Applications for Authorisation Consultation number 0013-02 ... · shows the uses of FR-EPS articles that authorisation is applied for as mentioned in ECHA’s consultation web page

AfA 0013-02 – Technical alternative - Mineral wool

Applications for Authorisation

Consultation number 0013-02

Flame-retarded EPS

Third party submission of information on alternatives

Legal name of submitter(s): Rockwool International A/S Hovedgaden 584 DK-2640 Hedehusene Denmark

SUBMISSION OF INFORMATION ON ALTERNATIVES (NON-CONFIDENTIAL)

2 AfA 0013-02 – Technical alternative - Mineral wool

TABLE OF CONTENTS

1 ALTERNATIVE ID AND PROPERTIES ......................................................................... 3

1.1 Technical alternative to flame-retarded expanded polystyrene insulation products ... 3

1.2 Identification of mineral wool fibres ................................................................... 3

1.3 Manufacture and use ........................................................................................ 3

1.4 Classification of mineral wool fibres.................................................................... 3

1.5 Guidance on safe use ....................................................................................... 4

2 TECHNICAL FEASIBILITY ........................................................................................ 4

3 ECONOMIC FEASIBILITY ......................................................................................... 8

4 HAZARDS AND RISKS OF THE ALTERNATIVE ............................................................. 8

4.1 Human health ................................................................................................. 9

4.2 Environment ................................................................................................... 9

5 AVAILABILITY ....................................................................................................... 10

6 CONCLUSION ON SUITABILITY AND AVAILABILITY OF THE ALTERNATIVE .................... 10

7 OTHER COMMENTS ................................................................................................ 10

8 REFERENCES ........................................................................................................ 11

9 APPENDIXES ......................................................................................................... 13


AfA 0013-02 – Technical alternative - Mineral wool 3

1 ALTERNATIVE ID AND PROPERTIES

1.1 Technical alternative to flame-retarded expanded polystyrene insulation products

Flame-retarded expanded polystyrene insulation (hereinafter called FR-EPS) products are used in building applications. We present mineral wool insulation products as technical alternatives for the use of FR-EPS insulation products in identical application fields in buildings. The use of mineral wool products and EPS products building insulation are governed by the European standards EN 13162 (mineral wool products) and EN 13163 (EPS products). Mineral wool insulation products are made from mineral wool fibres glued together with a binder as described in section 1.3. The mineral wool fibres have been registered; cf. section 1.2, in which the fibres are identified. For comparison FR-EPS insulation products are made from FR-EPS beads by expansion. Manufacture of the FR EPS beads is covered by Application for Authorisation number 0013-01.

1.2 Identification of mineral wool fibres

Name: Man-made vitreous (silicate) fibres with random orientation with alkaline oxide and alkali earth oxide (Na2O+K2O+CaO+MgO+BaO) content greater than 18% by weight and fulfilling one of the note Q conditions,

(MMVF note Q fibres; hereinafter called mineral wool fibres) CAS no: not allocated Index no: 650-016-00-2 EC no: 926-099-9 Registration no’s: 01-2119472313-44-0000 to 01-2119472313-44-0062 The registration dossier /1/ covers mineral wool fibres produced from different raw material sources (rock, glass and slags). Mineral wool fibres are biosoluble and fulfilling one of the Note Q criteria in the CLP Regulation (EC) No 1272/2008 /2/.

1.3 Manufacture and use

Mineral wool fibres are produced by fiberizing molten glass/stone. The molten glass/stone goes to the fiberizing area. Fiberizing combines a mechanical centrifugal drawing of the molten glass/stone through a rotating device drilled with holes, or through rotating cylinders, and/or a fibre attenuation by means of high temperature gas jet streams or compressed air /1/. In a later step of the mineral wool manufacturing process, the fibres are glued together by means of a binder, which cures before the material leaves the process line. This mineral wool material is manufactured into products (form pieces, slabs, etc.) to be used for building applications, e.g. heat, noise and vibration insulation.

