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A report for
Department for Environment, Food and Rural Affairs
September 2010
A Study to Facilitate the Implementation of the Waste Related Provisions of
Regulation (EC) No 850/2004 on Persistent Organic Pollutants
Appendix
This report has been prepared by: Dr Adrian Chapman, Dr Helmut Sengstschmid, Dr Hüdai Kara and Mr Stefan Posner Checked as a final copy by: Lesley Maddox Reviewed by: Nicholas Morley Date: 17th September 2010 Contact: [email protected] File reference number: DEFR01 236 final.doc
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For Defra
Glossary
ABS Acrylonitrile Butadiene Styrene ASR Automotive Shredder Residue BFR Brominated Flame Retardant Congeners A group of chemicals which have different chemical formulas, but have related
properties and structural features. CRT Cathode Ray Tube (a specific type of VDU) HBCD Hexabromocyclododecane HIPS High Impact Polystyrene Isomers A chemical compound with the same formula, but different molecular structure PBDE Polybrominated diphenyl ether PCB Printed Circuit Board PFOS Perfluorooctane Sulphonic Acid POPs Persistent Organic Pollutants PS Polystyrene PUR Polyurethane TBBA Tetrabromobisphenol-A VDU Visual Display Unit Units Conventional SI units and prefixes used throughout: {k, kilo, 1000} {M, mega, 1,000,000} {G, giga,
109} {kg, kilogramme, unit mass} {t, metric tonne, 1000 kg}
For Defra
(Left Blank)
Appendix
1 Supplemental data for PBDEs
2 Supplemental data for PFOS
1 Supplemental data for PBDEs
1.1 Additional information on methodologies
1.1.1 Description of Methodology - C-PentaBDE
Calculation of UK c-pentaBDE consumption was carried out as follows:
An estimate of historic European c-pentaBDE consumption was used as the basis for this model. a This information presented a model for the maximum, minimum and average concentrations of c-pentaBDE consumption. Where possible this data was cross-checked with values from other sources to confirm its reliability. The range of data was extended to 2010 based on the existing trend, and taking into account the ban in 2004.
Exports from the UK of products containing PBDEs are not accounted for by these figures. However, EU production ceased in 1998, and there is no evidence that the export of finished products containing PBDEs significantly reduced the UK inventory of these substances. Therefore this assumption is not expected to significantly alter the estimations.
Maximum, minimum and average c-pentaBDE UK consumption figures were estimated from this by using ratio of UK GDP compared to Europe. This provided a range of c-pentaBDE consumption values over the conceivable timescale for product lifetimes.
The concentration of c-pentaBDE in relevant waste streams was calculated using the following methodology:
Based on the information in various reports, it was assumed that all use relevant to current waste arisings occurred in flexible PUR foams, and the quantities used for other applications were assumed to be insignificant.
It was estimation that split of c-pentaBDE use in UK in the 2000s (the most relevant time period found) was 68% automotive, 31% furniture and mattresses. Different scenarios were constructed for these applications.
The remaining 1% is assumed to be used for applications such as packaging. Based on the weight of c-pentaBDE this represented, the lifetime of packing, and the EU ban in 2004, it was assumed none was now entering the waste stream from these sources. Other sources include rebounded PUR from off-cuts; again it has been assumed this presents a very small level of use and concentration in waste.
The scenario for automotive PUR was constructed following this methodology:
Relevant data, such as average ages and materials compositions, was obtained for UK vehicles. The fate of PUR foam in vehicles was discussed with industry representatives. It was found that at the current time PUR foam is not recovered and forms part of the general automotive shredder residue (ASR) which is used for landfill covering.
Average concentrations for c-pentaBDE in ASR were calculated based on figures gathered. A further estimate was made of the concentration PUR foam if separation is initiated.
The concentration in furniture waste was estimated using the following methodology:
Relevant data, such as average ages and materials compositions, was obtained for the UK furniture industry.
This was used to estimate the average concentration of c-pentaBDE in PUR foam in furniture waste.
The most common end-of-life fate was determined to be landfill with a small amount of energy recovery. Other options such as reuse and remanufacturing were considered.
a Estimation of the Production, Consumption, and Atmospheric Emissions of Pentabrominated Diphenyl Ether in Europe between 1970 and 2000, K. Jones et al,
Environmental Science and Technology, 2004.
1.1.2 Description of Methodology - C-OctaBDE
The concentration of c-pentaBDE in relevant waste streams was calculated using the following methodology:
In the case of c-octaBDE a model had to be generated from scratch using bromine production and fire retardant use. Other methods were investigated such as modelling the use of antimony trioxide (used in combination with BFRs), however, these were unable to produce a satisfactory model. The steps below outline the basic methodology used based on world bromine production:
Historic world bromine production was obtained from the US Geographical Survey. This data, as well as other information from the OECD, contained data points indicating the percentage of bromine used for all BFRs. Where data was incomplete linear trends were drawn between data points.
Based on industry data it assumed that the three major BFR types (PBDEs, TBBA, HPCD) consumed 50% of the total bromine used for BFRs. Using the different bromine contents of each of these flame retardants (averages taken for c-pentaBDE, c-octaBDE and c-decaBDE) and known historical trends, the percentage of this bromine used to produce c-octaBDE was estimated. This information allowed the historic production of c-octaBDE to be modelled.
