rohs annex ii dossier for hbcdd

Substance Name: Hexabromocyclododecane

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

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

(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)

Vienna, October 2013

ROHS ANNEX II DOSSIER FOR HBCDD

Restriction proposal for hazardous substance in electrical and

electronic equipment regulated under RoHS

ROHS Annex II Dossier for HBCDD

Vienna, October 2013 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 ......................................................12

2.1 Use and function of HBCDD ............................................................... 12

2.2 Use of HBCDD in EEE ......................................................................... 12

2.3 Quantities of HBCDD used in EEE .................................................... 13

3 HUMAN HEALTH ......................................................................15

3.1 Human health hazards ........................................................................ 15

3.2 Endpoints of concern ......................................................................... 15

3.3 Existing guidance values ................................................................... 19

3.4 Preliminary DNEL derivation .............................................................. 19

4 ENVIRONMENT .........................................................................22

4.1 Environmental fate properties ........................................................... 22

4.2 Environmental hazard ......................................................................... 24

4.2.1 Eco-toxicity studies ............................................................................... 24

4.2.2 Potential for secondary poisoning ......................................................... 25

4.3 Existing Guidance values (PNECs) ................................................... 26

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


4 Vienna, October 2013

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

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

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

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

6 EXPOSURE ESTIMATION ........................................................ 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 Estimation of risks for workers and neighbouring residents .............................................................................................. 51

7.3 Risks estimation for the environment ............................................... 51

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

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

9 SOCIO-ECONOMIC IMPACT ANALYSIS ................................ 55

9.1 Approach and assumptions ............................................................... 55

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

9.3 Impact on EEE producers .................................................................. 57

9.4 Impact on EEE users .......................................................................... 58

9.5 Impact on waste management ........................................................... 58

9.6 Impact on administration ................................................................... 58

9.7 Total socio-economic impact ............................................................. 59

10 RATIONALE FOR INCLUSION OF THE SUBSTANCE IN ANNEX II OF ROHS ............................................................. 62

11 REFERNCES ............................................................................. 68

12 ABBREVIATIONS ..................................................................... 74

13 LIST OF TABLES ...................................................................... 75

14 LIST OF FIGURES .................................................................... 77



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 221-695-9

b

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

CAS number (in the EC in-ventory):

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

b

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

b

CAS name: Hexabromocyclododecane and

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

IUPAC name: Hexabromocyclododecane

Index number in Annex VI of the CLP Regulation

602-109-00-4

Molecular formula: C12H18Br6

Molecular weight range: 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



Table 1 (continued)

Structural formulac

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

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

cyclododecane.

Remarks There are three main chiral diasteromers present in

technical HBCDD, which are α-hexabromocyclo-

dodecane (CAS No 134237-50-6),

beta-hexabromo-cyclododecane (CAS No 134237-51-7),

gamma-hexabromocyclododecane (CAS No 134237-52-

8).

Depending on the production method technical 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 have been found in lower concentrations

(0.5 and 0.3, respectively).

The composition of HBCDD diasteromers is likely to dif-

fer between products from the different manufacturers,

but also to differ between different products of a single

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

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

a refers to hexabromocylcododecane (withoutspecifiyng the bromine positions) and is used mainly

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

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

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



1.1.2 Physico-chemical properties

Table 2: Physico-chemical properties of HBCDD (Source: ECHA, 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; 2.24g/cm

3

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 tech-nical 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 tech-nical 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



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 a 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 has been submitted by the Swedish

Chemicals Agency in 2009. Since 10 July 2012 HBCDD is listed in Annex VI of

the Regulation (EC) No. 1272/2008 as Repro 2, Lact (for details see Table 3).

Additionally to the harmonised classification HBCDD is classified as Aquatic

Acute 1 and Aquatic Chronic 1 (Hazard class H400 and H410) by numerous

manufactures and/or importers as indicated in the C&L inventory provided 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 Identificati-on

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

Hexabromocyclododecane [1]

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



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) in the REACH regulation. On February 17, 2011 the European

Commission decided to include HBCDD in Annex XIV to 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. On May, 2013 the conference of parties (COP) has decided within the

sixth meeting of 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 of opting-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. The opt-

out is done with binding effect for the Union and all its Member States (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 acquits 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´s 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

th April – 10

th May, 2013

5 Directive 2012/19/EU of the European Parliament and of the Council on waste electrical and elec-tronic equipment (WEEE) (recast)



Occupational exposure limits

No occupational exposure values for HBCDD have been established in Europe

so far. There are no entries regarding occupational exposure limits of HBCDD in

the EU SCOEL (Scientific Committee on Occupational Exposure Limits) docu-

ment database.



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 retarded 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 wiring fittings, electrical appliance parts, business ma-

chines, and interior parts of refrigerators DEPA (2010).

According to DEPA (2010) indication is given that on the European market en-

closures of computer monitors seem generally not to be made of HIPS, but of

acrylonitrile butadiene styrene (ABS) or co-polymer of polycarbonate (PC)/ABS

due to their higher impacts strength and resistance to cracking. It is also stated

that major European manufacturers of TV sets seemed to be using copolymers

like PC/ABS, PS/PPE or PPE/HIPS6 either without flame retardants, or with

non-halogenated flame retardants.

According to GENERAL ELECTRIC (2006) 14% of the global plastic consumption

for flat panel TV sets is HIPS with flame retardants7.

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 Electic, 2006)

Main uses of

HBCDD

Minor uses of

HBCDD

Main uses of

HBCDD in EEE



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.

HBCDD is also used as a flame retardant in printed circuit boards (MORF et al.,

2005). Analysed samples from the Swiss market contained approximately

10mg/kg HBCDD in circuit boards, 10 mg/kg HBCDD in TV housings (wood),

50mg/kg HBCDD in TV/PC housings (plastic) and 1400 mg/kg HBCDD in TV

rear covers. The most abundant detected flame retardants, however, in the ana-

lysed samples have been Decabrominated diphenylether (DecaBDE) and

tetrabromobisphenol A (TBBPA).

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 bigger 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

retarded 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 to

be used for this assessment 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, 2008).

SWEREA (2010) expect that around 10% of the total polystyrene market applies

HBCDD in their end products. According the European Brominated Flame Re-

tardants Industry panel11

5 percent of all HIPS in the EU is flame retarded with

8 another 1.7% of the polymers were none flame retarded PS

9 another 14.3% of the polymers were non flame retarded PS

10 Minor uses of HBCDD in PP, PVC etc. were not considered.

11 Cited in KemI (2006) cited in DEPA (2010)

HBCDD quantity in

European EEE



HBCDD. 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. cooling and freezing appliances (95,000 t/a), in small electronic

appliances (111,000 t/a), in consumer equipment without screens (CRT moni-

tors or flat screens) (100,000 t/a), in CRT monitors (39,000 t/a) and TV sets

(120’000 t/a). Relevant amounts are furthermore used in other large household

appliances than cooling and freezing appliances and in IT equipment other than

screens. According to the authors these figures are characterized by significant

uncertainties.

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

stat12

). Assuming a plastic content in EEE of 30% of the appliance´s weight13

an

overall amount of 1,400 tonnes of HBCDD entering the European market via

flame retarded plastic parts in EEE is assumed for the present assessment.

12

http://www.eea.europa.eu/data-and-maps/indicators/waste-electrical-and-electronic-equipment/assessment-1

13

See e.g. Schlummer et al (2007)





3 HUMAN HEALTH

3.1 Human health hazards

Different official bodies have assessed the toxicity and human health risk re-

lated to HBCDD exposure (e.g., EC, 2008; ECHA, 2010b, EFSA, 2011). The

main outcome of these assessments is summarized below, whereas the end-

points of concern are in more detail depicted in chapter 3.2. For more back-

ground 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, the outcome of toxicological studies re-

vealed that the compound is not corrosive, irritating or sensitizing to the skin.

