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Rome: On 18 October 2013, the 9th meeting of the Persistent Organic Pollutant Review Committee (POPRC) of the UNEP Stockholm Convention on POPs decided to develop a risk profile for commercial Deca-BDE // MISSING LINK despite uncertainty surrounding whether the substance itself actually meets the Convention’s bio-accumulation screening criteria. It is important to note that the POPRC has not concluded that commercial Deca-BDE is a POP. Members have decided to start a scientific review and evaluation of the substance through the development of a risk profile. A draft risk profile will now be developed by Norway for discussion by POPRC at its 10thmeeting in October 2014. The risk profile phase is the second step in a process that takes several years.
The decision followed lengthy discussions about the proposal submitted by Norway to list commercial Deca-BDE as a Persistent Organic Pollutant (POP). The POPRC was tasked with deciding whether the proposal provided sufficient evidence indicating that commercial Deca-BDE meets the screening criteria of the Stockholm Convention.
In BSEF’s opinion, the nominating proposal does not represent an accurate and balanced compilation of the scientific evidence. It includes inaccuracies on the substance itself, its toxicology, and its potential for accumulation. BSEF does not believe that the proposal provided a sufficient scientific basis to meet the screening criteria.
In particular, we believe that commercial Deca-BDE does not bio-accumulate and is not subject to bio-magnification. This view was shared by several members of the POPRC. However, in the end a decision was taken to move ahead to the next step without clear scientific evidence that the substance itself meets the bio-accumulation criteria.
It is also regrettable that the decision makes reference to issues upon which there was no opportunity for discussion by all parties and observers. For example, on potential debromination and postulated synergistic effects no discussion took place during the open group meetings. The decision’s reference to the potential degradation of commercial Deca-BDE is based on the EU and Canadian assessments, but does not indicate the very low rate of degradation concluded by the EU. This is a critical element, as POPRC members recognised that the significance of debromination is directly linked to the rate of this activity. The Stockholm Convention is an important global regulation and decisions should be based on the best available information, including discussion with observers.
Furthermore, robust GLP compliant OECD guideline studies demonstrating that commercial Deca-BDE does not show adverse effects were omitted from the nominating proposal. As an example, Biesemeier et al (2011) showed a no-observed-adverse-effect level of Deca-BDE for developmental neurotoxicity as high as 1000mg/kg/day, the highest does used in the study and also the highest commonly used testing dose.
Under these circumstances, BSEF believes the decision to move forward despite expressed concern of POPRC members is most unfortunate and sets precedent that undermines the scientific integrity of the convention. Moving substances forward despite serious shortcomings with the proposal, and introducing new data at the POPRC without adequate time or opportunity for review and intervention by Parties and Observers subverts the nomination and review process.
BSEF will continue to actively engage in this process to ensure a science-based assessment of commercial Deca-BDE.
Commercial Deca-BDE // MISSING LINK is a brominated flame retardant used in plastics for electric and electronic equipment (E&E), in the transportation sector and in construction and building. Deca-BDE is additionally used as a flame retardant in textiles to enable upholstered furniture to comply with fire safety standards for public places and buildings. BSEF members have voluntarily agreed to phase out the production, manufacture and sales of Deca-BDE in North America by end of 2013.
About the Stockholm Convention and Brominated Flame Retardants
The Stockholm Convention is an international agreement of the United Nations Environmental Programme. Its remit is the identification, evaluation and elimination of persistent organic pollutants (POPs) from the environment. Brominated flame retardants are not POPs. All commercially available brominated flame retardants are safe for their intended use and none are presently listed as POPs. The decision was taken in May 2013 to list one of these substances, HBCD // MISSING LINK, for elimination as of late 2014 however with specific exemptions for use in polystyrene insulation foams in buildings for up to five years to allow time for the market to complete a smooth transition to a suitable alternative in this critical application.
Brominated flame retardants are chemicals commonly used in the manufacture of many domestic and industrial appliances, for instance in electrical and electronic appliances for the purpose of fire safety. Flame retardants are essential to slow down the spread and decrease the number of fires.
BSEF is the international organisation of the bromine chemical industry, whose remit is to inform stakeholders and commission science on brominated chemicals such as flame retardants. www.bsef.com
 UNEP Stockholm Convention on Persistent Organic Pollutantshttp://chm.pops.int/Convention/ConventionText/tabid/2232/Default.aspx
 The decision will be made available by the Convention Secretariat here:http://chm.pops.int/TheConvention/POPsReviewCommittee/ReportsandDecisions/tabid/3309/Default.aspx
 Decabromodiphenyl ether
 As set out in Annex D of the Stockholm Convention: http://www.pops.int/documents/convtext/convtext_en.pdf
 Biesemeier et al. 2011. An oral developmental neurotoxicity study of decabromodiphenyl ether (DecaBDE) in rats. Birth Defects Res Part B 92:17-35. Supplemental Information and Tables, pg 1-68.