A historic profile of EU c-octaBDE consumption was modelled, based on figures available from BSEF and EU data. The UK consumption was then calculated based on GDP ratio.
Exports from the UK of products containing PBDEs are not accounted for by these figures. However, EU production ceased in 1998, and there is no evidence that the export of finished products containing PBDEs significantly reduced the UK inventory of these substances. Therefore this assumption is not expected to significantly alter the estimations.
This information was then used to calculate the concentration of c-octaBDE in relevant waste streams the
following methodology:
Based on information available in various reports all c-octaBDE occurring in waste was assumed to originate from TV and monitor housings. It was also assumed that the majority was used in CRT type products due to the banning of c-octaBDE in the EU in 2004 which coincides with the switch from CRT to flat screen technology. Any c-octaBDE arising in flat screen television and monitor casings is assumed to be sufficiently small to be diluted to safe levels in WEEE. Similarly, concentrations in other WEEE were assumed to be insignificant, and again any preset will be in very small quantities and be diluted into the general plastics/waste streams. This assumption is supported by data obtained from the waste industry. a
It was assumed that all end-of-life CRTs are treated according to existing legislation (i.e. none ending up in landfill or illegally exported). Data was gathered for the usage of CRT based screens in the UK, resulting in the waste stream being separated into two categories: televisions and other displays, and computer monitors. This differentiation was necessary as these products had different lifespans and plastic weights associated with them. bc As CRTs based screens are treated separately from other WEEE, the concentrations calculated were based solely on the total arisings of waste plastic associated with these screens, rather than the generic WEEE plastics.
1.2 Trends in PBDE concentration in Waste Streams
1.2.1 C-pentaBDE in vehicle waste
a Personal communication, 2010. Information is commercially sensitive
b New Approach to Cathode Ray Tube Recycling, ICER 2003
c Develop a process to separate brominated flame retardants from WEEE polymers, WRAP, 2006
Table1: General information about UK vehicle scrappage (from discussions within industry ASR per vehicle (kg) 212*
PUR foam per vehicle (kg) 22.5*
Average vehicle life (years) 14**
Source: *Industry Representative,**SMMT data
Table 2: Predicted trends in ASR and PUR from vehicle waste, and quantity of c-pentaBDE it is estimated to contain.
Year of Manufacture
Vehicles Registered*
ASR (mega
tonnes)**
PUR Foam (tonnes)**
c-pentaBDE (tonnes)**
Mean Min Max
1996 2,020,000 430,000 45,400 65 105 85
1997 2,090,000 445,000 47,000 46 83 65
1998 2,240,000 477,000 50,400 25 56 41
1999 2,370,000 503,000 53,300 20 42 31
2000 2,340,000 498,000 52,700 17 27 22
2001 2,430,000 516,000 56,700 15 15 15
2002 2,710,000 576,000 61,000 16 16 16
2003 2,820,000 598,000 63,500 16 16 16
2004 2,820,000 599,000 63,500 16 16 16
2005 2,780,000 592,000 62,300 0 7 3
2006 2,600,000 553,000 58,500 0 7 3
2007 2,500,000 531,000 56,300 0 7 3
2008 2,540,000 539,000 57,200 0 7 3
2009 2,190,000 465,000 49,300 0 7 3
Source: *SMMT, **Oakdene Hollins estimates
The following trends were estimated from these figures. Figure 1: Estimated concentration of c-pentaBDE found in ASR in existing waste streams to 2020
Source: Oakdene Hollins estimates
0
50
100
150
200
250
300
2008 2010 2012 2014 2016 2018 2020 2022
c-p
en
taB
DE
in A
SR m
g/kg
Mean Min Max
Figure 2: Theoretical concentration of c-pentaBDE found in separated PUR foam found in vehicles in existing waste streams to 2020
Source: Oakdene Hollins estimates
1.2.2 C-pentaBDE in furniture waste
Table 3: Relevant data used for office and contact furniture.
Office Chair Contract Seating Contract Bedding
Sales (‘000s) 1,520 5,000 5,000
Value (£m) 159 360 579
Average Weight (kg)
18 28 25
Total weight (kg)
27,360 140,000 125,000
Weight of Foam (kg)
1 1* 7.5*
Total Foam (kg) 1,520 5,000* 375,000
Lifespan 5 5 5
*Estimated as half total fabric and foam value Source: Alistair Bromhead and Furniture Reuse Network Data
Table 4: Breakdown of weight of furniture and PUR foam used in PUR foam containing furniture for different sectors. This data is based on industry estimates of markets size and sales of different products.
Type Weight of assessed Furniture
(tonnes)
Percentage PUR
consumption
Weight of PUR foam (tonnes)
Percentage of PUR foam consumption
Lifespan
Contract & Offce 292,000
30% 425,00 40% 5 years
Domestic
677,000 70% 64,500 60% 10 years
Total 696,000 10,700
Source: Oakdene Hollins Estimates
0
500
1000
1500
2000
2500
2008 2010 2012 2014 2016 2018 2020 2022
c-p
en
taB
DE
in v
eh
icle
PU
R F
oam
mg/
kg
Mean Min Max
Figure 3: Estimated concentration of c-pentaBDE found in isolated PUR foam from furniture in existing waste streams to 2020.
Source: Oakdene Hollins estimates
Figure 4: Estimated concentration of c-pentaBDE found in isolated PUR foam from furniture in existing waste streams to 2020.
