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Investigation of brominated flame retardants present in articles being used, recycled and disposed of in New Zealand

• Executive Summary
• 1. Introduction
• 2. Estimate of the amount of BDE in New Zealand
• 3. Assessment of the fate of BDEs in waste
• 4. Profile of BDE flows in New Zealand
• 5. Risk analysis
• 6. Environmentally sound disposal methods
• 7. Limitations of the study
• 8. Conclusions and Recommendations
• Additional readings
• Appendix A Detailed data tables
• Appendix B Polybrominated Diphenyl Ether (PBDE) structure and physical properties
• Appendix C Analytical equipment and procedures
• Appendix D Certificate of analysis
• Appendix E Methods and analysis of consumer products
• Appendix F Calculating the % BDE present in consumer products
• Appendix G Details of the selected landfills and the sampling of leachate
• Appendix H Current status of the flame retardant industry
• Appendix I Non-dust sources of BDEs more prominent human intake
• Appendix J Completed Questionnaire SC-4/19 for submission of information on new POPs in accordance with SC-4/19
• Appendix L Questionnaire for organisations that manufacture articles containing BFR’s
• Appendix M Excel spreadsheet entitled ‘XRF analyser raw data’
• Appendix N Excel spreadsheets entitled ‘NZ Statistics data giving categories with raw data’

Appendix J Completed Questionnaire SC-4/19 for submission of information on new POPs in accordance with SC-4/19

PART II – Commercial PentaBDE (tetra- and pentabromodiphenyl ether) and commercial OctaBDE (hepta- and hexabromodiphenyl ether)

SECTION A – GENERAL QUESTIONS

II-A-1 Has your country ever manufactured articles containing commercial PentaBDE or commercial OctaBDE? (Please see Part II - Section B for a list of articles potentially containing commercial PentaBDE or commercial OctaBDE)

Yes (Please also answer the more detailed questions in section B)

No

Unknown

II-A-2 Do you have information on articles in use in your country containing commercial PentaBDE or commercial OctaBDE, including concentrations of those substances in articles?

Yes (Please also answer the more detailed questions in section B)

No

II-A-3 If possible, please provide information on articles containing commercial pentaBDE and octaBDE that are recycled in your country. Please add additional rows if necessary.

There are very few articles containing commercial pentaBDE and octaBDE that are recycled in New Zealand. The majority of recycled polymer articles recovered by commercial recycling companies are in the packaging category and are unlikely to contain brominated flame retardants (or flame retardants of any kind). As our research has shown BDEs are limited to a small range of specialist applications and electronics. These include

Polymers used in imported electronic parts (circuit boards, television set casings, switches, lamp holders (WEEE type articles), cable coverings, furniture, stereos, home appliances)

A small range of foam, furniture upholstery and furnishing products that are used in commercial and/or public sector settings:
-marine industry, hospitals, schools, stadiums

A small range of New Zealand manufactured industrial applications (cable covering, under floor insulation).

Discussions with polymer recyclers have found that the New Zealand recycling system has very low levels of BDE containing articles (less than 5%) as over 95% of polymers manufactured in New Zealand do not contain BDE flame retardants and the majority of household and post industrial use recycling is destined for food contact and packaging use that do not contain BDE. There is a small specialised electronic recycling industry emerging that breaks down computer and electronic articles for reuse and these parts are likely to contain BDE in the quantum estimated in the database. However, while specialist electronic recyclers will breakdown and some shred and granulate specific parts (e.g., PCBs) the purpose is for size reduction and export to Asia rather than for remanufacturing in New Zealand.

II-A-4 What types of new articles are produced from recycled articles which contained commercial pentaBDE and octaBDE?

Our discussions with recycling industry stakeholders indicates that BDE is unlikely to be in any new articles produced from recycled articles (i.e., from recycled articles containing pentaBDE and octaBDE). While some very small operations have emerged that are specialising in recycling electronics, computers, cell phones and household appliance (WEEE type’s products) these operations only break down products for containerising and export to offshore recyclers or deposit these articles in New Zealand landfills (A-3).

Most recyclers and polymer compounders avoid polymers that could contain flame retardants, such as ABS (used in electronic parts) due to problems arising in the compounding process. One such problem is caused by butynol content required in ABS polymers to give the products flexibility. Butynol is lost with each recycling and compounding process and the polymer becomes brittle and less valuable.

II-A-5 Are there any legal or other frameworks (e.g. voluntary agreement, license conditions, extended producer responsibility, export control, labelling requirements, etc.), for waste management and/or recycling of articles containing polybrominated diphenyl ethers under development or currently being implemented in your country? Please add additional rows if necessary.

