Albemarle's Earthwise team speaks about flame retardant regulatory status and future development at the GPEC 2010 conference. This was presented by Susan Landry and Ray Dawson of Albemarle.

1. Flame Retardant Regulatory Status and
Future Development
GPEC 2010 – March 9, 2010
Susan D. Landry Raymond B. Dawson
Advisor, Fire Safety & Advocacy Global Director, Advocacy
susan.landry@albemarle.com ray.dawson@albemarle.com

2. Why are Flame Retardants Needed?
Non flame Flame retarded
retarded to UK-standard
Flame retardants are used to help:
Prevent ignition
Delay the spread of fires
Delay the time of flashover to enable people
time to escape
Extract from a Dutch TV documentary, RTL 5,
2000
It is estimated that escape times
can be up to 15 times longer
when flame retardants are
present, providing increased
chances of survival
“Fire-Hazard comparison of fire retarded and non fire
retarded products,” NIST 1988,
http://fire.nist.gov/bfrlpubs/fire88/art003.html Toronto, Canada, August 2, 2005: Flame retardants
were credited with increasing escape times for all 309
passengers from this jet, which was ultimately
completely consumed by fire.
Washington Post, Aug. 5, 2005

3. Why are Flame Retardants Needed?
Fire prevention is essential from a number of perspectives:
Protection of life
Protection of property and the environment
Prevention of immediate local pollution to air and water
Prevention of lesser-known long-term environmental effects
Results of a 2009 study, performed by Greenstreet Berman Ltd for the UK Department of Business,
Innovation and Skills, has shown that the UK furniture fire safety regulations account for
54 fewer deaths per year
780 fewer non-fatal casualties per year
1065 fewer fires per year
(A statistical report to investigate the effectiveness of the Furniture and Furnishings (Fire) (Safety) Regulations 1988, December 2009)
The introduction of voluntary flammability standards made possible by the use of flame retardant plastics in the TV enclosures
and accessories led to a significant reduction in the number of TV-initiated fires, even with a sharp increase in the total number
of TV sets per household. It is estimated that 190 lives are saved annually through the use of brominated flame retardants in
TV enclosures.
F. Clarke, “The life safety benefits of brominated flame retardants in the United States,” Final Report to the Chemical Manufacturers Association
Brominated Flame Retardant Industry Panel, Benjamin/Clarke Associates, 1997

4. Combustion Gases Generated In Fires
Typically items involved in fires are a complex mixture of
materials (furniture, electronics, building materials, household
cleaners, etc…)
Combustion Gases generated regardless of whether or not flame
retardants are present
“Clearly, fire gases are dangerous to fire fighters and other citizens who
could be exposed, independent of the presence or absence of flame
retardants [2] ”
“Combustion gases contain very high concentrations of acutely toxic
substances [3] ”
Combustion gases generated during fires that contribute to acute toxicity
include CO, HCN, HCl, and acrolein [1]
The acute toxicity of fire gases is controlled by carbon monoxide (CO) –
responsible for over 90% of fire deaths [1]
1) Troitzsch, J, “Fire Gas Toxicity and Pollutants in Fires – The Role of Flame Retardants,” FR2000 Conference, London, 8th-9th February 2000
2) “Review of Fire Emissions from Products with and without BFRs and the Hazard of Exposure for Fire Fighters and Clean-up Crews”, SP
Report 2007:74
3) Rechenbach, P, Troitzsch, J, “Smoke Toxicity and Pollutants from Fires”, Kunststoffe 89 (1999) 9, pp. 132-134

