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(  traduction française)

Foreword:

Brominated flame retardants perform an essential role in helping plastics meet and even surpass the most stringent fire safety standards in Electrical and Electronic (E&E) equipment. It is becoming increasingly important for policymakers to define a regulatory framework to manage the recovery of materials contained in E&E equipment in an environmentally sound manner. There is a perception that brominated flame retardants (BFRs) in some way affect adversely the potential to recover plastics. In fact there exists a wide range of data and practical experience demonstrating that the end-of-life management of plastics containing BFRs is fully compatible with an integrated waste management concept, in line with the waste policy of the EU. Such reports suggest that BFRs in E&E equipment will not prevent the recovery, including recycling, of materials currently in use. In fact any move to restrict the use of BFRs in E&E equipment would preclude the development of products and processes which may provide the best solution for future recovery and recycling goals.

Mechanical Recycling:

Several studies have shown that plastics containing BFRs can be recycled. First studies from the BAYFORREST project [1], sponsored by the Bavarian State, demonstrate that plastics containing BFRs can meet the strict PBDD/F limit values of the German „Dioxin Ordinance" (Chem.-Verbots-VO) in the recyclate if recycling is done properly. Further independent studies sponsored by the industry on the recycling of BFR plastics are currently in process. Additionally, industry is sponsoring a program to test existing data which show that potential brominated dioxin/furan (PBDD/F) exposure at the workplace during recycling is of no concern. There is evidence from BAYFORREST tests that PBDD/F workplace exposure is insignificant during recycling. The results of the BIA report [2] came to comparable conclusions regarding the processing of plastics containing BFRs. The University of Erlangen [3] and AG CYCLE [4] are currently working on identification and separation processes for plastics containing BFRs to enable the separate treatment of this type of plastics on an operational scale. Moreover, the copiers industry convinced the German Environmental Agency (UBA) to delay eco-label criteria discriminating against BFRs precisely because BFR plastics were preferable from the point of view of recyclability [5].

Feedstock Recycling:

An APME report [6] concluded that feedstock recycling (depolymerisation & hydrogenation) of plastics from WEEE is a promising option and an environmentally sound method for recovering BFR plastics. These tests have been carried out at the Veba Oel AG, KAB in Bottrop/Germany on a commercial scale (15.000 t/y). The bromine industry is currently undertaking a feasibility study to determine the economic and technical viability of bromine recovery from plastics containing BFRs (e.g. printed circuit boards, housings). This would close the bromine loop, ensuring the sustainability of bromine production. First workgroup meetings have already taken place with the bromine industry, electronic equipment manufacturers and the recycling industry.

Energy Recovery:

Incineration tests, pyrolysis [7] and combustion studies [8] have demonstrated that waste from E&E equipment can be safely added to today’s municipal solid waste (MSW) to generate in an environmentally sound manner useful energy. PBDD/F formation is not altered by the presence of the bromine-containing waste, and remains well within emission standards in these processes. The OECD [9] came to the same conclusion regarding the insignificance of dioxin/furan formation when incinerating BFRs. The OECD noted that the highest formation rates for brominated dioxins/furans from PBDEs during laboratory experiments [10] were associated with low temperatures and pyrolitic conditions. Modern waste-to-energy facilities are specifically designed to avoid these conditions. A report from the European Commission [11] came to the same results. This is reflected in the reality that several MSW incinerators (e.g. in Germany) have the permission to co-combust of WEEE plastics and MSW.

Any presumption that BFRs make plastics recovery more complex requires justification as it could be argued that any plastics additive makes plastics recovery a more complicated process. The fact is that without additives plastics would no longer be able to be used in the vast majority of applications. BFRs add value to E&E plastics by enabling E&E equipment manufacturers to go beyond minimum fire safety standards in order to enhance consumer safety levels. (It should be noted that in certain cases such as TV sets, the standards are appreciably lower than those in force in the US and Japan.) The widespread use of BFRs in E&E appliances over the last ten years is all the more reason to ensure that these high value plastics can clearly be identified, thus avoiding their disposal and enabling their separation for recovery, including their reuse and recycling.

Date: Brussels, 18 January 1999

References:

[1] Rieß et al. (1998): Analysis of flame retarded polymers and recycling materials. Organohalogen Compounds, Vol. 35, 443-446.

[2] Hauptverband der gewerblichen Berufsgenossenschaften (1997): Dioxine am Arbeitsplatz.

[3] van Eldik et al. (1997): Bewertung und Optimierung von Verfahren zum Recycling flammgeschützter Kunststoffe aus der Elektrotechnik. BAYFORREST-Report 7, p.65-74.

[4] CYCLE (1998): Sekundärrohstoffe aus IT-Produkten. Umweltmagazin, 3/98, p73.

[5] Blue Angel Criteria Document for copiers RAL-UZ 62 p.6 §3.2.4.

[6] APME (1997): Feedstock recycling of electical & electronic plastics waste.

[7] Christill et al. (1996): Drehrohrpyrolyse als Verwertungsverfahren für Elektro-Altgeräte aus dem Investitionsgüterbereich, VDI Berichte, 1288, p321-333.

[8] APME (1997): Electrical & electronic plastics waste co-combustion.

[9] OECD (1998): Report on incineration of products containing brominated flame retardants.

[10] UBA (1989): Sachstand PBDD/PBDF.

[11] European Commission (1995): Techno-economic studies on the reduction of industrial emissions to air, discharges to water, and the generation of waste from the production, processing and destruction (by incineration) of brominated flame retardants.