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Comments on report on alternatives to brominated flame retardants

1. Comments on report on alternatives to brominated flame retardants

Background

The European Flame Retardants Association (EFRA) has made a number of comments to the report from the Danish EPA "Alternatives to brominated flame retardants - Screening for environmental and health data" based on other data than those included in the report. In this short note the comments is discussed.

Assumptions

Attention is directed to the fact that the original report is a rapid screening exercise based on readily available data sources as stated in the report. The report is not an assessment of the compounds, but a presentation of the readily available data. The choice of compounds and CAS numbers are not a matter of the report, but is based on a report from Danish EPA (1999) "Brominated Flame Retardants. Substance Flow Analysis and Assessment of Alternatives".

There are a few important other assumptions for the screening report regarding the selected data and the assessment.

Quote from report:
Since the screening is based on compiled results in reviews, handbook and databases the data quality is difficult to evaluate. In the selection of data for the screening emphasis has been given to more recent data and studies performed after test guidelines, wherever this could be identified.

Quote from the report:
Attention is drawn to the fact that no assessment of hazard or risk is made, nor is exposure included in the screening. Since the submission of the report, the database IUCLID has emerged in a new version.

Phrasing in the original report is based on the limited information available from databases etc. In general, the phrasing is not discussed here since it is often directly based on the original text of the reference. The use of the words very toxic, toxic and harmful refers to the definitions in the classification procedure. The use of categorical words such as "non-toxic" is avoided.

The new information provided by EFRA may allow for more precise descriptions and conclusions as suggested by EFRA. This will have to be assessed in combination with the original references or original studies.

The following tables present the original text, the EFRA suggestion and the response side-by-side to provide overview. When the EFRA text is based on information not available at the time of submission of the report, this information is not discussed in detail nor is the consequent changes assessed.

Brief summary

A brief overview of the compounds for which the submitted data may significantly change the rating and conclusions: Resorcinol, melamine, zinc borate.

For the following compounds more precise conclusions can be developed: triphenyl phosphate, tricresyl phosphate, ammonium polyphosphate and red phosphorus.

For the metal compounds the use or no use of parent ion toxicities in addition to compound data can change the screening results.

Generally, the phrasing in a rapid screening document can be improved and many of the suggestions of EFRA are welcomed. To develop the precise phrasing the original and new data should be considered, especially with respect to the use of product data in evaluation of the chemical compounds.

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