Mesothelioma Awareness: Asbestos and Occupational Safety

by Sarah Wallace, Mesothelioma + Asbestos Awareness Center

For many years, the natural mineral known as asbestos was used in constructing buildings, insulation, roofing, and homes. Asbestos is heavily regulated in the United States today, but many people are still exposed daily to asbestos containing materials (ACMs) that still exist in buildings, structures, and homes. During demolition, DIY, or renovation projects, asbestos can become friable and people are then susceptible to inhaling the small fibers. When asbestos becomes lodged in the body, specifically in the lining of the lungs, abdomen, or heart, it can lead to lung cancer or mesothelioma.

Even though the use of asbestos has decreased dramatically in the United States since the late 20th century, mesothelioma is still the leading occupational cancer. This is because the disease can take up to 50 years to develop, and those who were exposed to asbestos prior to the 1980s are still being diagnosed today. On top of that, professionals who work in different industries that have a history of asbestos use, such as construction, manufacturing, and shipyard work, are still at risk of exposure they may come into contact with materials and products made before regulations were put in place. Due to the microscopic size of asbestos fibers and ambiguity around where the toxin could have been used in the past, it’s important for workers to stay educated on where asbestos might be hiding and what safety precautions to take on the job.

Occupations most at risk and how to stay safe:

Construction Workers– Because asbestos was used heavily in the construction of homes and other buildings, many construction workers have been exposed to asbestos, and they are still at risk for exposure. With ACMs still existing in buildings, approximately 1 million construction workers could still be vulnerable to asbestos annually. Today, professionals in the construction industry are at risk for first-hand exposure more than any other profession. Workers in multiple trades including roofers, carpenters, electricians, and masonry should be aware of asbestos as they work.

In order for workers to protect themselves, professionals in these fields should take the precaution of wearing the proper masks during any type of construction project. Understanding the age of the building and what asbestos looks like is also important because this could help workers know the risks associated with a certain structure, making them less vulnerable to exposure. Keep in mind that asbestos can exist in a variety of products including drywall, shingles, ceiling tiles, and insulation, so even those participating in DIY projects should be aware of where their health and safety could be at risk.

Firefighters– Asbestos fibers can be released into the air when a building or home catches on fire. This puts first responders like firefighters in danger of inhaling the toxin in the process of putting out a fire. This leaves firefighters at risk to develop peritoneal mesothelioma, which originates in the lining of the lungs after being inhaled.  While the initial danger to firefighters is the fire itself, even after the flames are put out, asbestos could be present in the air as the structure cools off. Firefighter equipment is designed to keep out hazardous materials like asbestos, but many people do not understand that certain risks persist even after the initial fire is put out. Asbestos fibers can attach to clothing, leading to the possibility of second-hand exposure for those who might come in contact with any type of clothing used at the scene of the fire.

In order to limit exposure to asbestos particles, firefighters should wear a certified self-containing breathing apparatus (SCBA) mask that covers the mouth and nose in order to protect themselves while on the job. They should also keep masks on even after the fire has been put out while debris is cooling, because asbestos fibers could still be in the air. To eliminate risks of exposure for family, friends, and colleagues, firefighters should also remove their gear before leaving the scene and wash off before returning home.

 Shipyard Workers– At one time, asbestos exposure was a large risk for laborers and those employed on ships. Due to the mineral’s strong and heat resistant attributes, was often used for things like boilers and steam pipes on Navy ships and shipyards. As a result, many shipyard laborers were exposed to asbestos, especially if they worked as electricians, painters, machinists, or “asbestos insulators.” This is one of the reasons veterans make up about 30 percent of mesothelioma diagnoses in the United States.

Shipyard workers are less likely to be exposed first-hand to asbestos today, but anyone working with older shipbuilding materials or piping should be aware of the possible risks and wear the appropriate masks to limit inhaling fibers. Workers who have been exposed in the past should let their primary care doctor know and stay up-to-date on appointments. Symptoms of mesothelioma specifically can often go undiagnosed because they are similar to symptoms of the flu, manifesting as a cough at first and eventually leading to shortness of breath and fever. If you know that you have been exposed, paying careful attention to your health and communicating with your doctor could lead to an early diagnosis, improving prognosis and life expectancy.