1.4 Classification of mineral wool fibres

Mineral wool fibres are exempted from classification according to CLP Regulation (EC) No 1272/2008, as amended in Regulation (EC) No 790/2009 /3/ and thus not classified, cf. the registration dossier /1/.



1.5 Guidance on safe use

Mineral wool fibres are not used in their own right; they are used to manufacture mineral wool articles as mentioned in section 1.3, and loose mineral wool. The following guidance on safe use is regarding the final mineral wool articles. This section on safe use is taken from the registration dossier /1/. Exposure control No specific requirements for exposure control exist for working with mineral wool articles. There is no occupational exposure limit (OEL) value at European level. But national OELs exist. Handling Avoid unnecessary handling of unwrapped product. Ensure adequate ventilation of workplace. No specific technical measures are needed. When shaping is needed, use preferably a knife. If a power tool is used, it must be equipped with efficient air suction. Personal protection When working in unventilated areas or during operations, which can generate significant emissions of dust, wear a disposable face mask. Type in accordance with EN 149 FFP1 is recommended. To avoid itching of hands, use gloves in accordance with EN 388. Cover possibly exposed skin. When working overhead, wear goggles in accordance with EN 166. Hygienic measures: Rinse in cold water before washing. Storage The mineral wool articles are packed in polyethylene film or cardboard on wooden pallets. They should be stored dry; if possible also in original packaging. Mineral wool articles without packaging should always be stored dry. There are no incompatible materials to mineral wool articles. Exposure scenarios Mineral wool is not classified. No exposure scenario development is required.

2 TECHNICAL FEASIBILITY

The Application for Authorisation is sought for manufacture of flame retarded (FR) expanded polystyrene (EPS) articles to be used for insulation in building applications. The manufacture of the FR EPS articles are produced from FR EPS beads that are expanded using steam at a temperature of 100-110 °C. Application for Authorisation number 0013-01 covers the manufacture of the FR EPS beads. Table 2-1 shows the uses of FR-EPS articles that authorisation is applied for as mentioned in ECHA’s consultation web page (Consultation 0013-02). The table also shows with ‘+’ in the mineral wool column for the uses, where mineral wool products can be equally applied for insulation in buildings.



Table 2-1. Uses of FR-EPS articles (boards etc) in building applications as listed in the consultation. Where mineral wool articles are suitability alternatives to (FR-)EPS, it is marked with ‘+’.

# FR-EPS uses in listed in the consultation

Mineral wool

Remarks

1 Flat roof insulation + - 2 Pitched roof insulation + - 3 Floor insulation ‘slab-on-ground’

insulation + -

4 Insulated concrete floor systems + No need for flame retardant in EPS 5 Interior wall insulation with

gypsum board (‘doublage’) + -

6 Exterior wall insulation or ETICS (External Insulated Composite Systems)

+ -

7 Cavity wall insulation boards + - 8 Cavity wall insulation loose fill + - 9 Civil engineering applications + No need for flame retardant in EPS 10 Insulated concrete forms (ICF) + - 11 Foundation systems and other

void forming systems + No need for flame retardant in EPS

12 Load bearing foundation applications

+ No need for flame retardant in EPS

13 Core material for EPS used in sandwich and stressed skin panels (metal and wood fibreboard)

+ -

14 Floor heating systems + Most likely no need for flame retardant in EPS

15 Sound insulation in floating floors (to avoid transmission of contact sound)

+ -

16 Seismic applications - Earthquake protection 17 EPS drainage boards + Flame retardant in EPS may be

necessary; if it goes over ground level, it may be reached by external fire

HBCDD is used in EPS as flame retardant for building applications. Mineral wool can be used and is used for the same purposes as FR-EPS; mineral wool being non-combustible and not flammable. Mineral wool is used for heat insulation (uses ##1,2,3,4,5,6,7,8,10,11,12,13,14), noise insulation use #15), vibration absorption (use #16) and other applications (uses ##9,17). In some of the FR-EPS uses mentioned in Table 2-1 use of flame retardant materials is not necessary, because the insulation material is covered by fire protective material like concrete and is not in contact with other combustible constructions /4//5//6/. Elmroth has assessed the use of EPS (and XPS) in building applications and compared with mineral wool /7/. For some uses flame retardant is not needed as also remarked in Table 2-1. Elmroth points out that the main difference is fire resistance; mineral wool is incombustible whereas EPS is combustible. COWI gives an overview of the characteristics regarding building