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 study the carcinogenic effect of

HBCDD further (EC, 2008).

Sub-chronic and chronic toxicity studies identified liver, thyroid, prostate, repro-

ductive, nervous and immune system as the main targets of HBCDDs toxicity

(ECHA, 2008; EFSA, 2011). From the repeated dose toxicity studies a

NOAEL/BMD-L of 22 mg/kg/day was deduced based on changes of the liver

weight (ECHA, 2008).

Since adverse outcomes on the reproductive system have to be harmonised

classified according to the CLP regulation, a proposal for harmonised classifica-

tion and labelling has been submitted by Sweden in 2009, the risk assessment

committee (RAC) has adopted the opinion for a harmonised 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 immune and nervous sys-

tem has been identified as target organs of HBCDD toxicity.

Main findings of studies carried out to investigate toxicity effects of HBCDD on

the developmental 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 developmental study (Saegusa et al., 2009), as well as neurodevel-

opmental studies (Lilienthal et al., 2007, Eriksson et al., 2006). Study outcomes

and deduced toxicological values (such as no observed adverse effect levels –

NOAELs, lowest observed adverse effect levels - LOAELs, bench mark dose -

BMD) are summarised in Table 4.

There are observations of increased postnatal mortality, delayed physical de-

velopment, and alterations in the weight of internal organs in offspring in the

one and two-generation studies (Ema et al., 2008, van der Ven et al., 2009,

Outcome of hazard

assessment(s) in

brief

Acute toxicity

Carcinogenicity

Repeated dose

toxicity studies

Reproductive and

developmental

system

Adverse effects on

development and

fertility



Saegusa et al. 2009) at dose levels inducing mild maternal toxicity. Based on

the available data the contribution of prenatal developmental alterations to

these postnatal manifested effects cannot be excluded (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 with 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 NMRI mice were exposed to a dose of

0.9 or 13.5 mg/kg b.w. of technical HBCDD on PND10. Behavioural effects such

as changes in rearing, locomotion and habituation, in response to a novel envi-

ronment were already observed at a dose level of 0.9 mg/kg b.w. Neurodevel-

opmental effects have been also observed in F1 and F2 offsping at the highest

dose level of approximatly 1000 mg/kg bw in a two generation study carried out

by Ema et al. (Ema et al., 2008). In an one generation study with Wistar rats re-

duced latencies to movement at exposure levels of 0.6-4.4 mg/kg b.w. and for

increased thresholds in the brainstem auditory evoked potential (BAEP) were

observed at 0.2-0.9 mg/kg b.w. per day. In rat offspring from dams that were

exposed from GD10 until PND10 effects on oligodendroglial 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 of 22 mg/kg bw based on the increased liver weight has been de-

duced (ECHA, 2011).

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, 2008). It is supposed that also the effects on the thyroid

system is related to liver enzyme induction, however, there is still some un-

certainty 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, as well as the lymphocyte counts were decreased in the one

generation study. Furthermore, a decreased thymus and popliteal lymph node

weight, an enlarged spleen zone was observed in the one-generation study with

rats.

Table 4 summarises the toxicity values as well as the major outcome of animal

studies conducted in order to investigate the effect of HBCDD on the develop-

ment, fertility and also on the endocrine system (e.g., thyroid hormones). The

respective studies have been thoroughly assessed and are described in the EU

risk assessment report.

Neurodevelopmental

effects

Outcome of

repeated dose

toxicity studies

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

Study type Species Application and exposure levels

Outcome 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, 1500 or 15000 mg/kg diet

10-14, 101-141, or 1008-1363 mg/kg b.w. 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 b.w.)

150 mg/kg diet (10 mg/kg b.w.)

-- 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 b.w. 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 b.w. per day

IgG response:

BMDL20: 0.46 mg/kg b.w. per day

Bone mineral density:

BMDL10 0.056 mg/kg b.w. per day

Retinoids:

BMDL10 1.3 mg/kg b.w. per day

van der Ven et al., 2009

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

Pregnant Spra-gue-Dawley rats


100, 1,000 and 10,000 mg/kg diet

8-21, 81-213, or 803-2231 mg/kg b.w./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 b.w./day)

100 mg/kg diet (8-21 mg/kg b.w./day)

-- Saegusa et al., 2009

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

Wistar

WU

(CBP) rats


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 b.w.

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 b.w. per day

Catalepsy: 0.6-4.4 mg/kg b.w. per day

Lilienthal et al., 2009

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

18

RO

HS

Annex II D

ossie

r for H

BC

DD

18

V

ienna, O

cto

be

r 20

13

Study type Species Application and exposure levels

Outcome LOEL(*) NOEL(*) BMDL* Reference

Developmental Neu-rotoxicity study

NMRI mice Orally, via gavage, single dose.

0.9 or 13.5 mg/kg b.w./ day

PND10

Behavioural disturbances 0.9 mg/kg b.w.

-- -- Eriksson et al., 2006

Repeated dose toxicity studies

90-day oral toxicity study

Sprague Dawley rats

Orally; via gavage;

100, 300 or 1,000 mg/kg b.w. 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 b.w. per day

100 mg/kg b.w. 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 b.w. 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 (fmales)

--- 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 b.w. per day

T4 decrease: BMDL10: 55.5

mg/kg b.w. per day

Pituitary weight: BMDL10 29 mg/kg b.w. per day

Splenocyte count: BMDL20 104 mg/kg b.w. per day

T4 UGT: BMDL10: 4.1 mg/kg b.w. per day

Liver weight: BMDL20: 23 mg/kg b.w. 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, 2008



3.3 Existing guidance values

An overview on derivation of International occupational exposure limits (OELs)

is provided by the European Agency for Health and Safety at work (EU-OSHA

website14

). No international limit values are published on the database of haz-

ardous substances provided by the Institute for Occupational Safety and Health

of the German Social Accident Insurance (GESTIS15

). No OEL has been de-

rived by the European Scientific Committee on Occupational Exposure Limits

(SCOEL)16

. No OELs and threshold limit values (TLVs) of HBCDD are given at

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 Commission17

.

3.4 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 are

going to be estimated based on the REACH guidance18

.

Within the REACH regulation the DNEL (derived no effect level) approach has

become an important method to further characterise a possible risk. The DNEL

is in most cases due to absence of relevant human studies deduced from ani-

mal data.

Within the present assessment the point of departure to calculate the prelimi-

nary DNELs is deduced form the study of Eriksson et al. (2006) based on the

negative impact of HBCDD administered to mice at PN10 on the neurodevel-

opmental behaviour of off-springs at a dose level of 0.9 mg/kg bw.

The recent assessment from EFSA has selected the study of Eriksson et al.

(Eriksson et al., 2006) as basis for human risk characterisation (EFSA, 2011).

Although there are several drawbacks and uncertainties within the use of the

single-dose administration study, the CONTAM Panel stated that there are ar-

guments for the use of the study including that the results provide the lowest

doses leading to effects and that a relevant neurodevelopmental period is cov-

ered by the study, which needs particular consideration. The CONTAM Panel

concluded that based on the uncertainties in the database an application of the

margin of exposure approach is more appropriate than the deduction of a TDI.

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, an assessment factor of 3 for taking into LOAEL to NOAEL extrapolation

14

EU-OSHA: https://osha.europa.eu/en/topics/ds/oel/nomembers.stm 15

GESTIS-GefahrenSToffInformationsSystem – database of hazardous substances provided by In-stitute for Occupational Safety and Health of the German Social Accident Insurance (IFA); http://limitvalue.ifa.dguv.de/Webform_gw.aspx

16 SCOEL: http://ec.europa.eu/social/main.jsp?catId=148&langId=en&intPageId=684 http://www.ilo.org/dyn/icsc/showcard.listCards2

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

18 ECHA Guidance on information requirements and chemical safety assessment; Chapter R.8: Characterisation of dose[concentration]-response for human health (available at: http://echa.europa.eu/documents/10162/13632/information_requirements_r8_en.pdf)

International limit

values

Point of departure

Assessment factors

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

http://www.ilo.org/dyn/icsc/showcard.listCards2

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

http://echa.europa.eu/documents/10162/13632/information_requirements_r8_en.pdf



has been applied. Thus, the applied factor for workers is 150 and for the gen-

eral population 300.

Furthermore a difference in the absorption between rats (85%) and humans

(100%) humans has been considered for the deduction of 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. 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 by correcting

for differences in absorption between routes (5% absorption is considered for

the dermal route). Further correction for exposure during 5 days a week instead

of 7 days a week has been applied to derive a dermal DNEL for workers.

The oral LOAEL in rat was converted into an inhalation corrected LOAEC (in

mg/m3) by using a default 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 m

3).

Preliminary derived no effect levels (DNELs) for worker and general population

for the oral, dermal and inhalation route are presented in Table 5.

Preliminary DNEL

oral

Preliminary DNEL

dermal

Preliminary DNEL

inhalation



Table 5: 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



4 ENVIRONMENT

An in-depth evaluation of the environmental fate properties and adverse effects

on the ecological system of HBCDD has been published in the frame of the

European risk assessment reports in 2008 (EC, 2008).

In the following section the environmental fate properties are described and

compared with the Persistence and Bio accumulative criteria (PBT criteria) set-

tled down in Annex XIII of the REACH regulation, as well as with the criteria in-

dicated in Annex D of the Stockholm Convention (POPs criteria) (Table 7).

The predicted no effect levels (PNEC) depicted in chapter 4.3 have been previ-

ously deduced within the EU RAR (EC, 2008).

4.1 Environmental fate properties

HBCDD has a very high bio-accumulative potential and data have 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 as global persistent organic pollutant (POP)

according to the Stockholm Conventions criteria defined in Annex D and the cri-

teria as persistent, bioaccumulative and toxic (PBT) substance defined in the

REACH regulation (Annex XIII). A brief summary of these evaluations is given

below.

On 18th June 2008 a proposal to amend HBCDD to Annex A to the Stockholm

Convention has been submitted by the Government of Norway. After various

foreseen evaluation steps, the conference of parties (COP) within its sixth meet-

ing (May 2013) has decided to include HBCDD to Annex A to the Stockholm

Convention (UNEP, 2013).

HBCDD meets the criteria defined within the Stockholm Convention to be per-

sistent and bio-accumulative. Furthermore, HBCDD fulfils the characteristics to

have a potential for long-range environmental transport and it possess adverse

effects to organisms.

A brief summary of the evaluation is given in Table 6. Documents for further

readings are provided on the website of the Stockholm Convention19

, at which

the reviewing process of HBCDD is transparent documented.

19

Substances, which have been reviewed within the Stockholm Convention http://chm.pops.int/Convention/POPsReviewCommittee/Chemicals/tabid/243/Default.aspx

HBCDD a global

POP

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



Table 6: Persistent organic pollutant (POP) characteristics of HBCDD

Criterion Outcome

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 Artic 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 Artic environment and has been detected in Artic 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 exerts 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 if these crite-

ria are met has been carried out in the year 2008.

The following table summarises the parameters characterising the environ-

mental fate properties of HBCDD.

Table 7: 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) >2000 l/kg >5000 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 ecotoxicity data that indicate the potential for damage to

human health or to the environ-ment

1 defined in Annex XIII of the REACH-regulation;

2defined in Annex D of Stockholm Convention

PBT Substance



4.2 Environmental hazard

4.2.1 Eco-toxicity studies

HBCDD studies with aquatic species indicate high toxicity (72h EC50 of 52 µg/L

for Skeletonema costatum, NOEC of 3.1 µg/l For Daphnia magna).

Based on these outcomes and also on evidences from mammalian studies, the

T criterion (REACH) is met and also the defined criteria set out in Annex D of

the Stockholm convention to possess adverse effects on environmental organ-

ism.

Results of the eco-toxicity testing described in the EU RAR are depicted in Ta-

ble 8 below (EC, 2008).

Table 8: Outcome of eco-toxicity studies (Source: EC, 2008)

Species Method Results

Aquatic compartment: Fish

Onchorhyncus mykiss (Rainbow trout)

OECD 203 and TSCA 40/797/1400, and ASTM Stan-dard 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 on

eco-toxicity studies



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 (Mos-quito)

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 cepa (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 prosal and 207 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 tvalues 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 possess 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 marine

mammals and birds are highly exposed to HBCDD.

Based on the data assessed within the EU RAR the PNEC for secondary poi-

soning is 5 mg HBCDD/kg wt food (EC, 2008).

A comparison of measured levels in fish and marine mammals indicate that they

are mostly below the estimated PNEC.

Secondary

poisoning



However the PNEC value is uncertain and there are numerous studies indicat-

ing higher HBCDD concentrations (e.g., in marine mammals, eel and brown

trout) than the estimated PEC.

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 8 following PNECs have

been estimated (EC, 2008), which are used in the present evaluation for further

risk characterisation (details see chapter 7.3).

Table 9: Deduced predicted no effect concentrations (PNECs) for different

compartments (Source: EC, 2008)

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

PNECs for different

compartments



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 on the presence of HBCDD flame retarded

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 12) 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 cabinets/ enclosures

HIPS wiring fittings

Brominated epoxy / PCBs

PVC / cables

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

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”.

Only minor percentages can be expected in the fractions “printed circuit

boards“ and “cables”.

Main materials/

components

Minor materials/

components



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 tonnes20

.

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 EEE21

the

quantity of HBCDD in cables derived from WEEE is estimated to account for

maximum 7 tonnes20

.

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

HBCDD containing categories (in particular IT&T, UE and large household ap-

pliances) is either manual dismantling or mechanical separation in a shredder

process. The latter may by be performed in large-scale metal shredders22

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 plastics 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) estimated an overall number of

WEEE dismantling installations and mixed scrap processors of 1300 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.

A relevant share of the potential WEEE arising – be it as waste or as “used

goods” - is supposed to be shipped to third countries. These WEEE may un-

dergo dismantling, dumping or any kind of combustion process.

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.

20

Based on 9.4 Mio EEE placed on the market in the EU in 2010 (Eurostat) 21

Estimation based on sorting analysis of small WEEE (Salhofer & Tesar, 2011) 22

Often called car shredders

Treatment of

separately collected

WEEE

Treatment of WEEE

ending up in

unsorted MSW

Treatment of WEEE

shipped to third

countries

Recycling of

plastics housings



The WEEE-Directive requests the separation of flame retarded plastics from

WEEE during their treatment23

.

However, evidence exists, that such a separation is not made comprehensively

and the plastics parts remain unsorted to a large extent. These mixed fractions

are assumed to be exported to third countries (mainly to Asia) to a considerable

extent24

.

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 mainly derived from dismantling, i.e. large plastic parts including hous-

ings, 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

Subsequent treatment of secondary wastes in third countries may be recycling,

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 EEE25

,

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.

23

In practice such a separation of flame retarded plastics from mixed WEEE plastics may be per-formed by analysis of the presence of Br using easy to handle techniques (XRF). 24

Personal communication Austrian MoE 25

Based on 9.4 Mio EEE put on the market 2010

Treatment of

shredder residues

Treatment of

secondary wastes

resulting from

WEEE treatment in

third countries

Waste management

scenario for HBCDD

containing WEEE



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

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 2010), assumptions made by EC (2008b) and

own estimations.

WEEE treated in WEEE treatment plants in the EU

44 %26

of the overall WEEE arising27

are treated in WEEE treatment plants in

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

Taking into account also the composition of WEEE that are reported to be sepa-

rately collected (Eurostat, WEEE- statistics28

) it is assumed that these are com-

posed 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) thereof are consumer electronics incl. screens (assumed

30% dismantling, 70% shredder)

Thus for separately collected WEEE an overall share of 71% of shredding and

29% 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 incinerated29

.

WEEE shipped out of the EU

41 % of the overall WEEE arising (3.9 Mio t) are assumed to be shipped to third

countries.

26

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 the comparable appliances reported as being separately collected.

27 For the purpose of the present assessment the WEEE arising is seen equal to the amounts put on the market

28 The shares of individual categories in the amounts reported to be separately collected were used

29 See for example EEA (2013)

Assumptions



WEEE Re-Use

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 assumed that two thirds of generated shredder residues are landfilled, the

remaining third is incinerated. Recycling of a minor fraction of plastics derived

from shredding is considered to play a minor role.

Taking further into consideration the material composition of WEEE, for exam-

ple as published by HUISMAN ET AL (2007), and using the same estimates for the

quantities of HBCDD in EEE as described in Chapter 2.330

the HBCDD quanti-

ties entering the main treatment processes were estimated (see 13 below).

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

derived thereof (in tonnes per year)

WEEE Secondary wastes

Separately collected

WEEE

WEEE in unsorted wastes

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

30

14% of WEEE plastics are HIPS, 5% of all HIPS contains HBCDD, concentration of HBCDD in HIPS = 7% as a worst case average HBCDD concentration in WEEE = 0.015%

HBCDD input into

WEEE treatment

processes



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 recycling of plas-

tics in general is expected to increase in future.

The following treatment processes were NOT selected for a quantitative risk

characterization within this assessment:

Manual dismantling, because - as there is neither a mechanical nor a

thermal treatment releases to air, water and soil are assumed to be low

(specific information on releases from / exposure through manual disman-

tling is not available)

Land-filling, because WEEE or materials derived thereof are not the main

source for HBCDD in wastes usually.

Polymers containing HBCDD will accumulate on landfill sites. Degradation of

the matrix will sooner or later cause release of the substance from the ma-

trix. Besides, bio-degradation of HBCDD occurring in the landfill will limit po-

tential future emissions. HBCDD is regularly found in particulate but also in

dissolved phase of landfill leachate31

. Estimations on overall releases of

HBCDD to the environment from landfills were performed in the context of

the RAR HBCDD (EC, 2008). Occupational exposures to HBCDD at man-

aged landfill sites are likely to be very low (IOM 2009).

Incineration under controlled conditions, because WEEE or materials de-

rived thereof are not the main source for HBCDD in wastes usually.

Furthermore a well-functioning emission control is assumed.

Treatment processes under uncontrolled conditions, because WEEE or

materials derived thereof are not the main source for HBCDD in wastes usu-

ally.

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 is done at temperatures below 200°C there is a possibility that HBCDD

containing particles are emitted from the incineration source under uncon-

trolled conditions (Posner et al. 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 PBDDs and PBDFs (EC 2008, RAR HBCDD).

31

According to DE BOER et al. 2002 particulate phase of leachate in nine Dutch landfills contained 15-22 000 μg HBCDD/l. In the study of FJELD et al. 2005 from landfills in Norway, the concentra-tions 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



5.3 Releases of HBCDD from selected WEEE treatment processes

Below information on and estimates of HBCDD releases from the selected

processes 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 BREF WTI (2006) generic emission levels for

dust (PM) associated to the use of BAT are in the range of 5-20 mg/Nm3. How-

ever, treatment of metal wastes, including WEEE, in shredders has been in-

cluded into the scope of IED-Directive recently. Information on the actual dust

emissions from shredders under current operational conditions is scarce32

.

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 fines33

.

MORF ET AL (2004) calculated transfer coefficients for HBCDD during treatment

of small WEEE using a combination of dismantling and mechanical treatment34

.

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

for 437 t/a (compare HBCDD flows in Table 11)

94% of the HBCDD input into a WEEE shredder are transferred to

fluff/fines/dust35

0.1% of fluff/fines/dust are emitted diffusely via PM10 (under dry conditions,

watering of the material and other measures for prevention of diffuse emis-

sions will reduce the percentage by one order of magnitude)

32

Dust concentrations between 1.3 and 18.7 mg/Nm3 for German shredders have been reported

(BDSV, 2012) 33

based on an assumption of 18% generation of fines/dust from materials treated in a shredder and an emission factor of the dry material (g/kg) of 1 g/kg

34 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.

35 Basis for the assumption: Morf et al (2004)

Info on releases

Assumptions

concerning diffuse

emissions



The overall quantity of HBCDD emissions via diffuse dust emissions from sites,

WEEE are shredded, in Europe is estimated to range from 41.1 kg/a36

to 411

kg/a37

. 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 estimation of

HBCDD being 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 m

3/h

38 and a

treatment capacity of 60 tonnes of WEEE per hour39

was assumed.

Furthermore it was assumed that the HBCDD concentration in dust is 60% of

the HBCDD concentration in the WEEE processed40

.

Based on these assumptions41

the total HBCDD releases via residual dust

emissions are about 1.78 kg/a.

In order to estimate the HBCDD releases per installation42

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 tonnes43

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 channeled 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 also various types of mechanical

treatments, such as shredding, milling, etc., where dust is generated. It is as-

sumed that not all of those installations are equipped with efficient dust preven-

tion techniques. Additional HBCDD releases via dust from processing of shred-

der residues in such installations are likely.

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

36

RFair…0.094 g/kg 37

RFair…0.94 g/kg 38

E.g. described by Ortner (2012) 39

Umweltbundesamt (2008) 40

Morf et al 2004 report a HBCDD concentration in dust of 10 mg/kg compared to 17 mg/kg in the processed WEEE

41 RFair…0.004 g/kg

42 According to EC (2007) there are 220 large scale shredders in the EU-25; taking further into ac-count that WEEE are not only shredded in large scale shredders and

43 Capacities of Austrian ELV-shredders: 25 – 60 t/h, assumption 7 working hours per day

Estimates of diffuse

emissions

Assumptions

concerning

emissions

Estimates of

channeled

emissions

Releases per

installation and day

Further

considerations



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 where WEEE are treated including e.g. horizontal

cross flow shredders or special drums may be completed by manual sorting of

the disintegrated appliances along a conveyer belt. The air at these indoor work

places may be sucked or not. Usually workers are required to use masks for

prevention of dust inhalation, however, the practical implementation is consid-

ered improvable.

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

For the further mechanical treatment of mixed shredder residues different op-

tions are realized. Installations exist where the – mostly encapsulated – aggre-

gates are operated outdoors or partly encased. Thus material manipulation by

workers is carried out outdoors or in partly encased places with natural ventila-

tion.

Workplace

description

mechanical

treatment of WEEE



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 Additives44

or the EU RAR on

HBCDD45

point out that the situation regarding recycling of waste plastics is cur-

rently in a state of flux.

According to OECD (2009), the following types of plastics recovery are possi-

ble:

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 avail-

able. 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.

44

OECD, 2009 45

EC, 2008

Info on releases

from HIPS recycling



For estimation of the releases from recycling of HIPS in the present assessment

the same release factors as applied for estimating the 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 46

are as follows:

For water: 0.0076% (0.0053% to surface water 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 %47

.

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 spread from

the process (transport, sawing, and cutting). The other half is assumed to be di-

rected to air as a result of HBCDD and HIPS dust spread to the air from the

process and released to the atmosphere via the ventilation. The resulting emis-

sion factors to both water and air are thus 0.003%. The RAR further assumes a

80-%-connection-rate to sewage treatment plants.

Based on a total HBCDD-input into HIPS-recycling processes of 179 t yearly 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 retarded 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 HIPS48

each

Operation days per year: 220 (see Guidance Document R.18, plastics recy-

cling sector)

46

According to the RAR several site specific information is available 47

The original reference was not found in the OECD-document 48

Basis for the assumption: IPTS (2013): an overall quantity of 50,000 plastics-converters process-es 46 Mio tonnes plastics,

Assumptions

concerning

emissions

Estimates of total

releases

Estimates of

releases per

installation and day



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 retarded 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)


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)


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



6 EXPOSURE ESTIMATION

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 inhalation of airborne dust or by

dermal 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, 2008; 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

within the last 30 years.

An overview on HBCDD levels detected in human breast milk worldwide is

given in the supporting document for the draft risk profile on hexabromocyclo-

dodecane (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, 2008) 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.

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 b.w 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 b.w,

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 reviewing of classification of HBCDD it was postulated that at present

the potential of HBCDD to affect child development at the observed exposure

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



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 estimation performed within this assessment is based on the as-

sumptions and calculations provided in the chapter waste treatment and re-

leases 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 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 like 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, 2010).

No explanation on the differences of the subcategories 24 a, b, c is given in the

R12 guidance nor in the ECETOC guidance (ECETOC, 2012); therefore all

three subcategories have been selected.

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-

ECETOC TRA

Limitations



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

shredding (see Chapter 5.3.1). Thus the estimate of an average content of

HBCDD in the dust of WEEE shredders is 0.0084%. In table 14 the results of

the assessment are summarized.

Parameter PROC

Process category

Long-term Inhalative Exposure Estimate

(ppm for volatiles) / (µg/m3 for solids)

Long-term Inhalative

Exposure Es-timate

(µg/m3)

Long-term Dermal Ex-posure Esti-

mate (µg/kg/day)

conc. solid 24a 2100.00 2100.00 2828.57

conc. solid 24b 3500.00 3500.00 2828.57

conc. solid 24c 14000.00 14000.00 2828.57

HBCDD 24a 0.18 0.18 0.24

HBCDD 24b 0.29 0.29 0.24

HBCDD 24c 1.18 1.18 0.24

DNEC/DNEL 9.00 9.00 75.00

*RCR 24a 0.02 0.02 0.0032

*RCR 24b 0.03 0.03 0.0032

*RCR 24c 0.13 0.13 0.0032

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

* RCR: Risk Characterization Ratio

The comparison of exposure with hazard leads to the risk characterization. Di-

viding the exposure concentration by the derived hazard value (here: DNEC or

DNEL) gives the risk characterization ratio (RCR): a RCR above 1 indicates a

risk for human health for the mentioned concentration and route of exposure.

By comparison of the derived exposure concentrations with the above prelimi-

nary derived DNELs respectively DNECs it becomes visible, that under the as-

sumptions described previously no risk for workers is expected.

However, taking into consideration that other hazardous substances are present

in the WEEE shredders 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 inhalatory and 9 for long

term dermal exposure.

RCR- Risk

Characterisation

Ratio

Occupational risk

identified



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 HBCDD.

Higher levels of brominated flame retardants (BFs) in blood samples of workers

at e-waste sites compared to workers exposed via other industrial processes

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

lipid 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

area are considerably higher compared to non e-waste areas (0.030–3.2

(18*49

)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 compared to control

groups (Takigami, et al., 2006, Tue et al., 2010) and also food items are higher

contaminated (Zheng et al., 2012).

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 (Berkely Center, 2012).

Dramatically increases in hazardous degradation products in human blood or

milk have been found in residents of e-waste regions (Berkely Center, 2012).

49

Values from 2004

Third countries

Hazardous

degradation and

incineration

products



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 within the Stockholm

Convention evaluation to list HBCDD as global POP (UNEP, 2010a) and also in

the EU RAR (EC, 2008).

In general, HBCDD is found widespread in the environment, with very high lev-

els in organism of high trophic levels. HBCDD has been detected in very remote

areas, 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

biomagnification in marine and aquatic food webs. According to recent evalua-

tions the levels are increasing over time, which might be explained due to the

increasing use of HBCDD (EC, 2008, UNEP, 2010b).

According to assessments by Covaci et al. 2006, EC, 2008 and UNEP, 2009

HBCDD is detected at higher concentration levels near point sources (e.g.,

plants producing or pro-cessing HBCDD) compared to areas without obvious

HBCDD sources. Several European hot spots have been identified, such as riv-

ers Viskan (Sweden), Tees and Skerne (UK), Cinca (Spain); and the Western

Scheldt estuary (Netherlands). These areas are related to production of

HBCDD. Covaci et al. (2006) furthermore demonstrates higher contamination

near urban centres and industrial sites.

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/m

3

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 to be a decision-support system for the evalua-

tion of the risks of substances to man and the environment of new and existing

substances and biocides. Within this assessment EUSES 2.1. was used to cal-

culate predicted environmental 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 applicable emission tables

and no special scenario to be selected are integrated in EUSES so far. There-

fore the results of this assessment have limitations. In order to ensure transpar-

ency are the selected input parameters summarized in Table 16.

Global pollutant

Contaminated sites

EUSES

Limitations



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 in total 36 g were taken as local emissions to the air as

presented in table 12 chapter 5.3.3. 437 t/a as total input of HBCDD in WEE

shredders was taken 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



The derived local PECs are given in table 17 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

Further the risk of secondary poisoning has been evaluated; the calculated con-

centrations in fish are summarized in table 18.

Table 19: Results of PECs for secondary poisioning: 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

Shredding: PECs

Shredding: PECs

secondary

poisoning

Recycling: input formulation



The derived local PECs are given in table 21 below

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

The derived local PECs are given in table 24 below.

Recycling: PECs

formulation

Recycling:

formulation:

Secondary

poisoning

Recycling: use

input parameters



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

So far, no investigation of a potential HBCDD contamination near European

WEEE treatment plants has been performed.

There are numerous recent investigations- determining the HBCDD contamina-

tion levels from areas near WEEE treatment sites/locations - carried out in de-

veloping 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, 0.22-0.79 ng/g dw and 5.4-

400 ng g-1 dw (Gao et al., 2011; Tue et al. 2012, Eguchi et al., 2013).

Soils of e-waste areas have up to 100 fold higher HBCDD exposure levels

compared to reference sites. In particular the e-waste recycling areas of China

and Vietnam have high HBCDD exposure levels (up to 400 ng/g dw) (Tue et al.

2013). The detected HBCDD concentrations are comparable with levels of

HBCDD point sources (producing and formulating plants) in Europe (111-23

200 ng/g dw) (Covaci et al, 2006).

Recycling: use

PECs

Recycling: use

Secondary

poisoning

Developing

countries

Soil



Only one study is available, in which HBCDD levels in sediments from an e-

waste dismantling site in China are measured. Total HBCDD mean concentra-

tion in sediments is between 4.6 to 35 ng/g dw. The authors state that these

values are higher than those of not obvious 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., nd-1995 ng g-1 lipid wt. for winkles, crucian craps, and different

birds, respectively.

Analyses of birds samples revealed that birds within e-waste areas contain

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 results 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 transforma-

tion products as polybrominated dioxins and furans, which pose a risk to organ-

isms and accumulate in the food chain.

Aquatic species near WEEE plants in developing countries contain comparable

HBCDDs levels to those from contaminated sites (e.g. HBCDD production sites)

in Europe (Covaci et al. 2006; Wu et al., 2012), which gives a clear indication

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 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

Ann

ex II D

ossie

r for H

BC

DD

Vie

nna, O

cto

be

r 20

13

49

Table 26: Monitoring data (environmental compartments, biota, and human diet) from sites near to WEE 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 in e-waste recycling site (284 ng g

-1 dw)

and total level decreased within the distance from recycling site.

Gao et al., 2011

Soil 5.4-4001

0,99-611 Vietnam E-waste recycling

Significantly higher levels in e-waste recycling areas compared to urban areas

Tue et al., 2013

Soil nd-2.51 nd-1.4

1

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

Dumping sites -- Eguchi et al., 2013

Sediments

Sediments

4.6-351 <10

1,3 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 - 333

2

Crucian crap: 199-728

2

Loach: 934- 3529

2

Aquatic invertebrates: 1,3-106

2,3

Freshwater fish: 12-160

2,3

China E-waste dismantling site Higher contamination levels compared to other areas without known sources.

Very high concentrations have been detected in loaches.

Zhang et al., 2009

Aquatic species 11-23702 Aquatic invertebrates:

1,3-1062,3

Freshwater fish: 12-160

2,3

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 higher contaminated compared to urban site (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



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 therefore is that the use of other brominated flame retardants

in products, including those using recyclates, is already restricted by the RoHS

Directive 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)).

In practice the separation of plastics containing restricted brominated substanc-

es from mixed plastics are performed using simple screening methods (e.g. X-

ray fluorescence 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 contains substances which must not

be recycled and that this plastics must not be recycled. In practice plastics with

HBCDD consequently cannot be recycled, even though the use of recycled

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 retarded plastic parts from plastic parts with restricted

brominated flame retardants by the use of XRF screening, and the plastic parts

may be recycled. The enclosure parts are typically of a size that makes recy-

cling practicable.

Under current operational conditions removal of plastics containing brominated

flame retardants is hardly implemented. The resulting mixed WEEE plastics are

to a considerable extent exported to Asia. Indication is further given, that in the

import countries plastics containing flame retardants, including HBCDD, are not

separated and HBCDD is transferred to recycled plastics, used also in products

which do not need flame retardants, e.g. hair combs. Comparably high recycling

rates for plastics waste in some third countries (e.g. close to 60% India, (EMPA,

2011)) 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

contain HBCDD an annual quantity of approximately 20,000 tonnes of hazard-

ous HIPS waste would arise.

The only legal options for treating HBCDD containing plastics are to dispose

them in a landfill for hazardous waste or to incinerate them in an expensive

plant for hazardous waste incineration.

Reduced recycling

possibilities

HBCDD remaining in

the recycling loop

Generation of

hazardous waste



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 in plants for non-hazardous waste incin-

eration, landfilled, both reducing the life time of the plants and (over time) re-

leasing HBCDD to the environment.

7.2 Estimation of risks for workers and neighbouring residents

No human biomonitoring studies in the neighbourhood of WEEE treatment sites

in Europe have been identified so far. HBCDD has been identified as PBT sub-

stance and will be listed as POP to Annex A of the Stockholm Convention. Al-

though there has been no risk identified for workers under occupational condi-

tions 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 contaminates these regions for decades and will con-

tribute to the body burden of the residents in this region and pose a risk to fu-

ture generations.

Main targets for HBCDD toxicity are the liver, thyroid hormone homeostasis, the

reproductive, the nervous and the immune system. 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 is contaminated with this long lasting pollutant.

7.3 Risks estimation for the environment

In case of HBCDD environmental releases have due to its persistency, ten-

dency to accumulate and magnify in the food chain and its toxicity to be mini-

mized anyway. However, in order to assess if the HBCDD exposure of the

herein described scenarios pose a risk to the environment the PEC/PNEC ratios

have been calculated. In general if the ratio of the predicted environmental con-

centration to the concentration which is expected to pose no risk is higher than

1 a risk can be expected and risk reduction measures should take place. In ta-

ble 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 secon-

dary poisoning. Even if the secondary poisoning could be overestimated by

EUSES and also due to the difference of PNECs which are usually given in dry

weight (sediment, soil, fish) whereas PECs are calculated in wet weight it can

be expected that the herein described waste treatment processes lead to a risk

for the environment.

No PNECs are usually derived for the air compartment, but it is known, that

HBCDD can be detected in eggs of terrestrial birds in Europe; increasing con-

centrations have been reported for several marine bird species as well as in

arctic birds-eggs (EC, 2008). Potential for in vivo endocrine disruption of the re-

Contribution to

corrosion in waste

incineration

Europe

Third countries

POP

Risk identified



productive and thyroid hormonal has been reported on European Flunder (EC

2008).

Table 27: PEC/PNEC ratios for the different scenarios

PECs PNECs PEC/PNEC ratios

shredding rec-form rec-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

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



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). However, some of

these substances possess adverse effects and therefore human health con-

cerns, as well as concerns regarding environmental fate properties and toxic ef-

fects on environmental organisms.

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 biodegrad-able, low to moderate bioaccumulation poten-tial

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 ether - DecaBDE (in combination with ATO**)

1163-19-5 Neurotoxicant Not readily biode-gradable, low to mod-erate bioaccumulation potential; On the EU SVHC candidate list identified as substance with PBT** properties

no HC; SC: Acute Tox. 4; Eye Irrit. 2; Muta. 2; STOT RE 2; Aquatic Chronic 4;

Decabromodiphenyl ethane (in combination with ATO**)

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

Not readily biodegrad-able, may be persistent

no HC; SC: Aquatic Chronic 4

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

32588-76-4 Low toxicity Not biodegradable and is 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

Bis phenol 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-ism

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 (avail-able 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;

Substitutes for

HBCDD in HIPS

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



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 the use of non-

halogenated flame retardants (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 in regard to human toxicity, but da-

ta for critical endpoints are missing (IOM, 2009).

Based on the available data regarding the hazardous properties we assumed

that co-polymere of HIPS and polyphenylene ether (PPE) in combination with

halogen-free flame retardants as in regard to the toxicological profile as the

most suitable alternative and used this alternative for further socio-economic

impact analysis.

Alternatives for

HIPS in EEE

Conclusion



9 SOCIO-ECONOMIC IMPACT ANALYSIS

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 scenar-

ios:

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 option which should give the highest benefits

with respect to reducing environmental 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 for the frame assumptions of this analysis. Following as-

sumptions are taken:

The selection of HBCDD or of its alternative does not have an effect on the

life time of the EEE or its usability.

Approximately 20,000 tonnes of HBCDD containing plastics (HIPS) are sold

annually 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 con-

tained in the EEE sold in the EU (see chapter 2.3). Thus if HBCDD would be

banned in EEE this may result in the reduction of 1,400 tonnes of HBCDD

consumption annually.

Table 29 summarises the described frame assumptions.

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

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

Parameter Assumption

Effect on life time of EEE Negligible effect

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 bromine production globally

and produce a range of brominated compounds. They also manufacture differ-

ent halogen-free flame retardants like organo-phosphorous compounds and

magnesium hydroxide. These three companies jointly formed the European

Brominated Flame Retardant Industry Panel (EBFRIP) representing these three

main members, as well as a number of major polymer producers as associate

members. These companies are vulnerable to changes in the demand for bro-

minated flame retardants; however, the same companies also manufacture

some of the alternatives.

The manufacturers of alternative flame retardants would benefit from a restric-

tion 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 com-

pounders 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 compared to their larger competi-

tors. The relatively larger burden for SMEs holds for 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 retarded plastics for EEE al-

ready have procedures in place for ROHS compliance, the differences between

the SMEs and larger companies is probably not as large as seen by the initial

implementation of the RoHS Directive. The companies offering the alternative

flame retardants are large companies, and they serve as general customer ad-

visers when it comes to adjusting polymer formulations and production setup,

however, the burden of identification of suitable alternatives and R&D by 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 a chance for the European production industry.

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) then 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 fall at the formulators and converters of HIPS

(and other plastics),which likely in some cases will include the EEE manufactur-

ers, especially with regard to HIPS housings. The major technical costs are the

costs for more expensive flame retardants, higher loadings 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 are already devel-

oped and on the market. Costs for mould changes can be reduced significantly

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 a halogen-free plastics,

additional material and investment costs of 31.3 Million € occur annually (see

Table 30 below).

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 as in scenario B for switching to bromine-free

plastics.

With respect to jobs it is expected that the higher turnover of the flame retardant

and plastic industry 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 recede, in Sce-

nario A by additional emission reduction measures and in Scenario B by the

ban of HBCDD. While both scenarios may lead to similar results in the EU, from

a ban of HBCDD also the workers and the environment abroad would benefit.

9.3 Impact on EEE producers

Production of EEE is substantial in the EU. However, a large part of the total

end-user consumption of EEE is imported as finished goods from outside the

EU. This is notably the case for small household appliances, consumer elec-

tronics, IT equipment, and toys etc., but also for other EEE groups.

As the service of the plastic used in EEE does not change when switching from

HBCDD as flame retardant to HIPS/PPE with halogen-free flame retardants, no

major effect is expected for the EEE producers. The higher costs of the plastics



occur for all EEE producers selling to the EU market. Thus no change in the

relative competitive position of the different EEE producers is to be expected

from a HBCDD ban.

As compared to the turnover of the EU electrical engineering industry of 411 bil-

lion € in 2008, the additional costs of 31.3 million € (+0.008 %) is so small that

no influence on the market needs to be feared. In any case additional costs are

to be expected with and without the ban.

9.4 Impact on EEE users

The major impact on EEE users, is the additional costs which are to be borne

by the EU industrial and private consumers. It is to be expected that a some-

what higher price of the EEE draws on the competitive position of the European

industry as a whole causing some jobs to be lost. On the other hand, jobs are

created as an essential part of the additional costs are spent for the benefit of

European plastic producers and environmental industry.

In any case additional costs are to be expected for both scenarios, with and

without a ban of HBCDD. As the amount of the additional costs should be simi-

lar in both cases, the ban of HBCDD should not be more expensive than the op-

tion of staying with the HBCDD.

With respect to the benefits, however, there is a difference between the scenar-

ios. In rare cases EEE start to glow or burn. Then an EEE which does not con-

tain bromine can be expected to be less harmful to the user of the EEE than an

EEE which contains HBCDD.

9.5 Impact on waste management

For details on impacts of HBCDD in EEE on waste management refer to Chap-

ter .7

In total the benefits for the waste management sector of banning HBCDD in

EEE can be summarized as:

Reduced environmental and health impacts (Increased recycling potential

Reduced corrosion of waste incineration plants

For the waste management sector no substitution costs occur, as with the exist-

ing equipment bromine-free plastics can even be treated better than HBCDD

containing plastics.

9.6 Impact on administration

According to DEPA (2010) extra compliance costs related to the addition of one

new substance under RoHS are expected to be minimal for companies which

have already implemented RoHS, that is, for most companies which are rele-

vant for this analysis. HBCDD is typically used in parts where deca-BDE have

traditionally also been used and compliance documentation would usually be

required for such parts.



The main extra costs are estimated to be related to control; both by the manu-

facturers, importers and the authorities. The presence of HBCDD cannot be de-

termined by simple XRF screening (only the presence of Br), therefore sam-

pling, extraction and laboratory analysis is required. As the parts that may con-

tain HBCDD typically may also contain other RoHS substances the extra costs

would mainly comprise the costs of analysis as the sampling and sample prepa-

ration would in any case be undertaken for control of other RoHS substances in

the parts.

The administrative costs for Scenario B (ban of HBCDD) are estimated as fol-

lows:

DEPA (2010) estimates that the additional costs for proving that the produced

plastics is 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

the average two test samples have to be provided by company and year,

proving that the produced plastics is HDPCC free the total administrative

costs for the EU are 3.3 million €/year.

But also in Scenario A (no ban of HBCDD) additional administrative costs occur.

As explained above, in this scenario emission reduction measures are required.

Public administration is required to keep control that these measures are effec-

tive. For the scenario analysis it is assumed, that the costs for monitoring the

emission reduction measures are as high as the costs for monitoring a HBCDD

ban.

In both scenarios, however, the administrative costs are not lost costs, as they

increase the turnover of the chemical analysis industry.

9.7 Total socio-economic impact

When comparing the costs of the Scenario A (no HBCDD ban) with the costs of

a Scenario B (with HBCDD ban) it is expected, that:

Without a ban of HBCDD flame retardant and plastics producers will have to

invest in additional emission reduction measures

With the ban of HBCDD flame retardant and plastics producers will have to

deal with higher material costs and investments in new moldings.

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

Also in both scenarios the total effect on jobs is expected to be neutral. While

some jobs are lost in the industries using EEE, some jobs are created with

flame retardant/plastic producers and the environmental industry. In any case,

also with respect to jobs the difference between the 2 scenarios and thus the ef-

fect of a HBCDD ban should be very small.

With respect to the benefits, however, the difference between the two scenarios

is big. While the implementation of emission reduction measures in scenario A

provides only for a better protection of the workers in and the environment



around the flame retardant / plastic production sites in Europe a ban of HBCDD

generates following additional benefits:

Increase in the competitive position of environmentally friendly industry

Globally reduced environmental and health impacts during HBCDD and plas-

tics production

Reduced environmental and health impacts during especially waste phase


Reduced generation of hazardous waste

Increased recycling potential of plastics

In total the ban of HBCDD creates no additional costs as compared to a non-

ban scenario while creating substantial additional benefits for health, environ-

ment and economy.

Table 30: Scenario Management Tableau of the Socio Economic Analysis regarding a ban of HBCDD as flame

retardant for EEE (electrical and electronic equipment)

Scenario A – no ban of HBCDD

Scenario B – ban of HBCDD

Difference of Sce-narios (B-A)

Material used for EEE plastics HIPS with HBCDD as flame retardant

HIPS/PPE with halo-gen-free flame retar-dants

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 0 0

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 environ-mental and health im-pacts during HBCDD and plastics produc-tion also 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 waste phase

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



Increased recycling potential

Increased recycling potential



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 wastes50

.

The RAR for HBCDD (EC, 2008) identifies EPS and XPS insulation boards as

the most relevant post-consumer waste streams. Regarding the actual releases

of HBCDD from demolition of buildings there is generally a big uncertainty de-

pending very much on the techniques used for demolition. Nevertheless rough

estimates for 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 were estimated to account for 108

kg/a for a 30% share of boards being recycled after manual removal from build-

ings plus an estimated 5,600 kg/a resulting from demolition of buildings contain-

ing the remaining 70% of EPS/XPS boards. Releases from further waste man-

agement operations were not 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 little 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 sub-

jected to mechanical treatment processes several times during the overall

treatment chain, it is expected that the actual releases might even be higher.

HBCDD releases to air and waste water from recycling of WEEE-HIPS parts,

each approximately 25.7 kg/a, are estimated to be lower than releases from

mechanical treatment of WEEE.

In any case, overall releases from WEEE treatment (compare Table 12) are ex-

pected to be far lower than the releases estimated to arise from EPS/XPS con-

taining demolition boards (5,780 kg/a from recycling and demolition of buildings

in a worst case scenario).

50

In general RAR HBCDD provides little information on releases of HBCDD containing products af-ter they became waste.

WEEE treatment

compared to

treatment of other

post-consumer

wastes



Compared to the overall releases of HBCDD to air other than those resulting

from waste management activities estimated in the RAR for HBCDD (i.e. 508

kg/a; see Table 31 below) the releases from WEEE treatment are either in the

same order of magnitude (420 kg/a) or down to one order of magnitude lower

(50 kg/a), when measures for prevention of dust emissions are taken.

Releases into waste water from WEEE treatment are expected to be of little

relevance (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 treatments of WEEE.

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

EC, 2008)

Releases from

WEEE treatment

compared to total

HBCDD releases



Risk for human health

A risk for workers is expected in facilities where HBCDD containing plastic

parts from WEEE are recycled.

Based on an estimated number of 50 installations where HBCDD-containing

plastics are processes/recycled and taking into account an average of 25 em-

ployees in the plastics processing sector the number of affected workers is es-

timated to account for 1,250.

Shredding, applied outdoors, is considered to be of lower health relevance.

However workers might be at risk because they are exposed to a mixture of

hazardous substances contained in shredder dust. Even if the risk characteriza-

tion ratio is below 1, the safety margin is in some cases below the factor of ten.

Based on an estimated number of 450 installations in the EU where WEEE and

materials derived thereof are treated mechanically and assuming 5 to 15 work-

ers per installation51

, the estimated range of workers exposed to HBCDD re-

leases ranges between 2,250 to 6,750.

Considerable higher risk is expected due to uncontrolled treatment in third

countries. Neighbouring residents of waste treatment sites are also at risk due

to hazardous degradation and incineration products. Especially risks for

unborn and breast fed children have been identified and health effects have

been reported.

Exposure of the environment

For shredding of WEEE and recycling of HIPS the environmental exposure was

estimated from the calculated HBCDD releases using the EUSES. 2.1 system

for evaluation of substances. Comparable with other industrial processes local

HBCDD concentrations at sites where WEEE are shredded and HIPS is recy-

cled are more than one order of magnitude higher than background concen-

trations.

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

tion of the environment due to WEEE treatment.

Risk for the environment

For shredding of WEEE52

and recycling of HIPS53

, a risk for the aquatic com-

partment as well as for secondary poisoning for the aquatic, marine and

terrestrial compartment has been identified. The major concern is that accu-

mulation of such substances in the food chain presumable result in adverse ef-

fects in the long term. Especially top predators are at risk due to 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 endangers espe-

51

Estimation based on Umweltbundesamt (2008) 52

Involved number of sites: at least 450 53

Involved number of sites: 50

Workers in plastics

recycling

Workers in

mechanical

treatment of WEEE



cially sensitive and endangered species and affects sensitive stages of de-

velopment.

Main influencing factors within the assessment

Regarding the establishment of the waste management scenario and determi-

nation of environmental releases there are 2 major factors:

The annual quantities of HBCDD actually contained in the collected WEEE

are influenced by various factors, including the actual HBCDD put on the Eu-

ropean market via EEE, the lifespan of EEE, the actual WEEE collection

amounts.

The degree of application of measures for preventing diffuse emissions 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 were used. As these are not yet aligned to evaluate waste expo-

sure scenarios because no process categories, emission tables and special

scenarios are integrated, appropriate scenarios were defined, emissions and re-

leases calculated and then used as input parameters 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 WEEE plastics recycling as it is not distinguishable with routine de-

tection methods from other brominated flame retardants.

The extent to which HBCDD remains in the recycling loop

In practice removal of plastics containing brominated flame retardants is hardly

implemented. Indication is given that especially in third countries plastics con-

taining flame retardants, including HBCDD, are not separated and HBCDD is

transferred to recycled plastics, used also in products which do not need flame

retardants, e.g. hair combs. In those countries high recycling rates are realized.

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

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.

Other negative impacts on waste management

In waste incineration plants HBCDD containing plastics contribute to corrosion

increasing treatment costs and lowering the life-time of the plants.



Available Alternatives

The availability of substitutes/alternatives with less negative properties

Both is available, substitutes for HBCDD in HIPS and alternatives for HIPS in

EEE. These include also substances with lower hazardousness compared to

HBCDD, in particular p-based flame retardants.

Technical and economical feasibility of the alternative substance

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).

Socio-economic impact analysis

In total the ban of HBCDD creates no additional costs as compared to a non-

ban scenario (which requires investments in emission reduction measures)

while creating substantial additional benefits for health, environment and econ-

omy.

The costs of a potential restriction of HBCDD (higher material costs and invest-

ments in new moldings for the producers) in EEE compared to no action (costs

for additional emission reduction measures) are considered to balance each

other. Also in both scenarios the total effect on jobs is expected to be neutral.

With respect to the benefits the difference between the two scenarios is big.

While the implementation of emission reduction measures in scenario A pro-

vides only for a better protection of the workers in and the environment around

the flame retardant / plastic production sites in Europe a ban of HBCDD (sce-

nario B) generates 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



Draft Conclusion:

It is recommended to include HBCDD in Annex II to the RoHS-Directive be-

cause:

a risk for the environment caused by both, shredding of WEEE and recy-

cling of HBCDD containing HIPS, is expected: for the aquatic compartment

and for secondary poisoning

a risk to human health of workers involved in the recycling of HBCDD con-

taining plastics is expected

a risk for neighboring residents is expected, especially in third countries

the overall releases from the relevant WEEE treatments are a relevant

contributor to the total HBCDD releases to air

there are several negative impacts on the waste management (reduced

recycling possibilities for WEEE plastics, generation of considerable amounts

hazardous wastes, corrosion in incineration plants where HBCDD containing

plastics are processed, stays long in the recycling loop)

alternatives with less negative properties are available and technically and

economically feasible, in particular P-based flame retardants

the socio-economic analysis revealed no additional costs but several benefits

from 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 by Annex IV to the EU POPs Regulation (850/2004/EC) for most POPs,

i.e. 0.005 %.



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12 ABBREVIATIONS

ABS .................... acrylonitrile butadiene styrene

BMD ................... Bench mark dose

CLP .................... Classification, packaging and labelling

DecaBDE .......... Decabrominated diphenylether

DNEL ................. Derived no effect level

EEE ................... Electrical and electronic equipment

HBCDD ............. Hexabromocyclododecane (same as HBCD)

HIPS .................. High impact polystyrene

LOAEL(s) ........... Lowest observed adverse effect levels

MSW .................. Municipal solid waste

NOAEC .............. No observed adverse effect concentration

NOAEL(s) .......... No observed adverse effect levels

PC ...................... Polycarbonate

PBT .................... Persistent, bioaccumulative and toxic

PEC .................... Predicted effect concentration

PNEC ................. Predicted no effect concentration

POP ................... Persistent organic pollutant

PVC ................... Polyvinyl chloride

PP ...................... Polypropylene

PPE ................... Polyphenylene ether

RAC ................... Risk assessment committee

RAR ................... Risk assessment report

REACH .............. Registration, Evaluation, Authorisation and Restriction of Chemicals

SMEs ................ Small and medium sized enterprises

WEEE ................ Waste electrical and electronic equipment

XRF ................... X-ray fluorescence screening,



13 LIST OF TABLES

Table 1: Substance identity and composition (Source: ECHA, 2009) ............. 5

Table 2: Physico-chemical properties of HBCDD (Source: ECHA, 2009) ....... 7

Table 3: Harmonized classification of HBCDD1 ............................................... 9

Table 4: Examples of developmental and repeated-dose toxicity studies

(cited in EC, 2008 and ECHA, 2008, EFSA, 2011) .......................... 17

Table 5: Preliminary (not by technical committees reviewed) derived no

effect levels (DNELs) deduced for the present assessment ............ 21

Table 6: Persistent organic pollutant (POP) characteristics of HBCDD ........ 23

Table 7: Environmental parameters in comparison with PBT1 and POPs

2

criteria .............................................................................................. 23

Table 8: Outcome of eco-toxicity studies (Source: EC, 2008) ....................... 24

Table 9: Deduced predicted no effect concentrations (PNECs) for

different compartments (Source: EC, 2008) .................................... 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 entering 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 poisioning: 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

Table 25: Results of PECs for secondary poisoning: recycling use ................ 47

Table 26: Monitoring data (environmental compartments, biota, and

human diet) from sites near to WEE 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) ..................................... 53

Table 29: Frame assumptions of the Socio Economic Analysis regarding

a ban of HBCDD as flame retardant for EEE (electrical and

electronic equipment) ....................................................................... 55

Table 30: Scenario Management Tableau of the Socio Economic Analysis

regarding a ban of HBCDD as flame retardant for EEE

(electrical and electronic equipment) ............................................... 60

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

for HBCDD, EC, 2008) ..................................................................... 63



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