Preventing asbestos-related disease

 If you come across asbestos on the job, contacting a professional who knows how to handle the material will be the best way to move forward. No amount of asbestos exposure is safe, and handling the mineral should be taken seriously before proceeding with a project. Mesothelioma is a deadly but preventable cancer, if the correct steps are taken by employers and employees. Although asbestos has been heavily regulated over time, there is still not a ban on the material in the United States. Taking the time to check labels before using any products and educating others in your industry on how to protect themselves are sure ways to help bring an end to mesothelioma and other health issues caused by asbestos.

 

New U.S. EPA e-Manifesting System Took Effect June 30th

By Laura Ragozzino, Cohen & Grigsby P.C.

The U.S. Environmental Protection Agency (the “EPA”) launched its new Hazardous Waste Electronic Manifest (“e-Manifest”) System on June 30, 2018. The new requirements impact all U.S. companies that handle waste requiring a Resource Conservation and Recovery Act (“RCRA”) manifest, a regulated universe that includes approximately 150,000 entities across at least 45 industry segments. Under the new rules, regulated waste handlers will need to use the new paper or electronic EPA manifest form and waste receiving facilities will have to submit the new manifests to the e-Manifesting system, incurring a processing fee.

The goal of the new e-Manifesting system is to reduce costs and improve regulatory oversight and data quality. The EPA estimates that the manual processing and documentation of paper manifests costs regulators and companies $193 million to $400 million annually.

RCRA is the federal law that creates the framework for managing hazardous and non-hazardous solid waste. Since 1980, the EPA has required a RCRA manifest, a multi-copy paper form, to track hazardous waste from the time it leaves the generating facility until it reaches the off-site waste management facility that will store, treat, or dispose of it. The manifest helps the EPA verify proper waste handling.

E-Manifest requirements are effective in all states on June 30, 2018. These requirements apply to domestic hazardous waste (as defined at the federal and state level) and state-only regulated waste subject under state law to RCRA hazardous waste manifesting. The e-Manifesting system is a product of the 2012 Hazardous Waste Electronic Manifest Establishment Act and subsequent February 2014 and January 2018 final rulemakings. Starting June 30, receiving facilities are required to submit copies, whether electronic or paper, of RCRA waste manifests to the EPA within 30 days of receipt. Receiving facilities will also incur a processing fee for manifest submittal. In three years, paper manifests will be phased out of use.

The new requirements fall under RCRA enforcement policy. Noncompliance with RCRA, including improper manifesting, exposes waste handers to substantial civil penalties.

Before this e-Manifesting system’s implementation, shipments of waste across state borders could create jurisdictional issues for states with enhanced regulatory requirements. Some states impose manifesting requirements that are more stringent than RCRA’s rules, or define hazardous waste more broadly than under RCRA. When waste generated in these more stringent states was disposed of in less stringent states, the generating state lacked the ability to enforce the receipt of manifest copies from out-of-state receiving facilities. For example, if a disposal site in Ohio received waste oil from Connecticut that was classified as hazardous under Connecticut law but not classified as hazardous under Ohio law, then the Ohio disposal facility may or may not have submitted the manifest to Connecticut, and Connecticut did not have the ability to enforce its collection.

Now, under the 2012 Hazardous Waste Electronic Manifest Establishment Act, federal and state regulators can access complete cradle-to-grave waste manifesting records from the e-Manifest system because submitting manifests is compulsory. For example, as of June 30, 2018, if a disposal site in Ohio receives waste oil from Connecticut that is classified as hazardous under Connecticut law but not classified as hazardous under Ohio law, then the Ohio disposal facility must submit the manifest to the e-Manifest system, even if Ohio law does not require such submittal.

On or after June 30, waste generators, transporters, receivers, and disposers of waste regulated by the new regulations must track the waste on the new paper or electronic manifest, U.S. EPA Form 8700-22, and submit the manifest to the e-Manifest system. The EPA granted an initial extension of the 30-day manifest-receipt deadline for paper manifests received from June 30, 2018 through September 1, 2018. With this extension, receiving facilities may submit those manifests on or before September 30, 2018.

What Generators and Transporters Need to Know

Waste handling facilities should review the waste and manifest requirements that pertain to their business. It is important to understand the laws and regulations of the generating and receiving state. Any waste defined as hazardous by the generating or receiving state, or any waste requiring tracking on a RCRA manifest (i.e., a hazardous waste manifest), is subject to the e-Manifesting requirements.

Generators have the option to create and submit manifests electronically or to submit paper manifests to the e-Manifest system. The existing 6-copy manifest is being replaced with a new 5-copy form that must be ordered from a registered printer.

