Draft technical guidelines for the environmentally sound
management of wastes consisting of, containing or
contaminated with hexabromocyclododecane
(Draft of 26 November 2014)
Contents
Abbreviations, acronyms and units of concentration ...................................................................................... 3
I.
Introduction ............................................................................................................................................. 5
A.
B.
II.
Relevant provisions of the Basel and Stockholm conventions ........................................................... 12
A.
B.
III.
Basel Convention ......................................................................................................................... 12
Stockholm Convention ................................................................................................................. 14
Issues under the Stockholm Convention to be addressed cooperatively with the Basel
Convention ............................................................................................................................................. 14
A.
B.
C.
IV.
Scope .............................................................................................................................................. 5
Description, production, use and wastes ........................................................................................ 5
1. Description ............................................................................................................................. 5
2. Production .............................................................................................................................. 6
3. Use ......................................................................................................................................... 6
4. Wastes .................................................................................................................................... 7
Low POP content ......................................................................................................................... 14
Levels of destruction and irreversible transformation .................................................................. 14
Methods that constitute environmentally sound disposal ............................................................. 14
Guidance on environmentally sound management (ESM) ................................................................ 14
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
General considerations ................................................................................................................. 14
Legislative and regulatory framework .......................................................................................... 14
Waste prevention and minimization ............................................................................................. 15
Identification of wastes ................................................................................................................ 16
1. Identification ........................................................................................................................ 16
2. Inventories ........................................................................................................................... 17
Sampling, analysis and monitoring .............................................................................................. 18
1. Sampling .............................................................................................................................. 18
2. Analysis ............................................................................................................................... 19
3. Monitoring ........................................................................................................................... 19
Handling, collection, packaging, labelling, transportation and storage ........................................ 19
1. Handling .............................................................................................................................. 19
2. Collection ............................................................................................................................. 20
3. Packaging ............................................................................................................................. 20
4. Labelling .............................................................................................................................. 20
5. Transportation ...................................................................................................................... 20
6. Storage ................................................................................................................................. 20
Environmentally sound disposal .................................................................................................. 21
1. Pre-treatment........................................................................................................................ 21
2. Destruction and irreversible transformation methods .......................................................... 21
3. Other disposal methods when neither destruction nor irreversible transformation is the
environmentally preferable option ............................................................................................... 21
4. Other disposal methods when the POP content is low ......................................................... 21
Remediation of contaminated ....................................................................................................... 21
Health and safety .......................................................................................................................... 21
1. Higher-risk situations ........................................................................................................... 21
2. Low-risk situations .............................................................................................................. 21
Emergency response ..................................................................................................................... 22
Public participation ...................................................................................................................... 22
Annex: Bibliography......................................................................................................................................... 23
2
Abbreviations and acronyms
BAT
best available techniques
BEP
best environmental practices
CAS
Chemical Abstracts service
DE
destruction efficiency
DRE
destruction removal efficiency
EPS
Expanded Polystyrene
ESM
environmentally sound management
ETICS
external insulated composite systems
EU
European Union
FR
Flame retardant
GC/MS
gas chromatograph/mass spectrometer
HBCD
hexabromocyclododecane
HIPS
high-impact polystyrene
IEC
MSWI
International Electrotechnical Commission
OECD
Organisation for Economic Co-operation and Development
PBDD
polybrominated dibenzo-p-dioxin
PBDEs
polybrominated diphenyl ethers, which are included in the Stockholm
Convention (tetra-, penta-, hexa- and hepta-BDE)
PBDF
polybrominated dibenzofuran
PBT
polybutylene terephthalate
PCB
polychlorinated biphenyl
PCDD
polychlorinated dibenzo-p-dioxin
PCDF
polychlorinated dibenzo-furan
PCT
polychlorinated terphenyl
POP
persistent organic pollutant
PP
polyamide polymers
PUR
polyurethane
SCWO
super-critical water oxidation
TEQ
toxic equivalent
UNEP
United Nations Environment Programme
WEEE
waste electrical and electronic equipment
XPS
Extruded Polystyrene
XRF
X-ray fluorescence
Municipal Solid Waste Incineration
Units of concentration
mg/kg
μg/kg
ng/kg
Mg
kg
milligram(s) per kilogram. Corresponds to parts
per million (ppm) by mass
microgram(s) per kilogram. Corresponds to
parts per billion (ppb) by mass
nanogram(s) per kilogram. Corresponds to parts
per trillion (ppt) by mass
megagram (1,000 kg or 1 tonne)
kilogram
3
mg
ng
Nm3
million
billion
trillion
ppm
ppb
ppt
4
milligram
nanogram
normal cubic metre; refers to dry gas, 101.3 kPa
and 273.15 K
106
109
1012
parts per million
parts per billion
parts per trillion
I.
Introduction
A.
Scope
1.
The present guidelines provide guidance for the environmentally sound management (ESM)
of wastes consisting of, containing or contaminated with hexabromocyclododecane (HBCD),
pursuant to several multilateral environmental decisions.1
2.
HBCD was listed in Annex A to the Stockholm Convention in 2013 and the amendment
entered in force in 2014.2
3.
The present document should be used in conjunction with the document entitled “General
technical guidelines for the environmentally sound management of wastes consisting of, containing
or contaminated with persistent organic pollutants (POPs)” (hereafter referred as “the general
technical guidelines”) (UNEP, [2015]).The general technical guidelines is intended to serve as an
“umbrella” guide for the management of wastes consisting of, containing or contaminated with
POPs. It provides more detailed information on the nature and occurrence of wastes consisting of,
containing or contaminated with POPs for purposes of their identification and management.
4.
In addition, regarding the use of HBCD in waste electrical and electronic equipment
(WEEE), the technical guidelines for the environmentally sound management of wastes consisting
of, containing or contaminated with hexabromodiphenyl ether and heptabromodiphenyl ether, and
tetrabromodiphenyl ether and pentabromodiphenyl ether (POP-BDEs) (UNEP, [2015]) are relevant.
B.
Description, production, use and wastes
1.
Description
5.
HBCD is used as a flame retardant additive to delay polymer ignition and slowing subsequent
fire growth during the service life of buildings, articles or vehicles, as well as during storage of
materials.
6.
HBCD is defined as hexabromocyclododecane (CAS No: 25637-99-4), 1,2,5,6,9,10hexabromocyclododecane (CAS No: 3194-55-6) and its main diastereoisomers: alphahexabromocyclododecane (CAS No: 134237-50-6); beta-hexabromocyclododecane (CAS No:
134237-51-7); and gamma-hexabromocyclododecane (CAS No: 134237-52-8).
7.
HBCD is a cyclo-aliphatic brominated hydrocarbon produced by the bromination of
cyclododecatriene. The structural formula of HBCD is a cyclic ring structure with Br-atoms attached
(see figure 1). The molecular formula of the compound is C12H18Br6 and its molecular weight is 641
g/mol. 1,2,5,6,9,10-HBCD has six stereogenic centers and, in theory, 16 stereoisomers could be
formed (Heeb et al. 2005). Each of these stereoisomers has its own specific CAS number i.e. αHBCD, CAS No: 134237-50-6; β-HBCD, CAS No: 134237-51-7; γ-HBCD, CAS No: 134237-52-8.
However, in commercial HBCD only three of the stereoisomers are commonly found, alpha (α-),
beta (β-) and gamma (γ-) HBCD.
Figure 1: The structural formula of HBCD
1
Decision BC-11/3 of the Conference of the Parties to the Basel Convention on the Control of Transboundary
Movements of Hazardous Wastes and Their Disposal and decision SC-4/19 of the Conference of the Parties to the
Stockholm Convention on Persistent Organic Pollutants.
2
Decision SC-6/13 of the Conference of the Parties to the Stockholm Convention.
5
8.
Depending on the manufacturer and the production method used, technical HBCD consists of
70-95 per cent γ-HBCD and 3-30 per cent of α- and β-HBCD.
9.
HBCD is used solely as an additive in physical admixture with the host polymer and can
migrate within the solid matrix and volatilize from the surface of articles during their service life
(Swerea, 2010; ECHA, 2008a; European Commission [EC], 2008). It may be released from
materials due to material abrasion, but the releases from polystyrene foams are low
(UNEP/POPS/POPRC.6/13/Add.2). Additive flame retardants are physically combined with the
material being treated rather than being chemically bonded as is the case with reactive flame
retardants; therefore, there is potential for migration, at least to some extent, within and from the
polymer matrix. A number of factors act to constrain migration of HBCD within polymers,
including low vapour pressure, low water solubility and a high predicted Koc of the substance.
Nevertheless, some HBCD at the surface of a polymer or product could be released into the
environment during use or disposal of the product (Environment Canada & Health Canada, 2011;
UNEP/POPS/POPRC.7/19/Add.1; USEPA, 2014).
10.
HBCD is found to be widespread in the global environment, with elevated levels in top
predators in the Arctic. In biota, HBCD has been found to bioconcentrate, bioaccumulate and to
biomagnify at higher trophic levels. Several trend studies show an increase of HBCD in the
environment and in human tissues from 1970/1980s until recent years. Its increased presence in the
environment is likely attributed to the increased global demand. The general trend is to higher
environmental HBCD levels near point sources and urban areas. High concentrations have been
identified in Europe and in coastal waters of Japan and south China, near production sites of HBCD,
manufacturing sites of products containing HBCD and waste disposal sites including those whose
processes include either recycling, landfilling or incineration (UNEP/POPS/POPRC.6/13/Add.2).
Analyses of sediment core samples show a clear trend of increasing concentrations of HBCD since
the 1970s, confirming stability in deep sediments for periods of more than 30 years. Measured and
modelled data indicate that HBCD will undergo primary degradation under some conditions;
however, ultimate degradation in the environment is a slow process. (Environment Canada & Health
Canada, 2011).
2.
Production
11.
Parties to the Stockholm Convention shall prohibit and/or eliminate the production of HBCD,
except if they have notified the Secretariat of their intention to use for the time-limited specific
exemption for EPS and XPS used in buildings, as provided in Annex A to that Convention. In
addition, a number of countries will continue production of HBCD for any purpose until their
ratification. Information on production of HBCD under the exemption and the status of parties’
ratification of amendments can be found on the register for specific exemptions on the website of the
Stockholm Convention (www.pops.int).
12.
HBCD is still being produced for its use in EPS and XPS in buildings. HBCD has been on
the world market since the late 1960s. It has been mainly produced in China, the European Union
(EU), Japan and the United States. The total production of HBCD was estimated at around 31,000
tonnes in 2011, of which about 13,000 tonnes was produced in the EU and the United States, and
18,000 tonnes in China (UNEP/POPS/POPRC.7/19/Add.1, UNEP/POPS/POPRC.8/16/Add.3). In
the recent years the production of HBCD appears to have grown. For comparison, in 2001 European
demand for HBCD ranged from 9,500 to 16,500 tonnes, 3,900 tonnes in Asia and 2,800 tonnes in
North and South America (further data is available in UNEP/POPS/POPRC.7/19/Add.1 and
UNEP/POPS/POPRC.8/16/Add.3).
3.
Use
13.
Parties to the Stockholm Convention shall prohibit and/or eliminate the use of HBCD, except
if they have notified the Secretariat of their intention to use it under the time-limited specific
exemption for EPS and XPS used in buildings, as provided in Annex A to that Convention. In
addition, a number of countries will continue use of HBCD for any purpose until their ratification.
Information on production of HBCD under the exemption can be found on the register for specific
exemptions and the status of parties’ ratification of amendments on the website of the Stockholm
Convention (www.pops.int).
14.
HBCD is mainly used to reduce the flammability of expanded polystyrene (EPS) and
extruded polystyrene (XPS) foams and textiles. The majority of HBCD is used as a flame retardant
in EPS and XPS foams that are used as insulation materials of industrial and residential buildings in
the construction sector. These applications are currently considered to account for 90 per cent of the
6
HBCD use (UNEP/POPS/POPRC.7/19/Add.1). Outside the construction sector, polystyrene (PS)
foams are also used to insulate coolers, as a packaging material, decorations and ornaments. The use
of flame retardant in the EPS for these applications depends on local requirements, as well as the
quality of EPS raw material that may be available (logistical reasons). HBCD is not used in food
packaging according to an EU technical report (ECHA, 2008), but flame-retardant EPS has been
found in packaging materials as well (EUMEPS, 2009).
15.
The use of flame retarded EPS and XPS insulation varies significantly between countries,
depending on local building code and fire safety regulations. Due to the high volume and bulky size
of insulation products, and associated transportation costs, PS foam insulation materials are usually
tailor made for the local market, and the main share of the production is for local consumption, not
for export (SWEREA, 2010; BSEF, 2011). In some countries, virtually all EPS and XPS are flame
retardant grades, while in other countries only flame retardant-free EPS and XPS are used. The
concentrations at which HBCD is used depend on the polymer it is used with and the fire safety
requirements the product needs to meet (UNEP/POPS/POPRC.7/19/Add.1); however, it should be
noted that these concentrations vary from country to country. Typical concentrations at which
HBCD is used in different materials are shown in table 1.
