MEMA submitted comments to the EPA on Aug. 30 supporting the agency’s proposed risk evaluation regarding Cyclic Aliphatic Bromide Cluster (HBCD) specifically on replacement parts and to highlight the automotive industry’s efforts to phase the chemical out of those parts.
HBCD was primarily used as a flame retardant but is no longer applied to production parts when new vehicles are made. They are only prevalent in replacement parts, but the chemical is so sparingly used that the EPA finds it “poses no unreasonable risk to the environment or human health,” according to MEMA’s letter. Further, MEMA stresses that EPA is directed to, “exempt replacement parts for complex durable goods and complex consumer goods,” unless EPA finds that, “such replacement parts contribute significantly to the risk, identified in a risk evaluation conducted under subsection (b)(4)(A), to the general population or to an identified potentially exposed or susceptible subpopulation.”
“In 2017, MEMA submitted comments to the EPA indicating that motor vehicle suppliers have indicated ‘HBCD is not used during the manufacturing process of any automotive components’ and that industry has phased out the use of HBCD,” MEMA stated. “MEMA’s and other motor vehicle industry data show that HBCD is being phased out or has already been phased out of replacement parts.”