Hexabromocyclododecane (HBCD) is a toxic chemical that has been used as a flame retardant in foam building insulation and other products for many years. Although it is being phased out of new foam board, this legacy use combined with other ongoing uses in the U.S. create a toxic reservoir of HBCD that may be released into the environment and harm people’s health. The Environmental Protection Agency has decided to evaluate this chemical to determine its risks. We need to make sure EPA reviews all the information it needs to protect health and the environment!
Buildings in U.S. contain a toxic reservoir of HBCD
Healthy Building Network (HBN) recently reported that approximately 99 million pounds of HBCD were used in the United States over the period between 1988 and 2010. Most of this was added to foam insulation board installed in buildings – including homes, schools and workplaces. HBCD was also used in building insulation after 2010, but the specific amount is unknown.
This first-ever estimate of HBCD use and much of the information discussed below were published in comments jointly submitted to EPA by Safer Chemicals Healthy Families, Environmental Health Strategy Center (EHSC), and HBN. These groups provided input on what should be addressed by the agency’s risk evaluation of HBCD under the Lautenberg Chemical Safety Act.
Multiple pathways for exposure to HBCD from foam board put people’s health at risk
When the foam board is removed or destroyed – through renovations, demolition, or a fire – HBCD may be released into dust, since it isn’t chemically bound to the foam. Fires can generate byproducts that are also toxic, putting firefighters at risk for serious health problems. Firefighters are at an increased risk for developing a range of cancers, especially when flame retardants are used in furniture and other household or office items. (According to EPA, studies indicate that HBCD may affect human reproduction and development.)
Foam insulation has a limited service life of 25 to 60 years, so its disposal will likely be a significant source of HBCD emissions in future years. A European study found that in 2006, a sizeable amount of HBCD was already being released from discarded insulation boards – almost 19,000 pounds. Weathering and degrading of foam insulation in landfills and burning during incineration can release HBCD, potentially exposing workers at these facilities. Improper disposal can also impact the food chain: a study found that if insulation fragments with HBCD end up in the ocean, high levels of the chemical can be transferred to mussels that latch onto the foam.
Other uses of HBCD are ongoing in the U.S., despite its global phase-out
U.S. manufacturers are moving away from adding HBCD to new foam insulation board, but the chemical is still used in other products, such as textile coatings. According to industry reporting in Washington State, HBCD is present in at least 48 children’s products, including clothing, blankets, and toys. The Washington State Department of Ecology’s testing also found HBCD in poly foam beans of a beanbag chair, as well as the rubber palm fabric of a protective glove. SCHF coalition partners at the Ecology Center analyzed samples of foam in children’s car seats and found flame retardants believed to be HBCD.
The U.S. is not a signatory to the international Stockholm Convention on Persistent Organic Pollutants, which provides for the global phase-out of HBCD. Parties to this agreement, which include almost all other countries in the world, have agreed to stop using HBCD because it persists in the environment and builds up to high levels in the food web and in humans. These characteristics mean that HBCD also accumulates in the food and medicine sources of indigenous Arctic communities, who are disproportionately impacted even though they live far from where the chemical is actually used.
What is EPA doing about this?
Among its new responsibilities under the recently amended Toxic Substances Control Act (the Lautenberg Chemical Safety Act), EPA must decide whether existing chemicals pose an unreasonable risk to human health or the environment. EPA has begun risk evaluations for 10 chemicals, including HBCD. The agency is currently deliberating on the scope of the evaluation and will issue a final scoping document by June 2017.
Make your voice heard!
EPA needs to hear from you that its risk evaluation must ensure that public health and the environment are protected. Tell EPA to:
- Consider exposures and releases connected with all uses, both legacy and ongoing; and
- Assess all potentially exposed or susceptible subpopulations, including workers in waste industries, firefighters, pregnant women, indigenous Arctic populations, and fenceline communities that may be disproportionately exposed to HBCD.
We want EPA to have all of the evidence necessary to support a finding that HBCD poses an unreasonable risk. This determination will give EPA a strong foundation for taking needed regulatory actions, including: banning all remaining uses, holding chemical manufacturers financially responsible for safely removing and destroying HBCD-containing foam insulation board at the end of its useful life, restricting releases during building demolition, and banning the disposal of this foam board in landfills and incinerators.
