Organic flame retardant decabromodiphenyl ethane (DBDPE) public comments summary table

Official title: Organic flame retardant decabromodiphenyl ethane (DBDPE) public comments summary table

Comments on the draft screening assessment for DBDPE to be addressed as part of the Chemicals Management Plan were submitted by:  Netchem Inc., Albemarle Corporation, and Global Automakers of Canada.

A summary of comments and responses is included below, organized by topic:

1. Information and data updates

Summarized comment Summarized response
DBDPE is most effective in reducing flammability of polymeric materials, which can be made to successfully pass certain fire safety standards.  Brominated flame retardants may be found in electronic devices, in wire and cable applications, in buildings where electrical current is present and in a variety of transportation related applications. Brominated flame retardants are used in applications such as these because lower volumes of additive brominated flame retardants are required to pass certain standards resulting in lower potential to compromise important qualities of the polymer. The Government of Canada should bear in mind these justified concerns for fire safety during evaluation of these substances. The Uses section of the SAR will be updated with the information provided and fire protection qualities of DBDPE that enable flammable materials to meet fire safety standards will be noted.    
The European Chemicals Agency (ECHA) has required DBDPE toxicity and fate studies as part of their Substance Evaluations. These studies are to be concluded by January 2019.  This information is directly relevant to questions raised in the dSAR. From an environmental aspect, outcomes from the ECHA Substance Evaluation should be used by the Government of Canada to inform decisions on any risk management measures for DBDPE. The soil and sediment transformation studies completed for ECHA were considered in the assessment. Also, study summaries on DBDPE biotransformation in soils the presence of plants; degradation in use at high temperature applications during multiple recycling cycles; possible formation of polybrominated dioxins and furans during incineration; chronic (21 day) toxicity to Daphnia magna; and bioaccumulation in fish (preliminary study, definitive study currently underway) were considered in the finalization of the assessment. Comments on the proposed risk management document will be sought, and the timeline for proposed risk management measures for DBDPE are outlined in the risk management approach. All CMP assessed substances are subject to future evaluation if new and significant information is provided that indicates a need for further consideration.

2. Methodology

Summarized comment Summarized response
It is not advisable to make direct comparisons between DBDPE and the flame retardant, Decabromodiphenyl Ether (decaBDE) because important differences in their properties affect the way these two substances react in the environment. In particular the dSAR indicated that EBP gradually debrominates in the environment based on models only. However this modelling is not confirmed by any experiments and does not lead to reliable predictions. These premature conclusions should not be used to determine risk management measures for DBDPE. In the assessment decaBDE is considered to have a high degree of chemical and physical similarities to DBDPE. Comparisons of the way decaBDE and DBDPE interact with the environment such as characteristics of degradation, bioaccumulation, and ecotoxicity are based on available scientific data and information. This supports a concern that DBDPE will break down in the environment and release harmful substances.
Caution should be used when making assumptions regarding environmental fate and possible transformation products based on read-across or computer modeling as testing does not confirm these assumptions. Testing to date does not support a concern for degradation to lower brominated congeners of DBDPE in the environment.   The DBDPE assessment conclusions are based on a weight of evidence approach that considers experimental data, modelling, and scientific data from a close analogue. The DBDPE biodegradation studies submitted to the Government of Canada by the lead registrant in Europe conclude that DBDPE biodegradation is minimal or absent. However these studies have several limitations, such as the study time period being much shorter than the expected half-life of DBDPE in soil and sediment.

3. Alternatives

Summarized comment Summarized response
Qualifying a replacement substance to produce a limited run of parts for what may amount to a very small number of products to be sold in Canadian is not justifiable. Any RM controls for DBDPE or for manufactured items containing DBDPE, should recognize the typical production cycles for new (5-8 years) and legacy (12-15 years) replacement parts. Additionally, likely substitutes for DBDPE should be considered when developing RM controls, and whether these substitutes will become subject to control measures in the future.   Risk management tools are developed and implemented based on a number of environmental, health, economic and social considerations. Socio-economic factors are considered, such as the time and cost to industry to make the transition to alternative substances and/or processes and technologies. When necessary, mechanisms such as the Identification of Risk Assessment Priorities process are applied by the Government of Canada to monitor new information on substances like DBDPE and the potential for substitution. The Government of Canada is also exploring ways to advance responsible replacement of chemicals of concern, including ways to apply informed substitution to support chemicals management (Combined government discussion paper and science committee report on informed substitution. Publication date: 2018-08-28).

4. Risk management

Summarized comment Summarized response
RM controls for DBDPE that apply equally to all Canadian stakeholders should be enacted as soon as possible. Delays in implementing risk management actions such as adding DBDPE to the DSL encourages a monopoly.     When a substance is added to CEPA’s Schedule1, the Government of Canada may propose a variety of RM instruments. The Government of Canada is considering amendment of the Prohibition of Certain Toxic Substances Regulations, 2012, to include DBDPE and products containing this substance. These proposed regulations would apply to all stakeholders in Canada.
Ministerial Conditions for DBDPE should be rescinded concurrently with implementation of new RM controls for DBDPE.  Upon coming into force of the new regulation, the existing Ministerial Conditions for DBDPE would be rescinded.
The development and implementation of RM controls for DBPDE should recognize and incorporate existing voluntary RM measures that have been adopted by industry, namely Responsible Care and VECAP. To identify the best suited RM tools for a given substance, the GOC follows a consistent and systematic approach. This approach takes into consideration, a number of factors in the identification, development and implementation of RM controls. The Government of Canada intends to consult extensively with all affected stakeholders when developing risk management measures.
Report a problem or mistake on this page
Please select all that apply:

Thank you for your help!

You will not receive a reply. For enquiries, contact us.

Date modified: