BSEF response to publication ““Ecotoxicological characterization of possible degradation products of the polymeric flame retardant “Polymeric FR” using algae and Daphnia OECD tests”

BSEF notes the recent publication titled “Ecotoxicological characterization of possible degradation products of the polymeric flame retardant “Polymeric FR” using algae and Daphnia OECD tests” by C. Koch and B. Sures[1].

In an earlier study, Koch et al subjected Polymeric FR to a series of degradation experiments. Under unrealistic conditions, which do not represent normal conditions of use, the study found a range of degradation products (ca. 75) and identified 3 potential degradation products[2].

A follow up study by the same authors[1] subjected these 3 degradation products of Polymeric FR to several standard OECD ecotoxicity tests. The study also tested a 4th substance, which was not found in the above study.

The study did not find any meaningful acute effects.” said Dr Kevin Bradley, BSEF Secretary General. “The authors themselves indicate thatIf at all, effects can only be found at extremely high concentrations, which are presumably not to be expected following degradation of “polymeric FR”

In a chronic test the authors find an effect level when testing a mix a 4 substances[3]. However, using a worst case scenario where these products may reach the environment the authors conclude that environmental levels are about 10 000 times lower than their effect level, so no risk is to be expected. Moreover, they conclude that “…with proper precautional care (sic), such products might never end up in the environment”.

Dr Bradley further noted “It is regrettable that these results were not discussed in the first (degradation) paper by the same authors. This would have helped putting the results into context. Unfortunately, the authors decided to not mention this in the paper, despite the fact that the results were available at the time. This would have allowed the reader to draw his conclusions based on the full picture.”

About BSEF

BSEF is the international bromine producers organisation. Since 1997, the organisation has been working to foster knowledge on the uses and benefits of bromine-based solutions. BSEF strongly believe in science and innovation. Through investments in research and development BSEF members create robust bromine-based technologies meeting the needs of society. The members of BSEF are Albemarle Corporation, ICL Industrial Products, Lanxess and Tosoh Corporation.

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[1] Science of the Total Environment 656 (2019) 101–107

[2] 5-bromosalicylic acid, 2,4,6-tribromo-3-hydroxybenzoic acid, and 3,5-dibromo-4-hydroxybenzoic acid

[3] An EC50 value of 187 ug/L per substance