1. 23-Dec-11 Guidelines on Best Available Techniques and Best Environmental Practice for the Recycling and Disposal of Articles containing Polybrominated Diphenyl Ethers (PBDEs) under the Stockholm Convention on Persistent Organic Pollutants

2. 2 POP-BDEs in the Stockholm Convention The COP decided at the fourth meeting to list in Annex A certain congeners contained in commercial pentabromodiphenyl ether (c-PentaBDE) and/or commercial octabromodiphenyl ethers (c-OctaBDE) including tetrabromodiphenyl ether, pentabromodiphenyl ether, hexabromodiphenyl ether, and heptabromodiphenyl ether (POP-BDEs). Prominent POP-BDE congeners BDE-47BDE-154BDE-183

3. 3 Need for the BAT/BEP guidance The Convention prohibits the use of POP-BDEs but contains a time-limited exemption for the recycling of articles that may contain PBDEs and the use and final disposal of articles manufactured from such recycling. The allowance of reuse and recycling of articles containing POP-BDEs results in the need to define Best Available Technology (BAT) and Best Environmental Practices (BEP) to carry out the recycling and the final disposal in an environmentally sound manner (ESM) considering the recommendations made by COP5 for the management of POP-BDE containing materials.

4. 4 Purpose of this BAT/BEP guidance The objective of this guidance document is to assist Parties in developing strategies for complying with the Convention obligations related to the recycling and waste disposal of articles containing POP-BDEs, and implementing the recommendations of the COP. Technologies are evaluated and defined in this document which can be considered as BAT/BEP to manage these material streams in an ESM and should be used for developing action plans and to prioritize areas for the management of POP-BDE containing material flows.

5. 5 Approach of this BAT/BEP guidance The document provides technical outlines, advantage/disadvantage, priority sources to be addressed, and health safety issues of the BAT/BEP introduced in this guidance. To keep the document as short as possible, reference is given to Stockholm Convention BAT/BEP guidance sections and to the BAT REFerence Documents (BREFs) from the European Commission.

6. 6 Main target audience Ministries/staff developing management plans for the recycling and waste disposal of materials containing BDEs (e.g. E-waste, end-of-life vehicles, construction) and technical staff involved in their implementation. Ministries and staff responsible for the import, sales, and export of secondhand articles possibly containing POP-BDEs (e.g. cars and other vehicles, electronics). Also the guideline provides information for industries recycling or disposing such material streams.

7. 7 Structure of the BAT/BEP guidance Production (1) Management transport sector (6) Production c-PentaBDE (stopped)Production c-OctaBDE (stopped) Transport sector Energy/material recovery (8)* Incineration (8.1) Cement (8.2) Melting (8.3) Pyrolysis (8.4) Smelters (8.5) Polyurethane Foam Electrical & Electronic Equipment Mattresses; Construction ABS Minor uses: Textile, PWB, rubber, oil drilling Landfill disposal (10) Management of WEEE & Polymers (5) Furniture Recovery of Bromine (9)* Disposal Use (1) & Reuse (5,6,7) Recycling Recovery PBDE screening technologies (4) General BAT/BEP (3) Other PolymersHIPS Alternatives to POP-BDE (2.2) Life Cycle Consideration POP-BDE containing materials (3.3) *Bromine recovery is not operated in full scale yet. Reuse of Articles (e.g. cars, electronics, furniture). Management PUR Foam (7)

8. 8 PBDE material flows and major use areas to be addressed by BAT/BEP (Section 2.1) Polymers containing c-OctaBDE – Largest amount used in electronics and now in waste electronic and electric equipment (WEEE) – Minor amount in polymers in transport sector Polyurethane (PUR) foam containing c-PentaBDE – Largest amount in transport (car, bus, truck, train, etc.) – In countries with flame retardant standards also used in furniture and construction and minor in mattresses Minor use PentaBDE: in textiles and rubber

9. 9 Alternatives to POP-BDEs (Section 2.2) Ecological priorities (Section 2.2.4) : 1.Design measures to reduce flame retardants 2.Inorganic flame retardants 3.Reactively bonded, halogen-free organic nitrogen and phosphorus compounds 4.Non-persistent or bioaccumulative additive flame retardants that are not toxic to humans and the environment in the long term List of alternative flame retardants in the main use areas of c-PentaBDE and c-OctaBDE (Section 2.2.5).

10. 10 General BAT/BEP considerations POP-BDEs: Waste management hierarchy (Section 3.1) Since the use of POP-BDE have largely stopped a decade ago, a large share of POP-BDE-containing materials have already entered the waste management and recycling flow or might soon come to this stage. Therefore considerations of waste management options play a crucial role in the overall assessment. The Stockholm Convention BAT/BEP Guidelines provide a useful starting point for the assessment of waste management options.

