The Fire Retardant Dilemma: Should Green Buildings Contain Toxic Fire Retardant Chemicals? Arlene Blum, Green Science Policy Institute Polystyrene, polyisocyanurate, and polyurethane are highly energy efficient insulation materials whose use in green buildings is increasing. However, due to their flammability, fire retardant chemicals (FRs) must be added to meet building codes. Many of the FRs currently in use are halogenated organic chemicals, meaning that they contain chlorine or bromine bonded to carbon. Most of these FRs have not been adequately evaluated for their impact on human health and the environment. When tested, many are found to be persistent, bioaccumulative, and/or toxic. Being persistent means that they do not break down into safer chemicals in the environment over months or years. Being bioaccumulative means that they accumulate in plants and animals, becoming more concentrated as they move up the food chain. Additionally, some of these FRs are carcinogens, mutagens, and/or reproductive, neurological, thyroid, and/or developmental toxicants. The impacts of exposure to fire retardant chemicals upon workers, human and animal health, building occupants, wildlife and the global environment should be considered when selecting insulation materials. All polystyrene foam insulation used in building insulation (both XPS, such as Styrofoam, and EPS) is treated with hexabromocyclododecane, (HBCD), a persistent, bioaccumulating, and toxic fire retardant. This chemical was recently nominated for the first EU list of sixteen "Substances of Very High Concern" and will likely be banned in Europe. It has been widely detected in household dust, sewage sludge, breast milk and body fluids as well as wildlife and the global environment. HBCD is also used with fabrics and plastic; however 85% is used with polystyrene insulation, which is likely the primary source of the global contamination. Polyisocyanurate (polyurethane) board often contains TCPP (tris (1-chloro-2-propyl) phosphate). While its toxicity in mammals appears to be limited, the effects of long-term exposure are unknown, and it is toxic in aquatic environments. Triethyl phosphate (TEP), a non-halogenated FR used in the EU, is a safer alternative. Polyurethane boards can contain up to five percent "blowing agents", which are usually volatile hydrocarbons or halogenated hydrocarbons. Polyurethane spray foam formulations can contain both blowing agents and proprietary FRs with unknown composition and health effects. For example, Dow THERMAX(TM) Insulation board contains a maximum of ten percent of TCPP and five percent 1-Bromopropane. The MSDS states that this blowing agent can cause central nervous system effects in humans and harm to male and female reproductive organs and the liver as well as interference with reproduction and fertility and toxicity to the fetus in animal studies. The sheet also states that "normal handling and cutting are unlikely to result in exposure levels of 1-bromopropane sufficient to cause the listed effects." The impact of long term and cumulative exposures to mixtures of such chemicals upon the health of workers, inhabitants of homes, and the environment is not known. Halogenated fire retardants are becoming widespread in the environment Halogenated fire retardants (FRs) can migrate out of furniture foam, electronics, fabric and other consumer products as well as foam insulation so humans are exposed to a "cocktail" of such toxins. Levels of FRs are increasing rapidly in household dust, human breast milk, and wild animals. The chemicals are widely distributed in the outdoor environment with the highest concentrations in the Arctic and marine mammals. Certain classes of brominated fire retardants, the polybrominated diphenyl ethers, have been banned for most applications, but other brominated and chlorinated compounds have taken their place in consumer products without adequate studies to determine their health and environmental safety. How to reduce the health and environmental hazard from FRs in insulation Develop design guidelines, green building credit systems, and codes to encourage designers to: Consider the toxicity of insulation options when selecting insulation types. Consider alternate pathways to attaining needed levels of fire safety, such as designing with fire barriers or other materials to reduce flammability. Encourage research and use of alternative, non-halogenated fire retardant additives such as sodium borate and triethyl phosphate (TEP). Support governmental programs to require full health testing of all chemicals and use of safer alternatives where available. Arlene Blum is a biophysical chemist, visiting scholar at UC Berkeley's Department of Chemistry, and author of Annapurna: A Woman's Place and Breaking Trail: A Climbing Life. Blum's research contributed to the regulation of two cancer-causing flame retardants used in children's sleepwear in the 1970's. Dr. Blum was selected by the National Women's History Project as one of the 100 "Women Taking the Lead to Save Our Planet".

"All polystyrene foam insulation used in building insulation (both XPS, such as Styrofoam, and EPS) is treated with hexabromocyclododecane, (HBCD), a persistent, bioaccumulating, and toxic fire retardant. This chemical was recently nominated for the first EU list of sixteen "Substances of Very High Concern" and will likely be banned in Europe. It has been widely detected in household dust, sewage sludge, breast milk and body fluids as well as wildlife and the global environment."

Why do you think HBCD is "likely to be banned in Europe?" What is it about this substance that is toxic, and what is the effect of its alleged toxicity?