Source: Oakdene Hollins estimates
1.2.3 C-octaBDE in CRT housings
Table 5: General information about CRT based VDUs used to construct models. TV and Other Monitor
Lifespan* 12 years 5 years
Weight of plastic in housing**
1.7 kg 0.96kg
Source: *ICER and **WRAP
0
10
20
30
40
50
60
70
80
90
2008 2010 2012 2014 2016 2018 2020 2022
c-p
en
taB
DE
in w
aste
fu
rnit
ure
PU
R
Foam
mg/
kg
Mean Min Max
0
1
2
3
4
5
6
7
8
9
10
2008 2010 2012 2014 2016 2018 2020 2022
c-p
en
taB
DE
in a
ll w
aste
fu
rnit
ure
as
sess
ed
mg/
kg
Mean Min Max
Table 6: Estimate of historic production of different classes of CRT and corresponding c-octaBDE usage. Year of Production
Television + Other Monitors C-octaBDE (tonnes)
Sales (‘000s)
Waste Plastic (tonnes)
Sales (‘000s)
Waste Plastic (tonnes)
Mean
Min
Max
1998 6,100 10,000 2,000 1,900 293 262 321
1999 6,100 10,000 1,800 1,700 271 242 297
2000 6,100 10,000 1,700 1,600 180 161 198
2001 6,100 10,000 1,500 1,500 92 82 101
2002 6,100 10,000 1,300 1,300 62 55 68
2003 5,800 9,500 1,200 1,100 31 28 34
2004 5,500 9000 1,000 970 15 10 20
2005 5,200 8,500 840 810 10 5 15
2006 4,300 7000 670 650 5 0 10
2007 3,400 5,500 500 480 5 0 10
2008 2,700 4,500 340 320 5 0 10
2009 1,500 2,500 170 160 5 0 10
2010 920 1,500 81 770 5 0 10
Source: Oakdene Hollins Estimates
Figure 5: Estimates for total waste plastics arising from CRTs, and estimates of c-octaBDE concentration
Source:Oakdene Hollins Estimates
1.3 Further Strategies for mitigating the impact of c-octaBDE in CRT housings, which are not appropriate.
Separation of all c-octaBDE containing housings from the CRT waste stream followed by incineration. This method is deemed unsuitable, as identifying c-octaBDE amongst other BFRs is difficult and a sample from each casing would need to be tested singly. Therefore this would be time consuming and not economic.
0
2000
4000
6000
8000
10000
12000
0
5000
10000
15000
20000
25000
30000
2010 2012 2014 2016 2018
Waste
plastic fro
m C
RT h
ou
sings
(ton
ne
s)
c-o
ctaB
DE
con
cen
ttra
toin
(m
g/kg
)
Year
Mean Min Max Waste Plastic
A small number of landfills in the UK accept hazardous waste, these could be utilised as a disposal method. However, this was not deemed a suitable disposal route as the PBDEs present would not be destroyed or irreversibly transformed.
More sophisticated processing methods are available for plastic containing BFRs, such as the CreaSolv process. However, this processing is not available in the UK. Therefore this would require the installation of specialist equipment for plastics sorting and processing. This is both expensive and time consuming, and would not be online. However, this may be relevant in the future in BFR containing plastics do require separate treatment. Similar processes are available in other countries such as Switzerland and Germany.
2 Supplemental Data for PFOS
2.1 Estimation of PFOS concentration in waste
Limited data exists for the production, use and concentration of PFOS, especially regarding the years since the phase out of 3M in 2001. Therefore, a model for world production and consumption was generated based on available literature. An estimate for the average content of PFOS products used and
disposed of in the UK can be made based on the use of PFOS for different products and their imports to the UK. The focus of this study is on products containing PFOS that are still widely used in the UK and are not yet restricted regarding their disposal: carpets, textiles and paper. Other applications of PFOS, like fire extinguishers, process aids in the industry and hydraulic fluids in aviation are not within the scope of this study. Effects of recycling of the investigated products have been included. The import of waste is not relevant for these product groups and has not been included. Further information was gathered for the age of these products, and for the decrease in PFOS concentration during their lifetime.
Calculation of PFOS content in new products was carried out as follows:
An estimate of historic global PFOS production published by Paul et al. in 2009a was used as the basis for this model. Two scenarios (low and high production) were derived based on different sources in the literature.
Based on available literature, estimates regarding the historic and the current share of applications of PFOS were derived. The lower and higher estimates were incorporated in the low and high production scenario respectively.
From the global production (excl. production in the UK) of a product group and the corresponding amount of PFOS used in this application, an average PFOS content for imports of this type of product could be obtained.
As UK data show no more use of PFOS in the investigated applicationsb, concentration of PFOS was assumed to be zero.
Using the import and export ratio an average PFOS concentration of a new product was calculatedc.
For imports it is assumed that the recent regulation (EC) 552/2009 limiting the PFOS content in coated materials incl. textiles to max. 0.001 mg/m2 is not implemented. This is a very conservative assumption based on the fact that the actual analytical measurement is complex and that there is still an insignificant amount of data on actual PFOS contents in carpets, textiles and paper to be found.
The concentration of PFOS in the waste was calculated using the following methodology:
The loss of PFOS during the use and the recycle phase was estimated for each product based on a life cycle study for 3Md
Combined with the initial year of production, this yielded a matrix containing the average concentration of waste coming from this product group produced in a given year for each year.
a “A First Global Production, Emission and Environmental Inventory For Perfluorooctane Sulfonate”, Paul A.G., Jones K.C.J., Sweetman A.J., 2009, Environ. Sci.
