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Mapping of decabromodiphenylether (decaBDE) in other products than electrical and electronical products 7 Conclusion and summary
This report presents the result of the project ”Mapping of decabromodiphenylether (decaBDE) in other products than electrical and electronical products”. The project is part of the Danish EPA’s continuous initiatives on the consumer product area. The project was purposed to map the use of decaBDE in products that are not covered by the RoHS Directive and give an assessment of trends and alternatives to use of decaBDE in this type of products. The project’s initial phase is mapping and collection of present knowledge on use of decaBDE in products that are not covered by the RoHS Directive, while a potential second phase will consist of a number of chemical analyses of selected product groups with the purpose to procure missing knowledge occurrence and amounts of decaBDE in these product types. DecaBDE is used as an additive to obtain a flame-retardant effect. Normally this would mean concentrations in percentage levels in the products. In connection with this project this means that concentrations on trace levels due to unintentional contaminations are uninteresting and thus not included in this mapping. 7.1 MethodThe mapping of the use of decaBDE in Denmark has been completed in accordance to the Danish EPA’s paradigm for mass flow analyses (item 1.1-2.3 and 4.1). DecaBDE is not produced in Denmark and the substance may thus theoretically enter the Danish market through import of the chemical or as part of semi-finished products or finished goods. The three routes are investigated separately. The information on imported chemicals and semi-finished products are collected through public registers and contact to trade associations, while the information of finished goods are collected through identical channels added inquiry to companies in the relevant trades. A detailed questionnaire containing questions on decaBDE content in imported products and knowledge of alternatives and trends has been sent to approximately 1000 Danish companies. The total response rate is approximately 20% from the contacted companies. Naturally the low response rate has an impact on the validity of the results – not least due to the few ”findings” of decaBDE in the material. Furthermore, the project group has found that most importers of finished goods know very little of potential decaBDE content in the imported goods. It is thus likely that there are false negative responses in the material. 7.2 Imported amounts of decaBDE to Denmark as chemical or semi-finished productsThe collected information has documented import of decaBDE within several trades. There is a determined import of estimated 5 tons as chemical or part of semi-finished products. The determined cases have been import to the plastic industry. The investigation has shown that the major part is reexported following processing. The import seems connected to single special orders and there are no indicators that decaBDE is used regularly in Danish production. The collected information on import of decaBDE as chemical and semi-finished product is assessed to provide a credible image of this import to Denmark. It is, however, notable that the investigation documented import of 3 tons chemical that was not registered in the public registers. 7.3 Imported amounts of decaBDE to Denmark as part of finished productsThere is a determined import of decaBDE in finished products as tents, cars, and heat-shrink tubes. The use for tents is estimated to 32 kg (23-110 kg), while the heat-shrink tubes are estimated at less than 5 kg per year. The estimated import for cars is 240 kg per year (18-1000 kg) that originates from flame retardant connectors. Besides the uncertainty that is attached to the estimate for these components, the estimate for cars is connected with uncertainty due to potential use of decaBDE for the interior of the car. This investigation has not been able to determine a considerable use for this purpose as former investigations have. There is no determined import of decaBDE in the product groups upholstery, bedding articles, cables, furnishing textiles, glues, health articles, baby and children’s articles, and paints and joint fillers. The investigation of the import of finished products is connected with considerable uncertainty. The uncertainty is connected with the selection of product groups, response rates from companies, and the companies’ knowledge of potential decaBDE content in their products. It is assessed that the selection of product groups in this investigation is adequately comprehensive to the fact