The Environmental Protection Agency (EPA) is seeking public comments on a revised draft risk evaluation for the substance Cyclic Aliphatic Bromide Cluster — also known as HBDC — which states that the chemical poses unreasonable risk under certain conditions.
This reverses a previous evaluation, which found that the chemical substance presented no unreasonable risk of injury to humans or the environment.
What is HBCD, and how is it used?
HBCD is a flame retardant chemical used most often in foam building insulation, as well as textiles and electrical appliances.
Despite its continued commercial use, domestic manufacturing of the chemical substance ceased in 2017.
According to the EPA’s revised draft of the chemical assessment, several occupational uses of the chemical present unreasonable risk, including:
- Importing
- Processing by incorporation into a formulation, mixture, or reaction products
- Processing by incorporation into articles
- Recycling of extruded/expanded polystyrene foam, resin, and panels containing HBCD
- Commercial or consumer use of HBCD in construction or building materials
- Disposal in construction and demolition waste
HBCD is one of the first chemicals to be reassessed under the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which requires the EPA to provide risk-based chemical assessments to increase public transparency of chemical information.
The EPA’s initial evaluation found that HBCD presented no unreasonable risk to the general population, workers, or the environment.
However, in a 2010 “action plan” the EPA expressed that it was “highly toxic to aquatic organisms,” and that it presented “potential human health concerns based on animal test results indicating potential reproductive, developmental, and neurological effects.”
Of the revision to the draft, the agency says it “supersedes the condition of use-specific no unreasonable risk determinations in the September 2020 HBCD risk evaluation (and withdraw the associated order) and makes a revised determination of unreasonable risk for HBCD as a whole chemical substance.”
The EPA is now using this “whole substance” approach when determining unreasonable risk rather than basing those determinations on specific conditions of use.
They’re also assessing whether or not to continue assuming that personal protective equipment is being provided and properly worn when making risk determinations.
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