fire safety, cf. Table 2-2. The table shows EPS and FR-EPS have higher fire reactivity, i.e. higher combustibility (European fire classes: Euroclasses F and E), develop more toxic smoke, emits burning droplets and contributes to fire load; this is not the case for the alternative mineral wool products (stone wool, glass wool), which all are non-combustible, do not emit toxic smoke or burning droplets, or contribute to fire load /5/.

Table 2-2. Summary of properties (reaction to fire) regarding building fire safety (Modified from /5/).

Material/technique Combustible (Euroclass)

Development of toxic smoke

Burning droplets Contribution to fire load

EPS sheets (flame retarded)

E Yes Yes Yes

EPS sheets (non-flame retarded)

F Yes Yes Yes

Stone wool A1, A2 Non/less No No (negligible) Glass wool A1*), A2 Non/less No No (negligible) *) ref. /8/. For certain building applications FR-EPS is not enough; well-dimensioned fire barriers are necessary /7/. Elmroth concludes

HBCDD has to be phased out by 2015. However, there are some applications where EPS/XPS insulation materials without HBCDD can be used in constructions where no fire risk is present like below ground. For the rest of the applications within building insulation this survey demonstrates that feasible alternatives exist.

The feasible alternatives are e.g. mineral wool products /7/. COWI gives a comprehensive overview on alternatives to the use of FR-EPS in building applications /5/. The report cites the German Gesamtverband Dämmstoffindustrie (GDI) for the information in Table 2-3. It may be seen that mineral wool can be used in the same building applications as EPS. Some application areas, for which heavy mineral wool is marketed (e.g. slabs-on-ground), are not indicated in the table.



Table 2-3. Application areas for different insulation materials according to the German standard DIN V 4108-10 /5/. References in the table refer to mineral wool applications.

Application area Mineral wool

EPS

Pitched roof (/9//10//11//12//13//14/) On the rafter + + Between the rafter + + Below the rafter + + Flat roof (/15//16//17/) Sloping roof + + Green roof only DAA * only DAA * Parking deck - only DAA *

a) Roof terrace - only DAA* Steel profile tin roof + + Ceiling/floor (/18//19//20//21//22//23/) Top ceiling - walkable b) b) Top ceiling - not walkable + + Basement ceiling + + Floor - below screed without requirements for footfall noise reduction

+ +

Floor - below screed with footfall noise requirements + + Industry floors - + Walls (/24//25//26//27//28//29//30/) Internal insulation + + Cavity insulation + + ETICS (external thermal insulation composite systems) c) c) Base insulation – thermal bridge insulation + + Ventilated façades + + Wood and timber frame building + + House partition walls with requirements for noise reduction + c) Room partitioning wall + -



Application area Mineral wool

EPS

Perimeter Floor batt against the ground /31//32//33/ + c), d) Wall against the ground /31//32//33/ - c) - No information * Only for roofs where the insulation is under seal which protect against the weather (DAA) – not for

inverted roofs where the insulation is not protected (DUK). ** Only for internal insulation of the ceiling (the underside) or the roof, insulation at rafter / support

structure, suspended ceilings, etc (DI) a) Insulation must meet the requirements regarding static/dynamic compressive strength/pressure

resistance. Manufacturer’s instructions must be observed. b) Additional load-distributing layer required. c) Regulated by general approvals by the building authorities. d) Additional general approvals by the building authorities regarding weight-carrying foundation slabs.

3 ECONOMIC FEASIBILITY

Mineral wool is an economically and technically viable alternative to FR-EPS for almost all applications. Umweltbundesamt in Germany (UBA) compared the relative costs of material per area unit insulated to a specific insulation performance; if the costs for EPS = 1, then mineral wool = 1.3, PUR = 2.8 and XPS = 3. Thus, the raw material cost of mineral wools is slightly higher as compared EPS. The comparison is based on material costs only; other costs, e.g. the need for more or less supporting construction material are not included /34//35/. Table 3-1 shows a summary of technical feasibility and cost of mineral wool (stone wool) as compared to EPS. The table is modified from /5/. It is seen that mineral wool products are priced the same and up to 30% more as compared to EPS.

Table 3-1. Summary of technical feasibility and cost of stone wool as compared to EPS (modified from /5/).

Technical solution

Technical feasibility Price of functional unit compared to EPS*1,2

Advantages (as compared to EPS)

Disadvantages (as compared to EPS)

Stone wool Diffusion-open, allows vapour to pass. Easier to fasten tight in some cases due to flexibility.

Similar insulation efficiency. Higher weight. Lover compressive strength than some EPS types

≈/+

*1: ≈ prices similar to EPS; + 10-30% more than for EPS. *2: Functional unit: Insulation thickness which provides the same thermal resistance as 10 centimetres of EPS covered outer wall insulation.

4 HAZARDS AND RISKS OF THE ALTERNATIVE

Based on the information in sections 4.1 and 4.2 below, using mineral wool instead of FR-EPS with HBCDD as flame retardant will reduce the risk both to humans and to the environment to negligible level.



4.1 Human health

Mineral wool is not classified in EU /2/. The data in the registration dossier does not result in a re-evaluation of the classification /1/. Mineral wool is an inert material that does not pose a hazard to building occupants, when used as insulation. Although formaldehyde-phenolic resins may be used to bind these products, emissions to indoor air are extremely low and do not impact on indoor air quality /37/. During installation or renovation demolition of buildings dust containing fibres may be released /4/. There is no occupational exposure limit (OEL) value for mineral wool fibres at European level; but some national OELs exist /4/.

4.2 Environment

Mineral wool is inorganic and slightly soluble in water through slow non-reversible leaching of inorganic chemical species, which are naturally occurring in water (Na+, K+, Ca2+, Mg2+, Ba2+, OH-, and SiO3

3- or SiO44-) /1/. The water solubility for mineral wool samples from six different

manufacturers is on average 27 mg/L as sodium and silicium; five samples in the range 0.6-18 mg/L, and one sample dissolved 123 mg/L /1/. Mineral wool does not show short-term aquatic toxicity. Mineral wool does not have potential for crossing biological membranes, and the leached inorganic chemical species do not pass into lipid phase because they are ionized. Mineral wool or the leached inorganic chemical species do not pose toxic effects in the environment or to environmental organisms; including the microorganisms in sewage treatment plants /1/. HBCDD used as flame retardant in FR-EPS is classified in the EU as Repr. 2 (H361 - Suspected of damaging fertility or the unborn child) and Lact. (H362 - May cause harm to breast-fed children) /38/. Furthermore, HBCDD is assessed as a persistent organic pollutant (POP) /39//40/, and is on the Candidate List based on its PBT properties /41/. Production of mineral wool products uses energy and emits CO2. The energy used in production is paid back more than a 100 times over 50 years in case of attic insulation with 250 mm stone wool insulation /42/, i.e. the savings in heating energy for the insulated house is paid back after less than half a year with present European insulation thicknesses. From the numbers in ref. /42/ it may be calculated that for each ton of CO2 generated in the manufacturing process of mineral wool, more than 100 tons of CO2 over a 50-year period are saved due to the thermal insulation properties of mineral wool /42/. For technical insulation (e.g. oven hot pipes, power plants) the energy and CO2 payback time is much shorter, often in the order of days or weeks - depending on temperature and application. For an industrial pipe at 350 °C insulated with 80 mm stone wool, the CO2 payback time is 0.2 days, calculated using the Rockassist computer tool /43/. The mineral wool industry uses increasing amounts of recycled materials in manufacture. Depending on the quality and availability of local supplies recycled glass makes up 30% to 60% of the raw material input. In some plants this is as high as 80% /4/. One stone wool producer recycled more than 565,000 tonnes waste materials from other industries in 2012. In some production plants waste materials made up more than 60% of the total raw material consumption /46/. Up to 25% EPS can be recycled and still maintaining the technical performance of the EPS insulation boards /44/. FR-EPS containing HBCDD is not being recycled /45/. Energy is recovered when EPS is incinerated. Furthermore, incineration together with household waste aids burning of the solid waste /44/. Disposal of mineral wool removed from buildings may be disposed of as inert construction waste, unlikely to have a major adverse impact on the environment. However, there is an increasing trend to recycle mineral wool when removed from buildings /4//46/.