11. 11 General BAT/BEP considerations POP-BDEs: Reasons to separate BFR containing materials To practically achieve the separation of POP-BDE containing materials in the frame of the Convention. A separation of BFR and non-BFR polymers will improve the recyclability of the polymer streams. For sensitive non-BFR applications made from recycled polymers (e.g. toys, kitchen articles etc.) no BFR or other critical chemicals should be present in these materials. Separation of BFR containing polymers for Br recovery. PBDD/F formation potential end-of-life BFR materials COP5 emphasized the importance to separate POP-BDEs containing materials. There are good reasons to separate Brominated flame (BFRs) from waste streams (Section 3.2) :

12. 12 Live Cycle Assessment (LCA) for the management of material and recycling flow quantifying impact on ecological and heath is considered BAT/BEP. Life cycle assessments have been undertaken for electronics and transport – the main material flows impacted by POP-BDEs. Recycling of PUR foam & Bromine? General BAT/BEP considerations POP-BDE: Life cycle management considerations (Sect. 3.3) This can provide an important driving force for the recycling and waste management of these material flows.

13. 13 Specific BAT/BEP on monitoring of POP-BDE/BFR in articles (Section 4) Standard/rapid PBDE analysis: is not practical for separation in the recycling and the waste stream (Section 4.1) Bromine in situ measurement can be used (X-ray technologies; sliding spark) (Section 4.2) COP5 recommended separation of POP-BDE containing materials. How to screen and separate POP-BDEs materials?

14. 14 Specific BAT/BEP: POP-BDE/BFR containing polymers in WEEE (Section 5) Recovery of materials from WEEE (Section 5.1) – The management of POP-BDE in WEEE polymers needs to be addressed in the frame of BAT/BEP for EEE/WEEE. BAT/BEP for management of WEEE is established by the Basel Convention and is an important synergy. Reuse of electric and electronic equipment (Section 5.2) – Repair and reuse of EEE is the preferred option for end-of- life management. Reuse extends the life span, safes energy for the manufacturing and lowers the environmental impacts of mining for raw materials.

15. 15 – The recovery of metals is the key driver of WEEE recycling. – Current WEEE recycling facilities are normally not optimized for separation of PBDE/BFR containing polymer. – The complex mixture of polymers is difficult to separate and industry has tight specifications for materials/chemicals resulting in low recycling rates of polymers from WEEE. – Strategy: to produce valuable recyclates with a quality accepted by producers of new products and separation of PBDE/BFR as an integrative part of recycling. Polymer recovery/separation of BFR containing materials from WEEE (Section 5.3) Specific BAT/BEP: POP-BDE/BFR containing polymers in WEEE (Section 5)

16. 16 Technologies to separate PBDE/BFR-containing polymers (Section 5.4) −The overall cost for separation technologies need to be covered by revenues from the marketable products Specific BAT/BEP: POP-BDE/BFR containing polymers in WEEE (Section 5)

17. 17 Full scale plant to separate PBDE/BFR-containing polymers (Section 5.4) WEEE input Separation techniques Polymers Separated Quality of separated polymers PBDE/BFR Elimination (RoHS compliant products) Development Stage* Reference Mixed polymer from WEEE (Austria, China) Not disclosed A) Low-BFR types of ABS, HIPS and PP A) Good (Customer specify) Yes BFR rich fraction incinerated Industrial scale MBA Polymer Patent Small electronic equipment, White goods (Switzerland) Includes XRT BFR and PVC free polymers GoodYesIndustrial scale(Gerig 2010) WEEE polymers (UK) Undisclosed Low-BFR types of ABS and HIPS GoodYesIndustrial scale(Morton 2007) WEEE polymers (Germany) Undisclosed (incl. S/F and Electrostatic) Low-BFR types of PP, ABS and HIPS GoodYesIndustrial scale(wersag 2011) TV and computer casings (Sweden) Manual, not disclosed Low-BFR types of ABS and HIPS GoodYesIndustrial scale (Retegan 2010) Mixed polymer from WEEE (Germany) Successive Grinding and XRT BFR and PVC free polymers Not approved yet YesIndustrial scale (Adamec 2010) Specific BAT/BEP: POP-BDE/BFR containing polymers in WEEE (Section 5)

18. 18 Material recycling of polymer containing POP-BDEs (Section 5.5) The recycling of POP-BDE containing material is discouraged by the recommendations of COP5. For exempted recycling of POP-BDE containing polymers BAT/BEP needs to be defined: – for the labelling of articles produced from POP-BDE containing recyclates (Section 5.5.1) – for minimization of occupational exposure (Sections 3 & 5.5.2) – what type of article might be produced or not be produced from such recycled polymers (Section 5.5.3) – end-of-life treatment of materials and articles (Section 7) Specific BAT/BEP: POP-BDE/BFR containing polymers in WEEE (Section 5)

19. 19 Specific BAT/BEP: POP-BDE/BFR materials in the transport sector (Section 6) Reuse of vehicles containing POP-BDEs (Section 6.1) −Some special care has to be taken for cars and other vehicles from the US (possibly North America) where a large share of c-PentaBDE and c-OctaBDE has been used with production until 2004. −Vehicles from other regions can be expected to have considerably lower overall c-PentaBDE (and possibly c-OctaBDE) use considering the much lower use volumes. However, also in Asia and Europe some c-PentaBDE and c-OctaBDE have been used before 2000.