Table 1: Typical concentrations at which HBCD is used in different materials
(UNEP/POPS/POPRC.7/19/Add.1)
Flame-retarded material
Expanded polystyrene EPS
Extruded polystyrene XPS
Textile back-coating
Textiles
High-impact polystyrene HIPS
HBCD content (in mg/kg)
5000-10000
8000-25000
10000-15000
22000-43000 (Kajiwara et al. 2009)
10000-70000
16.
The technical ability to use flame retardants other than HBCD is heavily influenced by the
production process and is not possible in some cases. For EPS in Europe, for example, the standard
“one-step” process has meant that HBCD is used as a flame retardant, whereas in other countries
with different production processes other flame retardants may also occasionally be found.
17.
A smaller application of HBCD is for flame-retarded textiles and textile back coating for use
in residential and commercial upholstered furniture, transportation seating, curtains, wall coverings
and draperies. The flame retardant can be introduced to the textile by impregnation/spraying or by
spinning flame-retarded polymer into textile yarn. The concentrations of HBCD used for flameretardant textiles are much higher than in PS foam production.
18.
Other minor uses include addition to adhesives and paints and to high-impact polystyrene
(HIPS) for electrical and electronic equipment to make them flame-retardant. HBCD has been
largely replaced by other flame retardants in these applications
19.
The majority of HBCD has been used in the European Union, but its use in China has
increased over the past ten years (UNEP/POPS/POPRC.6/13/Add.2,
UNEP/POPS/POPRC.7/19/Add.1, UNEP/POPS/POPRC.8/16/Add.3).
4.
Wastes
20.
Recognizing the following considerations:
(a)
The available assessments estimate the environmental emissions of HBCD during
production and chemical use to be small, compared to the releases from HBCD containing articles
and waste (EC, 2008). The losses from EPS raw material production may, however, be high unless
the HBCD chemical packaging materials (bags) are properly managed
(UNEP/POPS/POPRC.6/13/Add.2). Releases from processing of PS foams are expected to be much
lower than those associated with the application of HBCD containing back coat to textiles. (ECHA,
2008). According to the European Union Risk Assessment (EC, 2008), 99.9 per cent of the
produced/imported volume of HBCD ends up in mainly in polystyrene (XPS, EPS) used in the
construction and building sector.
(b)
There are releases of HBCD from products and articles (EC, 2008; Miyake et al.,
2009; Kajiwara et al., 2009), but the estimates concerning releases during consumer use of products
are highly uncertain (ECHA, 2009). Releases from polystyrene foams are low
(UNEP/POPS/POPRC.6/13/Add.2) because HBCD is incorporated in the plastic polymer matrix,
which prevents migration and exposure via surface contact. However, the use of HBCD as a flame7
retardant additive in textiles could possibly lead to contamination of surface-water during washing
of the fabric. Furthermore, emissions due to the wear of the fabric during its service life can also be
expected (EC, 2008).
(c)
Due to the long service-life of products where HBCD has mainly been used, waste
management is a potential increasing source of HBCD releases to the environment. Action towards
waste streams of importance in terms of volume and concentration will be essential in order to
eliminate, reduce and control the environmental load of HBCD from waste management activities.
There may be some releases of HBCD in dust when buildings insulated with flame-retarded
insulation materials are demolished but the future emissions from these constructions (e.g. at repair
or demolition of old buildings, roads, railway and other constructions) will depend on the techniques
used for demolition (EC, 2008). There may also be industrial/municipal wastewater discharges to
surface waters and through leachate from landfills. There is little information on the quantity of
HBCD in landfill leachate; however, given the low water solubility of the substance, it is expected
that leaching from the surfaces of polymer products in the landfill is limited (Environment Canada
& Health Canada, 2011).
21.
Wastes may contain variable concentrations of HBCD depending on initial quantities in the
product, releases occurring during its use and in waste management. The concentrations of HBCD in
insulation foams are, however, expected to remain stable due to assumed low emissions during its
service life (ECHA, 2008). HBCD wastes can be in the form of pure chemical, HBCD mixtures
(formulations), packaging materials and articles containing HBCD. Pure chemical waste and HBCD
mixtures constitute a small fraction of total HBCD waste (>90 per cent.
UNEP/POPS/POPRC.7/19/Add.1). At the end of their service life most articles containing HBCD
will become construction waste, waste electrical and electronic equipment (WEEE), textile waste,
furniture waste, waste vehicles or household waste. HBCD wastes may be found in a number of
forms including:
(a)
(b)
(c)
(d)
HBCD chemical:
(i)
Pure HBCD;
(ii)
Obsolete HBCD, which can no longer be used;
HBCD mixtures:
(i)
EPS beads;
(ii)
XPS masterbatch;
(iii)
Textile back-coating;
(iv)
HBCD-containing paints, adhesives and latex binders;
HBCD mixture packaging materials:
(i)
HBCD packing;
(ii)
HBCD mixture packing;
HBCD-containing articles:
(i)
EPS beads;
(ii)
PS foam production waste (cutting waste, etc.);
(iii)
Construction and demolition waste (insulation boards used in foundation, walls
and ceilings, ground deck, parking deck, etc.);
(iv)
Packaging materials made of PS foams;
(v)
Ornaments and decorations;
(vi)
EPS loose filling used in furniture (bean bags, sofas);
(vii)
Housing (HIPS) and wirings in electronic and electrical equipment;
(viii) Flame retardant textiles (protective clothing, carpets, curtains, upholstered
fabrics, tents, interiors in public transportation conveyances (e.g. automobiles,
trains, aircraft, etc.) and other technical textiles);
(ix)
(e)
8
Automotive parts made of PS foams;
Municipal and industrial sludge and landfill leachate.
22.
Insulation boards form the majority of HBCD waste. HBCD waste forms a very specific
challenge to waste management because of the long service life of some of the articles containing
HBCD: the lifespan of PS foam insulation in buildings is reported to be 30-50 years (ECHA, 2009;
SWEREA, 2010), but could even exceed 100 years. The use of HBCD in insulation boards and the
HBCD built into buildings and constructions has been increasing since the 1980s and it is therefore
likely that releases from EPS/XPS from waste materials will be more significant in the future;
particularly from about 2025 onwards, as increasing number of buildings containing HBCD will be
refurbished or demolished (UNEP/POPS/POPRC.6/13/Add.2). This turn-over will be different in
different regions of the world.
23.
The most important waste streams in terms of potential volume are expected to be:
(a)
Insulation boards (more than 90 per cent of the HBCD is used for flame-retardant EPS
and XPS foam for insulation and construction (UNEP/POPS/POPRC.7/19/Add.1);
(b)
Textile waste from automotive and other means of transportation upholstery and
commercial buildings, e.g. from recycling and maintenance;
(c)
Furniture waste in countries where flame-retarded EPS and textiles have been used;
(d)
Packaging material made of flame-retarded PS foam.