What Receiving and Disposal Facilities Need to Know

The new manifesting requirements will impact both RCRA-permitted disposal facilities (i.e., Treatment, Storage, and Disposal Facilities (“TSDFs”)) and non-TSDFs when such facilities receive waste that is either (1) non-hazardous but requires a RCRA manifest, or (2) is hazardous under the generating state’s laws and regulations. Therefore, the new e-Manifesting system extends the scope of regulatory obligations under federal law even if the law of the receiving state does not require a RCRA manifest for the waste at issue.

Receiving and disposal facilities must submit all RCRA manifests, paper or electronic, to the EPA. Receiving facilities need to obtain an EPA Identification number to use the e-Manifest system. To obtain an EPA ID number, facilities must submit EPA’s Site Identification form (U.S. EPA form 8700-12). EPA will charge receiving facilities a fee for each manifest submitted. Fees, which are differentiated based on how the manifest is submitted, are projected to range from $4 to $20. Late payments are subject to interest penalties.

EPA Resources:

This article was first published at the Cohen & Grigsby website.  To help its clients better understand the most efficient and cost-effective means of compliance, Cohen & Grigsby will continue to monitor this issue. If you have any questions, please contact Laura Ragozzino at (412) 297-4713 or lragozzino@cohenlaw.com.

________________________________

About the Author

Laura Ragozzino is regulatory compliance and environmental attorney for Cohen & Grigsby P.C.  She practices out of the firm’s Pittsburgh offices.

Ms. Ragozzino is an energetic counselor with proven success mitigating compliance risk. She practices in the areas of administrative law, energy law, EHS law, and government and regulatory affairs. She is passionate about building a compliance culture based on mutual respect for engineering, operations, and the regulations that govern their activities.

Ms. Ragozzino manages complex issues with federal, state, and local agencies to achieve results exceeding her business clients’ expectations. She brings creative, detail-oriented, and tactical thinking to the table to find effective and appropriate compliance solutions across industry sectors.

Nano-Scale Selective Ion Exchange used to Remove Radioactive Contamination from Water

Researchers from the University of Helsinki in Finland recently reported that they have developed a new method to remove radioactive contamination from water.  They claim their method of nano-scale selective ion exchange is faster than the conventional method and more environmentally-friendly as less radioactive solid waste is produced.

Risto Koivula, researcher at the University of Helsinki

The new method of selective ion exchange uses electrospun sodium titanate.  Electrospinning is a fibre production method which uses electric force to draw charged threads of polymer solutions or polymer melts up to fiber diameters in the order of some hundred nanometers  “The advantages of electrospun materials are due to the kinetics, i.e. reaction speed, of ion exchange,” says Risto Koivula, a scientist in the research group Ion Exchange for Nuclear Waste Treatment and for Recycling at the Department of Chemistry at the University of Helsinki.

One conventional method of removing radioactive ions from water is using granular sodium titanate as an ion exchange medium.  It is currently used to treat the 120,000 cubic meters of radioactive wastewater generated as a result of the Fukushima, Japan nuclear accident.  As radioactive wastewater is run through the ion exchanger, the radio-active ions are exchanged with the sodium in the sodium titantate.  The radioactive pollutants remain bound by the granules in the ion exchange unit.

Sodium Titanate fibres

The advantage of sodium titanate over other ion exchange media is that it is selective, which means that it is picks out only the radioactive ions from the water.  One disadvantage of ion exchange is that a water pollution problem is being transferred into a waste management problem.  When the ion exchange capacity is filled, the filtering material has to be switched out.  This leaves solid radio-active waste which must be managed.

The utilization of electrospun sodium titanate results in nano-scale spindles.  The result is an ion exchange solution that occupies less space but provides an equal treatment capability.  “Since less electrospun material is needed from the start of the process, the radio-active waste requiring a permanent repository will also fit in a smaller space,” says Koivula.

The electrospinning equipment at the University of Helsinki was developed and built in the Centre of Excellence for Atomic Layer Deposition, led by Mikko Ritala. The researchers successfully tried this quite simple method for working sodium titanate into fibre.  Koivula’s team studied the ion exchange features of fibre produced this way and found it worked like the commercially produced ones.

The utilization of this selective ion exchange method could be applied to the sites with groundwater contaminated with radioactive ions.

