San Antonio Statement on Brominated Flame Retardants

On October 28, 2010, the San Antonio Statement on Brominated and Chlorinated Flame Retardants was published on-line by Environmental Health Perspectives, see http://www.ehponline.org/article/info:doi/10.1289/ehp.1003089. The Statement appeared in print in December 2010 in Environmental Health Perspectives.

San Antonio Statement on Brominated and Chlorinated Flame Retardants

Joseph DiGangi,¹ Arlene Blum,^2,3 Åke Bergman,⁴ Cynthia A. de Wit,⁵ Donald Lucas,⁶ David Mortimer,⁷ Arnold Schecter,⁸ Martin Scheringer,⁹ Susan D. Shaw,¹⁰ and Thomas F. Webster¹¹

1 International POPs Elimination Network, Berkeley, California, USA;
2 Department of Chemistry, University of California, Berkeley, California, USA;
3 Green Science Policy Institute, Berkeley, California, USA;
4 Department of Materials and Environmental Chemistry, and
5 Department of Applied Environmental Science, Stockholm University, Stockholm, Sweden;
6 Lawrence Berkeley National Laboratory, Berkeley, California, USA ;
7 Food Standards Agency, London, United Kingdom;
8 University of Texas School of Public Health, Dallas, Texas, USA;
9 Institute for Chemical and Bioengineering, ETH Zürich, Zürich, Switzerland;
10 Marine Environmental Research Institute, Center for Marine Studies, Blue Hill, Maine, USA;
11 Department of Environmental Health, Boston University School of Public Health, Boston, Massachusetts, USA

The statement is signed by the individual scientists and other professionals listed separately below. Please note that the views expressed are those of the authors and signatories; institutional affiliations are provided for identification purposes only. Abbreviations and an Annotated Statement are available as Supplemental Material (doi:10.1289/ehp.1003089).

We, scientists from a variety of disciplines, declare the following:

2. Many commonly used brominated and chlorinated flame retardants can undergo long-range environmental transport.

3. Many brominated and chlorinated flame retardants appear to be persistent and bioaccumulative, resulting in food chain contamination, including human milk.

4. Many brominated and chlorinated flame retardants lack adequate toxicity information, but the available data raises concerns.

5. Many different types of brominated and chlorinated flame retardants have been incorporated into products even though comprehensive toxicological information is lacking.

6. Brominated and chlorinated flame retardants present in a variety of products are released to the indoor and outdoor environments.

9. Brominated and chlorinated flame retardants can increase fire toxicity, but their overall benefit in improving fire safety has not been proven.

10. When brominated and chlorinated flame retardants burn, highly toxic dioxins and furans are formed.
Therefore, these data support the following:

11. Brominated and chlorinated flame retardants as classes of substances are a concern for persistence, bioaccumulation, longrange transport, and toxicity.

13. Consumers can play a role in the adoption of alternatives to harmful flame retardants if they are made aware of the presence of the substances, for example, through product labeling.

16. When seeking exemptions for certain applications of flame retardants, the party requesting the exemption should supply some information indicating why the exemption is technically or scientifically necessary and why potential alternatives are not technically or scientifically viable; a description of potential alternative processes, products, materials, or systems that eliminate the need for the chemical; and a list of sources researched.

17. Wastes containing flame retardants with persistent organic pollutant (POP) characteristics, including products and articles, should be disposed of in such a way that the POP content is destroyed or irreversibly transformed so that they do not exhibit the characteristics of POPs.

Signatories:
Sam Adu-Kumi, M.S., Deputy Director, Environmental Protection Agency, Accra, Ghana
Björn Albinson, Fire Protection Engineer (retired), Karlstad, Sweden
Henrik Alm, M.S., Doctoral Student, Pharmaceutical, Biosciences, Division of Toxicology, Uppsala University, Uppsala, Sweden
Misha Askren, M.D., F.A.A.F.P., Physician, Southern California Permanente Medical Group, Pasadena, CA, USA
Ralph Baker, M.S., Ph.D., Chief Scientist, TerraTherm Inc., Fitchburg, MA, USA
John Balmes, M.D., Professor of Medicine, University of California, San Francisco, San Francisco, CA, USA, and Professor of Environmental Health Sciences, University of California, Berkeley, Berkeley, CA, USA
Scott Bartell, Ph.D., Assistant Professor, University of California, Irvine, Irvine, CA, USA
Georg Becher, Ph.D., Department Director and Professor, Analytical Chemistry, Norwegian Institute of Public Health, Oslo, Norway
David C. Bellinger, Ph.D., Professor, Harvard Medical School and Harvard School of Public Health, Boston, MA, USA
Stephen Bent, M.D., Associate Professor of Medicine, Psychiatry, Epidemiology & Biostatistics, University of California, San Francisco, San Francisco, CA, USA
Åke Bergman, Ph.D., Professor, Environmental Chemistry, Stockholm University, Stockholm, Sweden, and Board Member, International Panel on Chemical Pollution, Zürich, Switzerland
Anders Bignert, Ph.D., Professor, Contaminant Research, Swedish Museum of Natural History, Stockholm, Sweden
Justina Björklund, M.S., Graduate Student, Applied Environmental Science, Stockholm University, Stockholm, Sweden
Arlene Blum, Ph.D., Visiting Scholar, Chemistry, University of California, Berkeley, Berkeley, CA, USA
Christian Bogdal, Ph.D., Researcher, Swiss Federal Institute of Technology, Zürich, Switzerland
Phil Brown, Ph.D., Professor, Sociology and Environmental Studies, Brown University, Providence, RI, USA
David Camann, M.S., Staff Scientist, Southwest Research Institute, San Antonio, TX, USA
Carmela Centeno, M.S., Ph.D., Industrial Development Officer, United Nations Industrial Development Organization, Vienna, Austria
Ibrahim Chahoud, Ph.D., Professor of Reproductive Toxicology, Institute of Clinical Pharmacology and Toxicology, Charité-Universitätsmedizin Berlin, Berlin, Germany
Eliza Chin, M.D., M.P.H., President, American Medical Women’s Association, Philadelphia, PA, USA
Brock Chittim, M.S., General Manager, Wellington Laboratories, Guelph, Ontario, Canada
Carsten Christophersen, Ph.D., Associate Professor, Chemistry, University of Copenhagen, Copenhagen, Denmark
Bradley Clarke, PhD, Research Fellow, Imperial College, London, United Kingdom
Theo Colborn, Ph.D., Professor Emeritus, University of Florida, Gainesville, Florida, USA
Kathleen Collins, Ph.D., Professor, Molecular and Cell Biology, University of California, Berkeley, Berkeley, CA, USA
Terrence Collins, Ph.D., Teresa Heinz Professor of Green Chemistry and Director of the Institute for Green Science, Carnegie Mellon University, Pittsburgh, PA, USA
Adrian Covaci, Ph.D., Professor, University of Antwerp, Antwerp, Belgium
Craig Criddle, Ph.D., Professor, Civil and Environmental Engineering, Stanford University, Palo
Alto, CA, USA
Margarita Curras-Collazo, Ph.D., Associate Professor, Cell Biology and Neuroscience, University of California, Riverside, Riverside, CA, USA
Kyle D’Silva, Ph.D.,Product Manager, Thermo Fisher Scientific, Dreieich, Germany
Devra Davis, M.A., Ph.D., M.P.H, Visiting Professor, Georgetown University, Washington, DC, USA, and Founder, Environmental Health Trust, Teton Village, WY, USA
Joao De Assuncao, M.S., Ph.D., Professor and Department Head, Environmental Health, University of Sao Paulo School of Public Health, Sao Paulo, Brazil
Cynthia A. de Wit, Ph.D., Professor, Applied Environmental Science, Stockholm University, Stockholm, Sweden
Mike Denison, Ph.D., Professor of Environmental Toxicology, University of California, Davis, Davis, CA, USA
Miriam Diamond, Ph.D., Professor, Geography, University of Toronto, Toronto, Ontario, Canada
Joseph DiGangi, Ph.D., Senior Scientist and Technical Advisor, International POPs Elimination Network, Berkeley, CA, USA
Alin Dirtu, Ph.D., Researcher, University of Antwerp, Antwerp, Belgium
Michelle Douskey, Ph.D., Lecturer, Chemistry, University of California, Berkeley, Berkley, CA, USA
Anne Ehrlich, Ph.D., Senior Research Scientist, Biology, Stanford University, Palo Alto, CA, USA
David Epel, Ph.D., Jane & Marshall Steel Jr. Professor Emeritus in Marine Sciences, Cell and Developmental Biology, Stanford University, Palo Alto, CA, USA
Brenda Eskenazi, M.A., Ph.D., Jennifer and Brian Maxwell Professor of Maternal Health and Epidemiology, University of California, Berkeley, Berkeley, CA, USA
Tim Evans, Ph.D., Cancer Registration Information Manager, West Midlands Cancer Intelligence Unit, Birmingham, United Kingdom
Peter Fantke, Ph.D., Research Associate, Institute of Energy Economics and the Rational Use of Energy, University of Stuttgart, Stuttgart, Germany
Joseph Gardella Jr., Ph.D., Professor and Larkin Chair of Chemistry, University at Buffalo, State University of New York, Buffalo, NY, USA
Philip Germansderfer, D.Sc., International Marketing Sales, Fluid Managment Systems, Watertown, MA, USA
Gillian Gibson, M.Sc., Environmental Scientist, Gibson Consulting and Training, Cheshire, United Kingdom
Andreas Gies, Ph.D., Director and Professor, Department for Environmental Hygiene, Federal Environment Agency, Berlin, Germany
Robert Gould, M.D., President, San Francisco Bay Area Chapter of Physicians for Social Responsibility, Berkeley, CA, USA
Konstanze Grote, Ph.D., Institute of Clinical Pharmacology and Toxicology, Charité University Medical School Berlin, Berlin, Germany
Rui Guo, Ministry of Environment, Toronto, Ontario, Canada
Jana Hajslova, Ph.D., Head of Department of Food Analysis, Institute of Chemical Technology,
Prague, Czech Republic
Ralph Hall, Ph.D., Assistant Professor, Virginia Polytechnic Institute, Blacksburg, VA, USA
Bruce Hammock, Ph.D., Professor, Entomology, University of California, Davis, Davis, CA, USA
Tran Thi Tuyet Hanh, M.P.H., Lecturer in Environmental Health, Hanoi School of Public Health, Hanoi, Vietnam
Kim Harley, Ph.D., Associate Director, Center for Children’s Environmental Health Research, University of California, Berkeley, Berkeley, CA, USA
Stuart Harrad, Ph.D., Professor, Environmental Chemistry, University of Birmingham, Birmingham, United Kingdom
Robert Harrison, M.D., M.P.H., Clinical Professor, Occupational and Environmental Medicine, University of California, San Francisco, San Francisco, CA, USA
Line Smastuen Haug, Doctoral Student, Norwegian Institute of Public Health, Oslo, Norway
Yasuhiro Hirai, Ph.D., Associate Professor, Environment Preservation Engineering, Kyoto University, Kyoto, Japan
Ivan Holoubek, Ph.D., Director and Professor, Masaryk University, Research Centre for Toxic Compounds in the Environment, Brno, Czech Republic, and Board Member, International Panel on Chemical Pollution, Zürich, Switzerland
Ron Hoogenboom, Ph.D., Toxicologist, RIKILT Institute of Food Safety, Wageningen University and Research Center, Wageningen, the Netherlands
David Hope, CEO, Pacific Rim Laboratories, Surrey, British Columbia, Canada
William J. Hirzy, Ph.D., Chemist in Residence, American University, Washington, DC, USA
Heinrich Huehnerfuss, Ph.D., Professor, University of Hamburg, Hamburg, Germany
Alastair Iles, Ph.D., Assistant Professor, Environmental Science, Policy, and Management, University of California, Berkeley, Berkeley, CA, USA
Tomohiko Isobe, Ph.D., Senior Research Fellow, Ehime University, Matsuyama City, Japan
Kristina Jakobsson, Ph.D., Associate Professor, Occupational and Environmental Medicine, Lund University, Lund, Sweden
Sarah Janssen, M.D., Ph.D., M.P.H., Senior Scientist, Natural Resources Defense Council, New York City, NY, USA
Niklas Johansson, Scientist, Karolinska Institute, Stockholm, Sweden
Catherine Karr, M.D., Ph.D., M.S., Assistant Professor and Director, Pediatric Environmental Health Specialty Unit, Pediatrics, University of Washington, Seattle, WA, USA
Donald Kennedy, Ph.D., Bing Professor of Environmental Science, Emeritus, Stanford University Palo Alto, CA, USA, and Editor Emeritus, Science
Sergio Kuriyama, Ph.D., Guest Scientist, Laboratory of Environmental Toxicology, National School of Public Health, Fiocruz, Brazil
C.L. Peck, Class of 1906 Professor of Engineering and Director, Center for Sustainable Development and Global Competitiveness, Stanford University, Palo Alto, CA, USA
Pamela Lein, Ph.D., Professor, Molecular Biosciences, University of California, Davis, Davis, CA, USA
Juliana Leonel, Ph.D., Postdoctoral Researcher, Universidade Federal do Rio Grande, Rio Grande, Brazil
Mark Levine, Ph.D., Leader, China Energy Group, and Former Director, Environmental Energy Technologies Division, Lawrence Berkeley National Laboratory, Berkeley, CA, USA
Donald Lucas, Ph.D., Deputy Director, Environment, Health, and Safety Division, Lawrence Berkeley National Laboratory, Berkeley, CA, USA
Richard Luthy, Ph.D., Silas H. Palmer Professor, Civil and Environmental Engineering, Stanford University, Palo Alto, CA, USA
Karl Mair, D.Sc., Senior Scientist, Eco Research SRL, Bolzano, Italy
Govindan Malarvannan, Ph.D., Research Fellow, Center for Marine Environmental Studies, Ehime University, Matsuyama City, Japan
John Meeker, M.S., Sc.D., Assistant Professor, Environmental Health Sciences, University of Michigan School of Public Health, Ann Arbor, MI, USA
Richard Meigs, P.E., Senior Principal Engineer, RJR Engineering, Ventura, CA, USA
Mark Miller M.D., M.P.H., Director, Pediatric Environmental Health Specialty Unit, and Assistant Clinical Professor, Pediatrics, University of California, San Francisco, San Francisco, CA, USA
Paolo Mocarelli, M.D., Professor and Director, Department of Clinical Pathology, University of Milano Bicocca, Milano, Italy
Rachel Morello-Frosch, M.P.H., Ph.D., Associate Professor, Department of Environmental Science Policy and Management, University of California, Berkeley, Berkeley, CA, USA
Jochen Mueller, Ph.D., Professor, University of Queensland, Brisbane, Australia
Tom Muir, M.S., Retired, Environment Canada, Québec City, Quebec, Canada
Martin Mulvihill, Ph.D., Associate Director for Education and Outreach, Center for Green Chemistry, University of California, Berkeley, Berkeley, CA, USA
Anbu Munasamy, M.S., Ph.D., National Institute for Interdisciplinary Science and Technology–Council of Scientific and Industrial Research, Thiruvananthapuran, Kerala, India
Richard Murphy, Ph.D., Director of Science and Education, Jean-Michel Cousteau Ocean Futures Society, Santa Barbara, CA, USA
Takeshi Nakano, Ph.D., Research Professor, Center for Advanced Science and Innovation, Osaka University, Osaka, Japan
Shoji Nakayama, M.D., Ph.D., National Research Council Associate, U.S. Environmental Protection Agency, Washington, DC, USA
Amgalan Natsagdorj, Ph.D., Department Head, Environmental Chemistry, National University of Mongolia, Ulaanbaatar, Mongolia
William Nazaroff, Ph.D., Daniel Tellep Distinguished Professor and Vice Chair for Academic Affairs, Civil and Environmental Engineering, University of California, Berkeley, Berkeley, CA, USA
John Neuberger, Dr.Ph., M.P.H., M.B.A., Professor, Preventative Medicine and Public Health, University of Kansas School of Medicine, Kansas City, KS, USA
Jessica Norrgran, Doctoral Student, Stockholm University, Stockholm, Sweden
Fardin Oliaei, Ph.D., M.P.A., Consultant, Cambridge EnviroScience Consulting, LLC, Cambridge, MA, USA
Kees Olie, Ph.D., Associate Professor, University of Amsterdam, Amsterdam, the Netherlands
Olaf Paepke, Ph.D., Eurofins, Hamburg, Germany
Victoria Persky, M.D., Professor, University of Illinois at Chicago School of Public Health, Chicago, IL, USA
Agneta Rannug, Ph.D., Professor, Institute of Environmental Medicine, Karolinska Institute, Stockholm, Sweden
Ulf Rannug, Ph.D., Professor, Genetics, Microbiology and Toxicology, Stockholm University, Stockholm, Sweden
Eric Reiner, Ph.D., Senior Research Scientist, Ontario Ministry of Environment, Toronto, Ontario, Canada
Martin Reinhard, Ph.D., Professor, Civil and Environmental Engineering, Stanford University, Palo Alto, CA, USA
Karen Rice, M.D., Physician, Obstetrics and Gynecology, Walnut Creek Kaiser, Walnut Creek, CA, USA
Robert H. Rice, Ph.D., Professor of Environmental Toxicology, University of California, Davis, Davis, CA, USA
Anthony Roach, Ph.D., Senior Research Scientist, Government of New South Wales, Sydney, Australia
David Roberts, Ph.D., William R. Kenan, Jr. Professor of Astrophysics, Brandeis University, Waltham, MA, USA
Mary Roberts, Ph.D., Professor, Chemistry, Boston College, Boston, MA, USA
Christina Rudén, Ph.D., Professor, Philosophy and the History of Technology, Royal Institute of Technology, Stockholm, Sweden
Cindy Lee Russell, M.D., Vice President of Community Health, Santa Clara County Medical Association, San Jose, CA, USA
Kenneth Sauer, Ph.D., Professor Emeritus of Chemistry, University of California, Berkeley, Berkeley, CA, USA
Arnold Schecter, M.D., M.P.H., Professor, Environmental and Occupational Health Sciences, University of Texas School of Public Health, Dallas, TX, USA
Martin Scheringer, D.Sc., Senior Scientist, ETH Zürich, Zürich, Switzerland, and Board Member, International Panel on Chemical Pollution, Zürich, Switzerland
Ted Schettler, M.D., M.P.H., Science Director, Science and Environmental Health Network, Ames, IA, USA
Karl-Werner Schramm, Ph.D., Professor and Chair, German Research Center for Environmental Health, Neuherberg, Germany
Megan Schwarzman, M.D., M.P.H., Research Scientist, University of California, Berkeley, Berkeley, CA, USA, and Associate Physician, University of California, San Francisco, San Francisco, CA, USA
Susan D. Shaw, Dr.PH., Director, Marine Environmental Research Institute, Blue Hill, ME, USA
Heather Stapleton, Ph.D., Assistant Professor, Nicholas School of the Environment, Duke University, Durham, NC, USA
Kristina Sundqvist, Ph.D., Project Assistant, Chemistry, Umeå University, Umeå, Sweden
Patrice Sutton, M.P.H., Research Scientist, Program on Reproductive Health and the Environment, University of California, San Francisco, San Francisco, CA, USA
Shanna Swan, Ph.D., Professor and Associate Chair for Research, Obstetrics and Gynecology, and Director, Center for Reproductive Epidemiology, University of Rochester School of Medicine, Rochester, NY, USA
Takumi Takasuga, Ph.D., Director, Shimadzu Techno-Research Inc., Kyoto, Japan
Chris Talsness, D.V.M., Working Group Leader in Reproductive Toxicology, Charite Universitätsmedizin Berlin, Berlin, Germany
Cathrine Thomsen, Ph.D., Senior Scientist, Norwegian Institute of Public Health, Oslo, Norway
Gregg Tomy, Ph.D., Adjunct Assistant Professor, Fisheries and Oceans, University of Manitoba, Winnipeg, Manitoba, Canada
Joao Paulo Machado Torres, Sc.D., Associate Professor, Universidade Federal do Rio de Janeiro, Rio de Janeiro, Brazil
James Trosko, Ph.D., Professor, Pediatrics and Human Development, Center for Integrative Toxicology, Michigan State University, East Lansing, MI, USA
Mary Turyk, Ph.D., M.P.H., Research Assistant Professor, University of Illinois at Chicago, Chicago, IL, USA
Gunther Umlauf, Ph.D., European Commission Joint Research Center, Ispra, Italy
Bryan Vining, Ph.D., Analytical Perspectives, Wilmington, NC, USA
Qiuquan Wang, Ph.D., Professor of Chemistry, Xiamen University, Xiamen, China
Yawei Wang, Ph.D., Research Center for Eco Environmental Science, Beijing, China
Julie Shu-Li Wang, Ph.D., Investigator, National Health Research Institute, Taipei, Taiwan
Rosemary Waring, Ph.D., Honorary Reader, Human Toxicology, University of Birmingham, Birmingham, United Kingdom
Thomas F. Webster, D.Sc., Associate Professor and Associate Chair, Department of Environmental Health, Boston University School of Public ealth, Boston, MA, USA
Charles Weschler, Ph.D., Adjunct Professor, UMDNJ–Robert Wood Johnson Medical School and Rutgers University, New Brunswick, NJ, USA, and Continuing Visiting Professor, International Centre for Indoor Environment and Energy, Technical University of Denmark, Lyngby, Denmark
Stevie Wilding, Chemist, U.S. Environmental Protection Agency, Region 3, Philadelphia, PA, USA
Duane Wilding, M.E., Senior Engineer, Maryland Environmental Service, Millersville, MD, USA
Gayle Windham, Ph.D., Researcher, Breast Cancer and the Environment Research Centers, Research Triangle Park, NC, USA
Tracey Woodruff, Ph.D., M.P.H., Associate Professor and Director, Program on Reproductive Health and the Environment, University of California, San Francisco, San Francisco, CA, USA
Jae-Ho Yang, M.D., M.P.H., Professor, Catholic University of Daegu, Gyeongsan, Korea
Tom Young, M.P.P., Ph.D., Professor, Civil & Environmental Engineering, University of California, Davis, Davis, CA, USA
Bin Zhao, Doctoral Student, Environmental Toxicology, University of California, Davis, Davis, CA, USA
R. Thomas Zoeller, M.A., Ph.D., Professor, Biology Department, University of Massachusetts, Amherst, Amherst, MA, USA
Ami Zota, Sc.D., Postdoctoral Scholar, Program on Reproductive Health and the
Environment, University of California, San Francisco, Oakland, CA, USA

SAS Post Publication Signatory List:

Rebecca Gasior Altman, Ph.D., Lecturer, Community Health Program, Tufts University, Medford, Oregon, USA
Cort Anastasio, Ph.D., Professor Land, Air & Water Resources University of California, Davis, California, USA
Lillemor Asplund, Ph.D., Lecturer, Materials and Environmental Chemistry, Stockholm University, Stockholm, Sweden
Peter Behnisch, Ph.D., Director, BioDetection Systems BV (BDS), The Netherlands
Susanne Bejerot, M.D., Assistant professor, Karolinska Institute, Department of Clinical Neuroscience, St Göran Hospital, Stockholm, Sweden
James Bill, Master of Architecture, MIT, Partner and licensed architect, Zero Impact Architecture (ZIA), San Anselmo, California, USA
Michal Bittner, Ph.D., Senior Scientist, Research Centre for Toxic Compounds in the Environment, Masaryk University, Brno, Czech Republic
Bruce Blumberg, Ph.D., Professor of Developmental and Cell Biology, University of California, Irvine, CA, USA
Carl-Gustaf Bornehag, Ph.D., Professor of Public Health Sciences, Department of Health and Environment, Karlstad University, Karlstad, Sweden
Lindsay Bramwell, MSc, Research Associate, Institute of Health and Society, Newcastle University, Newcastle, UK
Finn Bro-Rasmussen, Professor Emeritus, Ecology & Environmental Science (DTU), former Chair/member of EU/CSTE, Scientific Committee Toxicology & Ecotoxicology, President, SECOTOX, Holte, Denmark
Anna Christiansson, Ph.D., Environmental Chemistry, Chemical Advisor, Stockholm University, Stockholm, Sweden
Francisco Costa, Ph.D., Environmental Scientist, Environmental Agency, Cathedral City, California, USA
Per Ola Darnerud, Associate Professor, Senior Toxicologist, Research and Development Department, National Food Administration, Uppsala, Sweden
Merete Eggesbo, MD, Ph. D., Senior Researcher, Department of Genes and Environment, Norwegian Institute of Public Health, Oslo, Norway
Sune Eriksson, Ph.D., Consultant, Er DevCo Consultants AB, Källby, Sweden
Ann Gardner, MD, Ph.D., Karolinska Institute, Department of Clinical Neuroscience, Stockholm, Sweden
Stephen Gardner, DVM, Medical Director, Albany Animal Hospital, Albany, California, USA
Chris A. Geiger, Ph.D., Green Purchasing Program Manager, City Toxics Reduction Program, San Francisco Department of the Environment, San Francisco, CA, USA
Adam Grochowalski, Ph.D., Head of Laboratory for Trace Organic Analyses, Chemical Engineering and Technology, Krakow University of Technology, Krakow, Poland
Arno Gutleb, Dr., Project Leader, Environment and Agrobiotechnologies, Centre de Recherche Public – Gabriel Lippmann, Belvaux, Luxembourg
Irva Hertz-Picciotto, Ph.D., Professor, Public Health Sciences, University of California at Davis, Davis, California, USA
Ch-Ying Hsieh, Ph.D., Assistant Professor, Dept. of Environmental Science and Engineering, National Pingtung University of Science and Technology, Pingtung, Taiwan
Jill Johnston, MSPH, Organizing Coordinator, Southwest Workers Union, San Antonio, Texas, USA
Maria Jönsson, Ph.D., Assistant Professor, Environmental Toxicology, Uppsala University, Uppsala, Sweden
Hronn Jorundsdottir, Ph.D., Project Manager, Food Safety and Environment, Matis, Reykjavik, Iceland
Bonnie J. Kaplan, Ph.D., Professor, Departments of Paediatrics and Community Health Sciences, University of Calgary, Calgary, Alberta, Canada
Walter Kloepffer, Ph.D., Professor, Physical Chemistry, University of Mainz, Frankfurt am Main, Germany
Anton Kocan, M.Sc., Ph.D., Head of Department, Toxic Organic Pollutants, Slovak Medical University, Bratislava, Slovakia
Petr Kukucka, MSc, Ph.D., Student Research Centre for Toxic Compounds in the Environment, Masaryk University, Brno, Czech Republic
Michele La Merrill, Ph.D., MPH, Environmental Pediatric Postdoctoral Fellow, Preventive Medicine, Mount Sinai School of Medicine, New York, New York, USA
Duk-Hee Lee, MD, Ph.D., Professor Department of Preventive Medicine, Kyungpook National University, Daegu, South Korea
Monica Lind, Ph.D., Research Fellow in Environmental Toxicology, Occupational and Environmental Medicine, Uppsala University, Uppsala, Sweden
Rainer Lohmann, Ph.D., Associate Professor, Graduate School of Oceanography, University of Rhode Island, Narragansett, Rhode Island, USA
Sonya Lunder, MPH, Senior Analyst, Environmental Working Group, Washington DC, USA
Alex Madonik, Ph.D., Organic Chemistry, Senior Scientist, Green Science Policy Institute, Berkeley, California, USA
Jiri Matousek, Ph.D., DSc, Dipl.-Eng. Professor, Research Centre for Toxic Compounds in the Environment, Masaryk University, Faculty of Science, Brno, Czech Republic
Stanley McKnight, Ph.D., Professor of Pharmacology, University of Washington, Seattle, Washington, USA
Sverker Molander, Ph.D., Professor, Environmental Systems Analysis, Chalmers University of Technology, Gothenburg, Sweden
Jae Ryoung Oh, Ph.D., Section Head, Marine Environmental Studies Laboratory, IAEA, Monte Carlo, Monaco
Lena Olsén, Ph.D., Researcher, Department of Biomedical Sciences and Veterinary Public Health, Division of Pathology, Pharmacology and Toxicology, Swedish University of Agricultral Sciences (SLU), Uppsala, Sweden
Bindu Panikkar, MA/MS, Post Graduate Fellow Sociology, Environmental Studies, Brown University, Providence, Rhode Island, USA
Judith Perlinger, Sc.D., Associate Professor, Civil & Environmental Engineering, Michigan Technological University, Houghton, Michigan, USA
Kevin Plaxco, Ph.D., Professor, Chemistry and Biochemistry, University of California, Santa Barbara, California, USA
Yanling Qiu, Ph.D., Associate Professor, College of Environmental Science and Engineering, Tongji University, Shanghai, China
Cathryn J. Rehmeyer, Ph.D., Assistant Professor of Pathology, Pikeville College School of Osteopathic Medicine, Pikeville, Kentucky, USA
Charles Riley, Life Science/Physiology, CEO, Discover-e, Richmond, California, USA
Ott Roots, Ph.D., Director/Chief Scientist, Estonian Environmental Research Institute, Estonian Environmental Research Centre, Tallinn, Estonia
Per Rydberg, Ph.D., Reseacher, Materials and Environmental Chemistry, Stockholm University, Stockholm, Sweden
Andreas Rydén, M.Sc, Ph.D., Student, Department of Materials and Environmental Chemistry, Stockholm University, Stockholm, Sweden
Andreas Schaeffer, Ph.D., Director, Institute for Environmental Research, RWTH Aachen University, Aachen, Germany
Martin Schlabach, Ph.D., Senior Scientist, Environmental Chemistry, NILU, Kjeller, Norway
Margret Schlumpf, Ph.D., CO Director GREEN Tox, Institute of Anatomy, University of Zuerich, Zuerich, Switzerland
Cynthia Sparr, M.S. Tax, Builder, ECOwREN, Berkeley, California, USA
Nancy Sudak, MD, Staff Physician, Lake Superior Community Health Center, Duluth, Minnesota, USA
Neeta Thacker, Ph.D., Synthetic Organic Chemistry Scientist G & Head, Analytical Instruments Division (AID), National Environmental Engineering Research Institute (NEERI), Nagpur, Maharashtra, India
Mats Tysklind, Ph.D., Professor of Environmental Chemistry, Department of Chemistry, Umeå University, Umeå, Sweden
Robert Wålinder, Ph.D., Senior Physician, Occupational and Environmental Medicine, Uppsala University and University Hospital, Uppsala, Sweden
Kimberly A. Warner, Ph.D., Marine Pollution Scientist, Science, Oceana, Washington, USA
Glenys Webster, MRM, Ph.D. candidate, School of Environmental Health, University of British Columbia, Vancouver, Canada
Bernice Wiberg, MD, Ph.D., Senior consultant, Uppsala University Hospital, Uppsala, Sweden
Amber R. Wise, Ph.D., UC Berkeley, Assistant Professor Science – Chemistry, Asian University for Women, Chittagong, Bangladesh
Zhiqiang Yu, Ph.D., Professor, Guangzhou Institute of Geochemistry, Chinese Academy of Sciences, China