“HBCDD is highly toxic to aquatic organisms, and according to laboratory tests with mammals,
it affects the functioning of the thyroid system and liver. There are also indications of effects on
fertility and developmental neurotoxicity of mammals. HBCDD is according to the available
data also transferred from mother to child during pregnancy via blood and after delivery via
breast feeding.
The monitoring data available from remote areas provide inevitable evidence that HBCDD is
transported over long distances in the environment. HBCDD has been detected in a number of
samples in the abiotic environment, biota and/or humans of the Arctic, Europe, Asia and North
and South America regions. Furthermore, HBCDD is degraded slowly in the aquatic
environment and soil. It has a great potential for bioaccumulation and in addition there is
evidence of its biomagnification. The highest concentrations of HBCDD are detected in marine
top-predators such as porpoise and seals showing that HBCDD biomagnifies up the food chain.
HBCDD is used as a flame retardant in a wide variety of articles in all parts of the world. The
releases, as quantified in Europe, are at present entering the environment mainly from a large
number of industrial point sources. However, HBCDD is also released from articles during and
at the end of their service-life. In addition, the volume of HBCDD constantly increases in the
built technosphere (articles in use), and future releases are therefore unpredictable. As HBCDD
can move far from its sources, single countries or groups of countries alone cannot abate the
pollution caused by it. Due to the harmful POP properties and risks related to its widespread
production and use, international action is warranted to control this pollution.”

Ref: http://chm.pops.int/Convention/POPsReviewCommittee/Chemicals/tabid/243/language/en-US/Default.aspx

So if I read you correctly, no one really knows what bad it does, just that it's out there so it must be bad? What do you mean by "indications" it effects fertility and developmental neurotixicity? Can you tell me in your own words? At what levels does this toxicity become apparent?

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POPs are Persistent Organic Pollutants (POPs) - organic chemical substances - that are carbon-based.
They possess a particular combination of physical and chemical properties such that, once released into the environment, they:

1. remain intact for exceptionally long periods of time (many years);

2. become widely distributed throughout the environment as a result of natural processes involving soil, water;

3. accumulate in the fatty tissue of living organisms including humans, and are found at higher concentrations at higher levels in the food chain; and

4. are toxic to both humans and wildlife.

We do know that HBCDD has been proven to be highly toxic to aquatic wildlife. In mammals it has been shown to affect the liver and thyroid (increase in size and weight) but also lead to changes in thyroid hormone levels.  It affects neurological (as measured by behavioural changes at levels of 0.9  ug/kg/day) and sex organ development and activity (inhibited egg development and swelling of uterus at similar levels) - these studies were done in rats.

In summary at this time we do not know how dangerous HBCDD is – but so far it exhibits many of the properties of known, proven POPs that have been phased out of production and usage.    POPs persistent longevity (it does not degrade in the environment) leads to bioaccumulation so that toxicity develops over time – it accumulates in the body (stored in fat cells) and is not metabolised - we call this biomagnification. Therefore although HBCDD is at low levels in ICFs it is the bioaccumulation aspect and its global spread that has scientists worried; thus the concern and necessity to put it on the watch list for further study.

Hopefully I have answered your questions. At this time, as a precaution, I would avoid repeated inhalation of the dust from ICFs – wear a mask when rasping, cutting etc.  I see no danger in handling ICFs (but I would wear gloves) and since HBCDD is not very water soluble and does not off-gas there is no problem using it in a liveable structure.

HBCDD has been put on an international watch list as a ‘possible global POP’.

POPs are Persistent Organic Pollutants (POPs) - organic chemical substances - that are carbon-based.
They possess a particular combination of physical and chemical properties such that, once released into the environment, they:

1. remain intact for exceptionally long periods of time (many years);

2. become widely distributed throughout the environment as a result of natural processes involving soil, water;

3. accumulate in the fatty tissue of living organisms including humans, and are found at higher concentrations at higher levels in the food chain; and

4. are toxic to both humans and wildlife.

We do know that HBCDD has been proven to be highly toxic to aquatic wildlife. In mammals it has been shown to affect the liver
and thyroid (increase in size and weight) but also lead to changes in thyroid hormone levels.  It affects neurological
(as measured by behavioural changes at levels of 0.9  ug/kg/day) and sex organ development and activity (inhibited egg
development and swelling of uterus at similar levels) - these studies were done in rats.

In summary at this time we do not know how dangerous HBCDD is – but so far it exhibits many of the properties of known,
proven POPs that have been phased out of production and usage.    POPs persistent longevity (it does not degrade in the
environment) leads to bioaccumulation so that toxicity develops over time – it accumulates in the body (stored in fat cells)
and is not metabolised - we call this biomagnification. Therefore although HBCDD is at low levels in ICFs it is the
bioaccumulation aspect and its global spread that has scientists worried; thus the concern and necessity to put it on
the watch list for further study.

Hopefully I have answered your questions. At this time, as a precaution, I would avoid repeated inhalation of the dust
from ICFs – wear a mask when rasping, cutting etc.  I see no danger in handling ICFs (but I would wear gloves) and since
HBCDD is not very water soluble and does not off-gas there is no problem using it in a liveable structure.

TerrJ
How about Borates. I thought some of the EPS producers use that. Is it safer?? Is it effective

Borate is for protection against insect damage whereas HBCDD is a fire retardant.

TerryJ
Sorry to mis-type on the last one.
Thanks for the answer. I have heard people claim Borate as a fire retardant additive.
It is just a pest deterrent then, no fire retardant properties?

Zinc borates act as a fire retardants in plastics, rubber products and cellulose insulation. But in polystyrene the zinc borates do not have enough fire retardant capability and that's why HBCDD is used. For example a common fire retardant formulation used in ploystyrene is ~50% HBCDD, 15% antimony oxide, 20% zinc borate and 15% hydrated alumina.

To the best of my knowledge there is no current substitiute for HBCDD available to act as a fire retardant in polystyrene. If HBCDD production and use is banned, it would be devastating to the industry.

Terry