Hexabromocyclododecane (HBCD) question for the gurus...
Last Post 22 Nov 2010 09:42 PM by deermere. 12 Replies.
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renangleUser is Offline
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22 Oct 2010 11:11 AM

Hello,

I have a question that was recently brought up to me by an architect that I know and it has me a little confused.  According to the architect, there is concern from his firm that the flame retardant hexabromocyclododecane (HBCD) is toxic and is now being addressed by both the U.S. Environmental Protection Agency (EPA) and the Canadian agencies Environment Canada and Health Canada. 

Is anyone familiar with this and/or provide me some information to discredit the concerns?  Anything would be helpful.

Thanks,

renangle

BrucePolycreteUser is Offline
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22 Oct 2010 11:28 AM
I have heard this issue raised in the past. The potential concern is for exposure in the manufacturing process (I also believe that the level of exposure in the real world makes it immaterial). However, once installed in the building there is no concern for the homeowner, as it is not an "off gassing" issue, but a particulate one. Feel free to correct me if I am wrong.
BrucePolycreteUser is Offline
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22 Oct 2010 11:40 AM
By the way, Here's the Wikipedia link....

http://en.wikipedia.org/wiki/Hexabromocyclododecane
renangleUser is Offline
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22 Oct 2010 02:33 PM
Thanks Bruce, I had seen/read the wiki information regarding HBCD, but it doesn't really discuss the harmful (or lack there of) HBCD in an ICF wall, especially when convered with the 20 min thermal barrier. I realize that this seems almost silly, but I need to answer the question regarding HBCD in the EPS for the architect, which is why I'm asking here and elsewhere.

renangle
glennUser is Offline
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23 Oct 2010 12:05 PM
does anybody out there have extensions for superior alinment system we currently have 10' braces and have to pour an 18' tall wall if someone is looking to sell please call me at 605 520 0314 thanks
glenn
emsteinerUser is Offline
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24 Oct 2010 02:53 PM
Like many other chemicals, HBCD is included in a systematic review to determine whether it should be listed as a chemical of concern or not. While certain aspects of HBCD toxicity are still under review, it is clear that a concern for human health due to HBCD is off the table. In Europe, and most recently Canada, both governments have determined HBCD is NOT a human health concern - not in building use or in worker exposure. The remaining concern being evaluated is for bioaccumulation and persistency in environmental systems (the earth). The US EPA incorrectly - and irresponsibly - indicated HBCD may be a human health concern although they should have been fully aware of the outcome in Europe and Canada  if they had conducted a minimum level of due diligence in their research. In addition, a proper risk benefit analysis has not been done to weigh the significant energy savings and fire safety foam plastics offer in building insulation versus the potential for harmful impact on the environment which is something each and every product does to some extent.
emsteinerUser is Offline
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24 Oct 2010 02:54 PM
Like many other chemicals, HBCD is included in a systematic review to determine whether it should be listed as a chemical of concern or not. While certain aspects of HBCD toxicity are still under review, it is clear that a concern for human health due to HBCD is off the table. In Europe, and most recently Canada, both governments have determined HBCD is NOT a human health concern - not in building use or in worker exposure. The remaining concern being evaluated is for bioaccumulation and persistency in environmental systems (the earth). The US EPA incorrectly - and irresponsibly - indicated HBCD may be a human health concern although they should have been fully aware of the outcome in Europe and Canada  if they had conducted a minimum level of due diligence in their research. In addition, a proper risk benefit analysis has not been done to weigh the significant energy savings and fire safety foam plastics offer in building insulation versus the potential for harmful impact on the environment which is something each and every product does to some extent.
BrucePolycreteUser is Offline
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24 Oct 2010 07:52 PM
Excellent post, emsteiner. Can you direct us to document or website that we can use to support your information?
renangleUser is Offline
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25 Oct 2010 01:19 PM
Thanks emsteiner, that was one of the better first posts I've seen! I agree with Bruce, while I believe you and agree 100%, is there any corresponding documentation regarding HBCD? That would be very helpful. Thanks!
solar geekUser is Offline
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03 Nov 2010 02:08 PM
Here is the link to the EPA action plan set forth 8/18/2010.  Many links are inside this one from EPA.  Thought this might help.  SG
http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/hbcd.html

Here is a very basic summary from EPA as to what they are doing. This is taken from the site - not my words.  However, as someone who has has much contact with EPA, this is NOT minor.  SG

"What action is EPA taking? EPA intends to initiate the following actions to manage the risk that may be presented by HBCD.

