1
Austria
Federal Ministry of Agriculture, Forestry, Environment and Water Management
Sonja Löw
30/11/2014
Austrian comments on
Guidance on BAT and BEP for the recycling and disposal of articles containing
Polybrominated diphenyl ethers (PBDES) listed under the Stockholm Convention on
Persistent Organic Pollutants (draft March 2014)
Comment ref. to page 37 - XRF Technology - Austrian experience
Austria requires continuous measurements of plastics from WEEE where the presence of
brominated flame retardants cannot be excluded, especially in the case of housings for CRTs
(monitors, TV), if plastic wastes shall be subject to material recycling.
Some Austrian dismantlers use XRF technology (handhelds) for this separation. In the
amendment of the Austrian Waste Treatment Obligation Ordinance a limit value of 800 mg
bromine /kg d.s. will be fixed which correlates with a limit of 1000 mg of the sum of PBDE/kg
d.s. and is based on the worst case assumption that all the detected bromine is caused by
PBDEs.
An Austrian study report: "Determination of levels of polybrominated biphenyls (PBBs) and
polybro-minated diphenyl ethers (PBDEs) in visual display units", prepared by
theMontanistic University Leoben(2012) as a result of a large-scale study to determine the
levels of PBBs and PBDEs in visual display units concludes that about 15% of plastic waste
from TV housings and about 47% plastic waste from PC-casings show significantly higher
levels of PBDEs than 0,1%.
The effectiveness of XRF measurement has been presented by Ms. Alexia Aldrian
(Montanuniversitaet Leoben - Waste Processing Technology and Waste Management) at the
ISWA world congress 2013. Waste plastic of 3000 pieces of black TV and 1600 pieces of grey
PC were analysed. The average distribution of bromine content was the following:
In case of TV: 85% below 1000ppm Br, 4% 1001-6000 ppm Br; 4% 9001-50000 ppm Br; 2%
50001-70000 ppm Br, 5% > 70001 ppmBr
In case of monitors: 53% below 1000 ppm Br, 6% 1001-6000 ppm Br; 2% 9001-50000
ppmBr, 17% 50001-70000 ppmBr, 22% 70001 ppm Br.
2
Austria
Federal Ministry of Agriculture, Forestry, Environment and Water Management
Sonja Löw
30/11/2014
The presence of brominated flame retardants in TV sets andPC monitors was confirmed by
means of handheld XRF technique.The handheld XRF is the only method available that allows
the operator todecide on the recycling quality of the sample in real time and on site.
The precision as well as accuracy were sufficient.Handheld XRF are a quite expensive
acquisition, but the maintenance costs are manageable.
According to information gained from industry the acquisition costs for XRF handhelds are
around € 15.000-25.000,- (depending on whether the XRF can also measure other parameters such as heavy metals) . The costs for additional necessary software for bromine
determination in plastics by means of XRF ranges between € 2.500-3.000,-.The endeavours
with regard to the measuring process result in additional costs of around 30-40,--€/ton.
Cheaper XRF handhelds require longer measurement time (10-15 sec per measurement),
more expensive appliances only need around 3-4 sec per measurement. When using the
XRF-handheld, radiation protection regulations have to be obeyed. As thebeam, which
permeates the plastic containing BFR has a range of around 15m the measurement is carried
out in a way that the beam vertically penetrates the plastic part to be measured.
This study underlines the importance of constant monitoring of PBDE and PBB in TV and PC
waste plastic and concludes that the evaluation of bromine content based on brand or type
of TV/PC monitors is not possible.A visual distinction or separation based on specific
manufacturers, colors or models cannot solve the problem.Handheld XRF was proven to be
a quite effective tool and allows fast monitoringof large volumes of waste plastics within
short amounts of time.
The use of stationary XRF requires also some measures of reconstruction in order to comply
with radiation protection requirements and therefor is much more expensive (detailed date
not data).et
General Comment on Chapter 2 Background Information on POP-PBDES
It would be advisable to mention the latest developmentsin European Legislation.