24.
The most important waste streams in terms of potential release or HBCD concentration are
expected to be:
(a)
(b)
produced);
(c)
HBCD chemical waste;
Waste from production of HBCD (only in the few countries where HBCD is
Packages used for HBCD chemical and mixtures;
(d)
Textile waste from automotive and other means of transportation upholstery and
commercial buildings, e.g. from recycling and maintenance; WEEE and solid wastes from disposal
of such waste;
(e)
HBCD mixtures (EPS beads, XPS masterbatch, textile back-coating).
25.
Table 2 provides a summary of the production and use of HBCD and its release media into
the environment.
9
Table 2: Production and use of HBCD and their release media (Based on UNEP/POPS/POPRC.6/13/Add.2,
UNEP/POPS/POPRC.7/19/Add.1)
Group
Source materials
Uses/Applications
End Product
Release Media
Chemical
Production
HBCD CHEMICAL PRODUCTION
Cyclododecatriene,
bromine
Chemical synthesis
HBCD chemical
 Solid waste
 Water
 Sludge
 Air
HBCD MIXTURE PRODUCTION
HBCD mixture production
(note that emptied packages of HBCD chemical have been identified as an important source of emissions among the firstline users of HBCD and appropriate waste management has reduced emissions significantly
(UNEP/POPS/POPRC.7/19/Add.1)
Styrene, pentane, HBCD
and other additives
Production of flameretarded EPS raw
material
PS beads containing a blowing
agent for EPS production
PS, HBCD and other
additives
Production of
flame-retarded XPS
HBCD masterbatch
HBCD masterbatch compound for
XPS production
Surfactants, HBCD,
antimony tri-oxide, acrylic
adhesive
Production of
flame-retarded
textile back-coating
Textile back-coating mixture
Textiles, HBCD
Production of
impregnated textiles
Flame-retardant textiles
Polymer, HBCD
Production of
flame-retarded yarn
Flame-retardant polymer for
spinning into textile yarn
HIPS
Flame-retardant HIPS pellets
Styrene-acrylonitrile
plastics
Styrene-acrylonitrile resins
 Landfill leachate
 Wastewater
cleaning
 Sludge
HIPS pellets, antimony
trioxide, HBCD
HBCD packaging
Production of
adhesives and paints
Adhesives, paints
HBCD packaging
10
 Solid waste
 Air
PRODUCTION OF ARTICLES CONTAINING HBCD
(Note that the table below refers to articles that have become wastes. Such waste may also be produced at production sites
(such as leftovers, cutting waste, etc.)
Expansion and
molding
EPS articles
EPS beads
Flame-retarded EPS insulation,
including:
-
Flat roof insulation
-
Pitched roof insulation
-
Floor insulation ‘slab-onground’ insulation
 Solid waste
 Landfill leachate
-
Insulated concrete floor systems
-
Interior wall insulation with
gypsum board (‘doublage’)
 Liquid industrial
and household
cleaning waste
-
Exterior wall insulation or
ETICS (External Insulated
Composite Systems)
 Wastewater
-
Cavity wall insulation boards
-
Cavity wall insulation loose fill
-
Insulated concrete forms (ICF)
-
Foundation systems and other
void forming systems
-
Load bearing foundation
applications
-
Core material for EPS used in
sandwich and stressed skin
panels (metal and wood
fibreboard)
-
Floor heating systems
-
Sound insulation in floating
floors (to avoid transmission of
contact sound)
-
EPS drainage boards
 Sludge
 Air
EPS concrete bricks, EPS concrete
Soil stability foam (for civil
engineering use)
Seismic insulation
Packaging materials made of PS
foams1
Other molded EPS articles, such as
ornaments, decorations, logos, etc.
1
EPS packaging is not usually made of flame retardant EPS unless specifically required or due to logistical
reasons.
11
XPS masterbatch
Expansion and
Extrusion
XPS articles
or
PS, HBCD and other
additives (including
blowing agent e.g. CO2)
Flame-retarded XPS insulation
boards:
Cold bridge insulation
Floors
Basement walls and foundations
Inverted roofs
Ceilings
Cavity insulation
Composite panels and laminates
 Solid waste
 Landfill leachate
 Liquid industrial
and household
cleaning waste
 Wastewater
 Sludge
Textile production
 Air
Flame-retarded textile
(back-coating or fabrics)
Residential and commercial
upholstered furniture
Transportation seating
Wall coverings and draperies
 Solid waste
 Landfill leachate
 Liquid industrial
and household
cleaning waste
 Wastewater
Protective clothing and other
technical textiles
 Sludge
 Air
Electric and electronic
equipment production
Tents etc.
HIPS pellets
Production of
casings for
electronic and
electric equipment
Electric and electronic appliances
 Solid waste
 Landfill leachate
 Liquid industrial
and household
cleaning waste
 Wastewater
 Sludge
 Air
II.
Relevant provisions of the Basel and Stockholm conventions
A.
Basel Convention
26.
Article 1 (“Scope of the Convention”) defines the waste types subject to the Basel
Convention. Subparagraph 1 (a), of that Article sets forth a two-step process for determining if a
“waste” is a “hazardous waste” subject to the Convention. First, the waste must belong to any
category contained in Annex I of the Convention (“Categories of wastes to be controlled”). Second,
the waste must possess at least one of the characteristics listed in Annex III of the Convention (“List
of hazardous characteristics”).
27.
Annex I lists some of the wastes which may consist of, contain or be contaminated with
HBCD:
(a)
Y12 (Wastes from production, formulation and use of inks, dyes, pigments, paints,
lacquers, varnish);
(b)
Y13 (Wastes from production, formulation and use of resins, latex, plasticizers,
glues/adhesives);
(c)
Y17 (Wastes resulting from surface treatment of metals and plastics);
(d)
Y18 (Residues arising from industrial waste disposal operations);
(e)
Y45 (Organohalogen compounds other than substances referred to in this Annex (e.g.
Y39, Y41, Y42, Y43, Y44));
(f)
12
Y46 (Wastes collected from households).
28.
