The brominated flame retardants industry has produced its third annual report on its Voluntary Emissions Control Programme, known as VECAP.1
The programme was set up in 2004 to address emissions of deca-bromo diphenyl ether (deca-BDE) during processing, in response to concerns about the chemical’s environmental persistence and potential to break down into bioaccumulative products (ENDS Report 358, p 10 ).
VECAP focuses on promoting best practice emissions reduction measures among flame retardant user companies in the textile and plastics sectors. It has won praise from the government’s Chemicals Stakeholder Forum and the Environment Agency as an good example of producer responsibility. The latest report also has a foreword by Mike Barry, head of corporate social responsibility at Marks and Spencer, who applauds VECAP as "a great example of how chemicals need to be managed in the 21st century".
This year’s report details continuing reductions in emissions to air and water during textile finishing and plastics moulding. A particular focus this year has been on cutting emissions in spent packaging used to deliver flame retardants to manufacturers.
From its roots in the UK, the programme has spread to five other EU countries - France, Italy, the Netherlands, Belgium and Germany. Together, these account for 95% of EU deca-BDE consumption. All remaining EU countries are scheduled to join the scheme between before 2010.
The report says that 97% of textile industry users and 82% of plastic industry users are now signed up to VECAP. Paul Adriaenssens, VECAP product steward, explained there are many "small guys" in the plastics sector who are hard to track, making it unlikely that commitments will reach the high levels seen for textiles.
VECAP has been extended to include the use of two additional brominated flame retardants in textiles - tetra-bromo bisphenol A (TBBPA), and hexa-bromo cyclododecane (HBCD). The industry says that the first data on TBBPA and HBCD emissions and user commitments will be published in next year’s report.
Through international expansion, VECAP now covers North America, where 79% of deca-BDE use, 60% of TBBPA use, and 39% of HBCD use is now signed up. In Japan too, 88% of HBCD use is committed.
One area where VECAP has been criticised is in the transparency of its emission figures. Its first report included only percentage reductions of undisclosed deca-BDE baseline figures (ENDS Report 377, pp 18-19 ).
VECAP’s second report presented 2005 baseline figures in an unusual way: Examples of best and worst practice at the level of individual plants were used to derive potential maximum and minimum overall emissions for the EU6 countries - if all manufacturers followed best (or worst) practice.2 For textiles, these were between 45 and 140 kilograms per year, excluding the UK, and for plastics, between 15 and 100 kg/yr.
According to the third report, deca emissions from the plastics industry fell from 150 kg per year in 2006 to 95 kg per year in 2007 - again, for the EU6 countries. How these figures relate to the 2005 baseline is not clear. Meanwhile updated textiles industry emissions were not reported.
Although VECAP appears to be making progress, the inconsistent and incomplete presentation of results will do little to satisfy its critics and be an embarrassment for those who have praised it.
Environmental groups such as CHEMTrust have criticised VECAP for failing to address emissions from products. A 2003 risk assessment report on deca-BDE notes that "total emissions are dominated by the estimated emissions over the service life of products and disposal of products".
Another controversial aspect of VECAP is its data collection methodology, which relies on a mass balance calculation rather than actual measurement of emissions. Mass balance compares the amount of flame retardant arriving at the factory gate with the amount leaving in completed products.
Mr Adriaenssens maintains that in practice, mass balance figures correspond well with data subsequently collected from the local environment. In contrast, he suggests that direct on-site measurement of emissions is unreliable, highly variable and misleading.
VECAP is working on a third-party independent verification with consultancy Bureau Veritas, which may succeed in increasing the scheme’s credibility. Full-scale trials are expected later this year, while 50% of deca-BDE use is scheduled to be independently verified by 2010.