Yes No Unknown

If yes, please describe these frameworks and indicate references. Please add additional rows if needed.

In 2006 Plastics New Zealand launched a voluntary best practice programme (Design for the Environment Guidelines 2006) for its members to improve a range of polymer industry environmental outcomes. The guidelines are an industry/government collaboration (the Ministry for Environment) and cover six design areas:

1. General Guidelines for all polymer products

2. Managing Design for the Environment Projects and four specific guidelines for the

3. Electronics,

4. Packaging,

5. Construction and

6. Agricultural Sectors

Since 2003 Plastics New Zealand has been offering the Plastics Best Practice Programme to its members. During 2005–2006 the Best Practice Programme companies have addressed Design for the Environment requirements. The programme aims to develop products in a way that minimise their environmental impact. In regards to PBDEs, the guidelines provide users with a range of alternatives to halogenated flame retardants ^{Footnote 26} .

II-A-6 Please identify methods you are aware of for identifying the presence and levels of commercial pentaBDE and octaBDE in articles. Please add additional rows if necessary.

While the technology does exist internationally, there are no recycling plants operating in New Zealand that have the “in-line” technology to identify the presence and levels of commercial pentaBDE and octaBDE in recycled articles in recycling operations.

The only available analysis options for specific congeners is laboratory testing of swabs. As a screening tool total bromine can be analysed using hand held or lab based XRF analysers.

For those in the WEEE breaking down sector, flame retardant containing parts of electronic equipment are generally stamped with a mark that signals the presence and the percent of flame retardant in the part.

Recycling participants suggest that because New Zealand lacks the legislation requiring the polymers industry to identify product groups that contain BDEs, then recycling is limited to post consumer packaging materials and/or industrial sources of known specification because other sources of recycled polymers lack standards to ensure traceability.

II-A-7 Please describe recycling operations in your country for articles potentially containing commercial pentaBDE and octaBDE (e.g. large scale commercial recycling of polymers or foams, small backyard recycling of electronic equipment, etc.). Please add additional rows if necessary.

Our research indicates that only one recycling operation exist in New Zealand that potentially uses BDE containing polymers in recycling processes and compounding for remanufacture in New Zealand. This is only for expanded polystyrene.

Most types of polymers are generally broken down by WEEE type recyclers and exported for processing or are deposited in New Zealand landfills.

II-A-8 Please describe measures for the environmental management of recycling operations under development or currently implemented in your country (e.g. flue-gas treatment, water treatment, etc.). Please add additional rows if necessary.

Given that, besides one small operator, most recyclers in New Zealand do not recycle BDE containing articles there are no environmental management measures used in New Zealand for these articles as the articles are not recycled and therefore BDE are assumed to be contained in alloyed co-polymers and not leaching from recycling operations.

II-A-9 Please provide a list of methods in development or in use for the disposal of articles containing commercial pentaBDE and octaBDE (e.g., environmentally sound disposal, low technology methods, etc.). Please add additional rows if necessary.

No specific methods in development or in use for the disposal of articles containing commercial pentaBDE and octaBDE because articles are exported. There are some shredding operations of auto-polymer parts and these are being sent to sanitary landfills.

II-A-10 If your country has identified sites contaminated by commercial pentaBDE and octaBDE e.g. from production and compounding sites or open burning areas, please describe environmentally sound methods used in your country for the remediation of these sites. Please add additional rows if necessary.

II-A-11 Please provide any other related information that may be useful for the work programme to facilitate the elimination of commercial pentaBDE and octaBDE listed under the Stockholm Convention.

II-B-1 Please indicate the types and quantities of articles containing commercial PentaBDE or commercial OctaBDE that were manufactured in your country including concentrations of those substances in the articles. Please also indicate any additional information, such as the years you are referring to, the year when production was stopped, estimates or assumptions used for calculations, the estimated lifetime of products, etc. Please add additional rows as required to include other types of articles. If you do not have information on any of the elements, please indicate “no data”.

Refer to data tables in Report

II-B-2 Please indicate the types and quantities of articles containing commercial PentaBDE or commercial OctaBDE that currently exist in your country including concentrations of those substances in the articles. Please also indicate any additional information, such as the years you are referring to, the year when production was stopped, estimates or assumptions used for calculations, the estimated lifetime of products, etc. Please add additional rows as required to include other types of articles. If you do not have information on any of the elements, please indicate “no data”.

Refer to data tables in Report

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