Supplemental Material to the San Antonio Statement on Brominated and Chlorinated Flame Retardants

Abbreviations
Brominated and chlorinated flame retardants may be mentioned under different names and abbreviations. Preferred abbreviations, alternative abbreviations, chemical name and Chemical Abstract System (CAS) numbers , related to the compound names, are given for those compounds discussed in the “Annotated San Antonio Statement on Brominated and Chlorinated Flame Retardants” are listed below.

TBP-AE or ATT: 2,4,6-tribromophenyl allyl ether; CAS 3278-89-5
BTBPE: 1,2-Bis(2,4,6-tribromophenoxy)ethane; CAS 37853-59-1
BEHTBP: bis(2-ethylhexyl) tetrabromophthalate; CAS 26040-51-7
BTBPIE: 1,2-Bis(tetrabromophthalimido)ethane; CAS 32588-76-4
DBDPE: Decabromodiphenylethane; CAS 84852-53-9
DBHC-TCTD or HCDBCO: 5,6-Dibromo-1,10,11,12,13,13-hexachloro-11-tricyclo[8.2.1.02,9]tridecene; CAS 51936-55-1
DP: Dechlorane Plus, Bis (hexachlorocyclopentadieno)cyclooctane; CAS 13560-89-9
TBP-DBPE: 2,4,6-Tribromophenyl 2,3-dibromopropyl ether; CAS 35109-60-5
HBB: Hexabromobenzene; CAS 87-82-1
HBCDD¹ or HBCD: Hexabromocyclododecane; CAS 3194-55-6; Major isomers are: α-, β-and γ-HBCDD
PBEB: Pentabromoethylbenzene; CAS 85-22-3
PBT: Pentabromotoluene; CAS 87-83-2
POPs: Persistent Organic Pollutants
SCCP: Short-chain chlorinated paraffins; CAS 85535-84-8 and 71011-12-6
EH-TBB or TBB: 2-Ethylhexyl-2,3,4,5-tetrabromobenzoate; CAS 183658-27-7
TBBPA: Tetrabromobisphenol A; CAS 79-94-7
TBBPA-DAE: Tetrabromobisphenol A diallyl ether; CAS 25327-89-3
TBBPA-DBPE: Tetrabromobisphenol A bis(2,3-dibromopropyl) ether; CAS 21850-44-2
TBECH: 1,2-Dibromo-4-(1,2-dibromoethyl)cyclohexane; CAS 3322-93-8
DEHTBP or TBPH: Di(2-ethylhexyl) tetrabromophthalate; CAS 26040-51-7
TCEP: Tris(2-chloroethyl) phosphate; CAS 115-96-8
TDCPP or TDCP: Tris(1,3-dichloroisopropyl) phosphate; CAS 13674-87-8

1 HBCDD is used herein to distinguish hexabromocyclododecane from hexabromocyclodecane (CAS 25495-98-1), for which HBCD is also used as an abbreviation as well.