Annex I wastes are presumed to exhibit one or more Annex III hazard characteristics, which
may include H6.1 “Poisonous (acute), H11 “Toxic (delayed or chronic)”; H12 “Ecotoxic”; or H13
(capable after disposal of yielding a material which possess a hazardous characteristic)”, unless they
can be shown to not exhibit these characteristics through “national tests”. National tests may be
useful for identifying a particular hazard characteristic in Annex III of the Convention until such
time as the hazardous characteristic is fully defined. For example, tests of both EPS and XPS boards
conducted by the industry in line with the UK Environmental Agency Technical Guidance WM2
(Hazardous waste: Interpretation of the definition and classification of hazardous waste) concluded
that EPS and XPS foam boards that contain HBCD need not be classified as hazardous waste
(HBCD in Polystyrene Foams: Product Safety Assessment 2013). Guidance papers for Annex III
hazardous characteristics H11, H12 and H13 were adopted on an interim basis by the Conference of
the Parties to the Basel Convention at its sixth and seventh meeting.
29.
List A of Annex VIII of the Convention describes wastes that are “characterized as hazardous
under article 1, paragraph 1 (a)”, although “their designation on this Annex does not preclude the
use of Annex III to demonstrate that a waste is not hazardous”. List A of Annex VIII includes a
number of wastes or waste categories that have the potential to contain or be contaminated with
HBCD, including :
(a)
A1180 (Waste electrical and electronic assemblies or scrap containing components
such as accumulators and other batteries included on list A, mercury-switches, glass from cathoderay tubes and other activated glass and PCB-capacitors, or contaminated with Annex I constituents
(e.g. cadmium, mercury, lead, polychlorinated biphenyl) to an extent that they possess any of the
characteristics contained in Annex III (note the related entry on list B B1110));
(b)
A3050 (Wastes from production, formulation and use of resins, latex, plasticizers,
glues/adhesives excluding such wastes specified on list B (note the related entry on list B B4020));
(c)
A3120 (Fluff – light fraction from shredding);
(d)
A4070 (Wastes from the production, formulation and use of inks, dyes, pigments,
paints, lacquers, varnish excluding any such wastes specified on list B (note the related entry on list
B B4010));
(e)
A 4130 (Waste packages and containers containing Annex I substances in
concentration sufficient to exhibit Annex III hazard characteristic);
(f)
A4140 (Waste consisting of or containing of specification or outdated chemicals
corresponding to Annex I categories and exhibiting Annex III hazard characteristics);
(g)
B2060)).
A4160 (Spent activated carbon not included on list B (note the related entry on list B
30.
List B of Annex IX lists wastes that will not be wastes covered by article 1, paragraph 1 (a),
unless they contain Annex I material to an extent causing them to exhibit an Annex III
characteristic. List B of Annex IX includes a number of wastes or waste categories that have the
potential to contain or be contaminated with HBCD, including:
(a)
B1250 (Waste end-of-life motor vehicles, containing neither liquids nor other
hazardous components);
(b)
B3010 (Solid plastic waste);
(c)
B3030 (Textile wastes);
(d)
B3035 (Waste textile floor coverings, carpets);
(e)
B4010 (Wastes consisting mainly of water-based/latex paints, inks and hardened
varnishes not containing organic solvents, heavy metals of biocides to an extent to render them
hazardous (note the related entry on list A A4070));
(f)
B4020 (Wastes from production, formulation and use of resins, latex, plasticizers,
glues/adhesives, not listed on list A, free of solvents and other contaminants to an extent that they
do not exhibit Annex III characteristics, e.g. water-based, or flues based on casein, starch, dextrin,
cellulose ethers, polyvinyl alcohols (note the related entry on list A A3050)).
31.
For further information, see section II.A of the general technical guidelines.
13
B.
Stockholm Convention
32.
The present document covers intentionally produced HBCD, whose production and use are to
be prohibited in accordance with article 3 and part I of Annex A of the Stockholm Convention.
33.
Part VII of Annex A also outlines specific requirements for HBCD containing products
manufactured under the exemption, as follows:
Each party that has registered for the exemption pursuant to Article 4 for the production and
use of hexabromocyclododecane for EPS and XPS in buildings shall take necessary measures
to ensure that EPS and XPS containing HBCD can be easily identified by labelling or other
means throughout its life cycle.
34.
For further information, see section II.B of the general technical guidelines.
III.
Issues under the Stockholm Convention to be addressed
cooperatively with the Basel Convention
A.
Low POP content
35.
The provisional definition of low POP content for HBCD is [1000 mg/kg]2.
36.
The low POP content of the Stockholm Convention is independent from the determination of
hazardous waste under the Basel Convention. Provisions of the Stockholm Convention complement
the provisions for the management of hazardous wastes under the Basel Convention to form a
comprehensive regime to manage wastes consisting of, containing or contaminated with POPs.
Provisions from the two conventions are to be applied to wastes consisting of, containing or
contaminated with POPs in making decisions about their environmentally sound management.
37.
Wastes consisting of, containing or contaminated with HBCD above [1000 mg/kg] must be
disposed of in such a way that the POP content is destroyed or irreversibly transformed according to
the methods described in section IV.G.2 of the general technical guidelines, or otherwise disposed of
in an environmentally sound manner when destruction of irreversible transformation does not
represent the environmentally preferable option according to the methods described in section
IV.G.3 of the general technical guidelines.
38.
Wastes consisting of, containing or contaminated with HBCD below [1000 mg/kg] should be
disposed of in accordance with relevant national legislation and international rules, standards and
guidelines, including the specific technical guidelines developed under the Basel Convention.
Further information is given in section IV.G.4 of the general technical guidelines and examples of
relevant national legislation in annex II of the same guidelines.
39.
For further information on the low POP content, refer to section III.A of the general technical
guidelines.
B.
Levels of destruction and irreversible transformation
40.
For the provisional definition of levels of destruction and irreversible transformation, see
section III.B of the general technical guidelines.
C.
Methods that constitute environmentally sound disposal
41.
See section G of chapter IV below and section IV.G of the general technical guidelines.
IV.
Guidance on environmentally sound management (ESM)
A.
General considerations
42.
B.
For further information, see section IV.A of the general technical guidelines.
Legislative and regulatory framework
43.
2
Parties to the Basel and Stockholm Conventions should examine national controls, standards
Decision OEWG-9/3 on technical guidelines for the environmentally sound management of wastes consisting of,
containing or contaminated with persistent organic pollutants.
14
and procedures to ensure that they are in line with the respective conventions and their obligations
under them, including those that pertain to ESM of HBCD wastes.
44.
