1 North American Flame Retardant Alliance



### January 6, 2011 Washington, DC 

# HBCD Use in Polystyrene Foam Insulation **Presentation to U.S. Environmental Protection Agency**2 2 2 NAFRA 

# Polystyrene Foam Industry Participants  EPS Molders Association (EPSMA) – Betsy Steiner, Executive Director

– Andrew Bayley, BASF Corporation

– Ted Grant, Atlas EPS

– Eugene Zimmermann, Zimmermann Management Solutions

– Walter Reiter, EPS Molders Association 

###  XPS Polystyrene Foam Association (XPSA) – Allen Weidman, Executive Director  American Chemistry Council (ACC) North American Flame Retardant Alliance – Jackson Morrill, Director

– Barbara Little, Albemarle Corporation

– Robert Campbell, Great Lakes Solutions, Chemtura Corporation

– Joel Tenney, ICL Industrial Products33 3 NAFRA 

### I. Self - Introductions & Meeting Objectives II. Polystyrene Foam Product Overview a. Uses & Applications b. Unique Features & Benefits 

### III. HBCD Use & Function a. Fire Safety & Building Code Requirements b. EPS & XPS Foam Manufacturing Streams 

### IV. Regulatory Review Process a. Industry Business Impact in U.S. Economy b. EU & Canada Regulatory Status 

### V. Alternative Flame Retardant Status Report VI. Follow Up & Action Items 

# AGENDA4 4 4 NAFRA 

# FOAMED PLASTIC INSULATION ENVIRONMENTAL & SOCIETAL VALUE
 Major Role in the Fight Against Climate Change • Advances Energy Efficiency Policy Goals • Reduces GHG Emissions • Energy Savings 

###  Addresses Unique Building Challenges  Contributes to Localized Economic Development5 5 5 NAFRA 

# U.S. Policy Drivers For Energy Efficiency

 Save America Energy Act (H.R. 889)  EPA Energy Star ― Air, Seal & Insulate Partnerships (21% held by polystyrene foam manufacturers

### ) 

##  Department of Energy • Energy Efficiency & Renewable Energy (EERE) • Federal Energy Management Program (FEMP) 

##  Energy & Environmental Building Alliance (EEBA)  Sustainable Buildings Industry Council (SBIC)  Responsible Energy Code Alliance (RECA)6 6 6 NAFRA 

# Energy & CO2 

# Savings Potential

 Plastic insulation boards save more than 14,500 MJ per kg insulation material or 150 times more energy than was needed for production.  Total net- savings of greenhouse gas emissions by use of added insulation for use on external walls are approximately 290 Mill tons of CO 2 

### equivalents in their lifetime.  Increased use of foam insulation materials will make a significant contribution to sustainable resource management in North America and should therefore be supported.7 7 7 NAFRA 

## Key Polystyrene Foam Insulation Features

 High Compressive Strength / Load Bearing  Light-weight  Speeds Construction Time  Resists Mold & Mildew  Durable  Cost- Effective  Consistent, Long -Term R -Value  Moisture Resistant  Fire Resistant Properties Dependent on Use of Flame Retardant **HBCD enables polystyrene foam to achieve key performance properties while minimizing risk factors related to fire hazards in**  **building applications.**8 8 8 NAFRA 

# Essential PS Foam Insulation Applications **Not Easily Substituted by Alternative Insulation Materials** 

###  Green Roof Applications & Other High Moisture Environments  Frost - Protected Shallow Foundations  Radiant Floor Heating Systems  Ultra Energy Efficient Building Systems:  Structural Insulation Panels (SIPs)  Insulating Concrete Forms (ICFs)  Exterior Insulating Finishing Systems (EIFS) 

###  Civil Engineering Applications  Geofoam – FHWA Technology Transfer Program  Highway Insulation Underlayment9 9 9 NAFRA 

# Green Roof Assembly

Vegetated (Green) Roofs  Provide increased insulative value & heat absorption.  16.1% growth in green roofs in 2009. City of Chicago City Hall10 10 10 NAFRA 

# Polystyrene Foam Sheathing  Excellent Solution for DeepEnergy Retro- Fit.  Some sheathing applications eligible for Weatherization Assistance Program & National Energy Analysis Tool (NEAT).