5 AVAILABILITY

Mineral wool has been registered by 62 companies located across most Member States. The total registered amount of mineral wool on the European market is 1,000,000 – 10,000,000 tons/year /1/. The largest tonnage volume is used for heat insulation in buildings. Minor tonnage volume is used for noise reduction purposes. Mineral wool already has a large share of the insulation market in Europe (>30%) and appears to be a economically and technically viable alternative to FR-EPS for many applications /36/. As seen from Chapter 2, mineral wool can substitute all the uses that authorisation is applied for FR-EPS. As seen from the previous paragraph, mineral wool articles for different insulation purposes are produced in EU in large quantities. Furthermore, the production volume can be increased.

6 CONCLUSION ON SUITABILITY AND AVAILABILITY OF THE ALTERNATIVE

Mineral wool is a suitable technical alternative to FR-EPS for almost all building applications listed in the Application for Authorisation. For a number of building applications there is no fire risk and therefore EPS does not need to contain fire retardant. Mineral wool products are already on the market for the same purposes as FR-EPS. In some countries (FR-)EPS is used, in other countries mineral wool is used; this is due to marketing of local producers and tradition. On average, mineral wool is slightly more expensive than EPS. The mineral wool industry uses increasing amounts of recycled materials in its production. Depending on the quality and availability of local supplies recycled material makes up 30% to 60% of the raw material input, or even higher. Recycled stone wool materials may also come from demolishing old buildings. Mineral wool is non-toxic to humans and in the environment; whereas HBCDD (the fire retardant in FR-EPS) is classified in EU as Repr. 2 (H361 - Suspected of damaging fertility or the unborn child) and Lact. (H362 - May cause harm to breast-fed children). Furthermore, HBCDD is assessed as a persistent organic pollutant (POP), and is on the Candidate List based on its PBT properties. Mineral wool products (stone wool, glass wool) are all non-flammable and non-combustible, and do not emit toxic smoke, burning droplets, or contribute to fire load, as opposed to EPS and FR-EPS. Mineral wool is registered to ECHA by 62 companies in Europe. The total registered amount of mineral wool on the European market is 1,000,000 – 10,000,000 tons per year. The mineral wool industry has capacity for increasing the yearly output. Thus, mineral wool is available for substitution of FR-EPS in the building applications listed in the Application for Authorisation. In conclusion, mineral wool is a suitable alternative for FR-EPS in building applications. It has a long history (since 1937) and is readily available on the European market, and the mineral wool industry has sufficient capacity to increase the production volume.

7 OTHER COMMENTS

From a fire protection point of view, mineral wool offers a safer solution. EPS on its own is flammable (combustible Euroclass F); but even FR-EPS may catch fire if not protected by a thermal barrier, like concrete /6/; as also shown in Table 2-2, FR-EPS is classified as combustible in Euroclass E, whereas mineral wool is classified in Euroclass A1 and A2.



HBCDD is regarded as a POP substance /38//40/. The possibility for substituting HBCDD with alternative flame retardants in EPS has been analysed in more reports, e.g. /5//47/. US-EPA /47/ points to butadiene styrene brominated copolymer as flame retardant additive. A number of EPS manufacturers have already switched to this polymeric flame retardant /48/ and the large German chemical manufacturer BASF opposes extension of HBCDD use, because a better and safer alternative has already been introduced successfully /48/.

