1. PBDEs: Update on Current Issues NAHMMA Tacoma, Washington September 22, 2005

2. Ann Blake, Ph.D. Work with local government, industry, NGOs to find viable alternatives to toxic chemicals in manufacturing and consumer products From Policy to Implementation: legislation, policy papers, EPP standards, research on alternatives Molecular biology research background Hazardous waste regulation and Pollution Prevention California EPA, Dept of Toxic Substances Control Currently work with the City of San Francisco, health & environment NGO coalitions Precautionary Principle implementation National and international chemicals policy

3. Context Chemicals Policy Reform What does a sustainable chemicals policy look like? Precautionary Principle What does putting PP into practice look like? Body burden and bio-monitoring What information do we need for decision-making? Toxics reduction strategies State legislation, local policy Change manufacturing (P2) Educate consumers (Market Campaigns) Create markets for less toxic products (EPP)

4. PBDEs and Brominated Flame Retardants: A Brief History What are the PBDEs? Subclass of brominated flame retardants, which also include TPPBA, HBCD 175 FRs commonly in use; 25% are halogenated (Br & Cl) Why do we use them? Increased fire hazard with increased volume of flammable consumer products What’s the concern? Detected in human breast milk, ubiquitous in the environment Potential harmful effects Routes of exposure remain largely unknown What’s happening? Voluntary & Legislated Phase-outs Alternatives & Chemicals Policy Reform

5. Current Research Routes of exposure Food Indoor air, dust Concern as levels increase Approaching levels that cause neurological damage in laboratory animals »Swedish peregrine falcons »Highest 5% of North American breast milk Northwest Environment Watch/ Cal/EPA HML study (Dioxin 2005) now exceeding concentrations of PCBs in breast milk Summaries: IPEN: http://www.oztoxics.org/ntn/bfrs.html (Sept 2004, April 2005)http://www.oztoxics.org/ntn/bfrs.html HCWH: http://www.noharm.org/ (June 2005)http://www.noharm.org/

6. Status State bans (CA, WA, NY, MI, MD, IL, HI) DfE project on alternatives to penta in furniture US EPA TSCA SNUR: Significant New Use Rule for penta and octa- BDE Nominated for elimination under LRTAP and POPS treaties (penta and octa) EU: deca toxicity still under discussion Broad mainstream coverage of toxics in consumer products, body burden

7. Implementation Issues Regulatory expansion into products Authority and personnel has not caught up Impacts on recycling markets Consumer electronics plastic Carpet cushion No clear alternatives for penta-BDE in furniture foam

8. Next Steps Exposure: identify exposure routes of concern Food, house dust, elsewhere? Implementation: work with industry to identify barriers to change; e.g., DfE furniture partnership Carpet Cushion Council, carpet recyclers?

9. Policy Reform Case study for inadequacies of current chemicals management approach Grossly inadequate data before chemicals put on market »85,000 chemicals in use, with 1,000 added every year No data on interactions with other chemicals No systematic assessment of potential persistence, bio- accumulative properties, long-range transport, breakdown, etc. Need: Better ongoing monitoring of humans, environment Better data PRIOR to putting chemicals on the market –Europe: “No data, no market” –Implementing Precautionary Principle Alternatives, alternatives, alternatives

10. Beyond Policy Leverage institutional purchasing to create market where alternatives already exist Automotive maintenance Janitorial cleaners Low mercury light bulbs Demand full disclosure in purchasing or no deal (“No data, no market” at home) E.g., PBT-free purchasing Harmonize “green” purchasing standards Center for New American Dream –Institutional Purchasing Program GreenSeal, Scientific Certification Systems

11. Beyond Pollution Prevention Figure out barriers to implementing toxics reduction Common ones include: Lack of information about current use, alternatives –Inventory! Misperceptions about cost, performance –Demo it! Purchasing structures Resistance to change

12. Some Successful Partnerships Hospitals: HCWH/ Hospital purchasing Green Guide to Health Care Hospitality Industry: Hotel Janitorial Project / Green Business Program, San Francisco Local Government Wet cleaning demonstration projects in LA, SF Bay Area Regional, state EPP groups

13. Trends Coalition-building between environment and public health and new partners in industrial/ service sectors, labor Multi-stakeholder policy discussions National Chemicals Policy Meeting, April 2005 »Lowell Center for Sustainable Production Upcoming California Chemicals Policy meeting, Jan-Feb 2006 »Based on paper to CA legislature assessing chemicals policy options

14. Haz Mat & Beyond PBDE & other bans address products, not waste Regulatory authority lacking or unclear Changing chemicals policies locally and globally What will haz mat encompass in 2010, 2020?

15. Environmental and Public Health Consulting 510-769-7008 annblake@comcast.net