In Canada, the Town of Port Hope (located approximately 100 km east to Toronto) has over 1 million cubic metres of low-level radioactive waste as well as radioactive waste in treatment ponds.  The source of the radioactive contamination is the historic operation of the former radium and uranium refining activities of Eldorado Nuclear.  The wastewater treatment facility at Port Hope is a two-stage process that removes salts, heavy metals, and contaminants such as radium and arsenic.  The process involves chemical precipitation with clarification followed by reverse osmosis.

Canadian Government Announces Action on Pollution Prevention and Toxic Chemicals

The Canadian government recently issued a press release which states that it is undertaking actions to strengthen Canada’s approach to managing harmful substances and is committing to reform the Canadian Environmental Protection Act, 1999. The announcement is in response to a 2017 report issued by the House of Commons’ Standing Committee on Environment and Sustainable Development (“Standing Committee”) that entitled “Healthy Environment, Healthy Canadians, Healthy Economy: Strengthening the Canadian Environmental Protection Act, 1999”.

The 2017 report issued by the Standing Committee made 87 recommendations to the federal government, including prohibiting substances of very high concern unless industry can prove the substances can be used or emitted safely and there are no feasible substitutes; ensuring that vulnerable people are taken into consideration when the government assesses and manages new substances; implementing timelines throughout the Act to oblige action on toxic substances; and facilitating public participation in environmental decision-making and in enforcement of the Act.

At the time of the release of the 2017 report, the Committee Chair Deb Schulte stated, “The Act has now been in place for almost three decades. It is time to bring it into the 21st century by taking into account new scientific knowledge and evolving concepts in environmental law.”

Photography of Factory https://www.pexels.com/photo/photography-of-factory-929385/The Government of Canada is taking action to implement many of the Committee’s recommendations including:
• The development of a policy framework for considering vulnerable populations—such as children, pregnant women, and the elderly—in the assessment and management of chemicals;
• Action to protect Canadians from chemicals of high concern, such as endocrine disruptors, which can affect how hormones work and lead to long-term health issues; and
• Updating standards and developing new instruments to improve air quality and reduce air pollution from industrial sources, including oil refineries.

As a first step in the legislative reform of the Canadian Environmental Protection Act, 1999 and updating of Canada’s Chemicals Management Plan, the Canadian government will conduct a thorough review and consult with various groups

Couple admits illegally storing 4,500 tons of hazardous waste in warehouse

As reported in the St. Louis Post-Dispatch, a husband and wife recently plead guilty to a U.S. federal charge and admitted improperly transporting 4,500 tons of hazardous waste and storing it in a warehouse near St. Louis, Missouri.

The couple, both in their 60’s, pleaded guilty in U.S. District Court in St. Louis to a misdemeanor charge of placing someone in danger of death or serious bodily injury from a hazardous waste.

Green Materials LLC facility in Missouri (Photo Credit: Robert Patrick, Post Dispatch)

Their company, Missouri Green Materials LLC, Missouri Green Materials LLC stored a large quantity of spent sandblasting materials inside a warehouse located in the town of Berger, approximately 70 miles west of St. Louis.  They couple admitted that they arranged for the transport and storage of the hazardous waste from Mississippi, and failed to tell both the trucking companies that hauled the waste and the personnel that unloaded it of the danger.  Their storage facility was not properly permitted was not registered as a permitted hazardous waste storage or recycling facility.

The sandblasting waste materials are considered to be hazardous because they contain amounts of certain metals, including cadmium, that exceed regulatory limits established by the Missouri Department of Natural Resources and the U.S. Environmental Protection Agency (U.S. EPA).

The materials were stored in a warehouse in a flood plain for more than four years.  There are no indications of any release of the materials from the warehouse.

The couple have agreed to pay $1.5 million to the U.S. EPA for the costs of dealing with the waste. They could face probation or a sentence of six months behind bars for the crime under federal sentencing guidelines.

The source of the sandblasting waste was for a site in Mississippi.  An Ohio company, U.S. Technology Corp had been buried the waste.  The company was repeatedly ordered by regulators to remove it.

In 2016, the U.S. EPA and U.S. Technology signed a consent agreement whereby the company agreed to remove the waste from Green Material’s facility in Missouri and test the site for soil contamination.  According to prosecutors, this work was never performed.

U.S. Technology and president Raymond Williams, 71, both pleaded not guilty in the case. A hearing has been scheduled to change both pleas later in June.