8 REFERENCES

/1/ REACH registration dossier. Man-made vitreous (silicate) fibres with random orientation with alkaline oxide and alkali earth oxide (Na2O+K2O+CaO+MgO+BaO) content greater than 18% by weight and fulfilling one of the note Q conditions. List number 926-099-9. Available: http://apps.echa.europa.eu/registered/data/dossiers/DISS-a20ff2ce-1643-54e6-e044-00144f67d031/DISS-a20ff2ce-1643-54e6-e044-00144f67d031_DISS-a20ff2ce-1643-54e6-e044-00144f67d031.html.

/2/ Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006.

/3/ Commission Regulation (EC) No 790/2009 of 10 August 2009 amending, for the purposes of its adaptation to technical and scientific progress, Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures.

/4/ IOM Consulting. Data on manufacture, import, export, uses and releases of HBCDD as well as information on potential alternatives to its use. 2009. ECHA_2008_2_SR04_HBCDD_report_12_01_2009.doc.

/5/ COWI. Alternative to the use of flame retarded EPS in buildings. Climate and Pollution Agency, Norway. 2011. (Report No TA 2827).

/6/ Babrauskas V, Lucas D, Eisenberg D, Singla V, Dedeo M, Blum A. Flame retardants in building insulation: a case for reevaluating building codes. Building Research & Information. 2012:40(6);738-55.

/7/ Elmroth A. The optimal use of XPS and EPS insulation materials. 2011.

/8/ Saint-Gobain Isover UK. CWS. Silicone impregnated glass mineral wool slabs providing thermal insulation in masonry cavity walls in full-fill applications. Ref: CWS001; July 2006.

/9/ http://www.rockwool.de/produkte/u/2101/schraegdach.

/10/ http://www.rockwool.de/produkte/zwischensparrend%c3%a4mmung+klemmrock.

/11/ http://www.isover.de/Home/Produktwelt/Produkte/Integra/Integra-AP-Basic.aspx.

/12/ http://www.isover.de/Home/Produktwelt/Produkte/Integra/Integra-ZKF-1-035.aspx.

/13/ http://www.knaufinsulation.de/product/steinwolle/schragdach-dammplatte-sdp-035.html.

/14/ http://www.knaufinsulation.de/product/glaswolle/universaldammrolle-classic-032.html.

/15/ http://www.rockwool.de/produkte/u/2105/flachdach.



/16/ http://www.isover.de/Home/Produktwelt/Produkte/Metac/Metac-FLP-1-Duratec.aspx.

/17/ http://www.knaufinsulation.de/product/steinwolle/flachdach-dammplatte-ddp-s.html.

/18/ http://www.rockwool.de/produkte/u/2176/fussboden.

/19/ http://www.isover.de/Home/Produktwelt/Produkte/Akustic/Akustic-EP-2.aspx.

/20/ http://www.isover.de/Home/Produktwelt/Produkte/Topdec/Topdec-Loft.aspx.

/21/ http://www.knaufinsulation.de/product/steinwolle/dachboden-dammplatte-tpd-l.html.

/22/ http://www.knaufinsulation.de/product/steinwolle/deckendammplatte-basic.html.

/23/ http://www.knaufinsulation.de/product/glaswolle/akustik-dammplatte-tp-120.html.

/24/ http://www.rockwool.de/produkte/u/1143/aussenwand.

/25/ http://www.rockwool.de/produkte/u/2124/innenausbau.

/26/ http://www.isover.de/Home/Produktwelt/Produkte/Sillatherm/Sillatherm-WVP-2.aspx.

/27/ http://www.isover.de/Home/Produktwelt/Produkte/Kontur/Kontur-FSP-1-032.aspx.

/28/ http://www.isover.de/Home/Produktwelt/Produkte/ULTIMATE/ULTIMATE-Kern-Daemmplatte-035.aspx.

