HBCD-free Styrofoam™ Insulation Coming to USA

Jim Vallette - July 8, 2016

By 2018, extruded polystyrene (XPS) insulation[1] will be available in North America without the extremely toxic flame retardant, hexabromocyclododecane (HBCD). Yesterday, Dow Chemical announced plans to construct a new manufacturing plant in Burley, Idaho, which will produce XPS insulation with its own flame retardant.[2] Last month, Dow trademarked its butadiene styrene brominated copolymer by the name "BLUEDGE™."[3]

This appears to be a good step forward, although much remains to be done to eliminate foam insulation's hazards.

"Small changes in this sector can multiply and add up to meaningful change."

Halogenated flame retardants like HBCD are substances of global concern; they are among the most toxic, persistent, and bio-accumulative substances used in building products. Typically, XPS insulation contains about 0.7% HBCD flame retardant by weight.[4] Polystyrene insulation is the primary use of HBCD. The removal, recycling and disposal of this insulation from buildings will contribute to global HBCD pollution long after companies stop making the flame retardant.

HBCD has been found in human breast tissue, adipose tissue and blood. It is highly toxic to aquatic animals and biomagnifies in the environment. The flame retardant has been detected in the environment worldwide, even remote locations like the Arctic with no local sources. According to the US EPA, “HBCD also presents human health concerns based on animal test results indicating potential reproductive, developmental, and neurological effects. People may be exposed to HBCD from products and dust in the home and workplace.”[5]

Dow is positioned to become the first North American insulation manufacturer to make XPS without HBCD, and is invested in its success. In 2013, Dow first used its butadiene styrene brominated copolymer alternative in XPS insulation made in Japan. It licenses production of its BLUEDGE alternative, also commonly called “PolyFR,” to longtime brominated flame retardant producers Albemarle, ICL, and Chemtura.[6]

The US Environmental Protection Agency has assessed Dow’s butadiene styrene brominated copolymer flame retardant to be far lower in health and environmental hazard than HBCD. However, in some categories for which HBCD had particularly high hazard - aquatic toxicity and bioaccumulation - there are significant data gaps. Furthermore, the EPA assessment for many hazards relies on modeling and professional judgement instead of measured data.[7] EPA also noted that some particle sizes of the flame retardant are potentially toxic from inhalation, and that smaller particles are potentially persistent, bio-accumulative, and toxic.[8]

The copolymer approach probably is significantly better in the use phase; however, the production and disposal of brominated chemicals are inherently problematic - issues that appear to have been outside of the EPA assessment. As the Green Science Policy Institute noted this year, the market for thermal insulation needs to move “away from [the] use of organohalogen flame retardant chemicals which are known to be hazardous to human health and the environment, are persistent, and also lead to the formation of toxic halogenated dioxins and furans in fires or during thermal processing.”[9]

Dow Chemical expects to begin manufacturing its HBCD-free STYROFOAM™ XPS Insulation in Idaho in early 2018.[10]

While a welcome development (at least compared to the status quo of HBCD), there is no word yet from Dow, or other XPS manufacturers, on when it will transition away from the use of blowing agents with high global warming potential. The most common XPS blowing agent, HFC-134a, is a powerful greenhouse gas. It has a global warming potential (GWP) of 1,430, meaning it is 1,430 times more potent than carbon dioxide.[11] These blowing agents typically comprise about 8% of XPS insulation by weight.[12]

As Rebecca Stamm noted in our Pharos Signal last year, “In the past, regulations have pushed the industry away from environmentally damaging blowing agents (such as the ban on ozone depleting chlorofluorocarbons under the Montreal Protocol), and an EPA rule is set to do so again. The rule, enacted in July 2015, will require XPS manufacturers to stop using high GWP HFCs by the year 2021. Alternative blowing agents are already available and in use in XPS made in Europe. Exiba, the European XPS trade association, reports that the large majority of their members do not use fluorinated greenhouse gases as blowing agents. But the EPA cites North American industry concerns – manufacturers say they need time to change over equipment and complete new product certifications – in allowing the industry six more years to use HFCs in polystyrene insulation.”[13]

Dow’s press release did not indicate whether its Idaho plant will meet the EPA blowing agent rule in advance. There’s no excuse for delay. The transitions are underway overseas; only the U.S. is lagging.

There are intractable issues with polystyrene insulation in its production (styrene is a potent carcinogen) and disposal (it’s not recyclable into the same product). But when it is not possible to avoid using polystyrene insulation, the least the industry can do is find and use green chemistry solutions for functional additives, like blowing agents, flame retardants, and biocides,[14] that do no harm to installers, building occupants, and the global environment.

Small changes in this sector can multiply and add up to meaningful change. The polystyrene insulation industry accounts for the vast majority – over 90% – of the HBCD produced worldwide.[15] The XPS insulation sector, particularly in North America, has been the last to change blowing agents as new technologies become available, despite these chemicals’ contributions first to ozone depletion and then to global warming. A United Nations task force recently noted that among industries that use blowing agents, XPS alone continues to be “heavily dependent” on high GWP technologies, and that this industry in North America is responsible “by far” for the most use of high-GWP blowing agents.[16]

When the changes finally come to this continent, they will have global benefits. The UN task force noted that “any measures to reduce reliance on high GWP blowing agents will have an enduring effect beyond 2030. The most notable benefits are likely to come from the XPS sector in the period beyond 2025.”[17]

Health-conscious building owners have been avoiding the use of products that contain halogenated additives and potent global warming agents, and are in no small part responsible for the positive changes ahead. As companies like Dow Chemical move towards less toxic chemistries, our movement is demonstrating its ability to reduce this sector’s impacts on people’s health and the world’s environment.