5. Pollutants Generated In Fires
Pollutants generated regardless of whether or not flame
retardants are present
Polycyclic Aromatic Hydrocarbons (PAHs) and polyhalogenated
dibenzodioxins and furans (PHDDs/PHDFs) are the most important
pollutants generated in fires [1]
Compared to PAHs, the impact of PHDDs/PHDFs on our health is
negligible [1]
In the Lengerich fire (Germany in 1992), measurements and their
respective cancer risk and relationship showed that the PAHs have an
up to 500 times higher cancer risk than the PHDDs/PHDFs [1]
PAHs are generated in all fires [1]
There are several hundred different substances in the PAH family [1]
Many PAHs generated in fires are carcinogenic compounds, including
benzo[a]pyrene (BaP) [1]
PAHs are found in high amounts in the soot after fires [1]
1) Troitzsch, J, “Fire Gas Toxicity and Pollutants in Fires – The Role of Flame Retardants,” FR2000 Conference,
London, 8th-9th February 2000

6. Common Flame Retardant Classes
Mineral
Others…
Halogenated
Brominated Chlorinated
Phosphorus
Based on natural elements
There are many different flame retardants in each of these classes
Each individual flame retardant has it’s own unique set of environmental, human
health, physical, and chemical properties
The distinct nature of individual flame retardants requires that each be treated
on it’s own merits

7. European Union (EU) Risk Assessment
The EU Regulation 793/93 - EU Risk Assessment was one such
assessment process adopted in 1993
The most comprehensive assessment of a materials environmental and
human health characteristics
Products were assessed individually, not as a class
Determined the need for further testing to fill in data gaps
Determined if there was a need to limit risks
This process:
Examined mammalian toxicology
Acute, chronic
Established acceptable human exposure limits: Predicted No-Effect Conc. (PNEC)
Examined environmental fate and toxicology
Established acceptable environmental exposure limits: PNEC
Examined all releases to water, soil, air, from all operations throughout
lifecycle
Volumes, processing, uses, waste streams
Established human and environmental exposures: Predicted Environmental
Concentrations (PEC)
Evaluated risk: Exposures versus limits
Determined if exposure is above or below established limits

8. Summary of FR EU Risk Assessments
Flame Retardant Status Next Steps Risks Identified Conclusions Classification
Risk Assessment Banned in EU as of
Penta-BDE Concluded ---
Unfavorable Aug 2004
---
Banned in EU as of
Octa-BDE Concluded --- Some risks identified
Aug 2004
---
Additional tests, - Safe for continued
monitoring, and use
Deca-BDE Concluded
emissions control in
None
- Emissions control
None
progress program active
- Not restricted for any
ENV: risk identified
applications
ENV: Finalized at one additive user
- Authorities have
TBBPA HH: Finalized
None plant only
emission requirements
R50/53
- Emissions control
HH: None
program active
Classified a PBT
ENV: Finalized Transferred to REACH
On the SVHC Risks identified, PBT
HBCD HH: Finalized Candidate List status debate – new
- on the SVHC R50/53
Candidate List
science
ENV = Environmental Sections, R38 = irritating to skin, HH = Human Health Sections, R40 = Carcinogenic category 3, limited evidence of a carcinogenic,
PBT = Persistent, Bioaccumulative, and Toxic effect, C&L = Classification and Labeling, SVHC – Substance of Very High concern, N - Dangerous to the
Environment, T = Toxic, R22 = Harmful if swallowed, Xn = Harmful, R50/53 = Very toxic to aquatic organisms, may cause long-term adverse effects in the
aquatic environment, R51/53 = Toxic for aquatic environment, may cause long-term adverse effects in the aquatic environment, R60 = Toxic to
reproduction category 2 (CMR category 2), ATP = Adaptation to Technical Progress

