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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’

2. Estimate of the amount of BDE in New Zealand

2.1 Purpose

The purpose of this section of the study is to provide an estimate of the quantities of BDE in New Zealand by reviewing potential sources, the end use of BDE-containing articles and the disposal of these articles in New Zealand to the extent possible given the limited scope of the study. A preliminary quantitative assessment of the following potential sources of BDE are given:

• the types and quantities of articles in New Zealand containing BDEs, including concentrations of those substances in the articles;

• the fate of these BDE-containing articles once they are discarded as wastes, including the proportion and/or approximate quantities disposed to landfill or recycled (including export);

• the types of articles being recycled, the nature and extent of this recycling (including export), and the types of articles and/or reusable materials produced from recycling.

2.2 Method

This assessment of BDE in New Zealand was undertaken through industry participant interviews and by researching quantitative information from the following sources:

• New Zealand based literature assessing management of polymers and contaminants;

• International literature on the management of BDEs in manufacturing, waste and recycling;

• Statistical analysis of trade flows of raw materials and industrial and consumer goods that contain BDEs from government statistics;

• Semi structured interviews with major manufacturers that currently use or have used BDEs in their manufacturing processes;

• Analysis of the BDE content of sampled consumer goods to estimate total BDE volumes; and

• Plastics New Zealand polymer Mass Balance Survey data.

A review of literature and interviews with industry participants identified the most likely uses of BDE in consumer goods for various BDEs. The major retail stores were identified and approached for testing. The analysis of BDE content in finished consumer goods required sample testing in retail stores. The retail stores were selected based on the products they stocked, their likely market share and willingness to participate in the sampling exercise.

The major goal in testing the products was to identify quickly and non-destructively which articles contain polybrominated diphenyl ethers (PBDEs). This was achieved using an X-ray fluorescence (XRF) analyser. The XRF analyser is discussed in more detail in appendix C but in short it reveals quickly the concentration of bromine within a sample in part per million (ppm). Over a four day period from 5 April to 8 April 2010 seven major retail stores were investigated with the XRF analyser and a total of over 800 analyses were carried out on a wide variety of consumer products.

It has been necessary to make a number of assumptions in developing the estimate of PBDE flows in New Zealand. These have been made due to limitations to the scope and time available to research the required data. All assumptions are stated in the report alongside key data tables and are based on sample analysis, interviews with industry experts and literature.

Further details on the methods used for each of the sources of information are contained in the relevant sections of the report with the study findings.

Recommendations are made on the key data gaps and a proposed methodology to overcome the current study’s limitations.

2.3 Results of research into the types and quantities of articles containing BDEs

The estimate of BDE contained in various articles in New Zealand has been quantified into three categories: imported articles to New Zealand; exported articles; and existing articles currently in use. Four key potential sources of BDE have been targeted in the analysis:

• Plastics New Zealand mass balance survey on end use of polymers imported as virgin resin and reel stock;
• National trade statistics on imports of finished consumer goods;
• Estimated BDE content of finished consumer goods based on laboratory and XRF data;
• Interviews with industry participants on likely increase proportion of imported goods containing BDEs.

2.3.1 BDE contained in existing products

To assess the quantities of BDEs in existing articles, an assessment of historical quantities used in manufacturing and quantities likely to be contained in imported articles has been undertaken. The following types of organisations were contacted to gather information on the current use of BDEs as a flame retardant in New Zealand manufactured plastic products (for both domestic use and export). Key people contacted were category managers, technicians and managers of small companies involved in niche roles in the supply chain (e.g., importers and plastic recycling companies). The following types of organisations were contacted:

• Furniture retailer
• Foam fabricator/cutter
• Foam manufacturer
• Furniture importers and manufacturers
• Soft furnishings manufacturers and retailers
• Importers of plastic manufacturing inputs
• Plastics New Zealand
• Plastic recycling companies and industry organisations

In order to gather quantitative information on current and historical volumes of BDEs used in New Zealand the team prepared and mailed an industry survey questionnaire (see Appendix D) through Plastics New Zealand. There was a very low response to this questionnaire and the only quantitative information gathered was done so through telephone interviews to targeted manufacturers (those viewed as having a major share of their respective markets). This assessment has provided an indication of trends in use and some limited information on quantities. However, it is recommended that future studies include in-depth analysis using an industry endorsed survey to develop a more comprehensive assessment of quantities currently and historically used in New Zealand.