• Rigid foam supports exterior finishing materials. • Provides significant R -value upgrade. 75% of existing homes will remain in use beyond 2050. Rigid foam insulation is a non-intrusive & cost-effective solution.11 11 11 Polystyrene foam insulation product modeling used within RESNET Protocol for Home Energy Ratings: ...this core material is polystyrene, generally considered to be one of the foam plastics with lower overall environmental impact... Appendix 4: #19, Structural Insulated Panels, pg. 42 

# State of Oregon ― Life Cycle Perspective12 12 12 NAFRA 

# Polystyrene Industry Sectors

 Extruded polystyrene foam insulation (XPS)  Expanded polystyrene foam insulation (EPS) **The brominated flame retardant most commonly used is Hexabromocyclododecane (HBCD)** 

**at a typical loading of 0.5 -**  **1% by weight.** 13 13 13 Raw Material Feedstock Resin Manufacturing Foam Manufacturing (XPS & EPS Molding ) Pre - Manufacturing Molding/Extrusion Equipment Hotwire Cutting Equipment Tooling Additives (HBCD & Other)
Polystyrene Foam Insulation Markets • Building Insulation • Geotechnical Civil Engineering • Structural Insulated Panels • Exterior Insulating Finishing Systems • Insulating Concrete Forms • Green Roofing 

## PS Foam Insulation Manufacture & Distribution

Primary Distribution Points
• Building Material Suppliers • Building Developers • Contractors & Installers • DIY Retailers14 14 14 

# XPS Foam Manufacturing Process  PS resin and other solids (including HBCD) are melted and mixed in an extruder.  Blowing agents are added at high pressure.  The resultant mix is foamed and cooled into continuous sheets (boards) of closed -cell insulation.  The boards are cut to size.15 15 15 NAFRA 

# EPS Foam Manufacturing Process  EPS is made from a PS resin that is produced by suspension polymerization. HBCD and the blowing agent, pentane, are introduced into the suspension process.  At the point of manufacture, the expandable polystyrene resin is pre-expanded with steam to reach the desired density.  Pre-expanded beads are aged and conveyed to closed mold.  Aged beads are steam -expanded in a mold to produce a large block of foam insulation.  Insulation boards are cut from the block in desired thicknesses.16 16 16 NAFRA 

# HBCD Uniquely Suited To PS Foams

 It provides a high degree of flame retardancy when used at low concentrations.  It is compatible with suspension polymerization of EPS and high temperatures of XPS extrusion.  It has an extremely low water solubility to preserve the materials’ fire safety for decades even after extended water contact.  No commercially or technically-viable flame retardant alternative that would be suitable for the vast majority of producers, currently exists.17 17 17 NAFRA 

# HBCD Ensures Fire Safety Compliance  The 2009 International Building Codes allow the use of foamed plastics in non - combustible construction (commercial) when the flame spread is <500.  ASTM C578, the material standard governing PS thermal insulation, requires an oxygen index >24%.  Underwriters Laboratory provides a listing and follow- up service that confirms flame spread ratings.  Factory Mutual insures commercial buildings for products able to meet specified flame spread performance standards. **In all cases, a brominated fire retardant is necessary for PS foam insulation use to ensure fire safety for building**  **occupants.**18 18 18 NAFRA 

# HBCD Stability in PS Foam  High molecular weight and low water solubility.  HBCD is fixed in the polymer matrix of the polystyrene foam.  HBCD provides long term flame retardancy over the life of the insulation product.  PS foam in building and construction applications are contained within building structure.19 19 19 NAFRA 

# HBCD GLOBAL REGULATORY ACTIONS
 Canada  European Union • REACH 

###  International • UN - ECE • UNEP20 20 20 NAFRA 

# Status: Environment Canada  Risk Assessment • Preliminary Conclusions (Draft) Released 8/28/10 • Health Canada and Environment Canada’s latest assessment stated “ **the margins between estimated exposures to HBCD and critical effect levels are considered adequately**  **protective of human health”**. • Comment Period Closed and under consideration • Final Assessment yet to be issued by Environment Canada 

###  Risk Management Scoping • Intent to Regulate Released 8/28/10 • Official Risk Management Draft to be Published Following Comment Period (closed 10/28/10).21 21 21 NAFRA 

# EU HBCD Risk Assessment  HBCD was being evaluated under a 793/93/EC risk assessment.  For consumers & most workers no new risk management measures were needed.  For workers with high exposure risk, they can be handled via improved industrial practices.  Environment issues – not human health concerns – led to HBCD designation as having PBT properties.  EU Risk Assessment finalized but not published in official EU journal before June 2008 deadline and therefore moved under REACH.22 22 22 NAFRA 

# HBCD Status Under REACH  Included in the candidate list for authorization.  Due to importance of its role in lowering EU energy consumption, authorization for XPS and EPS foams is being sought. • Socio-economic factors • Lack of commercially available alternatives • Need for orderly transition once alternatives are identified 

###  Product stewardship program active to limit emissions.  Time frame to be determined.23 23 23 NAFRA 

# International • UNECE LRTAP POP

– Track A Assessment - Completed & Adopted at EB Meeting December 2009 .

– Track B Management - Completed & Adopted at EB Meeting December 2010 .

