean (standard deviation) 0.78 (0.21) 23.8 (11.8) 1.43 (0.64) 22.7 (12.3) 

90th Percentile 0.94 34.8 1.98 34.6 

Dermal exposure during micronising was estimated in the RAR using the EASE 

model. The reasonable worst-case dermal exposure was estimated as 4,200 mg/day, 

when no PPE is used. Gloves and protective clothing, which were worn during 

surveys undertaken by Searl and Robertson (2005), will reduce that figure to 840 

mg/day. 

1.4.2.2 Releases to environment 

Data from one site with micronising have been submitted from Industry (Esser et al., 

2003). According to industry this site uses the major part of the amount of HBCDD 

processed by micronising. 

Local emissions 

No water is used in the process; except for the cleaning-water, which is collected in a 

tank and disposed of via a “waste management treatment company”. It is therefore 

assumed that there are no emissions to wastewater or surface-water. 

The emission to air from the site that submitted data was determined to be 0.3 kg/year 

based on site-specific data (Esser et al., 2003). No data on the number of emission 

days per year are given so the RAR used the TGD (Technical Guidance Document) 

default value from the B-tables (300 days/year). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 13 of 108 

Regional and continental emissions 

Based on the information given by industry that the site for which data are given is the 

by far largest microniser, it is assumed that the emissions from possible other sites 

involved in micronising are negligible. Thus, the continental release is assumed to be 

zero. 

The resulting total, regional and continental emissions of HBCDD for micronising are 

given in Table 1.5. 

Table 1.5: Total, regional and continental emissions of HBCDD from micronising 

Total 

(kg/year) 

Regional 

(kg/year) 

Continental 

(kg/year) 

Air 0.28 0.28 0 

Wastewater 0 0 0 

Surface 

water 

0 0 0 

1.5 Unintentional formation 

There is no information on the unintentional formation of HBCDD during 

incineration, by transformation/degradation, or through other processes. Any 

unintentional formation of HBCDD is likely to be in negligible amounts. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 14 of 108 

INFORMATION ON USES AND RELEASES FROM USES 

2.1 Identification of uses 

HBCDD is solely used as an additive flame retardant. HBCDD is used in four 

principal product types: 

• Expanded Polystyrene (EPS) 

• Extruded Polystyrene (XPS) 

• High Impact Polystyrene (HIPS) 

• Polymer dispersion for textiles 

The HBCDD Industry Users Group have been unable to supply information on the 

proportions of HBCDD currently used for different purposes in the EU. Most is used 

in EPS and XPS and in 2006, there was a slightly greater proportion used in XPS than 

in EPS (ratio about 52:48). It is believed that the use of HBCDD in HIPS is small, less 

than 10% of total use and that the use in textiles is also small. The use of HBCDD in 

textiles is believed to have fallen substantially in recent years. The use of HBCDD in 

textiles is believed to have fallen substantially in recent years. Although industry 

initially provided an estimate of use in textiles in 2007 as 2% of total use, they 

subsequently indicated that they were uncertain as to the reliability of this estimate. In 

the absence of other information, however, we have based our estimates of releases on 

the estimated use level originally provided. As a first approximation, it has been 

assumed that all Masterbatch has been used in XPS manufacture. Masterbatch 

production accounts for 12% of HBCDD use. 

2.1.1 Masterbatch 

Masterbatch is a concentrated mixture of HBCDD encapsulated during a heat process 

into a carrier resin (polystyrene) which is then cooled and cut into a granular shape. It 

is used to manufacture end products such as XPS or HIPS. Masterbatch contains a 

higher concentration of HBCDD than the final product made from it. 

2.1.2 Expanded Polystyrene 

Expanded Polystyrene (EPS) is a rigid cellular plastic, which is used in a multitude of 

applications such as packaging. HBCDD-containing EPS is mainly used for the 

following purposes: 

• insulation panels/boards in the construction sector 

• automobile cushions for children (KemI, 1994) to meet the needs of the 

FMVSS 302 standard 

• rigid packaging material for fragile equipment (minor use) 

• packaging material such as “chips” and shaped EPS-boards (minor use) 

• in props for theatre and film, and in exhibitions (minor use) 

Expanded polystyrene is produced in a batch process by suspension polymerisation of 

styrene in water. Prior to combining the water with the organic phase, additives are 

introduced such as suspension agents, free-radical forming initiators and HBCDD. 

HBCDD powder, most often delivered in 25kg paper bags with a plastic liner, is 

suspended at low temperatures in styrene prior to the addition of the water phase. 

Normally the bags are emptied into an intermediate storage container from where the 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 15 of 108 

HBCDD is transported via pipes and a weighing station prior to the addition to the 

styrene. 

In the reactor, styrene forms the disperse phase as small monomer droplets in the 

continuous water phase. Final droplet size (0.01 to 0.5 mm) is determined by the ratio 

of disperse to continuous phase (typically 50:50) and by stirrer speed. Within the 

monomer droplets (bulk), polymerisation occurs while the reactor content is heated up 

and held at its reaction temperature. During this free-radical polymerisation an 

expansion agent (e.g. pentane) is added to the reactor under pressure, where it is 

absorbed in the polymer droplets. 

HBCDD is incorporated as an integral and encapsulated component within the 

polymer matrix with uniform concentration throughout the bead. 

After complete conversion of the styrene monomer to EPS-beads, the reactor is 

cooled down and the beads are separated from the water by centrifugation. The 

decanted water, which could contain dissolved and dispersed HBCDD, is reused and 

exchanged on an annual basis or less frequently. The EPS beads are dried and 

classified into various size fractions and surface coated. These different grades are 

packed in bins, bags, or transported in bulk trucks to the EPS-converters. The 

maximum concentration of HBCDD in EPS beads is assumed to be 0.7 %. 

EPS foam is produced from EPS beads through pre-expansion of the beads with dry 

saturated steam, drying with warm air and shaping in shape moulds or in a continuous 

moulding machine. First, the raw material beads are pre-expanded in loose form with 

the help of dry saturated steam in pre-expanders. The raw materials are transported 

via pipes or tubes from the packaging containers to these stirred vessels. After 

expansion the beads are partly dried in fluid bed driers with warm air. The beads are 

subsequently stored in large permeable silos to “mature” for up to 24 hours. During 

this stage the beads dry further and reach equilibrium with the ambient atmosphere 

around them. In the third phase the beads are transported/blown, via pipes/tubes into 

block or shape moulds or in a continuous moulding machine in which the product gets 

its shape. The foam can then be further formed by cutting, sawing or other machine 

operations. 

2.1.3 Extruded Polystyrene 

Extruded polystyrene (XPS) is a plastic foam based on polystyrene that is formed by 

adding gas during extrusion. HBCDD-containing XPS is mainly used for the 

following purposes: 

• Cold bridge insulation 

• Sandwich Panels and Laminates 

• Cavity Insulation 

• Floors 

• Basement Walls and Foundations 

• Inverted Roofs 

• Ceilings 

The manufacture of XPS materials is carried out in the following way: 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 16 of 108 

1. The polystyrene, the additives such as processing aids, flame retardant, dye 

and blowing agent are fed continuously to an extruder. 

2. The polymer is melted; the blowing agent is mixed with the melted polymer 

and a “foamable gel” is formed. 

3. The gel is then cooled before it exits through an orifice called a die, where the 

blowing agent volatilises, causing the plastic to assume a foam structure. The 

blowing agent is usually a volatile, chemically stable compound, and by its 

introduction into the molten polymer, it reduces the density of the product by 

the formation of a myriad of closed cells within its structure. 

4. The foam is then trimmed to desired shape. The boards are packed into shrinkwrapped bundles and palleted. The pallets are stored for curing (usually 1 

week) and are then ready for shipment. 

5. A remainder of about 25 % of the material is recycled to the extruder. This 

material is mainly “skin” from the surface, with higher density. The recycled 

material comes in contact with water. 

The HBCDD is supplied either in powder or in low-dust granulated form in either 25 

kg bags or in 1 tonne supersacks or “big bags”. The supersacks are emptied into 

hoppers designed to minimise dust emissions. The HBCDD is then carried to the point 

of mixing with screw or air driven metering equipment. The compounded polystyrene 

is extruded and cut into granules, and packaged. The extrudate is either air-cooled or 

cooled by running in a water bath. 

One technology usually known as the UCI technology uses a vacuum in addition to 

blowing agents to produce lighter (lower density) foams. In this technology, the 

product comes into contact with water in a water pond directly after the extrusion.

2.1.4 High Impact Polystyrene 

Most flame-retarded High Impact Polystyrene (HIPS) products are used in electrical 

and electronic appliances. For example: 

• audio visual equipment cabinets (video and stereo equipment) 

• distribution boxes for electrical lines in the construction sector 

• refrigerator lining 

HIPS pellets are produced either in a batch or continuous polymerisation process. 

HBCDD powder, delivered in plastic bags, is filled in intermediate storage containers. 

HBCDD and other ingredients required for the particular HIPS formulation are 

weighed and transported to the feeding hopper of the extrusion equipment where they 

undergo further mixing, homogenisation and granulation into pellets. 

An alternative route for HIPS pellet production is via an intermediate-compounding 

route. Masterbatch (as detailed in section 2.1.1) is compounded with non flameretarded HIPS material in a conversion step. 

After the molten mass at the end of the extruder is pressed through a plate with holes 

(die/plate), different granulation processes take place, for example: 

• face cutting in air; a rotating knife directly after the plate cut the extruded 

“strands” into pellets cooled by air. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 17 of 108 

• under water face cutting; a rotating knife directly after the plate in a water bath 

cuts the extruded strands in pellets cooled by water. 

• strand cutting; the molten strands are passed through a water bath to solidify 

and cool and are cut in a granulator. 

After the granulation process the HIPS pellets are dried and packed, either in bulk 

silos/containers or 25 kg bags, ready for conversion into HIPS products. 

HIPS materials can be converted into HIPS products using various extrusion 

techniques and injection moulding. HIPS products can also be manufactured via a 

compounding route, i.e. mixing non flame-retarded HIPS raw material with a 

HBCDD masterbatch during the extrusion or injection moulding process. 

The HBCDD content of flame-retarded HIPS is 1 - 3 % (w/w) (BASF, 1996) or in 

other cases 5 or 7 % (Albemarle, March 1996). In the RAR (Swedish Chemicals 

Agency, 2008), it was assumed for the calculations of exposure, as a realistic worst

case, that HIPS contains 7 % HBCDD. 

2.1.5 Textile Coating 

Flame retardant systems are used in textile applications to comply with British 

Standard and German DIN flame retardant standards. HBCDD is formulated to 

polymer-based dispersions (e.g. acrylic or latex) of variable viscosity in the polymer 

industry. The dispersions are then processed in the textile finishing industry. The 

textiles with the back-coating containing HBCDD are mainly used for: 

 

• flat and pile upholstered furniture (residential and commercial furniture) 

• upholstery seating in transportation 

• draperies, and wall coverings 

• bed mattress ticking 

• interior textiles e.g. roller blinds 

• automobile interior textiles and car cushions. 

The HBCDD particles used for textile back-coating need to be very small and 

micronised (see chapter 2.1.2). Flame retarded formulations containing HBCDD are 

prepared as water-based dispersions that can contain a binder system and HBCDD as 

well as up to 20 other ingredients. These flame retarded formulations, mostly custom 

tailored, are supplied as a dispersion to back-coaters. In this scenario, formulation is 

carried out in an open batch system. HBCDD is added to a dispersion containing 

water, a polymer e.g. synthetic latex, acrylates or PVC, thickener and dispersion 

agent. The chemical preparation can also contain other brominated flame-retardants 

such as decabromodiphenyl ether. In addition, synergists such as antimony trioxide 

and antimony pentoxide may also be included in the end-product. According to 

industry information, the concentration of HBCDD in the dispersion may range from 

5 to 48 %. However, additional product information indicates that a likely 

concentration of HBCDD in the coated layer may be about 25 % corresponding to 10 

- 15 % in the final dilution of the dispersion. Water and solvents will leave the 

preparation when dried and concentrations of flame-retardants in the coating layer 

will be higher than in the preparation. Preparations with the highest concentration of 

HBCDD are assumed to be diluted before use. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 18 of 108 

The water based dispersion used by the back-coaters needs to be stable (no 

precipitation and no viscosity change) and should not contain particles that could clog 

the coating system. Therefore, the particle size of the solids is very important. 

Particles that are too fine act as a thickener, whereas particles that are too large will 

lead to a non-stable dispersion (precipitation) and an applied coated film with an 

unacceptable rough surface. 

Back-coating to textile can be applied in the following ways: 

1. as a paste where a layer is “glued” to the textile and a scratch knife defines the 

final thickness depending on the flame retardant standard, the textile used and 

the flame retardant concentration in the dispersion; or 

2. as a foam, where a foam layer is pressed on the textile through a rotating 

screen. Once applied the foam cells will break resulting in a thin coating film. 

The coating is dried and fixated in an oven at temperatures between 140 to 180 °C, 

(Delgado and (EIPPCB, 2003). 

The formulated product is used on technical textile and furniture fabric, on cotton 

fabrics, and on cotton polyester blends. For the calculations of exposure, the RAR 

assumed that the backcoating layer of the finished textile contains 25 % HBCDD. 

HBCDD is usually applied with antimony trioxide as a back-coating in a mass ratio of 

2:1 (i.e. about 6-15 % HBCDD and 4-10 % antimony oxide by weight) (National 

Research Council, 2000). 

2.2 Quantification of uses 

2.2.1 Inventory Table 

The figures in Table 2.1 below are taken from the risk assessment report (EC, 2008). 

They relate to the EU-15 countries. The values come from a range of years, but were 

considered in the RAR (EC, 2008a) to be representative of the period 2000-2004. 

Table 2.1: Inventory of HBCDD use in the EU15 in 2000-2004 (Swedish Chemicals 

Agency, 2008) 

Use Tonnes/year No. of users Geographical 

distribution 

EPS formulators 3392 18 Unknown 

EPS industrial users 3392 100s Across Europe 

XPS formulators 1730 14 approx 9 in Italy 

1 in Germany 

1 in Austria 

1 in UK 

1 in Belgium 

1 unknown 

XPS industrial users 4962 35 Across Europe 

HIPS formulators 210 3 Unknown 

HIPS industrial users 210 18 Unknown 

Textile coating 

formulators 

1050 16 7 in UK 

5 in Belgium 

4 in Germany 

Textile coating 

industrial users 

1050 24 15 in Belgium 

9 in UK 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 19 of 108 

Masterbatch quantities are included under the relevant polystyrene type. 

Most HBCDD used in XPS is used as powder at the industrial use stage, rather than 

being included in a compound at the formulation stage. 

More recent data for EPS and XPS in the EU27 in 2007 has been provided by the 

HBCDD industry user group (31/10/2008). The total tonnage of HBCDD used in XPS 

and EPS in the EU as a whole has increased over the last 5 years which presumably 

reflects the growing use of XPS and EPS in construction (Table 2.2). 

Table 2.2: Use of HBCDD in EPS and XPS in the EU (tonnes) 

Year EPS XPS 

2002 3,452 3,954 

2003 4,053 4,350 

2004 4,270 4,617 

2005 4,690 5,123 

2006 5,301 5,859 

2007 5,652 N/A 

Industry data also stated that 2% of HBCDD production went to textile manufacture 

in 2007, implying that a little over 200 tonnes of HBCDD was used in textiles in 

2007. 

For the purposes of the estimation of releases to the environment, the 2006 usage 

figures for EPS and XPS and a 2007 estimate of 210 tonnes for textile coating were 

used. These figures are used in tables 2 and 3 in Annex 1. 

Industry data for 2007 also show that HBCDD is widely used to manufacture EPS and 

XPS across the EU (Table 2.3). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 20 of 108 

Table 2.3: Distribution of EPS and XPS manufacturing sites in Europe 

Number of sites Country 

EPS XPS

Austria 1 1 

Belgium 2 1 

Czech Republic 2 

Finland 1 

France 1 3 

Germany 4 6 

Greece 1 1 

Hungary 1 1 

Italy 1 5 

Netherlands 4 1 

Norway 1 

Poland 1 

Portugal 1 

Serbia 1 

Spain 2 4 

Sweden 1 

Turkey 3 

United Kingdom 2 

The use of XPS and EPS may be slightly reduced in the immediate future (2008-9) 

because of the downturn in house-building currently affecting much of Europe, but 

the insulation industry is confident that sales of insulation products will continue to 

increase in coming years in response to the increasing relative cost of energy and 

growing awareness of climate change (Global Insulation (international trade 

association) 

http://www.propubs.com/GI/Articles/eGI_May08_ExaneBNPParibas.pdf). 

2.3 Quantification of releases from uses 

2.3.1 Masterbatch 

2.3.1.1 Releases into working environment 

Exposure to airborne HBCDD during the production of masterbatch is most likely 

during the mixing of HBCDD product with polystyrene and other additives prior to 

melting of the mixture. Exposure is also possible during the extrusion of the melt and 

subsequent processing into granular form for packing. 

Searl and Robertson (2005) measured HBCDD during masterbatch production in one 

plant. Measured personal exposure concentrations were variable. Peak concentrations 

during the task of mixing and weighing were quite high, but shift mean concentrations 

were much lower as these dusty tasks were only performed for part of the shift. The 

extruder operator was exposed to relatively low concentrations of dust and HBCD 

(Table 2.4). No information is available about patterns of shift rotation and the 

proportion of shifts on which workers might be exposed. 

Table 2.4: Personal exposure concentrations associated with the production of 

Masterbatch (Searl and Robertson, 2005) 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 21 of 108 

Dust Concentration 

(mgm-3) 

Concentration of HBCD 

(mgm-3) 

Task No of 

samples 

Duration 

(minutes) 

Respirable Inhalable Respirable Inhalable 

Mean 0.54 9.24 0.16 1.89 

Standard 

deviation 

0.30 5.43 0.10 2.45 

Median 0.45 7.25 0.17 0.83 

Mixing and 

weighing 

10 

90th percentile 0.72 14.57 0.25 5.35 

Mean 0.38 1.73 0.05 0.12 

Standard 

deviation 

0.05 0.19 0.02 0.05 

Median 0.40 1.65 0.05 0.10 

Extruder 

operator 

4 

90th percentile 0.40 1.91 0.06 0.16 

For dermal exposure, there are no measured data and EASE was therefore used by in 

the RAR to assess exposure levels. The reasonable worst-case dermal exposure level 

during the use of fine and standard grade HBCDD was estimated to be 0.1 

mg/cm2/day. It was assumed that both hands are exposed in Masterbatch-production, 

corresponding to an exposed area of 840 cm2, respectively. This leads to an exposure 

to 84 mg/day in Masterbatch production. For granules, the exposure is thought to be 

10 % of that with powder because it is less dusty. Gloves were routinely worn when 

pure HBCDD was handled at all plants surveyed by Searl and Robertson (2005). 

Gloves will reduce dermal exposure and figures of 17 mg/day and 1.7 mg/day are 

reasonable worst cases for Masterbatch production with powder and granules, 

respectively. 

2.3.1.2 Release into environment 

The emissions from the formulation of EPS beads and HIPS compound are dealt with 

in the same scenario. This is because information received from most of the sites 

cannot be separated between these two activities. 

The emission estimates shown in Tables 2.5 and 2.6 are based largely on site specific 

information, applying the largest emission factor from actual sites to the use quantity 

not covered by the specific information. They are taken from the risk assessment 

report (EC, 2008) and are based on the tonnages used in the period 2000-2004 in the 

EU15. For the geographical distribution of these uses see Section 2.2.1. They include 

any emissions from masterbatch. The more recent information on the amounts of 

HBCDD used in EPS and XPS indicates an increase over the figures from 2000-2004, 

by 56% for EPS and by 18% for XPS for the 2006 figures. Assuming that the 

emissions would increase pro rata, the revised emissions would be as in Tables 2.7 

and 2.8. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 22 of 108 

Table 2.5: Total, regional and continental emissions of HBCDD from formulation of 

EPS beads and HIPS compound (Point sources< RAR) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 19.5 0.4 19.1 

Wastewater 48 0 48 

Surface water 212 113.4 98.6 

Table 2.6: Total, regional and continental emissions of HBCDD from formulation of 

XPS compound (Point sources, RAR) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 11.4 5.7 5.7 

Wastewater 71.2 35.6 35.6 

Surface water 8.6 4.3 4.3 

Table 2.7: Total, regional and continental emissions of HBCDD from formulation of 

EPS beads and HIPS compound (Point sources, 2006 values) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 30.4 0.6 29.8 

Wastewater 75 0 75 

Surface water 330 177 154 

Table 2.8: Total, regional and continental emissions of HBCDD from formulation of 

XPS compound (Point sources, 2006 values) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 13.5 6.7 6.7 

Wastewater 84 42 42 

Surface water 10 5 5 

EPS 

2.3.1.3 Releases into working environment 

Release during industrial use 

Exposure to HBCDD occurs primarily during the production of EPS when it is added 

to the reactor. 

The RAR (EC 2008a) reported that personal exposures to inhalable dust for five 

operators at one plant were 0.5 mgm-3 for respirable dust (0.5-5 μm) and 2.0 mgm-3for 

total inhalable dust. Exposures to organic dusts were measured at another European 

EPS plant. All 22 measurements were less than 6 mgm-3 (Ransbotyn, 1999). 

In addition, Searl and Robertson (2005) measured inhalation short and long term 

exposures to HBCDD during the production of EPS in four plants. 

Measured short term personal exposure concentrations at two plants for dust and 

HBCDD during the period of addition of HBCDD were high (Table 2.9). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 23 of 108 

When these short-term measurements were recalculated into 8 hour average 

concentrations, the mean and 90th percentile HBCDD concentrations were 1 and 1.3 

mgm-3 of inhalable HBCDD, respectively. Full shift measurements were conducted 

(Table 2.7) with the mean and 90th percentile inhalable HBCDD concentrations being 

1.39 and 4.91 mgm-3 respectively. 

Table 2.9: Summary of measured personal exposure concentrations, representative of 

average exposure over a full shift for process operators undertaking addition of 

HBCDD to the reactor. 

Dust concentration (mgm-3) HBCDD concentration (mgm-3 Number of ) 

measurements 

(plants) 

Respirable Inhalable Respirable Inhalable 

Mean 0.42 2.59 0.33 1.18 

Standard 

deviation 1.25 4.01 1.21 3.39 

Median 0.10 1.40 0.03 0.27 

90th Percentile 

17 

(3) 

0.36 4.29 0.12 1.10 

Short term personal exposure concentrations during addition of HBCDD to the EPS 

reactor were higher, with mean and 90th percentile inhalable dust concentrations of 

6.98 and 10.46 mgm-3, respectively. The task lasted 10 to 15 minutes and took place 

up to four times per shift and these results are not inconsistent with the full shift 

measurements. 

There were no observations recorded regarding the exposure pattern for process 

workers 

Four personal samples collected during weighing of HBCDD for addition to the 

reactor gave mean and 90th percentile inhalable HBCDD concentrations of 7.2 and 

10.5 mgm-3 respectively. Although individuals spent up to the whole working day 

doing this task, a few hours of weighing provides sufficient HBCDD to last for 2 

weeks production. 

For dermal exposure, there is no measured data and EASE (Tickner et al., 2005) was 

therefore applied in the RAR to assess exposure levels during industrial use of 

HBCDD as an additive. The same process was followed as for Masterbatch resulting 

in figures of 17 mg/day and 1.7 mg/day as reasonable worst cases for EPS production 

with powder and granules, respectively. 

Release during professional and private use 

There is no information about occupational exposure to HBCDD during the 

installation of EPS during construction and other activities. It is likely that inhalable 

dust concentrations arising from the board will not exceed 10 mgm-3 and, as the 

proportion of HBCDD in EPS is around 1% exposure, inhalable HBCDD 

concentrations are unlikely to exceed 0.1 mgm-3. 

Dermal exposure is very likely to be less than the level of 1.7 mg/day during 

manufacture of EPS with granules. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 24 of 108 

Release during service life 

There is insufficient information regarding exposure to HBCDD from disturbance of 

products made from EPS during normal service life. Any exposure from disturbance 

is likely to very occasional and very low as dust generation is unlikely and the vapour 

pressure of HBCDD is low. 

Consumer exposure to HBCDD from construction boards (EPS or XPS) was 

calculated in the RAR to be 11.6 μg or 0.11 μg depending on the emission factor used. 

If the body weight is 60 kg and, if the uptake is 100 %, the internal exposure will be 

0.19 or 0.002 μg/kg bwt/day. This exposure was considered insignificant and was not 

included in the risk assessment. 

Release during disposal 

Removal of EPS insulation board at the end of its life is likely to be a dusty operation. 

In buildings, inhalable dust concentrations of more than 10 mgm-3 are likely but this 

will not be a continuous process. It is likely that occupants will not be present during 

removal. Concentrations will be lower outside. HBCDD constitutes around 1% of 

this insulation board and, assuming inhalable dust concentrations average 10mgm-3, 

the exposure concentration of HBCDD to which workers will be exposed will be 0.1 

mgm-3. 

Insulation boards form the majority of HBCDD containing waste. It is understood 

that most goes to landfill or incineration. Swan et al (2004) and Krajewski et al

(2002) reported personal exposures to inhalable dust on several landfill sites to be 

between 0.3 and 9.0 mgm-3. EPS boards contain around 1% of HBCDD. Given the 

multitude of dust sources on landfill sites, it is inconceivable that there will be 

measurable levels of HBCDD attributable to treated insulation boards in these dusts. 

Exposure to HBCDD from boards at managed incinerator sites is likely to be similarly 

low. 

2.3.1.4 Release into environment 

Release during industrial use 

The emission estimates shown in Table 2.10 have been taken from the RAR and were 

derived using the approach in the OECD Emission Scenario Document on Plastics 

Additives (OECD, 2004) and are based on the use data for the EU15 in 2000-2004. 

For the geographical distribution of these uses see Section 2.2.1. 

Table 2.10: Total, regional and continental emissions of HBCDD from industrial use 

of EPS compound in the manufacture of flame retarded EPS (Point sources, RAR 

data) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 102 10.2 92 

Wastewater 82.2 8.2 74 

Surface water 20.4 2 18 

The more recent information on the amounts of HBCDD used in EPS indicates an 

increase over the figures from 2000-2004, by 56% for the 2006 figures. Assuming 

that the emissions would increase pro rata, the revised emissions would be as in Table 

2.11. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 25 of 108 

Table 2.11: Total, regional and continental emissions of HBCDD from industrial use 

of EPS compound in the manufacture of flame retarded EPS (Point sources, 2006 

figures) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 159 16 144 

Wastewater 128 13 115 

Surface water 31 3.1 28 

Release during professional and private use 

HBCDD is used as a flame retardant in polystyrene. The predominant use of 

polystyrene is in rigid insulation panels/boards for building construction (EPS and 

XPS). 

The private use of articles (e.g. insulation boards) containing HBCDD is small 

compared to professional use. Emissions from private use are considered to be 

covered by the calculation of emissions during professional use. 

The professional use of insulation boards during construction and renovation of 

buildings is assumed to result in releases to the environment. 

The release of particles from cutting EPS-boards was estimated in the RAR to be 100 

g particles per tonne of EPS. A total of 3,392 tonnes of HBCDD was used in EPS 

each year. The RAR concluded that a worst-case estimate therefore results in a yearly 

release of 339 kg HBCDD from the use of EPS in insulation boards. 

In the RAR it was assumed that a total of 4,926 tonnes of HBCDD is used in XPS 

each year. The release of particles from sawing XPS-boards is estimated to be 5.0 g 

particles per tonne of XPS. This results in a yearly release of 25 kg HBCDD from the 

use of XPS in construction. 

The RAR estimated that the total yearly release figure is 364 kg of HBCDD from the 

use of installation boards in construction. The distribution of the release was 

estimated to be 50% to surface water and 50% to air (Table 2.12). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 26 of 108 

Table 2.12: Total, regional and continental emissions of HBCDD from installation of 

professional insulation boards (Diffuse sources, RAR) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 182 18 164 

Wastewater 0 0 0 

Surface water 182 18 164 

The emission estimates shown in Table 2.12 are taken from the RAR (EC, 2008a) and 

are based on the tonnages used in the period 2000-2004. For the geographical 

distribution of these uses see Section 2.2.1. They relate to the EU-15 countries. 

The more recent information on the amounts of HBCDD used in insulation boards in 

EU27 indicates an increase over the figures from 2000-2004, by 30% for the 2006 

figures. Assuming that the emissions would increase pro rata, the revised emissions 

would be as in Table 2.13. 

Table 2.13: Total, regional and continental emissions of HBCDD from installation of 

professional insulation boards (Diffuse sources, 2006 figures) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 236 23 213 

Wastewater 0 0 0 

Surface water 236 23 213 

Release during service life 

The emission estimates shown in Table 2.14 are based on the results of experiment 

measuring the loss of HBCDD from a sample of foamed polystyrene, assuming an 

average service life of 30 years. 

Table 2.14: Total, regional and continental emissions of HBCDD from building 

insulation (EPS and XPS) (Diffuse sources) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 54 5.4 48.6 

Wastewater 0 0 0 

Surface water 0 0 0 

These emissions are taken from the RAR (EC, 2008a) and are based on the tonnages 

used in the period 2000-2004. They relate to the EU-15 countries, and there is no 

information regarding use in specific countries. As noted above, there is significant 

use in Eastern European countries, and so the emissions from the EU-27 may be 

greater. Applying the same market figures as above, the increased use could be up to 

1.3 times that assumed for the calculation in the risk assessment report, or 70 kg/year 

(to air). Again as noted above, if some of the products used in Eastern Europe come 

from the Western European production, then the increase would not be as much. The 

more recent information on the amounts of HBCDD used in insulation boards 

indicates an increase over the figures from 2000-2004; however, as the estimate of 

losses from service life is based on a lifetime of 30 years, this increase will not 

significantly affect the emission estimates for some time. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 27 of 108 

Release during disposal 

Waste generated during the industrial use scenario is generally recycled into the 

process, put into landfill or incinerated. Emissions from this kind of waste generation 

are assumed to be included in the release estimates of the TGD for the corresponding 

life-cycle step. There are no data available. 

There may be releases of HBCDD when buildings insulated with flame retarded EPS 

are demolished. Estimates of possible future emissions from insulation boards to the 

wider environment at disposal are included in the risk assessment (EC, 2008a). The 

basis for the estimates is as follows. 

For boards which are recovered, possible losses of particulates were based on tests on 

manual breaking of board samples (information no referenced in EC, 2008a). There 

were no particulate losses for XPS, and 90 g particulates per tonne for EPS. The 

proportion of demolition waste recycled was taken as 30% (from RTD information). 

A quantity of 4,000 tonnes per year of HBCDD in EPS was assumed (as 50% of the 

8,000 tonnes of HBCDD used in insulation boards). The resulting emission was 108 

kg per year. 

For the 70% of boards assumed not to be recycled, an emission factor of 0.1% was 

used. (This is referenced to Anonymous, 1998 in the risk assessment, but this source 

does not appear in the reference list. In an earlier draft of the assessment, this source 

was given as a draft version of the OECD ESD on Plastics Additives (OECD, 2004). 

However, no such emission factor could be found in that source.) Applying this factor 

to 70% of the 8,000 tonnes gives an emission of 5,600 kg per year. 

The same approaches can be applied to the tonnages for 2006. For use of 5,301 tonnes 

of HBCDD in EPS, an emission of 143 kg per year (in EPS particulates) is estimated 

(assuming 30% recycling). For the use of 12,160 tonnes in EPS and XPS, an

emissions of 8,5112 kg per year of HBCDD can be estimated for the 70% not 

recycled. 

These estimates assume that the equivalent of one year’s production is present in 

demolition waste each year. The figures apply to the EU27. The estimate of 30% of 

material recycled has been retained. It could be foreseen that in the future a higher 

percentage could be recycled (no specific evidence, but based on general trends in 

recycling). Emissions from recycled material are lower, and hence the above 

estimates should be a worst case. There are considerable uncertainties in these 

estimates and it is likely that a substantial proportion of buildings in which flame 

retarded EPS has been used are less than 30 years old and not likely to be subject to 

demolition at present or in the near future. EC (2008) suggested that such products 

had not yet been in use for 30 years. Therefore emissions from this source are unlikely

to be significant at present, but may grow in the future, particularly from about 2025 

onwards as increasing numbers of buildings containing HBCDD-treated EPS become 

subject to refurbishment or demolition. There have been no studies of predicted 

current or future emissions. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 28 of 108 

2.3.2 XPS 

2.3.2.1 Releases into working environment 

Release during industrial use 

Potential exposure to HBCDD during XPS manufacture occurs when it is added to a 

hopper that feeds into the polystyrene melt. Further potential exposure to HBCDD 

contained within polystyrene dust may also occur during secondary processing of 

XPS and during the shredding and reprocessing of process waste. 

Searl and Robertson (2005) measured inhalation exposures to HBCDD in during the 

production of XPS in four plants. Masterbatch was used as a feedstock in three of 

these. Results are summarised in Table 2.15 below. 

Table 2.15: Data summary for personal exposure measurements made in XPS plants 

handling Masterbatch (Searl and Robertson, 2005) 

Dust concentration 

(mgm-3) 

Concentration HBCD 

 (mgm-3) 

Task Number of 

measurements 

(plants) 

Measure 

Respirable Inhalable Respirable Inhalable 

Process Mean 0.16 1.41 0.01 0.03 

operators 

handling 

Master-batch 

24 

 (3) 90th

Percentile 

0.20 2.95 0.01 0.03 

Other process Mean 0.10 1.68 0.01 0.03 

control 

operators 

4 

(1) 90th

Percentile 

0.10 2.07 0.02 0.03 

Secondary Mean 0.13 0.86 0.01 0.08 

processing of 

boards 

9 

 (2) 90th

Percentile 

0.31 1.33 0.02 0.22 

Reclamation 5 Mean 0.09 0.75 0.06 0.02 

 (1) 90th

Percentile 

0.16 1.50 0.14 0.02 

Searl and Robertson (2005) also made exposure measurements at an XPS plant that 

used HBCDD granules. Measured exposures to HBCDD were all less than 0.1 mgm-3

and the highest inhalable dust concentration was 2.1 mgm-3. It was also noted that 

shift rotation meant that exposure occurred on between only one in five and one in 3 

shifts. 

The RAR described exposure measurement from eight surveys of the manufacturing 

of extruded polystyrene (XPS) foam described by Abbot (2001). 95 % of the inhalable 

and respirable HBCDD concentrations were below 0.47 mgm-3. 

Thomsen et al., 2007 analysed HBCDD concentrations in the workplace air and in the 

workers’ serum Ten workers working in the “reactor” or “mixer” areas and ten 

persons from the general Norwegian population were selected for study. The 

HBCDD concentrations in air ranged from 0.24 μg.m-3 to 150 μg.m-3. The 

concentrations in the mixer area (mean 0.5 μg.m-3) were significantly lower than 

those in the reactor area (mean 15 μg.m-3, median). The mean serum concentrations 

were 162 ng/g lipids and 218 ng/g lipids, for mixer area and reactor area workers, 

respectively. HBCDD was not detected above the limit of detection (LOD = 0.5 ng/g 

lipid) in any serum samples from the control group. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 29 of 108 

For dermal exposure, there are no measured data and EASE was therefore used by in 

the RAR to assess exposure levels during industrial use of HBCDD as an additive. 

The same process was followed as for Masterbatch resulting in figures of 17 mg/day 

and 1.7 mg/day as reasonable worst cases for XPS production with powder and 

granules, respectively. As Masterbatch contains around 50% HBCDD, a reasonable 

worst case for XPS production using Masterbatch would be 0.9 mg/day, half of that 

for XPS production using HBCDD granules. 

Release during professional and private use 

There is no information about occupational exposure to HBCDD during the 

installation of EPS during construction and other activities. It is likely that inhalable 

dust concentrations arising from the board will not exceed 10 mgm-3 and, as the 

proportion of HBCDD in EPS is around 1% exposure, inhalable HBCDD 

concentrations are unlikely to exceed 0.1 mgm-3. 

Dermal exposure is very likely to be less than the level of 1.7 mg/day during 

manufacture of EPS with granules. 

Release during service life 

Any exposure to HBCDD from disturbance of products made from XPS during 

normal service life is likely to very low and very occasional as dust generation is 

unlikely and the vapour pressure of HBCDD is low. 

Consumer exposure to HBCDD from construction boards (XPS or EPS) was 

calculated by the RAR to be 11.6 μg/day or 0.11 μg/day depending on the emission 

factor used. If the body weight is 60 kg and, if the uptake is 100 %, the internal 

exposure will be 0.19 or 0.002 μg/kg bwt/day. This exposure was considered 

insignificant and was not included in the risk assessment. 

Release during disposal 

Removal of XPS insulation board at the end of its life is likely to be a dusty operation. 

Assuming there is approximately 1% HBCDD in XPS board and that inhalable dust 

concentrations would average 10mg m-3, the concentration of HBCDD to which 

workers will be exposed will be 0.1 mgm-3. It is likely that occupants will not be 

present during removal. 

Insulation boards form the majority of HBCDD containing waste. It is understood 

that most goes to landfill or incineration. Swan et al (2004) and Krajewski et al

(2002) reported personal exposures to inhalable dust on several landfill sites to be 

between 0.3 and 9.0 mgm-3. XPS boards may contain up to a few percent of HBCDD. 

Given the multitude of dust sources on landfill sites, it is inconceivable that there will 

be measurable levels of HBCDD attributable to treated insulation boards in these 

dusts. Exposure to HBCDD from boards at managed incinerator sites is likely to be 

similarly low. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 30 of 108 

2.3.2.2 Release into environment 

Release during industrial use 

The sites producing flame retarded XPS use HBCDD either as powder or as a 

compound. The emission estimates shown in Tables 2.16 and 2.17 have been taken 

from the RAR and are based on site specific information, applying the largest 

emission factor from actual sites to the use quantity not covered by the specific 

information. They are based on the tonnages used in the period 2000-2004. For the 

geographical distribution of these uses see Section 2.2.1 and relate to the EU-15 

countries. The more recent information on the amounts of HBCDD used in XPS 

indicates an increase over the figures from 2000-2004, by 18% for the 2006 figures. 

Assuming that the emissions would increase pro rata, and that the distribution 

between compound and powder remains the same, the revised emissions would be as 

in Table 2.18 and 2.19. The best estimate of the current total release to the 

environment during the manufacture of flame retarded XPS is the sum of the figures 

in tables 2.18 and 2.19. 

Table 2.16: Total, regional and continental emissions of HBCDD from industrial use 

of XPS compound in the manufacture of flame retarded XPS (Point sources) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 100 20 80 

Wastewater 27 5.4 21.6 

Surface water 7 1.4 5.6 

Table 2.17: Total, regional and continental emissions of HBCDD at sites 

involved in industrial use of HBCDD powder for flame retarded XPS 

(Point sources) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 23.6 2.1 21.5 

Wastewater 26.4 16.9 9.5 

Surface water 6.6 4.2 2.4 

Table 2.18: Total, regional and continental emissions of HBCDD from industrial use 

of XPS compound in the manufacture of flame retarded XPS (Point sources, 2006 

figures) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 118 24 94 

Wastewater 32 6.4 25 

Surface water 8.3 1.7 6.6 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 31 of 108 

Table 2.19: Total, regional and continental emissions of HBCDD at sites involved in 

industrial use of HBCDD powder for flame retarded XPS (Point sources, 2006 

figures) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 28 2.5 25 

Wastewater 31 20 11 

Surface water 7.8 5 2.8 

Release during professional and private use 

HBCDD is used as a flame retardant in polystyrene. The predominant use of 

polystyrene is in rigid insulation panels/boards for building construction (EPS and 

XPS). 

The private use of articles containing HBCDD (e.g. insulation boards) is small 

compared to professional use. Emissions from private use are considered to be 

covered by the calculation of emissions during professional use. 

Please see Section 2.3.2.2 for details on the release of HBCDD from the professional 

use of XPS boards and EPS boards in construction. 

 

Release during service life 

Please see Section 2.3.2.2 for the total, regional and continental emissions of HBCDD 

from building insulation (EPS and XPS). 

Release during disposal 

Waste generated during the industrial use scenario is generally recycled into the 

process, put into landfill or incinerated. Emissions from this kind of waste generation 

are assumed to be included in the release estimates of the TGD for the corresponding 

life-cycle step. 

The discussion on emission at disposal for EPS in Section 2.3.1.4 is also relevant for 

XPS. 

2.3.3 HIPS 

2.3.3.1 Releases into working environment 

Release during industrial use 

There are few direct measurements associated with the industrial use of high impact 

polystyrene (HIPS). The mixing processes used are comparable to those used for the 

preparation of EPS and XPS. Following the approach of the RAR (EC 2008a) it is 

assumed that inhalation exposure of HBCDD during preparation of HIPS would be 

the same as for EPS. 

For dermal exposure, there is no measured data and EASE was therefore used by in 

the RAR to assess exposure levels during industrial use of HBCDD as an additive. 

The same process was followed as for Masterbatch resulting in figures of 17 mg/day 

and 1.7 mg/day as reasonable worst cases for HIPS production with powder and 

granules, respectively. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 32 of 108 

Release during professional and private use 

There is insufficient information regarding exposure to HBCDD from handling 

products made from HIPS. Handling HIPS containing HBCDD during assembly of 

electrical equipment is likely to be limited and result in much lower exposure levels 

than the scenarios arising during production of HIPS. 

Release during service life 

Handling HIPS containing HBCDD during service and repair of electrical equipment 

is likely to result in much lower exposure levels than the scenarios arising during 

production of HIPS. 

Any exposure to HBCDD from products made from HIPS during normal service life 

is likely to be low and very occasional as dust generation is unlikely and the vapour 

pressure of HBCDD is low. 

Release during disposal 

The removal of electrical equipment from premises for disposal and the transport of 

electrical equipment to recycling or waste disposal sites are unlikely to cause any 

significant occupational or consumer exposure to HBCDD. Occupational exposures 

to HBCDD at managed landfill sites and managed incinerators are likely to be very 

low. Recycling of electrical equipment is unlikely to generate significant amounts of 

dust and it is expected that occupational exposure levels will be low. Julander et al 

(2005), for example, measured concentrations of polybrominated diphenyl ether (the 

most abundant brominated fire retardant present) of much less than 1μgm-3 in a 

recycling plant. 

2.3.3.2 Release into environment 

Release during industrial use 

The emission estimates shown in Table 2.20 have been taken from the RAR and were 

derived using the approach in the OECD Emission Scenario Document on Plastics 

Additives (OECD, 2004). They are based on 2000-2004 production data and related to 

the EU15. The limited more recent information on the amounts of HBCDD used in 

HIPS indicate a similar amount to that in the risk assessment, and so the figures are 

not changed.

Table 2.20: Total, regional and continental emissions of HBCDD from industrial use 

of HIPS compound in the manufacture of flame retarded HIPS (Point sources) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 6.3 0.63 5.7 

Wastewater 5.0 0.5 4.5 

Surface water 1.3 0.13 1.2 

Release during professional and private use 

HBCDD is used as a flame retardant in high impact polystyrene (HIPS) which is used 

in electrical and electronic parts (e.g. distribution boxes for electrical lines, video 

cassette and VCR housings). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 33 of 108 

No quantitative information is given in the RAR. This life cycle step involves the 

assembly of electrical and electronic equipment, and so appears unlikely to lead to 

significant emissions to the environment. 

Release during service life 

No quantitative information is given in the RAR. Emissions to air may occur in a 

similar way to those from EPS/XPS as described in the previous two sections. The 

quantity of HBCDD used for this purpose is around 2% of that used in EPS/XPS, and 

the likely lifetime of articles containing HIPS is shorter than those with EPS/XPS. 

Hence the emissions from the service life in HIPS can be considered to be negligible 

in comparison to those estimated in Section 2.3.2.2. 

Release during disposal 

Waste generated during the industrial use scenario is generally recycled into the 

process, put into landfill or incinerated. Emissions from this kind of waste generation 

are assumed to be included in the release estimates of the TGD for the corresponding 

life-cycle step. 