The results of industry interviews indicate that, while EU and North America regulatory authorities have led an international response to the threat of the presence of BDEs (in commercial and consumer products) has to human health; New Zealand is likely to have a significantly lower level of BDE in existing, imported and exported products than those regions. This is due to the historical absence of regulations requiring household goods to contain flame retardants in New Zealand manufactured goods. Anecdotal evidence suggests that this type of regulation was a major driver for the increased prevalence of BDE (as an effective flame retardant) in EU countries and the UK, and was introduced in the late 1980s.

The discussions gained from industry interviews suggests that the main source of PBDE in existing products has come from finished consumer products imported within the last decade (mainly from developing countries), from polymer resin used in the manufacture of New Zealand products and in chemical compound form for production of polymer products for specific applications. These include drapes, furnishings and furniture in hospital, schools, cinemas and other public places that require a higher flame retardancy rating than consumer products do.

Another source of information used to identify potential articles that contain BDE and an indication of the percentage in each article was to undertake physical samples of consumer articles currently in-use using the XRF method (see Section 2.3.2 and Appendix E for details on the method used). The team expected to find the presence of BDE in a range of furniture (in foam and upholstery), furnishings and floor coverings of 10 – 30 years in age. The relative absence of PBDE (i.e., readings under 0.1% bromine) in most samples (over 85%) of finished consumer goods is an unexpected finding and is likely to be due to the absence of legislation in New Zealand for the compulsory use of flame retardants in consumer goods. The low levels of BDE in current imports are likely due to the phasing out of BDEs under international agreements on the use of hazardous substances.

While the use of BDE is still permitted in New Zealand, major foam manufacturing companies limit the use of any form of flame retardant to “specific applications”. A major importer of polymers for the furniture and furnishings industry only uses flame retardants for specific uses such as schools, hospitals, cinemas and marine as is required by legislation (drapes, furnishings, and foam in chairs). For example, a specific application (less than 5 percent of the market) may use an imported chemical such as Firemaster550 (27% Bromine) and is mixed at a rate of 2 percent in the final product. In this example 1 tonne of FireMaster550 is used and over 85 percent of the foam product is exported leaving 150kg of FireMaster550 in 7,500 tonnes of foam (at 2 percent content) entering the New Zealand market annually. Industry interviews indicate that prior to 2006 larger quantities of BDE were used.

Interviews with major New Zealand based flooring manufacturers also indicate that historical usage was around 15 tonnes per year of D60F (containing PBDE) from 2000 - 2005 and prior to that 8.0 tonnes from 1990 - 2000. The data table in Appendix A contains a summary of imported volumes (tonnes) of plastic resins from all countries from 1988 to 2009^{Footnote 1}. This data was used to estimate the volume of potentially BDE containing products that are manufactured in New Zealand. The polymer resins included in the analysis is based on the Plastics New Zealand Mass Balance Survey (a statistical analysis of imported volumes of polymer resins and their uses in New Zealand) and is shown in Appendix A. An estimate of the amount of BDE containing products manufactured from imported plastics resins in New Zealand using BDEs is based on the Mass Balance Survey end use profile and estimates of the percentage of BDE contained in finished products. Assumptions on the percentage of BDE in finished products are based on the results of the finished goods analysis and data sheet information provided by manufacturers interviewed. The assumptions used for % of BDE in finished products are shown in the table below.

Using this approach the estimate of BDE used in New Zealand manufacturing is likely to be around 15 tonnes of BDE imported and used in New Zealand manufactured products annually, although most of these products are exported (i.e. over 80 percent). We estimate that the range of this value is from 5-30 tonnes and is based on the quantitative analysis outlined above and also shown in Section 5 (Profile of BDE flows in New Zealand). This estimate is also supported by information gathered through interviews with plastic manufacturers suggesting that the estimate is a “reasonable estimate”.

The profile of BDE in New Zealand articles is derived from trade statistics (See Appendix A) and this also suggests that the volume of BDE in existing articles is likely to be between 250 and 350 tonnes. We have estimated a most likely value of 280 tonnes. Given that many articles containing BDE are electrical equipment with a typical lifetime of less than 10 years, this volume is decreasing and is estimated to have peaked between 2000 and 2005 at 400 – 450 tonnes. As BDE containing articles reach their usable lifetime, BDE is moving from “in-use” category and into landfills which is increasing. The quantified flow of BDEs in New Zealand is described in Appendix A.