/29/ http://www.knaufinsulation.de/product/glaswolle/trennwand-dammrolle-ti-140-t.html.

/30/ http://www.knaufinsulation.de/product/steinwolle/stahlkassetten-dammplatte-skp-035.html.

/31/ http://www.rockwool.no/produkter/u/2011.product/1661/byggisolasjon/drensplate.

/32/ http://www.rockwool.se/produkter/u/2011.product/1666/byggisolering/markskiva-industri.

/33/ http://www.rockwool.dk/produkter/u/1096/A-FUNDAMENTSBATTS.

/34/ Umweltbundesamt (UBA). Erarbeitung von Bewertungsgrundlagen zur Substitution umweltrelevanter Flammschutzmittel – Band II Flammehemmende Ausrüstung ausgewählter Produkte, anwendungsbezogene Betrachtung, Stand der Technik, Trend Alternativen. UBA: 2000. (UBA Texte 26/01). (cited in ref. /36/).

/35/ Leisewitz A, Kruse H, Schramm E. Substituting environmentally relevant flame retardants: Assessment fundamentals. Results and summary overview. Umweltbundesamt (UBA): 2001. (UBA Texte 40-01).

/36/ Heijkenskjöld L. Strategy for limiting risks. Hexabromocyclododecane (HBCDD). 2nd Priority List. CAS no. 25637-99-4 and 3194-55-6; EINECS no. 247-148-4 and 221-695-9. Swedish Chemicals Agency: 2007.

/37/ Salthammer T, Mentese S. Comparison of analytical techniques for the determination of aldehydes in test chambers. Chemosphere. 2008:73;1351–6.

/38/ Commission Regulation (EU) No 618/2012 of 10 July 2012 amending, for the purposes of its adaptation to technical and scientific progress, Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures.



/39/ United Nations. Stockholm Convention on persistent organic pollutants. Stockholm, 22 May 2001. Amendment to Annex A.

/40/ Nordic Council of Ministers. Hexabromocyclododecane as a possible global POP. Copenhagen; 2007. (TemaNord 2008:520).

/41/ ECHA. First recommendation for inclusion in the authorisation list. 1 June 2009. Available: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/authorisation/recommendation-for-inclusion-in-the-authorisation-list/previous-recommendations/1st-recommendation.

/42/ Schmidt AC, Clausen AU, Jensen AA, Kamstrup O. Comparative life cycle assessment of three insulation materials: stone wool, flax and paper wool. Final report, August 2003. In: Klöpffer W, Hutzinger O, eds. LCA Documents; vol 8. Landsberg, Germany: ecomed publishers; 2003.

/43/ Rockassist computer tool. Available at http://www.rockassist.com/?AspxAutoDetectCookieSupport=1.

/44/ EUMEPS. Recycling. Available at http://www.eumeps.org/recycling_4499.html.

/45/ EUMEPS. EUMEPS comment on applications for Authorisation of HBCD (consultation no’s 0013-01 and 0013-02). 27 May 2014. Available at http://echa.europa.eu/documents/10162/18074545/a4a_comment_556_1_attachment_en.pdf.

/46/ Rockwool. Available at http://www.rockwool.com/files/COM2011/CSR/Committed-to-society/Sustainability-Report/Reporting-year-2012_Published-2013/SR-2012_2013_EN.pdf.

/47/ US EPA. Flame retardant alternatives for hexabromocyclododecane (HBCD). Final report, June 2014. (EPA Publication 740R14001). Available at http://www.epa.gov/dfe/pubs/projects/hbcd/hbcd-full-report-508.pdf.

/48/ Plasteurope. German chemical giant opposes prolonged use of HBCD flame retardants in EPS/XPS foams (BASF). Available at http://www.plasteurope.com/news/BASF_t228528.

9 APPENDIXES

Please refer to reference list.

http://www.epa.gov/dfe/pubs/projects/hbcd/hbcd-full-report-508.pdf