Posted on 27/06/2023 in Fire Safety Regulatory 2023
UNEP reports on chemicals in plastics

Document for UN Plastics Treaty on plastics identifies certain specific flame retardants as one of ten chemical concerns.

The United Nations Environment Assembly (UNEA) Resolution 5/14 (10th May 2022) started the process to develop an “international legally binding instrument on plastic pollution, including in the marine environment” (see also update from 2nd International Negotiating Committee on this UN Plastics Treaty June 2023).

A technical report to support development of this UN ”Plastics Treaty” summarises relevant knowledge and proposes policy actions. Flame retardants are identified as one of ten families of chemicals of concern in plastics. FRs cited as problematic are: halogenated FRs (in particular PBDEs, HBCDD, HBB, TBBPA, Dechlorane Plus, BTBPE, DBDPE, HBBz, SCCPs, MCCPs) and organophosphorus FRs (in particular TDCPP, TBOEP, TPhP). The report also suggests that there are “concerns about the efficacy of flame retardants because their use in some applications does not provide additional protection” and that brominated FRs “can increase the toxicity of smoke due to smouldering, which releases more carbon monoxide (CO)”. Policy action proposals include restricting hazardous chemicals to specific applications (“essential use”), avoiding regrettable substitution, improving plastics chain transparency, updating chemical testing to address combinations of chemicals and bioaccumulation in the environment and improvement of waste management policies.

A second report addresses reducing plastics pollution and improving circularity and proposes “three shifts: Reuse, Recycle, Reorient and Diversify”. Flame retardants are indicated as one of three chemical types with high “scientific consensus that harm is caused by plastic-related exposure” (fig.3, page 5). This is taken from a publication from the Minderoo Foundation, an NGO whose objectives are to “eliminate the negative impacts of plastic on people and the planet” and is based on the NGO’s assessment of a literature review. The UNEP report also indicates economic damage estimates of plastic pollution (table 1, page 6), again taken from Minderoo. In this case, UNEP incorrectly cites more than 100 billion USD/y as damage from FRs. In fact, the Minderoo estimate for FRs is 10-100 bnUSD/y (fig.6, page 28) and covers the whole plastics life cycle (not only end-of-life plastic pollution). The UNEP report estimates that in total plastics pollution costs 300 – 1500 billion USD/year. It estimates that waste management and circularity policies could reduce virgin plastic use by over 50%, increase plastics recycling to nearly 30% and reduce environmental losses by over 80%.

The Minderoo Foundation NGO report cited by UNEP (see above), is an NGO document, authored by the NGO’s own Head of Finance and a Senior Advisor, which claims to show that societal costs of plastics pollution (environmental clean-up, impacts on ecosystems, human health and life expectancy) are more than 100 billion US/year. This is somewhat confusing as the document also suggests that the health impacts of micro/nano plastic particles, bisphenols and phthalates in plastics alone are each > 100 bnUSD/y (Annex 1, table 1, page 24). The “damage cost” of FRs (incorrectly) cited by UNEP seems to come principally from Annex 1, table 1, page 24, of the Minderoo report which suggests societal health costs of FRs as “low” except for endocrine & immune and development impacts (both medium, estimates of 47 and 26 bn USD/y respectively). This Minderoo document also models (page 38) US industry expected litigation liabilities as “moderate probability” 10 bnUSD for brominated FRs and “low probability” 4 bnUSD for phosphorus FRs.

“Chemicals in plastics. A technical report”, 144 pages, United Nationals Environment Programme (UNEP) 2023, ISBN: 978-92-807-4026-4

“Turning off the Tap. How the world can end plastic pollution and create a circular economy”, 88 pages, United Nationals Environment Programme (UNEP) 2023, ISBN: 978-92-807-4024-0

Minderoo Foundation “The price of plastic pollution. Social costs and corporate liabilities”, Merkl & Charles 2022, 48 pages plus 166 pages of three annexes.

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