Elements of a regulatory framework to prevent, minimize and manage HBCD wastes in an
environmentally sound manner could also include the following:
(a)
Prohibitions on the manufacture, sale, use, import and export of HBCD, except if they
have notified the Secretariat of their intention to use for the time-limited specific exemption for EPS
and XPS used in buildings, as provided in Annex A to Stockholm Convention;
(b)
Requirement to use best available technologies (BAT) and best environmental
practices (BEP) in the production and use of HBCD under the specific exemption;
(c)
Take appropriate measures to ensure HBCD wastes are not permitted to subjected to
disposal operations that may lead to recovery, recycling, reclamation, direct reuse or alternative uses
of HBCD;
(d)
Adequate ESM controls on facilities involved in the recycling of wastes containing
HBCD at levels below the defined low POP content;
(e)
Adequate ESM controls to separate materials in which HBCD has been used from
those that can continue to be recycled (e.g. non-HBCD containing insulation and packaging
materials, textiles, and materials made with alternative flame retardants;
(f)
Parties that will allow production and use of HBCD for EPS and XPS in buildings
under the specific exemption pursuant to Article 4 of the Stockholm Convention, are to take
necessary measure to ensure that expanded PS and extruded PS containing HBCD can be easily
identified by labelling or other means throughout its life cycle;
(g)
Environmental protection legislation establishing a regulatory regime, setting release
limits and establishing environmental quality criteria;
(h)
(i)
Requirements for health and safety of workers;
Transportation requirements for hazardous materials and waste;
(j)
Specifications for containers, equipment, bulk containers and storage sites for HBCD
chemical waste;
(k)
Specification of acceptable analytical and sampling methods for HBCD;
(l)
Requirements for waste management and disposal facilities;
(m) A general requirement for public notification and review of proposed government
regulations, policy, certificates of approval, licences, inventory information and national
releases/emissions data;
(n)
Requirements for identification and remediation of contaminated sites;
(o)
Other potential legislative controls, as for waste prevention and minimization,
inventory development and emergency response.
45.
C.
For further information, see section IV.B of the general technical guidelines.
Waste prevention and minimization
46.
Both the Basel and Stockholm Conventions advocate waste prevention and minimization.
HBCD production and use are to be eliminated under the Stockholm Convention with limited
exemption for the production and use of HBCD, as provided in Part I of Annex A of the Convention.
47.
Quantities of waste containing HBCD should be minimized through isolation and source
separation to prevent mixing and contamination of other waste streams.
48.
Mixing of wastes with HBCD content above [1000 mg/kg] with another material solely for
the purpose of generating a mixture with a POP content below [1000 mg/kg] is not environmentally
sound. Nevertheless, mixing of materials as a pre-treatment method may be necessary in order to
enable or optimize treatment efficiencies.
49.
For further information, see section IV.C on waste prevention and minimization of the
general technical guidelines.
15
D.
Identification of wastes
50.
Article 6, paragraph 1 (a) of the Stockholm Convention requires the development of
appropriate strategies for the identification of products and articles in use and POPs wastes.
Identification of HBCD wastes is the premise for their effective environmentally sound
management.
51.
For general information on identification and inventories, see section IV.D of the general
technical guidelines.
1.
Identification
52.
HBCD can be found:
(a)
In HBCD production facilities:
(i)
(b)
(c)
Industrial wastewater and sludge;
In HBCD mixture production:
(i)
EPS beads (EPS foam raw material);
(ii)
XPS masterbatch (XPS foam raw material);
(iii)
Packaging material of HBCD chemical;
(iv)
Flame retardant textiles and back coatings;
(v)
HIPS pellets;
(vi)
Adhesives, paints;
When articles containing HBCD are produced, used or have become wastes:
(i)
Solid cutting and production waste (EPS and XPS foam);
(ii)
Municipal wastewater and sludge;
(iii)
Contaminated surface and groundwater;
(iv)
Landfill leachate;
(v)
Construction waste (including insulation materials, demolition waste
containing EPS/XPS (also mixed with concrete), soil stability foams and
seismic insulation);
(vi)
Other EPS/XPS waste (ornaments, decorations, molded PS products such as
company logos and stands);
(vii)
Packaging waste;
(viii) Textile waste;
(ix)
Furniture waste;
(x)
Electronic and electric equipment waste;
(xi)
Waste vehicles;
(xii)
Dust filter materials and cakes and other waste from WEEE and construction
waste treatment.
53.
It should be noted that even experienced technical persons may not be able to determine the
nature of an effluent, substance, container or piece of equipment by its appearance or markings.
Consequently, the information on production, use and waste types provided in section B of chapter I
of the present document may be useful in identifying those articles and mixtures containing HBCD.
54.
Articles and products containing HBCD can be found on the market; they may contain
alternative flame retardants or are not flame retarded, depending on local fire safety requirements,
building codes and the type of EPS raw material available on the market. It is not possible to
distinguish between HBCD containing EPS, XPS, textiles or furniture based on visual appearance
only. Knowledge on current and past fire safety requirements is important. HBCD is seldom used
unless flame retardancy is specifically required.
55.
The Stockholm Convention provides that parties should take the necessary measures to
ensure that expanded PS and extruded PS containing HBCD can be easily identified by labelling or
16
other means throughout its life cycle in cases where EPS and XPS are produced under the specific
exemption under the Convention.
56.
X-ray fluorescence (XRF) analysis can be used as a cheap and rapid screening method to
determine whether a material contains bromine. The presence of bromine in PS-based articles
produced before 2014 indicates the presence of HBCD. Other brominated flame retardants may have
been used enhance PS fire safety only in so-called two step production process, which is rare and
appears to be in use only in the United States. Furthermore, as the HBCD alternatives are based on
bromine as well, this method will not be useful for distinguishing products flame-retarded with
alternative chemicals.
2.
Inventories
57.
When developing an inventory, it is important to consider the service life of the articles and
when they have been placed on the market. Whether HBCD has been used in articles largely
depends on local regulations and practices (current and historical), and it may be possible to identify
the times when flame-retardancy has been required for the uses of the articles. As all flame retardant
EPS and XPS has been produced with HBCD until recently, it significantly impacts the volumes of
POPs waste.
58.
PS foam insulation materials and certain textiles have a very long service life, and will enter
the waste stage decades after they were introduced on the market. Their presence depends on the
local fire-safety regulations at the time of construction or placing on the market. Also electrical and
electronic equipment have a relatively long service life, but according to information from UNEP3,
HBCD has been mainly replaced by other chemicals and the majority of those articles may already
have been disposed of. The same applies with packaging materials, which have a short service life,
but generally do not contain HBCD. However, they may have already contaminated recycling
streams.
59.
The first issue to consider when developing an inventory is identifying the types of industries
and applications that may have been producing HBCD or using it for the production of mixtures or
articles. An inventory should, as appropriate, be based on information on:
(a)
Production of HBCD within the country;
(b)
Import and export of products and articles containing HBCD;
(c)
Uses of articles containing HBCD in the country;
(d)
Regulatory requirements (e.g. building codes, fire-safety requirements) regarding use
insulation materials and textiles, including regulatory history to assess the time frame when the
materials were likely to contain HBCD;
(e)
products;
(f)
Disposal of HBCD waste, including possible recycling into new or non-flame retarded
Import/export of HBCD waste.