Annotated San Antonio Statement on Brominated and Chlorinated Flame Retardants

1. Parties to the Stockholm Convention have taken action on three brominated flame retardants that have been listed in the treaty for global elimination. These substances include components of commercial pentabromodiphenyl ether and commercial octabromodiphenyl ether, along with hexabromobiphenyl. Another brominated flame retardant, hexabromocyclododecane, is under evaluation.
Commercial pentabromodiphenyl ether² (PentaBDE) has been commonly used in foam for furniture and commercial octabromodiphenyl ether³ (OctaBDE) has been used in plastics for electronic products. Both substances have been listed in the Stockholm Convention on Persistent Organic Pollutants for prohibition of production, use, import and export in more than 170 countries (UNEP 2009). POPs pose a threat to Arctic ecosystems and health of indigenous communities that are particularly at risk because of the biomagnification of persistent organic pollutants and the contamination of their traditional foods (AMAP Assessment 2009).

Hexabromobiphenyl (CAS 36355-01-8) is a component of commercial polybrominated biphenyls (PBB), another halogenated flame retardant previously used in plastics for electrical products and foam for auto upholstery. It is also a POP and has been listed in the Stockholm Convention on Persistent Organic Pollutants for prohibition of production, use, import and export in more than 170 countries (UNEP 2009).

The Stockholm Convention POPs Review Committee is currently evaluating commercial
hexabromocyclododecane (CAS 25637-99-4 and 3194-55-6), a brominated flame retardant frequently used in building materials, for possible addition to the Convention due to concerns about its persistence, bioaccumulation, long-range transport, and toxicity (UNEP/POPS/POPRC 2009a).

2. Many commonly-used brominated and chlorinated flame retardants can undergo longrange environmental transport.
Modeling studies have identified 120 high production volume brominated and chlorinated chemicals which are structurally similar to known Arctic contaminants and/or have partitioning properties that suggest they are potential Arctic contaminants (Brown and Wania 2008). These substances include the following halogenated flame retardants: tetra- to octabromodiphenyl ether, decabromodiphenyl ether, hexabromocyclododecane, tetrabromocyclohexane, chlorendic acid, tetrabromophthalic anhydride, and 2,4,6-tribromophenol.

Monitoring studies show that many brominated and chlorinated flame retardants are found in the Arctic or Antarctic indicating long-range transport. These include the following brominated and chlorinated flame retardants: components of Firemaster 550 (EH-TBB and BEHTBP) (Sagerup et al. 2010), Dechlorane Plus (Sverko et al. 2010), BEHTBP (Sagerup et al. 2010), BTBPE (Verreault et al. 2007a), DBDPE (Sagerup et al. 2010), TBECH (Tomy et al. 2008), HBCDD and PBEB (de Wit et al. 2010), SCCPs (Tomy et al. 1998), TBBPA (de Wit et al. 2010; SAICM 2009; Xie et al. 2007), TCEP (Laniewski et al. 1998), BEHTBP (Sagerup et al. 2010), and HBB (de Wit et al. 2010). The references are given as examples and not as a comprehensive list.

3. Many brominated and chlorinated flame retardants appear to be persistent and bioaccumulative, resulting in food chain contamination, including human milk.
Modeling studies examined 22,263 commercial substances that are not currently part of contaminant measurement programs identified 610 substances that are likely to be persistent and bioaccumulative (Howard and Muir 2010). These substances include the following flame retardants: TBP-AE, BTBPE, BEHTBP, BTBPIE, DBDPE, Dechlorane Plus, HBCDD, PBEB, TBBPA, TBBPA-DAE, TBBPA-DBPE, TBECH and TDCPP.

Monitoring studies show that many brominated and chlorinated flame retardants are found in the bodies of wildlife and humans, and some are found in the indoor environment. These include the following flame retardants: Firemaster 550 compounds, EH-TBB and BEHTBP, in house dust (Stapleton et al. 2008), in dolphins and porpoises (Lam et al. 2009), chlorinated tris (TDCPP) in indoor house dust (Stapleton et al. 2008), Dechlorane Plus in Great Lakes fish, herring gull eggs, and house dust (Gauthier et al. 2007; Hoh et al. 2006; Zhu et al. 2007), BTBPE in northern fulmar eggs, herring gull eggs and glaucous gulls in the Norwegian Arctic, house dust (Gauthier et al. 2007; Karlsson et al. 2006; Stapleton et al. 2008; Verreault et al. 2007a), DBDPE in fish and house and air craft dust (Law et al. 2006; Stapleton et al. 2008; Bergman et al. 2010), TBECH in beluga whales in the Canadian Arctic (Tomy et al. 2008), HBCDD in Arctic biota including polar bears, human serum, indoor dust, fish, breast milk (Fängström et al. 2008; Kakimoto et al. 2008; Letcher et al. 2009; Stapleton et al. 2008; Thomsen et al. 2010), DBHCTCTD in house dust (Zhu et al. 2008), PBEB in herring gull eggs and glaucous gulls in the Norwegian Arctic (Gauthier et al. 2007; Verreault et al. 2007a), SCCPs in Arctic biota and breast milk (Thomas et al. 2006; Environment Canada 2004), TBBPA in marine mammals, predatory bird eggs, breast milk, umbilical cord serum, blood and adipose tissue (Cariou et al. 2008; Antignac et al. 2008; Jakobsson et al. 2002; Johnson-Restrepo et al. 2008; NTP 2002), and HBB in falcon eggs, eggs of Great Lakes gulls, glaucous gulls in the Norwegian Arctic, human serum
(Gauthier et al. 2009; Verreault et al. 2007b; Zhu et al. 2009).

4. Many brominated and chlorinated flame retardants lack adequate toxicity information and the available data raises concerns.
In the US in the 1970s, brominated tris (tris(2,3-dibromopropyl) phosphate) was banned (U.S.Consumer Product Safety Commission 1977) from children’s pajamas and chlorinated tris was removed from pajamas because these two flame retardants caused genetic mutations in the Ames test and were suspected carcinogens (Blum and Ames 1977; Gold et al. 1978). According to the US Consumer Product Safety Commission, chlorinated tris is a probable human carcinogen (Babich 2006). Dechlorane Plus is poorly characterized toxicologically though it shares the chlorinated norbornene moiety with dieldrin, chlordane, heptachlor, endrin – all substances listed in the Stockholm Convention (UNEP 2001), and endosulfan (under evaluation for the Stockholm Convention) (UNEP/POPS/POPRC 2009a). A metabolite of BTBPE is 2,4,6-ribomophenol, a thyroid disrupting chemical (Hamers et al. 2006; Suzuki et al. 2008) which has been found in similar to decaBDE but has not been assessed toxicologically. Neonatal exposure to decaBDE causes changes in learning and behavior in adult animals and an altered response to nicotine, indicating a change in the brain cholinergic system (Viberg et al. 2003; Viberg et al. 2007). TBECH is a strong androgen agonist (Larsson et al. 2006) that is mutagenic to mammalian cells in vitro (McGregor et al. 1991). HBCDD is very toxic to aquatic organisms and can disrupt the hypothalamic- pituitary-thyroid (HPT) axis, disrupting normal development, affecting the central nervous system, and inducing reproductive and developmental effects in mammals with some of them being trans-generational (European Commission 2008; Swedish Chemicals Agency 2009). DBHC-TCTD is poorly characterized toxicologically though the substance shares the chlorinated norbornene moiety with dieldrin, chlordane, heptachlor, endrin – all substances listed in the Stockholm Convention (UNEP 2001) – and endosulfan (under evaluation for the Stockholm Convention) (UNEP/POPS/POPRC 2009a). PBEB is poorly characterized toxicologically but the substance is a brominated analogue of ethylbenzene, a carcinogen. SCCPs are considered cancer causing under California’s Safe Drinking Water and Toxic Enforcement Act of 1986, also known as Proposition 65 (OEHHA 1986). TBBPA is structurally similar to thyroxine and shows thyroid hormone activity in vivo and in vitro (Van der Ven et al. 2008). It shows estrogenic activity in animals (Kitamura et al. 2005) and inhibits neurotransmitter uptake affecting dopamine, GABA, and glutamate (Mariussen and Fonnum 2003). TCEP causes adverse reproductive outcomes (Beth-Hübner 1999; EHRT 1999) and is considered a carcinogen under California Office of Environmental Health hazard Assessment Proposition 65 (OEHHA 1986).

5. Many different types of brominated and chlorinated flame retardants have been incorporated into products even though comprehensive toxicological information is lacking.
These products include foam used in furniture, plastics used in electrical and electronic products, building materials, textiles, and other types of products. For example: PentaBDE: polyurethane foam used in upholstered furniture, carpet padding, and automobiles; polyurethane foam containing pentaBDE also is being reused in re-bonded carpet cushion and could be used in other recycled products (Daley et al. 2010).
OctaBDE: primarily used in acrylonitrile-butadiene-styrene (ABS) polymers for office electrical equipment; other uses include high impact polystyrene (HIPS), polybutylene terephthalate (PBT) and polyamide polymers (UNEP/POPS/POPRC 2009a).
DecaBDE: primarily used in high impact polystyrene (HIPS) for televisions, printers, and other electrical equipment; also used in thermoplastic polyesters, nylon, polypropylene and polyethylene for wires, cables, connectors and switches (Danish EPA 2006).
DEHTBP and EH-TBB: components of Firemaster 550, are e.g. used as a plasticizer for PVC (Harju et al 2008) and in wire and cable insulation, film and sheeting, carpet backing, coated fabrics, wall coverings and adhesives (OEHHA 2008).
Dechlorane Plus: used in electrical wires, cables, computer connectors, and plastic roofing (OEHHA 2008).
BTBPE: substitute for octaBDE (OEHHA 2008).
DBDPE: substitute for decaBDE (OEHHA 2008).
TBECH: used in polystyrene home insulation, adhesives in fabric and vinyl, electrical cables, plastic parts of appliances, and construction materials (OEHHA 2008).
HBCDD: used in polystyrene home insulation, in HIPS plastic for VCR housings and video cassettes, textile coating for upholstery fabric, bed mattresses, transportation upholstery, drapes, and wall coverings (OEHHA 2008).
DBHC-TCTD: used in polystyrene (OEHHA 2008).
PBEB: used in the 1970s and 1980s in polyester resins for circuit boards, textiles, adhesives, wire and cable coatings, polyurethanes and other resins (OEHHA 2008).
SCCPs: used for metal-working and cutting, flame retardants, and plasticizers in paint and sealants (OEHHA 2008).
TBBPA: used in printed circuit boards and various plastics and resins (OEHHA 2008).
TDCCP: used in polyurethane foam as a pentaBDE substitute, and in plastics, resins, and as a fabric back-coating (OEHHA 2008).
TCEP: used in polyurethane foam, plastics, carpet backing, and fabric back-coating (OEHHA 2008).

6. Brominated and chlorinated flame retardants present in a variety of products are released to the indoor and outdoor environments.
Most brominated and chlorinated flame retardant chemicals, including PBDEs, are additive flame retardants in that they are simply mixed with the polymer resin as plastics and foams are being made and are not chemically bound to the material. Consequently, these chemicals leach continuously out of the final product (Bergman 1989; de Wit 2002; Rahman et al. 2001; Bergman 2005). Over time, these chemicals accumulate in indoor air (Harrad et al. 2010) and eventually enter the natural environment (Hale et al. 2006; Moeckel et al. 2010). Given the ubiquity of these products in the modern world, it should come as no surprise that flame retardant chemicals are being found in all environmental matrices examined including air, water, soil sediment, and sewage sludge (de Wit et al. 2010; Harrad et al. 2009; Shaw and Kannan 2009).

7. Near-end-of-life and end-of-life electrical and electronic products are a growing concern as a result of dumping in developing countries, which results in the illegal transboundary movement of their hazardous constituents. These include brominated and chlorinated flame retardants.
The consensus Decision II/4D of more than 110 countries at the Second International Conference on Chemicals Management in 2009 uses this language to describe concerns over hazardous substances such as brominated and chlorinated flame retardants within the life cycle of electrical and electronic products (SAICM 2009).

8. There is a lack of capacity to handle electronic waste in an environmentally sound manner in almost all developing countries and countries with economies in transition, leading to the release of hazardous substances that cause harm to human health and the environment. These substances include brominated and chlorinated flame retardants.
The consensus Decision II/4D of more than 110 countries at the Second International Conference on Chemicals Management in 2009 uses this language to describe concerns over hazardous substances such as brominated and chlorinated flame retardants within the life cycle of electrical and electronic products (SAICM 2009).

9. Brominated and chlorinated flame retardants may increase fire toxicity, but their overall benefit in improving fire safety has not been proven.
The fire safety benefit of brominated and chlorinated flame retardants is questionable because they can increase the release of carbon monoxide, toxic gases, and soot which are the cause of most fire deaths and injuries (Stec and Hull 2010). For example, in one experiment, compared to untreated foam, pentaBDE-treated foam released approximately twice the amount of smoke (833 m2/kg vs. 413 m2/kg), seven times the amount of carbon monoxide (0.13 kg/kg vs. 0.018 kg/kg), and nearly 70 times the amount of soot (0.88 kg/kg vs. 0.013 kg/kg) but only provided three additional seconds before ignition compared to untreated foam (19 seconds vs. 16 seconds) (Jayakody et al. 2000). Also, the California furniture standard, California Department of Consumer Affairs Technical Bulletin 117 (TB 117 2000) on the flammability of foam inside furniture neither protects the foam from ignition nor reduces the severity of a fire, two measures of efficacy (Babrauskas 1983; Schuhmann and Hartzell 1989; Talley 1995). In applications where chemical flame retardants are considered for use, an investigation should address whether flame retardancy is needed (i.e. breast feeding pillows do not need flame retardancy) and if so, whether appropriate fire safety benefits may be obtained from using chemicals or techniques that do not present such serious potential adverse environmental and human health consequences. In some cases, reducing the sources of ignition can prevent fires without adding potentially hazardous chemicals to consumer products⁴.

