110
5.4.2 HELCOM Policy
By the time brominated fl ame retardants started to be targeted by policymakers, the
Helsinki Convention had been amended, requiring the Parties ‘to prevent and eliminate pollution of the marine environment of the Baltic Sea Area caused by harmful
substances from all sources’. Compared to the 1974 convention, the 1992 version is
more stringent and comprehensive. One example is that the 1974 Annex II list of
‘noxious substances and materials’ has been broadened to a 1992 Annex I list of
‘Priority groups of harmful substances', where, for example, (all) ‘ organohalogen
compounds’ are included, as opposed to only ‘ persistent halogenated hydrocarbons’
in 1974, meaning that now all PBDEs are defi nitely covered at least indirectly.
In the mentioned 1998 Recommendation (19/5) on the 2020 target, brominated
fl ame retardants were included in the list of 280 substances of potential concern, but
neither the BFR-group as a whole nor organohalogens and PBDEs were among the
42 substances prioritised for immediate action. However, explicit reference to
PBDEs was repeatedly made in the 2007 Baltic Sea Action Plan (HELCOM 2007 ),
which updated the Recommendation. PentaBDE and octaBDE were targeted for
use, production and marketing bans by 2010, whereas decaBDE could be a target
from 2009 for less stringent measures, in some sectors, if further assessments
showed a need for taking such action. All three PBDEs were included in a group of
11 substances of ‘specifi c concern’ to the Baltic Sea.
Moreover, 3 years later, when the 1990 Recommendation (19/5) was updated, all
three – penta, octa and decaPBDE – were included in the list of priority hazardous
substances, against which measures should be focused (HELCOM 2010c ).
5.4.3 Analysis of Measures Taken and Approaches Applied
According to HELCOM, the PBDE levels in, for example, fi sh and guillemots are
generally higher in almost all monitored areas in the Baltic Sea than what is defi ned
to be a Good Environmental Status (Nyberg et al. 2013a ). At the same time, the
concentrations of some individual PBDEs are decreasing, which has been claimed
to be a result of the EU restrictions in place since 2004, even though data is missing
for some marine areas (Nyberg et al. 2013a ). It thus seems plausible that the legal
measures against pentaBDE and octaBDE have given results. However, since many
products with PBDEs remain in use and since the restrictions have not targeted
decaBDE , which as such is a problematic substance and in addition can be degraded
in the environment into, for example, pentaBDE, the environment is still affected by
this group of brominated fl ame retardants . It is moreover evident that it took a long
time for measures to be implemented, in particular those for decaBDE. Even if the
time between substance introduction and policy-making is far from as long in total
as for PCBs , the general awareness of chemical risks – and the science-policy arsenal available – was much stronger after the 1980s than in the 1960s, so it could well
M. Karlsson and M. Gilek
5.4.2 HELCOM Policy
By the time brominated fl ame retardants started to be targeted by policymakers, the
Helsinki Convention had been amended, requiring the Parties ‘to prevent and eliminate pollution of the marine environment of the Baltic Sea Area caused by harmful
substances from all sources’. Compared to the 1974 convention, the 1992 version is
more stringent and comprehensive. One example is that the 1974 Annex II list of
‘noxious substances and materials’ has been broadened to a 1992 Annex I list of
‘Priority groups of harmful substances', where, for example, (all) ‘ organohalogen
compounds’ are included, as opposed to only ‘ persistent halogenated hydrocarbons’
in 1974, meaning that now all PBDEs are defi nitely covered at least indirectly.
In the mentioned 1998 Recommendation (19/5) on the 2020 target, brominated
fl ame retardants were included in the list of 280 substances of potential concern, but
neither the BFR-group as a whole nor organohalogens and PBDEs were among the
42 substances prioritised for immediate action. However, explicit reference to
PBDEs was repeatedly made in the 2007 Baltic Sea Action Plan (HELCOM 2007 ),
which updated the Recommendation. PentaBDE and octaBDE were targeted for
use, production and marketing bans by 2010, whereas decaBDE could be a target
from 2009 for less stringent measures, in some sectors, if further assessments
showed a need for taking such action. All three PBDEs were included in a group of
11 substances of ‘specifi c concern’ to the Baltic Sea.
Moreover, 3 years later, when the 1990 Recommendation (19/5) was updated, all
three – penta, octa and decaPBDE – were included in the list of priority hazardous
substances, against which measures should be focused (HELCOM 2010c ).
5.4.3 Analysis of Measures Taken and Approaches Applied
According to HELCOM, the PBDE levels in, for example, fi sh and guillemots are
generally higher in almost all monitored areas in the Baltic Sea than what is defi ned
to be a Good Environmental Status (Nyberg et al. 2013a ). At the same time, the
concentrations of some individual PBDEs are decreasing, which has been claimed
to be a result of the EU restrictions in place since 2004, even though data is missing
for some marine areas (Nyberg et al. 2013a ). It thus seems plausible that the legal
measures against pentaBDE and octaBDE have given results. However, since many
products with PBDEs remain in use and since the restrictions have not targeted
decaBDE , which as such is a problematic substance and in addition can be degraded
in the environment into, for example, pentaBDE, the environment is still affected by
this group of brominated fl ame retardants . It is moreover evident that it took a long
time for measures to be implemented, in particular those for decaBDE. Even if the
time between substance introduction and policy-making is far from as long in total
as for PCBs , the general awareness of chemical risks – and the science-policy arsenal available – was much stronger after the 1980s than in the 1960s, so it could well
M. Karlsson and M. Gilek