60.
Preparing an inventory requires cooperation by the relevant authority with the fire-safety and
building authorities, possible producers of HBCD, HBCD mixtures and formulations and their
downstream users producing articles containing HBCD, customs offices, waste disposal and
recycling facilities, and the national focal points for the Basel Convention as well as for the
Stockholm Convention. In some cases, government regulations may be required to ensure that
owners report their holdings and cooperate with government inspectors.
61.
The first issue to consider when developing an inventory is the types of industries and
applications that may have been using HBCD as a chemical or mixtures or articles containing
HBCD.
62.
Recognizing that the majority of HBCD is likely to be in insulation in the construction sector,
analysing historical regulatory measures governing the use of flame retardant materials, as well as
past requirements and building practices, should help provide a sense of the magnitude of the
inventory effort and can help to narrow down a list of possible holders of waste. If HBCD has been
produced in or imported into the country for formulating HBCD mixtures, these industries involved
3
http://chm.pops.int/Portals/0/download.aspx?d=UNEP-POPS-POPRC.7-19-Add.1.English.pdf.
17
should also be part of the initial consultations. These companies may be able to give estimates or
even exact figures of the timeframe and amount of these products that were used in domestic
applications. These estimates can be very valuable in determining how much of a chemical has been
accounted for by an inventory.
63.
Although HBCD has been on the world market since the 1960s, its use has grown as a
response to the national fire safety requirements in the few last decades. However, even in cases
where national fire safety requirements do not exist, flame retardant materials may be used due to
logistical reasons, i.e. the raw material available for articles may be flame retarded.
64.
The volumes of HBCD flame-retarded articles imported and exported globally are generally
unknown.
65.
For further information, please refer to “Guidance on inventory of HBCD developed under
the Stockholm Convention”.
E.
Sampling, analysis and monitoring
66.
For general information on sampling, analysis and monitoring, see section IV.E of the
general technical guidelines.
67.
Identifying HBCD-containing materials is important as it facilitates the recycling of nonHBCD containing materials, especially in construction waste, textiles and WEEE. In articles that
potentially contain HBCD, the sampling, analysis and monitoring procedures should be described in
conjunction with waste collection and waste handling processes, which are waste category specific.
1.
Sampling
68.
Sampling serves as an important element for identifying and tracking environmental concerns
and human health risks.
69.
Standard sampling procedures should be established and agreed upon before the start of the
sampling campaign. Sampling should comply with national legislation, where it exists, or with
international regulations. Currently, there is no standardized method for sampling of HBCD in
articles, such as foams, furniture or textiles. However, for buildings, based on an analysis of fire
safety requirements and building codes at the time of construction/renovation or placing on the
market, it can be determined whether the articles in question are likely to contain HBCD. In that
case, sampling may not be necessary. If such records are not available, and/or should it be
appropriate to prove that polystyrene foam boards in a given building do not contain HBCD, it is
recommended to conduct the identification of HBCD via sampling at the building site before
demolition. Separate sampling of different applications (e.g. facade, flooring etc.) may also be
necessary. In Europe, Technical Specification (TS) 50625-3-1 Collection logistics treatment
requirements for WEEE is currently under development, describing a sampling method for WEEE.
70.
Types of matrices typically sampled for HBCD include:
(a)
(b)
(c)
Liquids:
(i)
Leachate from dumpsites and landfills;
(ii)
Water (surface and ground water, drinking water, and industrial and municipal
effluents);
(iii)
Biological fluids (blood, in the case of monitoring the health of workers);
Solids:
(i)
Sewage sludge;
(ii)
Biological samples (adipose tissue);
(iii)
Stockpiles, mixtures and articles consisting of, containing or contaminated with
HBCD;
(iv)
Indoor dust;
Gases:
(i)
18
Air (indoor and outdoor).
2.
Analysis
71.
Analysis refers to the extraction, purification, separation, identification, quantification and
reporting of HBCD concentrations in the matrix of interest. In order to obtain meaningful and
acceptable results, the analytical laboratory should have the necessary infrastructure (housing) and
proven experience.
72.
The development and dissemination of reliable analysis methods and the accumulation of
high-quality analytical data are important to understand the environmental impact of hazardous
chemicals, including POPs.
73.
Total HBCD (sum of isomers) can be analyzed via GC/MS, LC-MS and HPLC-MS. GC-FID
using a HBCD reference is also able to identify and quantify HBCD. A number of analytical
methods to analyze HBCD in environmental samples as well as in foams have been developed, but
none have yet been internationally standardized. The accuracy as well as comparability especially at
low levels may be questioned until standard methods will become available. For the analysis of
HBCD in WEEE plastics, standard IEC 62321-Part 6 ‘Determination of certain substances in
electrotechnical products - Part 6: Determination of polybrominated biphenyls and polybrominated
diphenyl ethers in polymers and electronics by GC-MS, IAMS and HPLC-UV’ can be applied.
Analyzing HBCD in articles, such as furniture, should be further developed.
74.
Laboratory analyses are not applicable for determining HBCD in materials and articles in the
waste management processes, as they are too expensive and time-consuming. At present, fast and
inexpensive screening methods only determine the presence of bromine, but they can be used as an
indicator for HBCD presence for EPS and XPS articles placed on the market before 2014 in
countries where HBCD was the only flame retardant used for PS foams. Currently, there are
methods to analyse HBCD in WEEE, but not in textiles.
3.
Monitoring
75.
Monitoring and surveillance serve as elements for identifying and tracking environmental
concerns and human health risks. Information collected from monitoring programmes feeds into
science-based decision-making processes and is used for the evaluation of the effectiveness of risk
management measures, including regulations.
76.
F.
Monitoring programmes should be implemented for facilities managing HBCD wastes.
Handling, collection, packaging, labelling, transportation and storage
77.
For general information on handling, collection, packaging, labelling, transportation and
storage, see section IV.F of the general technical guidelines. In Europe, Technical Specification (TS)
50625-3-1 Collection logistics treatment requirements for WEEE is currently under development,
describing the waste management processes for WEEE.
1.
Handling
78.
A set of procedures should be prepared by each organization that handles HBCD chemical
and mixture wastes and workers should be trained in the procedures.
79.
HBCD may be released from articles containing HBCD by material abrasion or interfering
with the polymer integrity. Polystyrene foam should not be compacted, but transported to the nearest
suitable waste management facility. As such, HBCD incorporated in the PS foam matrix remains
unexposed to the environment, whilst being safely destroyed. It follows that, during the destruction,
care should be taken to reduce foam breakage to a minimum and to divert polystyrene foams to
outlets that allow controlling the release of fine particles and of dust.