– Protocol Amendment - EB Meeting December 2012 (est.) 

### • UNEP Stockholm POP

– Risk Profile - Approved POPRC 6 Meeting October 2010

– Risk Profile Adoption - COP 5 Meeting May 2011

– Risk Management Evaluation - Approved POPRC 7 or 8 October 2011 or 2012 (est.)

– Amendment of the Convention COP 7 Meeting May 2013 (est.) **Management strategies for both are anticipated to include time** **- limited exemptions for use of HBCD in insulation foam** 24 24 24 NAFRA 

# VIABLE FR ALTERNATIVES DO NOT CURRENTLY EXIST  Attempts to Identify Potential Replacement Candidates Underway.  Collaborative, Multi -Tiered Industry Process. • Develop/identify new flame retardant • Resin & Foam Production Integration  Industry manufacturers will need sufficient time to safely transition into a new flame retardant.25 25 25 NAFRA 

# Attempts to Identify HBCD Alternatives  EU regulatory review of potential HBCD toxicity prompted industry investigation of alternative flame retardants.  EU industry has identified two potential alternatives currently at preliminary stages of evaluation for suitability.26 26 26 NAFRA 

# Progress-to- Date Alternative in PS Foams EPS Issues Suspension Stability Bead Size Distribution Product Properties Fire Performance

Foam Cell Size
XPS Issues Extrusion Heat Stability Product Properties Fire Performance

Foam Cell Size Program Set Up • Common tests at

various companies
• Defined guidelines

respecting competition rules Commercial Substances Screening on lab scale of commercially available options **30 -**  **40 tested**  Novel Substances Small scale samples tested on lab scale as and when available from suppliers Short- Listed Options Larger scale samples tested on pilot scale Further optimisation at individual companies

Flame Retardant Alternative Identification Process27 27 27 NAFRA 

# Considerations for Alternative FR Candidates

 Technical Feasibility – alternative must provide high thermal stability, water insolubility and stability in PS product manufacture.  Health, Safety & Environmental Profile – alternative must be a safer and more environmentally benign material.  Fire Safety Performance & Verification – must perform as well or better than HBCD in flammability, flame spread and smoke development ratings.  Commercial Viability – must be readily available and minimize expense of retooling current U.S. manufacturing.28 28 28 NAFRA 

## Polystyrene Manufacturing Transitioning Milestones

Resin Product Development: Lab **⇒** Pilot scale

- Polymer formulation

- EPS product coatings/lubricants

- Optimized FR, resin, processing performance EPS Foam Application Trials

- Application validation – small scale field trials

- Molder & foam customer validation – larger scale trials Manufacturing Validation Trials

- Large scale resin plant trial followed by extended field trials Fire Performance Approvals

- EPS resin – multiple grades & densities

- EPS foam applications (mfg specific) Polystyrene Foam Manufacturing Adoption & Integration Process29 29 29 NAFRA 

# Potential Transition Scenario  Identify Candidate Alternatives • Product & Process Development. • FR Manufacturers Offer Technically Viable Alternative, Including Toxicity Testing. • FR Requires Time To Bring It To Commercial Availability Phase. 

###  Pilot Manufacturing Line for Trials  Start –Up/Product Qualification  Code Compliance with Listing Agencies30 30 30 NAFRA 

# Socio- Economic Considerations

 Impact throughout polystyrene foam insulation production & supply chain.  Impact on the construction industry.  US energy efficiency targets not met.  Industry remains committed to using good housekeeping practices to ensure continued, responsible use of HBCD in PS foam until appropriate alternatives can be identified and commercialized.31 31 31 NAFRA 

# U.S. Polystyrene Foam Industry  U.S. Polystyrene Foam Industry Is A Significant And Widespread Economic Contributor.  Polystyrene Foam Product Manufacturing Generates ~$1.3 Billion In Annual Sales For Building & Construction Applications.  Industry Supports Approximately 30,000 Jobs In Over 500 Facilities In 34 States. Reference : “Polystyrene Foam Product Manufacturing: 2007”, Economic Census, Manufacturing Industry Series, U.S. Census Bureau32 32 32 NAFRA 

# THANK YOU **The polystyrene foam industry appreciates the opportunity to work productively with the U.S. EPA and welcomes an**  **ongoing dialogue to promote beneficial solutions.** EPS Molders Association Betsy Steiner, Executive Director 1298 Cronson Blvd., Suite 201 Crofton, MD 21114 (410) 451-8340 emsteiner@epscentral.org www.epsmolders.org North American Flame Retardant Alliance American Chemistry Council Jackson Morrill, Director 700 Second Street NE Washington, DC 20002 (202) 249-6712 jackson_morrill@americanchemistry.com www.americanchemistry.com