10. When brominated and chlorinated flame retardants burn, highly toxic dioxins and furans are formed.
When brominated and chlorinated flame retardants burn, high yields of toxic brominated-, chlorinated-, and bromo-chlorinated dioxins and furans are formed (Söderström and Marklund 2002; Weber and Kuch 2003; Wichmann et al. 2002). In fact, the total amounts of brominated dioxins/furans generated from polybrominated diphenyl ethers are estimated in the tons scale and are comparable in magnitude to the total global formed amounts of chlorinated dioxins and furans (Zennegg et al. 2009). Brominated dioxins have toxicities similar to their chlorinated counterparts in human cell lines, mammalian species, and other assays (Behnisch et al. 2003; Birnbaum et al. 2003; Matsuda et al. 2010; Olsman et al. 2007). In addition, brominated dioxin/furan contamination has been reported in humans, including human milk as well as in food and dust (Ashizuka et al. 2008; Choi et al. 2003; Jogsten et al. 2010; Kotz et al. 2005; Ma et al. 2009; Matsuda et al. 2010b; Rose and Fernandes 2010; Suzuki et al. 2006; Suzuki et al. 2010; Takigami et al. 2008). State of the art incinerators have been used for disposal of flame retardant-containing materials. However an investigation of the process for disposing electronic waste containing halogenated flame retardants revealed that high levels of chlorinated, brominated-chlorinated and brominated dioxins and furans can be formed in the primary combustion zone (Hunsinger et al. 2002; UNEP/POPS/POPRC 2010). A secondary combustion zone can help destroy most of these unintentionally formed substances (Hunsinger et al. 2002). This and other studies indicate that combusting waste containing brominated and/or chlorinated flame retardants requires state-of-the-art incinerators operating under stringent conditions. Continuous or near-continuous monitoring of stack gases and frequent monitoring of residues is necessary to ensure that toxic contaminants are not released to the environment.

11. Brominated and chlorinated flame retardants as classes of substances are a concern for persistence, bioaccumulation, long-range transport, and toxicity.
Please see paragraphs 2-4 above.

12. There is a need to improve the availability of and access to information on brominated and chlorinated flame retardants and other chemicals in products in the supply chain and throughout each product’s life cycle.
The consensus Decision II/4C of more than 110 countries at the Second International Conference on Chemicals Management in 2009 uses this statement to apply to all chemical substances (SAICM 2009).

13. Consumers can play a role in the adoption of alternatives to harmful flame retardants if they are made aware of the presence of the substances, for example, through product labeling.
This is the conclusion of the Stockholm Convention POPs Review Committee, an expert
committee of the Convention that approved a guidance document on considerations relating to alternatives and substitutes (UNEP/POPS/POPRC 2009b).

14. The process of identifying alternatives to flame retardants should include not only alternative chemicals but also innovative changes in the design of products, industrial processes, and other practices that do not require the use of any flame retardant.
This is the conclusion of the Stockholm Convention POPs Review Committee, an expert
committee of the Convention that approved a guidance document on considerations relating to alternatives and substitutes (UNEP/POPS/POPRC 2009b).

15. Efforts should be made to ensure that current and alternative chemical flame retardants do not have hazardous properties, such as mutagenicity and carcinogenicity, or adverse effects on the reproductive, developmental, endocrine, immune, or nervous systems.
This is the conclusion of the Stockholm Convention POPs Review Committee, an expert
committee of the Convention that approved a guidance document on considerations relating to alternatives and substitutes (UNEP/POPS/POPRC 2009b).

16. When seeking exemptions for certain applications of flame retardants, the party requesting the exemption should supply information indicating why the exemption is technically or scientifically necessary and why potential alternatives are not technically or scientifically viable; a description of potential alternative processes, products, materials, or systems that eliminate the need for the chemical; and a list of sources researched.
These recommendations come from the Stockholm Convention POPs Review Committee, an expert committee of the Convention that approved a guidance document in 2009 on considerations relating to alternatives and substitutes for use by all Parties and Observers (UNEP/POPS/POPRC 2009a)

18. Flame retardants with POP characteristics should not be permitted to be subjected to disposal operations that may lead to recovery, recycling, reclamation, direct reuse, or alternative uses of the substances.
Stockholm Convention Article 6, para1; in legal force for more than 170 countries (UNEP 2001).

19. Wastes containing flame retardants with POP properties should not be transported across international boundaries unless it is for disposal in such a way that the POP content is destroyed or irreversibly transformed.
Stockholm Convention Article 6, para 1; in legal force for more than 170 countries (UNEP 2001).

20. It is important to consider product stewardship and extended producer responsibility aspects in the life-cycle management of products containing flame retardants with POP properties, including electronic and electrical products.
The consensus Decision II/4D of more than 110 countries at the Second International Conference on Chemicals Management in 2009 uses this statement to describe concerns over hazardous substances within the life cycle of electrical and electronic products (SAICM 2009).

2 Tetrabromodiphenyl ether (CAS 40088-47-9), pentabromodiphenyl ether (CAS 32534-81-9 and other tetra- and pentabromodiphenyl ethers present in commercial pentabromodiphenyl ether

3 Hexabromodiphenyl ethers BDE-153 (CAS 68631-49-2), BDE-154 (CAS 207122-15-4), heptabromodiphenyl ethers BDE-175 (CAS 446255-22-7), BDE-183 (CAS 207122-16-5), and other hexa- and heptabromodiphenyl ethers present in commercial octabromodiphenyl ether.

4 In the US, California’s flammability standard TB117 has led to the use of flame retardants in California furniture for more than thirty years. Despite this, an analysis of fire data from 1980 to 2005 by the National Fire Protection Association (NFPA) does not show a greater reduction in the rate of fire deaths in California compared to that of other states without such a standard. (Hall JR. US Unintentional Fire Death Rates by State. National Fire Protection Association (NFPA), Quincy, MA. 2008.) A 60% decrease in fire deaths in the United States since 1980 parallels the decrease in per capita cigarette consumption. Increased enforcement of improved building, fire, and electrical codes and the increased use of smoke detectors and sprinkler systems in new construction have also contributed to an increase in fire safety. In the US, an estimated 65% of reported home fire deaths in 2000-2004 resulted from fires in homes without working smoke alarms.

San Antonio Statement on Brominated Flame Retardants

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