Technol. 43, 386-392 b
“Perfluorooctane Sulfonate (PFOS) – Production and Use: Past and Current Evidence”, UNIDO, D. Carloni, 2009 c Data from the Office of National Statistics and the UK Tradeinfo
d “Sulfonated Perfluorochemicals: U.S. Release Estimation – 1997; Part 1: Life-Cycle Waste Stream Estimate”, Battelle Memorial Institute, 2000, for 3M
Speciality Materials; company sanitizes version AR 226-0681 available from the EPA (US) on request
The age distribution was derived from the literature to construct the correct distribution of waste collected in a given year. This yielded the average concentration of PFOS for a product in a given year.
2.2 Definition of a concentration limit for PFOS
The starting point for the definition of a possible concentration limit was the already existing threshold
values within Europe, both for PFOS and for other POPs. On this basis, a low and a high threshold
scenario were defined and discussed with regards to their justifications. As both scenarios were
considered unsatisfactory, a third scenario was developed which takes both the precautionary principle
to protect the environment and the actual circumstances in the UK into account.
2.3 Split of PFOS use for product groups
An overview of the use of PFOS in the UK including a split into different applications has been reported in an RPA report for DEFRAa and is shown in Figure 1. Figure 1: Use of PFOS within the UK for carpets, textiles, paper and packaging (P&P) and other applications (mainly processing aids)
Source: Oakdene Hollins based on RPA, 2004 and Paul et al., 2009
a “Perfluorooctane Sulphonate – Risk Reduction Strategy and Analysis of Advantages and Drawbacks”, RPA/DEFRA, 2004
0
20
40
60
80
100
120
1985 1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009
Use
of
PFO
S [t
/y]
others
P&P
textile
carpet
As reported by Paul et al.a, the share of applications for the UK and globally before 2002, differ significantly. This is illustrated in Table 3. Table 3: Split of PFOS use by applications before 2002
Application Share of the market
UK global
Carpet 23% 48%
Textiles 25% 12%
Paper & packaging 32% 24%
Others 20% 20%
For this study the lower figure of each application has been used to generate the “low production scenario”, whereas the higher figure was used for the “high production scenario”. This implies mixing figures from different sources and leads to the undesired effect of having the shares in the high production scenario adding up to more than 100%. However, as each group is considered separately, and no final sum is calculated, this seems justified for a conservative estimate. After2001 it is assumed that within OECD countries all applications except for process aid (“Others”) have been phased-out. This use is given by the OECD survey 2006 to be around 200 to/y. Our approach was then to subtract this OECD use from the global production number and distribute the remainder among the four fields of application according to their split before 2002. These figures were used to generate the final “low production” and “high production” scenarios.
2.4 Estimation of PFOS in waste from selected product groups
2.4.1 Carpets
An estimate for the content of PFOS in carpets is derived as follows:
The average content of PFOS-polymer and the average content of residual PFOS are calculated based on the estimated global use of PFOS for carpets and the global production of carpets.
The average concentration of free PFOS is calculated for carpets used in the UK based on the production and import figures.
This approach includes the following assumptions:
By using global production numbers only an average concentration of PFOS in carpets is obtained. Specific types of carpets, especially carpets intended for heavy use and with special protection treatment, may have significantly higher concentrations of PFOS. However, as the different types of carpets are collected together, the overall PFOS in the waste stream arising from carpets is expected to be a valid estimate.
The concentration for imported carpets is a conservative estimate, as it uses the highest reported residual concentration of free PFOS found in the literaturej.
The effect of recycling of carpets is not included in the mass balance, as recycling rates of carpets are reported to be only around 1%b.
Carpets lose approx. 95% of their free PFOS during their lifetime due to wear and cleaningc.
a
“A First Global Production, Emission and Environmental Inventory For Perfluorooctane Sulfonate”, Paul A.G., Jones K.C.J., Sweetman A.J., 2009, Environ. Sci. Technol. 43, 386-392
b “Maximising Reuse and Recycling of UK Clothing and Textiles: A report to the Department for Environment, Food and Rural Affairs”, Oakdene Hollins Ltd, Morley, N.J., Bartlett, C., McGill I., 2009
c “Sulfonated Perfluorochemicals: U.S. Release Estimation – 1997; Part 1: Life-Cycle Waste Stream Estimate”, Battelle Memorial Institute, 2000, for 3M Speciality Materials; company sanitizes version AR 226-0681 available from the EPA (US) on request
An overview of the average concentration of free PFOS in new carpets is given in Figure 2. The steep decline in PFOS concentration before 2004 reflects the phase out of PFOS in Western Europe and the USA. The concentration of PFOS stabilises around 0.4-0.6 mg/m2 caused by imports especially from Asia. Figure 2: Average concentration of PFOS in new carpets in the UK
Source: Oakdene Hollins
The initial value of 1 - 3 mg/kg (2 - 5 mg/m2) of PFOS before phasing out of PFOS agrees well with estimates in a 2005 study which estimates a PFOS concentration of 0.2 – 2 mg/kg (0.4 – 4 mg/m2)a. To calculate the concentration of PFOS in carpet waste an age distribution of the carpets is assumed. This distribution is based on an average lifetime of approx. 12 years, taking into account that in some sectors (e.g. retail) carpets are typically exchanged after 5 years, whereas in domestic applications carpets may be used much longer. Additionally, about 7% of carpets are disposed of directly as left-over cuts during installationb. By combining the age distribution of carpets with the loss of free PFOS due to wear, an estimate for the average concentration of PFOS in the carpets shown in Figure 3 is obtained. Any treatment of carpets with stain proofing agents after their installation has not been taken into account, as since 2004 PFOS is no longer used in such agents within the UK.
