EPA also says that HBCD is "persistent, bioaccumulative and can undergo long-range atmospheric transport." These have become big qualifiers for chemical concern. If something is persistent it means it can stay in the environment for a very long time. And if it is bioaccumulative it means all that chemical in the environment could possibly build up in the bodies of plants and/or animals, then the animals that eat those plants or animals, then the animals that eat those animals, etc. But the "long-range atmospheric transport" is an added concern. That means that the chemical could persist and bioaccumulate not only near where it is released into the environment, but in remote locations like the Arctic.
Add in EPA's contention that "studies show HBCD is highly toxic to aquatic organisms" and that "health concerns include potential reproductive, developmental and neurological effects in humans," and you have the reason why they feel they need a plan of action.
But as I've discussed in the past, these actions are planned for the future, or in some cases, just the consideration of taking action is planned for the future. Given the old adage that a plan is obsolete as soon as it is printed, the actual actions taken by EPA and industry could be much different when they actually take place. But for now, EPA's plan to deal with HBCD is to:
- Consider initiating TSCA §5(b)(4) Concern List rulemaking on HBCD. Proposed rule in late 2011.
- Initiate TSCA §5(a)(2) Significant New Use Rule to designate HBCD use in consumer textiles as a flame retardant as a significant new use.
- Consider initiating rulemaking under TSCA §6(a) to regulate HBCD.
- Initiate rulemaking to add HBCD to the Toxics Release Inventory. Action expected in late 2011.
- Conduct a Design for the Environment and Green Chemistry alternatives assessment of HBCD.