NAFRA Comments on Canadian Regulatory Proposal for DBDPE
Proposed Restrictions Are Not Supported by the Best Available Science
WASHINGTON (May 18, 2022) — The American Chemistry Council’s (ACC) North American Flame Retardant Alliance (NAFRA) issued the following statement in response to the regulatory proposal from Environment and Climate Change Canada (ECCC) and Health Canada (HC) to restrict decabromodiphenyl ethane (DBDPE), a flame retardant used to meet flammability standards and performance requirements in a wide range of products, including automotive, aerospace, home appliances, electronics, and coatings for wire and cable.
“Flame retardants are an essential tool for meeting fire safety standards and keeping people and property safe. Removing DBDPE from the Canadian market is unwarranted based on the data provided by manufacturers and the lack of available alternatives. As such, NAFRA is extremely disappointed in this decision and will continue to support the product’s continued use to enhance fire protection.
“Canada’s regulatory proposal for DBDPE is not supported by the state of the science, does not align with global regulations, and has the potential to create inconsistencies and disruptions for the North American supply chain. Fire safety is a critical public health issue, and flame retardants such as DBDPE are an important tool to help protect the public from the dangers posed by fire.
“Dozens of studies have been submitted demonstrating that DBDPE is safe for its intended use. In addition, a study commissioned by ECCC found that the costs of prohibiting DBDPE remain uncertain because suitable alternatives do not exist for some critical product applications. More recently, new information has been shared with ECCC refuting assumptions that have been made regarding degradation of DBDPE in the environment. The best available science and information does not support the regulatory actions proposed by ECCC and HC.
“The proposed regulation is an outlier globally and would be the first to place such broad restrictions on the use of DBDPE. It is also inconsistent with the U.S.-Mexico-Canada Agreement (USMCA), which requires a risk-based approach to chemical regulations. Limiting the use of a fire safety tool that is not restricted in other jurisdictions has the potential to cause unnecessary supply chain disruptions that could affect businesses and consumers.
“Product manufacturers balance consumer demand for smaller, lighter, and more powerful products with the need to ensure that those devices meet performance and safety standards. One of the most important benefits of flame retardants in product design is they can stop small ignition events from turning into larger fires.1,2,3
“Safety is a top priority for our industry. Our members invest significant resources in product and environmental stewardship and advocate for advancing the safety of the products they produce and sell. We encourage product manufacturers, suppliers, and designers to weigh-in with ECCC regarding the use of DBDPE to meet safety standards as part of an overall effort to protect consumers. NAFRA looks forward to continued engagement with the Canadian government to properly apply a weight of the evidence approach in considering any regulations for DBDPE.”
1 Knapp, G., The Analysis of the Transition from Smoldering to Flaming in Polyurethane Containing Assemblies Representative of Upholstered Furniture, 2019. https://drum.lib.umd.edu/bitstream/handle/1903/25190/Knapp_umd_0117N_20336.pdf
2 Blais, M.S., Carpenter, K. & Fernandez, K. Comparative Room Burn Study of Furnished Rooms from the United Kingdom, France and the United States. Fire Technol 56, 489–514 (2020). https://doi.org/10.1007/s10694-019-00888-8
3 Blais, M., Carpenter, K. Combustion Characteristics of Flat Panel Televisions with and Without Fire Retardants in the Casing. Fire Technol 51, 19–40 (2015). https://doi.org/10.1007/s10694-014-0420-7