Discussion paper welcomes the ECHA FR Strategy grouping approach and proposes additional criteria. The paper, by three environmental scientists, suggests that flame retardant use should target applications where FRs bring significant fire safety benefits and where alternative routes to fire safety are not available, citing as examples upholstered furniture as a main cause of fire deaths and injuries, and polymers in electronics which are subject to heat. The paper welcomes the ECHA Flame Retardants Strategy (March 2023, see pinfa Newsletter n°147) and its “grouping” approach as susceptible to prevent regrettable substitution, when one banned individual FR is replaced by a similar one. The paper suggests however that the grouping approach should be extended to also take into account complex toxicity effects (neurotoxicity, endocrine disruption), mobility, impacts on recycling and waste/emissions. The paper notes that difficulties to identify specific brominated FRs in WEEE already lead to exclude from recycling all plastics with total bromine > 2000 mg/kg (CENELEC 50625-3-1).
“The European Regulatory Strategy for flame retardants – The right direction but still a risk of getting lost”, J. de Boer, S. Harrad, M. Sharkey, Chemosphere 347 (2024) 140638, https://doi.org/10.1016/j.chemosphere.2023.140638 Paper written with financial contribution from Rockwool.