1. Consider initiating rulemaking under TSCA section 5(b)(4) to add HBCD to the Concern List of chemicals which present or may present an unreasonable risk of injury to health or the environment. EPA intends to publish this notice of proposed rulemaking by the end of 2011.

2. Initiate rulemaking under TSCA section 5(a)(2) to designate manufacture or processing of HBCD for use as a flame retardant in consumer textiles as a significant new use. This would require manufacturers and processors to notify EPA before manufacturing or processing HBCD for this use. This Significant New Use Rule (SNUR) also would be proposed to apply to imports of consumer textiles articles containing HBCD. EPA has evidence to suggest that the use of HBCD in textiles may be limited to specialty commercial applications, and that general consumer textile use may be so limited it would be appropriate for SNUR regulation. If information shows this assumption to be incorrect, EPA will consider initiating rulemaking under TSCA section 6(a) to address general consumer textile use

 3. Consider initiating rulemaking under TSCA section 6(a) to regulate HBCD. A section 6(a) action could take the form of a comprehensive ban on the manufacturing, processing, distribution in commerce and use of a chemical substance, or a more targeted regulation to address specific activities. The extent of the rule for HBCD would be determined during the rulemaking process.

4. Initiate rulemaking in 2011 to add HBCD to the Toxics Release Inventory (TRI). Listing on TRI will require manufacturers or importers to provide environmental release information.

5. Conduct a Design for the Environment (DfE) alternatives assessment of HBCD. The information developed may be used to encourage industry to move away from HBCD instead of, in addition to, or as part of any regulatory action taken under TSCA. The alternatives assessment would build upon existing knowledge and would consider various exposed populations, including sensitive human subpopulations, as well as environmental exposure. The work will begin in 2011, with completion expected in 2013. "
emsteinerUser is Offline
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03 Nov 2010 11:59 PM
Here is the link to the Environment Canada HBCD Risk Assessment citing it is not a human health concern (see page 11). Only one of the criteria needs to be met for a chemical to be listed as a Persistent, Bioaccumulative Toxin (PBT). The issue with HBCD is bioaccumulation which is clearly proven, while persistency is as yet undetermined as there is insufficient evidence. For example, most EU and CAN risk assessments use terms like 'potential' and 'associated with' when referencing test data on HBCD persistency with clearly noted caveats that it is likely but not proven. Toxicity is not an issue for human health (despite the poorly presented data references by the U.S. EPA). Here are the conclusions presented by the Canadian government which are in concert with the EU:

·         The analysis of risk quotients determined that HBCD concentrations in the Canadian environment have the potential to cause adverse effects in populations of pelagic and benthic organisms but are unlikely to result in direct adverse effects to soil organisms and wildlife.

 

·         Based on the available information it is proposed that HBCD is not entering the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health.

If anyone has any other questions, please email me at [email protected].  

Betsy Steiner

BrucePolycreteUser is Offline
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04 Nov 2010 07:13 PM
One final comment on this topic from me. Here's a link to a report put out by the EPS Molders Association that addresses all of the current concerns about HBCD.

www.epsmolders.org/PDF_FILES/HBCD_Fact_Sheet_final_web.pdf


deermereUser is Offline
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22 Nov 2010 09:42 PM
If the form of ICF is on fire, I guess it will emit a lot of toxic emissions like the HBCD. Has anyone concerned about this? People can die not because of fire, but because of the toxin.
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