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EPA Action Plan for Hexabromocyclododecane

October 14th, 2010


HexabromocyclododecaneThe EPA is considering hexabromocyclododecane, a brominated flame retardant made up of various mixtures of its 16 isomers (herein: HBCD), for action under the Toxic Substance Control Act (TSCA). This is in addition to two other groups of compounds already discussed in previous Lab Science News articles.

HBCD is ubiquitous in the environment throughout the world and is also found in human tissues, including blood, adipose, and breast milk. When released into the environment, it can travel great distances, bioaccumulating and biomagnifing in the food chain. In addition to its high toxicity to aquatic organisms, studies have also linked HBCD to reproductive, developmental, and neurological effects in humans, with a potentially higher impact on children because of their smaller size.

HBCD is a highly effective flame retardant even in very low concentrations, which explains its widespread use. One of its main uses is in polystyrene foams used routinely in the construction industry. It is also used to a lesser extent in the textile industry for: upholstered furniture for homes and cars; draperies, wall coverings, mattresses, and blinds; and in the electronics industry in appliances, audio-visual equipment, and some cables and wires. It’s the flame retardant of choice used in textiles to meet the strict requirements for fire safety in California and Great Britain. Other flame retardants could be and are used in place of HBCD in textiles, but the replacements themselves may not be as effective and are also persistent, toxic, and do bioaccumulate. There is no good substitute for the use of HBCD in construction materials as the substitutes, to date, render the materials unusable.

HBCD is already listed on the TSCA inventory, so its production, importation, and uses are being tracked. However, there is no information on HBCD’s release into the environment in the US, because it is not presently on the Toxics Release Inventory. A study in Britain indicated that its primary source was emissions from the manufacture of and use in products, emissions from incinerators, and from the leachate from landfills. Another study in Europe indicated that 50% of the release of HBCD was to wastewater, 29% to surface water, and 21% to air. Also, because of its use in products that may have a long life, the products containing HBCD can release it into the environment over a long period of time.

The EPA is reviewing the following actions as warranted:

  1. Initiating rulemaking under TSCA to add HBCD to the list of chemicals that may cause injury to health or the environment.
  2. Initiating rulemaking under TSCA to require a “significant new use rule” for any production or subsequent use of HBCD in textiles, which would require notification to the EPA before production or use.
  3. Regulating HBCD by either banning or limiting its use.
  4. Adding HBCD to the Toxics Release Inventory, so its releases can be noted.
  5. Designing an Environmental and Green Chemistry alternative assessment to help in encouraging industry to limit or quit using HBCD, in addition to the other actions under this action plan.

Additional information may be found on the EPA’s website, accessible at

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One Response to “EPA Action Plan for Hexabromocyclododecane”

  1. Bonny Boltz Says:

    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 – in building use or in worker exposure. The Environment Canada HBCD Risk Assessment cited that HBCD it is not a human health concern. Only one of the criteria needs to be met for a chemical to be listed as 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. The Canadian government concluded 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, the Canadian government 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. The remaining concern being evaluated is for bioaccumulation and persistency in environmental systems; the earth. The US EPA incorrectly 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.

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