Consider a recent group of chemical compounds that fit this description: Polybrominated Diphenyl Esters (PBDEs). According to the American Council for Science and Health, organic compounds such as PBDEs that contain multiple atoms of bromine and chlorine in their structure usually have two properties: (1) they don’t burn, and (2) they are highly stable in the body, metabolize slowly, and, consequently, tend to bioaccumulate.
The former attribute was desirable as it reduced fires in consumer products including mattresses, pajamas, and electronics. The latter attribute is the cause for concern by some.
Many advocacy groups, NGOs, and regulators are concerned that PBDEs are posing a risk to human health and the environment. Industry groups are not as convinced. You can read opposing views in these documents:
- Review of the Scientific Basis for the Document: Healthy Environments: Strategies for Avoiding Flame Retardants in the Built Environment
- EWG’s comments on EPA’s exposure assessment report for PBDEs
PBDEs in the Environment
As previously noted, PBDEs are in a lot of consumer products and, consequently, are commonly found in water and sediment and have many potential routes of entry into the environment. According to the International Joint Commission (IJC),the following are potential pathways:
- Surface Water: from landfills after landfill leachate is treated, from wastewater discharges to surface water.
- Sediments: from land application of municipal sewage sludge
- Air: from scrap yards when products are shredded and via vapourization of household products.
The IJC is seeking further restrictions on PBDE (logo source www.ijc.org)
IJC Report on PBDE: Chemical of Mutual Concern
The regulated community in Ontario (and the Great Lakes States) should be aware of a November 2016 report by the International Joint Commission that is seeking more restrictions on PBDEs. The report, “Polybrominated Diphenyl Esters (PBDEs) in the Great Lakes,” may lead to development of more regulations.
In May 2016, the IJC designated PBDEs as Chemicals of Mutual Concern (CMC). Once they are designated as a CMC, binational strategies are then developed.
In the November report, the IJC provided nine recommendations related to addressing PBDEs in the Great Lakes including “…a binational strategy to reduce these chemicals in the Great Lakes basin…before the end of 2017.” Another of the recommendations includes asking provincial, state, and federal governments to implement Extended Producer Responsibility (EPR) programs to require industries to be responsible for their products containing PBDEs from cradle to grave (my words). The IJC recommends that the EPR be implemented in two phases:
- Phase 1 would include electronics, appliances, carpets, mattresses, and furniture
- Phase 2 would include construction, renovation, and demolition wastes
Requiring an EPR on such a variety of consumer products (home furnishings, automobiles, consumer electronics, etc.) would be no small challenge. And as recycling these products with PBDEs would seem to counter the intent of removing these compounds from the environment, the challenge is compounded.
The IJC acknowledges that there are knowledge gaps regarding the extent of PBDEs in the environment. Others believe there are knowledge gaps relating to the actual toxicity of the PBDEs. We are detecting PBDEs in the picogram level (a picogram is one trillionth of a gram). Let’s hope that we make wise policy decisions on both sides of the border that are protective of human health and the environment and are based on good science.
If you would like to learn more, you can view a recent webinar or visit the page on Environment Canada’s website on PBDEs.
As always, if you have any questions relating to environmental remediation, expert environmental services, environmental compliance, etc., please feel free to contact me (cpare@dragun.com) at 519-979-7300.