In the October Letters (see EBN Oct 2009), the American Chemistry Council (ACC) attempts to downplay the placement of HBCD in the REACH Substance of Very High Concern (SVHC) category. This placement, however, is not done lightly by the European Union. HBCD has been placed in a very small select group of substances due to its “hazardous properties of very high concern”. Only 20 chemicals have been selected for this group to date. The ACC suggests that they may avoid REACH restrictions on polystyrene insulation by asserting a low likelihood of exposure asserting that it is retained in the polymer matrix. Yet they also acknowledge that Kemi has found that fully 14% of all human exposure is from this application alone. Furthermore, the “adequate control route” for REACH authorization appropriately does not apply for substances with persistent bioaccumulative toxic (PBT) properties so will not be applicable to HBCD.
That does not mean that HBCD cannot receive authorization for limited uses under REACH but that it will be subject to significant analysis. They must determine if the socio-economic benefits outweigh the risks and find no suitable alternative substances or technologies. Even if it meets these criteria, the Authorization will only be for a limited time and with a plan in place to develop alternatives. (http://guidance.echa.europa.eu/authorisation_en.htm)
Given the seriousness of the hazards posed by a PBT like HBCD, its identification as an SVHC is sufficient to make it eminently responsible to encourage the use of alternatives where possible immediately, regardless of the results of any future temporary authorization. It also is important to begin to look at the other sources of HBCD exposure and explore avoidance alternatives for those applications as well
Tom Lent, Policy Director
Healthy Building Network
www.healthybuilding.net
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