a
“Exposure Assessment and Risk Characterization for Perfluorooctanoate in Selected Consumer Articles”, S.T. Washburn, T.S. Bingman, S.K. Braithwaite, R.C. Buck, L.W. Buxton, H.J. Clewell, L.A. Haroun, J.E. Kester, R.W. Rickard, A.M. Shipp, 2005, Environmental Science & Technology 39(11), 3904-3910
b “Flooring: Towards a Resource Efficiency Plan”, Contract Flooring Association, P. Thomas, 2009
0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5
PFO
S in
ne
w c
arp
ets
[m
g/kg
]
high production
low production
Figure 3: Expected concentration of PFOS in carpet waste in the UK
Source: Oakdene Hollins
As can be seen from the graph the expected concentration of PFOS in the waste is currently in the range of 0.05-0.2 mg/kg (0.1 – 0.4 mg/m2) and slowly decreasing, mainly due to the effect of the phase out since 2002.
2.4.2 Textiles
An estimate for the content of PFOS in textiles is derived as follows:
The average content of PFOS-polymer and the average content of residual PFOS are calculated based on the estimated global use of PFOS for textiles and an estimate of the global production of workwear and home textiles.
Based on the production and import figures, the average concentration of free PFOS is calculated for textiles used in the UK.
This approach includes the following assumptions:
By using global production numbers only an average concentration of PFOS in workwear and home textiles is obtained. As some textiles might be treated with PFOS while others are treated with other types of water proofing agents (e.g. fluorinated telomers), the actual concentration in an individual textile might be considerably higher. However, as it is assumed that it is not practically feasible to distinguish between the different types of impregnation during waste collection/recycling this approach is expected to be a valid estimate.
The concentration for imported workwear and home textiles is a conservative estimate, as it uses the highest reported residual concentration of free PFOS found in the literaturea.
It is assumed that the import/export ratio of workwear and home textiles for the UK is the same as of the total textile sector.
The effect of recycling workwear or home textiles is not included in the mass balance, as the share of recycled textiles in the UK is only around 5%b and the concentration of PFOS has fallen to 25% of its initial value at this pointc.
a
“A First Global Production, Emission and Environmental Inventory For Perfluorooctane Sulfonate”, Paul A.G., Jones K.C.J., Sweetman A.J., 2009, Environ. Sci. Technol. 43, 386-392
b “Maximising Reuse and Recycling of UK Clothing and Textiles: A report to the Department for Environment, Food and Rural Affairs”, Oakdene Hollins Ltd, Morley, N.J., Bartlett, C., McGill I., 2009
c “Sulfonated Perfluorochemicals: U.S. Release Estimation – 1997; Part 1: Life-Cycle Waste Stream Estimate”, Battelle Memorial Institute, 2000, for 3M Speciality Materials; company sanitizes version AR 226-0681 available from the EPA (US) on request
0.00
0.05
0.10
0.15
0.20
0.25
2010 2011 2012 2013 2014 2015
PFO
S in
car
pe
t w
aste
[m
g/kg
] high production
Unlike carpets, the average concentration of PFOS in new workwear and home textiles remains fairly constant in a range of 0.1 – 0.25 mg/kg of PFOS. This is due to the much shorter lifetime of textiles, where the phasing out of PFOS in Europe and the USA has already taken effect and the European or American products, with a significant PFOS content, have mostly been dispose of already. For comparison, a study commissioned by the Norwegian Pollution Control Authoritya found a concentration of up to approx. 0.03 mg/m2 of a fluorinated protecting agent, which corresponds to approx. 0.1 mg/kg. Again the estimate from the high production scenario arrives at higher value in line with the intention to err on the ‘safe’ side. To calculate the concentration of PFOS in textile waste an age distribution of the carpets is assumed. This distribution is based on an average lifetime of workwear and home textiles of approx. 5 years (average of clothes and home textilesb). By combining the age distribution with the slow loss of free PFOS due to wear, an estimate for the average concentration of PFOS in the textiles shown in Figure 4 is obtained. Any treatment of textiles with stain proofing agents after their manufacture has not been taken into account, as PFOS is no longer used in such agents within the UK since 2004. Figure 4: Expected concentration of PFOS in textile waste in the UK
Source: Oakdene Hollins
As can be seen from the graph, the expected concentration of PFOS in the waste is in the range of
0.04-0.10 mg/kg, if workwear and home-textiles are collected separately. If they are mixed with all
other textiles a concentration of 0.01 - 0.020 mg/kg of free PFOS is expected. These values are
expected to remain stable for the next years as the effect of phasing out PFOS in the USA and in
Europe has already passed and there is a specific exemption for the use of PFOS in textiles and
upholstery in the Stockholm Convention.
a “Survey, screening and analysis of PFCs in consumer products”, TA-2578/2009, Swerea IVF for the Norwegian Pollution Control Authority, D. Herzke, S.