Articles containing HIPS treated with HBCDD may be returned to the manufacturers 

under the requirements of the WEEE directive, which will increase the potential for 

recycling of the materials in these articles. No specific information relating to the 

possible emissions of HBCDD from such recycling has been located. Material which 

cannot be used in recycling will be disposed of to landfill or incineration. Other 

articles will be disposed of into municipal waste, and the eventual fate of this material 

will also be to landfill or incineration. The proportion which is disposed of by each 

route will depend on the Member State in which this occurs (no information on the 

geographical distribution has been located) – the overall figures (2006) for the EU-27 

are 68% to landfill, 32% to incineration (Eurostat, 2008). For landfill, the risk 

assessment report (EC, 2008a) concludes that HBCDD has a very low mobility in 

soil, with strong sorption to organic matter. Hence is it very unlikely that HBCDD 

will be leached in significant quantities from landfills. The risk assessment considers 

that incineration leads to only very low levels of products such as brominated dioxins, 

and that operated correctly it is a suitable method for the disposal of HBCDD. 

2.3.4 Textile coating 

2.3.4.1 Releases into working environment 

Release during industrial use 

Searl and Robertson (2005) reported inhalation exposures to HBCDD in during the 

production of textile coatings in one plant. Laboratory staff were primarily exposed 

to HBCDD when making up liquid formulations. Micronised HBCDD powder was 

added to some, but not all, of the products and this was the most important source of 

exposure for production workers. 

Measured personal exposure concentrations to HBCDD for laboratory staff and 

production workers are in Table 2.21. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 34 of 108 

Table 2.21: Personal exposure concentrations for workers involved in the preparation 

of textile coatings (Searl and Robertson, 2005) 

Concentration of dust (mgm-3) Concentration of HBCDD (mgm-3 Task Duration ) 

(minutes) Respirable Inhalable Respirable Inhalable 

Mean 

(standard 

deviation) 

Laboratory 0.26 (0.26) 0.85 (0.36) 0.09 (0.09) 0.23 (0.34) 

staff 

90th

percentile 

0.50 1.25 0.19 0.53 

Mean 

(standard 

deviation 

Production 0.75 (0.44) 9.23 (6.64) 0.12 (0.11) 1.35 (11.94) 

using 

HBCDD 

90th

percentile 

1.16 15.47 0.23 3.12 

For dermal exposure, there is no measured data and EASE was therefore used in the 

RAR to assess exposure levels during industrial use of HBCDD as an additive, 

assuming dermal exposure depends on the form of HBCDD (fine, standard grade and 

granules) used in the production rather than the product. Dermal exposure to HBCDD 

when making textile coatings occurs principally during manual adding of the 

substance to the process. It was assumed that both hands and face are exposed in 

textile coating. This gives 120 mg/day as a reasonable worst case for texture coating 

production. Protective clothing was not rigorously worn in the plant surveyed (Searl 

and Robertson, 2005). 

Only 15 to 20% of textiles are coated with HBCDD (Searl and Robertson, 2005) and 

it is likely therefore that exposure occurs at the above levels for <25% of time 

worked. 

Release during professional and private use 

Dermal exposure to HBCDD may occur during sewing textiles with latex backcoating containing HBCDD. Due to the low vapour pressure the release to air from 

products is assumed to be relatively low at room temperature, but the release may be 

larger because of a temporary rise in temperature or because of weathering and 

abrasion. The RAR estimated that the inhalation exposure concentration will be 0.5 

mgm-3 and the total dermal dust exposure to HBCDD will be 840 mg/day. This 

exposure is likely to be intermittent as a result of the wide range of flame retardants 

used with textiles. 

Release during service life 

Several studies have demonstrated the presence of brominated fire retardants in 

household, office and vehicle dust (eg Stapleton et al., 2008, Takigami et al., 2008, 

Stuart et al. 2008). House dust is the most important source of exposure to brominated 

fire retardants for the general population (Lorber, 2008). The Polymer Research 

Centre at the University of Surrey and the Bolton Institute undertook studies to 

determine the release of flame-retardants from backcoated textiles (Thomas and 

Stevens, 2006). It was estimated that if a 10 kg child ate all the dust generated from 

the sofas in their home, the daily exposure would be 1.2 μg/kg/day by the RAR who 

considered this exposure insignificant. The RAR also calculated that the internal 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 35 of 108 

exposure from inhalation of HBCDD from house dust will be 1.5 μg/kg bwt/day, 

using the results from Thomas and Stevens (2006). 

On the basis of measured concentrations of HBCDD in house dust, Abdallah 

Mohamed et al (2008) estimated that UK adults and toddlers are exposed to 

respectively, to 1.1 and 4.4 μg HBCD/day (ie 0.015 and 0.44 μg/kg/day) from 

ingesting house dust. 

The extraction of HBCDD from fabric by simulating oral suckling or mouthing and 

aqueous phase dermal exposure was also investigated by Thomas and Stevens (2006). 

In the RAR, the average daily mouthing was estimated to be 30 μg/kg bwt/day if the 

back coated side is available and 3 μg/kg/day if it is not. 

Textile on mattress ticking may be flame-retarded with HBCDD but there is no 

information on how common this could be. Individuals could be exposed by lying on

such a mattress with bedding. This exposure is assumed to be via dermal route, with 

an uptake of 4 % of the external exposure. The exposure was estimated to be 0.01 

μg/kg bwt/day (EC, 2008a). This exposure level was considered insignificant by the 

RAR. 

Exposures during sewing and repair of textiles are likely to be similar in intensity to 

those described in the sewing scenario above, but occur only occasionally, perhaps 

once per year. 

Release during disposal 

There is little information currently available to fully assess exposure levels during 

disposal. The removal of curtains or furnishings by consumers may lead to a short 

term small exposure but this is a “one off” for each item and, given the 10 or 20 year 

projected lifetime, is too small to be significant. 

Coated textiles form a relatively low proportion of HBCDD containing waste. It is 

understood that most goes to landfill or incineration. Swan et al (2004) and 

Krajewski et al (2002) reported personal exposures to inhalable dust on several 

landfill sites to be between 0.3 and 9.0 mgm-3. It is inconceivable that that there will 

be measurable levels of HBCDD attributable to treated textiles in dusts on a mixed 

landfill site. Exposure to HBCDD from textiles at managed incinerator sites is likely 

to be similarly low. 

2.3.4.2 Release into environment 

Release during industrial use 

The emission estimates shown in Tables 2.22 and 2.23 have been taken from the RAR 

and are based on site specific information, applying the largest emission factor from 

actual sites to the use quantity not covered by the specific information. These 

emissions estimates are based on the tonnages used in the period 2000-2004. For the 

geographical distribution of these uses see Section 2.2.1. They relate to the EU-15 

countries. 

Table 2.22: Total, regional and continental emissions of HBCDD from formulation of 

polymer dispersions for textiles (Point sources, RAR). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 36 of 108 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 6.8 2.3 4.5 

Wastewater 220 74 146 

Surface water 55 18 37 

Table 2.23: Total, regional and continental emissions of HBCDD at sites involved in 

industrial use of textile back-coating (Point sources, RAR) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 0.64 0.32 0.32 

Wastewater 5,653 2,826 2,826 

Surface water 1,413 706.5 706.5 

The more recent information on the amounts of HBCDD used in textile coatings 

indicates a decrease over the figures from 2000-2004, by 80% for the 2007 figures. 

Assuming that the emissions would decrease pro rata, the revised emissions would be 

as in Table 2.24 and 2.25. 

Table 2.24: Total, regional and continental emissions of HBCDD from formulation of 

polymer dispersions for textiles (Point sources, 2007 figures). 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 1.4 0.5 0.9 

Wastewater 44 15 29 

Surface water 11 3.6 7.4 

Table 2.25: Total, regional and continental emissions of HBCDD at sites involved in 

industrial use of textile back-coating (Point sources, 2007 figures) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 0.12 0.06 0.06 

Wastewater 1130 565 565 

Surface water 283 141 141 

Release during professional and private use 

No quantitative information is given in the RAR. 

Release during service life 

The release estimates shown in Table 2.26 were developed using the results of 

wearing and leaching tests on aged samples of treated textiles 

Table 2.26: Total, regional and continental emissions of HBCDD from textiles during 

service life (wearing the fabric) (Diffuse sources). 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 0 0 0 

Wastewater 107 27 80 

Surface water 27 7 20 

The estimates shown in Table 2.27 are derived using the methods for service life 

releases from indoor service for organic flame retardants in OECD (2004). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 37 of 108 

Table 2.27: Total, regional and continental emissions of HBCDD from washing of

textiles (Diffuse sources). 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 0 0 0 

Wastewater 10.5 2.6 7.9 

Surface water 0 0 0 

These emissions are taken from the risk assessment report (EC, 2008a) and are based 

on the tonnages used in the period 2000-2004. For the geographical distribution of 

these uses see Section 2.2.1. Specific information on the geographical distribution has 

not been located. However, most of the use of these textiles is expected to be in those 

countries which have specific regulatory requirement for use of flame-retarded 

textiles, namely the UK and Ireland. Therefore most of the above emissions are 

expected to occur in those two countries. 

The reduced figure for use in textiles leads to reduced emission estimates from the 

service life of textiles, as in Tables 2.28 and 2.29. 

Table 2.28: Total, regional and continental emissions of HBCDD from textiles during 

service life (wearing the fabric) (Diffuse sources, 2007 figures). 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 0 0 0 

Wastewater 21.4 5.4 16 

Surface water 5.4 1.4 4 

Table 2.29: Total, regional and continental emissions of HBCDD from washing of

textiles (Diffuse sources, 2007 figures). 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 0 0 0 

Wastewater 2.1 0.5 1.6 

Surface water 0 0 0 

Release during disposal 

Waste generated during the industrial use scenario is generally recycled into the 

process, put into landfill or incinerated. Emissions from this kind of waste generation 

are assumed to be included in the release estimates of the TGD for the corresponding 

life-cycle step. 

Disposal of used furniture containing treated textiles is most likely to occur to 

municipal waste, and through that to landfill or to incineration. As noted above, most 

of the use of these treated materials is likely to be in the UK and Ireland. In these 

countries the main route of disposal for municipal solid waste is landfill (86% in the 

UK, 100% in Ireland). The possible emissions of HBCDD from landfill and 

incineration are considered in Section 2.3.3.2, with the conclusion that such emissions 

are negligible. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 38 of 108 

2.3.5 Total emissions 

Table 2.30 shows estimated total releases of HBCDD as estimated in the RAR as

outlined above. These figures are based on an estimated EU wide consumption of 

HBCDD of 9618 tonnes/year compared with the HBCDD Industry Users’ Group 

estimate of EU wide consumption in 2007 of 11,000 tonnes. Using the revised 

production and use figures for 2006/2007, the total emissions are as in Table 2.31. 

Table 2.30: Estimated total releases of HBCDD from uses in the EU15 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 508.4 67.4 441 

Wastewater 6,251 2,998 3,253 

Surface water 1,933 875 1,058 

Table 2.31: Estimated total releases of HBCDD from uses in the EU27 (2006/7 

figures) 

HBCDD emissions Total (kg/year) Regional (kg/year) Continental (kg/year) 

Air 649 82 568 

Wastewater 1553 669 884 

Surface water 924 361 563 

Note on uncertainty 

The basis of the emission estimates for each step is indicated in the sections above. 

Most of the formulation and industrial use estimates make use of actual measured 

emissions at sites, applying the worst case values from these to the quantities not 

covered by the sites providing information. These can be considered to have a 

reasonable degree of reliability. Other estimates are based on generic emission factors 

from the plastics additives emission scenario document (OECD, 2004); these are less 

specific to the substance (although the selection of some factors involves considering 

the volatility of the substance) and so will have a higher degree of uncertainty. The 

emission estimates over the service life are considered to have the highest degree of 

uncertainty.
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 39 of 108 

INFORMATION ON ALTERNATIVE SUBSTANCES AND TECHNIQUES 

3.1 Identification of alternative substances and techniques 

Manufacturers have identified certain requirements that should be met before 

substitution of HBCDD can be made (Scheifers, 2004). These requirements include: 

• Equal or better flame retardance for the product/part 

• Equal or better performance and physical properties for the product/part 

• Less risk to environment and human health 

• Cost 

• Commercial availability 

Different applications require different levels of flame retardancy, which results in a 

large number of flame retardants for each specific purposes. The alternatives listed 

below are unlikely to represent a comprehensive list but are intended to give an 

overview of what possible alternative to HBCDD may be available. There are other 

alternatives to HBCDD in different applications, however little information is 

available on their environmental and health hazards or their technical and economic 

feasibility. The alternative substances and techniques described below have largely 

been identified from previous reviews of the availability of alternatives to brominated 

fire retardants undertaken by regulatory authorities including KEMI (2006) and the 

Illinois Environmental Protection Agency (2007). Further information about the 

technical feasibility of suggested alternatives was obtained by visiting the websites of 

the manufacturers and suppliers of these products and relevant trade associations 

representing manufacturers of insulation products and plastics. 

ALTERNATIVE FIRE RETARDANTS FOR USE IN HIPS, EPS AND XPS 

3.1.1 Halogenated flame retardants in conjunction with Antimony Trioxide 

As an alternative substance for use in HIPS, other halogenated flame retardants in 

connection with antimony trioxide (ATO) are available: 

• Decabromodiphenylether/ATO 

• Decabromodiphenylethane/ATO 

• Ethylenebis(tetrabromo phthalimide)/ATO 

3.1.2 Organic aryl phosphorous compounds 

As an alternative substance for use in HIPS, organic aryl phosphorous compounds are 

available: 

• Triphenyl phosphate 

• Resorcinol bis (biphenyl phosphate) 

• Bis phenol A bis (biphenyl phosphate) 

• Diphenyl cresyl phosphate 

ALTERNATIVE FIRE RETARDANTS FOR USE IN TEXTILE BACKINGS 

3.1.3 Textile alternatives 

For the use of HBCDD in textiles, alternative substances are commercially available. 

These are: 

• chlorinated paraffins 

• decabromodiphenylether (please see Section 3.1.1 above for details) 

• ammonium polyphosphates 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 40 of 108 

• reactive phosphorus constituents 

ALTERNATIVES TO EPS AND XPS INSULATION 

At present, no suitable flame retardant is available to replace HBCDD in XPS or EPS 

as the required loadings of alternative flame retardants impair the structure and 

properties of the finished product to the extent that is no longer suitable for use. There 

are however a number of alternative forms of insulation that can be used in place of 

XPS or EPS. These alternative insulation systems have different characteristics to 

XPS and EPS and may be less appropriate for some specific use scenarios or may 

incorporate different environmental issues such as increased energy costs during 

transportation. 

3.1.4 Phenolic Foam and Phenolic Resins 

Closed cell phenolic foam is available as an alternative technique to EPS/XPS for 

some insulation applications in the building and construction industry,. It has been 

used in the building industry for various applications such as roofing, cavity board, 

external wall board, and floor insulation. Phenolic resins are used to bind glass fibre, 

mineral wool, or shredded waste to make insulation products. Glass fibre is the most 

commonly used material, accounting for 88% of all phenolic insulation products. 

Phenol and formaldehyde are the raw materials used to make the phenolic resin 

monomer. 

3.1.5 Polyurethane and Polyisocyanurate Products 

Polyisocyanurate modified urethane foams are available ss an alternative technique to 

EPS/XPS for some insulation applications in the building and construction industry. 

They are used in a variety of construction applications, and are commonly referred to 

as “polyiso” products. Polyiso insulation products use the following flame retardant 

chemicals: tris monochloropropyl phosphate (TMCPP), tris chloroethyl phosphate 

(TCEP), and RB-79 (diol made from tetrabromo phthalic anhydride). 

3.1.6 Mineral wools, other mineral products and cellulose fibre 

Mineral wools including glasswool and rockwool and products such as gypsum board 

are widely used in building insulation. Cellulose fibres, commonly manufactured from

recycled paper, are less widely used and must be treated with flame retardants and 

pesticides such as boron salts before use. These products may be used in insulation 

products as part of the following systems: 

Thermal barriers 

Reflective insulation systems are available as an alternative technique to EPS/XPS for 

some insulation applications in the building and construction. These insulation 

systems include foils, films, or papers that are fitted between studs, joists, and beams. 

Common reflective system materials include foil-faced paper, foil-faced polyethylene 

bubbles, foil-faced plastic film, and foil-faced cardboard. The resistance to heat flow 

depends on the heat flow direction, and this type of insulation is most effective in 

reducing downward heat flow. When using alternative building insulation materials, 

the necessary flame retardancy is often provided by use of a thermal barrier. Thermal 

barriers are fire resistant coverings or coatings that separate the insulation material 

from the building interior. Thermal barriers can be used to increase the fire retardant 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 41 of 108 

performance for various types of insulation. Commonly used thermal barriers include: 

gypsum board, gypsum or cement plasters, perlite board, spray-applied cellulose, 

mineral fibre, or gypsum coatings, and select plywoods. 

Loose-fill insulation 

Loose-fill insulation that can be blown into place or be spray-applied by special 

equipment can be used as an alternative to EPS?XPS in some building and 

construction applications. It is particularly suited for filling existing wall cavities and 

for irregularly shaped areas. Materials used for blown-in or spray-applied insulation 

include rock wool, fibre glass, cellulose, or polyurethane foam. Loose-fill cellulose 

insulation is commonly manufactured from recycled newsprint, cardboard, or other 

forms of waste paper. The blown-in loose-fill insulation can provide additional 

resistance to air infiltration if the insulation is sufficiently dense. Loose-fill insulation 

can also be poured in place by using materials such as vermiculite or perlite. These 

materials are produced by expanding naturally occurring minerals in a furnace. 

Blanket insulation 

As an alternative to EPS/XPS in certain insulation applications in the building and 

construction industry, blanket insulation is available. It is usually made of fibre glass 

or rock wool and can be fitted between studs, joists, and beams. They are available in 

widths suited to standard spacings between wall studs or floor joists. Continuous rolls 

can be hand cut and trimmed to fit various spaces. The blankets are available with or 

without vapour retardant facings. Batts with special flame resistant facing are 

available where the insulation will be left exposed. 

3.1.7 Intumescent systems 

An intumescent system is a combination of various compounds that in the event of 

fire react together as a result of the temperature increase to form a carbon foam. This 

foam attains a thickness of 10 to 100 times of the originally applied coating and 

insulates the substrate material through its low thermal conductivity. 

Intumescent systems include use of expanded graphite impregnated foams, surface 

treatments and barrier technologies of polymer materials. 

Almost all intumescent systems comprise, in general, of three basic components

• a dehydrating component, such as APP 

• a charring component, such as pentaerythritol (PER) 

• a gas source, often a nitrogen component such as melamine 

Whatever the detailed mechanisms for intumescents systems are, the formation of a 

thick char layer, high carbon concentration, high viscosity of pyrolyzing melt and low 

penetration capability for propagation of heat, makes intumescent systems efficient to 

reduce flammability and the exposure of fume gases (Swaraj 2001), (Posner 2004). 

ALTERNATIVES TO HIPS 

3.1.8 Polyethylene with Magnesium Hydroxide 

As an alternative technique to flame-retarded HIPS, it is possible to use polyethylene 

in conjunction with magnesium hydroxide. 

3.2 Information on alternatives 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 42 of 108 

3.2.1 Human health and environmental effects 

ALTERNATIVE FIRE RETARDANTS FOR USE IN HIPS, EPS AND XPS 

3.2.1.1 Halogenated flame retardants in conjunction with Antimony Trioxide 

Human health effects 

Antimony Trioxide

Antimony trioxide has an oral LD50 in rats of >34,600 mg/kg and LD50 values for 

administration by intraperitoneal and subcutaneous injection are 3,250 and 7,904 

mg/kg respectively (RTECS). The lowest reported toxic dose in repeated dose 

experiments listed in RTECS are summarised in Table 3.1. 

Table 3.1 Lowest reported toxic dose of antimony trioxide in repeated dose 

experiments

Species Duration 

of 

experiment 

Exposure 

Route 

Dose Effects 

Rat 90 days Oral 1690 mg/kg/day Liver - changes in liver weight Blood - 

other changes Biochemical - Enzyme 

inhibition, induction, or change in blood 

or tissue levels - phosphatases 

Rat 21 days oral 1000 mg/kg/day Nutritional and Gross Metabolic - weight 

loss or decreased weight gain 

Rat 17 weeks Inhalation 72 ugm-3 (24 

hours/day) 

Blood - pigmented or nucleated red 

blood cells Biochemical - Enzyme 

inhibition, induction, or change in blood 

or tissue levels - true cholinesterase 

Biochemical - Metabolism 

(Intermediary) - lipids including 

transport 

Rat 1 year Inhalation 4.5 mgm-3 (6 

hours/day) 

Sense Organs and Special Senses (Eye) - 

effect, not otherwise specified Lungs, 

Thorax, or Respiration - other changes 

Rat 20 days Inhalation 2.6 mgm-3 (6 

hours/day) 

Lungs, Thorax, or Respiration - other 

changes Lungs, Thorax, or Respiration - 

changes in lung weight 

Rat 13 weeks Subcutaneous 282 mg/kg/day Cardiac – other changes 

Guinea 

pig 

10 weeks Inhalation 45 mgm-3 Lungs, Thorax, or Respiration - fibrosis, 

focal (pneumoconiosis) Liver - fatty 

liver degeneration Related to Chronic 

Data - death 

In one year inhalation studies in rats, lung tumours have been reported in animals 

exposed at concentrations ranging between 1.6 and 50 mgm-3 (RTECS). Data from 

animal experiments seem to indicate that females are more sensitive concerning 

developing lung neoplasms than males. Antimony trioxide induced DNA damage in 

bacteria (IARC, 1989). 

In experiments in pregnant rats, inhalation exposure to antinomy oxide at 

concentrations of 82 and 270 ugm-3 throughout gestation have given rise to postimplantation mortality and foetal toxicity (RTECS). 

There are epidemiological indications that antimony trioxide causes dermatitis and 

has an impact on reproduction in female workers (IARC, 1989). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 43 of 108 

Antimony trioxide is classified in the EU as "Harmful (Xn)" and must be labelled 

with the risk-phrase "Possible risk of irreversible effects" (R40) as a possible 

carcinogen. 

The UK Workplace Exposure Limit for antimony and its inorganic compounds is 0.5 

mgm-3. 

Name of substance Antimony Trioxide 

Abbreviation 

CAS No. 8452-53-9 

Endpoint Value Reference 

LD50 rat oral >34600 mg/kg RTECS 

NOAEL mg/kg bw 

Reproductive toxicity 

Foetal toxicity and postimplantation mortality, LOEL rat 

inhalation 

82 ugm-3 RTECS 

Repeated dose Toxicity, LOAEL 

Rat oral 

Rat inhalation 

1000 mg/kg/day 

72 ugm-3 (24 hour exposure) 

RTECS 

Genotoxicity 

Carcinogenicity 

LOEL rat inhalation 

Possible human carcinogen 

1.6 mgm-3

IARC 

Critical endpoint Effects on general health (oral 

exposure) LOEL 

Lung cancer LOEL in rats 

OEL 

1000 mg/kg/day 

1.6 mgm-3

0.5 mgm-3

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 50 mg/day Intake equivalent to workplace exposure 

limit 

General population, oral 0.25 mg/day Intake equivalent to inhalation DNEL 

Workers, inhalation 0.5 mgm-3 Workplace exposure limit 

General population, inhalation 0.0025 mgm-3 Default assessment factor for 

worker/general population exposure, 

adjustment to allow for difference in 

duration of exposure (x10 for lifetime 

exposure) 

Based on workplace exposure limit 

Decabromodiphenylether/ATO

Studies of toxicokinetics of Decabromodiphenyl ether (decaBDE) reveal that the 

chemical can be absorbed by the oral route to a limited extent, does not accumulate in 

tissues, and undergoes clearance, largely as a result of metabolism in the liver and 

excretion in the bile. 

Short-term and subchronic studies demonstrated low toxicity from oral exposure to 

decaBDE with NOAELs of 3,000 mg/kg-day or higher. NTP (1986) conducted a 

chronic toxicity and carcinogenicity dietary study in F344 rats. DecaBDE caused an 

increase in the incidence of thrombosis in the liver in high-dose male rats (2,240 

mg/kg-day). A dose-dependent, but insignificant, increase in the incidence of 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 44 of 108 

degeneration of the liver was also observed in treated male rats. In the spleen, a dosedependent increase (statistically significant in the high-dose group) in the incidence of 

fibrosis was observed in males. In the mandibular lymph node, lymphoid hyperplasia 

increased in males in a dose-dependent manner, but the incidence reached statistical 

significance only at the high dose. Histopathology examination also revealed a dosedependent increase in the incidence of neoplastic nodules in the liver in both male and 

female rats. Female rats appeared to be refractory to the systemic toxicity of decaBDE 

at the doses used in this study. 

The observed toxicity of decaBDE in the 2-year study in rats is further supported by 

the 2-year mouse study conducted by NTP (1986). Significant increases in the 

incidence of centrilobular hypertrophy were observed in the liver of treated male 

mice. In the thyroid gland, a dose-dependent and statistically significant increase (at 

all dose levels) in the incidence of follicular cell hyperplasia was observed in male 

mice. In the females, the incidence increased in the low- and high-dose groups 

compared with the control group, but the increase was not statistically significant at 

any dose level. Female mice in the high-dose group exhibited a significant increase in 

the incidence of stomach ulcers. In addition, there were significant increases in the 

combined incidence of hepatocellular adenomas or carcinomas at both low and high 

doses in male mice. In the thyroid gland, follicular cell adenomas or carcinomas 

(combined) were slightly, but not significantly, increased in treated mice of both 

sexes. Similar to female rats, female mice appeared to be refractory to the systemic 

toxicity of decaBDE. 

DecaBDE also has been shown to induce behavioural changes in several studies in 

mice and rats (Viberg et al., 2007, 2003a; Rice et al., 2007). In the principal study 

selected, Viberg et al. (2003a) investigated the neurotoxic effects of decaBDE on 

spontaneous motor behaviour of adult NMRI male mice when these animals were 

exposed to a single oral dose as neonates on PND 3, 10, or 19 (i.e., at different stages 

of neonatal mouse brain development). Pair-wise testing between adult mice exposed 

on PND 3 and control groups indicated significant dose-related changes in all three 

spontaneous behaviour variables at 2, 4, and 6 months of age. Adult mice exposed 

neonatally up to 20.1 mg on either PND 10 or 19 did not show any significant 

differences in any of the variables. These data suggested that there was a critical 

window for the induction of behavioural disturbances, and the neurotoxic effect of 

neonatal decaBDE exposure was persistent and also worsened with age in male mice. 

The appropriate hazard descriptor for decaBDE is ‘suggestive evidence of 

carcinogenic potential’ (U.S. EPA, 2005a, b). DecaBDE was not mutagenic or 

genotoxic in several in vitro studies. In the International Agency for Research and 

Cancer (IARC, 1990) evaluation, it was concluded there was limited evidence for the 

carcinogenicity of decaBDE in experimental animal and classified it as Group 3: "Not 

classifiable as to its carcinogenicity to humans". In the EU RAR for DecaBDE, a 

cautious approach was followed, and a LOAEL for carcinogenicity of 1,120 

mg/kg/day was stated based on the increased incidence of liver neoplastic nodules 

from the lowest tested dose (1,120 mg/kg/day). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 45 of 108 

Name of substance Decabromodiphenylether 

Abbreviation DecaBDE 

CAS No. 1163-19-5 

Endpoint Value Reference 

LD50 (rat, oral) 2000 mg/kg RTECS 

NOAEL mg/kg bw 

Reproductive toxicity 

Effects on neurobehavioural 

development 

20.1 mg/kg/day Viberg et al (2007) 

Repeated dose Toxicity, LOAEL 

in male rats 

2,240 mg/kg-day 

Genotoxicity 

Carcinogenicity LOAEL for carcinogenicity of 1,120 

mg/kg/day in animals 

“not classifiable in humans” 

RAR 

IARC, 1990 

Critical endpoint Effects on neurobehavioural 

development 

Dose 20.1 mg/kg/day 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 5.6 mg/day Default assessment factors plus x5 for 

LOEL rather than NOEL 

General population, oral 2.8 mg/day 

Workers, inhalation 0.56 mgm-3 

General population, inhalation 0.07 mgm-3 

Decabromodiphenylethane/ATO

Ethane, 1,2-bis(pentabromophenyl) (EBP; CAS no. 8452-53-9) dose levels of 0, 100,

320 and 1000 mg/kg/day administered to rats by gavage in corn oil for 90 consecutive 

days produced no compound-related clinical signs of systemic toxicity, ocular lesions, 

or alterations in urinalysis, clinical chemistry, and haematology values in the treated 

or recovery groups. No biologically or toxicologically significant differences were 

observed in body weights, body weight gains, and food consumption. Statistically 

significant differences were found between control and high-dose animals in mean 

absolute or relative liver weights. Histomorphological evaluation showed in male rats 

low-grade liver changes consisting of minimal to slight hepatocellular vacuolation 

(high-dose males) and minimal to slight centrilobular hepatocytomegaly (high- and 

possibly mid-dose males). These changes had resolved by the end of the 28-day 

recovery period. No treatment-related changes were found in the livers of female rats. 

No treatment-related histomorphologic changes were present in any of the other 

tissues examined in either sex, except for evidence of aspirated test article in 

individual rats. The 90-day EBP NOAEL in the rat was 1000 mg/kg/day, and was 

consistent with that of the preceding 28-day study (no-effect level 1250 mg/kg/day). 

EBP’s lack of toxicity is likely related to poor bioavailability due to its high molecular 

weight and low solubility (Hardy, 2002). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 46 of 108 

Name of substance Ethane, 1,2-bis(pentabromophenyl) 

Abbreviation DecaBDEthane 

CAS No. 8452-53-9 

Endpoint Value Reference 

LD50 No information 

NOAEL mg/kg bw No information 

Reproductive toxicity No information 

Repeated dose Toxicity, NOAEL 

rat 

≥1000 mg/kg bw Hardy, 2002 

Genotoxicity No information 

Carcinogenicity No information 

Critical endpoint Not known 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 700 mg/day Default assessment factors

Based on NOEL in repeated dose 

experiments 

General population, oral 350 mg/day 

Workers, inhalation 70 mgm-3 

General population, inhalation 17.5 mgm-3 

Ethylenebis(tetrabromo phthalimide)/ATO

The information in this section is taken from the HPV Data Summary and Test Plan 

for 1H-Isoindole-1,3(2H)-dione, 2,2’-(1,2-ethanediyl)bis(4,5,6,7-terabromo-) (a.k.a. 

Ethylene bis tetrabromophthalimide) prepared by Abermarle (2004). 

In studies of uptake and elimination, Ethylenebis(tetrabromophthalimide) (EBTBP) 

was mainly excreted in the faeces (65% of dose), urine (15% of dose), and breath (1% 

of dose) twenty-four hours after oral dosing in laboratory rats. The organs containing 

the highest concentrations of the compound were the liver, kidney, and muscles. 

Lower levels were detected in the brain and fat. 

The acute oral LD50 in the rat was greater than 7.5 g/kg. The dermal LD50 in rabbits 

was > 2,000 mg/kg and the inhalation LC50 in rats was > 203 mg/L for 1 hour. 

No dermal irritation or reactivity was observed in rabbits treated with 0.5 g or 2.0 

g/kg ethylenebis(tetrabromophthalimide). Ethylenebis(tetrabromophthalimide) was 

determined to be an eye irritant when tested in rabbits at a dose of 100 mg/eye. It was 

mildly toxic to rats when inhaled. 

Repeated Dose Toxicity: In a 28-day experiments in rats EBTBP was fed to male rats 

(n=10/group) at 0, 0.01, 0.1 and 1% of the diet for 28 days. No mortality occurred 

during the study. No clinical signs of toxicity were observed. Mean body weights, 

body weight gains, food consumption and organ weights, haematology and serum

chemistry parameters were not affected by treatment. No gross or microscopic lesions 

attributable to test article were detected at necropsy or on light microscopy. The 28-

day NOEL was ∞ 1% of the diet. This is estimated to be ~ 1,000 mg/kg/ ay. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 47 of 108 

In a 90-Day study in rats EBTBP was administered to four groups of rats 

(n=15/sex/group) at 0, 0.01, 0.1 and 1.0% of the diet for 90 days followed by 46 days 

during which the rats were fed control diet. No changes in haematology or serum 

chemistry values related to treatment were detected on study days 0, 45, 92. No effect 

of treatment was found on urinalysis (d 0, 45 and 90). The mean relative and absolute 

organ weights of the liver, kidney, heart, and thyroids from the control and 1.0% 

groups were statistically comparable. Several animals died on test from non-test 

article related causes (most deaths were related to collection of blood for haematology 

and serum chemistry evaluations). Gross necropsy from animals dieing on test and 

sacrificed on days 92, 134, 135 and 136 revealed no test article-related gross lesions. 

No test article related lesions were detected on histopathology. The 90-day NOEL 

was 1% of the diet. This was estimated to be ~ 1,000 mg/kg/day. 

Developmental: EBTBP was administered to four groups of 25 pregnant rats by 

gavage in corn oil at doses of 0, 100, 500 or 1000 mg/kg/d on gestation days 6-15. No 

maternal mortality or clinical signs of toxicity were observed during the study. No 

treatment-related differences were noted among the groups with respect to maternal 

body weights, food consumption, necropsy or caesarean section data. No treatmentinduced fetal malformations or developmental variations were detected. The maternal 

and foetal NOEL was 1,000 mg/kg/day. 

EBTBP was administered to two groups of 20 pregnant rabbits each by gavage in 

methyl cellulose at dose of 0 or 1,000 mg/kg/d on gestation days 7-19. No maternal 

mortality, abortions or clinical signs of toxicity were observed during the study. 

Maternal body weights, weight gain, food consumption, necropsy observations and 

cesarean section data were generally comparable among the groups. No treatmentrelated malformations or developmental variations were observed. The maternal and 

foetal NOEL was 1,000 mg/kg/day. 

Genetic Toxicity - Mutagenicity 

In the Ames assay, the tester strains used were Salmonella TA98, TA100, TA1535, 

TA1537, and TA1538 and E. coli, WP2 uvrA. Each strain was tested with and without 

a source of exogenous metabolic activation of Arochlor-induced rat liver microsomes. 

EBTBP dose levels were 0, 1, 10, 100, 500, 1,000 and 5,000 ug/plate. Positive and 

negative controls were included, and performed as expected. No increase in revertant 

colonies was found at any EBTBP dose level either in the presence or absence of 

microsomal enzymes. EBTBP was not genetically active in this assay. (Mutagenicity 

Evaluation of Ethylene-1,2-bis(3,4,5,6-tetrabromophthalimie) in the Ames 

Salmonella/Microsome Assay. February 18, 1982. Chemical Inspection & Testing 

Institute, Japan, Induced Mutation Division). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 48 of 108 

Name of substance Ethylenebis(tetrabromo phthalimide) 

Abbreviation EBTBP 

CAS No. 32588-76-4 

Endpoint Value Reference 

LD50 – rat oral >750 mg/kg HPV data summary (2004) 

NOAEL mg/kg bw 

Reproductive toxicity No reported effects on fertility or 

foetal development; 

NOEL 1000 mg/kg/day 

HPV data summary (2004) 

Repeated dose Toxicity, NOAEL 

rat, 90 day oral 

1000 mg/kg HPV data summary (2004) 

Genotoxicity Not genotoxic HPV data summary (2004) 

Carcinogenicity No information 

Critical endpoint Not determined 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 700 mg/day Default assessment factors

Based on NOEL in repeated dose 

experiments 

General population, oral 350 mg/day 

Workers, inhalation 70 mgm-3 

General population, inhalation 17.5 mgm-3 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 49 of 108 

Environmental effects 

Diantimony trioxide

Identity and properties 

CAS number 1309-64-4 

Water solubility 2.76 mg/l in reconstituted water (=ISO 6341 

medium) at 22°C (EC, 2008) 

Vapour pressure 133 Pa (1 mm Hg) at 574°C (EC, 2008) 

Log Kow Not relevant for this type of substance 

Fate data 

Biodegradability Not readily biodegradable (EC, 2008). 

Bioconcentration factor Bioaccumulation potential seems to be low to 

moderate* (EC, 2008). 

* No reliable bioaccumulation studies are available. Measured data from different 

aquatic organisms have been used to calculate tentative BCF values which range from 

<5 – 15,000. It should be noted that there is considerable uncertainty in these values 

(EC, 2008). 

Aquatic effects 

Species Effect Value Reference 

Marine fish (Pargus major) 96 hr LC50 6.9 mg Sb/l# EC, 2008 

Freshwater fish (Pimephales 

promelas) 

96 hr LC50 14.4 mg Sb/l EC, 2008 

Freshwater fish (Pimephales 

promelas) 

28 d NOEC/LOEC (growth; 

length) 

1.13/2.31 mg Sb/l EC, 2008 

Invertebrate (Chlorohydra 

viridissimus) 

96 hr LC50 1.77 mg Sb/l EC, 2008 

Invertebrate (Daphnia magna) 21 d NOEC/LOEC 

(reproduction) 

1.74/3.13 mg Sb/l EC, 2008 

Algae (Raphidocelis 

subcapitata) 

72 hr ErC50 (growth rate) 

72 hr NOEC/LOEC (growth 

rate) 

> 36.6 mg Sb/l 

2.11/4.00 mg Sb/l 

EC, 2008 

The PNEC for freshwater aquatic organisms based on the above data is 0.113 mg Sb/l, 

derived by applying an assessment factor of 10 to the lowest NOEC for freshwater 

fish (EC, 2008b). 

#

 This was the only reliable study for marine aquatic organisms. Therefore the PNEC 

for marine water had to be derived by applying an assessment factor of 100 to the 

lowest NOEC for freshwater fish; PNECmarine water 11.3 μg Sb/l (EC, 2008). 

There is currently no agreed approach to perform a PBT-assessment of a metal; 

therefore a PBT-assessment has not been performed. Diantimony trioxide is classified 

as a dangerous substance and is listed in Annex 1 of Directive 67/548/EEC. 

Given that the ESR process involved a rigorous data searching and review process, 

with the possibility of the generation of new data through tests, the values reported in 

the RAR for diantimony trioxide can be considered to have little uncertainty. 

The vapour pressure of diantimony trioxide at ambient temperature is considered to be 

negligible. In the environment, antimony trioxide will slowly dissolve and transform 

into Sb(OH)3, which is oxidised to Sb(OH)6

-

 under oxic conditions. Antimony, being 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 50 of 108 

a natural element cannot by definition be degraded. However, it can be transformed 

between different speciation forms and oxidation states. 

Decabromodiphenylether

Identity and properties 

CAS number 1163-19-5 

Water solubility <0.1 g/l at 25°C (EC, 2002) 

Vapour pressure 4.63×10-6 Pa at 21°C (EC, 2002) 

Log Kow 6.27 (measured value) (EC, 2002)) 

Fate data 

Biodegradability Not readily biodegradable (EC, 2002). 

Bioconcentration factor Appears to have a low bioaccumulation potential, 

although there is a lack of consistent evidence 

(ECB, 2007). 

Aquatic effects 

Species Effect Value Reference 

Fish (Oryzias latipes) 48 hr LC50 >500 mg/l (well in excess of 

substance’s solubility). 

EC, 2002 

Fish (Oncorhynchus 

mykiss) 

120 day feeding 

experiment (dose of 

7.5-10 mg/kg bw/day) 

Increased liver weights and 

lactate levels in blood after 120 

days. Significance of these 

effects unknown. 

EC, 2002 

Invertebrates (Daphnia 

magna) 

21 d NOEC No information for deca-. Study 

carried out for octa-. 

No effects on survival, growth or 

reproduction up to 2 μg/l. 

EC, 2002 

Algae (Skeletonema 

costatum and 

Thalassiosira 

pseudonona) 

Chlorella sp. 

72 hr ErC50 

96 hr ErC50 

At the highest concentration 

tested (1mg/l), growth reduced 

by <50%. Not clear if any toxic 

effects were seen. EC50 cannot 

be determined. 

EC, 2002 

It is not possible to derive a true PNEC for the aquatic compartment as no effects are 

expected at concentrations up to the water solubility of decabromodiphenylether. 

A tentative PNEC of >1 μg/l can be estimated based on an EC50 >1 mg/l from the 

algal studies, using an assessment factor of 1,000. Alternatively, a tentative PNEC of 

>0.2 μg/l can be derived based on the 21 d NOEC for Daphnia magna with 

octabromo-diphenylether (no effects were seen up to the solubility limit of 2 μg /l). 

This approach assumes that deca- has a similar toxicity to octa- in long-term tests and 

the derived PNEC is of the same order of magnitude as that estimated using the algal 

data(EC, 2002). 

Given that the ESR process involved a rigorous data searching and review process, 

with the possibility of the generation of new data through tests, the values reported in 

the RAR for decabromodiphenylether can be considered to have little uncertainty. 

Decabromodiphenylether is persistent. No significant toxicity has been observed. A 

conclusion on bioaccumulation cannot be drawn based on the current evidence (ECB, 

2007). This substance is not currently classified for environmental or health effects 

according to Directive 67/548/EEC. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 51 of 108 

Relative emissions: the emissions of HBCDD from industrial use in HIPS are related 

to the vapour pressure. Decabromodiphenylether has a lower vapour pressure and so 

emissions from the same processes would be expected to be lower. Losses of HBCDD 

from articles during their service life are also related to the vapour pressure; hence 

emissions from service life would be expected to be lower. Decabromodiphenylether 

is not readily biodegradable, so is not expected to be degraded significantly in 

wastewater treatment plants (wwtps) or to degrade in the environment. 

The emission estimates for HBCDD from use in textiles are based largely on specific 

measurements. Therefore it is not appropriate to make an estimate of the relative 

emissions for decabromodiphenylether based on a comparison of the physicochemical properties. 

 Decabromodiphenylether is used in HIPS and in flame retarded textile coatings (EC, 

2002). 

Decabromodiphenylethane

Identity and properties 

CAS number 84852-53-9 

Water solubility ~ 0.72 μg /l at 25°C (measured value) (EA, 

2007)#

Vapour pressure ~ 1×10-6 Pa at 25°C (nominal value to indicate 

low volatility) (EA, 2007) 

Log Kow No value selected (a more reliable measurement is 

needed) (EA, 2007) 

#

 There is evidence from predictive models and analogues that the true water solubility of this 

substance could be much lower (EA, 2007). 

Fate data 

Biodegradability Not readily biodegradable (EA, 2007). 

Bioconcentration factor 25 l/kg (limit value used in calculations for the 

assessment for illustrative purposes) (EA, 2007). 

Aquatic effects 

Species Effect Value Reference 

Fish (Oncorhynchus 

mykiss) 

96 hr LC50 No effects seen at the highest 

loading rate of 110 mg/l*. 

EA, 2007 

Fish (Cyprinus carpio) 8 wk bioaccumulation 

study 

No abnormalities observed at 

exposure concentrations of 0.5 

and 0.05 mg/l. 

EA, 2007 

Invertebrates (Daphnia 

magna) 

48 hr EC50 No effects seen at the highest 

loading rate of 110 mg/l*. 

EA, 2007 

Algae (Selenastrum 

capricornutum) 

96 hr EC50 No effects seen at the highest 

loading rate of 110 mg/l*. 

EA, 2007 

* Given the excess of substance used to prepare the WAF in these studies, it is 

assumed that the water solubility limit of ~ 0.72 μg/l at 25°C was reached. 

No toxic effects were seen in any of the tests with fish, invertebrates or algae. 

Therefore, it is not possible to derive a PNEC for aquatic organisms (freshwater or 

marine). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 52 of 108 

Based on screening information only, decabromodiphenylethane is considered to be 

potentially persistent. A firm conclusion on bioaccumulation potential cannot be 

drawn due to the lack of reliable data. The substance does not meet the toxicity 

criterion. Decabromodiphenylethane is not classified for either environmental or 

human health hazards on Annex 1 of Directive 667/548/EEC (EA, 2007). 

Relative emissions: the emissions of HBCDD from industrial use in HIPS are related 

to the vapour pressure. A vapour pressure of 1×10-6 Pa at 25°C was assumed in the 

risk assessment for decabromodiphenylethane to indicate low volatility. However, the 

vapour pressure of this substance could be even lower. Therefore emissions from the 

same processes would be expected to be lower than for HBCDD. Losses of HBCDD 

from articles during their service life are also related to the vapour pressure; hence 

emissions from service life would be expected to be lower. Decabromodiphenylethane 

is not readily biodegradable, so is not expected to be degraded significantly in wwtps 

or to degrade in the environment. 