Thanks to Michel Dedeo, Susan Sabella, Teresa Skaar, Rebecca Stamm, Peter Sullivan, and Tom Lent for their assistance with this article.


Please join me at the forthcoming Living Products Expo in Pittsburgh, September 13-15. I participated in last year’s conference on a panel that debuted the open source Quartz Project, and this year I will be speaking about polyvinyl chloride, alongside architects, manufacturers and government experts. Last year’s inaugural Expo was a great success. As the International Living Future Institute explains, “The Expo is an opportunity for participants to share and discover disruptive new ideas and technologies that are reshaping the materials landscape, accelerating the pace of innovation and making Living Products possible today. Join us, and together we will craft the future of materials. For more information and to register, visit http://www.livingproductexpo.org

[1] Polystyrene insulation falls into two categories: expanded polystyrene (EPS) and extruded polystyrene (XPS). Although they have different properties, EPS and XPS products are used for many of the same applications. Both extruded and expanded polystyrene are used for insulation, packaging and food-service products. (Collectively, these are commonly known as Styrofoam™, which is Dow’s trade name for its polystyrene products.)

[2] Kavanaugh, Catherine. “Dow Building Styrofoam Plant in Idaho.” Plastics News, July 7, 2016. http://www.plasticsnews.com/article/20160707/NEWS/160709888/dow-building-styrofoam-plant-in-idaho

[3] Trademark Electronic System (TESS). “Bluedge Word Mark.” U.S. Patent and Trademark Office, June 16, 2016.

[4] Quartz Project. “XPS Insulation.” Quartz Database, October 2015. http://www.quartzproject.org/p/CP036-a00.

[5] US EPA, Flame Retardant Alternatives for Hexabromocyclododecane (HBCD), June 2014, http://www2.epa.gov/sites/production/files/2014-06/documents/hbcd_report.pdf

[6] Dow Chemical Company. “Dow Produces First XPS Foam Material With New Sustainable Polymeric Flame Retardant in Europe,” April 15, 2014. http://building.dow.com/media/news/2014/20140415a.htm

[7] US EPA, Flame Retardant Alternatives for Hexabromocyclododecane (HBCD), June 2014, http://www2.epa.gov/sites/production/files/2014-06/documents/hbcd_report.pdf 

[8] Babrauskas, Vytenis, Donald Lucas, David Eisenberg, Veena Singla, Michel Dedeo, and Arlene Blum. “Flame Retardants in Building Insulation: A Case for Re-Evaluating Building Codes.” Building Research & Information 40, no. 6 (November 26, 2012): 738–55. doi:10.1080/09613218.2012.744533.

[9] Green Science Policy Institute. “Comments on the Proposed Standard, Technical Review, and Rationale. Green Seal Certification for Insulation Products.,” March 31, 2016

[10] “Dow to Construct New STYROFOAM Brand Insulation Manufacturing Facility.” LBM Journal, July 8, 2016. http://www.lbmjournal.com/dow-to-construct-new-styrofoam-brand-insulation-manufacturing-facility/.

[11] US EPA, “Global Warming Potentials and Ozone Depletion Potentials of Some Ozone-Depleting Substances and Alternatives Listed by the SNAP Program,” last updated November 6, 2014, http://www3.epa.gov/ozone/snap/subsgwps.html

[12] Quartz Project. “XPS Insulation.” Quartz Database, October 2015. http://www.quartzproject.org/p/CP036-a00.

[13] Stamm, Rebecca. “More Impending Changes in the Insulation Market.” Pharos Signal, November 6, 2015. https://www.pharosproject.net/blog/show/203/polystyrene-changes

[14] For further details about the use of imidaclopid biocides in polystyrene insulation, see: Vallette, James. “Common Decking and Insulation Pesticide Is a Honeybee Killer.” Healthy Building News, January 21, 2016. https://www.healthybuilding.net/news/2016/01/21/common-decking-and-insulation-pesticide-is-a-honeybee-killer.

[15] In 2011 the United Nations Report of the Persistent Organic Pollutants Review Committee stated that the global production of HBCD was 28,000 tonnes (30,800 tons). The report further states that over 90% of the HBCD produced is used by the EPS and XPS insulation markets. This makes over 27,700 tons of HBCD being used by the polystyrene insulation market. (UNEP, Report of the Persistent Organic Pollutants Review Committee on the work of its seventh meeting, Addendum Risk management evaluation of hexabromocyclododecane, November 8, 2011, http://echa.europa.eu/documents/10162/18074545/a4a_comment_551_1_attachment_en.pdf )

[16] The United Nations task force noted, “In non-Article 5 Parties, the phase-out of HCFCs in the foam sector was achieved for the most part by 2010, with the XPS industry in North America being amongst the last to phase-out their use.” And further,  “North America remains by far the largest user of high-GWP HFCs amongst the non-Article 5 Parties” because of their use in the XPS industry (p. 41). Non-Article 5 parties are mainly European countries, the USA, Canada, Japan, New Zealand and Australia.

[17] United Nations Environmental Programme. “October 2014 Report of the Technology and Economic Assessment Panel. Decision XXV/5 Task Force Report. Additional Information on Alternatives to ODS (Final Report).” United Nations Environment Programme, October 2014. http://ozone.unep.org/Assessment_Panels/TEAP/Reports/TEAP_Reports/TEAP_Task%20Force%20XXV5-October2014.pdf.


Jim Vallette is the Research Director for the Healthy Building Network.