2.3.2 BDE contained in imported products

The main source of BDE in imported products is from finished consumer products and as a flame retardant used by polymer manufacturers of some plastic products and industrial applications (for example, cable coverings and circuit boards). Our investigations of polymer manufacturing companies and literature review indicates that the number of products containing BDE retardants will decline over time as countries sign up to international frameworks that limit their use in manufacturing and require the use of alternatives (e.g., metal based or phosphate flame retardants).

Our survey of literature and interviews with industry participants indicate that flooring underlay manufactured in New Zealand do not contain flame retardants and only a small amount of imported product is likely to have them. Testing of samples in various retail stores has confirmed this finding.

The information in the box below summarises findings from a brief review of international literature to assess the international environment for the use of BDE in plastics manufacturing as a reference point to gauge estimates of quantities in New Zealand.

Trade import data above was used with the analysis of weight and percentage of BDE in the over 800 samples taken of imported consumers goods. Table 3 below shows assumptions used for the %BDE in imported goods based on the analysed samples of imported goods. The correlation factor of 0.5 was determined in an attempt to correlate the laboratory analysis (of a selection of plastics) with the XRF analyser data obtained when testing the consumer products. A more detailed explanation is provided in the following section (section 2.3.3) and Appendix F.

Given the uncertainty in forecasting future imported volumes, particularly as the volumes (mass of BDEs) being imported have decreased significantly over the past five years and the limited time series available for statistical analysis, a statistical analysis of future volumes is not included here. However in section 4 we do present an uncertainty analysis of current data.

Other assumptions used in estimating the total volume of BDE in imported finished goods include an allowance for a variance in the percentage of BDE in imported goods over three periods. Table 4 below shows that estimates of percentage BDE contained in finished products is likely to be higher for the decade prior to 2004 (as a year in which international pressure emerged to reduce the use of BDEs) and lower prior to 1994.

An example imported product is shown below; hair-dressing apparatus; electro-thermal hair dryers- Customs Code 516310001 to illustrate how the assumptions for weight of product, percentage BDE, likely percentage of imports containing BDE and expected lifetime of the imported product are used with the trade import data. These assumptions are also used to develop the profile of BDE in New Zealand in Section 5.

Table 5 below contains a summary of the likely imported volumes of BDE from a range of imported articles manufactured in overseas countries using the approach and assumptions outlined above. A more detailed breakdown of estimated quantities is contained in Appendix A and is based on the quantification of total imports of 219 customs codes from the period 1988 – 2009. Given the international trend to phase out the use of BDE as a flame retardant, imported volumes from finished articles are likely to be in the range of 5 – 25 tonnes per year for the next five years with further reductions thereafter.

To obtain an indication of the number of products that contain brominated compounds a survey of consumer products was carried out. The results of this survey are set out in Appendix M.

2.3.3 Methods used to analyse the presence of BDE in imported consumer products

XRF analysers have the ability to detect total bromine including the various oxidation states of bromine and also in organic compounds such as brominated flame retardants and long chain polymers. This provides a simple, cost effective and non destructive manner to show the presence of bromine in various consumer products.

The XRF technique relies on the fluorescence of elements in the X-ray spectrum. The area analysed is only a few square millimetres and the item is not damaged. The analysis reveals the concentration of bromine in the product in ppm in a short time period (20 seconds). While the presence of bromine can be easily established with the use of a XRF analyser it can also quantify the total amount of bromine in the sample once the analyser has been calibrated. The calibration has been carried out using internationally certified standards of 98 and 808 ppm Br (Appendix D). These standards were constantly used throughout the investigation to ensure the reliability and validity of the analysis carried out.

New Zealand’s leading electrical and retail outlets were approached and their consent was sought to analyse the goods of interest in their stores and over a 4 day period well over 800 analyses were carried out on a variety of the consumer products. Details on the types of products that were selected are described in Appendix E. The product details were noted whenever a positive bromine result was obtained so that the quantities of each of these products imported or manufactured per year could easily be obtained from NZ Statistics database.