Some sandblasting waste is classified as hazardous

Medical Waste Management Market predicted to reach $16.35 billion by 2023

According to the new market research report by IndustryARC, the world-wide medical waste management market is predicted to reach $16.35 billion by 2023.  The report, entitled “Medical Waste Management Market by Waste Type (Biomedical, Cytotoxic, Pharmaceutical, Genotoxic, Radioactive); by Treatment Technology (Thermal, Irradiative, Biological, Mechanical) – Forecast (2018-2023)”, provides useful insights and predictions on the medical waste management market. 

The report predicts that the North American medical waste market is expected to reach revenue of $6,077.7 million by 2023 at a compound annual growth rate (CAGR) of 5.1%.  It states that the North American market is driven by growing number of healthcare facilities.  The reports sties the reason for growth in North America is due to large amount of medical waste produced and effective management of the waste with the use of advanced technologies.  Hospitals have a major share in the market due to the amount of hazardous waste generated per day.  In the US, many organisations provide services to the healthcare facilities.  The government has been levelling fines on such hospitals in the region, if the infection rate is high.  This factor increases more number of companies in the market.

With respect to incineration of medical waste, the report states that the incineration segment had revenue of $3,851 million in 2015.  The report predicts revenue in the medical waste incineration sector to reach $5,627 million by 2023 at a CAGR of 4.3%.  The report defines incineration as the process of burning waste materials which are hazardous, at higher temperatures for eliminating contaminants.  In this process, toxic elements are burnt and the ash is disposed into landfills.

All Hazards Waste Management Planning (WMP) Tool

The U.S. EPA recommends that communities have a Waste Management Plan (WMP) that addresses the management of waste generated by all hazards, particularly from homeland security incidents ranging from natural disasters and animal disease outbreaks to chemical spills and nuclear incidents to terrorist attacks involving conventional, chemical, radiological, or biological agents.

This tool is intended to assist emergency managers and planners in the public and private sectors in creating or updating a comprehensive plan for managing waste generated from man-made and natural disasters. The tool walks the user through the process of developing and implementing a plan. The tool also contains many resources that can be used as aids to various aspects of the planning process. View and use at https://wasteplan.epa.gov.

Ontario Transitioning Municipal Hazardous Waste Program

The Ontario Minister of the Environment and Climate Change recently issued direction to Stewardship Ontario (SO) to wind up the Municipal Hazardous or Special Waste Program by December 31, 2020. This wind up will allow the transition of materials collected under the program to individual producer responsibility under the Resource Recovery and Circular Economy Act, 2016.

The Minister’s letters can be found at:

Information related to the program wind up and future consultations will be posted to the Program Wind Up page when available. Until the wind up date, the Municipal Hazardous or Special Waste Program will continue to operate without disruption. This includes the operation of the Industry Stewardship Plans managed by the Automotive Materials Stewardship, the Product Care Association and SodaStream.

The Ontario Municipal Hazardous or Special Waste Program recycles or properly disposes of paint, antifreeze, batteries, fertilizers and other hazardous or special materials.  These wastes will continue to be managed in Ontario, but under a new program.  The winding down of the existing program is part of the provinces attempt to shift to a circular economy – a new waste management approach where waste is seen as a resource that can be recovered, reused and reintegrated into the production stream.

Ontario’s new waste management framework includes new legislation and a strategy to guide progress that will protect the environment, drive innovation, performance and competitiveness, and stimulate economic growth and development.

 

Using GPS trackers to fight toxic soil dumping

As reported by the CBC News and the Montreal Gazette, the Province of Quebec and the City of Montreal are joining forces to try to crack down on a possible link between organized crime and the dumping of contaminated soil on agricultural land.

The solution? A GPS system that can track where toxic soil is — and isn’t — being dumped.

According to the province, there are about two million metric tonnes of contaminated soil to be disposed of every year.

Toxic soil is supposed to be dumped on designated sites at treatment centres. But the Sûreté du Québec has confirmed it believes members of organized crime have been dumping soil from contaminated excavation sites onto farmland.

Quebec Provincial police confirm they are investigating a possible link between organized crime and the dumping of contaminated soil.

“It’s a constant battle. The city and all municipalities have to be very vigilant about any types of possible corruption,” said Montreal Mayor Valérie Plante.

“What we are talking about today supports a solution, but again, we always have to be proactive.”

The new pilot project, called Traces Québec, is set to launch in May. Companies would have to register for the web platform, which can track in real time where soil is being transported — from the time it leaves a contaminated site to the time it’s disposed of.