9. Summary of FR EU Risk Assessments
Flame Retardant Status Next Steps Risks Identified Conclusions Classification
ENV: finalized Reprotox + chronic Transferred to REACH
On the SVHC T, N, R51/53, R22, R60,
TCEP HH: finalized Candidate List
tox + Carc, several - on the SVHC
R40
exposure scenarios Candidate List
ENV: finalized REACH registration, TCPP will be sold with
Reprotox, dermal,
TCPP HH: finalized C& L decision production
the same existing Xn, R22
labels
Chronic tox + Carc,
ENV: Finalized REACH registration, TDCP will be sold with
dermal, production &
TDCP HH: Finalized C& L decision flexible PU foam
the same existing N, R51/53, R40
labels
manufacturing
Antiblaze® TL-10
ENV: Finalized Antiblaze® TL-10 successfully completed
V-6 HH: Finalized
successfully completed None registration (REACH None
REACH registration Registration # 01-
2119419991-33-0000
ENV: risks identified
for sediments at a
few plants
ENV: finalized Risk Assessment Transferred to the
(Sb2O3) HH: finalized transferred to REACH
HH: no risks
REACH
R38, R40
identified at current
stage –discussions
in progress
ENV = Environmental Sections, R38 = irritating to skin, HH = Human Health Sections, R40 = Carcinogenic category 3, limited evidence of a carcinogenic,
PBT = Persistent, Bioaccumulative, and Toxic effect, C&L = Classification and Labeling, SVHC – Substance of Very High concern, N - Dangerous to the
Environment, T = Toxic, R22 = Harmful if swallowed, Xn = Harmful, R50/53 = Very toxic to aquatic organisms, may cause long-term adverse effects in the
aquatic environment, R51/53 = Toxic for aquatic environment, may cause long-term adverse effects in the aquatic environment, R60 = Toxic to
reproduction category 2 (CMR category 2), ATP = Adaptation to Technical Progress

10. Restriction of Certain Hazardous Substances in
Electrical and Electronic Equipment (RoHS)
Directive 2002/95/EC - came into force July 1, 2006
Restricts the placing on the EU market new electrical and electronic
equipment containing certain levels of lead, cadmium, mercury, hexavalent
chromium, polybrominated biphenyl (PBB), and polybrominated diphenyl
ether (PBDE) flame retardants
Review of the RoHS Directive is now ongoing:
European Commission proposal (December 2008):
No addition of new substances
New Annex III with list of substances for priority review including HBCD & 3
phthalates
REACH / RoHS alignment to avoid contradiction
European Parliament (November 2009):
The Green Political Party has the lead on the discussions = “rapporteur”
Their current proposal is to ban all BFRs & other substances
Not endorsed by a number of MEPs - too extreme
Discussion around open scope for RoHS

11. RoHS Revision – current status
European Council
Main focus is on alignment between REACH & RoHS
No discussion on addition of substances yet but discussion on need
of criteria &/or methodology for inclusion of new substances
Discussion around open scope for RoHS
The RoHS revision is still under discussion by the
European Institutions & nothing is decided yet
Most industry associations do not agree to add further
substances to the RoHS Directive

12. Registration, Evaluation, Authorization and
Restriction of Chemical Substances (REACH)
REACH is a new European Community Regulation on chemicals and
their safe use (EC 1907/2006) - entered into force on 1 June 2007
Registration, Evaluation, Authorization and Restriction of Chemical
substances
All manufacturers and importers of chemicals in the EU must identify
and manage risks linked to the substances they manufacture and
market
REACH replaces about 40 pieces of EU legislation
Industry must bear most responsibilities to manage the risks posed by
chemicals and provide appropriate safety information to their users
REACH calls for the progressive substitution of the most dangerous
chemicals when suitable alternatives have been identified

13. REACH – Registration timelines
06/2007 06/2008 12/2010 06/2013 06/2018
P
R
REACH Entry
into force E
-
R
> 1000 tpa
> 1 tpa (CMR cat. 1 & 2,
E Registration
PBT, vPvB) G
> 100 tpa (N; R 50/53) I
S
> 100 tpa T Registration
R
A
T
> 1 tpa I Registration
O
N
Not pre-registered / non phase-in substances
CMR = Carcinogen, Mutagen, Reprotoxic, N - Dangerous to the Environment , tpa = tonnes per annum per company, PBT =
Persistent, Bioaccumulative, and Toxic, R 50/53 = Very toxic to aquatic organisms, may cause long-term adverse effects in the
aquatic environment, vPvB = very Persistent and very Bioaccumulative