Posner, E. Olsson, 2009, available at http://www.klif.no/publikasjoner/2578/ta2578.pdf (accessed 05.08.2010) b “The stock of consumer durables in the United Kingdom: new estimates 1948-1995”, G. Williams, 1998, Review of Income and Wealth 44(3), 417-436
0.00
0.05
0.10
0.15
0.20
0.25
0.30
newworkwear/
home textiles
wasteworkwear/
home textiles
wasteall textiles
PFO
S in
te
xtile
was
te [
mg/
kg]
high production
low production
2.4.3 Paper and Packaging
An estimate for the content of PFOS in coated paper is derived as follows:
Based on the estimated global use of PFOS for paper and packaging and an estimate of the global production of coated paper, the average content of PFOS-polymer and the average content of residual PFOS is calculated.
The average concentration of free PFOS is calculated for coated paper used in the UK based on the production and import figures.
This approach includes the following assumptions:
By using global production numbers only, an average concentration of PFOS in the product is obtained. As not all coated paper products are be treated with PFOS (e.g. coated paper for colour prints does not contain PFOS), the actual concentration in the individual paper might be considerably higher. However, it is assumed that it is not practically feasible to distinguish between the different types of impregnation during waste collection/recycling and this approach is expected to be a valid estimate.
The concentration for imported coated paper is a conservative estimate, as it uses the highest reported residual concentration of free PFOS found in the literaturea.
It is assumed that the import/export ratio of coated paper for the UK is the same as of the total paper and cardboard sector.
The effect of recycling is taken into account by generating three scenarios: First, it is assumed that coated paper waste is collected separately and is incinerated. In the second and third scenario, coated paper waste enters the waste stream and is recycled together with other paper waste. The difference between these scenarios is that in the second only virgin paper is used for coated paper, whereas in the third recycled paper goes into coated paper as well.
The recycling rate for general paper waste is assumed to be approx. 70%b. Based on a study by 3M it is assumed that approx. 15% of the PFOS is lost during the recycling processc.
As no loss of PFOS during the short lifetime of coated paper products is assumed (loss to food contents is minimalv) the concentration of 0.06-0.10 mg/kg PFOS in new coated products is the same as in the waste thereof. In the combined paper waste the coated paper is diluted by the much larger portion of non-coated and the concentration is reduced to about 0.001 mg/kg PFOS. Unfortunately, no data of paper actually containing fluorinated compounds were available for comparison. However, based on experience it is assumed that a value of approx. 0.001-0.020 mg/m2 of PFOS is reasonable for coated paper. Based on a paper density between 60 and 350 g/m2 our results correspond to approx. 0.004 – 0.035 mg/m2 which is in good agreement. Our estimate is also in so far conservative, as no material containing more than 0.001 mg/m2 of PFOS should enter the UK anymore (Regulation (EC) 552/2009).
2.5 Effect of recycling on the PFOS content of selected products
2.5.1 Carpets
The effect of recycling of carpets was not included in the mass balance, as recycling rates of carpets are reported to be only around 1%d.
a “A First Global Production, Emission and Environmental Inventory For Perfluorooctane Sulfonate”, Paul A.G., Jones K.C.J., Sweetman A.J., 2009, Environ. Sci.
Technol. 43, 386-392
b “Recovery and Recycling of Paper and Board”, confederation of paper industries”, CPI, 2009, available at
http://www.paper.org.uk/information/factsheets/recovery_and_recycling.pdf (accessed 05.08.2010)
c “Sulfonated Perfluorochemicals: U.S. Release Estimation – 1997; Part 1: Life-Cycle Waste Stream Estimate”, Battelle Memorial Institute, 2000, for 3M Speciality Materials; company sanitizes version AR 226-0681 available from the EPA (US) on request
d “Maximising Reuse and Recycling of UK Clothing and Textiles: A report to the Department for Environment, Food and Rural Affairs”, Oakdene Hollins Ltd, Morley, N.J., Bartlett, C., McGill I., 2009
To determine the effect of recycling on the issue of PFOS three scenarios were compared:
Base case: no recycling
Recycling at the current rate of 1%
Recycling at tenfold the current rate of 10% For all scenarios the concentration of PFOS in freshly installed carpets is compared. Even though a small amount of recycling already takes place, the estimates shown above have been calculated neglecting recycling and can therefore be used directly as base case. The results of these scenarios are shown in Table 4. Table 4: Effect of recycling of carpet waste on PFOS in installed carpets (2010-2015)
Recycling rate Change in PFOS concentration [mg / kg]
Low production High production
1% -0.0001 -0.001
10% -0.001 -0.012 Source: Oakdene Hollins
As can be seen from the data the effect of both current and significantly higher recycling on PFOS content of installed carpets is negligible. In all cases recycling is lowering the PFOS content in installed carpets. This is due to the fact that most PFOS in old carpets has already been lost during its lifetime. Recycled material therefore contains less PFOS then the average of freshly produced carpets and is thus contributing to a reduction of the amount of PFOS in the UK.