20. 20 Recycling of end-of-life vehicles (Sections 6.2-6.5) −End-of-life vehicles contain valuable materials (in particular metals) and therefore the recycling rate of ELVs has always been high (about 70%). −However the polymer containing fraction is often not recycled but disposed to landfills often as shredder fractions. One reason is the complex material mix after the shredding step containing hazardous compounds (e.g. heavy metals, POP PBDE/PCB, oils). −Recently some facilities aim on high recycling rates including the polymer fractions. BAT/BEP facilities are listed. −Energy recover from the high calorific fraction can be a BAT/BEP component (Section 8). Specific BAT/BEP: POP-BDE/BFR materials in the transport sector (Section 6)

21. 21 Specific BAT/BEP: POP-BDEs containing polyurethane (PUR) foam (Section 7) PentaBDE in PUR foam The use of flame retardants are in particular triggered by flammability standards often specific for countries/region. Due to specific flammability standard by far the largest part of c-PentaBDE have been used in PUR foam in the North America/US with minor use in other regions. For management and recycling of PUR foam this former use pattern need to be considered/assessed for a country. The guidelines give strategies for assessment and recycling.

22. 22 PentaBDE in PUR foam −7.1 Reuse of furniture/mattresses possibly POP-BDE impacted −7.2 General management and recycling of PUR foam −7.3 Assessment of POP-BDEs impact of PUR foam in a country −7.4 Separation strategy of PUR foam impacted by c-PentaBDE −7.5 Recycling areas and technologies for flexible PUR foam −7.6 Labelling of POP-BDE containing (recycled) PUR foams −7.7 Other materials possibly impacted by POP-BDE (rubber, textiles, coatings) Specific BAT/BEP: POP-BDEs containing polyurethane (PUR) foam (Section 7)

23. 23 Energy/material recovery from POP-BDE containing materials (Section 8) BAT/BEP guideline for treatment of POP-BDE containing materials can not describe the BAT/BEP for the single thermal treatment technologies since BAT/BEP descriptions of each of the processes would require several 100 pages. Such descriptions have been compiled in the BAT REFerence Documents (BREFs) for respective industrial processes (http://eippcb.jrc.es/reference/) and also have been described for UPOPs reduction in the Stockholm Convention BAT/BEP Guideline (UNEP 2007).http://eippcb.jrc.es/reference/

24. 24 General issues of thermal treatment of POP-BDE containing materials (Section 8.1) −8.1.1 High calorific value and high halogen content of POP-BDE containing materials −8.1.2 Monitoring of PBDD/PBDF and PXDD/PXDF release. −8.1.3 Considerations on corrosion caused by bromine/HBr −8.1.4 Removal of HBr/ bromine from flue gas Therefore the current guideline addresses the specific features of POP-BDE containing material with respect to the treatment/recovery technologies and refer to the related section of Stockholm BAT/BEP and EU BREF documents.

25. 25 Energy/material recovery from POP-BDE containing materials (Section 8) Following technologies are addressed for energy recovery of POP-BDE containing materials: −8.2 Energy recovery in waste incinerators −8.3 Energy recovery in cement kilns −8.4 POP-BDE containing materials in melting systems −8.5 Pyrolysis and gasification of POP-BDE containing materials −8.6 POP-BDE containing materials in metal industries Recovery of bromine from PBDE/BFR containing materials (Section 9)

26. 26 Disposal of POP-BDE containing materials to landfills (Section 10) Landfilling of wastes containing POPs is the least preferred option and must generally be avoided. This is in agreement with life cycle analysis and with the Stockholm Convention BAT-BEP guidance. Hence, the guidelines for landfilling POP-BDE assume: All possibilities to establish “clean” material cycles, or to mineralize POP-BDE by thermal treatment in BAT/BEP facility have been exploited (depends on country situation).

27. 27 10.3Categories of landfills to receive POP-BDE wastes 10.4Delivery of wastes to landfills 10.5Operation and maintenance of landfills containing POP-BDE – 10.5.1PBDE releases from landfills – 10.5.2Release of POP-BDE from landfill fires – 10.5.3BAT measures to prevent short- and long-term release of POP-BDE from landfills 10.6BAT/BEP of landfill after care 10.7Landfill mining and impact of POP-BDE Disposal of POP-BDE containing materials to landfills (Section 10)

28. 28 Overview on treatment options of POP-BDE containing materials considering key criteria Comparative emissions & impacts of recycling and recovery technologies of POP-BDE containing materials (UNEP 2010) ** Economics includes external cost considerations

29. 29 Developing country considerations The current BAT/BEP guidance has highlighted developing country considerations where possible. However there is currently a lack of information on BEP (and BAT) applied in developing countries. Information and comments on BAT/BEP from developing countries are welcome and will be considered in an update of this guidance.

30. 30 Thank you! For more information, please contact: Secretariat of the Stockholm Convention 11-13, Chemin des Anémones - 1219 Châtelaine, Switzerland Tel.: +41 (0)22 917 8729 - Fax: +41 (0)22 917 8098 E-mail: ssc@pops.int, Website: www.pops.intssc@pops.intwww.pops.int