14. REACH – Evaluation Duties of registrants :
Update with undue delay and with relevant
new information (uses, hazard information, tonnage band)
Update submission on examined testing proposals,
Submission of registration requirements of compliance checks and
(by registrant) other requirements set by Authorities
Additional fees for each update
Completeness Check Registration
for dossier and fee (by ECHA) No. assignment
Dossier Evaluation Substance Evaluation
(by ECHA) (by MS)
Check of Testing Check of
Compliance Check
Proposals (by ECHA) Substance properties
(by ECHA)
OUTPUT :
Decision on further information requirements
Information for stakeholders
Restrictions

15. REACH – Authorization
Substances targeted by authorization are Substances of Very High
Concern (SVHCs):
CMR (Carcinogen, Mutagen, Reprotoxic) cat. 1 and 2
PBT (Persistent, Bioaccumulative, and Toxic)
vPvB (very Persistent and very Bioaccumulative)
Substances with equivalent concern (e.g. endocrine disruptors)
There are reporting, notification, and information obligations for suppliers
of SVHC substances, and preparations and articles containing them
The Authorization process comprises three stages:
Identification of SVHC (Candidate list) - This triggers notification and
communication obligations for candidate list in articles, with possible
black list effects
HBCD listed on the first candidate list published by ECHA October 2008
TCEP added to the candidate list
Inclusion of candidate substances in the list of substances subject to
authorization (Annnex XIV)
Decisions on applications for authorization

16. REACH – Authorization
Potential Options for Authorization
SUBSTANCES of VERY HIGH CONCERN
RISK IS NOT ADEQUATELY CONTROLLED :
RISK IS ADEQUATELY CONTROLLED :
CMRs 1 & 2
CMRs 1 & 2 +
+ OTHER substances with threshold limits
OTHER substances with threshold limits +
PBTs, vPvBs
Suitable alternative
YES NO YES
Socio-economic benefits
YES
AUTHORIZATION NO SUBSTITUTION
Time-limited review on case-by-case basis
BAN

17. REACH Flame Retardant Summary
Pre-registration / Registration
Albemarle pre-registered all its flame retardants
Consortia formation and registration dossiers gathering ongoing
Risk assessed substances are already data-rich
TL-10ST
Albemarle’s TL-10ST (2,2-Bis(chloromethyl)trimethylene
bis(bis(2-chloroethyl)phosphate)) has successfully
completed registration (REACH Registration # 01-
2119419991-33-0000)

18. REACH Flame Retardant Summary
HBCD (Hexabromocyclododecane)
Classified as a PBT - On the 1st Candidate List for Authorization
Used in EPS & XPS, with no available alternatives
Authorization is being sought for this application due to the importance
of insulating foam
Application for Authorization due mid-2012
Current sunset date is late 2013 for all applications without
Authorization
TCEP (Tris(2-chloroethyl) phosphate)
Classified CMR cat. 1-2 after EU risk assessment
Not sustainable under REACH - alternatives available for all uses

19. HBCD – Other Issues
HBCD (Hexabromocyclododecane)
UNECE POP
HBCD classified as a POP Dec 2009
Q1 2010 - Risk management Questionnaire
Q4 2010 - Risk management will be decided
Q4 2011 - Potential POP listing unless exemption is granted
Industry is actively co-operating with the UNECE process to ensure
exemption for EPS & XPS use
UNEP POP (Stockholm Convention)
May 2013 - Potential POP listing unless exemption is granted

