COMMENTS BY NORWAY ON THE REVISED PENTABDE REPORT

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Comments to 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 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.

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14 OCTOBER 2016 SUBMISSION OF EFPIA COMMENTS ON GUIDELINE
15 COMMENTS DUTCH ACCOUNTING STANDARDS BOARD (DASB) ON EXPOSURE

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