that it is unlikely that there are product groups with considerable use of decaBDE that are not represented. As mentioned the average response rate was approximately 20%. Naturally the remaining 80% represents a certain uncertainty, and there is no doubt that this group contains companies that import finished products with decaBDE content. The third source of uncertainty is the companies’ actual knowledge to potential decaBDE content. As the substance is not regulated many importers’ knowledge is presently insufficient. A number of the contacted companies have made a huge effort to clarify whether decaBDE is part of their products in connection with the questionnaire. However, there are also companies that refer to the fact that the substance is not regulated for which reason detailed knowledge is not necessary. During the course of the project there have been many contacts to companies and centres of excellence. The obtained knowledge as related to the conclusions in the formerly published Nordic mappings indicates that the greatest uncertainty is connected to the investigation’s results within import of transportation means (cars) and upholstery. 7.4 Alternatives and trends in the use of decaBDECompanies and trade associations inform that decaBDE is sought substituted with other flame-retardant substances or methods if possible. It is a general impression from the investigation that there is no demand for products that are flame-retardant treated with decaBDE in Denmark. A wide variety of methods and substances are used to substitute decaBDE and the investigation has determined use of structural flame retardant properties as well as substitution with substances that are regarded less problematic in terms of health and environment relations. The completed mapping has only limited and sporadically mentioned use of decaBDE as chemical and semi-finished products in Denmark just as the import through finished products seems limited to no more than a few tons a year. As it appears from the above mentioned the estimated use is connected with great uncertainty and the question is whether it is possible to obtain a precise estimate of the total use in Denmark. When the investigation’s results are joined the result is that use of decaBDE for flame-retardant purposes is limited in Denmark. In 1999 the Danish EPA (Miljøstyrelsen) concluded that the use of decaBDE seems to be decreasing. This investigation confirms this assumption. Thus there seems to be a clear tendency towards a minor use of decaBDE. There is no reason to assume that the use of decaBDE will increase in Denmark over the coming years unless new product types with decaBDE content are introduced. References Bekendtgørelse om begrænsning af import og salg af elektrisk og elektroniks udstyr, der indeholder visse farlige stoffer (BEK nr. 1008 af 12.10.2004). Danmarks Statistik 2006, Udenrigshandelen fordelt på varer og lande, januar-december 2005, Danmarks Statistik, 2006. EBFRIP 2004: European Brominated Flame Retardant Industry Panel – refereret i Kemikalieinspektionen 2004. EU 2004: Kommissionens forordning (EF) nr. 1982/2004 af 18. november 2004 om gennemførelse af Europa-Parlamentets og Rådets forordning (EF) nr. 638/2004 om statistikker over varehandelen mellem medlemsstaterne og om ophævelse af Kommissionens forordning (EF) nr. 1901/2000 og (EØF) nr. 3590/92. EU kommissionen 2005: 2005/717/17/EC af 13. oktober 2005. Kemikalieinspektionen 2004: Dekabromdifenyleter (dekaBDE) – underlag til et nationellt förbud. Stockholm 2004. Kemikalieinspektionen 1/2005: Survey and technical assessment of alternatives to decabromodiphehyl ether (decaBDE) in plastics. Stockholm 2005 LBK 2005: Bekendtgørelse af toldloven, Lovbekendtgørelse nr. 867 af 13/09/2005, Folketinget, 2005. Miljøstyrelsen 2000. Paradigme for massestrømanalyser (Paradigm for mass flow analyses), Miljøprojekt nr. 577, Miljøstyrelsen 2000 Miljøministeriet 2004a: Bekendtgørelse nr. 1008 af 12.. oktober 2004 om begrænsning af import og salg af elektrisk og elektronisk udstyr, der indeholder visse farlige stoffer. Miljøministeriet 2004b: Bekendtgørelse nr. 76 af 9. februar 2004 om begrænsning af import, salg og anvendelse af penta- og octabromdiphenylether. Miljøstyrelsen 1999: Brominated Flame Retardants. Substance Flow Analysis and Assessment of Alternatives. Miljøvejledning for arbejdsbeklædning med værneegenskaber. Udkast nr. 03 af 2005-03-10. Udarbejdet af HHK, IPU SFT 2003: Bruken af bromerte flammehemmere i produkter. Statens Forurensningstilsyn, Oslo 2003. SPIN 2006: Substances in Preparations in Nordic Countries, Arbejdstilsynet, Register for stoffer og materialer, 2006
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