Beyond a Ban of PBDEs
June 1, 2004
As explained in our feature article this month, certain brominated flame retardants, especially PBDEs, are being shown by scientists to pose significant risks to our health and the environment. Indeed, the arguments for banning PBDEs are so clear that
EBN calls for an immediate ban of all PBDEs, including the widely used deca form. This is only the second time
EBN has called for the outright ban of a particular product; the first was in 1997, when we argued for a ban of the wood preservative CCA (see
Beyond a ban of PBDEs,
EBN calls for the following:
•Comprehensive testing of all flame retardants relative to health and environmental safety;
•Additional bans of other halogenated flame retardants that cannot be proven, beyond a reasonable doubt, to be safe; and
•A voluntary transition to flame retardants less likely to be hazardous or to materials that do not require flame retardants.
Inherent in these recommendations is a shift in the burden of proof in demonstrating risk of chemicals. It should be up to manufacturers to demonstrate a product’s safety, rather than up to regulators or health activists to prove undue risk. The Toxic Substances Control Act of 1974 should be revised to reflect this shift in responsibilities, and the U.S. should support international efforts, such as the European Union’s REACH (Registration, Evaluation and Authorization of Chemicals) process for managment of chemicals.
Our recommendations regarding flame retardants will often necessitate going beyond simple chemical substitutions. We are suggesting a different way of thinking about which products are appropriate for which building applications, how those products should be installed to ensure fire safety, and what additional protective measures, such as universal sprinklering in buildings, may be required to provide the safety consumers deserve. If inherently flammable building materials, such as plastics and wood, cannot be made reasonably flame resistant with safe chemicals, then these materials should be used only in locations and applications where flame resistance is not required or where protective fire barriers or sprinklers can impart the necessary safety. This might include enclosing all wiring within metal conduit, for example, or protecting foam insulation with more fire-resistant barriers. For certain applications, it may be time to stop using inherently flammable materials altogether—replacing certain plastics, for example, with inherently fire-resistant cementitious materials, metals, and ceramics.
These shifts will be dramatic, they will be strenuously resisted by some (especially those in the plastics industry), and they will take time and money. It will take ingenuity to achieve these changes without adversely affecting safety, energy performance, durability, and affordability—all critically important goals. But this evolution will also create tremendous opportunities for new product development, with billions of dollars to be made by smart companies. For example, the technology exists today to produce foamed-mineral beadboard insulation that could replace plastic foam insulation. As for the costs of transitioning away from hazardous flame retardants, they might be far lower than those resulting from putting an ever-more-complex alphabet soup of new chemicals into our buildings, our bodies, and our environment.