20. Deca-BDE Phase-Out
The three major producers of Deca-BDE have entered into a “partnership” with
EPA to phase out production and importation of Deca-BDE
Other Deca-BDE importers/distributors are encouraged to join the partnership
Our commitments to EPA include the following:
We will stop manufacturing Deca-BDE by December 31, 2013
Deadline for completion of
End-Use Application
Deca-BDE phase-out
Wire & Cable
December 31, 2010
(except transportation or military)
All other uses
December 31, 2012
(except transportation or military)
Transportation and military uses December 31, 2013
We will submit to EPA annual progress reports
After the phase-out period, EPA intends to impose additional Deca-BDE testing
requirements on remaining producers/importers
After the phase-out period, EPA intends to impose a “significant new use rule” or
SNUR on Deca-BDE and articles containing Deca-BDE

21. NA Activity
State-by-state regulations - limited number of flame retardants
Potential TSCA Reform
EPA
“Chemicals of Concern” Action List announced Dec 2009
Include phthalates, short-chain chlorinated paraffins, polybrominated diphenyl
ethers (PBDEs), and perfluorinated chemicals, including PFOA
Process could lead to risk reductions actions under section 6 of TSCA
EPA also announced that three companies agreed to phase out Deca-BDE
Reinforcing the Deca-BDE phase-out – with requirements to ensure that any new
uses of PBDEs are reviewed by EPA prior to returning to the market.
“Polybrominated Diphenyl Ethers (PBDEs) Project Plan”
High Production Volume (HPV) Challenge (~2200 HPV chemicals)
Design for Environment (DfE) program
Partnership with a broad range of stakeholders - Several have and are currently
including flame retardants
California Green Chemistry Initiative
Encourage the development of “green chemistry” solutions
Canada - Implementation of Chemical Substances Plan

22. Informed Substitution

23. Safety & Sustainable Use of Flame Retardants
Flame Retardant Selection
Physical, Mechanical, and Flammability Properties; Stability;
and Recyclability of Polymer Formulations
Commercial Availability of FR
Cost
Human Health and Environmental Criteria
Meets Current Regulations
Meets Anticipated Regulations ?
How do you measure environmental impact of
various FR’s in use?
Life Cycle Assessment
Carbon Footprint, Global Warming, Energy Consumption,
Ozone Depletion, Air Acidification, etc…

24. Sustainability
Fire Safety is important for the good of society
We are a fire safety company
Albemarle will provide the right solution; we do not limit
ourselves to particular products or chemistries
The choice of technology used to achieve fire safety
should be based on sound principles
Full life-cycle analysis
Non-toxic, non-bioaccumulative products
Consideration of environmental and societal impacts
We must solve the end-of-life problem for products
Products should enable recyclability

25. To Achieve This
• Our new product development will focus on
Polymeric solutions, big molecules
Reactive products that become bound to the final polymer
Non-toxic small molecules
Mineral products
• Releases of all products to the environment must be minimized
We will champion the implementation of measures throughout the supply
chain to minimize emissions of persistent compounds
Engage distributors, customers, and competitors in programs such as
VECAPTM to eliminate all product emissions from the environment

26. The next generation of eco-friendly fire safety
• First product in our family of green solutions
• non-bioaccumulative
• superior toxicity profile
• excellent recycle capability
• exceptionally broad application profile
• Polymeric flame retardant
• Highly stable product lends itself to efficient recycling of plastics.
• Emissions to the environment are minimized, when combined with other
good practices such as the Voluntary Emissions Control Action Program.
earthwise™ A division of ALBEMARLE®

27. Eliminating Emissions To The Environment Is Of
The Utmost Importance For Sustainability
Voluntary Emissions Control Action Program
Voluntary – producer and user implemented
Emissions – identify sources of BFR emissions
Control – reduce, minimize and where possible eliminate
emissions
Action – dynamic, continuous process
Program – focus on best practices to eliminate emissions
TM
VECAP
VECAP™ is an Industry Program that can be applied to all polymer additives
to prevent potential emissions and save valuable raw material

28. Reduce Levels of Environmental Emissions of Flame Retardants
VECAP addresses many stages of the Life-Cycle
Manufacturing Processing Waste disposal
Production Dust from unloading and Residues in packaging
Packaging feed operations Poorly treated wastewater
Shipping Leaks in feed equipment from system wash-outs
Improper clean-up of spills Waste not reprocessed