80.
The waste streams containing HBCD should be kept separated from those waste streams that
do not contain HBCD, although they may visually look the same, to facilitate environmentally sound
waste management (for instance, buildings may contain both flame retarded and non-flame retarded
insulation materials). Only in cases where non-HBCD containing waste is managed according to
section IV.G of the general technical guidelines separation is not necessary.
81.
PS foam containing HBCD should not be compacted, but transported to the nearest suitable
waste management facility. As such, HBCD incorporated in the PS foam matrix remains unexposed
to the environment, whilst being safely destroyed. During the destruction care should be taken to
reduce foam breakage to a minimum and to divert polystyrene foams to outlets that allow
controlling the release of fine particles and of dust. If compaction takes place, appropriate measures
need to be taken to protect the human health and the environment from exposure to HBCD released
19
from degraded polymer.
2.
Collection
82.
Collection arrangements and collection depots for HBCD chemical waste should be separated
from all other wastes.
83.
A collection system for insulation materials, packaging materials and textile waste containing
HBCD should be organized, unless the waste is incinerated or otherwise managed according to
section IV.G of the general technical guidelines.
84.
Waste electrical and electronic equipment (WEEE) may contain high-impact-polystyrene
(HIPS) containing HBCD. For further information, see section IV.F.3 of the POP-BDEs technical
guidelines. In Europe, Technical Specification (TS) 50625-3-1 Collection logistics treatment
requirements for WEEE is currently under development, describing a sampling method for WEEE.
85.
The waste streams containing HBCD should be collected separately from those waste streams
that do not contain HBCD, unless the waste is incinerated or otherwise managed according to
section IV.G of the general technical guidelines. For instance, if the identification and analysis of a
building site finds both HBCD and non-HBCD containing applications, demolition teams need to
manually separate these waste streams to enable the recycling of any polystyrene foams that do not
contain HBCD.
86.
Collections depots should not become long-term storage facilities for HBCD chemical and
mixture wastes.
3.
Packaging
87.
HBCD, HBCD packaging and mixture wastes should be properly packaged before storage or
transport. Articles containing HBCD are typically consumer products and do not need specific
packaging or transport. However, waste polystyrene is often crushed down to reduce volume before
its transportation.
4.
Labelling
88.
All containers containing HBCD chemical should, as appropriate, be clearly labelled with a
hazard-warning label, as well as a label giving the details of the container and serial number. The
details should include the contents of the container (exact counts of equipment of volume and
weight), the type of waste, the name of the site from which it originated so as to allow traceability,
the date of repackaging and the name and telephone number of the responsible person during the
repackaging operation.
89.
The waste streams containing HBCD should be clearly identified to facilitate
environmentally sound management. This is especially important in cases where both HBCD and
non-HBCD grades of articles are found. The Stockholm Convention provides that for EPS and XPS
produced under the specific exemption, parties are to take necessary measures to ensure that
expanded PS and extruded PS containing HBCD can be easily identified by labelling or other means
throughout its life cycle.
5.
Transportation
90.
Appropriate measures should be taken to prevent scattering or leakage of HBCD chemical
wastes. Such wastes should be handled separately during transport to avoid mixing with other
materials.
6.
Storage
91.
HBCD wastes containing should be stored in designated sites, with appropriate measures
taken to prevent the scatter, release, underground seepage and spread of odors.
92.
Appropriate measures, such as the installation of partitions, should be taken to avoid
contamination of HBCD waste containing.
93.
The storage area for HBCD wastes containing should have reasonable access roads for
transportation vehicles.
94.
Storing large amount of HBCD wastes containing should be protected from fire, as those
materials are often inherently flammable.
20
G.
Environmentally sound disposal
1.
Pre-treatment
95.
2.
For information, see subsection IV.G.1 of the general technical guidelines.
Destruction and irreversible transformation methods
96.
Destruction and irreversible transformation methods in the general technical guidelines for
HBCD include incineration. By-product polybrominated dioxins and furans can be released from
fires, combustion and incineration of the substance or products containing HBCD
(UNEP/POPS/POPRC.7/19/Add.1).
97.
3.
Other disposal methods when neither destruction nor irreversible transformation is the
environmentally preferable option
98.
4.
For information, see section IV.H of the general technical guidelines.
Health and safety
101.
1.
For information, see subsection IV.G.4 of the general technical guidelines.
Remediation of contaminated
100.
I.
For further information, see subsection IV.G.3 of the general technical guidelines.
Other disposal methods when the POP content is low
99.
H.
For further information, see subsection IV.G.2 of the general technical guidelines.
For information, see section IV.I of the general technical guidelines.
Higher-risk situations
102.
For general information, see subsection IV.I.1 of the general technical guidelines.
103. Higher-risk situations occur where high concentrations of HBCD (chemical waste) or high
volumes of HBCD wastes are found and a high potential for exposure is present, for instance
because of the form of waste. HBCD can potentially be released from its end products over time, as
it is not chemically bound to the polymer matrix (UNEP/POPS/POPRC.7/19/Add.1, USEPA 2014).
Human exposure to HBCD may be either dermal or oral, and may also result from inhalation of
vapour and particles. Direct dermal exposure and inhalation of fine HBCD containing dust or
particles in the workplace are particular concerns. For example, industrial workers at plants that
produce EPS with HBCD were found to have elevated HBCD levels in their blood
(UNEP/POPS/POPRC.6/13/Add.2). According to EU risk assessment, utilizing recommended
occupational safety measures results in no risk to workers (European Commission 2008).
104.
Potential higher-risk situations specific to HBCD may include:
(a)
HBCD chemical or mixtures production sites;
(b)
EPS raw material, XPS masterbatch, and textile back-coating production facilities;
(c)
Releases of HBCD in dust when buildings with flame-retarded insulation boards are
demolished (UNEP/POPS/POPRC.6/13/Add.2) or PS foams compacted;
2.
(d)
Construction waste management facilities;
(e)
Textile and furniture waste management facilities;
(f)
EPS compaction processes;
(g)
WEEE management facilities;
(h)
Waste vehicle management facilities.
Low-risk situations
105. For information on lower risk situations, see subsection IV.I.2 of the general technical
guidelines.
21
J.
Emergency response
106. Emergency response plans should be in place for HBCD chemical in production (where
allowed), in use, in storage, in transport and at disposal sites. Further information on emergency
response plans is given in section IV.J of the general technical guidelines.
K.
Public participation
107. Parties to the Basel or Stockholm Convention should have an open public participation
process. For further information see section IV.K of the general technical guidelines.
22
Annex to the technical guidelines
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