2.5.2 Textiles
The effect of recycling of workwear or home textiles was not included in the mass balance, as the share of recycled textiles in the UK is only around 5%a and the concentration of PFOS has fallen to only 25% of its initial value at this point. To determine the effect of recycling on the issue of PFOS three scenarios were compared:
Base case: no recycling
Recycling at the current rate of 5%
Recycling at double the current rate of 10% For all scenarios the concentration of PFOS in new workwear and home textiles is compared. Even though a small amount of recycling already takes place the estimates shown above have been calculated neglecting recycling and can therefore be used directly as base case. The results of these scenarios are shown in Table 5. Table 5: Effect of recycling of textile waste on PFOS in new workwear and home textiles (2010-2015)
Recycling rate Change in PFOS concentration [mg / kg]
Low production High production
5% -0.003 -0.006
10% -0.008 -0.016 Source: Oakdene Hollins
As can be seen from the data the effect of both current and significantly higher recycling on PFOS content of installed carpets is small. In all cases recycling is decreasing the PFOS content in new workwear and home textiles. This is due to the fact that most PFOS in textiles has already been lost during its lifetime. Increased recycling of textile waste would in fact help to reduce the average concentration of PFOS in textiles as it replaces new textiles that have on average a higher concentration of PFOS.
a “Maximising Reuse and Recycling of UK Clothing and Textiles: A report to the Department for Environment, Food and Rural Affairs”, Oakdene Hollins Ltd,
Morley, N.J., Bartlett, C., McGill I., 2009
2.5.3 Paper and Packaging
A large portion (approx. 70%) of UK paper production is based on recycled material. The figures presented above include this recycling and assume – rather conservatively – that the food packaging is recycled to the same degree as uncoated paper. To determine the effect of recycling, three scenarios were compared: Table 6: Scenarios for recycling of paper and packaging
Scenario Coated paper entering general paper waste PFOS entering general
paper waste
1 Coated paper disposed of separately no
2 Coated paper recycled to ‘normal’ paper only yes
3 Coated paper recycled to all types of paper yes Source: Oakdene Hollins
For these scenarios the concentration of PFOS in freshly produced paper is compared. The results of these scenarios are shown in Table 7. If all coated paper would be disposed of separately without going into the recycling loop, no PFOS would be expected to appear in the general paper waste (scenario 1). However, it is more realistic to assume that some coated paper enters the recycling loop. If recycled paper would only be used for uncoated paper and packaging, a contamination with PFOS in the range of 0.001 -0.004 mg/kg is expected (scenario 2). If recycled paper is also used to produce coated paper within the UK rather than imported coated paper from outside the UK with an average higher concentration of PFOS, it would be crowded out and the PFOS concentration of paper waste would be about a third (0.0003- 0.001 mg/kg; scenario 3). Enforcing a separate collection and disposal of coated paper would have the effect of ensuring that no PFOS goes into the general paper waste, however, the effect would be small – in the range of max. 0.001-0.004 mg/kg. Provided that the input of PFOS into the UK economy via imports from outside the EU would remain constant, this value would remain stable – no significant enrichment would take place as approx. 15% of PFOS is lost during the recycling stage. Table 7: Effect of recycling of paper waste on PFOS in new paper (2010-2015) PFOS in general paper waste [mg / kg]
Low production High production
Coated paper disposed of separately 0 0
Coated paper recycled to ‘normal’ paper only 0.001 0.004
Coated paper recycled to all types of paper 0.0003 0.001 Source: Oakdene Hollins
2.5.4 Estimation of the economic burden of incineration of PFOS containing waste
As discussed above, a threshold limit on PFOS in waste preventing certain products being recycled, does not lead to an overall reduction of PFOS in the UK provided imports containing PFOS still occur. A threshold limit does not only prevent waste from being recycled but only requires a disposal method that destroys the PFOS contained in the waste. This implies that in the case of carpets, a threshold value below the current concentration of PFOS does not only inhibit the currently small carpet recycling industry, but it also requires the other 99% to be disposed of in incinerators suitable for destruction of PFOS. Economic burdens by setting a threshold limit can be estimated for each product based on the following assumptions:
The estimate for the total amount of waste from carpets is based on statistical info for 2009a.
a Data from Office for National Statistics and UK Trade Information (HM Revenue & Customs)
The estimate for the total amount of waste from work wear / home textiles is based on 2004 figures in the “Well dressed” reporta.
The estimate for the total amount of coated paper waste is based on: Low estimate: Assuming that the main application is direct contact food packing, based on the amount of coated paper used in food packaging waste in the EU-15b, the annual waste of coated paper possibly containing PFOS is approx. 264,000 to/y. As this estimate ignores other applications of potentially organofluorine-coated paper rather than food packaging, this is considered to be an underestimate. High estimate: Based on the amount of paper consumed in the UKc and the share of coated paper for paper consumptiond we arrive at the high value of 924,000 to/y of coated paper waste possibly containing PFOS. This value is an overestimate, as a large part of coated papers is used for high quality printing, which did never use PFOS. For the following estimation of disposal costs the lower estimate is chosen, as it is seen to be more realistic to implement a separate collection strategy for this type of waste, than for all coated paper.
A cheap and reliable analytical method for determination of PFOS is not feasible in the few next years, as the problem of distinguishing between free PFOS, PFOS bound as polymer, or other fluorinated substances (e.g. PFOS, fluorinated telomers) is analytically too complex.
Consequently, it is not feasible to test, e.g. every clothing, carpet or food packaging item regarding its PFOS content, and all such items would need to be considered for incineration.
For the estimation of a ballpark figure of the additional economic cost, only the additional costs for disposal of waste in incinerators for the recycling companies are included. As PFOS destruction requires high temperature incineratione the same costs as for incineration of hazardous waste are assumed.
