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 NAFRA 2

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 Products
3 3 NAFRA 3

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

AGENDA
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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 Development
5 5 NAFRA 5

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 NAFRA 6

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 CO2 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 NAFRA 7

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 NAFRA 8

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 Underlayment
9 9 NAFRA 9

Green Roof Assembly

Vegetated (Green) Roofs

 Provide increased insulative value & 

heat absorption.

 16.1% growth in green roofs in 2009.

City of Chicago City Hall
10 10 NAFRA 10

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 Perspective
12 12 NAFRA 12

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 Retailers
14 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.
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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.
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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 NAFRA 17

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 NAFRA 18

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.
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HBCD GLOBAL 

REGULATORY ACTIONS

 Canada

 European Union

• REACH

 International

• UN-ECE

• UNEP
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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).
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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.
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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.
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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
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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.
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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.
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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 Process
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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 NAFRA 28

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 Process
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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 Agencies
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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. 
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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 Bureau
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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