29. We are asking users to:
Perform self assessment
Commit to VECAP and Mass Balance;
Code of Good develop baseline
Practice emissions to ensure
progress is measurable
Drive to
Reduce
Emissions
Create and implement Utilize third-party
emissions reduction verification audits as
plan needed

30. VECAP in Action – Best Available Practices for Handling Packaging
Problem
• Discarded packaging can retain small amounts of
product
• Product has the potential to get into the environment,
depending on end-of-life practices for empty
packaging
Solution
VECAP Best Available
Technique (BAT) for
Emptying Packaging
Document and Poster
These techniques can be applied to all polymer
additives to prevent potential emissions and save
valuable material for use, rather than waste

31. Support of VECAP
Wildlife Habitat Council GM
"It was a pleasure to be introduced to the innovative Voluntary “VECAP is a good example of effective cooperation
Emission Control Action Program (VECAP) designed to reduce and throughout the whole supply chain. In line with GM’s
where possible eliminate avoidable emissions of brominated flame commitment to environmental excellence, the
retardants into the environment from manufacturing processes. The programme ensures that the chemicals included in
Wildlife Habitat Council supports voluntary efforts by industry to go our products are safely managed. Moreover, as it
beyond regulatory requirements and adopt management practices, allows a better management of substances, VECAP
such as VECAP. We look forward to working with this industry sector is particularly relevant in the context of REACH and of
and help them improve their overall sustainable management practices the development of the new chemical regulation in
to include wherever possible management strategies that promote the US.”
wildlife habitat improvement and on site conservation education for the Dr. Pat Beattie, Director Chemical Risk Management,
benefit of the local community.“ General Motors Corporation
Robert H. Loftur-Thun, Vice President External Affairs, Marketing, & Dave Mattis, Global Technology Engineering, General
Development, Wildlife Habitat Council Motors Corporation
Marks & Spencer
“VECAP is a great example of how chemicals need to be managed in the 21st Century, true producer responsibility. Here is a sector of the
chemical industry that has been under more pressure than most but has responded to the challenges before it by developing a ground
breaking model for control. VECAP’s strength lies in its focus on the use of brominated flame retardants across the whole value chain, not
just at one stage within it. It is based on the use of common sense best practice; often small things that added together can make a real
difference. Of course it doesn't just rely on words on paper but brings things to life on the factory floor with good practice guides, training and
audits. Finally VECAP does not duck the challenge of debate with those stakeholders who may criticize the performance of the industry, nor
has it hidden from the need to back up the claims for its potential with evidence of real year on year improvement in reducing emissions. Put
together this value chain approach, best practice, training, measurement and debate and we have a model that shows how a sector of the
chemical industry can go beyond compliance with legislation and develop a far more sustainable approach to doing business.”
Mike Barry, Head of Corporate Social Responsibility, Marks & Spencer

32. Eagle Performance Products Receives Environmental
Award for Use of VECAP
Eagle Performance Products has implemented 5 initiatives that have reduced waste both in-house and with
customers. These waste reduction initiatives have resulted in savings of approximately 6,000 Kg/yr of
formulated material and 11,500 Kg/yr of plastic additives at the Eagle Performance Products plant and
approximately 36,000 Kg/yr of formulated product at their customer’s facilities.

33. Conclusions
Flame Retardants provide a valuable role in our society
Prevent ignition
Delay the spread of fires
Delay the time of flashover to enable people time to escape
It is important that Flame Retardants are safe in use
Regulations that are being developed worldwide provide the platform to
achieve this goal with a level of confidence
Albemarle’s EarthwiseTM family of products will focus on sustainable
offerings
GreenArmorTM is the first product in this family of sustainable solutions

34. For More Information…
www.albemarle.com
www.earthwiseinside.com
www.vecap.info
www.bsef.org
www.ebfrip.org