Ethylene bis(tetrabromophthalimide)

Identity and properties 

CAS number 32588-76-4 

Water solubility <1.63 mg/l (measured), 3x10-9 mg/l (calc) – from 

ECB (2008) 

Vapour pressure 3.3×10-20 Pa (calc)(ECB, 2008) 

Log Kow 9.8 (calc) (ECB, 20082) 

Fate data 

Biodegradability Not readily biodegradable (ECB, 2008). 

Bioconcentration factor Does not meet the B criterion based on indicators 

of low bioaccumulation potential (ECB, 2008). 

Aquatic effects 

Species Effect Value Reference 

Fish (Oryzias latipes) 48 hr LC50 >500 mg/l (well in excess of 

substance’s solubility). 

ECB, 2008 

The EU PBT Working Group (2008)_ concluded that it is not possible to derive a 

true PNEC for the aquatic compartment as no effects are expected at concentrations 

up to the water solubility. Although the data can be considered reliable, they are 

insufficient to derive a PNEC, and so there is uncertainty over what level should be 

used to assess exposures. 

The PBT Working Group concluded that the substance meets the P/vP criteria, does 

not meet the B criterion based on indicators of limited bioaccumulation, and does not 

meet the T criterion in mammals. According to the ESIS database, this substance is 

not classified in the Annex I of Directive 67/548/EEC as such, but it may be included 

in one of the group entries. 

Relative emissions: the emissions of HBCDD from industrial use in HIPS are related 

to the vapour pressure. The substance has a very much lower estimated vapour 

pressure and so emissions from the same processes would be expected to be lower. 

Losses of HBCDD from articles during their service life are also related to the vapour 

pressure; hence emissions from service life would be expected to be lower. Ethylene 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 53 of 108 

bis(tetrabromophthalimide) is not readily biodegradable, so is not expected to be 

degraded significantly in wwtps or to degrade in the environment. 

3.2.1.2 Organic aryl phosphorous compounds 

Health effects 

Triphenyl phosphate

The information in this section is drawn from the SIDS (UNEP, 2002). 

Acute toxicity data exist for several species of animals and indicate low toxicity via 

the oral and dermal routes (1320 to 10 800 mg/kg and >7900 mg/kg, respectively). 

No inhalation data are available. TPP also exhibits low toxicity in short-term studies 

and is not an irritant to mouse skin. In repeated dose experiments in rats, reduced 

body weights and an increase in liver weights were observed in a 35 day experiment 

at an oral dose of 350 mg/kg/day with an estimated NOEL of 70 mg/kg. In two 4 

month studies, the NOEL for effects on weight was estimated as 161 mg/kg. 

There are limited data that suggest an absence of genotoxic activity and no indication 

of carcinogenic potential was observed in the mouse lung ademona assay. 

No effects on fertility or foetal development were observed following repeated dietary 

exposure of 166-690 mg/kg per day for a period of 91 days, including mating and 

gestation periods. 

The neurotoxicity of TPP has been debated since the early studies of Smith et al. 

(1930, 1932), which reported delayed neuropathy in cats and monkeys exposed to 

TPP in acute and short-term studies. However, Wills et al. (1979) could demonstrate 

no ataxia or neuropathic damage in cats exposed to 99.9%-pure TPP. Consequently, 

the validity of the Smith studies has been questioned. Other toxicity studies using 

behavioural and morphological end-points have demonstrated that TPP administered 

short-term to cats and chickens fails to produce neuro-toxic changes. A mixture of 

triaryl (including cresyl and phenyl) phosphates produced neurochemical changes and 

minor peripheral nerve pathology in the caudal nerve of rats; acute intraperitoneal 

injection of 150 mg or less produced neither biochemical nor morphological change. 

It has been suggested that small concentrations of impurities may explain the 

neurotoxic effects observed in some studies. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 54 of 108 

Name of substance Triphenyl phosphate 

Abbreviation TPP 

CAS No. 115-86-6 

Endpoint Value Reference 

LD50 mouse oral 1320 mg/kg SIDS (2002) 

NOAEL mg/kg bw 

Reproductive toxicity No effects on fertility or development 

have been observed 

SIDS (2002) 

Repeated dose Toxicity, NOAEL 

rat 

161 mg/kg/day SIDS (2002) 

Genotoxicity Limited evidence suggesting an 

absence of genotoxic activity 

SIDS (2002) 

Carcinogenicity Limited evidence suggesting an 

absence of carcinogenic potential 

SIDS (2002) 

Critical endpoint Liver toxicity Dose: 161 mg/kg/day - NOEL 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 112.7 mg/day Default assessment factors 

General population, oral 56.35 mg/day 

Workers, inhalation 11.27 mgm-3 

General population, inhalation 2.82 mgm-3 

Resorcinol bis (biphenyl phosphate)

The Illinois Environmental Protection Agency (2007) provided a summary of the 

toxicology of resorcinol bis (biphenyl phosphate) in a report on alternatives to 

decaBDE. Their findings are tabulated below: 

Endpoint Data 

Chronic toxicity 28-day LOAEL for increased liver weight=100 mg/kg/d (lowest dose 

tested); NOAEL for immune system effects=5000 mg/kg/d (highest 

dose tested); no other short- or long-term data. 

Irritation and sensitisation Minimal skin and eye irritation; not a sensitizer 

Mutagenicity No cancer data; not mutagenic (1 assay); no chromosomal 

abnormalities (1 assay); 

Reproductive/developmental 

effects 

Rat 2-generation study NOAEL=20000 mg/kg/d (highest dose tested) 

Limited additional data are listed by RTECS. The oral LD50 in rats is reported to be 

>5000 mg/kg. The LC50 is greater than 4860 mgm-3. Exposure led to lowered activity 

levels and breathing difficulties. Lowered activity levels were also observed following 

dermal application to rats and the LD50 by this route is >2000 mg/kg. 

 RTECS also lists two additional repeated dose experiments. The lowest reported 

toxic dose by inhalation in rats is 500 mgm-3 (6 hours/day) in a four week experiment. 

Effects included changes in lung and liver weights. In a 28 day experiment in mice, 

the lowest reported toxic dose was 5000 mg/kg/day which was associated with 

metabolic changes. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 55 of 108 

Name of substance resorcinol bis (biphenyl phosphate)

Abbreviation RBBPP 

CAS No. 57583-54-7 

Endpoint Value Reference 

LD50 rat oral >5000 mg/kg RTECS 

NOAEL mg/kg bw 

Reproductive toxicity No adverse effects reported on 

fertility or development at 20000 

mg/kg/day 

IEPA 

Repeated dose Toxicity, LOAEL 

rat oral – increased liver weight 

rat inhalation 

100 mg/kg/day 

500 mgm-3 (6 hours/day) 

IEPA 

Genotoxicity Limited data suggest absence of 

genotoxicity 

IEPA 

Carcinogenicity No data IEPA 

Critical endpoint 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 9.3 mg/day 

General population, oral 4.7 mg/day 

Default assessment factors plus x5 for 

LOEL rather than NOEL 

Based on oral LOEL in repeated dose 

experiments 

Workers, inhalation 0.34 mgm-3

General population, inhalation 0.084 mgm-3

Default assessment factors plus x5 for 

LOEL rather than NOEL 

Based on inhalation LOEL in repeated 

dose experiments 

Bis phenol A bis (biphenyl phosphate) (BPA-BDPP) 5945-33-5

NICNAS (2000) summarise the limited available data that are available for this 

substance. It has a low toxicity following oral administration with the rat LD50 being 

> 2000 mg/kg. The dermal LD50 is also >2000 mg/kg. It does not cause irritation to 

the eyes or skin in experiments in rabbits and is non sensitising in an assay in guinea 

pigs. 

There are no cancer data and the available data suggest an absence of genotoxicity. 

In a 28-day experiment in rats the NOAEL was 1000 mg/kg/d (highest dose tested, 

includes neurotoxicity evaluation). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 56 of 108 

Name of substance Bis phenol A bis (biphenyl phosphate) 

Abbreviation BPA-BDPP 

CAS No. 5945-33-5 

Endpoint Value Reference 

LD50 rat oral >2000 mg/kg NICNAS 

NOAEL mg/kg bw 

Reproductive toxicity 

Repeated dose Toxicity, NOAEL 

rat 

1000 mg/kg/day NICNAS 

Genotoxicity Not genotoxic NICNAS 

Carcinogenicity No information 

Critical endpoint Not known 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 467 mg/day Default assessment factors

Based on NOEL in repeated dose 

experiments 

General population, oral 233 mg/day 

Workers, inhalation 46.7 mgm-3 

General population, inhalation 11.7 mgm-3 

Diphenyl cresyl phosphate

The following information is provided in the SIDS initial assessment profile (UENP, 

1998). 

Acute toxicity 

Oral/Rat: LD50: 6,400 mg/kg 

Inhalation/Sheep: LC50: > 0.37 mg/l/1h 

Dermal/Rabbit: LD50: > 5,000 mg/kg 

Repeated dose toxicity 

In an OECD Combined Repeated Dose and Reproductive/Developmental Screening 

Toxicity Test in rats, salivation, reduced body weight gain and increased water intake 

were observed in both sexes, and increased food consumption was observed in male 

rats at 300 mg/kg/day. This was combined with enlargement and cortical vacuolation 

of the adrenals, enlargement of the liver, and fatty change of the proximal tubular 

epithelium were found in both sexes. In addition, reduction of fatty change of the 

hepatocytes, increase in hyaline droplets and basophilic changes in the proximal 

tubular epithelium, erosion or focal necrosis in mucosa of stomach and atrophy of 

seminiferous tubular were found in male rats, and clear cell change of hepatocytes, 

atrophy of thymus, hypertrophy and hyperplasia of the interstitial cells in the ovaries 

were found in female rats. Anaemia, and an increase of leukocytes were also observed 

in male rats at 300mg/kg together with an increase in total cholesterol and decreases 

in GOT, albumin, A/G ratio, cholinesterase activity and triglycerides. In urinalysis, 

decreases in pH and specific gravity, an increase of urine volume were found at 300 

mg/kg in male rats. At 60 mg/kg/day, reduced body weight gain was observed in 

females and enlargement and cortical vacuolation of the adrenals were found in both 

sexes. In addition, an increase of total cholesterol, a decrease of cholinesterase 

activity, and enlargement of the liver were found in male rats, and histopathological 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 57 of 108 

changes in the liver, kidneys and the thymus were found in female rats. The 

NOELwas identified as12 mg/kg/day. 

Reproduction/developmental toxicity 

In an OECD Combined Repeated Dose and Reproductive/Developmental Screening 

Toxicity Test in rats, reduced fertility and implantation rates were observed at 300 

mg/kg/day. These were probably caused by dysspermatogenesis. A birth index tended 

to low. There were no effects on the reproductive or developmental parameters of 

copulation, pregnancy, parturition or lactation. In an observation of neonates, no 

effects were found on the values for live pups, mean pup weights, sex ratio, abnormal 

pups or loss of offspring. 

These results indicate that the no effect levels for reproduction or development are 60 

mg/kg for sires, and 300 mg/kg for dams and offsprings. 

NOEL for P generation: 60 mg/kg 

NOEL for F1 generation: 300 mg/kg 

NOEL for F2 generation: not applicable 

Genetic toxicity 

Bacterial test: Negative results in S. Typhimurium TA100, TA1535, TA98, TA1537 

and E. coli WP2 uvrA with and without metabolic activation (Japanese TG). 

Chromosomal Aberration in vitro: Marginal positive result in Chinese hamster liver 

(CHL) cells with metabolic activation (Japanese TG). 

Micronucleus Test: Negative result (Japanese TG). 

Name of substance Diphenyl cresyl phosphate 

Abbreviation 

CAS No. 26444-49-5 

Endpoint Value Reference 

LD50 6400mg/kg (rat, oral) SIDS, 1998 

NOAEL mg/kg bw No information 

Reproductive toxicity Reduced fertility at 300 mg/kg/day, 

NOEL 60 mg/kg/day 

SIDS, 1998 

Developmental toxicity None (NOEL 300 mg/kg/day) SIDS, 1998 

Repeated dose Toxicity, NOEL rat 12 mg/kg/day SIDS, 1998 

Genotoxicity Negative SIDS, 1998 

Carcinogenicity No information 

Critical endpoint Toxicity to liver, kidney and blood Dose (NOEL) 12 mg/kg/day 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 8.4 mg/day Default assessment factors

Based on NOEL in repeated dose 

experiments 

General population, oral 4.2 mg/day 

Workers, inhalation 0.84 mgm-3 

General population, inhalation 0.21 mgm-3 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 58 of 108 

Environmental effects 

Triphenyl phosphate

Identity and properties 

CAS number 115-86-6 

Water solubility 1.9 mg/l at room temperature (Saeger et al., 1979) 

Vapour pressure 2.4x10-3 Pa at 25°C (estimated from several 

values at elevated temperatures) 

Log Kow 4.63 (Saeger et al., 1979) 

Fate data 

Biodegradability Readily biodegradable (CERI,2003) 

Bioconcentration factor 420 (Muir et al., 1983) 

Aquatic effects 

Species Effect Value Reference 

Fish (Oncorhynchus 

mykiss) 

96 hr LC50 0.31 mg/l Sittichaikasen, 1978 

Fish (Oncorhynchus 

mykiss) 

30d EC10 (growth in 

sac fry) 

0.037 mg/l Sittichaikasen, 1978 

Invertebrates (Gammarus) 96 hr EC50 0.25 mg/l Huckins et al., 1991 

Algae 26 hr IC50 0.2-0.5 Wong and Chau, 1983 

Algae NOEC 0.1 mg/l Wong and Chau, 1983 

The PNEC for aquatic organisms based on the above data is 0.74 μg/l, derived by 

applying an assessment factor of 50 to the EC10 value for fish. Although the source 

data were compiled during preparation of a draft ESR risk assessment was prepared 

for triphenyl phosphate and can be considered reliable, there is uncertainty in the 

derived PNEC which is reflected in the use of an assessment factor. 

Based on the above data, the substance does not meet the P, B or T criteria. Triphenyl 

phosphate is included on Annex 1 of Directive 67/548/EEC, with the classification 

R50/53. 

Relative emissions: the emissions of HBCDD from industrial use in HIPS are related 

to the vapour pressure. Triphenyl phosphate has a significantly higher vapour pressure 

and so emissions from the same processes would be expected to be higher. Losses of 

HBCDD from articles during their service life are also related to the vapour pressure; 

hence emissions from service life would be expected to be higher. Triphenyl 

phosphate is readily biodegradable, so is expected to be degraded significantly in 

wwtps and to degrade in the environment. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 59 of 108 

Tetraphenyl resorcinol diphosphate

Identity and properties 

CAS number 57583-54-7 

Water solubility 0.69 mg/l at room temperature (Akzo Nobel, 

2003) 

Vapour pressure 2.7x10-6 Pa at 25°C (calculated using MPBPWIN 

v 1.28) 

Log Kow 7.41 (calculated using KOWWIN v 1.60) 

Fate data 

Biodegradability Inherently biodegradable (van Ginkel and Stroo, 

1996) 

Bioconcentration factor No reliable measured data 

Aquatic effects 

Species Effect Value Reference 

Fish (Danio rerio) 96 hr LC50 No effect at 

solubility 

Geurts et al., 2006 

Invertebrate (Daphnia 

magna) 

48 hr LC50 0.76 mg/l IUCLID, 2001 

Invertebrate (Daphnia 

magna) 

21 d NOEC 

(reproduction/mortality) 

0.021 mg/l Wetton and Mullee, 2001 

Algae 72 hr Slight effect 

at solubility 

Kluskens et al, 2006 

The PNEC for aquatic organisms based on the above data would be 0.42 μg/l, derived 

by applying an assessment factor of 50 to the Daphnia NOEC. Although the source 

data were compiled during preparation of a draft ESR risk assessment was prepared 

for tetraphenyl resorcinol diphosphate and can be considered reliable, there is 

uncertainty in the derived PNEC which is reflected in the use of an assessment factor. 

Based on the above data, the substance does not meet the T criterion, but may meet 

the P or vP criteria and the B or vB criteria. Tetraphenyl resorcinol diphosphate is not 

included on Annex 1 of Directive 67/548/EEC. 

Relative emissions: the emissions of HBCDD from industrial use in HIPS are related 

to the vapour pressure. Tetraphenyl resorcinol diphosphate has a similar vapour 

pressure and so emissions from the same processes would be expected to be similar. 

Losses of HBCDD from articles during their service life are also related to the vapour 

pressure and so emissions from service life would be expected to be similar. 

Tetraphenyl resorcinol diphosphate is inherently biodegradable, so is expected to be 

degraded to a greater extent than HBCDD in wwtps and in the environment. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 60 of 108 

Bisphenol A bis (diphenyl phosphate)

Identity and properties* 

CAS number 5945-33-5 (sometimes given as 181028-79-5) 

Water solubility Practically insoluble (MSDS - Supresta, 2006) 

Vapour pressure 24 Pa at 25°C (MSDS - Supresta, 2006) 

Log Kow - 

The vapour pressure value seems very high for a substance of this structure and molecular weight . 

EPIWIN estimates a value of 3x10-6 Pa, which seems more realistic. 

Fate data* 

Biodegradability Not readily biodegradable 

Bioconcentration factor Not expected to bioaccumulate in fish 

Aquatic effects* 

Species Effect Value Reference 

Fish (Oncorhynchus 

mykiss) 

96 hr LC50 >1 mg/l MSDS (Supresta, 2006) 

Invertebrates (Daphnia 

magna) 

48 hr EC50 >1 mg/l MSDS (Supresta, 2006) 

Invertebrates (Daphnia 

magna) 

21 d NOEC >1 mg/l MSDS (Supresta, 2006) 

Algae 72 hr EC50 >1 mg/l MSDS (Supresta, 2006) 

* The property, fate and effects data given above are taken from an MSDS for this 

substance (Supresta, 2006). 

No PNEC has been derived for bisphenol A bis (diphenyl phosphate). There is

therefore uncertainty over whether it will have effects on aquatic organisms. 

Bisphenol A bis (diphenyl phosphate) is listed in ELINCS (EC number 425-220-8). 

There is no information in ESIS for this substance and an IUCLID data set is not 

available. According to ELINCS, this substance is not classified in the Annex I of 

Directive 67/548/EEC as such, but it may be included in one of the group entries. 

Trade names include: ADKSTAB FP-600 

CR-741 

FYROLFLEX BDP 

NCENDX P-30 

According to a European Flame Retardants Association fact sheet on 

bisarylphosphates (no date given) downloaded from the Internet, this substance is 

poorly biodegradable, but not toxic to fish, daphnia and algae. Bisphenol A bis 

(diphenyl phosphate) is not expected to bioaccumulate in fish. 

Relative emissions: the emissions of HBCDD from industrial use in HIPS are related 

to the vapour pressure. Bisphenol A bis (diphenyl phosphate) has a predicted vapour 

pressure lower than HBCDD and so emissions from the same processes would be 

expected to be lower. Losses of HBCDD from articles during their service life are 

also related to the vapour pressure; hence emissions from service life would be 

expected to be lower. Bisphenol A bis (diphenyl phosphate) is not readily 

biodegradable, so is not expected to be degraded significantly in wwtps or to degrade 

in the environment. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 61 of 108 

Diphenyl cresyl phosphate

Identity and properties 

CAS number 26444-49-5 

Water solubility 2.6 mg/l at room temperature (Saeger et al., 1979) 

Vapour pressure 6.3x10-5 Pa at 25°C (estimated from several 

values at elevated temperatures) 

Log Kow 4.51 (Saeger et al., 1979) 

Fate data 

Biodegradability Readily biodegradable (IUCLID, 2000) 

Bioconcentration factor 200 (Bengtsson et al., 1983) 

Aquatic effects 

Species Effect Value Reference 

Fish (Oryzias latipes) 96 hr LC50 1.3 mg/l UNEP, 2002 

Invertebrate (Daphnia 

magna) 

24 hr LC50 3.7 mg/l UNEP, 2002 

Invertebrate (Daphnia 

magna) 

21 d NOEC 

(reproduction) 

0.12 mg/l UNEP, 2002 

Algae 72 hr EC50 0.99 mg/l UNEP, 2002 

Algae 72 hr NOEC 0.55 mg/l UNEP, 2002 

The PNEC for aquatic organisms based on the above data would be 2.4 μg/l, derived 

by applying an assessment factor of 50 to the Daphnia NOEC. 

Based on the above data, the substance does not meet the P, B or T criteria. Cresyl 

diphenyl phosphate is not included on Annex 1 of Directive 67/548/EEC. 

Relative emissions: the emissions of HBCDD from industrial use in HIPS are related 

to the vapour pressure. Cresyl diphenyl phosphate has a higher vapour pressure and so 

emissions from the same processes would be expected to be higher. Losses of 

HBCDD from articles during their service life are also related to the vapour pressure 

and so emissions from service life would be expected to be higher. Cresyl diphenyl 

phosphate is readily biodegradable, so is expected to be degraded significantly in 

wwtps and to degrade in the environment. 

ALTERNATIVE FIRE RETARDANTS FOR USE IN TEXTILE BACKINGS 

3.2.1.3 Textile alternatives 

Health effects 

Chlorinated paraffins/ATO

The acute oral toxicity of chlorinated paraffins of various chain lengths is low. Toxic 

effects such as muscular incoordination and piloerection were most evident following 

single exposure to short chain length chlorinated paraffins. On the basis of very 

limited data, the acute toxicity by the inhalation and dermal routes also appears to be 

low. Mild skin and eye irritation has been observed after application of short and 

intermediate (skin irritation) chain length chlorinated paraffins. Results of several 

studies indicate that short chain chlorinated paraffins do not induce skin sensitization. 

In repeated dose toxicity studies by the oral route, the liver, kidney and thyroid are the 

primary target organs for the toxicity of the chlorinated paraffins. For the short chain 

compounds, increases in liver weight have been observed at lowest doses (lowestobserved-effect level is 50 to 100 mg/kg body weight per day and no-observed-effect 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 62 of 108 

level is 10 mg/kg body weight per day in rats). At higher doses, increases in the 

activity of hepatic enzymes, proliferation of smooth endoplasmic reticulum and 

peroxisomes, replicative DNA synthesis, hypertrophy, hyperplasia and necrosis of the 

liver have also been observed. Decreases in body weight gain (125 mg/kg body 

weight per day in mice), increases in kidney weight (100 mg/kg body weight per day 

in rats), replicative DNA synthesis in renal cells (313 mg/kg body weight per day) and 

nephrosis (625 mg/kg body weight per day in rats) have also been observed. 