Amendment of the EU-POP Regulation No. 850/2004
The Amendment ofAnnexes IV and V of the EU-POP Regulation recently was adopted and
foresees a limit value of 1000 mg/kg for the sum of the PBDE-congeners: Tetra, Penta,
Hexa, HeptaBDE. Wastes exceeding this limit are to be considered POP-wastes, which must
not be recycled any more. A recycling of plastics containing PBDEs could be foreseen in the
non-electronics sector (ohterwise limits of ROHS-Directive are to be obeyed) only, where a
proof is given that the exceedance of the limit value is caused by Deca-BDE, which has not
been limited yet. In practise however the costs of a permanent analytical measurementof
the PBDE-congeners will render material recycling uneconomical.
For the POP-PBDE-wastes therefore incineration with energy recovery or maybe
depolymerisation could be suitable treatment options.
3
Austria
Federal Ministry of Agriculture, Forestry, Environment and Water Management
Sonja Löw
30/11/2014
In exceptional cases, wastes listed in Annex V, part 2 of the EU-POP Regulation containing or
contaminated by any substance listed in Annex IV up to concentration limits specified in
Annex V, part 2, may be otherwise dealt with in accordance with a method listed in Annex V,
part 2 (e.g. special landfills, storage in underground salt mines). As the EU POP-Regulation
does not list plastic wastes or shredder light fractionsin Annex V part 2 alternative disposal
(such as landfilling or underground storage in salt mines) is not allowed any more in the
future.
Classification as hazardous waste in the EU
Recently the Commission Decision amending Decision 2000/532/EC on the list of waste
pursuant to Directive 2008/96/EC was adopted. The fact that wastes exceed thelimit value
for PBDE (and all the other recently listed “new” POPs) and are to be classified as POP-waste
in the meaning of the EU-POP Regulation does not trigger automatically the classificationas
hazardous waste according to EU-legislation (in contrast to wastes containing the “old”POPs
in an amount exceeding the POP-limit, which are automatically classified as hazardous
waste). This means that Member States shall lay down limit values for the classification of
wastes exceeding the limits for the “new” POPs as hazardous waste at national level.
In this context it should be borne in mind that if a limit value is fixed for the classification of
this waste as hazardous waste, the ban on export of hazardous waste to Non-OECD
countries will apply. It seems thatincineration in the EUmay take place in incinerators for
hazardous waste only, as the EU-Incineration Directive lays down that, if wastes with a
content of more than 1% of halogenated organics substances (expressed as “chlorine”) are
incinerated, the temperature has to be raised to 1100 °C for at least two seconds, which is
not the case in municipal waste incineration facilities.
It is unclear, whether the term “chlorine” might be interpreted as a restriction of this provision to organo-chlorine
compounds only, or whether the term ”halogenated organic substances” prevails (= Austrian view), which would also cover
organo-F, Cl, Br, I-compounds .
The incineration in cement kilns might be a solution to the extent that those wastes do not
exceed internal limits of the cement industry (prevention of corrosion).
Austrian legislation
For several years now the transboundary shipment of plastic waste containing more than
1000 mg/kg of PBDE (sum of all PBDEs, including also DecaBDE) has been subject to a
notification procedure in Austriaon the basis of national interpretation ofthe Annexes of the
EU-Waste Shipment Regulation 1013/2006 and in order to assess the environmentally sound
recovery (recycling) of these wastes. In Austria a provision in the Austrian Waste Treatment
obligation Ordinance has been implemented, which requires that wastes containing
brominated flame retardants may be recycled in accordance with chemicals legislation and
the EU-POP-Regulation in areas only where these flame retardants are required in the
product for technological reasons (e.g. production of park benches would be admissible, as
flame retardants are required according to technical standards, but the manufacture of hair
4
Austria
Federal Ministry of Agriculture, Forestry, Environment and Water Management
Sonja Löw
30/11/2014
combs would be prohibited, as flame retardants are not and should not be distributed into
products where nobody expects them).