Additional costs (investment for additional incinerators) or benefits (e.g. from energy use) are not included.
Costs for setting up the infrastructure of separate collection of waste potentially containing PFOS is not included.
Current landfill costs: approx. 65 £/to (incl. landfill tax).
Current cost of incineration of hazardous waste: 120 £/t. These assumptions, combined with the data yield for each product group, are an estimate of the additional economic cost, provided the threshold limits are set such that they are below the estimated average concentration. Table 8: Extra cost of disposal of PFOS containing waste as hazardous waste
Product Carpets Workwear Home textiles
Coated paper
Total amount 510,000 350,000 264,000 to/y
Of which recycled 5,000 17,000 0 to/y
Cost of non-hazardous landfill (65£/to)
33,000,000 21,000,000 17,000,000 £/y
Cost of incineration (120 £/to)
61,000,000 42,000,000 32,000,000 £/y
Increase in cost 28,000,000 21,000,000 15,000,000 £/y Source: Oakdene Hollins
According to this crude estimate the additional costs are in the range of £15-65M per year.
a “Well dressed”, Cambridge Inst. for Manufacturing, 2006
b 4.4 kg/y per capita acc. to “Industry Guideline – Paper & Board Materials and Articles for Food Contact”, European paper and board food packaging chain,
2010 c 13 mln to/y acc. to “Realising the value of recovered paper: An update”, WRAP 2010
d 7% acc. to “Web Proof Information Pack of Youyuan Intern. Holdings Ltd.”, 2010
e “Perfluorooctane Sulfonate (PFOS)”, Swedish Chemical Inspectorarte (KemI), 2004
2.6 Emission pathways of PFOS during waste management
Table 9: Emission pathways of PFOS for different waste management options Exposure scenarios Recycling Land fill Incineration below
760°C Controlled incineration
above 760°C
Offgassing E O E O
Washout E E Not relevant Not relevant
Binding to particles E E E O
Migration E E Not relevant Not relevant
Leachate
E E Not relevant Not relevant
Uptake and excretion into the human organism
E E E Not relevant
Uptake from plants and animals
E E E Not relevant
Source: Swerea
E = Emissions cannot be excluded
O= Emissions are not likely to occur
Not relevant = Emissions are not an issue
About the authors:
Hüdai Kara BSc MSc DPhil A materials scientist with a DPhil from Oxford University, Hüdai has over 10 years of experience in R&D, low carbon sustainable technologies, carbon footprinting, LCA, renewable energy and waste management in the metallurgy, materials, chemicals and energy sectors. His work includes techno-economic analysis of low carbon technologies from titanium production to lead-acid battery recycling. He is a registered assessor for EU R&D funding streams (Eco-Innovation, FP7) and a project monitor for the Technology Strategy Board on clean technologies. He is a carbon footprint expert and registered by Carbon Trust. Hüdai formerly worked for Johnson Matthey Corporate Research in the optimisation of precious metals extraction and recycling processes.
Adrian Chapman MSci PhD MRSC Adrian joined us from Nottingham University where he gained a PhD in Green Chemistry and experience in technology transfer. His research has included scoping the EPSRC’s potential contribution to the green economy, and case studies on the environmental impact of recycling and reuse strategies for a range of products. He is registered by the Carbon Trust to carry out Carbon Footprint Analyses according to the recently introduced PAS 2050 methodology. Adrian is also a life cycle assessment practitioner, using SIMAPRO software and ECOINVENT life cycle inventories.
Helmut Sengstschmid MSc PhD Dr. Sengstschmid is a Technical Consultant at Oakdene Hollins. He is currently assessing applications for Ecolabel, and is co-author on a report regarding issues around the criteria on formaldehyde emission in wooden furniture. Dr. Sengstschmid has worked for ten years in the process Industry and was responsible for developing, implementing and documenting procedures to ensure quality standards for food and feed additives. Dr. Sengstschmid holds a PhD in Chemistry and is currently finishing his MSc in Environmental Management for Businesses at Cranfield University.
Stefan Posner Stefan Posner is author and co-author to a large number of reports concerning functional chemicals, especially perfluorinated substances and brominated flame retardants and their alternatives, in textiles and polymers in electronic products. These reports have mainly been commissioned by The Swedish Chemicals Agency (KemI), The European Commission, The Norwegian EPA, UNEP and several other authorities
Disclaimer: Oakdene Hollins Ltd believes the content of this report to be correct as at the date of writing. The opinions contained in this report, except where specifically attributed, are those of Oakdene Hollins Ltd. They are based upon the information that was available to us at the time of writing. We are always pleased to receive updated information and opposing opinions about any of the contents. The listing or featuring of a particular product or company does not constitute an endorsement by Oakdene Hollins, and we cannot guarantee the performance of individual products or materials. This report must not be used to endorse, or suggest Oakdene Hollins’ endorsement of, a commercial product or service. We have prepared this report with all reasonable skill, care and diligence within the terms of the contract with the client. Although we have made all reasonable endeavours to ensure the accuracy of information presented in this report, we make no warranties in this respect. Factors such as prices and regulatory requirements are subject to change, and users of the report should check the current situation. In addition, care should be taken in using any of the cost information provided as it is based upon specific assumptions (such as scale, location, context, etc.). Clients should satisfy themselves beforehand as to the adequacy of the information in this report before making any decisions based on it.