Increases in thyroid weight, and hypertrophy and hyperplasia of the thyroid (LOEL of 

100 mg/kg body weight per day in rats) and replicative DNA synthesis in thyroid 

follicular cells (LOEL of 313 mg/kg body weight per day) have been reported. At 

higher doses (1000 mg/kg body weight per day), thyroid function is affected, as 

determined by free and total levels of plasma thyroxine and increased plasma thyroidstimulating hormone in rats. 

For the medium chain compounds, effects observed at lowest doses are generally 

increases in liver and kidney weight (LOEL in rats of 100 mg/kg body weight per 

day; NOAEL in rats of 10 mg/kg body weight per day). Increases in serum 

cholesterol and "mild, adaptive" histological changes in the thyroid have been 

reported at similar doses in female rats (NOAEL of 4 mg/kg body weight per day). 

 For the long chain compounds, effects observed at lowest doses are multifocal 

granulomatous hepatitis and increased liver weights in female rats (LOAEL of 100 

mg/kg body weight per day). 

In the only identified reproduction study, no adverse reproductive effects were 

reported following exposure of rats to an intermediate chain length chlorinated 

paraffin with 52% chlorine. However, survival and body weights of the exposed pups 

were reduced (LOEL for non-significant decrease in body weight of 5.7-7.2 mg/kg 

body weight per day; LOAEL for decreased survival of 60-70 mg/kg body weight per 

day). In a limited number of studies of the developmental effects of the short, medium 

and long chain chlorinated paraffins, adverse effects in the offspring were observed 

for the short chain compounds only, at maternally toxic doses in rats (2000 mg/kg 

body weight per day). For the medium and long chain compounds, no effects on the 

offspring were observed even at very high doses (1000 to 5000 mg/kg body weight 

per day). 

Chlorinated paraffins do not appear to induce mutations in bacteria. However, in 

mammalian cells, there is a suggestion of a weak clastogenic potential in vitro but not 

in vivo. Chlorinated paraffins are also reported to induce cell transformation in vitro.

Long term carcinogenicity studies by oral gavage in rats and mice have been 

conducted on a short chain chlorinated paraffin (C12; 58% Cl) and a long chain 

chlorinated paraffin (C23; 43% Cl). For the short chain compound in mice, there 

were increases in the incidence of hepatic tumours in males and females and tumours 

of the thyroid gland in females. In rats exposed to the short chain compound, there 

were increases in hepatic tumours in males and females, renal tumours (adenomas or 

adenocarcinomas) in males, tumours of the thyroid in females and mononuclear cell 

leukaemias in males. For the long chain chlorinated paraffin, the incidences of 

malignant lymphomas in male mice and tumours of the adrenal gland in female rats 

were increased. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 63 of 108 

In spite of the widespread use of chlorinated paraffins, there are no case reports of 

skin irritation or sensitization. This is supported by results of a limited number of 

studies in volunteers in which chlorinated paraffins have induced minimal irritancy in 

the skin, but not sensitization. (EHC).

Name of substance Medium Chain Chlorinated Paraffins 

Abbreviation MCCPs 

CAS No. 85535-84-9 

Endpoint Value Reference 

NOAEL mg/kg bw No data 

LD50 No data 

Reproductive toxicity 

Adverse effects on pup body 

weight and condition in rats 

(LOEL) 

Foetal toxicity in rabbits NOEL 

5 mg/kg/day 

100 mg/kg/day 

Serrone et al., 1987 

IRDC, 1983b; 1984 

Repeated dose Toxicity, NOAEL 

Effects on liver and kidney in rats 

10 mg/kg/day Serrone et al., 1987; Birtley et al. 1980 

Genotoxicity Negative Serrone et al., 1987; Birtley et al. 1980 

Carcinogenicity No information 

Critical endpoint Effects on newborn in rats Dose 5 mg/kg/day - LOEL 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 1.4 mg/day Default assessment factors plus x5 for 

LOEL rather than NOEL 

General population, oral 0.7 mg/day 

Workers, inhalation 0.14 mgm-3 

General population, inhalation 0.35 mgm-3 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 64 of 108 

Name of substance Long Chain Chlorinated Paraffins 

Abbreviation LCCPs 

CAS No. 85535-86-0 

Endpoint Value Reference 

LD50 No information 

NOAEL mg/kg bw No information 

Reproductive toxicity 

Foetal toxicity observed at dose 

causing maternal toxicity LOAEL 

in rabbits 

100 mg/kg/day IRDC, 1983c; 1981d; 1983d; 1982 

Repeated dose Toxicity 

Granulomatous inflammation of 

the liver in female rats LOEAL 

NOAEL in mice 

275 mg/kg/day 

7500 mg/kg/day 

NTP, 1986b; Bucher et al., 1987 

Genotoxicity Negative Birtley et al., 1980; NTP, 1986b; ICI, 

1982b; Serrone et al., 1987 

Carcinogenicity 

LOEL – benign lesions in the 

spleen - rats 

Carcinogenic in animals 

100 mg/kg/day 

NTP, 1986b; Bucher et al., 1987 

Critical endpoint Possible carcinogenicity and 

reproductive effects 

Dose - 100 mg/kg/day - rats 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 28 mg/day Default assessment factors plus x10 for 

LOEL rather than NOEL (to take account 

of severity of endpoint) 

General population, oral 14 mg/day 

Workers, inhalation 2.8 mgm-3 

General population, inhalation 0.7 mgm-3

Ammonium polyphosphates 68333-79-9

The Subcommittee on Flame-Retardant Chemicals, Committee on Toxicology, Board 

on Environmental Studies and Toxicology, National Research Council (2000)

reviewed the toxicology of ammonium polyphosphates and their findings are 

summarised below. 

No oral toxicity data for APPs were located for humans. Typical human dietary 

phosphorous levels are not harmful, especially in the presence of adequate calcium 

and vitamin D intake. The mean daily phosphorus dietary intake for adult males and 

females is estimated to be 1,500 mg/d and 1,000 mg/d, respectively. However, if the 

intake of phosphorus from processed foods was included in these values, the

estimated dietary intake of phosphorous would be up to 20% higher. 

It is known that high doses of ammonium ions can cause metabolic acidosis; persons 

with compromised liver function are at highest risk. Exposure to oral doses of 3.2 or 

4.8 g ammonium/d as ammonium chloride for 5 d caused metabolic acidosis in two 

humans with compromised liver function (Sartorius et al. 1949). Effects secondary to 

acidosis include renal enlargement and demineralization of bone (ATSDR 1990). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 65 of 108 

The oral LD50 for a commercially available ammonium polyphosphate in rats was 

estimated to be >5,000 mg/kg (Inveresk 1990b). No deaths or clinical signs of toxicity 

were observed among five male and five female Sprague-Dawley rats given a single 

gavage dose of 5,000 mg/kg in distilled water and observed for 14 d. Weight-gain was

normal in females during the second wk of the 2-wk observation period, but weightgain in exposed males was reduced during the second wk. Gross post-mortem analysis

of all dosed animals revealed no abnormalities. 

No deaths or toxicity symptoms were observed among five male and five female 

Sprague-Dawley rats treated with a single gavage dose of 2,000 mg/kg in distilled 

water (Safepharm 1993f). Body weight gain was normal for all animals during both 

wk of the observation period and no gross abnormalities were detected at necropsy. 

Therefore, it was concluded that the LD50 for in rats is >2,000 mg/kg. 

JECFA (1974) summarized a number of toxicity studies on phosphates and 

polyphosphate. The primary effect identified in these studies is kidney calcification 

(nephrocalcinosis), resulting from the precipitation of calcium phosphate due to an 

upset in phosphate homeostasis. JECFA (1974) noted that it is difficult to identify an 

effect level for nephrocalcinosis in toxicity studies because renal calcification occurs 

naturally to some extent in control rats which is determined by dietary intake of 

calcium and vitamin D. 

Studies by van Esch et al. (1957, as cited in JECFA 1974) and Hodge (1964a, 1964b) 

suggest that chronic exposure of rats to 0.5% (sodium) polyphosphates in the diet may 

cause increased kidney weight but no kidney histopathology, while higher 

concentrations may cause kidney calcification when mineral levels are not equalized. 

Based on standard food intakes, 0.5% in the diet corresponds to a dose of about 200 

mg/kg. 

Reproductive and Developmental toxicity 

No information was found regarding the reproductive or developmental effects of 

APPs following oral exposure. Information on reproductive and developmental effects 

of ammonium ions was also not located. 

A study conducted by van Esch et al. (1957, as cited in JECFA 1974) found decreased 

fertility in rats that were treated with a mixture of one-third Kurrol’s salt and twothirds diphosphate at a dietary concentration of 5%. No reproductive effects were 

reported at lower concentrations. 

Lang (1959, as cited in JECFA 1974), found no effects on reproduction in three 

generations of rats, each fed diets containing 0.4% or 0.75% phosphoric acid for 90 

wk. 

No effects on fertility, litter size, neonate growth, or neonate survival was observed in 

a three-generation reproduction study in groups of rats administered 0.5% sodium 

tripolyphosphate or 0.5% sodium hexametaphosphate (Hodge 1964a, 1964b, and 

BIBRA 1964). There was also no apparent effect on the histopathology of major 

organs of the third generation. 

Genotoxicity 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 66 of 108 

LR2 was not found to be mutagenic in 5 strains of Salmonella typhimurium (TA1535, 

TA1537, TA1538, TA98, TA100) exposed at concentrations of 25, 75, 250, 750, 

2,500, or 5,000 μg LR2/plate in the presence or absence of exogenous metabolic 

activation (rat liver S9) (Safepharm 1995). No other genotoxicity data were located 

for APPs or for other polyphosphates. 

Carcinogencity 

No data are available on the carcinogenic effects of APPs by any route of exposure. 

Because of the absence of carcinogenicity data, the subcommittee concluded that the 

carcinogenic potential of APPs cannot be determined. Carcinogenicity data on 

ammonium ion or polyphosphates were not located. However, based on the 

physiological roles of these compounds they would not be expected to be 

carcinogenic. 

Name of substance Ammonium Polyphosphate 

Abbreviation 

CAS No. 68333-79-9 

Endpoint Value Reference 

LD50 >5000 mg/kg Subcommittee on flame retarded 

chemicals 

NOAEL mg/kg bw 2000 mg/kg Subcommittee on flame retarded 

chemicals 

Reproductive toxicity No information 

Repeated dose Toxicity, NOAEL 

rat 

200 mg/kg/day Subcommittee on flame retarded 

chemicals 

Genotoxicity Limited data suggest not genotoxic 

Carcinogenicity No information 

Critical endpoint Possible kidney toxicity 

Preliminary DNEL DNEL for critical endpoint Remarks 

Workers, oral 56 mg/kg 

General population, oral 28 mg/kg 

Workers, inhalation 5.6 mgm-3

General population, inhalation 1.4 mgm-3

Default assessment factors plus additional 

uncertainty factor of x5 to allow for use of 

test data for sodium rather than aluminium 

polyphosphate 

Based on NOEL in repeated dose 

experiments with sodium polyphosphate 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 67 of 108 

Environmental effects 

Chlorinated Paraffins 

Medium chain chlorinated paraffins (MCCPs) 

Identity and properties 

CAS number 85535-85-9 (C14-17) 

Water solubility 0.027 mg/l for 51% wt. Cl (measured)* (EC, 2005) 

Vapour pressure 2.7×10-4 Pa at 20°C for 45 and 52% wt. Cl* (EC, 2005) 

Log Kow 5.52 - 8.21 for 45% wt. Cl 

5.47 - 8.01 for 52% wt. Cl 

7 (middle point of range of measured values)* (EC, 2005) 

Fate data 

Biodegradability Not readily biodegradable (EC, 2005). 

Bioconcentration factor BCF 1,087 l/kg* (EC, 2005).

* Values used in the risk assessment as representative values for a commercial 

product (EC, 2005). 

Aquatic effects 

Species Effect Value Reference 

Fish (Oncorhynchus 

mykiss) 

60 d NOEC No adverse effects at 4.5 mg/l over 60 

days for C14-17 52% wt. Cl mixed with 

n-pentadecane-8-14C 51% wt. Cl. 

EC, 2005 

Fish (Oryzias latipes) 20 day embryolarval study No adverse effects on embryos or 

larvae up to 1.6 and 3.4 mg/l over 20 

days (two substances tested: 

C14H23.3Cl6.7 55% wt. Cl and 

C14H24.9Cl5.1 48% wt. Cl). 

EC, 2005 

Invertebrates (Daphnia 

magna) 

21 d NOEC 

(reproduction) 

10 μg/l for C14-17 52% wt. Cl mixed 

with n-pentadecane-8-14C 51% wt. Cl. 

EC, 2005 

Crustacean (Gammarus 

pulex) 

96 hr LC50 >1.0 mg/l for C14-17 52% wt. Cl. EC, 2005 

Harpacticoid (Nitocra 

spinipes) 

96 hr LC50 9.0 mg/l for C14-17 45% wt. Cl 

>10,000 mg/l for C14-17 52% wt. Cl. 

EC, 2005 

Mussel (Mytilus edulis) 60 d NOEC 0.22 mg/l or C14-17 52% wt. Cl mixed 

with n-pentadecane-8-14C 51% wt. Cl. 

EC, 2005 

Algae (Selenastrum 

capricornutum) 

96 hr NOEC 

(biomass) 

72 hr NOEC 

(growth rate) 

0.1 mg/l for C14-17 52% wt. Cl mixed 

with n-pentadecane-8-14C 51% wt. Cl 

(96 hr EbC50 >3.2 mg/l) 

0.049 mg/l for C14-17 52% wt. Cl mixed 

with n-pentadecane-8-14C 51% wt. Cl. 

(72 hr ErC50 >3.2 mg/l). 

EC, 2005 

Long-term no observed effect concentrations (NOECs) have been reported for fish, 

Daphnia, mussels and algae. Effects have almost exclusively been observed on 

Daphnia (EC, 2005). 

A PNEC of 1 μg/l has been derived for aquatic organisms by applying an assessment 

factor of 10 to the long-term NOEC of 10 μg/l obtained from the 21-day reproductive 

study with Daphnia magna on the basis that it is the most sensitive substance (EC, 

2005). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 68 of 108 

Given that the ESR process involved a rigorous data searching and review process, 

with the possibility of the generation of new data through tests, the values reported in 

the RAR for MCCP can be considered to have little uncertainty. 

MCCPs are currently classified with respect to their effects on human health and the 

environment as follows (as of September 2008): 

• R64 (may cause harm to breastfed babies) 

• R66 (repeated exposure may cause skin dryness or cracking) 

• N; R50-53 (dangerous for the environment; very toxic to aquatic organisms – 

may cause long-term adverse effects in the aquatic environment) 

No PBT assessment is included in the published version of the risk assessment (EC, 

2005). 

Relative emissions: the emission estimates for HBCDD from use in textiles are based 

largely on specific measurements. Therefore it is not appropriate to make an estimate 

of the relative emissions based on a comparison of the physico-chemical properties. 

MCCPs are not readily biodegradable, so are not expected to be degraded 

significantly in wwtps or to degrade in the environment. 

Long chain chlorinated paraffins (LCCPs) 

Identity and properties 

CAS number 85422-92-0 (C≥18) and 63449-39-8 (C18-32) 

Water solubility 5 g/l at 20°C for all LCCPS (EA, 2008) 

Vapour pressure 2.5×10-4 Pa at 25°C for C18-20 liquids (typically 40-52% wt. Cl) 

2.5×10-5 Pa at 25°C for C>20 liquids (typically 40-54% wt. Cl) 

1.5×10-14 Pa at 25°C for C>20 solids (typically 70% wt. Cl) 

(EA, 2008)* 

Log Kow 9.7 for C18-20 liquids (typically 40-52% wt. Cl) 

10.3 for C>20 liquids (typically 40-54% wt. Cl) 

17 for C>20 solids (typically 70% wt. Cl) (EA, 2008)* 

* Vapour pressure and log kow values given above have been selected for use in the 

risk assessment for the three groups of long chain chlorinated paraffins considered 

(EA, 2008). 

Fate data 

Biodegradability Unlikely to be readily or inherently biodegradable (EA, 2008) 

Bioconcentration factor BCF 1,096 l/kg for C18-20 liquids 

BCF 192 l/kg for C>20 liquids 

BCF < 1 l/kg for C>20 solids (estimated values) (EA, 2008) 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 69 of 108 

Aquatic effects 

Species Effect Value Reference 

Fish (Alburnus alburnus) 14 d NOEC ≥125 μg/l for C18-26 49% wt. Cl (no 

effects were seen at solubility). 

EA, 2008 

Fish (Oncorhynchus 

mykiss) 

60 d NOEC ≥4 mg/l for C22-26 43% wt. Cl 

≥3.8 mg/l for C>20 70% wt. Cl 

(no effects were seen at solubility). 

EA, 2008 

Invertebrates (Daphnia 

magna) 

21 d NOEC 29 μg/l for C18-20 liquid 52% wt. Cl EA, 2008 

Invertebrates (Daphnia 

magna) 

21 d NOEC 

(reproduction) 

≥55 μg/l for C>20 liquid 43% wt. Cl (no 

effects were seen on reproduction). 

EA, 2008 

Based on the above data, the following PNECs have been derived for aquatic 

organisms using the long term NOECs from studies with Daphnia magna, and an 

assessment factor of 10: 

C18-20 liquid PNECwater = 2.9 μg/l 

C>20 liquid PNECwater, screening = 5.5 μg/l 

C>20 solids PNECwater, screening = 5.5 μg/l 

LCCPs are considered to potentially meet the persistent or very persistent criterion. 

They do not meet the toxic or bioaccumulative criterion. LCCPs are not listed in 

Annex 1 of Directive 67/548/EEC (EA, 2008). Given that the EA review involved a 

rigorous data searching and review process as undertaken for MCCPs, the values 

reported by the EA for LCCPs can be considered to have little uncertainty. 

Relative emissions: the emission estimates for HBCDD from use in textiles are based 

largely on specific measurements. Therefore it is not appropriate to make an estimate 

of the relative emissions based on a comparison of the physico-chemical properties. 

LCCPs are currently used in flame retardant textile coatings (EA, 2008).

Ammonium polyphosphates

Identity and properties 

CAS number 68333-79-9 

Water solubility 100% at 25°C (OECD, 2007) 

Vapour pressure Negligible* (OECD, 2007) 

Log Kow Not applicable to inorganic salts (OECD, 2007) 

 *Ammonium polyphosphate is an inorganic salt and will have negligible vapour pressure. Any 

measurable vapour pressure is due to the decomposition and release of ammonia gas. 

Fate data 

Biodegradability Standard biodegradation tests are not applicable to 

inorganic salts. The ammonium present in APP may be

nitrified (OECD, 2007). 

Bioconcentration factor APP is not expected to bioaccumulate as it has high 

aqueous solubility and will exist in a dissociated form 

in solution (OECD, 2007). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 70 of 108 

Aquatic effects 

Species Effect Value Reference 

Fish (Oncorhynchus mykiss) 96 hr LC50 >101 mg/l OECD, 2007 

Based on the above data, it is not possible to calculate a PNEC for the aquatic 

compartment. Given that these data come from an OECD SIAR, that has been 

reviewed internationally, it is assumed that there are no more data readily available. In 

the absence of a PNEC, there is uncertainty over what level should be used to assess 

exposures. 

According to the ESIS website, this substance is not classified in the Annex I of 

Directive 67/548/EEC as such, but it may be included in one of the group entries. 

Based on the above data, ammonium polyphosphate does not meet the P, B or T 

criteria, so is not a PBT substance. 

Reactive phosphorous constituents

We have been unable to determine exactly what these substances are and there is no 

readily available information on their toxicity or environmental effects. It appears to 

have been assumed by KEMI (2006) and others that these compounds will have less 

impact on human health and/or the environment than brominated compounds, but 

there appear to be few data to support this assertion. 

ALTERNATIVES TO EPS AND XPS INSULATION 

3.2.1.4 Phenolic Foam 

Health effects 

The health issues associated with the use of phenolic foam are expected to be 

minimal. Toxic gas emission from phenolic foam is generally limited to carbon 

dioxide and carbon monoxide with very low levels of other gases. Phenolic foams can 

achieve very low toxic gas ratings in tests such as UK Naval Engineering Standard 

NES 713 and Scandinavian NordTest NT036. Phenolic foam has good fire resistance. 

There is a limited potential for dust inhalation during the installation of phenolic foam 

or during the removal of phenolic foam during building renovation or demolition. 

Phenolic foams are made by a reaction of phenol and formaldehyde in the presence of 

a catalyst. There are potential health issues for workers involved in the manufacture of 

phenolic foam who may be exposed to these chemicals. Formaldehyde is irritating to 

mucous membranes at low levels of exposure and has been identified as a human 

carcinogen by IARC (2006). Phenol causes kidney and developmental toxicity in 

animals. IPCS (1994) identified NOAELS in rat studies in the range of 12-40 mg/kg 

body weight per day and recommended that the upper limit of total human daily 

intake should be in the range of 60-200 μg/kg body weight per day, equivalent to 

workplace exposure concentrations of 0.4-1.4 mgm-3 for an 8 hour shift. The UK 

Workplace exposure limits for formaldehyde and phenol are respectively as 8 hour 

time weighted averages. Formaldehyde is labelled as R23/24/25, 34, 40, 43 (Toxic by 

inhalation, in contact with the skin and if swallowed, limited evidence of a 

carcinogenic effect, may cause sensitisation by skin contact) and phenol is labelled as 

R23/24/25, 34, 48/20/21/22, 50/53 (Toxic by inhalation, in contact with the skin and 

if swallowed, danger of serious damage to health by prolonged exposure by 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 71 of 108 

inhalation, in contact with the skin or if swallowed, very toxic to aquatic organisms, 

may cause long-term serious effects in the aquatic environment). 

Environmental effects 

Formaldehyde 

Identity and properties 

CAS number 50-00-0 

Water solubility 95% (w/w) at 120°C (theoretical solubility)* 

(UNEP, 2002) 

Vapour pressure 5,185 hPa at 25°C (measured) (OECD, 2002) 

Log Kow 0.35 (measured) (UNEP, 2002) 

*At room temperature, pure aqueous solutions contain formaldehyde as methylene glycol and its 

oligomers. Aqueous solutions containing more than 30% (w/w) formaldehyde become cloudy at room 

temperature due to formation of larger poly(oxymethylene)glycols. 