Due to the destructive nature, the cost and the relatively large quantity (10-30g) required for laboratory analysis, testing of all the consumer products that were identified by the XRF as potentially containing BDEs was not possible. Consequently it was decided to use the XRF’s bromine results to generate an approximate quantity of the total BDE that were likely present in the consumer products. This was achieved by using the laboratory analysis (in mg/kg) that identifies 20 of the most significant polyBDEs and then calculating this into a ‘total bromine content’ for each plastic sample. A correlation factor was then calculated that related the total bromine found from the laboratory analysis to the value obtained by the XRF analyser.

Details of the step by step conversion from the laboratory analysis to a total bromine content value based on molecular weight and the subsequent determination of the ‘laboratory analysis to XRF correlation factor’ are given in Appendix F. A summary is given below in Figure 2.

As is shown in Figure 2 the correlation factor was found to be 0.5. In other words only half of the bromine value obtained by the XRF was actually detected as BDE’s by laboratory analysis. The laboratory has reported an extraction efficiency of > 90 %. Consequently in order to estimate the BDE content it was necessary to multiply the averaged XRF bromine value for a particular consumer product by 0.5.

A summary of the average %BDE present in the consumer goods was given in Table 3. Evidence of brominated compounds was found in many of the products that were expected to contain BFR the only exception being flooring materials. The full list of substances analysed and the results obtained can be found in Appendix M.

The location of the bromine containing polymers varies on the type of product investigated but in most cases the BFR was found to be located where there is a potential for considerable generation of heat or close to an electrical contact within the appliance. A notable exception was that of a dishwasher where the external panels all contained bromine presumably a BFR at >3 %. It was interesting to note that the appliances that typically generate the most heat had the largest proportion of BFRs namely, TVs, hair-dyers, convection heaters, and irons. This does not mean however that all products of this type contained a BFR.

Figure 2 The laboratory analysis of 16 plastic samples and their calculated total bromine value (mg/kg). (Note that the XRF Analyser readings (mg/kg) are shown in the shaded row at bottom of table. See Appendix F for further information.)

View figure at full size including text description

2.4 BDE contained in exported products

Our findings indicate that a wide range of products manufactured in New Zealand contain polymers which we have identified (through the imports sample analysis and literature) as potentially containing quantities of BDE within their polymer components. New Zealand exports relatively small quantities of domestic appliances which could contain BDE, an example of a major appliance exporter is Fisher and Paykel Appliances although the recent closure of their Dunedin plant has diminished the quantity.

Our search of New Zealand Statistics indicated that there is a range of New Zealand manufactured commercial type export products that may contain BDE. Examples include polymer and rubber hosing and pipes, insulated wire and electrical components such as circuit breakers, insulators, switches etc. Niche technology products play a small part in export quantities.

Our investigations of exporting companies and literature review indicates that the number of export products containing BDE retardants will decline over time as countries sign up to international frameworks that limit their use in manufacturing and require the use of alternatives (i.e. non halogenated flame retardants). The trend is for BDE to be used in these types of products and more to be manufactured in other countries due to competitive advantages in production such as wages.

A 2005 study found that 28.7 percent of polymer products manufactured in New Zealand are either directly or indirectly exported (Wittington, 2005). This report also indicates that the vast majority of New Zealand manufactured polymer is used for packaging from LDPE, PET and HDPE, and PP and that as a major exporter of food products, this packaging is unlikely to require flame retardant qualities.

The summary of the exported products statistics search is presented below in Table 5. Using the same approach as the quantification of imported volumes, a search for trade import data has been undertaken for the period 1988 – 2009 and has been extrapolated to estimate volumes of BDE using sample BDE % and weight analysis. Our analysis includes the 252 product categories and the list is summarised into three broad areas below. While we acknowledge that the list is not exhaustive, it covers the main areas including those that we have weight and BDE percentage data for.

1. Household consumer products such as kitchen and household electrical appliances (34 product categories).
2. Construction and agriculture polymer products, such as hoses, tubes, pipes and fittings, rubber conveyor belts and automotive parts (107 product categories).
3. Electrical goods such as circuit breakers, printed circuit boards, switches, television circuits and connectors, cable covering, insulated wire and electrical conductors (111 product categories).

A more detailed breakdown of the estimated quantities is contained in Appendix A.

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