rohs annex ii d ossier for hbcdd - umweltbundesamt · rohs annex ii dossier for hbcdd 10 january...

Substance Name: Hexabromocyclododecane

EC Number(s): 247-148-4 and 221-695-9

CAS Number(s): 25637-99-4 and 3194-55-6

Major diastereoisomers identified:

alpha-hexabromocyclododecane CAS No 134237-50-6

beta-hexabromocyclododecane CAS No 134237-51-7

gamma-hexabromocyclododecane CAS No 134237-52-8

(the latter numbers are more correct from a chemical point of view as far as the positions of the bro-mine atoms are specified; the first numbers are also used by industries for commercial use)

January 2014

ROHS ANNEX II DOSSIER FOR HBCDD

Restriction proposal for hazardous substances in electrical and

electronic equipment under RoHS

ROHS Annex II Dossier for HBCDD

January 2014 3

CONTENTS

CONTENTS ........................................................................................... 3

1 IDENTIFICATION, CLASSIFICATION AND LABELLING, LEGAL STATUS AND USE RESTRICTIONS ......................................................................... 5

1.1 Identification .......................................................................................... 5

1.1.1 Name, other identifiers and composition of the substance ..................... 5

1.1.2 Physico-chemical properties ................................................................... 7

1.2 Classification and Labelling Status .................................................... 8

1.3 Legal status and use restrictions ...................................................... 10

2 USE OF THE SUBSTANCE ..................................................... 11

2.1 Use and function of HBCDD ............................................................... 11

2.2 Use of HBCDD in EEE ......................................................................... 11

2.3 Quantities of HBCDD used in EEE .................................................... 12

3 HUMAN HEALTH ..................................................................... 14

3.1 Human health hazards ........................................................................ 14

3.2 Endpoints of concern ......................................................................... 14

3.3 Existing guidance values ................................................................... 18

4 ENVIRONMENT ....................................................................... 19

4.1 Environmental fate properties ........................................................... 19

4.2 Environmental hazard ......................................................................... 21

4.2.1 Eco-toxicity studies ............................................................................... 21

4.2.2 Potential for secondary poisoning ......................................................... 22

4.3 Existing Guidance values (PNECs) ................................................... 23

4.4 Preliminary DNEL derivation .............................................................. 23

5 WASTE MANAGEMENT OF ELECTRICAL AND ELECTRONIC EQUIPMENT .................................................... 27

5.1 Description of relevant waste streams ............................................. 27

5.1.1 WEEE categories containing HBCDD ................................................... 27

5.1.2 Relevant waste materials/components containing HBCDD .................. 27

5.2 Waste treatment processes applied to WEEE containing HBCDD ................................................................................................. 28

5.2.1 Treatment processes applied ................................................................ 28

5.2.2 HBCDD flows during treatment of WEEE ............................................. 29

5.2.3 Treatment processes selected for an assessment under RoHS ..................................................................................................... 32

5.3 Releases of HBCDD from selected WEEE treatment processes ............................................................................................. 33

5.3.1 Shredding .............................................................................................. 33


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5.3.2 Recycling ...............................................................................................36

5.3.3 Summary of releases from WEEE treatment ........................................38

6 EXPOSURE ESTIMATE ........................................................... 39

6.1 Human exposure .................................................................................39

6.1.1 Exposure estimates of workers of EEE waste processing plants .....................................................................................................40

6.1.2 Monitoring of human exposure at EEE waste processing plants .....................................................................................................42

6.2 Environmental exposure ....................................................................43

6.2.1 Exposure estimates for the environment due to WEEE treatment ...............................................................................................43

6.2.2 Monitoring data: WEEE treatment sites/locations .................................47

7 IMPACT ON WASTE MANAGEMENT ..................................... 50

7.1 Impacts on WEEE management as specified by Article 6 (1) a .......................................................................................................50

7.2 Estimate of risks for workers and neighbouring residents ............51

7.3 Risks estimate for the environment ..................................................51

8 ALTERNATIVES ...................................................................... 53

8.1 Availability of substitutes / alternative technologies ......................53

9 DESCRIPTION OF SOCIO-ECONOMIC IMPACTS ................. 56

9.1 Approach and assumptions ...............................................................56

9.2 Impact on flame retardant and plastics producers..........................56

9.3 Impact on EEE producers ..................................................................58

9.4 Impact on EEE users ..........................................................................59

9.5 Impact on waste management ...........................................................60

9.6 Impact on administration ...................................................................60

9.7 Total socio-economic impact .............................................................62

10 RATIONALE FOR INCLUSION OF THE SUBSTANCE IN ANNEX II OF ROHS ............................................................ 64

11 REFERENCES ......................................................................... 70

12 ABBREVIATIONS .................................................................... 76

13 LIST OF TABLES ..................................................................... 78

14 LIST OF FIGURES ................................................................... 80


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1 IDENTIFICATION, CLASSIFICATION AND LABELLING, LEGAL STATUS AND USE RESTRICTIONS

1.1 Identification

1.1.1 Name, other identifiers and composition of the substance

Table 1: Substance identity and composition (Source: ECHA, 2008)

EC number: 247-148-4a and 221-695-9b

EC name: Hexabromocyclododecane and 1,2,5,6,9,10-hexabromocyclododecane

CAS number (in the EC in-ventory):

25637-99-4a and 3194-55-6b

CAS number: 25637-99-4a and 3194-55-6b

134237-50-6 134237-51-7 134237-52-8

CAS name: Hexabromocyclododecane and

1,2,5,6,9,10-hexabromocyclododecane

alpha-hexabromocyclododecane

beta-hexabromocyclododecane

gamma-hexabromocyclododecane

IUPAC name: Hexabromocyclododecane

Index number in Annex VI of the CLP Regulation

602-109-00-4

Molecular formula: C12H18Br6

Molecular weight: 641.7

Synonyms: Cyclododecane, hexabromo; HBCD; Bromkal 73-6CD; Nikkafainon CG 1; Pyroguard F 800; Pyroguard SR 103; Pyroguard SR 103A; Pyrovatex 3887;Great Lakes CD-75P™; Great Lakes CD-75; Great Lakes CD75XF; Great Lakes CD75PC (compacted); (Dead Sea Bro-mine Group Ground FR 1206 ILM; Dead Sea Bromine Group Standard FR 1206 I-LM; Dead Sea Bromine

Group Compacted FR 1206 I-CM)c; FR-1206; HBCD ILM; HBCD IHM


6 January 2014

Table 1 (continued)

Structural formulac

Degree of purity The amount of unknown constituents/contaminants var-

ies (0-5 %) and one identified constituent is tetrabromo-

cyclododecane.

Remarks There are three main chiral diastereomers present in

technical HBCDD, which are α-

hexabromocyclododecane (CAS No 134237-50-6),

beta-hexabromocyclododecane (CAS No 134237-51-7),

gamma-hexabromocyclododecane (CAS No 134237-52-

8).

Depending on the producer technical grade HBCDD

consists of approximately 70-95 % γ-HBCDD and 3-30

% of α- and β-HBCDD due to its production method.

Two additional diastereoisomers, δ-HBCDD and

ε–HBCDD were found in lower concentrations

(0.5 and 0.3, respectively).

The composition of HBCDD diastereomers is likely to

differ not only between products from different manufac-

turers, but also between different products of a single

manufacturer (e.g., HBCD-ILM (high-melting) and

HBCD-IHM (low-melting) (ECHA, 2008).

a refers to hexabromocyclododecane (without specifying the bromine positions) and is used mainly

by industry for commercial purposes; b refers to 1,2,5,6,9,10-hexabromocyclododecane (bromine

positions are specified) and is therefore more specific from the chemical point of view; c The

formula depicts 1,2,5,6,9,10-hexabromocyclododecane.


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1.1.2 Physico-chemical properties

Table 2: Physico-chemical properties of HBCDD (Source: ECHA, 2008, EC, 2008)

Property Value

Physical state at 20°C and 101.3 kPa

White odourless solid

Melting/freezing point Ranges: 172-184°C to 201- 205°C

α-HBCDD: 179-181 °C

β-HBCDD: 170-172 °C

γ-HBCDD: 207-209 °C

Boiling point Decomposes at >190°C

Relative Density 2.38g/cm3 at 20°C

2.24g/cm3

Vapour pressure 6.3 10-5 Pa (21°C)

Water solubility Water:

α-HBCDD: 48.8±1.9 µg l-1

β-HBCDD: 14.7±0.5 µg l-1

γ-HBCDD: 2.1±0.2 µg l-1

Sum of above (HBCC technical product): 65.6 µg l-1

Water-salt medium:

α-HBCDD: 34.3 µg l-1

β-HBCDD: 10.2 µg l-1

γ-HBCDD: 1.76 µg l-1

Sum of above (HBCC technical product): 46.3 µg l-1

Water:

γ –HBCDD: 3.4±2.3 µg l-1

Partition coefficient n-octanol/water (log POW)

α-HBCDD: 5.07 ± 0.09

β-HBCDD: 5.12 ± 0.09

γ-HBCDD: 5.47 ± 0.10

Technical product: 5.625

Flash point n.a.

Flammability n.a.

Explosive properties n.a.

Oxidising properties n.a.

Auto flammability Decomposes at >190°C


8 January 2014

1.2 Classification and Labelling Status

The Classification, labelling and packaging (CLP) regulation1 requires compa-nies to classify, label and package their substances and mixtures before placing them on the market.

The regulation aims to protect human health and the environment by means of labelling to indicate possible hazardous effects of a particular substance. It should therefore ensure the proper handling, including manufacture, use and transport of hazardous substances.

A proposal for harmonised classification and labelling based on the CLP Regu-lation (EC) No 1272/2008, Annex VI, Part 2 was submitted by the Swedish Chemicals Agency in 2009. Since 10 July 2012 HBCDD has been listed in An-nex VI of the Regulation (EC) No. 1272/2008 as Repro 2, Lact (for details see Table 3).

In addition to the harmonised classification, HBCDD has been classified as Aquatic Acute 1 and Aquatic Chronic 1 (Hazard class H400 and H410) by nu-merous manufacturers and/or importers as indicated in the C&L inventory pro-vided by ECHA2.

In accordance with Directive 67/548/EEC HBCDD is classified as Repr. Cat 3; R63 (possible risk of harm to the unborn child) R64 (may cause harm to breast-fed babies) and labelled with Xn; R 63 - 64; S36/37-53.

1 Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification,

labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006

2 for details see: http://echa.europa.eu/web/guest/information-on-chemicals/cl-inventory-database

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Table 3: Harmonized classification of HBCDD1

Index No

International Chemical Identifica-tion

EC No CAS No Classification Labelling Spec. Conc. Limits, M-factors

Notes

Hazard Class and Category Code(s)

Hazard statement code(s)

Pictogram, Signal Word Code(s)

Hazard state-ment code(s)

Suppl. Hazard statement code(s)

602-109-00-4

Hexabromo-cyclododec-ane [1]

1,2,5,6,9,10- hexabromo-cyclododec-ane [2]

247-148-4 [1]

221-695-9[2]

25637-99-4[1]

3194-55-6[2]

Repr. 2

Lact.

H361 H362 GHS08 Wng H361 H362

-- -- --

1 Classification according to part 3 of Annex VI, Table 3.1 (list of harmonized classification and labelling of hazardous substances), of the CLP Regulation (EC) No 1272/2008 of the European

Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures.


10 January 2014

1.3 Legal status and use restrictions

REACH regulation3

HBCDD has been identified as a Substance of Very High Concern (SVHC), meeting the criteria of a PBT (persistent, bio-accumulative and toxic) pursuant to Article 57(d) of the REACH regulation. On February 17, 2011 the European Commission decided to include HBCDD in Annex XIV to the REACH regulation. Specific authorisation for HBCDD will be required for a manufacturer, importer or downstream user to place the substance on the market, use it in preparations or for the production of articles.

Stockholm Convention

In 2008 the Government of Norway, as a Party to the Stockholm Convention, submitted a proposal to list HBCDD in Annex A to the Stockholm Convention. The Persistent Organic Pollutants Review Committee (POPRC) of the Stock-holm Convention concludes that HBCDD meet the characteristics defined in Annex D. In May 2013 the Conference of Parties (COP) decided during the sixth meeting of the Conference of the Parties to the Stockholm Convention4 to amend part I of Annex A to list HBCDD with specific exemptions for production and use in EPS and XPS in buildings.

Interference REACH and Stockholm Convention

The European Commission has taken the decision to opt-out on a temporary basis from the listing of HBCDD under the Stockholm Convention as the sub-stance is covered by Union legislation (REACH).Therefore, in line with Article 25 (2) of the Convention and the Declaration of Competence submitted by the EU, it is for the Commission to communicate to the Secretariat on behalf of the EU the intention to temporarily opt-out from the Decision on HBCDD (EC, 2013). Finally, the EU must opt-in again to the Decision as soon as it is possible once the legal conflict with the EU acquis has seized to exist, which presently is expected to be possible in August 2015 subject to the proceedings of the au-thorisation process.

WEEE Directive5

Most relevant in the context of HBCDD is the provision of the EU WEEE Di-rective to remove plastics containing brominated flame retardants from any separately collected electrical and electronic equipment. Furthermore, the re-moval of printed circuit boards of mobile phones generally, and of other devices if the surface is > 10 cm2 and of external electrical cables, which may also con-tain HBCDD to a minor extent, is requested.

3 Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December

2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH).

4 28 April – 10 May, 2013 5 Directive 2012/19/EU of the European Parliament and of the Council on waste electrical and elec-

tronic equipment (WEEE) (recast)


January 2014 11

2 USE OF THE SUBSTANCE

2.1 Use and function of HBCDD

HBCDD is solely used as an additive flame retardant, with the intent of delaying ignition and slowing subsequent fire growth (IOM, 2009). It can be used on its own or in combination with other flame retardants.

In general HBCDD is mainly used in four different applications:

� Expandable Polystyrene (EPS);

� Extruded Polystyrene (XPS);

� High Impact Polystyrene (HIPS) � relevant for EEE

� Polymer dispersion for textiles.

According to SWEREA (2010) some other uses of HBCDD have been reported. For example, the use of HBCDD in polypropylene (PP), adhesives, latex bind-ers and unsaturated polyester has been reported in the USA. A minor use of HBCDD in PP was reported by industry. HBCDD can be used in adhesives and coatings and in SAN resins (styrene-acrylonitrile copolymer). It may also be used in polyvinylchloride (PVC) products, such as wires, cables and textile coat-ings.

2.2 Use of HBCDD in EEE

HBCDD is used in EEE in plastic parts made of HIPS. The main applications of flame retardant HIPS are in housings of appliances such as television sets, au-dio-videos and personal computers but it has also been mentioned to be used for electrical boxes and wire fittings, electrical appliance parts, business ma-chines, and interior parts of refrigerators (DEPA, 2010).

According to DEPA (2010) there are indications that on the European market housings of computer monitors generally do not seem to be made of HIPS, but of acrylonitrile butadiene styrene (ABS) or co-polymer of polycarbonate (PC)/ABS due to their higher impact strength and resistance to cracking. It is al-so stated that major European manufacturers of TV sets seem to be using co-polymers such as PC/ABS, PS/PPE or PPE/HIPS6 either without flame retard-ants, or with non-halogenated flame retardants.

HIPS with flame retardants7 account for 14 % of the global plastic consumption for flat panel TV sets.

6 Such copolymers have a higher inherent resistance to burning and spreading a fire, because they

form an insulating char foam surface when heated. Further they have higher impact strength. 7 The remainder are 33% HIPS without flame retardants, 42% PC/ABS, 10% modified PPE and 1%

other (General Electric, 2006, cited in DEPA, 2010)

Main uses of

HBCDD

Minor uses of

HBCDD

Main uses of

HBCDD in EEE


12 January 2014

Recent analyses of waste flat panel screens described by SALHOFER ET AL. (2012) showed that in PC monitors 1.7% of all polymers contained brominated flame retardants8. In TV screens 8.6% of all polymers contained brominated flame retardants9.

2.3 Quantities of HBCDD used in EEE

Information on the overall consumption and production of HBCDD in the EU is available from several pieces of work conducted in the context of the application of the REACH Regulation.

According to IOM (2009) the annual consumption in the EU in 2007 was esti-mated to be 11,000 tonnes, of which the larger part (70-90%) is applied in EPS and XPS polymers for building insulation materials. Less than 10% (1,100 t/y) is used in HIPS and an estimated 2% (220 t/y) is used for back coating of flame retardant textiles.

It has been estimated by Öko-Institut (2008) that approximately 210 t of HBCDD are used annually in EEE products in the EU.

Information on imports and exports of HBCDD in formulations and articles, however, is available only fragmentarily. In particular, EEE imports from third countries will have a significant impact on the quantities of HBCDD in the EU. According to DEPA (2010) this is notably the case for small household appli-ances, consumer electronics, IT equipment, and toys etc., but also for other EEE groups.

For estimating the quantity of HBCDD entering the European market via EEE the following assumptions were made:

Only HBCDD in HIPS was considered10.

Different sources report a HBCDD-content in HIPS between 1 - 7 % (w/w) (IOM, 2009). As a worst case scenario a content of 7% was assumed – like in the Risk Assessment Report for HBCDD (EC, 2008a).

SWEREA (2010) expects that around 10% of the total polystyrene producers ap-ply HBCDD in their end products. According the European Brominated Flame Retardants Industry panel11 5 per cent of all HIPS in the EU is made flame re-tardant with HBCDD. Representatives of the European flame retardant associa-tion - EFRA estimate that meanwhile far less than 5% of HIPS contain HBCDD. However, no data on the percentage of HBCDD in HIPS for EEE was provid-ed12. For the present assessment it is assumed that 5% of HIPS in EEE contain HBCDD.

According to VKE (2003) 14% of all plastics in EEE are HIPS.

According to a literature review conducted by EMPA (2010) HIPS is used in EEE as follows: in cooling and freezing appliances (95,000 t/a), small electronic

8 another 1.7% of the polymers were none flame retardant PS 9 another 14.3% of the polymers were non flame retardant PS 10 Minor uses of HBCDD in PP, PVC etc. were not considered. 11 Cited in KemI (2006) cited in DEPA (2010) 12 EFRA (2013) Stakeholder contribution in the context of elaborating this document

HBCDD quantity in

European EEE


January 2014 13

appliances (111,000 t/a), consumer equipment without screens (CRT monitors or flat screens) (100,000 t/a), CRT monitors (39,000 t/a) and TV sets (120,000 t/a). Relevant amounts are furthermore used in large household appliances oth-er than cooling and freezing appliances and in IT equipment other than screens. According to the authors these figures are characterized by significant uncer-tainties.

Thus, for the purpose of the present assessment the HBCDD quantity entering the European market via EEE was estimated as follows:

In 2010 9.4 Mio tonnes of EEE were placed on the market in the EU stat13). Assuming a plastic content in EEE of 30% of the appliance´s weight14 an overall amount of 1,400 tonnes

15 of HBCDD entering the European market via

flame retardant plastic parts in EEE is assumed for the present assessment. Representatives of EFRA assume a range of 50-200 tonnes of HBCDD in EEE based on the above mentioned. However, no basis data was provided12.