Fate data 

Biodegradability Readily biodegradable (UNEP, 2002)

Bioconcentration factor Unlikely to occur (UNEP, 2002) 

Aquatic effects 

Species Effect Value Reference 

Fish (Ictalorus melas) (freshwater) 96 hr LC50 24.8 mg/l UNEP, 2002 

Fish (Morone saxatilis) (marine) 96 hr LC50 6.7 mg/l UNEP, 2002 

Invertebrates (Daphnia pulex) 48 hr EC50 5.8 mg/l UNEP, 2002 

Invertebrates (Daphnia pulex) 48 hr EC50 29 mg/l UNEP, 2002 

Algae (Scenedesmus subspicatus) 24 hr EC50 

24 hr EC10 (endpoint: oxygen 

production and consumption) 

14.7 mg/l 

3.6 mg/l 

UNEP, 2002 

The PNEC for aquatic organisms based on the above data would be 5.8 μg/l, derived 

by applying an assessment factor of 1,000 to the lowest valid effect value (48 hr EC50

of 5.8 mg/l) for Daphnia pulex.

Based on the above data, formaldehyde does not meet the P, B or T criteria, so is not a 

PBT substance. 

Classification according to Annex 1 (ESIS website) for formaldehyde: 

Carc. Cat 3; R40 

T; R23/24/25 

C; R34, R43 

Formaldehyde is mainly used as an intermediate in the chemical industry for the 

production of condensed resins for the wood, paper and textile processing industries. 

Urea-formaldehyde foam insulation and formaldehyde disinfectants are important 

sources of formaldehyde exposure (OECD, 2002). 

As this substance is used in a completely different way to HBCDD, an estimation of 

relative emissions is not appropriate. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 72 of 108 

Phenol 

Identity and properties 

CAS number 108-95-2 

Water solubility 84 g/l at 20°C (EC, 2006) 

Vapour pressure 0.2 hPa at 20°C (measured) (EC, 2006) 

Log Kow 1.47 (measured) (EC, 2006) 

Fate data 

Biodegradability Readily biodegradable (EC, 2006) 

Bioconcentration factor 17.5 l/kg (EC, 2006) 

Aquatic effects 

Species Effect Value Reference 

Fish (Oncorhynchus mykiss) 96 hr LC50 5.02 mg/l EC, 2006 

Fish (Cirrhina mrigala) MATC (related to survival and 

growth of larvae) 

60 d NOEC (derived from MATC) 

77-94 μg/l 

77 μg/l 

EC, 2006 

Invertebrate (Cerodaphnia 

dubia) 

48 hr LC50 3.1 mg/l EC, 2006 

Invertebrate (Daphnia magna) 16 d EC10 (growth reduction) 0.46 mg/l EC, 2006 

Algae (Selenastrum 

capricornutum

96 hr ErC50 (growth inhibition) 61.1 mg/l EC, 2006 

The PNEC for aquatic organisms based on the above data would be 7.7 μg/l, derived 

by applying an assessment factor of 10 to the lowest NOEC (77 μg/l) for Cirrhina 

mrigala. [The NOEC is derived from a MATC of 77-94 μg/l with the assumption that 

the MATC is given as the range between the NOEC and the LOEC]. 

Annex I of Directive 67/548/EEC does not currently contain any environmentally 

relevant classifications for phenol. Classification according to Annex I (EC, 2006): 

T; R 23/24/25 

C; R 34 

R 48/20/21/22 

Muta. Cat. 3, R 68 

Based on the above data, phenol does not meet the P, B or T criteria so is not a PBT 

substance. 

Phenol is mainly used as an intermediate in organic synthesis for the production of 

bisphenol A, phenol resins, alkylphenols, caprolactam, salicylic acid, nitrophenols, 

diphenyl ethers, halogen phenols and other chemicals. 

As this substance is used in a completely different way to HBCDD, an estimation of 

relative emissions is not appropriate. 

3.2.1.5 Polyurethane and Polyisocyanurate Products 

Health effects 

These products do not give off volatile substances which in use and would not be 

expected to give rise to toxic exposures during use. There is a limited potential for 

dust inhalation during the installation or these products or during their during building 

renovation or demolition. These foams may be treated with brominated fire retardants 

to achieve required levels of fire resistance. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 73 of 108 

When subjected to burning, polyurethane foam systems will yield toxic fumes 

consisting of various gases, which may include, but not limited to, carbon monoxide, 

carbon dioxide and oxides of nitrogen, which may also present a risk to respiratory 

tract and eyes. 

The manufacture of polyurethane and polyisocyanurate products involves the use of 

isocyanates which are potent respiratory sensitisers. There are potential health issues 

for workers involved in the manufacture of polyurethane foam who may be exposed 

to these chemicals. The UK workplace exposure limits for isocyanates calculated in 

terms of the mass of NCO groups present are 0.02 and 0.07 mgm-3 for an 8 hour shift 

or 15 short term exposure respectively. 

Environmental effects 

Tris(2-chloro-1-methylethyl) phosphate (TCPP) 

This substance is used as a flame retardant additive for polyurethane. The main use of 

the treated polyurethane is in rigid foams for construction applications such as blocks 

and panels for insulation (EC, 2008c). 

Identity and properties 

CAS number 13674-84-5 

Water solubility 1,080 mg/l at 20°C (measured) (EC, 2008b) 

Vapour pressure 1.4×10-3 Pa at 25°C (measured) (EC, 2008b) 

Log Kow 2.68 (measured) (EC, 2008b) 

Fate data 

Biodegradability Inherently biodegradable, not fulfilling the criteria 

(EC, 2008b). 

Bioconcentration factor 0.8-4.6 l/kg (2.7 l/kg, arithmetic mean) (EC, 

2008b). 

Aquatic effects 

Species Effect Value Reference 

Fish (Pimephales promelas) 96 hr LC50 51 mg/l EC, 2008b 

Invertebrate (Daphnia magna) 48 hr EC50 131 mg/l EC, 2008b 

Invertebrate (Daphnia magna) 21 d NOEC (reproduction) 32 mg/l EC, 2008b 

Algae (Pseudokirchneriella 

subcapitata) 

72 hr ErC50 (growth rate) 

72 hr EbC50 (biomass) 

82 mg/l 

33 mg/l 

EC, 2008b 

Algae (Pseudokirchneriella 

subcapitata) 

72 hr ErC10 (growth rate) 

72 hr EbC10 (biomass) 

72 hr NOEC 

42 mg/l 

14 mg/l 

13 mg/l 

EC, 2008b 

The PNEC for aquatic organisms based on the above data would be 0.64 mg/l, derived 

by applying an assessment factor of 50 to the long-term NOEC for Daphnia magna. 

Given that the ESR process involved a rigorous data searching and review process, 

with the possibility of the generation of new data through tests, the values reported in 

the RAR for this substance can be considered to have little uncertainty. 

Tris(2-chloro-1-methylethyl) phosphate is not currently included on Annex I of 

Directive 67/548/EEC. Based on the above data, tris(2-chloro-1-methylethyl) 

phosphate is not a PBT substance. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 74 of 108 

This substance is used in a different material to HBCDD, and the processes involved 

may be different, hence it is not possible to make an estimate of the relative level of 

emissions through comparison of the substance properties with HBCDD. 

3.2.1.6 Mineral wools and other mineral products 

Health effects 

These systems employ inert materials such as fibre glass, glass wool, rock wool and 

gypsum that do not represent a hazard to building occupants when used as insulation. 

Although formaldehyde and phenolic resins may be used to bind these products, 

emissions to indoor air are extremely low and do not impact on indoor air quality. 

These materials are innately fire and heat resistant. There is potential for dust 

inhalation during the installation of these products or during building renovation or 

demolition. In the UK, the workplace exposure limit for all machine-made mineral 

fibres is 5 mgm-3 as inhalable dust or 2 fibres/ml, which ever is reached first. These 

materials are not classified as carcinogenic. Gypsum is a low toxicity dust and the UK 

workplace exposure limits would be 4 and 10 mgm-3 for the respirable and inhalable 

fractions respectively. 

Environmental effects 

The industry (EUROSIL: http://www.eurisol.com/pages/waste_sustainability.htm

claim that for each tonne of CO2 generated in the manufacturing process of mineral 

wool, about 200 tonnes of CO2 are saved by its thermal insulation properties over a 

50-year period and that producing mineral wool requires only half the energy needed 

to manufacture other types of insulation. EUROSIL also claim that there has been a 

steady decrease in energy inputs and emissions during production over time. In 

addition, the industry claim to be using increasing amounts of recycled materials in 

manufacture. Depending on the quality and availability of local supplies recycled 

glass now makes up 30% to 60% of the raw material input. In some plants this is as 

high as 80%. 

Following end of life removal from buildings, there is an increasing trend to recycle 

these materials, otherwise they may be disposed of as inert construction waste and are 

unlikely to have a major adverse impact on the environment. 

3.2.1.7 Cellulose fibre 

Insulation products based on cellulose recovered from the recycling of paper and 

similar materials have been promoted as a green alternative to traditional insulation 

systems. Cellulose fibres are believed to represent a relatively low health hazard for 

humans and the UK workplace exposure limits for respirable and inhalable dust are 4 

and 10 mgm-3 respectively as an 8 hour time weighted average. There is also a 15 

minute exposure limit for inhalable dust of 10 mgm-3. 

In order to meet fire safety standards and also in order to prevent rodent or other pest 

damage, cellulose fibre insulation must be treated with fire retardant and persistent 

pesticides to be effective in use. Potentially, the presence of these added chemicals 

would lead to human health hazards and potential environmental effects that were at 

least as serious as those associated with EPS or XPS. Some (perhaps all) cellulose 

insulation products marketed in the EU contain inorganic boron salts that have been 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 75 of 108 

added in sufficient quantity to meet fire safety regulations and to provide adequate 

pest protection. The IPCS (1998) report that animal experiments have shown that 

boron in the form of inorganic salts (borates) gives rise to reproductive and 

developmental toxicity in animals and calculated that the tolerable intake (TI) of 

boron for humans as 0.4 mg/kg body weight per day, equivalent to 28 mg/day for a 

70 kg adult. The American Conference of Industrial Hygienists (ACGIH) recommend 

Threshold Limit Values for inorganic borates of 2 mgm-3 and 6 mgm-3 as an 8 hour 

time weighted average and 15 minute maximum exposure concentrations respectively. 

The 8 hour limit would give a daily intake equivalent to 20 mg. The US EPA oral 

reference dose (ie dose at which repeated exposure would be expected to cause no 

significant hazard to health) for boron is 0.2 mg/kg/day (equivalent to an adult intake 

of 14 mg/day) to protect against reproductive and developmental effects 

(http://www.epa.gov/NCEA/iris/subst/0410.htm). The US ATSDR indicate that the 

short and intermediate term Minimal Risk Levels for oral intake are 0.2 mg/kg/day 

and also give a draft inhalation minimal risk level for acute respiratory effects of 0.01 

mgm-3 (for community rather than workplace exposure; 

http://www.atsdr.cdc.gov/mrls/index.html). 

The IPCS (1998) indicate that boron has a low aquatic toxicity. 

3.2.1.8 Intumescent systems 

We have been unable to find relevant health or environmental information. 

ALTERNATIVES TO HIPS 

3.2.1.9 Polyethylene with Magnesium Hydroxide 

Health effects 

The available data is not sufficient to conduct a health screening of magnesium 

hydroxide, but indicate that the substance can be regarded as relatively harmless in 

small quantities as the substance is used as food additive. 

Repeated or prolonged human exposure to larger quantities of the substance may 

imply adverse impact on human health, such as general irritation and malaise. There 

may be lung effects at high particulate concentrations and central nervous system 

depression at very high doses. 

The ISCS on polyethylene indicates low toxicity. 

Environmental effects 

Polyethylene is a persistent waste material, although an increasing quantity is being 

recycled. Ingestion of polyethylene particles by animals is a growing problem, 

particularly in marine ecosystems. Organisms may ingest plastics in preference to 

food. The release of small quantities of magnesium hydroxide to the environment 

would not be expected to cause toxicity. The disposal of large quantities in a restricted 

area of water or disposal onto soil could have a substantial impact on alkalinity levels 

with consequent impacts on flora and fauna. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 76 of 108 

3.2.2 Technical and economical feasibility and availability 

ALTERNATIVE FIRE RETARDANTS FOR USE IN HIPS, EPS AND XPS 

3.2.2.1 Halogenated flame retardants in conjunction with Antimony Trioxide 

Technical feasibility 

Diantimony trioxide is an effective flame retardant synergist used in conjunction with 

a source of halogen such as halogenated flame-retardants or PVC. It is used in 

plastics, rubber and textiles (EC, 2008). Diantimony trioxide has a wide range of 

applications and is used in polymers such as polypropylene, polyethylene, EDPM, 

ABS, HIPS (electrical components, appliance housings etc), flexible polyurethane, 

TPU, unsaturated polyesters, epoxies, phenolics and engineering thermoplastics such 

as PBT (Great Lakes, http://www.e1.greatlakes.com/corp/common/jsp/index.jsp). 

Decabromodiphenylethane is a general purpose additive flame retardant for a variety 

of polymer applications and textiles. It is used in ABS, HIPS, polypropylene and 

polyethylene, polycarbonate, polybutylene terephthalate and polyethylene 

terephthalate, PVC, thermoplastic elastomers, epoxy resins and unsaturated 

polyesters. Applications include building insulation and roofing materials, wire and 

cable insulation, coatings, and electrical and electronic applications (particularly those 

made from HIPS such as TV housings) (EA, 2007). Ehylene 

bis(tetrabromophthalimide) is used as a flame retardant in a range of applications 

including HIPS, ABS, thermoplastic polyester, polycarbonate, polypropylene and 

polyethylene, polyolefin, PVC and elastomers (Albemarle, 

http://www.albemarle.com/). 

HBCDD provides effective flame retardant properties at low loadings in HIPS, EPS 

and XPS that do not adversely impact the mechanical properties of these materials. 

Other fire retardants are only effective at much higher loadings which adversely affect 

the mechanical properties of HIPS, EPS and XPS. The higher loadings would also 

lead to greatly increased manufacturing costs (KEMI, 2006). 

The EPS sector group of Plastics Europe which represents 90% of the EPS producers 

in Europe has been involved in a five year investigation to identify alternatives to 

HBCDD in EPS. They concluded that there are currently no candidate molecules, 

either commercially available or “novel” compounds which are seen as feasible 

alternatives to HBCDD in EPS. A similar research project undertaken for XPS foams 

has drawn the same conclusions (Briefing note provided to IOM by the HBCD 

Industry User Group, October, 2008). 

In a review of the use of various hazardous substances in consumer products the 

Norwegian Pollution Control Authority concluded that although no other flame 

retardant that can fully replace HBCDD in all areas, but there are other different 

brominated and non-brominated flame retardants that can be used in 

electrical/electronic products (SFT, 2007). 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 77 of 108 

Economic feasibility 

The Danish EPA (2007) provide indicative prices for HIPS containing deca-BDE and 

alternative flame retardants (i.e. compounded), as shown in the table below. 

Polymer/compound European price range (€/kg) 

Standard HIPS 0.95-1.25 

HIPS + deca-BDE 1.50-1.80 

HIPS + other BFR 

- UL 94 V-0 

- UL 94 V-1 

1.90-2.10 

1.70-1.90 

HIPS/PPE + halogen-free FR 2.30-2.90 

In addition, RPA (2002) cite information from IVL (1997) on prices of various types of flame 

retardants, as shown below. 

Based on these sources of information, the following broad conclusions can be drawn: 

Raw material costs for deca-BDE appear to be less than for other brominated flame 

retardants. Therefore, it is likely that the purchase price of this potential alternative 

would be less than that for HBCDD. 

There is insufficient available information to make distinctions between HBCDD and 

other brominated flame retardant costs. They may be expected to be broadly similar. 

Chlorinated alternatives and particularly chlorinated paraffins are expected to be less 

expensive than HBCDD. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 78 of 108 

For use of any alternative flame retardant, there would be additional one-off costs of 

substitution associated with, for example, product testing and changes to processing 

equipment which cannot readily be quantified. 

3.2.2.2 Organic Aryl Phosphorous Compounds 

These compounds are not generally regarded as technically or economically viable 

alternatives to HBCDD in HIPS, EPS or XPS for the reasons described above for 

antimony trioxide based systems. They may be technically viable alternatives to 

HBCDD for some specific product types. 

Technical feasibility 

HBCDD is used in four principal product types; EPS (insulation), XPS (insulation), 

HIPS (electrical and electronic parts) and polymer dispersion for textiles. Producers’ 

websites have been checked to see if they recommend HBCDD is used in four 

principal product types; EPS (insulation), XPS (insulation), HIPS (electrical and 

electronic parts) and polymer dispersion for textiles. Producers’ websites have been 

checked to see if they recommend triphenyl phosphate, tetraphenyl resorcinol 

disphosphate, cresyl diphenyl phosphate or bisphenol A bis (diphenyl phosphate) for 

use in the same areas as HBCDD. According to the producers’ websites, triphenyl 

phosphate is recommended for use in HIPS, consumer electronics, appliance housings 

and TV housings. Tetraphenyl resorcinol disphosphate is recommended for use in 

consumer electronics, appliance housings, TV housings, construction, insulation and 

mattresses. It is also used in engineered resins such as modified PPO, 

polycarbonate/styrenic blends, polyesters and HIPS. HBCDD is used in four principal 

product types; EPS (insulation), XPS (insulation), HIPS (electrical and electronic 

parts) and polymer dispersion for textiles. Cresyl diphenyl phosphate is recommended 

for use in construction, insulation, furniture, mattresses, textiles, and wall and floor 

coverings. Bisphenol A bis (diphenyl phosphate) is recommended for use in the 

electrical and electronics industry, enclosures made out of ABS/PC blends, 

thermosplastics including ABS and HIPS, and engineered resin applications such as 

polyphenylene oxide alloys and PC/ABS. 

Economic feasibility

Based on information from RPA (2002), organophosphorus compounds could be 

expected to be broadly similar in price to that of HBCDD per unit mass of flame 

retardant. 

However, the Bromine Science and Environment Forum (quoted in Kemi, 2006) 

indicate that greater quantities of non halogen flame retardants are required to achieve 

the same overall level of fire protection. This would tend to suggest that the overall 

raw material cost would be higher than for HBCDD. This is supported by data from 

the Danish EPA (2007) (above) which suggests significantly higher compound costs 

for HIPS/PPE with halogen-free flame retardant (€2.3-€2.9 per kg compound 

compared to €1.7-€2.1 kg for a brominated flame retardant). Whilst the price per unit

of compound is relatively moderate, this implies a potentially significant increase in 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 79 of 108 

cost of flame retardant3. The Danish EPA (2007) estimated that the cost of producing 

HIPS with a halogen-free flame-retardant rather than a brominated flame-retardant 

(other than Deca-BDE) would increase the raw material price with about 4-5 EUR for 

a full enclosure of an average TV-set. 

Again, there would be additional one-off costs of substitution associated with, for 

example, product testing and changes to processing equipment which cannot readily 

be quantified.

ALTERNATIVE FIRE RETARDANTS FOR USE IN TEXTILE BACKINGS 

3.2.2.3 Textile Alternatives 

Technical feasibility 

KEMI (2006) indicate that reactive phosphorus constituents, ammonium 

polyphosphate, diammonium phosphate and intumescent systems are commercially 

available alternatives to HBCDD but do not provide information about performance 

or cost. 

Ammonium polyphosphate is primarily used as a fertiliser (OECD, 2007). An Internet 

search revealed that this substance is used as a flame retardant in textiles for fabric 

back coating and in the production of flame retardant furnishing and mattress ticking. 

Ammonium polyphosphate is also used as the catalyst component in intumescent 

formulation. Aqueous solutions of ammonium polyphosphate can be used in the flame 

retardant treatment of cellulosic materials (http://www.albemarle.com/). 

The use of fire retardant systems involving antimony trioxide is restricted by the 

white pigmenting behaviour of ATO which means that it is unsuitable for applications 

where a transparent backing is required. 

Although median-chain chlorinated parafins have been identified as a potential 

alternative to HBCDD for textile coating, the EC (2005) reported that there was no 

use of medium-chain chlorinated paraffins in textiles in the EU at that time; however 

the report did identify that some of the medium-chain chlorinated paraffins supplied 

to the PVC industry was used for coating applications, including textiles. Long-chain 

chlorinated paraffins are used for backcoating textiles. A limitation on the use of 

MCCPs in this area may be that the maximum chlorine content achievable is lower 

than for SCCPs and LCCPs. 

In their review of the use of various hazardous substances in consumer products the 

Norwegian Pollution Control Authority concluded that there are other different 

brominated and non-brominated flame retardants that can be used in place of HBCDD 

for textile coatings (SFT, 2007). 

Economic feasibility 

 

3

 For example, even taking a conservative assumption that 1kg of compound contains 7% 

HBCDD and assuming a price increase per kg of compound from €2.1 to €2.3 per kg, this would imply 

a price increase of around €3 per kg of flame retardant, assuming use in equivalent quantities. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 80 of 108 

As indicated above, the costs of deca-BDE are expected to be comparable or slightly 

lower than that for HBCDD and the cost of chlorinated paraffins is expected to be 

lower than that for HBCDD. 

Again, there would be additional one-off costs of substitution associated with, for 

example, product testing and changes to processing equipment which cannot readily 

be quantified. 

ALTERNATIVES TO EPS AND XPS INSULATION 

3.2.2.4 Overview 

A wide range of insulation products are available. KEMI (2007) reported that there 

are different views have been given on the economic impact of introducing a 

restriction on the use of HBCDD in EPS and XPS. Producers of EPS/XPS, building 

industry and authorities in 33(40) countries with little use, e g Sweden and Denmark 

indicate little or no consequences, whereas in countries with a large use, e g Poland 

and Germany, respondents indicate potentially severe consequences, in particular on 

small and medium sized enterprises (SMEs). 

