Comments By Norway On The Revised PentaBDE Report

comments by norway on the revised pentabde report * with reference to the question by ipen in the preface section, we do no

Comments by Norway on the revised PentaBDE report
*
With reference to the question by IPEN in the preface section, we
do not consider it necessary to reflect further work by the
Alternatives Working group in the preface of this report.
*
Disclaimer as it is in revised document:
The present document is a status report based on available knowledge
on health and environmental effects of flame retardants. The document
does not endorse the presented alternatives or recommend them as being
less harmless (as being less harmful?) than pentaBDE as there are
currently toxicological and ecotoxicological data gaps for the
potential alternatives to PentaBDE. The document might need to be
revised according to new information on environmental and health
effects of the discussed chemicals. Further assessment of
toxicological and ecotoxicological properties needs to be carried out
when evaluating the use of alternatives to PentaBDE. The document
furthermore reflects the specific concerns of the Stockholm Convention
and does not concern issues other than POPs issues.
We are of the opinion that according to the data in the guidance
report, there is reason to say that there are alternatives less
harmful than PentaBDE. Even so, the need for more information is
crucial to be able to draw final conclusions.
Proposal for revised text:
The present document is a status report based on available knowledge
on health and environmental effects of flame retardants. When reading
the document, it is important to keep in mind that there are currently
toxicological and ecotoxicological data gaps for the potential
alternatives to PentaBDE. Nevertheless, (based on the available data,)
there are alternatives that are considered to be less harmful than
PentaBDE. The data presented in the document are just suggestive and
it is crucial (or important) to search for further health and
environmental data to get a better understanding of toxicological and
ecotoxicological effects of the alternatives presented. The document
furthermore reflects the specific concerns of the Stockholm Convention
and does not concern issues other than POPs issues.
*
We agree with Mr. Posner on the question of whether extractability
for recyclability should be part of the list of mechanical
properties under 2.2.
*
We agree with the recommendation that general comments be
forwarded to the drafter of the guidance document on general
considerations related to the use of alternatives and substitutes
to POPs for possible inclusion.