13Waste Electrical and Electronic Equipment (WEEE) statistics (env_waselee): http://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_waselee&lang=de; extracted August 2011 14 See e.g. Schlummer et al (2007) 15 9,400,000 * 0.3 *0.14*0.05*0*07=1,382 t


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3 HUMAN HEALTH

3.1 Human health hazards

Different official bodies have assessed the toxicity and human health risk relat-ed to HBCDD exposure (e.g., EC, 2008a; ECHA, 2008; ECHA, 2010b, EFSA, 2011). The main outcome of these assessments is summarized below, whereas the endpoints of concern are depicted in more detail in chapter 3.2. For more background information and further reading, the reader is referred to the original documents.

The acute toxicity of HBCDD is low. The oral lethal dose is >20g/kg bw in rats and >10g/kg bw in mice. Furthermore, toxicological studies revealed that the compound is not corrosive, irritating or sensitizing to the skin (EC, 2008a).

HBCDD lacks genotoxic potential in vitro and in vivo. Based on reported data and the absence of mutagenicity it is concluded in the EU risk assessment re-port (RAR) that there are no indications to further study the carcinogenic effect of HBCDD (EC, 2008a).

Sub-chronic and chronic toxicity studies identified liver, thyroid, prostate, repro-ductive, nervous and immune system as the main targets of HBCDD’s toxicity (ECHA, 2008; EFSA, 2011). The repeated dose toxicity studies revealed a NOAEL of 22 mg/kg/day based on changes of the liver weight (ECHA, 2008).

Since substances which have adverse effects on the reproductive system have to be subjected to a harmonised classification according to the CLP regulation, a proposal for harmonised classification and labelling was submitted by Sweden in 2009 The risk assessment committee (RAC) adopted the opinion for a har-monised classification in 2010 (ECHA, 2010b). HBCDD is listed in Annex VI of the CLP regulation as Repr. 2 (H361) and Lact. (H361).

3.2 Endpoints of concern

HBCDD exposure has an impact on the reproductive system and developmen-tal system. Furthermore, liver, thyroid, prostate and the immune and nervous system have been identified as targets of HBCDD toxicity.

Studies carried out to investigate toxicity effects of HBCDD on the developmen-tal and reproductive system include a two-generation study (Ema et al., 2008), a one-generation study (van der Ven et al., 2009), a one-generation developmen-tal study (Saegusa et al., 2009), as well as neurodevelopmental studies (Lilien-thal et al., 2007, Eriksson et al., 2006). The main findings of these studies and deduced toxicological values (such as no observed adverse effect levels – NO-AELs, lowest observed adverse effect levels - LOAELs, bench mark dose - BMD) are summarised in Table 4.

The one and two-generation studies have shown increased postnatal mortality, delayed physical development, and alterations in the weight of internal organs in offspring (Ema et al., 2008, van der Ven et al., 2009, Saegusa et al. 2009) at dose levels inducing mild maternal toxicity. Based on the available data, it can-

Outcome of hazard

assessment(s) in

brief

Acute toxicity

Carcinogenicity

Repeated dose

toxicity studies

Reproductive and

developmental

system

Adverse effects on

development and

fertility


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not be excluded that prenatal developmental alterations contribute to these postnatal manifestations (ECHA, 2010a).

The outcome of the study of Ema et al. (2008) indicates potential effects of HBCDD on fertility - such as reduction of primordial follicles in ovaries of F1 generation females in the medium and high dose exposure levels.

Studies in rodents indicate that HBCDD exposure during development affects the nervous system and causes subsequent behavioural changes. The results of the study of Eriksson et al. (2006) provide the lowest observed doses at which an adverse effect has been observed. Male mice were exposed to a dose of 0.9 or 13.5 mg/kg bw of technical HBCDD on post natal day (PND)10. Be-havioural effects such as changes in rearing, locomotion and habituation in re-sponse to a novel environment were already observed at a dose level of 0.9 mg/kg bw. Neurodevelopmental effects were also observed in F1 and F2 off-spring at the highest dose level of approximately 1000 mg/kg bw in a two gen-eration study carried out by Ema et al. (Ema et al., 2008). In a one generation study with Wistar rats reduced latencies to movement at exposure levels of 0.6-4.4 mg/kg bw and for increased thresholds in the brainstem auditory evoked po-tentials were observed at 0.2-0.9 mg/kg bw per day. In rat offspring from dams that were exposed from gestational day (GD) 10 until PND10 effects on oli-godendroglial development were observed at the highest dose levels of 10,000 mg/kg feed (Saegusa et al., 2009).

Effects of repeated dose toxicity studies indicate effects of HBCDD on the thy-roid and the liver, as well as effects on the prostate. A NOAEL for repeated dose toxicity of 22 mg/kg bw based on the increased liver weight has been de-duced (ECHA, 2008).

The increased liver weight is assumed to be related to an induction of liver en-zymes. The effects of HBCDD on the thyroid system are thoroughly discussed in the EU RAR (EC, 2008a). It is assumed that also the effects on the thyroid system are related to liver enzyme induction, however, there is still some uncer-tainty regarding the mode of action.

Evidence that orally administered HBCDD has an impact on the immune system comes from a 28-day repeated dose toxicity study carried out by van der Ven (van der Ven et al., 2006) and from a one-generation reproductive study (van der Ven et al., 2009) (for details see EFSA, 2011). Decreased splenocytes counts were observed in the 28-day repeated dose study and the whole white blood fraction; in the one-generation study the lymphocyte counts were de-creased as well as. Furthermore, a decreased thymus and popliteal lymph node weight and an enlarged spleen zone were observed in the one-generation study with rats.

Table 4 summarises the toxicity values as well as the major findings of animal studies conducted to investigate the effect of HBCDD on development, fertility and the endocrine system (e.g., thyroid hormones). The respective studies have been thoroughly assessed and are described in the EU risk assessment report (EC, 2008a).

Neurodevelopmental

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Outcome of

repeated dose

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Table 4: Main findings of developmental and repeated-dose toxicity studies (Source: EFSA, 2011, ECHA, 2008)

Study type Species Application and exposure levels

Findings LOEL(*) NOEL(*) BMDL* Reference

Developmental Toxicity Studies

Two-generation study (according to OECD guideline 416 and GLP)

Crl:CD(SD) rats Orally; in the diet. 0, 150, 1,500 or 15,000 mg/kg diet 10-14, 101-141, or 1,008-1,363 mg/kg bw day

Decrease in fertility index in F0 and F1 animals Decrease in ovary primordial follicles in F1 females Decreased thyroid follicle size Increase of thyroid weight in F0 and F1 animals Decrease in serum T4 in all animals Increase in serum TSH in F0 and F1 females

1,500 mg/kg diet (100 mg/kg bw)

150 mg/kg diet (10 mg/kg bw)

-- Ema et al., 2008

One-generation study (according to OECD 415)

Wistar rats

Orally; in the diet. 0.1; 0.3; 1; 3; 10; 30 and 100 mg/kg bw per day in the feed. Exposure before mating till 11 weeks of age of F1.

Decrease in testes weight Increased anogenital distance (PND4) Delayed vaginal opening Increased IgG response Decreased trabecular bone mineral density (females) Decreased in apolar retinoids

-- -- Testes: BMDL5 11.5 mg/kg bw per day IgG response: BMDL20: 0.46 mg/kg bw per day Bone mineral density: BMDL10 0.056 mg/kg bw per day Retinoids: BMDL10 1.3 mg/kg bw per day

van der Ven et al., 2009

1-generation devel-opmental toxicity study (no guideline study)

Pregnant Spra-gue-Dawley rats

Orally; in the diet. 100, 1,000 and 10,000 mg/kg diet 8-21, 81-213, or 803-2231 mg/kg bw/day From mid-gestation through lactation

Reduced number of CNPase-positive oligodendroglia in the cortex Increased relative thyroid weight in male Thyroid follicular cell hyper-trophy Decreased serum T3

1,000 mg/kg diet (81-213 mg/kg bw/day)

100 mg/kg diet (8-21 mg/kg bw/day)

-- Saegusa et al., 2009

One-generation re-productive study (ac-cording to OECD 415)

Wistar WU (CBP) rats

Orally; in the diet. 1.43, 4.29, 14.3, 42.9, 143, 429, 1,430 mg/kg in diet 0.1, 0.3, 1, 3, 10, 30, 100 mg/kg bw Before mating to 11 weeks

Brainstem auditory evoked potential alterations sugges-tive for cochlear defect Reduced latency to move af-ter haloperidol

-- -- Brainstem auditory evoked po-tential: 1-6.3 mg/kg bw per day Catalepsy: 0.6-4.4 mg/kg bw per day

Lilienthal et al., 2009 (in addition to main publication of van der Ven et al., 2009)

Developmental Neu-rotoxicity study

NMRI mice Orally, via gavage, single dose.

Behavioural disturbances 0.9 mg/kg bw -- -- Eriksson et al., 2006

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Study type Species Application and exposure levels

Findings LOEL(*) NOEL(*) BMDL* Reference

0.9 or 13.5 mg/kg bw/ day PND10

Repeated dose toxicity studies

90-day oral toxicity study

Sprague Dawley rats

Orally; via gavage; 100, 300 or 1,000 mg/kg bw per day

Thyroid effects: Decrease in serum T4 Increase in TSH Thyroid follicular cell hyper-trophy Increased thyroid weight (fe-males) Increase in relative prostate weight Liver effects: Liver weight increase in both sexes

300 mg/kg bw per day

100 mg/kg bw per day

Chengelis et al, 2001

28-day study Wistar rats Orally; via gavage; 0.3, 1, 3, 10, 30, 100 and 200 mg/kg bw per day by gavage

Thyroid effects: Increased thyroid weight (fe-males) Decreased total T4 Increased TSH immunostain-ing and weight pituitary Liver effects: Increased hepatic capacity of T4 UGT (f) Increased liver weight (fe-males)

--- NOAEL/BMD-L 22.9 mg/kg bw (**) – liver weight in-crease (hepati-tis enzyme in-duction)

Increased thyroid weight: BMDL10: 1.6 mg/kg bw per day T4 decrease: BMDL10

: 55.5 mg/kg bw per day Pituitary weight: BMDL10 29 mg/kg bw per day Splenocyte count: BMDL20 104 mg/kg bw per day T4 UGT: BMDL10: 4.1 mg/kg bw per day Liver weight: BMDL20: 23 mg/kg bw per day

Van der Ven et al., 2006

LOEL: lowest-observed-effect level; NOEL; no-observed-effect level; BMD(L): benchmark dose (limit); TSH: thyroid-stimulating hormone; T4: thyroxine; T3: triiodothyronine UGT: UDP;

glucuronosyltransferase; RSV: respiratory syncytial virus; GD: gestational day; PND: postnatal day; * deduced by EFSA, 2011;

** deduced by EC, 2008a


18 January 2014

3.3 Existing guidance values

An overview of how the international occupational exposure limits (OELs) have been derived is provided by the European Agency for Health and Safety at Work (EU-OSHA, 2013). The database of hazardous substances provided by the Institute for Occupational Safety and Health of the German Social Accident Insurance (GESTIS, 2013) does not contain any international limit values. The European Scientific Committee on Occupational Exposure Limits (EU-SCOEL, 2013) has not derived any OEL either. . Neither are OELs and threshold limit values (TLVs) for HBCDD given in the International Chemical Safety Card -ICSC database, which was prepared in the context of cooperation between the International Programme on Chemical Safety and the European Commission16.

16 http://www.cdc.gov/niosh/ipcsneng/neng1413.html

International limit

values


January 2014 19

4 ENVIRONMENT

An in-depth evaluation of the environmental fate properties and adverse effects on the ecological system of HBCDD was published in the frame of the Europe-an risk assessment reports in 2008 (EC, 2008a).

In the following section the environmental fate properties are described and compared with the Persistence Bioaccumulation and Toxicity (PBT) criteria laid down in Annex XIII of the REACH regulation, as well as with the criteria indicat-ed in Annex D ,of the Stockholm Convention (POPs criteria) (Table 7).

The predicted no effect levels (PNEC) described in chapter 4.3 have been pre-viously deduced within the EU RAR (EC, 2008a).

4.1 Environmental fate properties

HBCDD has a very high bio-accumulative potential and it has been proven that HBCDD is persistent in the environment. There is a large set of measured data indicating that HBCDD is biomagnified in the environment.

HBCDD meets the characteristics of a global persistent organic pollutant (POP) according to the Stockholm Convention criteria defined in Annex D as a persis-tent, bioaccumulative and toxic (PBT) substance defined in the REACH regula-tion (Annex XIII). A brief summary of these evaluations is given below.

On 18 June 2008 a proposal to add HBCDD to Annex A to the Stockholm Con-vention was submitted by the Government of Norway (NCM, 2008). After vari-ous foreseen evaluation steps, the conference of parties (COP) during its sixth meeting (May 2013) decided to include HBCDD in Annex A to the Stockholm Convention (UNEP, 2013).

HBCDD is persistent and bio-accumulative and hence meets the criteria stipu-lated in the Stockholm Convention. Furthermore, HBCDD has a potential for long-range environmental transport and has adverse effects on organisms.

A brief summary of the evaluation is given in Table 5. Documents for further readings are provided on the website of the Stockholm Convention17, on which the reviewing process of HBCDD is documented in a transparent way.

17 Substances, which have been reviewed within the Stockholm Convention

http://chm.pops.int/Convention/POPsReviewCommittee/Chemicals/tabid/243/Default.aspx

HBCDD a global

POP


20 January 2014

Table 5: Persistent organic pollutant (POP) characteristics of HBCDD

Criterion Findings

Persistence Half-life of HBCDD in water exceeds 60 days. Data sediment cores indicate slow degradation

HBCDD is found to be widespread in the global environ-ment. High levels of HBCDD are found in Arctic top preda-tors.

Data indicate that HBCDD levels increase temporally in biota.

Bioaccumulation Log Kow is more than 5 (estimated to be 5.62).

BCF of 18,100 (fish studies).

BMF higher than 1 (aquatic ecosystems).

Higher HBCDD levels in top predators

Potential for long-range environmental transport

Estimated atmospheric half-life of HBCDD is two to three days.

HBCDD is found widespread in Arctic environment and has been detected in Arctic air.

Adverse effects HBCDD is highly toxic to aquatic species (72h EC50 of 52 µg/L for Skeletonema costatum, NOEC of 3.1 µg/l for Daphnia magna).

HBCDD causes reproductive, developmental and neuro-toxic effects in mammals and birds (NOEC, NOAEL in the order of 1 mg/kg/day).

HBCDD is a substance of very high concern (SVHC) meeting the PBT criterion defined under the REACH regulation (Annex XIII). An assessment as to wheth-er these criteria are met was carried out in 2008.

The following table summarises the parameters characterising the environmen-tal fate properties of HBCDD.

Table 6: Environmental parameters in comparison with PBT1 and POPs

2 criteria

Parameter Outcome PBT criteria (ac-cording REACH, Annex XIII)

POPs criteria (Stockholm Convention)

Half life

air soil

> 2 ds 210 ds

> 2 ds > 120 ds

- >180 ds

Log Kow 5.62 -- >5

Bio-concentration factor 18,100 (fish) >2,000 l/kg >5,000 l/kg

T criterion A 21d-NOEC of 3.1 µg/l has been derived for Daphnia magna

The long-term no-observed effect con-centration (NOEC) for marine or fresh-water organisms is less than 0.01 mg/l

Toxicity or eco-toxicity data that indicate a poten-tial for damage to

human health or to the environ-ment

1 defined in Annex XIII of the REACH-regulation;

2defined in Annex D of the Stockholm Convention

PBT Substance


January 2014 21

4.2 Environmental hazard

4.2.1 Eco-toxicity studies

HBCDD studies with aquatic species indicate a high toxicity (72h EC50 of 52 µg/L for Skeletonema costatum and a NOEC of 3.1 µg/l for Daphnia magna).

Based on these findings and on evidence from mammalian studies, it can be concluded that the toxic criterion (REACH) is met and also the defined criteria stipulated in Annex D of the Stockholm convention to possess adverse effects on environmental organism.

Results of the eco-toxicity testing described in the EU RAR are described in Ta-ble 7 below (EC, 2008a).

Table 7: Findings of eco-toxicity studies (Source: EC, 2008a)

Species Method Results1

Aquatic compartment: Fish

Onchorhyncus mykiss (Rainbow trout)

OECD 203 and TSCA 40/797/1400, and ASTM Stand-ard E729-88a

No mortalities or other effects around 2.5 µg/l.

Oncorhynchus mykiss (Rain-bow trout)

Flow-through OECD 210 and OPPTS 850.1400

NOEC : Hatching success ≥3.7 µg/l; Swim-up ≥3.7; Larvae and fry survival ≥3.7; Growth ≥3.7

Aquatic compartment: Invertebrates

Daphnia magna (Water flea)

OECD 202. Static

immobilisation test, and

TSCA 40/797/1300, and

ASTM Standard E729-88a

48 h EC50 >3.2 µg/l

Daphnia magna (Water flea)

TSCA , OECD

Flow-through 21-day test.

NOEC 3.1 µg/l

LOEC length 5.6 µg/l

Aquatic compartment: algae

Selenastrum capricornutum OECD 201 and

TSCA40/797/1050

96 h EC50 >2.5 mg/l

Skeletonema costatum

Thallassiosira pseudonana

Chlorella sp.

Marine algal bioassay

method, different marine

growth media

72 h EC50 =

9 µg/l (lowest value)

72 h EC50 =

40 µg/l (lowest value)

96h EC50 >water solubility

Skeletonema costatum OECD 201, ISO

10253:1995 and EU

Directive 92/69/EEC

Method C.3

NOEC <40.6 µg/l

EC50 >40.6

Skeletonema costatum OECD 201 NOEC >10 µg/l

EC50 52 µg/l

Sewage treatment plant: microorganisms

Microorganism; activated sludge

Respiration inhibition; OECD 209

EC50 15 mg/l; Limit test with one test concentra-tion, EC50 is estimated.

Main conclusion

from eco-toxicity

studies


22 January 2014

Table 6 continued)

Species Method Results

Sediment compartment: Invertebrates

Hyalella Azteca (Amphipod) Sediment toxicity test 28-day ex-posure period under flow-through conditions.

LOEC >1000 mg/kg dwt of sediment

NOEC 1000 mg/kg dwt of

sediment.

Lumbriculus variegatus (Worm)

28d- sediment bioassay LOEC = 28.7 mg/kg dwt

NOEC = 3.1 mg/kg dwt

Normalized:


Chironomus riparius (Mosqui-to)

28d- sediment bioassay

Egg production of F

generation

LOEC = 159 mg/kg dwt


Normalized:


Terrestrial compartment: Soil microorganisms

Soil microorganisms Nitrogen transformation

test

OECD 216

NOEC > 750 mg/kg dry

soil

Terrestrial compartment: Plants

Zea mays (corn), Cucumis sativa (cucumber), Allium ce-pa (onion), Lolium perenne (ryegrass), Glycine max (soybean), and Lycopersicon esculentum (tomato)

Seedling emergence, survival, height

21 days

OECD 308 (proposal for revi-sion), 850.4100 and 850.4225 (public drafts)

NOEC >5000 mg/kg dry

soil

Terrestrial compartment: Invertebrates

Eisenia fetida (Earthworm) Survival and reproduction,

56 days

OECD 207 proposal and

OPPTS 850.6200

NOEC 128 mg/kg dry soil

Normalized:

NOEC 59 mg/kg dry soil

(EC50 771 mg/kg dry soil)

1 bold values have been used within the RAR to deduce PNEC values.

4.2.2 Potential for secondary poisoning

Secondary poisoning is a phenomenon related to toxic effects which might oc-cur in higher members of the food chain resulting from ingestion of organisms from lower trophic levels that contain accumulated substances. Thus, chemicals which have bioaccumulation and biomagnification properties within the food chain pose an additional threat.

HBCDD accumulates in organisms such as fish. Therefore, fish feeding mam-mals and birds are exposed to HBCDD. In addition, predators feeding on ma-rine mammals and birds are highly exposed to HBCDD.

Based on the data assessed in the EU RAR the PNEC for secondary poisoning is 5 mg HBCDD/kg wet food (EC, 2008a).

A comparison of measured HBCDD levels in fish and marine mammals shows that they are mostly below the estimated PNEC.

Secondary

poisoning


January 2014 23

However, the PNEC value is uncertain and there are numerous studies indicat-ing HBCDD concentrations (e.g. in marine mammals, eel and brown trout) high-er than the estimated PEC (EC, 2008)

It is concluded that even though the PNEC for secondary poisoning is uncertain there is a potential for secondary poisoning of e.g., predatory mammals and birds as indicated by measured concentrations (EC, 2008; ECHA, 2008).

4.3 Existing Guidance values (PNECs)

The predicted no effect concentration (PNEC) is the concentration below which exposure to a substance is not expected to cause adverse effects to species in the environment. Therefore, the determination of these values is important for further risk evaluation.

Based on the eco-toxicity studies described in Table 7 the following PNECs have been estimated (EC, 2008a), which are used in the present assessment for further risk characterisation (details see chapter 7.3).

Table 8: Deduced predicted no effect concentrations (PNECs) for different

compartments (Source: EC, 2008a)

Compartment NOEC Safety factor PNEC

Aquatic compartment

Aquatic Compartment 3.1 µg/l 10 0.31 µg/l

Intermittent release; aquatic Compartment

50 µg/l 100 0.5 µg/l

Marine Environment 30 µg/l 100 0.03 µg/l

Intermittent release, marine environment

50 µg/l 1000 0.05 µg/l

Sediment 8.6 µg/l 10 0.86 mg/kg dwt

Sediment, marine environ-ment

8.6 µg/l 50 0.17 mg/kg dwt

Micro-organisms in sewage treatment plants

15 mg/l 100 0.15 mg/l

Terrestrial compartment

Terrestrial Compartment 59 mg/kg dwt 10 5.9 mg/kg dwt

Atmospheric compartment

Atmosphere -- -- No PNEC derivation

Secondary poisoning

Secondary poisoning 150 ppm 30 5.0 mg/kg food

4.4 Preliminary DNEL derivation

So far, no derived no effect levels (DNELs) have been deduced for HBCDD by official bodies. Therefore, within the present assessment preliminary DNELs will be estimated based on the REACH Guidance (ECHA, 2012c).

PNECs for different

compartments


24 January 2014

Within the REACH regulation the DNEL (derived no effect level) approach has become an important method to further characterise a possible risk. Due to ab-sence of relevant human studies the DNEL is in most cases deduced from stud-ies with laboratory animals.

Within the present assessment the study of Eriksson et al. (2006) demonstrat-ing a negative impact of HBCDD administered to mice at PN10 on the neurode-velopmental behaviour of off-spring at a dose level of 0.9 mg/kg bw is consid-ered for further risk characterisation.

A recent assessment from EFSA also used the study of Eriksson et al. (Eriks-son et al., 2006) as a basis for human risk characterisation (EFSA, 2011). Alt-hough there are several drawbacks and uncertainties inherent to the use of the single-dose administration study, the EFSA Panel stated that arguments for the use of the study include the fact that the results indicate that even the lowest doses cause effects and that the study covers a relevant neurodevelopmental period, which merits particular consideration. The EFSA Panel concluded that due to the uncertainties in the database an application of the margin of expo-sure approach is more appropriate than the deduction of a tolerable daily intake (TDI).

Within the present assessment the authors consider the study of Eriksson et al. (2006), because it shows negative effects already at low HBCDD concentra-tions. Therefore, the most sensitive endpoint can be deduced from this study (neurobehavioral changes). To select the most sensitive endpoint for DNEL der-ivation is well in line with ECHA’s guidance for DNEL derivation (ECHA, 2012c). Furthermore, we used the BMDL10 of 0.93 mg/kg bw as previously calculated by EFSA as point of departure, which is a more appropriate dose metric for comparing the effects between animals and humans.

Besides the application of an assessment factor for inter- and intraspecies dif-ferences, for which default values given in the REACH guidance have been used (ECHA, 2012c), an assessment factor of 3 for LOAEL to NOAEL extrapo-lation has been applied. Thus, the applied factor for workers is 150 and for the general population 300.

Furthermore a difference in the absorption between rats (85%) and humans (100%) has been taken into consideration for deducing the oral LOAEL. This assumption has also been considered by EFSA (EFSA, 2011). Therefore, the corrected oral LOAEL is 0.79 mg/kg bw/day (calculation: 0.93 mg/kg bw * 0.85). The calculated DNEL (long-term) for the general population is estimated to be 0.0026 mg/kg bw/day.

The oral LOAEL (rat) was converted into a dermal corrected LOAEL (human) by correcting differences in absorption routes (5% absorption is assumed for the dermal route). A further correction regarding exposure during 5 days a week in-stead of 7 days a week has been made to derive a dermal DNEL for workers.

The oral LOAEL in rats was converted into an inhalation corrected LOAEC (in mg/m3) by using a default value for respiratory volume for the rat corresponding to the daily duration of human exposure (general population: 0.79 mg/kg bw/day / 1.15 m3/kg bw, workers: 0.79 mg/kg bw/day / 0.38 m3/kg bw x 6.7 m3/10 m3) (ECHA, 2012c).

Point of departure

Assessment factors

Preliminary DNEL

oral

Preliminary DNEL

dermal

Preliminary DNEL

inhalation


January 2014 25

Preliminary derived no effect levels (DNELs) for workers and the general popu-lation for the oral, dermal and inhalation routes are presented in Table 9.


26 January 2014

Table 9: Preliminary derived no effect levels (DNELs) deduced for the present

assessment

Assessment Factors

Workers General population

(Adults& Children)

Interspecies, AS* 4 4

Interspecies, remaining differences 2.5 2.5

Intraspecies 5 10

Dose response (LOEAL to NOAEL ex-trapolation)

3 3

Quality of database 1 1

Applied Factor* 150 300

ORAL

Absorption (%) 100% 100%

LOAEL (corrected) (not relevant) 0.79

DNELs ORAL in mg/kg/d (not relevant) 0.0026

DERMAL


LOAEL (corrected) 11.3* 15.8

DNELs DERMAL in mg/kg/d 0.075 0.052

INHALATION


Standard respiratory volume in m3/kg bw per day

0.38 1.15

LOAEL (corrected) 1.39 0.69

DNECs INHALATION in mg/m3 0.009 0.002 *correction for exposure duration has been made (5 days for workers instead of 7 days) (for details on DNEL derivation method see: ECHA, 2012c)


January 2014 27

5 WASTE MANAGEMENT OF ELECTRICAL AND ELECTRONIC EQUIPMENT

5.1 Description of relevant waste streams

5.1.1 WEEE categories containing HBCDD

DEPA (2010) compiled an overview of the presence of HBCDD flame retardant parts in the 10 WEEE categories specified in Annex I to the WEEE Directive.

Taking into account additional information on HBCDD applications in EEE (see Chapter 2) and data on HBCDD contents analysed in WEEE (see Chapter 5.1.2 below) the following can be concluded regarding the presence of HBCDD in WEEE (12).

Table 10: Presence of HBCDD in the 10 WEEE categories as specified by Annex I to the WEEE Directive (Source:

DEPA, 2010, adapted by Umweltbundesamt)

WEEE Category Insulation board of EPS or XPS

HIPS cabi-nets/ hous-ings

HIPS wire fit-tings

Brominated epoxy / PCBs*

PVC / ca-bles

1. Large household appliances possible x possible x (minor)

2. Small household appliances x possible x (minor) x (minor)

3. IT and telecommunications equipment

x (main) possible x (minor) x (minor)

4. Consumer electronics x (main) possible x (minor) x (minor)

5. Lighting equipment possible possible x (minor) x (minor)

6. Electrical and electronic tools (ex-cept large-scale stationary industrial)

possible possible x (minor) x (minor)

7. Toys, leisure and sports equip-ment

possible possible x (minor) x (minor)

8. Medical devices x possible x (minor) x (minor)

9. Monitoring and control instruments including industrial

x possible x (minor) x (minor)

10. Automatic dispensers possible possible possible x (minor) x (minor)

X…presence of HBCDD

*…PCBs…printed circuit boards

5.1.2 Relevant waste materials/components containing HBCDD

The main application of HBCDD in EEE is the use in HIPS for housings. For the purpose of the present assessment it is therefore assumed that nearly 100% of HBCDD used in EEE (i.e. 1,400 tonnes, c.f. Chapter 2) are contained in the ma-terial stream “plastics”.

Main materials/

components


28 January 2014

Only minor amounts can be expected in the fractions “printed circuit boards“18 and “cables”19.

5.2 Waste treatment processes applied to WEEE containing HBCDD

5.2.1 Treatment processes applied

5.2.1.1 Initial treatment processes

Usually the initial treatment of separately collected WEEE of the relevant cate-gories containing HBCDD (in particular IT&T, consumer electronics and large household appliances) is either manual dismantling or mechanical separation in a shredder process. The latter may be performed in large-scale metal shredders20 or in special shredders dedicated to the treatment of particular types of WEEE.

Manual dismantling allows for separation of rather homogenous material frac-tions, including plastic housings. Shredder processes are in many cases com-bined with different types of automated material sorting.

IPTS (2013) refer to a study of ADEME demonstrating a growing trend of WEEE dismantling during the last few years. EC (2007) has estimated that there are 1300 WEEE dismantling installations and mixed scrap processors in the EU25.

WEEE ending up in the unsorted municipal waste is likely to be incinerated or land-filled. In MSW, especially small appliances which are easily thrown into a waste bin are found.

WEEE, which are not reported may either be home-stored or shipped out of the EU - be it as waste or as “used goods”. No information on the actual fate of these WEEE is available (may be any controlled or uncontrolled treatment).

5.2.1.2 Subsequent treatment processes

HIPS components, in particular housings and inner linings, resulting from dis-mantling of WEEE are assumed to be sent to recycling processes to a major ex-tent.

The WEEE-Directive requests the separation of flame retardant plastics from WEEE during their treatment21.

However, there is evidence22 that such a separation is not made comprehen-sively and that the plastics parts remain unsorted. 22.

18 Concentrations of 10 mg/kg HBCDD were measured in printed circuit boards from small WEEE by

Morf et al (2004). Assuming a 3% share of PCBs in EEE (see Huisman, 2007), the quantity of HBCDD in printed circuit boards derived from WEEE is estimated to account for 2.8 tonnes

19 Concentrations of 25 mg/kg HBCDD were measured in copper cables from small WEEE by Morf et al (2004). Assuming a 2% share of cables in EEE19 the quantity of HBCDD in cables derived from WEEE is estimated to account for maximum 4.7 tonnes (Estimation based on sorting anal-yses of small WEEE (Salhofer & Tesar, 2011)

20 Often called car shredders 21 In practice such a separation of flame retardant plastics from mixed WEEE plastics may be per-formed by analysis of the presence of Br using easy to handle techniques (XRF).

Minor materials/

components

Treatment of

separately collected

WEEE

Treatment of WEEE

ending up in

unsorted MSW

Treatment of WEEE

shipped to third

countries

Recycling of

plastics housings


January 2014 29

According to IPTS (2007) the most common treatment option for styrenics from housings and inner shelving & linings of cooling appliances consists of several steps of cleaning and inserts removal, the (automated) identification of poly-mers/additives and the sorting into regrind compatible fractions for repro-cessing.

For the purpose of the present assessment it is assumed that HBCDD contain-ing HIPS derived from dismantling, i.e. large plastic parts including housings, are subjected to recycling. This includes the processing of waste plastics by physical means (grinding, shredding, and melting) back to plastic products. It involves cutting, shredding, sorting, separation of contaminants, floating, melt-ing, extrusion, filtering, pelletizing. Process additives such as curing agents, lub-ricants and catalysts may be added to improve processing, as well as dyes and correction agents to re-establish the properties of the plastic in case the original additives have reacted or decomposed.

Plastics containing fractions resulting from shredding of WEEE as the initial treatment are usually either:

� Land-filled in the form of unsorted shredder residue

� incinerated (incineration or co-incineration)

� treated in further mechanical treatment processes, including so called Post-shredder processes

� thermal / chemical / physical processes” like pyrolysis/gasification and de-polymerisation/solvolysis

Subsequent treatment of secondary wastes in third countries may be recycling, landfilling, dumping or combustion.

5.2.2 HBCDD flows during treatment of WEEE

To evaluate which waste treatment processes are of relevance with regard to potential HBCDD releases and to estimate these releases, the following scenar-io for the treatment of HBCDD containing WEEE under current operational con-ditions was established:

It is assumed that the HBCDD-input into waste management by WEEE corre-sponds to the total quantity of HBCDD put on the European market via EEE23, i.e. 1,400 tonnes annually. Actual WEEE generation at a given time, e.g. based on models taking into account the life-time of particular equipment, was not considered for the present assessment.

To estimate the flows of HBCDD entering particular treatment processes, the following aspects were taken into account:

� the rate of separate collection of WEEE

� the rate of (illegal) shipment to third countries

22 enforcement experiences in the context of transboundary waste shipment, Austrian analyses of plastic fractions from dismantling of TV and monitors; (personal communication Austrian Ministry of Agriculture, Forestry, Environment and Water Management) 23 Based on 9.4 Mio EEE put on the market in 2010

Treatment of

shredder residues

Treatment of

secondary wastes

resulting from

WEEE treatment in

third countries

Waste management

scenario for HBCDD

containing WEEE


30 January 2014

� the share of individual treatment processes applied to the relevant waste streams

The treatment scenario was established on the basis of European WEEE statis-tics (Eurostat, WEEE data for 201024), assumptions made by EC (2008b) based on figures for 2005 and on own estimations.

WEEE treated in WEEE treatment plants in the EU

44 %25 of the total WEEE arising26 are treated in WEEE treatment plants in the

EU (i.e. 4.1 Mio t/a).

Taking into account also the composition of WEEE reported to be separately collected (Eurostat, WEEE- statistics27) it is assumed that these are composed of:

� 61% (2.5 Mio t/a) large household appliances (assumed treatment: 80% shredder process; 20% manual dismantling)

� 7% (0.29 Mio t/a) small household appliances (assumed treatment: 100% shredder)

� 17% (0.7 Mio t/a) IT&T appliances including screens (assumed treatment: 70% dismantling, 30% shredder)

� 15% (0.65 Mio t) consumer electronics incl. screens (assumed 30% disman-tling, 70% shredder)

Thus for separately collected WEEE an overall share of 72% of shredding and 28% of dismantling are assumed.

WEEE contained in unsorted MSW

13 % of the overall WEEE arising is not separately collected but ends up with unsorted MSW (i.e. 1.2 Mio t/a).

It is assumed that 2/3 of MSW in the EU are landfilled, 1/3 incinerated28.

WEEE whose fate is not known

41 % of the overall WEEE arising (3.9 Mio t) are unaccounted for and are as-sumed to be shipped to third countries to an unknown degree.

WEEE Re-Use

24

Eurostat: Waste Electrical and Electronic Equipment (WEEE) statistics (env_waselee); extracted

August 2013 25 WEEE reported to be collected separately, including also 11% of WEEE (particularly large house-

hold appliances) not reported to be separately collected but treated by the same processes as comparable appliances reported as separately collected.

26 For the purpose of the present assessment the amounts of WEEE arising are assumed to be equal to the amounts put on the market

27 The shares of individual categories in the amounts reported to be separately collected were used 28 See for example EEA (2013)

Assumptions


January 2014 31

A small share of an estimated 2% of WEEE is assumed to be re-used. This share is neglected within the present assessment.

Treatment of housings

It is assumed that dismantling results in a complete removal of HBCDD contain-ing parts, mainly housings.

The whole quantity of the housings derived from manual dismantling of WEEE is subjected to recycling.

Treatment of shredder residues

It is assumed that the whole HBCDD input into shredders is transferred to shredder residues.

It is further assumed that two thirds of generated shredder residues are land-filled, the remaining third is incinerated. Recycling of a minor fraction of plastics derived from shredding is considered to play a minor role.

Taking into consideration the material composition of WEEE, for example as published by HUISMAN ET AL (2007), and using the same estimates for the quan-tities of HBCDD in EEE as described in Chapter 2.329 the HBCDD quantities undergoing the main treatment processes were estimated (see Table 11 be-low).

Table 11: Estimated quantities of HBCDD undergoing the main treatment processes for WEEE and secondary

wastes derived thereof (in tonnes per year)

WEEE (1,400) Secondary wastes

Separately collected

WEEE

WEEE in unsorted

MSW

WEEE shipped out

of the EU

Large plastic parts (hous-ings) derived from disman-

tling

Shredder residues

Secondary wastes from uncontrolled

WEEE treatment in third coun-tries (incl. )

Re-Use minor (28 tonnes)

Manual dismantling ~179

Shredding (and auto-mated sorting)

~437

Landfilling (EU) ~122 ~ 292

Incineration (EU) ~ 6 ~ 145

Recycling ~ 179

Uncontrolled treatment in third countries (can be dismantling, combustion, dumping, recycling)

~574

29 14% of WEEE plastics are HIPS, 5% of all HIPS contain HBCDD, concentration of HBCDD in

HIPS = 7% as a worst case � average HBCDD concentration in WEEE = 0.015%

HBCDD input into

WEEE treatment

processes


32 January 2014

5.2.3 Treatment processes selected for an assessment under RoHS

In order to focus on those processes, where risks for workers or the environ-ment are most likely to be expected, the following treatment processes were se-lected for the present evaluation of potential risks:

� Mechanical treatment in shredders, because it is applied to HBCDD con-taining parts of WEEE at several stages in the overall treatment chain at a large number of installations/locations.

� Recycling of HIPS because it is a process applied to plastic parts removed from WEEE (HIPS-housings) in considerable amounts and the recycling of plastics in general is expected to increase in future.

The following treatment processes were NOT taken into account for a quantita-tive risk characterization within this assessment:

� Manual dismantling, because, as there is neither a mechanical nor a ther-mal treatment, releases to air, water and soil are assumed to be low (specific information on releases from / exposure through manual dismantling is not available)

� Land-filling, because WEEE or materials derived thereof are not the main source for HBCDD in wastes usually.

Polymers containing HBCDD accumulate on landfill sites. Degradation of the matrix will sooner or later lead to a release of the substance from the matrix. Besides, bio-degradation of HBCDD in the landfill will limit potential future emissions. HBCDD is regularly found in particulate but also in the dissolved phase of landfill leachate30. Estimates of overall releases of HBCDD to the environment from landfills were made in the context of the RAR HBCDD (EC, 2008a). Occupational exposure to HBCDD at managed landfill sites is likely to be very low (IOM 2009).

� Incineration under controlled conditions, because WEEE or materials de-rived thereof are usually not the main source of HBCDD in wastes. Further-more, a well-functioning emission control is assumed.

� Treatment processes under uncontrolled conditions, because WEEE or materials derived thereof are usually not the main source of HBCDD in wastes.

Uncontrolled incineration may result in potential emissions of incineration residues of unknown chemical composition, which may pose risks for health and environment at local compartments. If the uncontrolled incineration pro-cess takes place at temperatures below 200°C there is a possibility that HBCDD containing particles are emitted (Swerea, 2010).

In case of uncontrolled fires (accidental fire) and at co-combustion at lower temperatures or not well functioning incinerators there is a risk of formation of polybrominated dibenzo-dioxins and –furans (PBDDs and PBDFs) (EC 2008, RAR HBCDD).

30 According to DE BOER et al. (2002) the particulate phase of leachate in nine Dutch landfills con-

tained 15-22 000 µg HBCDD/l. In the study of FJELD et al. 2005 from landfills in Norway, the con-centrations in untreated leachate collected from 10 sites were considerably lower with 0.0002-0.15 µg HBCDD/l (UNEP 2011)

Relevant processes

Less relevant

processes


January 2014 33

5.3 Releases of HBCDD from selected WEEE treatment processes

Below information on and estimates of HBCDD releases from the selected pro-cesses are summarized.

5.3.1 Shredding

The most important route of HBCDD from shredding of WEEE or plastics mate-rials thereof is considered to be via emissions of dust.

Emissions from shredders are typically abated by dust removal in a cyclone and a wet scrubber. According to the BAT-Reference Document for the Waste Treatment Industries (BREF WTI) (IPPC, 2006) generic emission levels for dust (PM) associated with the use of BAT are in the range of 5-20 mg/Nm3. Howev-er, treatment of metal wastes, including WEEE, in shredders has been recently included into the scope of IED-Directive. Information on the actual dust emis-sions from shredders under current operational conditions is scarce31.

From EC (2007) estimates of the quantities of diffuse emissions of dust are available. They estimate an overall annual release of PM10 from European car shredders of 2,100 tonnes resulting from manipulation of fluff and fines. This is based on a generation of fines/dust from materials treated in a shredder of 18% and an emission factor of the dry material of 1 g/kg.

MORF ET AL (2004) calculated transfer coefficients for HBCDD during treatment of small WEEE using a combination of dismantling and mechanical treatment32.

In order to estimate HBCDD releases via diffuse emissions of dust during ma-nipulating material streams at sites where WEEE are shredded, the following assumptions were made:

� The total input of HBCDD into WEEE shredders was estimated to account to 437 t/a (compare HBCDD flows in Table 11)

� 94% of the HBCDD input into a WEEE shredder are transferred to fluff/fines/dust33

� 0.1% of fluff/fines/dust are emitted diffusely via PM10 (under dry conditions, wetting of the material and other measures to prevent diffuse emissions will reduce the percentage by one order of magnitude)34

31 Dust concentrations between 1.3 and 18.7 mg/Nm3 were reported for German shredders (BDSV,

2012) 32 It was found that 28% of the total HBCDD were removed by dismantling of housings of TV and PC

screens representing only 3% of the WEEE input, 57% were transferred to a fine plastics fraction representing 20% of the WEEE input, 7% were transferred to a fine metallic fraction, 4% to dusts representing 7% of the WEEE input, 3% in a fraction of Cu-cables and 1% in a fraction of printed wiring boards.

33 Basis for the assumption: Morf et al (2004) 34 EC (2007)

Info on releases

Assumptions

concerning diffuse

emissions


34 January 2014

The overall quantity of HBCDD emissions via diffuse dust emissions from sites where WEEE are shredded in Europe is estimated to range from 41.1 kg/a

35 to 411 kg/a

36. The actual order of magnitude depends on the degree to which BAT for preventing diffuse emissions from handling of shredded materials including e.g. encapsulation of aggregates, wettening of materials etc. is applied.

Having in mind that not all shredders in the EU apply BAT, the estimate of HBCDD emitted after de-dusting is based on the upper value for BAT-AELs, i.e. 20 mg/Nm3. Furthermore, an exhaust air flow of 20,000 Nm3/h37 and a treatment capacity of 60 tonnes of WEEE per hour38 was assumed.

Furthermore, it was assumed that the HBCDD concentration in dust is 60% of the HBCDD concentration in the WEEE processed39.

Based on these assumptions40 the total HBCDD releases via residual dust emissions are about 1.78 kg/a.

In order to estimate the HBCDD releases per installation and day the pro-cessing of WEEE in large-scale metal shredders was used as a reference. The following assumption was made:

� Typical daily WEEE throughput in a large-scale shredder is 250 tonnes41

Based on the resulting daily HBCDD input per installation of 37.7 kg and using the release factors as illustrated above the following HBCDD releases per in-stallation and day are estimated:

� 3.5 to 35.4 g of HBCDD are emitted diffusely

� 0.15 g of HBCDD are emitted after de-dusting of channelled emissions.

In general there is a tendency to further process mixed shredder residues with the aim to recover valuable metals and also to achieve legally binding recycling targets. In order to obtain recyclable metal-rich concentrates, several automated sorting techniques are used. These include various types of mechanical treat-ments, such as shredding, milling, etc., where dust is generated. It is assumed that not all of those installations are equipped with efficient dust prevention techniques. Additional HBCDD releases via dust from processing of shredder residues in such installations are likely.

Emissions to water and soil from shredding are considered to be negligible.

35 RFair…0.094 g/kg 36 RFair…0.94 g/kg 37 E.g. described by Ortner (2012) 38 Umweltbundesamt (2008) 39 Morf et al 2004 report a HBCDD concentration in dust of 10 mg/kg compared to 17 mg/kg in the

processed WEEE 40 RFair…0.004 g/kg 41 Capacities of Austrian ELV-shredders: 25 – 60 t/h, assumption 7 working hours per day

Estimates of diffuse

emissions

Assumptions

concerning

emissions

Estimates of

channelled

emissions

Releases per

installation and day

Further

considerations


January 2014 35

Treatment of WEEE in large-scale metal shredders is a highly automated pro-cess, where workers primarily manipulate the material outdoors using various work machines, partly sitting in closed cabins.

Figure 1: Large-scale metal shredder plant (Source: Umweltbundesamt, 2008)

Other mechanical processes for WEEE treatment including e.g. horizontal cross flow shredders or special drums may be completed by manual sorting of the dis-integrated appliances along a conveyer belt. The air at these indoor work places may be extracted or not. Usually workers are required to use masks to prevent them from inhaling the dust. Iit is assumed, though, that the practical implemen-tation leaves room for improvement .

Figure 2: Manual sorting of disintegrated WEEE (Source: Umweltbundesamt, 2008)

There are different options for further mechanical treatment of mixed shredder residues. There are installations where the – mostly encapsulated – aggregates are handled outdoors or partly encased. Thus material manipulation by workers is carried out outdoors or in partly enclosed places with natural ventilation.

Workplace

description

mechanical

treatment of WEEE


36 January 2014

Figure 3: Installation for further treatment of mixed shredder fractions (Source:

Umweltbundesamt, 2008)

Other installations have fully encapsulated grinding and sorting aggregates sit-uated in a closed building with indoor air extraction. The manipulation of the ma-terial is carried out both indoors and outdoors.

5.3.2 Recycling

Comprehensive literature on releases from plastics recycling, such as the OECD Emission Scenario Document on Plastics Additives

42 or the EU RAR on HBCDD43 point out that the situation regarding recycling of waste plastics is cur-rently in a state of flux.

According to the OECD (2009), the following types of plastics recovery are pos-sible:

a) The waste plastics may be sold to specialist companies which clean, grind and market them as clean low grade plastics material. The material may be classified into polymer type and, at the highest level the materials may be com-pounded into other polymers/plastics materials and sold as well specified mate-rials which compete against virgin plastics.

b) The waste plastics may be collected by a specialist manufacturer of plastics products who, after cleaning and compounding, processes them into a particu-lar product. Examples of this include the conversion of some waste from large distributors into plastic film and the use of spent PET bottles to produce polyes-ter staple fibre for use as insulating filler for clothing etc.

Possible releases of HBCDD during recycling of HIPS-parts (e.g. housings) may occur in particular through shredding, cleaning, preparation, melting, pelletizing, transfer and storage and through polymer processing by calendaring, extrusion, injection moulding etc. to form the final plastic products.

Information on actual releases from such complex process chains is not availa-ble. However, as in many of these processes the thermoplastic material is es-sentially melted and reused, the release of additives would be expected to be similar to that which results from the conversion of plastics compounds made from virgin polymers. According to OECD (2009) it is furthermore not known whether extra additives are used when recovered plastics articles are used as the feedstock for new products.

42 OECD, 2009 43 EC, 2008

Info on releases

from HIPS recycling


January 2014 37

When estimating the releases from recycling of HIPS in the present assessment the same release factors as applied to the estimate of releases from the “For-

mulation of PS compound for the manufacture of EPS and/or HIPS” and from the “Industrial use of HIPS compound at the manufacture of flame retarded

HIPS” by the RAR for HBCDD were used:

The release factors for emissions from “Formulation of PS compound for the

manufacture of EPS and/or HIPS” as derived by the RAR 44 are as follows:

� For water: 0.0076% (0.0053% to surface water and 0.0022% to waste water).

� For air: 0.0007 %

According to the RAR for “Industrial use of HIPS compound at the manufacture

of flame retarded HIPS” there is no site-specific information available on actual HBCDD emissions from such processes.

Therefore, the emission factor L3 (conversion, partially-open processes) from the Emission Scenario Document on Plastic Additives, ((OECD, 2004)) was used. For organic flame-retardants this factor is 0.006 %45.

In this scenario, half of the emission is supposed to go to water as a result of wet cleaning of surfaces contaminated with HBCDD and HIPS dust emitted from the process (transport, sawing, and cutting). The other half is assumed to be directed to air as a result of HBCDD and HIPS dust emitted to the air from the process and released to the atmosphere via the ventilation. The resulting emission factors to both water and air are thus 0.003%. The RAR further as-sumes an 80% connection-rate to sewage treatment plants.

Based on a total HBCDD input into HIPS-recycling processes of 179 t annually the following estimates are made:

Formulation of PS compound for the manufacture of EPS and/or HIPS

� Total releases to air: 1.3 kg/a

� Total releases to waste water: 3.9 kg/a

� Total releases to surface water: 9.5 kg/a

Industrial use of HIPS compound at the manufacture of flame retardant HIPS

� Total releases to air: 5.4 kg/a

� Total releases to waste water: 4.3 kg/a

� Total releases to surface water: 1.1 kg/a

In order to estimate the HBCDD releases from recycling per installation and

day the following assumptions were made:

� 50 installations of an average size are involved in the formulation and use of recycled HIPS46 each

44 According to the RAR several pieces of site specific information are available 45 The original reference was not found in the OECD document 46 Basis for the assumption: IPTS (2013): an overall quantity of 50,000 plastics-converters process-es 46 Mio tonnes plastics � average treatment capacity: 1,000 t/a. Amount of HIPS resulting from dismantling of WEEE: appr. 50.000 t/a of HIPS � 50 plants involved.

Assumptions

concerning

emissions

Estimates of total

releases

Estimates of

releases per

installation and day


38 January 2014

� Operation days per year: 220 (see Guidance Document R.18, plastics recy-cling sector, (ECHA, 2012b)

Based on these assumptions it is estimated that the HBCDD releases per instal-lation and day are as follows:

Formulation of PS compound for the manufacture of EPS and/or HIPS

� Releases to air: 0.1 g

� Releases to waste water: 0.35 g

� Releases to surface water: 0.86 g

Industrial use of HIPS compound at the manufacture of flame retardant HIPS

� Releases to air: 0.5 g

� Releases to waste water: 0.4 g

� Releases to surface water: 0.1 g

5.3.3 Summary of releases from WEEE treatment

Table 12: Estimated total HBCDD releases from WEEE treatment processes in the EU (in kg per year)

Air (particulates) diffuse releases

Air (particulates and gaseous)

Water (waste water Water (surface water)

Shredding (and automat-ed sorting)

41.1– 411 1.78

Recycling of HIPS

Formulation of HIPS

1.3 3.9 9.5

Use of HIPS 5.4 4.3 1.1

Total 49,6 - 420 19

Table 13: Estimated local HBCDD releases from WEEE treatment processes in the EU (in g per installation and day)

Air (particulates) diffuse

Air (particulates and gaseous)

Water (waste water Water (surface water)

Shredding (and automat-ed sorting)

3.5 -35.4 0.15

Recycling of HIPS

Formulation of HIPS

0.11 0.35 0.86

Use of HIPS 0.5 0.4 0.1


January 2014 39

6 EXPOSURE ESTIMATE

6.1 Human exposure

Humans are exposed to HBCDD via use of consumer products, indirect envi-ronmental and/or due to occupational exposure.

Humans might be exposed orally via food, by inhaling airborne dust or by der-mal contact. According to EFSA, 2011, non-dietary exposure, mainly through dust in homes, offices, schools, cars and public environment can substantially contribute, and in some cases even dominate the total human exposure to HBCDDs, especially for toddlers and other children. Unborn babies may be ex-posed via blood in the womb and newborns and babies may be exposed via breast-feeding.

It has been shown that HBCDD is present in human matrices, including human breast milk, serum samples and adipose tissue (EC, 2008a; EFSA, 2011).

Furthermore, an increased temporal trend in breast milk levels between 1980 and 2010 was identified based on studies carried out in Sweden (EFSA, 2011). In 1980 the mean HBCDD concentration was around 0.08 ng/g fat, while the levels in 2010 were higher than 0.80 ng/g fat, indicating a 10-fold increase with-in the last 30 years.

An overview on HBCDD levels detected in human breast milk worldwide is giv-en in the supporting document for the draft risk profile on hexabromocyclodo-decane (UNEP, 2010b). Time trend analyses from various countries show an increase in levels in the last decade, as well as higher concentrations in resi-dents from contaminated sites.

A calculation in the EU Risk Assessment Report (EC, 2008a) of HBCDD intake by breast-fed babies gives the following estimates: 15 ng/kg bw/day for 0-3 months old and 5.6 ng/kg bw/day for 3-12 months old babies.

According to EFSA (2011) the reported range for total HBCDD in human milk of 0.13-31 ng/g fat results in daily exposures of 0.60-142 ng/kg bw for breast-fed infants with average human milk consumption (800 ml per day). For infants with high human milk consumption (1,200 mL per day) this is 0.90-213 ng/kg bw, which is considerably higher than the values reported in 2008 in the EU-RAR.

HBCDD has also been found in human plasma and adipose tissue samples. The median concentration was generally not higher than 3 ng/g fat (EFSA, 2011).

Within the review of the classification of HBCDD it was postulated that at pre-sent the potential of HBCDD to affect child development at the observed expo-sure levels is unknown (ECHA, 2010b).

Studies investigating associations of HBCDD contamination levels and adverse effects on human health are scarce.

In epidemiological studies, no association was found between the levels of HBCDDs in blood and bone mineral density in an elderly female population, and between HBCDDs in human milk samples and thyroid-stimulating hormone (TSH) in neonates (EFSA, 2011).

Routes of exposure

Temporal increase

Contamination of

breast milk

Observations in

humans


40 January 2014

However, according to EFSA, 2011, epidemiological studies of HBCDDs with suitable estimates of human exposures are required.

6.1.1 Exposure estimates of workers of EEE waste processing plants

The exposure estimate performed within this assessment is based on the as-sumptions and calculations provided in the chapter waste treatment and releas-es of HBCDD (chapter 5.3.).

Within the frame of the process of registration of substances under REACH several guidance documents and supporting tools for exposure estimation have been introduced.

One of these tools, the TRA (Targeted Risk Assessment) tool has been estab-lished and developed by ECETOC to align with the expectations contained in Chapters R12-R16 of the Technical Guidance on Information Requirements and Chemicals Safety Assessment by ECHA (ECHA, 2013) and is frequently used by industry and also integrated in the Chesar tool, which is provided by ECHA.

Within this assessment the TRA tool 3.0. has been used to estimate exposure of workers.

Two scenarios have been selected as relevant regarding exposure due to waste management operations (see chapter 5.2.).

• shredding of WEEE containing HBCDD, where exposure mainly occurs through dermal uptake and inhalation of dust (see chapter 5.3)

• recycling of WEEE containing HBCDD, including shredding, cleaning and ex-trusion

One limitation of the TRA model is that waste treatment processes are not indi-cated explicitly by the uses and processes which can be selected, as the TRA tool is intended for industrial processes such as manufacture or formulation.

Therefore the most appropriate processes to describe the exposure conditions of waste treatment processes have been chosen.

6.1.1.1 Exposure estimates: Shredding

As described above no category “shredding” can be selected in the TRA tool. In order to define comparable exposure conditions the process category 24: “high (mechanical) energy work-up of substances bound in materials and/or articles” has been selected. Further description of these processes is given in the REACH guidance document R.12: “substantial thermal or kinetic energy applied to substance by hot rolling/forming, grinding, mechanical cutting, drilling or sanding. Exposure is predominantly expected to be to dust” (ECHA, 2010c).

Further selected input parameters: professional use of solid substance with high dustiness, 8 hours activity (>than 4 hours), outdoors, no respiratory protection or gloves (dermal PPE - personal protective equipment). Further 100% of sub-stance in the preparation (>25%) has been applied. The results were then cor-rected taking into account the calculated average HBCDD content of WEEE (Chapter 2.3) and information on transfer of HBCDD to dusts from WEEE

ECETOC TRA

Limitations


January 2014 41

shredding (see Chapter 5.3.1). Thus the average content of HBCDD in the dust of WEEE shredders is estimated at 0.009%. In table 14 the results of the as-sessment are summarized.

Parameter

PROC

Process

category

Long-term

Inhalatory

Exposure Es-

timate

(µg/m3)

Long-term

Dermal Ex-

posure Esti-

mate

(µg/kg/day)

conc. solid 24a 2100.00 2828.57

conc. solid 24b 3500.00 2828.57

conc. solid 24c 14000.00 2828.57

HBCDD 24a 0.19 0.25

HBCDD 24b 0.32 0.25

HBCDD 24c 1.26 0.25

DNEC/DNEL 9.00 75.00

*RCR 24a 0.02 0.0034

*RCR 24b 0.04 0.0034

*RCR 24c 0.14 0.0034

Table 14: Results of the ECETOC-TRA model for exposure and risk of shredding

* RCR: Risk Characterization Ratio

The comparison between exposure and hazard leads to the risk characteriza-tion. Dividing the exposure concentration by the derived hazard value (here: DNEC or DNEL) gives the risk characterization ratio (RCR): a RCR above 1 in-dicates a risk for human health for the mentioned concentration and route of exposure. By comparing the derived exposure concentrations with the above mentioned preliminary derived DNELs and DNECs, respectively, it becomes apparent, that under the assumptions described previously no risk for workers is expected.

However, taking into consideration that other hazardous substances are present in the WEEE shredders, a risk for shredder workers cannot be excluded.

6.1.1.2 Exposure estimates: Recycling

The recycling scenario is based on a series of assumptions and needs to be re-fined if more specific data are available. Several process categories relevant for recycling processes (PROC1, PROC 2, (closed process indoors) PROC3, PROC4, PROC 8a-b (transfer processes), PROC 14 (production) partly with LEV (local extract ventilation) were selected. A content of <1% of HBCDD in the preparation was used as input parameter.

This assessment could be refined if further conditions are reported.

Based on these assumptions a risk for workers has been identified. Maximum RCR (risk characterization ratios) were 4 for-long term exposure through inhala-tion and 9 for long-term dermal exposure.

RCR- Risk

Characterisation

Ratio

Occupational risk

identified


42 January 2014

6.1.2 Monitoring of human exposure at EEE waste processing plants

No studies on exposure conditions of shredders or HIPS recycling facilities have been identified.

Exposure in relation to e- waste treatment is mainly reported from Asia and Afri-ca. Most studies which focus on brominated flame retardants investigated polybrominated diphenyl ethers, only a limited number also dealt with HBCDD.

Higher levels of brominated flame retardants (BFRs) in blood samples of work-ers at e-waste sites compared to workers exposed via other industrial process-es have been identified (Sjödin et al., 1999; Thomson, 2001; Yang et al. 2013).

One study examined the levels of HBCDD in breast milk of mothers living near an e-waste region in Vietnam (Tue et al., 2010). Neighbouring residents of one recycling site were the only group with significant higher levels of HBCDD, whereas non recyclers in that region as well as neighbouring residents of other e-waste recycling sites and residents of Hanoi had lower levels. The levels ranged from 1.4 to 7.6 ng/g lipid wt (recyclers) compared to 0.29 to 1.2 ng/g li-pid wt (non-recyclers). Another human bio-monitoring study from Ghana, which is one of the major dumping grounds for electrical and electronic wastes, shows that HBCDD levels in breast milk from residents of an e-waste contaminated ar-ea are considerably higher than the ones from residents of non e-waste areas (0.030–3.2 ng/g versus 0.010–0.66 ng/g) (Asante et al., 2011).

Studies show also that the exposure levels through indoor dust and air of work-ers or neighbouring residents of e-waste plants are higher than in control groups (Takigami et al., 2006; Tue et al., 2013).

In a recent study carried out by Tue et al. (2013) high HBCDD concentration levels were detected in settled house dusts from houses near e-waste recycling sites. The measured concentration levels were between 5 and 400 ng/g. By comparison, in nearby urban or suburban sites the HBCDD levels ranged from 0.99 to 61 ng/g and were significantly lower. In the same study HBCDD expo-sure levels in air samples were measured. Samples from workers’ houses con-tained no measureable HBCDD. In the back-yards, where e-waste recycling operations, such as manual dismantling, burning wires and circuit, take place, HBCCD were detected in the air at exposure levels of less than 10 pg/m3 (Tue et al., 2013).

Zheng et al. (2012) demonstrate that HBCDD levels in eggs on the e-waste re-cycling sites range from 44 to 350 ng/g lw, which are one to two orders of mag-nitude higher than the ones on the references sites. The estimated uptake of HBCDD via egg consumption is 80-490 ng/day.

It is known that HBCDD as brominated compound can form hazardous degra-dation and incineration products and contributes to the body burden of those populations, which are already at risk (Berkeley Center, 2012).

Dramatic increases in hazardous degradation products in human blood or milk have been found in residents of e-waste regions (Berkeley Center, 2012).

Third countries

Indoor dust/air

samples

Food samples

Hazardous

degradation and

incineration

products


January 2014 43

6.2 Environmental exposure

To define the background levels and to evaluate the environmental fate proper-ties numerous monitoring studies have been conducted in all parts of the world. The available monitoring data have been summarised in the Stockholm Con-vention evaluation to list HBCDD as global POP (UNEP, 2010a) and also in the EU RAR (EC, 2008a).

In general, HBCDD is widespread in the environment, with very high levels in organisms at high trophic levels. HBCDD has been detected in very remote ar-eas, such as in air in northern Sweden and Finland, far from potential sources. Therefore, HBCDD is assumed to undergo long-range atmospheric transport (UNEP, 2010b). Available data from monitoring studies show HBCDD biomagni-fication in marine and aquatic food webs. According to recent evaluations the levels are increasing over time, which might be explained by the growing use of HBCDD (EC, 2008a, UNEP, 2010b).

According to assessments by Covaci et al. 2006, EC, 2008a and UNEP, 2009 HBCDD is detected at higher concentration levels near point sources (e.g., plants producing or processing HBCDD) compared to areas without obvious HBCDD sources. Several European hot spots have been identified, such as the rivers Viskan (Sweden), Tees and Skerne (UK), Cinca (Spain); and the Western Scheldt estuary (Netherlands). These areas are related to (former) production of HBCDD. Covaci et al. (2006) furthermore demonstrated higher contamination near urban centres and industrial sites. According to EFRA only one production site in Terneuzen (the Netherlands) is known47.

Table 15: Comparison of HBCDD contaminated vs not contaminated sites in Europe

(adopted from Zhang, 2009; Source: Covaci et al. 2006)

Not contaminated site Contaminated site

Air 2-740 pg/m3 280 -28 500 ng/m3

Soil n.a 111- 23 200 ng/g dw

Sediment <10 ng/g dw 54-1680 ng/g dw

Aquatic invertebrates 1.3-106 ng/g lw 80-727 ng/g lw

Freshwater fish 12-160 ng/g lw 73-1643 ng/g lw

6.2.1 Exposure estimates for the environment due to WEEE treatment

EUSES 2.0 has been designed as a decision-support system for the evaluation of the risks of new and existing substances and biocides to man and the envi-ronment. For this assessment EUSES 2.1. was used to calculate predicted en-vironmental concentrations, the so called “PECs” for the two scenarios which have been defined as most relevant: shredding and recycling.

In contrary to the ECETOC-TRA system described previously it is possible to select the scenario “waste treatment”. However, no suitable emission tables and

47 www.vecap.info

Global pollutant

Contaminated sites

EUSES

Limitations


44 January 2014

no special scenario to be selected have been integrated into EUSES so far. Therefore the results of this assessment have limitations. In order to ensure transparency the selected input parameters are summarized in Table 16.

Table 16: Selected EUSES input parameters

Descriptor Input

Assessment mode Interactive

Assessment type Local scale

Additional Predators exposed via the environment

Physical chemical properties Physical chemical parameters

Chemical class for Koc-QSAR predominantly hydrophobic

Biodegradability Non-biodegradable

Industry category 4: Electrical/Electronic engineering industry

Use category 22: Flame retardants and fire preventing

agents

Use pattern Waste treatment

Fraction of the main local source 0.02

Number of emission days per year 220

6.2.1.1 Exposure estimates: Shredding

Additional input parameters for the shredder scenario are given in table 17. As a worst case scenario a total of 36 g were assumed as local emissions to the air as presented in table 12 chapter 5.3.3. 437 t/a was assumed as total input of HBCDD in WEEE shredders as production volume.

Table 17: Selected EUSES input parameters: shredding

Descriptor input

Production volume 437

Fraction of the EU production volume in the region 10

Fraction of tonnage released to air 1 (~100%)

Local emissions to air during episode 0.036 kg (max.)

Local STP input Bypass STP

EUSES Input

parameters

Shredding: Input

parameters


January 2014 45

The derived local PECs are given in Table 18 below.

Table 18: Results of environmental assessment using EUSES: shredding

HBCDD concentrations and PECs result unit

Concentration in air during emission episode 6.3 ng/m3

Local PEC in surface water during emission episode (dis-solved)

0.54 µg/l

Annual average local PEC in surface water (dissolved) 0,54 µg/l

Local PEC in fresh-water sediment during emission epi-sode

0,53 mg/kg wwt

Local PEC in seawater during emission episode (dissolved) 0.06 µg/l

Annual average local PEC in seawater (dissolved) 0.06 µg/l

Local PEC in marine sediment during emission episode 0.06 mg/kg wwt

Local PEC in agric. soil (total) averaged over 30 days 1.93 mg/kg wwt

Local PEC in agric. soil (total) averaged over 180 days 1.93 mg/kg wwt

Local PEC in grassland (total) averaged over 180 days 1.93 mg/kg wwt

Local PEC in groundwater under agricultural soil 2.4 µg/l

Furthermore, the risk of secondary poisoning has been evaluated; the calculat-ed concentrations in fish are summarized in table 18.

Table 19: Results of PECs for secondary poisoning: shredding

HBCDD concentrations and secondary poisoning result unit

Concentration in fish for secondary poisoning (freshwater) 97 mg/kg wwt

Concentration in fish for secondary poisoning (marine) 10.3 mg/kg wwt

Concentration in fish-eating marine top-predators 103 mg/kg wwt

Concentration in earthworms from agricultural soil 10.5 mg/kg

Exposure estimates: Recycling

Table 20: Additional input parameters for the recycling formulation scenario

Descriptor input

Production volume 179

Fraction of tonnage released to air 0.08 (0.11 g)

Fraction of tonnage released to waste water 0.26 (0.35 g)

Fraction of tonnage released to surface water 0.65 (0.86 g)

Local STP input Bypass STP

The derived local PECs are given in table 21 below

Shredding: PECs

Shredding: PECs

secondary

poisoning

Recycling: input formulation


46 January 2014

Table 21: Results of environmental assessment using EUSES: recycling formulation




0.4 µg/l

Annual average local PEC in surface water (dissolved) 0.4 µg/l

Local PEC in fresh-water sediment during emission episode

0.4 mg/kgwwt

Local PEC in seawater during emission episode (dissolved)

0.05 µg/l


Local PEC in marine sediment during emission episode 0.045 mg/kgwwt

Local PEC in agric. soil (total) averaged over 30 days 0.07 mg/kgwwt


Local PEC in grassland (total) averaged over 180 days 0.006 mg/kgwwt



Table 22: Results of PECs for secondary poisoning: recycling formulation

HBCDD concentrations secondary poisoning result unit

Concentration in fish for secondary poisoning (freshwater) 79.5 mg/kg wwt


Concentration in fish-eating marine top-predators 81.5 mg/kg wwt

Concentration in earthworms from agricultural soil 1.01 mg/kg wwt

The scenario “recycling–use“is described in the following:

Table 23: Additional input parameters for the recycling use scenario

Descriptor input

Fraction of tonnage released to air 0.5

Fraction of tonnage released to waste water 0.4

Fraction of tonnage released to surface water 0.1

Local STP input Use STP

Recycling: PECs

formulation

Recycling

formulation:

Secondary

poisoning

Recycling use:

input parameters


January 2014 47

The derived local PECs are given in table 24 below.

Table 24: Results of environmental assessment using EUSES: recycling use




0.3 µg/l

Annual average local PEC in surface water (dissolved) 0.3 µg/l

Local PEC in fresh-water sediment during emission episode 0,3 mg/kgwwt

Local PEC in seawater during emission episode (dissolved)

0.03 µg/l


Local PEC in marine sediment during emission episode

0.03 mg/kgwwt



Local PEC in grassland (total) averaged over 180 days 0.4 mg/kgwwt



Table 25: Results of PECs for secondary poisoning: recycling use

HBCDD concentrations secondary poisoning result unit

Concentration in fish for secondary poisoning (freshwater) 53.6 mg/kg wwt


Concentration in fish-eating marine top-predators 55.4 mg/kg wwt

Concentration in earthworms from agricultural soil 3.12 mg/kg wwt

6.2.2 Monitoring data: WEEE treatment sites/locations

To date, potential HBCDD contamination near European WEEE treatment plants remains to be investigated.

There are numerous recent investigations - determining the HBCDD contamina-tion levels of areas near WEEE treatment sites/locations - carried out in devel-oping countries, mostly China and Vietnam. A summary of the findings of the monitoring studies is provided in Table 26.

The HBCDD levels measured in soil samples in different Asian countries, China and Vietnam are in the range of n.d.-2.5 ng/g dw and 0.22-0.79 ng/g dw (Gao et al., 2011, Eguchi et al., 2013).

Data demonstrate that soils of e-waste areas show up to 100 times higher HBCDD exposure levels than the reference sites (Gao, et al., 2011).

Recycling: use

PECs

Recycling: use

Secondary

poisoning

Developing

countries

Soil


48 January 2014

The detected HBCDD concentrations are close to exposure levels of HBCDD point sources (producing and formulating plants) in Europe (111-23 200 ng/g dw) (Covaci et al, 2006).

Only one study is available, in which HBCDD levels in sediments from an e-waste dismantling site in China have been measured. Total HBCDD mean con-centration in sediments is between 4.6 to 35 ng/g dw. The authors state that these values are higher than those of not obviously exposed areas, in which the levels are below 10 ng/g dw.

Furthermore, HBCDD contamination has been determined in biota samples. The highest HBCDD levels were detected in loachs (934- 3529 ng g-1 lipid wt.). HBCDD concentration ranges varied between 123 - 333 ng g-1 lipid wt, 199-728 ng g-1 lipid wt., and n.d.-1995 ng g-1 lipid wt. for winkles, crucian craps, and dif-ferent birds, respectively.

Analyses of birds samples revealed that birds in e-waste areas show higher levels of HBCDD (compared to rural areas) (Sun et al., 2012) and He et al. (2010) could demonstrate that the birds diet is an important source of HBCDD exposure.

In developing countries, electrical and electronic appliances containing HBCDD and other toxic substances are often recycled under conditions which result in a relatively high release of HBCDD to the environment and contamination of the sites (Zhang et al., 2009). Open burning and dump sites are common destina-tions for HBCDD-containing articles and electronic wastes (Malarvannan et al. 2009, Polder et al, 2008c).

It is well known that these processes lead to formation of hazardous transfor-mation products as polybrominated dioxins and furans, which pose a risk to or-ganisms and accumulate in the food chain.

Aquatic species near WEEE plants in developing countries contain HBCDDs levels comparable to those from contaminated sites (e.g. HBCDD production sites) in Europe (Covaci et al. 2006; Wu et al., 2012), which gives a clear indica-tion that e-waste recycling sites in developing countries are another important source of HBCDD entry into the environment.

In conclusion, the available monitoring studies clearly indicate a higher burden of HBCDD in soils and sediments as well as in biota in e-waste areas.

Sediments

Biota

Conclusion HBCDD

contamination

developing

countries

RO

HS

Annex II D

ossier for HB

CD

D

January 2014 49

Table 26: Monitoring data (soil, sediment, biota) from sites near WEEE treatment plants in developing countries

Samples WEEE area; HBCDD concentration range (ng g

-1);

Control area; HBCDD concentration range (ng g-1)

Country Sampling area Remarks Reference

Environment

Soil

Surface soils 2.34-106 (mean range) 1

0.22-0.79 (mean range)1 China E-waste recycling

Highest concentration found at e-waste recycling site (284 ng g-1 dw); total level decreased with distance to recycling site.

Gao et al., 2011

Soil nd-2.51 nd-1.41

Cambodia, India, Indo-nesia, Ma-laysia and Vietnam

Dumping sites -- Eguchi et al., 2013

Sediment

Sediment

4.6-351 <101,3 China E-waste dismantling site Higher contamination levels compared to other areas without known sources.

Zhang et al., 2009

Biota

Winkle, Crucian carp, loach

Winkle: 123 - 3332 Crucian carp: 199-7282 Loach: 934- 35292

Aquatic invertebrates: 1,3-1062,3 Freshwater fish: 12-1602,3

China E-waste dismantling site Higher contamination levels compared to other areas without known sources. Very high concentrations were detect-ed in loaches.

Zhang et al., 2009

Aquatic species 11-23702 Aquatic invertebrates: 1,3-1062,3 Freshwater fish: 12-1602,3

China E-waste recycling site Food web magnification has been ob-served

Wu et al., 2012

Different bird spe-cies

nd-50582 na China E-waste region Diet is an important exposure source He et al., 2010

Passerine birds (muscles)

11-732

2.8-162

China E-waste region E-waste and urban regions are more contaminated than urban sites (3.3-1700 ng g lipid wt.(urban) 2.8-16 ng g lipid wt. (rural))

Sun et al., 2012

1dry weight;

2lipid weight,

3comparison with data from literature (Covaci et al., 2006); na: not analysed; nd: not detected


50 January 2014

7 IMPACT ON WASTE MANAGEMENT

7.1 Impacts on WEEE management as specified by Article 6 (1) a

The presence of HBCDD reduces the possibilities of recycling of WEEE plas-tics.

The main reason for this is that the use of other brominated flame retardants in products, including those using recyclates, is already restricted by the RoHS Di-rective and/or the POPs Regulation (PBDEs (polybrominated diphenyl ethers), PBBs (polybrominated biphenyls)).

During the treatment of WEEE the separation of plastics containing brominated flame retardants is therefore needed - (this is also part of the minimum treat-ment requirements for WEEE stipulated by the WEEE Directive (2012/19/EU, Annex VII).

Options to separate those plastics include separation according to the type of appliance (e.g. CRT-housings from monitor housings) or density separation. Of-ten, also, the separation of plastics containing restricted brominated substances from mixed plastics is made by using simple screening methods (e.g. X-ray fluo-rescence screening, XRF). Plastics are screened for Br to determine which plastics must not be recycled. It is not possible to distinguish plastics with HBCDD from plastics with PBDEs (polybrominated diphenyl ethers) or PBBs (polybrominated biphenyls) already restricted by the RoHS Directive.

When the screening equipment detects brominated plastics the waste treatment institution must assume that the plastics contain substances which must not be recycled and that these plastics must not be recycled. In practice, plastics con-taining HBCDD consequently cannot be recycled, even though the use of recy-cled plastics with HBCDD is not restricted in the current RoHS Directive.

If HBCDD was replaced by halogen-free flame retardants, it would be possible to distinguish the flame retardant plastic parts from plastic parts containing re-stricted brominated flame retardants by using XRF screening, and the plastic parts may be recycled. The housing parts are typically of a size that makes re-cycling practicable.

There are indications that within the EU not all plastics containing the relevant brominated flame retardants are separated before the plastics are subjected to material recycling although this is required pursuant to the WEEE-Directive48. It is known that shipments of plastics containing flame retardants take place under the guise of the Green list.

Comparably high recycling rates for plastics waste in some third countries (e.g. close to 60% India, (EMPA, 2011)) may contribute to a long use of HBCDD.

Wastes with a HBCDD content of 0.5% are considered hazardous. The HBCDD concentrations in WEEE-HIPS were reported to be above this threshold (1-7% (IOM, 2009)). Taking further into account that about 5 % of HIPS used in WEEE

48 enforcement experiences in the context of transboundary waste shipment, Austrian analyses of

plastic fractions from dismantling of TV and monitors; (personal communication Austrian MoE)

Reduced recycling

possibilities

HBCDD remaining in

the recycling loop

Generation of

hazardous waste


January 2014 51

contain HBCDD, an annual quantity of approximately 20,000 tonnes of hazard-ous HIPS waste would arise.

The legal options for treating HBCDD containing plastics are to incinerate them in incineration plants for hazardous waste to dispose them in a landfill for haz-ardous waste or solvolysis, super-critical water processes or pyroly-sis/gasification.

Even in the best European waste collection systems not all WEEE are collected separately and not all HBCDD containing plastics are removed from other plas-tics. Under current operational conditions a considerable share of the HBCDD containing plastics will be incinerated contributing to corrosion of plants or land-filled contributing to HBCDD releases via leachate. In addition, the halogen content is an obstacle in the use of plastics in industrial co-incineration.

7.2 Estimate of risks for workers and neighbouring residents

No human biomonitoring studies in the neighbourhood of WEEE treatment sites in Europe have been found so far. HBCDD has been identified as PBT sub-stance and will be listed as POP in Annex A to the Stockholm Convention. Alt-hough no risk has been identified for workers under occupational conditions which are expected for shredders, a risk of workers in recycling facilities cannot be excluded.

In third countries it is documented that HBCDD is detected in higher concentra-tions near e-waste sites compared to other regions. It has to be taken into con-sideration that HBCDD has contaminated these regions for decades and will contribute to the body burden of the residents in this region and pose a risk to future generations.

Main targets for HBCDD toxicity are the liver, thyroid hormone homeostasis, the reproductive, the nervous and the immune systems. The developmental and neurotoxic potential of HBCDD observed in animal studies gives cause for con-cern, particularly for unborn babies and young children especially in regions where the environment has been contaminated with this long lasting pollutant.

7.3 Risks estimate for the environment

Due to its persistency, tendency to accumulate and magnify in the food chain and its toxicity releases of HBCDD into the environment have to be minimized. However, in order to assess whether the HBCDD exposure of the scenarios de-scribed in this Dossier pose a risk to the environment the PEC/PNEC ratios have been calculated. In general, if the ratio of the predicted environmental concentration to the concentration which is expected to pose no risk is higher than 1 a risk can be expected and risk reduction measures should be taken. In table 27 the PEC/PNEC- ratios for the three scenarios are depicted. It can be seen that a risk can be expected for the aquatic compartment, and for second-ary poisoning. Even if secondary poisoning was to be overestimated by EUSES and taking into account the difference between PNECs which are usually given in dry weight (sediment, soil, fish) and PECs which are calculated in wet weight,

Other impacts

Europe

Third countries

POP

Risk identified


52 January 2014

it can be expected that the waste treatment processes described in this Dossier lead to a risk for the environment.

Usually no PNECs are derived for the air compartment, but it is known that HBCDD can be detected in eggs of terrestrial birds in Europe; increased con-centrations have been reported for several marine bird species as well as in eggs of arctic birds (EC, 2008a). A potential for in vivo endocrine disruption of the reproductive and thyroid hormone systems has been reported for the Euro-pean Flounder (EC 2008).

Table 27: PEC/PNEC ratios for the different scenarios

PECs PNECs PEC/PNEC ratios

shredding recycling-formulation

recycling-use

Aquatic compartment

PEC surface water 0.31 µg/l 1.7 1.3 0.97

PEC seawater 0.03 µg/l 2 1.6 1

PEC freshwater sediment 0.86 mg/kg dwt

0.6 0,5 0.4

PEC marine sediment 0.17 mg/kg dwt

0.03 0,3 0.17

Terrestrial compartment

PEC soil 5.9 mg/kg dwt

0.3 0.01 0,06

Secondary poisoning

PEC fish (freshwater) 5.0 mg/kg food

20 15.9 10.72

PEC fish (marine) 5.0 mg/kg food

2.06 1.62 1.11

PEC marine predators 20.6 16.3 11.8

PEC terrestrial predators 5.0 mg/kg food

2.1 0.2 0.6

It could be demonstrated that HBCDD is released into the environment by the shredding of WEEE material as well as recycling processes. Due to its high chronic toxicity to aquatic organisms, the reproductive toxicity to mammals & birds and the effects on the thyroid-hormone system and the nervous system in mammals the PNEC for secondary effects in wildlife is exceeded.

Due to the long range transport of this chemical it contributes also to the body burden of arctic top predators and marine mammals.

PEC/PNEC ratio

Risk identified


January 2014 53

8 ALTERNATIVES

8.1 Availability of substitutes / alternative technologies

Several alternative flame retardants are available to replace HBCDD in HIPS (SWEREA, 2010, IOM, 2009).

The table below depicts some alternative substances used in HIPS, which in-clude halogenated flame retardants in conjunction with antimony trioxide (ATO) and halogen free aryl phosphorus compounds (IOM, 2009)49. EFRA50 have point out that phosphorus flame retardants cannot be used in HIPS alone, only in alloys. Therefore, HBCDD in HIPS needs to be replaced by other BFR sys-tems or by phosphorus FRs with different polymers. Furthermore they have pointed out that phosphorus based flame retardants performed worse than hal-ogenated ones regarding the mechanical properties of recycled plastics when it comes to recycling51. However, some of these substances possess adverse ef-fects and therefore cause human health concerns, as well as concerns regard-ing environmental fate properties and toxic effects on environmental organisms.

49 According to EFRA (comment during stakeholder consultation) that phosphorus flame retardants

cannot be used in HIPS alone, only in alloys. Therefore, HBCD in HIPS needs to be replaced by other BFR systems or by phosphorus FRs with different polymers

50 EFRA (2013): contribution in the course of stakeholder consultation 51 EFRA (2011): Keeping fire in check in electronic devices

Substitutes for

HBCDD in HIPS


54 January 2014

Table 28: Alternative flame retardants for HBCDD used in the production of HIPS (Source: adopted from IOM, 2009)

Substance name CAS number

Human Health concerns

Environmental concerns

Harmonised (HC) and/or self-classification (SC)*

Antimony trioxide (ATO)***

1309-64-4 Potential human car-cinogen and reproduc-tive toxicant.

Not readily biode-gradable, low to mod-erate bioaccumulation potential

HC: Carc. 2; SC: Carc. 2; Eye Dam. 1; Acute Tox. 4; Aquatic Chronic 2; Repr. 1A; STOT RE 2; Aquatic Chronic 3; Skin Irrit. 2; Eye Irrit. 2

Decabromodiphenyl ethane (in combination with ATO**)

84852-53-9 Limited data, but likely to be of low toxicity

Not readily biode-gradable, may be per-sistent

no HC; SC: Aquatic Chronic 4

Ethylene bis (tetrabro-mophthalimide) (in combination with ATO**)

32588-76-4 Low toxicity Not biodegradable and persistent. Non-toxic.

no HC; no SC

Triphenyl phosphate 115-86-6 Chronic toxicant with effects on liver

Readily biodegradable, toxic to aquatic organ-isms

no HC; SC: Aquatic Acute 1; Aquatic Chronic 1; Aquatic Chronic 4 Eye Irrit. 2;

Resorcinol bis (biphenyl phosphate)

57583-54-7 Chronic toxicant with effects on liver

Inherently biodegrada-ble, may be persistent and bio-accumulative

no HC; SC: Aquatic Chronic 3; Aquatic Chronic 2

Bisphenol A bis (biphenyl phosphate)

5945-33-5

Limited data, likely to be of low toxicity

Poor biodegradable; not bioaccumulative;

HC: aquatic chronic 4; SC: Aquatic Chronic 4

Diphenyl cresyl phosphate

26444-49-5 Chronic toxicant with effects on liver, kidney and blood. Effects on fertility

Readily biodegradable; toxic to aquatic organ-isms

no HC; SC: Aquatic Acute 1; Aquatic Chronic 1; Acute Tox. 4; Aquatic Chronic 2; STOT SE 2;

* indicated in the Classification and Labelling (C&L) inventory from ECHA (available at:

http://echa.europa.eu/web/guest/information-on-chemicals/cl-inventory-database);

** toxicological profile of ATO indicated in the first row; **persistence, bio-accumulative and toxic;

***ATO is used in conjunction with other halogenated flame retardants

Furthermore, HIPS in EEE can be replaced by several alternative materials, in-cluding blends of polycarbonate, acrylonitrile butadiene styrene (PC/ABS), poly-styrene/polyphenylene ether (PS/PPE), polyphenylene ether/high impact poly-styrene (PPE/HIPS) without flame retardants or with non-halogenated flame re-tardants (DEPA, 2010).

Since HBCDD is not widely used in HIPS (only 5%), it is assumed that the al-ternative flame retardants on the market are technically and economically feasi-ble (UNEP, 2011).

The available evaluation of IOM 2009 demonstrates that most of the alterna-tives are not more problematic than HBCDD with regard to human toxicity, but data for critical endpoints are missing (IOM, 2009).

Alternatives for

HIPS in EEE

Conclusion


January 2014 55

Based on the data available on the hazardous properties of HBCDD we as-sumed that a co-polymer of HIPS and polyphenylene ether (PPE) in combina-tion with halogen-free flame retardants are the most suitable alternative as re-gards the toxicological profile and used this alternative for further socio-economic impact analysis.


56 January 2014

9 DESCRIPTION OF SOCIO-ECONOMIC IMPACTS

9.1 Approach and assumptions

In accordance with the ECHA (2011) document “Guidance on socio economic analysis”, the socio-economic analysis of this dossier is based on two scenari-os:

� In Scenario A the present legislation is not changed and HBCDD may contin-ue to be used (no ban of HBCDD) in EEE.

� In Scenario B the use of HBCDD in EEE is banned. High Impact Polystyrene (HIPS) in combination with HBCDD is replaced by a co-polymer of HIPS and Polyphenylene ether (PPE) in combination with halogen-free flame retard-ants. This is probably the most expensive way of replacing the HBCDD in EEE. However, it is also the best option when it comes to reducing environ-mental and health impacts.

The major source for the assumptions used in this socio-economic analysis is DEPA (2010).

Some of the assumptions used in the socio-economic analysis are valid for both scenarios and thus provide the framework assumptions of this analysis. The fol-lowing assumptions were made:

Approximately 20,000 tonnes of HBCDD containing plastics (HIPS) are sold an-nually in the EU as part of EEE. These plastics may contain up to 7 % HBCDD. Consequently up to 1,400 tonnes per year of HBCDD may be contained in the EEE sold in the EU (see chapter 2.3). Thus if HBCDD was banned in EEE this may result in a reduction of 1,400 tonnes of HBCDD consumption annually.

Table 29 summarises the described frame assumptions.

Table 29: Framework assumptions of the Socio Economic Analysis regarding a ban of

HBCDD as flame retardant for EEE (electrical and electronic equipment)

Parameter Assumption

Consumption of flame retardant in t/y 1,400

Assumed share of HBCDD in EEE plastics (HIPS) 7%

Total amount of EEE plastics using HBCDD in t/y 20,000

9.2 Impact on flame retardant and plastics producers

In the following the impact of Scenario B (ban of HBCDD) is compared to Sce-nario A (no ban of HBCDD) from the point of view of the different stakeholders along the life cycle.

Three large companies with headquarters in the USA and Israel, but production facilities in Europe (among other places), dominate the bromine production globally and produce a range of brominated compounds. They also manufac-


January 2014 57

ture different halogen-free flame retardants such as organo-phosphorous com-pounds and magnesium hydroxide. These companies are vulnerable to chang-es in the demand for brominated flame retardants; however, the same compa-nies also manufacture some of the alternatives.

The manufacturers of alternative flame retardants would benefit from a re-striction of HBCDD in EEE. The phosphate esters are manufactured by the same companies that also provide the brominated flame retardants, but also by at least two other European companies (DEPA 2010).

Plastic resins are produced and formulated by relatively few large companies in Europe. The resins are mixed with additives (in so-called “masterbatches”) to form compounds, which are the raw materials for further processing. Com-pounding may take place by the resin manufacturer, by specialised compound-ers or by the company manufacturing the plastic parts.

Whereas the market for compounds is dominated by relatively few large actors, the market for plastic parts is characterized by many small and medium sized enterprises (SMEs). In the EU as a whole there are 55,000 companies manu-facturing rubber and plastics. Of these companies, the average enterprise size was given as 25 employees. No data are available on how many of these actu-ally supply EEE parts.

Previous studies have clearly indicated that SMEs are affected to a greater de-gree by compliance with the RoHS legislation than their larger competitors. The relatively larger burden for SMEs holds true for the total costs to comply with RoHS in general as well as more specifically the administrative burden. As most of the SMEs involved in the manufacturing of flame retardant plastics for EEE already have procedures in place for ROHS compliance, the differences be-tween the SMEs and larger companies are probably not as large as seen by the initial implementation of the RoHS Directive. The companies offering the alter-native flame retardants are large companies, and they serve as general cus-tomer advisers when it comes to adjusting polymer formulations and production setup. However, the identification of suitable alternatives and R&D for the intro-duction of new substances must still be expected to place a larger burden on SMEs than on larger companies (DEPA 2010).

Nevertheless, the switch to compounds having less negative environment and health impacts are regarded as an opportunity for the European production in-dustry.

In accordance with the Stockholm Convention on Persistent Organic Pollutants, UNEP (2011) expects that emission reduction measures and use of best prac-tices will be required in the production and use of HBCD, to reduce HBCD re-leases to the environment from these uses, if HBCDD is not banned.

Therefore it is assumed in Scenario A (no ban of HBCDD) that producers of HBCDD and producers of plastics / plastic products which use HBCDD must in-stall emission reduction measures and implement best practices. For the sce-nario calculation it is assumed that these measures cost at least as much (that is 10 % more) as the shift from HIPS with HBCDD to HIPS/PPE with halogen-free flame retardants.

In Scenario B (ban of HBCDD) besides the single HBCDD producer in the EU, the substitution costs will mainly hit the formulators and converters of HIPS (and other plastics), which in some cases are likely to include the EEE manufactur-


58 January 2014

ers, especially with regard to HIPS housings. The major technical costs are the costs for more expensive flame retardants, higher loads of flame retardants and costs for new moulds. In cases where the total polymer system is changed, more process steps may need to be changed implying higher costs (but also higher impact strength as described under available alternatives). The alterna-tive plasticisers, polymer systems and production set-ups have already been developed and on the market. Costs for mould changes can be reduced signifi-cantly with sufficiently long transition periods, as moulds have to be replaced regularly in any case (DEPA 2010).

DEPA (2010) estimates that the material price of HIPS containing 7 % HBCDD as flame retardant is about 2.31 €/kg and of HIPS/PPE containing halogen-free flame retardants is 3.64 €/kg, so that by a HBCDD ban additional material costs of 1.33 €/kg of plastics would occur. In addition DEPA (2010) estimates invest-ment costs of 0.23 €/kg of plastics when switching to a halogen-free system. In order to switch the 20,000 tonnes of HBCDD containing plastics which are esti-mated to be used in EU EEE annually (see Table 29) to halogen-free plastics, additional material and investment costs of 31.3 Million € occur annually (see Table 30 below). It is assumed that for these additional costs of the alternative HIPS/PPE, products can be designed, which achieve the same life time and product characteristics as the HBCDD containing products.

When comparing Scenario A (no ban of HBCDD) with Scenario B (ban of HBCDD), similar additional costs are assumed, in Scenario A for additional emission abatement equipment, in Scenario B for switching to bromine-free plastics.

It is expected that the higher turnover of the flame retardant and plastics indus-try in Scenario B will create some additional jobs in this sector.

In both scenarios the health impact on the workers of the flame retardant and plastics industry and the environmental impact are expected to decrease, in Scenario A through additional emission reduction measures and in Scenario B through the ban of HBCDD. While both scenarios may lead to similar results in the EU, the workers and the environment abroad would definitely benefit from a ban of HBCDD.

9.3 Impact on EEE producers

A substantial amount of EEE is finally produced in the EU. However, there is al-so a large part of the total quantity of EEE consumed by end-users that is im-ported as finished goods from outside the EU. This is notably the case for small household appliances, consumer electronics, IT equipment, and toys etc., but also for other EEE groups.

Additional costs which need to be covered by the EEE producers in addition to the above mentioned material costs arising from banning the use of HBCDD may include:

� Costs for proving that the components of the EEE products are HBCDD free

� Costs for developing, testing and approving alternative flame retard-ants.


January 2014 59

To some extent the costs for proving that EEE products are free from HBCDD are included in the administrative costs (discussed in the chapter below).

The level of costs for development, testing and the relevant permits very much depends on the availability of suitable, already tested and approved alterna-tives. While several comments submitted during the stakeholder process on the restriction of hazardous substances under ROHS refer to these additional costs, none of them provide any factual data on the level of these costs52. One of these comments53, however, states that “the amount of HIPS containing HBCDD in EEE is close to zero”. This is a strong indication that alternatives al-ready exist and have been tested and already approved. Therefore, no costs for developing, testing and approving alternative flame retardants for EEE produc-ers have been taken into account in this analysis.

The higher costs of plastics with alternative flame retardants are incurred by all EEE producers selling on the EU market. Thus no change in the relative com-petitive position of the different EEE producers is to be expected from a HBCDD ban.

As compared to the turnover generated by the EU electrical engineering indus-try (amounting to 411 billion € in 2008), the additional costs of 31.3 million € (+0.008 %) are so small that no influence on the market needs to be feared. Additional costs are to be expected in any case, with or without a ban.

9.4 Impact on EEE users

The major impact on EEE users is the additional costs which are to be borne by EU industrial and private consumers. It is to be expected that a somewhat high-er price for EEE jeopardises the competitive position of the European industry as a whole because some jobs will be lost. On the other hand, it can be ex-pected that other jobs will be created as an essential part of the additional costs will be for the benefit of European plastic producers and the environment indus-try.

Additional costs are to be expected in any case for both scenarios, with or with-out a ban on HBCDD. As the amount of the additional costs should be similar in both cases, a ban on HBCDD should not be more expensive than the option of staying with HBCDD.

With respect to the benefits, however, there is a difference between the scenar-ios. In rare cases an EEE product may start to glow or burn even when it con-tains a flame retardant. A glowing/burning EEE product containing HBCDD may emit hazardous bromine compounds, whereas a bromine free EEE product does not. An EEE product which does not contain bromine can thus be ex-

52 SEMI Europe (2013): Feedback – Consultation on draft ROHs Annex II dossiers for HBCDD,

DEHP, BB, DBP. EFRA (2013): RoHS questions on HBCD by Austrian UBA, 29.11.2013. BVMed (2013): BVMed Comment – RoHS2: Study for the Review of the List of Restricted Sub-

stances - Consultation on draft ROHs Annex II dossiers for HBCDD, DEHP, BB, DBP. Orgalime (2013): RoHS2: Study for the Review of the List of Restricted Substances - Consultation

on draft ROHs Annex II dossiers for HBCDD, DEHP, BB, DBP. Brussels, 29.11.2013 Edma & Eucomed (2013): no title, 29.11.2013 53 EFRA (2013): RoHS questions on HBCD by Austrian UBA, 29.11.2013.


60 January 2014

pected to be less harmful for the EEE user than an EEE which contains HBCDD.

9.5 Impact on waste management

For details on the impacts of HBCDD contained in EEE on waste management please refer to Chapter.7

In total, the benefits of banning HBCDD in EEE can be summarized as:

� Reduced environmental and health impacts (because of an increased recy-cling potential)

� Reduced corrosion of waste incineration plants

For the waste management sector there are no substitution costs, as bromine-free plastics can be treated with the existing equipment, in many cases even at lower costs than plastics containing HBCDD.

9.6 Impact on administration

According to DEPA (2010) extra compliance costs related to the addition of one a new substance under RoHS are expected to be minimal for companies which have already implemented RoHS, i.e. for most companies to which this analysis refers. HBCDD is typically used in parts where deca-BDEs have traditionally al-so been used and where compliance documentation would usually have been required.

The main extra costs are expected to arise from control measures, to be under-taken by manufacturers, importers and the authorities. The presence of HBCDD cannot be determined by simple XRF screening (detecting only the presence of Br). Sampling, extraction and laboratory analysis is required. As the parts that may contain HBCDD typically may also contain other RoHS substances the ex-tra costs would mainly be for the laboratory analysis, as sampling and sample preparation would be undertaken in any case to control other RoHS substances in the parts.

The administrative costs for Scenario B (ban on HBCDD) are estimated as fol-lows:

� DEPA (2010) estimates that the additional costs for proving that the produced plastics are HDPCC free is 30 €.

� The UK Risk Reduction Strategy and Analysis of Advantages and Drawbacks of Octa-BDE (Corden and Postle, 2002) reports that there are 55,000 com-panies manufacturing rubber and plastics in the EU. When assuming that on average two test samples have to be provided by company and per year (proving that the produced plastics are HBCCD free) the total administrative costs for the EU are 3.3 million €/year.

In Scenario A (no ban on HBCDD) additional administrative costs also occur. As explained above, emission reduction measures are required in this scenario. Public administration is required to ensure that the measures are effective. For


January 2014 61

scenario analysis purposes it is assumed that the costs for monitoring the emis-sion reduction measures are as high as the costs for monitoring a HBCDD ban.

In both scenarios, however, the administrative costs are not costs which are wasted, as they increase the turnover of the chemical analysis industry.


62 January 2014

9.7 Total socio-economic impact

When comparing the costs of Scenario A (no HBCDD ban) with the costs of Scenario B (which includes an HBCDD ban) it is expected that:

� Without a ban on HBCDD flame retardants, plastics producers will have to in-vest in additional emission reduction measures

� With a ban on HBCDD flame retardants, plastics producers will have to deal with higher material costs and investments in new molding processes.

In total, the costs should be about the same in both scenarios (see Table 30)

The total effect on jobs is expected to be neutral in both scenarios. While some jobs may be lost in the industries where EEE is used other jobs can be created with flame retardant/plastic producers and in the environment industry. In any case, the difference with respect to jobs between the 2 scenarios and thus the effect of a HBCDD ban should be very small.

With respect to the benefits, however, the difference between the two scenarios is considerable. While the implementation of emission reduction measures in scenario A provides only for a better protection of the workers in the environ-ment around the flame retardant / plastic production sites in Europe, a ban on HBCDD generates the following additional benefits:

� Increase in the competitive position of an environmentally friendly industry

� Globally reduced environmental and health impacts during HBCDD and plas-tics production

� Reduced environmental and health impacts during the waste phase especial-ly


� Reduced generation of hazardous waste

� Increased recycling potential of plastics


January 2014 63

In total, the ban on HBCDD creates no additional costs as compared to a non-ban scenario, while creating substantial additional benefits for health and envi-ronment and the economy.

Table 30:Scenario Management Tableau of the Socio Economic Analysis of a ban on

HBCDD as flame retardant in EEE (electrical and electronic equipment)

Scenario A – no ban on HBCDD

Scenario B – ban on HBCDD

Difference between Scenarios (B-A)

Material used for EEE plastics HIPS with HBCDD as flame retardant

HIPS/PPE with halo-gen-free flame re-tardants

Additional raw material costs of plastic mate-rial in €/kg

0 1.33 1.33

Additional investment costs for changing to other plastic material in €/kg plastic material

0 0.23 0.23

Additional raw material + investment costs for EEE HBCDD plastics or its alternative in €/kg

0 1.56 1.56

Additional raw material + investment costs for EEE HBCDD plastics or its alternative in €/y

0 31,300,000 31,300,000

Additional costs for HBCDD and plastic pro-ducer for emission reduction measures and use of best practices in €/y

34,300,000 0 -34,300,000

Additional costs for EEE producer in €/y 0 no data available -

Additional costs for waste treatment in €/y 0 0 0

Additional administrative costs in €/a 3,300,000 3,300,000 0

Total additional costs for final consumers 37,600,000 34,600,000 -3,000,000

Benefits Increase in the com-petitive position of environmentally friendly industry

Increase in the com-petitive position of environmentally friendly industry

Reduced environ-mental and health impacts during HBCDD and plastics production in the EU

Global reduced envi-ronmental and health impacts during HBCDD and plastics production

Reduced environmen-tal and health impacts during HBCDD and plastics production al-so abroad

Scenario A – no ban of HBCDD

Scenario B – ban of HBCDD

Difference of Sce-narios (B-A)

Reduced environ-mental and health impacts during use and especially the waste phase

Reduced environ-mental and health impacts during use and especially waste phase

Reduced corrosion of waste incineration plants

Reduced corrosion of waste incineration plants

Increased recycling potential

Increased recycling potential


64 January 2014

10 RATIONALE FOR INCLUSION OF THE SUBSTANCE IN ANNEX II OF ROHS

Hazardous potential

Nature and reversibility of the adverse effect

HBCDD is persistent and undergoes long range transport; it accumulates in the food chain, is reprotoxic and accumulates in human breast milk.

HBCDD releases from WEEE treatment

The relevant releases of HBCDD from shredding of WEEE and recycling of HIPS parts derived from WEEE are releases to the air. The same is true for the treatment of other post-consumer wastes54.

The RAR for HBCDD (EC, 2008a) identifies EPS and XPS insulation boards as the most relevant post-consumer waste streams. About the actual releases of HBCDD from the demolition of buildings, which depend very much on the tech-niques used for demolition, there is generally a big uncertainty. Nevertheless, rough estimates of HBCDD releases from insulation boards are provided by the RAR. Based on an annual consumption of 8,000 tonnes of such insulation boards in the EU, releases during waste management are estimated to account for 108 kg/a of a 30% share of boards being recycled after manual removal from buildings, plus an estimated 5,600 kg/a resulting from the demolition of buildings containing the remaining 70% of EPS/XPS boards. Releases from fur-ther waste management operations have not been estimated.

In a scenario where emissions of dust at shredder plants are prevented to a high extent, HBCDD releases via particulates from WEEE treatment are compa-rably low: 43 kg/a.

In a scenario where only limited measures for preventing dust emissions from shredder plants are taken, the estimated releases from mechanical treatment of WEEE are 413 kg/a, which is considerably higher than the emissions from manually removed EPS/XPS boards.

Taking into account that material streams derived from WEEE may be subject-ed to mechanical treatment processes several times during the overall treat-ment chain, it is expected that the actual releases might even be higher.

HBCDD releases to air and waste water from the recycling of WEEE-HIPS parts (each approximately 25.7 kg/a) are estimated to be lower than releases from the mechanical treatment of WEEE.

In any case, overall releases from WEEE treatment (compare Table 12) are ex-pected to be much lower than the estimated releases from EPS/XPS containing demolition boards (5,780 kg/a from the recycling and demolition of buildings in a worst case scenario).

54 In general, RAR HBCDD provides little information on releases of HBCDD-containing products

once they have become waste.

WEEE treatment

compared to the

treatment of other

post-consumer

wastes


January 2014 65

Compared to releases of HBCDD to air other than those resulting from waste management activities (as estimated in the RAR for HBCDD, i.e. 508 kg/a; see Table 31 below) the releases from WEEE treatment are either of the same or-der of magnitude (420 kg/a) or lower by one order of magnitude (50 kg/a) where measures for the prevention of dust emissions have been implemented.

Releases into waste water from WEEE treatment are expected to be of little rel-evance (19 kg/a) compared to the total HBCDD releases to waste water (6,251 kg/a) and surface water (1,933) as estimated in the RAR (see Table 31 below).

In addition, releases of HBCDD are also expected from landfills, incineration plants and uncontrolled treatment of WEEE.

Table 31: Summary of HBCDD releases (Source: Table 3-34 of the RAR for HBCDD,

EC, 2008a)

Releases from

WEEE treatment

compared to total

HBCDD releases


66 January 2014

Human health risk

Workers are expected to be at risk in facilities where HBCDD containing plas-tic parts from WEEE are recycled.

Based on an estimated number of 50 installations where HBCDD containing plastics are processed/recycled55, and taking into account an average of 25 employees in the plastics processing sector, the number of workers at risk is es-timated to be 1,250.

Shredding, applied outdoors, is considered to present a lower health risk. How-ever, workers might be at risk because they are exposed to a mixture of haz-ardous substances contained in shredder dust. Even if the risk characterization ratio is below 1, the safety margin is in some cases below a factor of ten.

Based on an estimated number of 450 installations in the EU where WEEE and materials derived thereof are treated mechanically56, and assuming 5 to 15 workers per installation57, the estimated range of workers exposed to HBCDD releases ranges between 2,250 to 6,750.

A considerably higher risk is expected to arise from uncontrolled treatment

in third countries. Residents in the neighbourhood of waste treatment sites are also at risk due from hazardous degradation and incineration products. Es-pecially risks to unborn and breast-fed babies have been identified and health effects have been reported.

Environmental exposure

Environmental exposure from the shredding of WEEE and recycling of HIPS was estimated on the basis of the calculated HBCDD releases using the EUSES. 2.1 system for the evaluation of substances. Compared to other indus-trial processes, local HBCDD concentrations at sites where WEEE is shredded and HIPS recycled are more than one order of magnitude higher than back-ground concentrations.

Monitoring data from third countries demonstrate the long-lasting contamina-

tion of the environment from WEEE treatment.

Risk for the environment

A risk to the aquatic compartment has been identified in the shredding of WEEE58 and the recycling of HIPS59, as well as a risk of secondary poison-

55 Basis for the assumption: IPTS (2013): an overall quantity of 50,000 plastics-converters process-

es 46 Mio tonnes of plastics � average treatment capacity: 1,000 t/a. Amount of HIPS resulting from the dismantling of WEEE: appr. 50,000 t/a of HIPS � 50 plants involved.

56 The estimation is based on the following: 220 (EC, 2012b) to 232 (IPTS, 2007) large-scale shred-der plants are operated in the EU. According to information available from Austria (Umweltbun-desamt, 2008) and France (contribution to a stakeholder consultation, the WEEE Forum), there are at least as many mechanical treatment plants for WEEE as large scale shredders. According to the estimates of other stakeholders, there are at least 100 installations. The total number of mechanical treatment plants has therefore been estimated at 450.

57 Estimate based on Umweltbundesamt (2008) 58 Involved number of sites: at least 450 59 Involved number of sites: 50

Workers in plastics

recycling

Workers in

mechanical

treatment of WEEE


January 2014 67

ing of the aquatic, marine and terrestrial compartment. There is a major concern that the accumulation of such substances in the food chain will lead to adverse effects in the long term. Especially top predators are at risk from the burden of persistent organic pollutants. In the environment HBCDD is part of a mixture of persistent organic pollutants which is toxic in many cases and en-dangers especially sensitive and endangered species and affects sensitive

stages of development.

Main influencing factors within the assessment

There are 2 major factors influencing the result of the risk assessment:

� The annual quantities of HBCDD actually contained in the WEEE collected are influenced by various factors, including the actual quantity of HBCDD put on the European market via EEE, the lifespan of EEE and the actual WEEE amounts collected.

� To what extent measures for preventing diffuse emissions have been applied when handling materials derived from shredded WEEE is considered to have a considerable impact on the estimated HBCDD emissions. However, there is no information available on the actual implementation of such measures.

Within the risk assessment approach the two evaluation tools ECETOC TRA and EUSES have been used. As these have not yet been adapted to the evalu-ation of waste exposure scenarios because no process categories, emission ta-bles and special scenarios have been integrated, appropriate scenarios have been developed; emissions and releases calculated and used as input parame-ters for EUSES.

Impact on waste management

The extent to which material recycling/recovery is affected:

Under current operational conditions the presence of Br is determined to decide whether it is allowed to recycle WEEE plastics or not. HBCDD thus reduces the possibilities for WEEE plastics recycling as it is not distinguishable with routine detection methods from other brominated flame retardants. The extent to which HBCDD remains in the recycling loop

There are indications that within the EU not all plastics containing HBCDD are separated before the plastics are subjected to material recycling although this is required pursuant to the WEEE-Directive60. It is known that such shipments take place under the guise of the Green List.

The amount of hazardous waste which is generated in the course of

processing WEEE

Wastes with a HBCDD content of 0.5% are considered hazardous. Assuming a separation of all plastics containing more than 0.5% HBCDD, the amounts of HBCDD used in EEE would lead to an annual quantity of up to 20,000 tonnes of hazardous plastics waste.

60 (enforcement experiences in the context of transboundary waste shipment, Austrian analyses of

plastic fractions from dismantling of TV and monitors; personal communication Austrian MoE)


68 January 2014

Other negative impacts on waste management

In waste incineration plants HBCDD containing plastics contribute to corrosion and the possibilities for use in industrial co-incineration are lower.

Available Alternatives

The availability of substitutes/alternatives with less negative properties

Substitutes for HBCDD in HIPS and alternatives for HIPS in EEE are both available. They include also substances which are less hazardous than HBCDD, in particular p-based flame retardants.

Technical and economic feasibility of the alternative substance

Since HBCDD is not widely used in HIPS (only 5%), it is assumed that using the alternative flame retardants on the market is technically and economically feasi-ble (UNEP, 2011).

Socio-economic impacts

In total, the ban on HBCDD creates no additional costs when compared to a non-ban scenario (which requires investments in emission reduction measures), while creating substantial additional benefits for health, environment and the economy.

The costs of a potential restriction of HBCDD (higher material costs and invest-ments in new moldings for the producers) in EEE are estimated to be no higher than those for non-action (i.e. costs for additional emission reduction measures). The overall effect on jobs is expected to be neutral in both scenari-os.

With respect to the benefits to be achieved, there is a major difference between the two scenarios. While the implementation of emission reduction measures in scenario A provides only for a better protection of workers in the environment around the flame retardant / plastic production sites in Europe a ban on HBCDD (scenario B) generates the following additional benefits:

� Globally reduced environmental and health impacts during HBCDD and plas-tics production

� Reduced environmental and health impacts during use and especially waste phase


� Increased recycling potential of plastics


January 2014 69

Conclusion:

It is recommended that HBCDD should be included in Annex II to the RoHS Directive. A restriction of HBCDD under RoHS is considered to be an appropri-ate measure to reduce any negative effects during or on WEEE management because:

� a risk for the environment from the shredding of WEEE and the recycling of HBCDD containing HIPS is expected: for the aquatic compartment and in the form of secondary poisoning

� a risk to human health of workers involved in the recycling of HBCDD con-taining plastics is expected

� a risk for residents in the neighborhood is expected, especially in third countries

� the overall releases from relevant WEEE treatment are a relevant con-

tributor to the total HBCDD releases to air

� there are several negative impacts on waste management (reduced recy-cling possibilities for WEEE plastics, generation of considerable amounts of hazardous wastes and a long life-time in the recycling loop)

� alternatives with less negative properties are available (in particular P-based flame retardants) and their use is technically and economically feasible

� the description of the socio-economic impacts shows that the additional costs for producers of chemicals and EEE are compensated by several bene-fits (such as the reduced risks and the less negative impacts on waste man-agement as a consequence of a restriction of HBCDD in EEE).

For the maximum concentration of HBCDD to be tolerated in homogenous

materials in EEE it is proposed to set the same value as defined for POPs waste in Annex IV to the EU POPs Regulation (850/2004/EC) for most POPs, i.e. 0.005 %.


70 January 2014

11 REFERENCES

Austrian MoE (2013): personal communication

Asante KA, Adu-Kumi S., Nakahiro K., Takahashi S., Isobe T., Sudaryanto A.,

Devanathan G, Clarke E, Ansa-Asare OD, Dapaah-Siakwan S, Tanabe S. Human

exposure to PCBs, PBDEs and HBCDs in Ghana (2011): Temporal variation,

sources of exposure and estimation of daily intakes by infants. Environment

International 37 921–928

Berkeley Center for Green Chemistry (2012). Identification of substances of concern

during informal recycling of electronics.

BDSV (2012): BVT-Merkblatt, BREF für Großshredderanlagen

Chengelis CP (2001): A 90-day oral (gavage) toxicity study of HBCD in rats. WIL-

186012, Wil Research Laboratories, Inc., Ashland, Ohio, USA, pp 1527. (as cited

in EC, 2008).

Covaci A, Gerecke AC, Law RJ; Voorspoels S, Kohler M, Heeb NV, Leslie H, Allchin CR,

de Boer J (2006): Hexabromocyclododecanes (HBCDs) in the environment and

humans: A review. Environ. Sci. Technol. 40, 3679-3688

Corden, C. and M. Postle. 2002. Risk Reduction Strategy and analysis of advantages

and drawbacks for octabromodiphenyl ether. RFA for U.K. Department for

Environment, Food and Rural Affairs (DEFRA).

DEPA - Danish Environmental Protection Agency (2010): Inclusion of HBCDD, DEHP,

BBP, DBP and additive use of TBBPA in annex IV of the Commission’s recast

proposal of the RoHS Directive, COWI A/S. Danish Ministry of Environment,

Environmental Project No. 13172010. Authors Maag J, Brandt K, Mikkel-sen S,

Lassen C. 87 p

EC – European Commission (2007): Data gathering and impact assessment for a review

and possible widening of the scope of the IPPC Directive in relation to waste

treatment activities. Study N° 07010401/2006/445820/FRA/G1.

EC – European Commission (2008a): Risk assessment hexabromocyclododecane, CAS-

No.: 25637-99-4, EINECSNo.: 247-148-4, Final Re-port May 2008. 492 pp.

EC – European Commission (2008b): Commission staff working paper accompanying

the Proposal for a Directive on waste electrical and electronic equipment (WEEE)

(recast) - Impact Assessment

EC - European Commission (2009): Communication from the Commission ‘ELECTRA’ -

For a competitive and sustainable electrical engineering industry in the European

Union. COM (2009) 594 final, Brussels, 29.10.2009.

http://ec.europa.eu/enterprise/sectors/electrical/competitiveness/electra/ind

ex_en.htm

EC – European Commission (2013): Meeting of the competent authorities under

regulation EC NO 850/2004 (POPS) Follow up on COP6 – HBCDD. Brussels,

24.09.2013. POP CA/2013/05.

ECETOC (2012): ECETOC TRA version 3: Background and Rationale for the

Improvements. Technical Report No. 114. Brussels, July 2012. ISSN-0773-8072-

114 (print). ISSN-2079-1526-114 (online).


January 2014 71

ECHA - European Chemicals Agency (2008): Member state committee support

document for identification of hexabromocyclododecane and all major

diastereoisomers as a substance of very high concern. 43 pp.

ECHA - European Chemicals Agency (2010a): Committee for Risk Assessment RAC

Opinion proposing harmonised classification and labeling at Community level of

hexabromocyclododecane (HBCDD). ECHA/RAC/CLH-O-0000001050-94-03/F

ECHA - European Chemicals Agency: (2010b): Committee for Risk Assessment RAC

Annex 1. Background Document to the Opinion proposing harmonized

classification and labelling at Community level of Hexabromocyclododecane

(HBCDD). ECHA/RAC/CLH-O-0000001050-94-03/A1

ECHA - European Chemicals Agency: (2010c): Guidance on information requirements

and chemical safety assessment. Chapter R. 12: Use descriptor system. ECHA-

2010-G-05-ENEuropean Chemicals Agency 2010.

ECHA - European Chemicals Agency (2011): Guidance on the preparation of socio-

economic analysis as part of an application for authorisation. ECHA-11-G-02-EN.

http://echa.europa.eu/home

ECHA - European Chemicals Agency (2012a): Guidance on information requirements

and chemical safety assessment. Chapter R.16: Environmental Exposure

estimation. ECHA-10-G-06-EN. http://echa.europa.eu/home

ECHA - European Chemicals Agency (2012b): Guidance on information requirements

and chemical safety assessment. Chapter R.18: Exposure scenario building and

environmental release estimation for the waste life stage. ECHA-2010-G-20-EN.

http://echa.europa.eu/home

ECHA- European Chemicals Agency (2012c): Guidance on information requirements

and chemical safety assessment; Chapter R.8: Characterisation of

dose[concentration]-response for human health,

http://echa.europa.eu/documents/10162/13632/information_requirements_r8

_en.pdf

ECHA – European Chemicals Agency (2013). Guidance on Information Requirements

and Chemical Safety Assessment. http://echa.europa.eu/guidance-

documents/guidance-on-information-requirements-and-chemical-safety-

assessment, date: October 2013

ECORYS (2009): Study on the competitiveness of the EU eco-industry. Brussels.

http://ec.europa.eu/enterprise/newsroom/cf/itemlongdetail.cfm?item_id=3769.

EEA – European Environment Agency (2013): Managing municipal solid waste.

EFRA- European flame retardant association (2011): Keeping fire in check in electronic

devices, http://www.cefic-efra.com/images/stories/IMG-BROCHURE-

2.4/EFRA_E&E_brochure_oct2011_v04.pdf

EFSA - European Food Safety Authority (2011): Scientific Opinion on

Hexabromocyclododecanes (HBCDDs), EFSA Panel on Contaminants in the

Food Chain, Parma, Italy; published in ESFA Journal 2011.

EMPA - Swiss Federal Laboratories for Materials Science and Technology (2011):

Improving Plastic Management in Delhi A report on WEEE plastic recycling;

published in 2012 by Toxic Link


72 January 2014

Eggesbø M, Thomsen C, Jørgensen JV, Becher G, Odland JØ and Longnecker MP

(2011): Association between brominated flame retardants in human milk and

thyroid-stimulating hormone (TSH) in neonates. Environmental Research,

Aug;111(6):737-43

Eguchi A, Isobe T, Ramu K, Tue NM, Sudaryanto A, Devanathan G, Viet PH, Tana RS,

Takahashi S, Subramanian A, Tanabe S (2013): Soil contamination by

brominated flame retardants in open waste dumping sites in Asian developing

countries. Chemosphere Mar; 90 (9):2365-71

Ema M, Fujii S, Hirata-Koizumi and Matsumoto M (2008): Two-generation repro-ductive

toxicity study of the flame retardant hexabromocyclododecane in rats.

Reproductive Toxicology, 25, 335-351.

EMPA (2010): RoHS Substances in Mixed Plastics from Waste Electrical and Electronic

Equipment. Final Report, St. Gallen, 2010. CPAN - Climate and Pollution Agency

in Norway (2010): Exploration of Management Options for

Hexabromocyclododecane (HBCD). Paper for the 8th meeting of the UNECE

CLRTAP Task Force on Persistent Organic Pollutants (updated version). Norway,

18 August 2010.

Eriksson P, Fischer C, Wallin M, Jakobsson E and Fredriksson A (2006): Impaired

behaviour, learning and memory, in adult mice neonatally exposed to

hexabromocyclododecane (HBCDD). Environmental Toxi-cology and Pharma-

cology, 21, 317-322.

ESWI – Expert team to Support Waste Implementation (2011): Study on waste related

issues of newly listed POPs and candidate POPs. Final report. Service request

under the framework contract No ENV.G.4/FRA/2007/0066

EU - OSHA – European Agency for Safety and Health at Work (2013): Occupational

exposure limits, https://osha.europa.eu/en/topics/ds/oel/-nomembers.stm, date:

October 2013

Eurostat: Waste Electrical and Electronic Equipment (WEEE) statistics (env_waselee);

extracted August 2013

EU-SCOEL – European Scientific Committee on Occupational Exposure Limits (2013):

http://ec.europa.eu/social/main.jsp?catId-=148&langId=en&intPageId=684, date:

October 2013

Gao S, Wang J, Yu Z, Guo Qm Sheng Q, Sheng G, Fu J (2011): Hexabromocy-

clododecanes in surface soils from e-waste recycling areas and industrial areas in

south China: concentrations, diastereoisomer- and enantiomer-specific profiles

and inventory. Environ. Sci. Technol. 2011, 456, 2093-2099

General Electric (2006):

GESTIS-GefahrenSToffInformationsSystem – (2013). Database of hazardous

substances provided by Institute for Occupational Safety and Health of the

German Social Accident Insurance (IFA),

http://limitvalue.ifa.dguv.de/Webform_gw.aspx, date: October 2013

He MJ, Luo X J, Yu L H, Liu J, Zhang X L, Chen S J, Chen D, Mai BX. (2010):

Tetrabromobisphenol-A and hexabromocyclododecane in birds from an e-waste

region in South China: influence of diet on diastereoisomer- and enantiomer-

specific distribution and trophodynamics. Environmental Science and Technology,

44(15): 5748–5754.


January 2014 73

Huisman, J. et al. (2007): 2008 Review of Directive 2002/96 on Waste Electrical and

Electronic Equipment (WEEE).

IOM (2009): Data on manufacture, import, export, uses and releases of HBCDD as well

as information on potential alternatives to its use, IOM Consulting, supported by

BRE, PFA and Entec under framework contract ECHA/2008/2 (specific contract

ECHA/2008/02/SR4/ECA.226).

IPPC-Bureau - Integrated Pollution Prevention and Control (2006): Reference Document

on Best Available Techniques for the Waste Treatments Industries (BREF WTI)

IPTS (2007): Assessment of the Environmental Advantages and Drawbacks of Existing

and Emerging Polymers Recovery Process.

IPTS (2013): End-of-waste criteria for waste plastic for conversion, Technical proposals,

Final Draft Report, March 2013

KEMI - Kemikalienspektionen- Swedish Chemicals Agency (2006): Survey and technical

assessment of alternatives to TBBPA and HBCDD. Author: Posner, S.

Lilienthal H, van der Ven L, Hack A, Roth-Härer A, Piersma A and Vos J, (2009):

Neurobehavioral effects in relation to endocrine alterations caused by exposure to

brominated flame retardants in rats – comparison to polychlorinated biphenyls.

Human and Ecological Risk Assessment: An International Journal, 15, 76-86.

MORF, L. & TAVERNA, R. (2004): Metallische und nichtmetallische Stoffe im

Elektroschrott., Stoffflussanalyse.

Morf, L., Tremp, J., Gloor, R., Huber, Y., Stengele, M., Zennegg, M. (2005): Brominated

flame retardants in Waste Electrical and Electronic Equipment: Substance Flows

in a Recycling Plant; published in Environmental Science & Technology, 2005.

Morf L.S, Buser A. M, Taverna R, Bader H-P, Scheidegger R (2008): Dynamic substance

flow analysis as a valuable risk evaluation tool- a case study for brominated flame

retardants as an example of potential endocrine disruptors”, Chimia 62 / 2008.

NCM - Nordic Council of Ministers (2008): Hexabromocyclododecane as a possible

global POP. Proposal to list hexabromocyclododecane in Annex A to the

Stockholm Convention. 91 pp.

OECD (2004): Emission scenario document on plastic additives; OECD Environment

Health and Safety Publications Series on Emission Scenario Documents No. 3,

ENV/JM/MONO(2004)8

OECD (2009): Emission scenario document on plastic additives; OECD Environment

Health and Safety Publications Series on Emission Scenario Documents No. 3,

ENV/JM/MONO(2004)8/REV1

Öko-Institut e.V. (2008): Study on Hazardous Substances in Electrical and Electronic

Equipment, Not Regulated by the RoHS Directive. Freiburg

http://ec.europa.eu/environment/waste/weee/pdf/hazardous_substances_re

port.pdf

Ortner, M. (2012): Kombiniertes Verfahren zur Reinigung von KWs (VOC) in

Großshredderanlagen. Tagungsband zur 11. Depotech-Konferenz

Posner, S., Roos, S., Olsson, E. (2010): Exploration of Management options for HBCD.

Swerea IVF AB.


74 January 2014

Salhofer, S, Tesar, M. (2011): Assessment of removal of components containing

hazardous substances from small WEEE in Austria. J Hazard Mater. 2011; 186(2-

3):1481-1488.

Saegusa Y, Fujimoto H, Woo G-H, Inoue K, Takahashi M, Mitsumori K, Hirose M,

Nishikawa A and Shibutani M (2009): Developmental toxicity of brominated flame

retardants, tetrabromobisphenol A and 1,2,5,6,9,10-hexabromocyclododecane, in

rat offspring after maternal exposure from midgestation through lactation.

Reproductive Toxicology, 28, 456-467.

Schlummer, M., Gruber, L., Mäurer, A., Wolz, G. and Van Eldik, R., 2007.

Characterisation of polymer fractions from waste electrical and electronic

equipment (WEEE) and implications for waste management. Chemosphere,

67:1866–1876.

Sjödin A, Hagmar L, Klasson-Wehler E, Kronhol-Diab K, Jakobsson E, Berg-man A

(1999): Flame retardant exposure: polybrominated diphenyl ethers in blood from

Swedish workers. Environmental Health Perspectives 107 (8), 643.

Sun YX, Luo XJ, Mo L, He MJ, Zhang Q, Chen SJ, Zou FS, Mai BX. (2012):

Hexabromocyclododecane in terrestrial passerine birds from e-waste, urban and

rural locations in the Pearl River Delta, South China: levels, biomagnification,

diastereoisomer- and enantiomer-specific accumulation. Environ Pollut. 171:191-

8.

Swerea (2010): Exploration of Management options for HBCD. Swerea IVF Project-

report 10/11.

Takigami H, Hirai Y, Matsuzawa Y, Sakai S. (2006): Brominated flame retard-ants and

brominated dioxins in the working environment and environmental emissions – a

case study at an electronics recycling plant. Organohalogen Compounds 68,

2190-2193

Thomson C, Lundanes E, Becher G (2001): Brominated flame retardants in plasma

samples from three different occupational groups in Norway. Journal of

Environmental Monitoring 3; 366-370.

Tue NM, Takahashi S, Suzuki G, Isobe T, Viet PH, Kobara Y, Seike N, Zhang G,

Sudaryanto A, Tanabe S. (2013): Contamination of indoor dust and air by

polychlorinated biphenyls and brominated flame retardants and relevance of non-

dietary exposure in Vietnamese informal e-waste recycling sites. Environment

International Volume 51, January 2013, Pages 160–167

Tue NM, Sudaryanto A, Minh TB, Isobe T, Takahashi S, Viet PH, Tanabe S. (2010):

Accumulation of polychlorinated biphenyls and brominated flame retardants in

breast milk from women living in Vietnamese e-waste recycling sites. Science of

the total environment 408. 2155-2162.

Umweltbundesamt (2008): Elektroaltgerätebehandlung in Österreich. Zustandsbericht

2008

UNEP - United Nations Environment Programme (2010a): Stockholm Convention on

Persistent Organic Pollutants, Persistent; Supporting document for the draft risk

profile on hexabromocyclododecane; UNEP/POPS/POPRC.6/INF/25

UNEP - United Nations Environment Programme (2010b): Report of the Persistent

Organic Pollutants Review Committee on the work of its sixth meeting Geneva,

11–15 October 2010. Risk profile on hexabromocyclododecane. pp. 43


January 2014 75

UNEP- United Nations Environment Programme (2011): Report of Persistent Organic

Pollutants Review Committee. Hexabromocyclododecane. Risk Management

Evaluation. pp. 21

UNEP- United Nations Environment Programme (2013): Report of the Conference of the

Parties to the Stockholm Convention on Persistent Organic Pollutants on the work

of its sixth meeting. Conference of the Parties to the Stockholm Convention on

Persistent Organic Pollutants Sixth meeting. Geneva, 28 April–10 May 2013.

VKE - Verband Kunststofferzeugende Industrie (VKE) (2003): Kunststoffe in Elektro- und

Elektronikgeräten.

www.plasticseurope.de/cust/documentrequest.aspx?DocID=46028

van der Ven L, van de Kuil T, Leonards PEG, Slob W, Lilienthal H, Litens H, Herlin M,

Håkansson H, Cantón RF, van den Berg M, Visser TJ, van Loveren H, Vos JG

and Piersma AH (2009): Endocrine effects of hexabromocyclododecane (HBCD)

in a one-generation reproduction study in Wistar rats. Toxicology Letters, 185, 51-

62.

van der Ven L, Verhoef A, van de Kuil T, Slob W, Leonards PEG, Visser TJ, Hamers T,

Herlin M, Håkansson H, Olausson H, Piersma AH and Vos JG (2006): A 28-day

oral dose toxicity study enhanced to detect endocrine effects of

hexabromocyclododecane in Wistar rats. Toxicological Sciences, 94, 281-292.

Wu J, Zhang Y, Luo X, She Y, Yu L, Chen SJ, Mai XB (2012): A review of

polybrominated diphenyl ethers and alternative brominated flame retardants in

wildlife from China: Levels, trends, and bioaccumulation characteristics. Journal

of Environmental Sciences 24(2) 183-194.

Yang Y, Qui X, Li R, Liu S, Kequi L, Wang F, Zhu P, Li G, Zhu T (2013): Exposure to

typical persistant organic pollutants from an electronic waste recycling site.

Chemosphere, 91, 205-2011

Zheng XB, Wu JP, Luo XJ, Zeng YH, She YZ, Mai BX (2012): Halogenated flame

retardants in home-produced eggs from an electronic waste recycling region in

South China: levels, composition profiles, and human dietary exposure

assessment. Environ Int. 15; 45:122-8.


76 January 2014

12 ABBREVIATIONS

ABS .................... Acrylonitrile butadiene styrene

BAT .................... Best available technique

BAT AEL ............ BAT associated emission level

BMD ................... Bench mark dose

BREF ................. BAT Reference document

bw ...................... Body weight

CLP .................... Classification, packaging and labelling

COP ................... Conference of parties

CRT .................... cathode ray tube

DecaBDE .......... Decabrominated diphenylether

DNEL ................. Derived no effect level

dwt ..................... dry weight

EEE ................... Electrical and electronic equipment

EPS .................... Expandable Polystyrene

GD ...................... Gestational day

HBCDD ............. Hexabromocyclododecane (same as HBCD)

HIPS .................. High impact polystyrene

IED ..................... Industry Emissions Directive

Koc ..................... organic carbon normalised distribution coefficient

LOAEL(s) ........... Lowest observed adverse effect levels

MSW .................. Municipal solid waste

NOAEC .............. No observed adverse effect concentration

NOAEL ............... No observed adverse effect levels

PBDF, PBDD ...... Polybrominated dibenzofurans/dioxins

PC ...................... Polycarbonate

PCB .................... printed circuit board

PCDF, PCDD ..... Polychlorinated dibenzofurans/dioxins

PBT .................... Persistent, bioaccumulative and toxic

PEC .................... Predicted effect concentration

PND ................... Postnatal day

PNEC ................. Predicted no effect concentration

POP ................... Persistent organic pollutant

PVC ................... Polyvinyl chloride

PP ...................... Polypropylene


January 2014 77

PPE ................... Polyphenylene ether

QSAR ................. Quantitative Structure-Activity Relationship

RAC .................... Risk assessment committee

RAR .................... Risk assessment report

REACH .............. Registration, Evaluation, Authorisation and Restriction of Chemicals

SAN .................... Styrene acrylonitrile

SMEs ................. Small and medium sized enterprises

STP .................... sewage treatment plant

TDI ...................... Tolerable daily intake

WEEE ................ Waste electrical and electronic equipment

XPS .................... Extruded polystyrene

XRF ................... X-ray fluorescence screening


78 January 2014

13 LIST OF TABLES

Table 1: Substance identity and composition (Source: ECHA, 2008) ............... 5

Table 2: Physico-chemical properties of HBCDD (Source: ECHA, 2008, EC, 2008) .................................................................................................... 7

Table 3: Harmonized classification of HBCDD1 ................................................ 9

Table 4: Main findings of developmental and repeated-dose toxicity studies (Source: EFSA, 2011, ECHA, 2008) .................................................. 16

Table 5: Persistent organic pollutant (POP) characteristics of HBCDD ........... 20

Table 6: Environmental parameters in comparison with PBT1 and POPs2 criteria ................................................................................................. 20

Table 7: Findings of eco-toxicity studies (Source: EC, 2008a) ....................... 21

Table 8: Deduced predicted no effect concentrations (PNECs) for different compartments (Source: EC, 2008a) .................................................. 23

Table 9: Preliminary derived no effect levels (DNELs) deduced for the present assessment ........................................................................................ 26

Table 10: Presence of HBCDD in the 10 WEEE categories as specified by Annex I to the WEEE Directive (Source: DEPA, 2010, adapted by Umweltbundesamt) ............................................................................ 27

Table 11: Estimated quantities of HBCDD undergoing the main treatment processes for WEEE and secondary wastes derived thereof (in tonnes per year) ............................................................................................. 31

Table 12: Estimated total HBCDD releases from WEEE treatment processes in the EU (in kg per year) ....................................................................... 38

Table 13: Estimated local HBCDD releases from WEEE treatment processes in the EU (in g per installation and day) ................................................. 38

Table 14: Results of the ECETOC-TRA model for exposure and risk of shredding............................................................................................ 41

Table 15: Comparison of HBCDD contaminated vs not contaminated sites in Europe (adopted from Zhang, 2009; Source: Covaci et al. 2006) ..... 43

Table 16: Selected EUSES input parameters .................................................... 44

Table 17: Selected EUSES input parameters: shredding .................................. 44

Table 18: Results of environmental assessment using EUSES: shredding ...... 45

Table 19: Results of PECs for secondary poisoning: shredding ........................ 45

Table 20: Additional input parameters for the recycling formulation scenario ... 45

Table 21: Results of environmental assessment using EUSES: recycling formulation.......................................................................................... 46

Table 22: Results of PECs for secondary poisoning: recycling formulation ...... 46

Table 23: Additional input parameters for the recycling use scenario ............... 46

Table 24: Results of environmental assessment using EUSES: recycling use . 47


January 2014 79

Table 25: Results of PECs for secondary poisoning: recycling use .................. 47

Table 26: Monitoring data (soil, sediment, biota) from sites near WEEE treatment plants in developing countries ........................................... 49

Table 27: PEC/PNEC ratios for the different scenarios ..................................... 52

Table 28: Alternative flame retardants for HBCDD used in the production of HIPS (Source: adopted from IOM, 2009) ........................................... 54

Table 29: Framework assumptions of the Socio Economic Analysis regarding a ban of HBCDD as flame retardant for EEE (electrical and electronic equipment) ......................................................................................... 56

Table 30: Scenario Management Tableau of the Socio Economic Analysis of a ban on HBCDD as flame retardant in EEE (electrical and electronic equipment) ......................................................................................... 63

Table 31: Summary of HBCDD releases (Source: Table 3-34 of the RAR for HBCDD, EC, 2008a) .......................................................................... 65


80 January 2014

14 LIST OF FIGURES

Figure 1: Large-scale metal shredder plant (Source: Umweltbundesamt, 2008) ................................................................................................ 35

Figure 2: Manual sorting of disintegrated WEEE (Source: Umweltbundesamt, 2008) ................................................................ 35

Figure 3: Installation for further treatment of mixed shredder fractions (Source: Umweltbundesamt, 2008) ................................................. 36