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Draft Revision to the HBCD Risk Determination Published by US EPA

Comments are due February 14, 2022.

On Dec 29, 2021, the US Environmental Protection Agency (EPA) published a draft revision to the risk determination for cyclic aliphatic bromide cluster chemicals including hexabromocyclododecane (HBCD) issued under TSCA. The draft revision addresses some of the shortcomings identified in the original risk assessment and reflects the announced policy changes to ensure the public is adequately protected from unreasonable risks from chemicals.

HBCD has primarily been used as a flame retardant in building materials including thermal insulation foams and textiles. It has been used since the 1960s and is comprised of 16 different stereoisomers. The HBCD chemical mixture meets the EPA’s criteria for being persistent, bioaccumulative and toxic (PBT) and has been banned or restricted in many countries and regions globally including being added to the UN’s Stockholm Convention’s list of Persistent Organic Pollutants (POPs) whereby parties must eliminate its use from all applications except those that have been exempted including use in expanded polystyrene and extruded polystyrene in buildings.

The original risk evaluation published in Sep 2020 concluded that HBCD presents unreasonable risk to the environment for 6 out of 12 conditions of use. The EPA’s draft revision to the risk assessment eliminates the assumption that all workers wear appropriate personal protective equipment (PPE). According to the draft revision to the risk determination, the same six conditions of use would continue to drive the unreasonable risk determination for HBCD. However, the impact of removing the assumption of PPE use by workers would cause four of the six conditions of use that drive the unreasonable risk determination based on risks to the environment to also drive unreasonable risk based on health risks to workers.

The next step in the process is for EPA to take public comment on the draft revised risk determination, before releasing a final revised risk determination. The EPA will pursue action under TSCA Section 6(a) to address any unreasonable risks to health and the environment. They will ultimately propose and take public comment on risk management measures prior to publication of the risk management measures for HBCD.

Comments are due to the agency by Feb 14, 2022. Please submit comments identified by docket identification (ID) number EPA–HQ–OPPT–2019–0237, using the Federal eRulemaking Portal at  Follow the online instructions for submitting comments. Do not submit electronically any information you consider to be Confidential Business Information (CBI) or other information whose disclosure is restricted by statute.

If you have any questions regarding the revised risk determination on HBCD or any other TSCA matter, or if you need any assistance submitting comments, please feel free to contact Shannon Gainey at

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