Some environmentalists say they’re concerned about the impact the toxic soil has had on agricultural land where it’s been dumped. They’re also uncertain about how a computerized tracking system will put an end to corruption and collusion.

“Right now, there’s no environmental police force in Quebec so there have been investigations into these toxic soils being dumped but unfortunately nobody’s been held accountable yet,” said Alex Tyrrell, leader of the Quebec Green Party.

“There’s really a lack of a coherent strategy for how Quebec is going to decontaminate all of these different toxic sites all over the province. There’s no announcement of any new money.”

The city and the province say this is a first step at addressing the issue and more announcements will be on the way in the coming months.

The pilot project — a joint effort with the city of Montreal — will test a system, known as Traces Québec, that uses GPS and other technologies to track contaminated soil. The first test case will involve a city plan to turn a former municipal yard in Outremont into a 1.7-hectare park. Work is to start in the fall.  All bidders on the project will have to agree to use the Traces Québec system.

Using the system, an official cargo document is created that includes the soil’s origin and destination and its level of contamination. Trucks are equipped with GPS chips that allow officials to trace the route from pickup to drop-off.

Mayor Valérie Plante said the pilot project is “a concrete response to a concrete problem.”

She said she wants to protect construction workers and residents by ensuring contaminated soil is disposed of properly. The city also wants to make sure the money it spends on decontamination is going to companies that disposed of soil safely and legally.

“Municipalities have to be very vigilant about any types of possible corruption,” she said. “We know there are cracks in the system and some people have decided to use them and it’s not acceptable.”

Plante said Montreal will study the results of the pilot project before deciding whether to make the system mandatory on all city projects.

The Traces Québec system was developed by Réseau Environnement, a non-profit group that represents 2,700 environmental experts.

Pierre Lacroix, president of the group, said today some scofflaws dispose of contaminated soil illegally at a very low cost by producing false documents and colluding with other companies to circumvent laws.

He said the Traces Québec system was tested on a few construction sites to ensure it is robust and can’t be circumvented. “We will have the truck’s licence plate number, there will be GPS tracking, trucks will be weighed,” Lacroix said.

“If the truck, for example, doesn’t take the agreed-upon route, the software will send an alert and we’ll be able to say, ‘Why did you drive that extra kilometre and why did it take you an extra 15 minutes to reach your destination?’”

Organized crime can be creative in finding new ways to avoid detection and Lacroix admitted “no system is perfect.”

But he noted that “at the moment, it’s anything goes, there are no controls. Technology today can help take big, big, big steps” toward thwarting criminals.

With files from CBC reporter Sudha Krishnan

How the GPS tracking system will work

Recycling end-of-life materials may be perpetuating toxic chemicals in new products

A researcher from the Canadian Environmental Law Association and paralegal, Fe de Leon, recently co-published a paper with HEJSupport International Co-Director Olga Speranskaya to bring public attention to toxic chemicals that appear in new products made out of recycled materials.  The authors of the paper argue that many countries have made investments into achieving progress towards a circular economy, but little or no attention is paid on toxic chemicals that appear in new products made out of recycled materials. The paper cites a growing body of evidence of how a circular economy fails to address concerns regarding toxic chemicals in products.

Fe de Leon, Researcher and Paralegal, CELA

In the paper, the authors cite a 2017 study prepared by IPEN, an environmental activist organization that focuses on synthetic chemicals, which revealed elevated concentrations of globally targeted toxic flame retardants in plastic toys.  The IPEN study claimed to have found elevated concentrations of toxic persistent organic pollutants (POPs) in samples of plastic toys purchased in different stores in Canada and other 25 countries globally.  The study further stated that the levels of some chemicals were more than five times higher than recommended international limits.  These chemicals include PBDEs (polybrominated diphenyl ethers) such as octabromodiphenyl ether (OctaBDE), decabromodiphenyl ether (DecaBDE); and SCCPs (short chain chlorinated paraffins).  They are listed under the Stockholm Convention on Persistent Organic Pollutants and are internationally banned or restricted due to their hazardous characteristics.  They all are persistent, highly toxic, travel long distances and build up in the food chain.  However, their presence in new products, although they are banned or restricted, opens up the discussion of a problem regarding recycling as a key component of a circular economy.

The paper concludes that product recycling and a focus on a circular economy should be encouraged.  However, material flows should be free from hazardous chemicals, at the minimum those chemicals which have already been regulated under the international treaties.

Olga Speranskaya, HEJSupport International Co-Director, IPEN CoChair