3.2.2.5 Phenolic Foam 

Phenolic foam insulation is commercially available in the EU but does not appear to 

have a significant share of the insulation market. The European EPS trade association 

(EUMEPS) claim to have a 35% share of the total construction insulation market in 

Europe (http://www.propubs.com/GI/Articles/eGI_Sep07_EPS.pdf) and it seems 

likely that the XPS market share will be of similar size. In addition, the Global 

Insulation trade association only consider EPS, XPS and mineral wool in their 

recent(2008) review of market trends, which suggests that the market share for 

phenolic foam is low 

(http://www.propubs.com/GI/Articles/eGI_May08_ExaneBNPParibas.pdf). The 

European Phenolic Foam Association (EPFA; http://www.epfa.org.uk/Pdfs/eng.pdf) 

claim that phenolic foam has exceptional fire performance with very low flame 

spread, negligible smoke emission and a very low level of toxic gas emissions and 

that it meets the fire certification requires of UK Class 0, Dutch NEN 6065/6055 

Class 1, German B1, Belgian A1, French M1 and Scandinavian NT 036 Class 1. It 

has an excellent strength/density ratio and offers a range of thermal conductivity 

performance and is up to 50% more thermally efficient than competing products. In 

terms of environmental performance, EBPF claim low embedded energy costs 

compared with other insulation materials, a potentially significant contribution to 

reducing carbon emissions and availability free of CFCs and HCFCs. 

The relatively small market share held by phenolic foam insulation may indicate that 

it is a relatively expensive product to use. Although no information about relative 

costs was identified in our searches, there is, a substantial market for these products in 

the US suggesting that it may be a economically feasible alternative for some 

applications. The US consumption of phenolic resins for insulation products in 2001 

was 106 thousand metric tonnes. This consumption was anticipated to increase to 115 

thousand metric tonnes in 2006. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 81 of 108 

Polyurethane and Polyisocyanurate Products 

Insulation products based on polyurethane and polyisocyanurate foams are 

commercially available but are less widely manufactured in the EU than EPS/XPS or 

mineral wool products 

(www.propubs.com/GI/Articles/eGI_May08_ExaneBNPParibas.pdf). They are used 

for a range of building insulation applications including cavity wall insulation, roof 

insulation (but not loft insulation) and in timber frame/stud walls. 

UBA (2000) provide a comparison of relative costs of material per area unit insulated 

to a specific insulation performance. If EPS = 1, mineral wool = 1.3, polyurethane = 

2.8 and XPS = 3 (raw material costs only). Therefore, the raw material cost of 

polyurethane may be expected to be slightly less than that for XPS but more than that 

for EPS. This includes only the materials costs and dose not take account of any 

required changes in construction techniques or supporting construction materials.

3.2.2.6 Mineral wools and other mineral products 

Fibre glass, rockwool and other mineral wools have a large share of the insulation 

market in Europe (>30%) and there would appear to be economically and technically 

viable alternatives to EPS and XPS for many applications. Differences in mass 

density and in resistance to water damage might influence technical feasibility in 

some applications. Based on the above comparison in UBA (2000), the raw material 

cost of mineral wools may be expected to be slightly more than that for EPS but less 

than that for XPS. 

3.2.2.7 Cellulose fibre 

Insulation products based on cellulose fibre are commercially available but not widely 

used. It is available in the UK for use in loft insulation, application to sloping 

ceilings/between rafters and in timber frame/stud walls/dry lining and suspended 

floors but not for cavity wall insulation, It is most effective where “breathable” 

insulation is required as it has the capacity to absorb and release moisture. It does 

however have a poor moisture resistance and will degrade in damp conditions. Given 

the high prevalence of building dampness, poor moisture is likely to limit the range of 

building insulation applications for cellulose fibre in much of European except in the 

most southerly member states. We have been unable to find information about the 

cost of cellulose fibre insulation relative to XPS/EPS. 

3.2.2.8 Intumescent systems 

We have been unable to find relevant information on technical and economic

feasibility. 

ALTERNATIVES TO HIPS 

3.2.2.9 Polyethylene with Magnesium Hydroxide 

KEMI (2006) indicate that polyethylene with magnesium hydroxide is a commercially 

available alternative to HIPS for the housing of electronic products and wiring parts 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 82 of 108 

but do not provide any information about its performance or cost relative to that of 

HIPS. 

In general, based for example on information from RPA (2002), it could be expected 

that use of polyethylene containing magnesium hydroxide would be less expensive in 

terms of raw material costs than HIPS containing HBCDD. However, there would be 

additional one-off costs of substitution associated with, for example, product testing 

and changes to processing equipment which cannot readily be quantified. 

3.3 Summary table 

For the major uses of HBCDD, namely in EPS/XPS there does not appear to be a fire 

retardant available that will provide equivalent performance. The main benefit of 

HBCDD is that it offers unique performance in polystyrene foams because it is 

effective at low levels (around 0.7% in EPS, 2.5% in XPS) (EC RAR, 2008). Higher 

quantities of non-halogen flame-retardants are required in order to get the same level 

of fire protection. This means that the qualities of the polymer (e.g. thermal 

insulation) are not as impaired using HBCDD as they would be with a flame retardant 

used in higher quantities. Higher production of non-halogen alternatives would lead to 

increase in manufacturing and transportation costs. In addition, the structural 

performance of EPS and XPS is impaired at higher fire retardant loadings. 

There are commercially available alternatives to EPS/XPS for use in building 

insulation that represent technically feasible substitutes in many, but not necessarily 

all applications. Mineral wools are already in wide use and have a share of at least 

30% in the European building insulation market indicating that they represent 

technically and economically viable alternatives to EPS/XPS in many applications. 

There may, however, be applications where the lower mass density or better moisture 

resistance of EPS/XPS are important. Phenolic foam is another commercially 

available product that meets relevant fire safety standards and has a low density, is 

moisture resistant and highly thermally efficient. It is primarily used in applications 

where moisture resistance or thickness are important and has only a small share of the 

European market for insulation. This may indicate that it is relatively expensive. 

These alternative insulation materials are not particularly hazardous for human health 

or environment, although the chemicals used in the manufacture of phenolic foam are 

hazardous to human health. There may also be significant differences between the 

various insulation products in terms of the net carbon savings that arise over the life 

cycle from manufacturing to disposal. 

There are commercially available alternative fire-retardants available to the use of 

HBCDD in HIPS and textile coatings, including non-halogenated flame retardants 

that provide the same level of fire protection and performance. The relatively small 

quantity of HBCDD used in these applications may reflect the availability of 

competing products that do not contain HBCDD, but are equally effective in use. 

Table 3.2 summarises the health, environment and feasibility information available 

for alternatives to HBCDD. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 83 of 108 

Table 3.2: Summary of alternatives to HBCDD Use Alternative Toxicity Ecotoxicity Cost Availability 

Antimony trioxide (ATO) Potential human 

carcinogen and reproductive toxicant 

Not readily biodegradable , low to moderate bioaccumulation potential 

Not directly comparable (synergist) 

Commercially available 

Decabromodiphenylether/ATO Neurotoxicant Not readily 

biodegradable , low to moderate bioaccumulation potential 

Comparable or slightly lower raw material price. Additional one-off costs. 

Commercially available 

Decabromodiphenylethane/ATO Limited data, but 

likely to be of low toxicity 

Not readily biodegradable, may be persistent 

Comparable raw material price. Additional one-off costs. 

Commercially available 

Ethylenebis(tetrabromo phthalimide)/ATO 

Low toxicity Not 

biodegradable and is persistent. Non-toxic. 

Comparable raw material price. Additional one-off costs. 

Commercially available 

Fire retardants in HIPS 

Triphenyl phosphate Chronic toxicant 

with effects on liver 

Readily biodegradable, toxic to aquatic organisms 

Likely higher raw material cost Additional one-off costs. 

Commercially available 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 84 of 108 

Use Alternative Toxicity Ecotoxicity Cost Availability 

Resorcinol bis (biphenyl phosphate) 

Chronic toxicant with effects on liver 

Inherently biodegradable, may be persistent and bioaccumulative 

Likely higher raw material cost Additional one-off costs. 

Not currently in widespread use as a flame retardant 

Bis phenol A bis (biphenyl phosphate) 

Limited data, likely to be of low toxicity 

Poorly biodegradable. Non-toxic and is not bioaccumulative 

Likely higher raw material cost Additional one-off costs. 

Commercially available 

Diphenyl cresyl phosphate Chronic toxicant 

with effects on liver, kidney and blood. Effects on fertility 

Readily biodegradable 

Likely higher raw material cost Additional one-off costs. 

Commercially available 

Alternatives to HIPS 

Polyethylene with Magnesium Hydroxide 

Insufficient data but likely to be of low toxicity 

Polystyrene particles are an issue in aquatic environments 

Likely lower raw material cost. Additional one-off costs. 

Commercially available 

Textiles decabromodiphenylether Neurotoxicant Not readily 

biodegradable , low to moderate bioaccumulation potential 

Comparable or slightly lower raw material price. Additional one-off costs. 

Commercially available 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 85 of 108 

Use Alternative Toxicity Ecotoxicity Cost Availability 

chlorinated paraffins Reproductive 

toxicant, chronic toxicity with effects of liver and kidneys, potential carcinogen 

LCCPs are considered to potentially meet the persistent or very persistent criterion. They do not meet the toxic or bioaccumulative criterion. 

Likely lower raw material cost. Additional one-off costs. 

Commercially available 

ammonium polyphosphates Low toxicity Not an 

ecotoxicant 

Likely higher raw material cost Additional one-off costs. 

ammonium polyphosphates 

EPS/XPS Phenolic Foam Low toxicity in use 

but manufactured from materials toxic and carcinogenic 

 Expensive? Commercially 

available, but only a small share of insulation market 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 86 of 108 

Use Alternative Toxicity Ecotoxicity Cost Availability 

Polyurethane and polyisocyanurate products 

May emit toxic fumes if burnt, otherwise low toxicity in use, but manufacture involves the use of isocyanates – potent respiratory sensitisers 

 Material cost 

likely less than XPS; more than EPS 

Commercially available, but less widely manufactured in EU than EPS/XPS 

Mineral wools Dust inhalation 

hazard during installation and removal; negligible emissions during use 

Minimal Material cost 

likely less than XPS; more than EPS 

Commercially available with substantial share of insulation market 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 87 of 108 

Use Alternative Toxicity Ecotoxicity Cost Availability 

Cellulose fibre Exposure to low 

toxicity dust during installation and removal ; potential exposure to flame retardants and pesticides; inorganic boron salts are widely used and are potential reproductive and developmental toxins 

Potential release of flame retardants and pesticides; boron is a widely used additive to cellulose fibre insulation and is believed to have a low aquatic toxicity and is naturally present in the environment 

More expensive than traditional insulation methods 

Commercially available but not widely used 

Intumescent systems Inadequate data Inadequate data Inadequate 

data 

Inadequate data 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 88 of 108 

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Disclaimers 

Third Party Disclaimer 

Any disclosure of this report to a third party is subject to this disclaimer. The report 

was prepared at the instruction of, and for use by, our client named on the front of the 

report. It does not in any way constitute advice to any third party who is able to 

access it by any means. Entec excludes to the fullest extent lawfully permitted all 

liability whatsoever for any loss or damage howsoever arising from reliance on the 

contents of this report. We do not however exclude our liability (if any) for personal 

injury or death resulting from our negligence, for fraud or any other matter in relation 

to which we cannot legally exclude liability. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 95 of 108 

Annex 1: List(s) of information requirements for pand specification of conditions for authorisation The formats provided in this Annex serve as examples of possible templates that may be used by the contracinformation. Other formats (containing the requested data and information) are acceptable after consultation w. Table 1: Overview on tasks related to work package 1 (grey shaded fields not relevant) 

Manufacture, trade and 

formation 

Process 

(narrative 

description)

Locations 

(number of M sites; 

spatial distribution) 2

Tonnage manufactured, imported, 

exported or formed 

Releases to 

environ

Manufacture EU Process A Batch-process: 

Elementary 

bromine added to 

cyclododecatriene 

in solvent.

1; Netherlands t/y 

6000 

Production woInhalable HBC

1.2 m

Dermal exposu

170 m

Dermal exposu

17 m

Process runs inexposure occurtime. 

Manufacture EU Process B Micronising small number, 

Belgium, unknown 

1000 Inhalable HBC

23 m

Dermal exposu

840 m

Process runs inexposure occurtime. 

Total Manufacture ∑ EU manufacture Uncertainty o
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 96 of 108 

(t/y ; uncertainty; trend, incl. shifts 

between manufacturing processes) 

t/y varies between years; trend: Likely 

to have increased between 2005 and 

2007 in response to 10% increase in 

sales in the EU over this period, may 

reduce in future between of growing 

consumer awareness of the 

environmental issues associated with 

brominated fire retardants plus 

economic recession 

Mean inhalati

levels, quite ti

process worke

control pro

micronising pl

opera

EASE model 

exposure is n

Import subst. on its own 5580t/yImport subst. in preparations unknown Import subst. in articles 2 unknown Import into EU (total) ∑ t/y Unknown: trends: Increasing use 

between 2003 and 2007

Export subst. on its own 1882t/yExport subst. in preparations unknown Export subst. in articles 1 unknown Export from EU (total) ∑ t/y Unknown; uncertainty: 

Unknown; trends: Unknown

Global manufacture ∑ t/y: Unknown; uncertainty: 

Unknown; trends: Unknown

Unintentional formation during incineration (EU)

0 0 

Unintentional formation in processes (EU) 

0 0 

Unintentional formation by transformation/degradation (EU)

0 0 

Total unintentional formation (EU) 

∑ t/y 0; uncer

trends

1 A list of article types in which the substance is included shall be provided in addition. 2 In quantitative or geographical terms exact specifications are only required if the number of sites is low. If there are many sites a semi-quantitative or qual

spatial distribution of manufacturing sites (e.g. in which Member States, regions, etc.) may suffice. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 97 of 108 

3 In case a quantification of releases is not possible a qualitative description of the emission situation at the workplace(s) shall be given and a semi-quantitativ

exposure – very high exp.). 

(a) – air; (ww) – waste water 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 98 of 108 

Table 2: Overview on tasks related to work package 2 (grey shaded fields not relevant) 

Uses Use Process 

(description: narrative and 

by use descriptor system)

Amount used

(t/y)

Number of 

sites of use 1 

(#)

Spatial distribution of 

emission sites 1

Releases t

enviro

(t

Formulation Formulation 1 Production of Expanded 

Polystyrene (EPS); 

PROC4 Use in batch 

and other process 

(synthesis) where 

opportunity for 

exposure arises, 

Industrial setting

5301 21 I in Austria 

2 in Belgium 

2 in Czech Republic 

1 in Finland 

1 in France 

4 in Germany 

1 in Greece 

I in Hungary 

1 in Italy 

4 in Netherlands 

1 in Poland 

2 in Spain 

Process workeInhalable HBC

1.2 

Dermal expos

17 m

Dermal expos

1.7 

Shift pattern nDuring weighInhalable HBC

7.2m

Dermal expos

17 m

Dermal expos

1.7 

15 days per ye

Formulation 2 Production of (XPS)

PROC4 Use in batch 

and other process 

(synthesis) where 

opportunity for 

exposure arises, 

Industrial setting

5859 28 1 in Austria 

1 in Belgium 

3 in France 

6 in Germany 

1 in Greece 

1 in Hungary 

5 in Italy 

1 in Netherlands 

1 in Portugal 

1 in Serbia 

Process workeInhalable HBC

0.03 

Dermal expos

17 m

Dermal expos

1.7 

Shift rotation exposure on 3less. 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 99 of 108 

4 in Spain 

1 in Sweden 

2 in UK 

Formulation 3 Production of HIPS

PROC4 Use in batch 

and other process 

(synthesis) where 

opportunity for 

exposure arises, 

Industrial setting

210 3 unknown Process worke

Inhalable HBC

1.2 

Dermal expos

17 m

Dermal expos1.7 mg/day Small scale, eto be occasion

Formulation 4 Textile Coating 

production 

PROC4 Use in batch 

and other process 

(synthesis) where 

opportunity for 

exposure arises, 

Industrial setting

210 (2007 

estimate) 

16 7 in UK 

5 in Belgium 

4 in Germany

Process workeInhalable HBC

1.35 

Dermal expos

120 

Many other foused, exposur<25% of shiftLaboratory staInhalable HBC

0.23 

Dermal expos

unk

Many other fohandled, expooccur on <25% 

∑ Formulation ∑ t/y: 11580; 

uncertainty: 

2006 figures 

except textile 

coating; trends: 

sales increased 

every year bar 

∑#: 47, trend: 

unknown 

Overall geographical 

pattern; trend: 

widespread across Europe; 

increased used in recent 

years, pressure to reduce in 

Nordic countries 

Uncertainty 

Mean inhala

levels, quite t

process 

EASE mode

exposure 

accu
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 100 of 108 

2006 between 

2002 and 2007, 

may be a 

decline in 

Nordic 

countries, 

economic 

uncertainty 

affecting 

construction 

and use of 

insulation

End uses End Use 1 Application of coating to 

textile 

PROC10: Roller 

application or brushing 

of adhesive and other 

coating Industrial or 

non-industrial setting

210 (2007 

estimate) 

24 15 in Belgium 

9 in UK 

Process workeInhalable HBC

1.35 

Dermal expos

120 

Many other foused, exposur<25% of shiftLaboratory staInhalable HBC

0.23 

Dermal expos

unk

Many other fohandled, expooccur on <25% 

End Use 2 Production of EPS articles 

PROC4 Use in batch 

and other process 

(synthesis) where 

opportunity for 

exposure arises, 

5301 28 across Europe Process worke

Inhalable HBC

1.2 

Dermal expos

17 m

Dermal expos
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 101 of 108 

Industrial setting 1.7 

Shift pattern n

End use 3 Production of HIPS 

articles PROC4 Use in 

batch and other process 

(synthesis) where 

opportunity for 

exposure arises, 

Industrial setting

210 unknown unknown Process worke

Inhalable HBC

1.2 

Dermal expos

17 m

Dermal expos

1.7 

Small scale, eto be occasion

End use 4 Production of XPS article

PROC4 Use in batch 

and other process 

(synthesis) where 

opportunity for 

exposure arises, 

Industrial setting s 

5859 21 unknown Process worke

Inhalable HBC

0.08 

Dermal expos

17 m

Dermal expos

1.7 

Shift rotation exposure on 3less. 

End Use 5 Use of Insulation Boards 

in construction (XPS + 

EPS) PROC21: Low 

energy manipulation of 

substances bound in 

materials and/or articles 

PROC23: High 

(mechanical) energy 

work-up of substances 

bound in materials 

and/or articles

Already 

included above 

1000s across Europe Inhalable HBC

<0.1 

Dermal Expos

<1.7

Exposure patt

∑ End Uses ∑ t/y11580; 

uncertainty: 

∑# 1000s, 

trend not 

Overall geographical pattern 

across Europe; trend: trend 

Uncertainty 

Mean inhala
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 102 of 108 

2007 estimate 

for textile 

coating, 2006 

figures for 

other uses, 

excludes 

imports of 

insulation 

boards; sales of 

HBCDD for 

EPS and XPS 

increased 

between 2002 

and 2006, 

Helcon 

countries 

discouraging 

use

known increased use over recent 

years; Pressure to reduce 

use in the Helcon countries 

levels, quite t

process worke

exposure to 

construction 

dust concentr

from the boar

10 mgm

EASE mode

exposure is 

Consumer use Substance in articles 2(service life of articles)

C12.1: Constructional articles and building material for indoor use: wall construction material ceramic, metal, plastic and wood construction material, insulating material C12.2: Constructional articles and building 

not appropriate textiles used mainly in UK 

and Ireland 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 103 of 108 

material for outdoor use: wall construction material, road surface material, ceramic, metal, plastic and wood construction material, insulating materialAC5: Fabrics, textiles and apparel: bedding and clothing; curtains, upholstery, carpeting/ flooring, rugs AC3: Electrical and electronic products, e.g. computers, office equipment, video and audio recording, communication equipment; Household appliances 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 104 of 108 

(white ware) 

Substance in preparations ∑ consumer use of subst. in articles and preparations 

∑ t/y not 

meaningful as 

most uses of 

HBCDD have a 

lifetime of 10 

or more years; 

uncertainty: 

huge; trends: 

amount of 

HBCDD in 

consumers’ 

premises 

increases every 

year as 

insulation is 

installed 

furniture 

replaced etc 

1 In quantitative or geographical terms exact specifications are only required if the number of sites is low. If there are many sites a semi-quantitative or q

distribution of sites of release (e.g. in which Member States, regions, etc.) may suffice. 

2 A list of article types with the substance included and used by consumers shall be provided as well.

3 In case a quantification of releases is not possible a qualitative description of the emission situation at the workplace(s) shall be given and a semi-quantitativ

exposure – very high exp.). 

(a) – air; (ww) – waste water; (sw) – surface water 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 105 of 108 

Table 3: Overview of quantitative information requested at Member State level for individual years. Prod

states is not available 

YEAR 2000-2004 Manufacturing 

(t/y)

Manufacturing 

# sites 

Formulation 

(t/y)

Formulation 

# sites 

Use 1 

(t/y)

Member state Austria Belgium ... Total 6000 1 6382 >50 1050 

YEAR 2000-2004 Use 3 

(t/y)

Use 3 

# sites 

Use 4 

(t/y)

Use 4 

# sites 

Use 5 

(t/y)

Member state Austria Belgium ... Total 210 unknown 4962 35 ~7500 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 106 of 108 

YEAR 2006 Manufacturing 

(t/y)

Manufacturing 

# sites 

Formulation 

(t/y)

Formulation 

# sites 

Use 1 

(t/y)

Member state 

Austria 2 

Belgium 3 

Czech Republic 2 

Finland 1 

France 4 

Germany 10 

Greece 2 

Hungary 2 

Italy 6 

Netherlands 6000 1 5 

Norway 1 

Poland 1 

Portugal 1 

Spain 6 

Sweden 1 

United Kingdom 2 

Total 6000 1 11580 49 210 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 107 of 108 

YEAR 2006 Use 3 

(t/y)

Use 3 

# sites 

Use 4 

(t/y)

Use 4 

# sites 

Use 5 

(t/y)

Member state 

Austria 1 

Belgium 1 

Czech Republic 

Finland 

France 3 

Germany 6 

Greece 1 

Hungary 1 

Italy 5 

Netherlands 1 

Norway 1 

Poland 

Portugal 1 

Spain 4 

Sweden 1 

United Kingdom 2 

Total 210 unknown 5859 28 11000 
ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc Page 108 of 108 

ANNEX 2: