HBCDD – ECHA committees recommend authorisation under REACH: PFA’s strong input to a landmark decision
March 16th, 2015
Hexabromocyclododecane (HBCDD) will require authorisation to be used in the EU after August 21st 2015 (the ‘sunset date’) under the REACH Regulation. This is because of HBCDD’s persistent, bioaccumulative and toxic (PBT) properties.
A key use for HBCDD is as a flame retardant in expanded polystyrene (EPS). EPS is used as an insulating material in buildings, and fire resistant EPS is a requirement in a number of EU countries. The EPS industry has identified an alternative to HBCDD, but a number of EPS producers determined that there would not be enough of the alternative (a polymer) available for them to switch before the sunset date. This meant that a number of EU-based EPS manufacturers would need to apply for an authorisation to bridge the gap between them phasing out the use of HBCDD and fully switching to the alternative flame retardant.
A consortium of EPS producers made an application for authorisation (AfA) for limited continued use of HBCDD. The application comprised a chemical safety report (CSR), an analysis of possible alternatives to HBCDD (AoA) and a socioeconomic analysis report (SEA). The SEA demonstrated that the benefit to society as a whole of a short term use of HBCDD outweighed the risks to the environment.
The application has been assessed by the ECHA risk assessment committee (RAC) and the socioeconomic committee (SEAC). The recommendation from the SEAC was to grant the application for a limited period of 2 years. The recommendation will be reviewed by the European Commission, who makes the decision on whether to grant or refuse the authorisation.
This is the first time that an authorisation application for a PBT substance has been assessed by the ECHA committees and it was a tough decision, since for a PBT any release into the environment is considered a risk. There are widely acknowledged technical difficulties in fully quantifying the environmental impacts that result from PBTs in the environment, which makes the decision-making on this aspect tricky.
PFA worked as technical consultants (with expert economists eftec Ltd) on the EPS consortium’s authorisation application for HBCDD, with ReachCentrum managing the consortium and application. PFA developed a model for HBCDD in the environment, which was presented in the application in order to describe the additional contribution that the continued use would make to the environmental burden of HBCDD and how that would change over time. PFA continues to work on dynamic modelling of the environmental fate of PBTs and very persistent and very bioaccumulative (vPvB) substances, as well as the potential environmental impacts of PBT/vPvB substances.