Global Scientific Organization Blasts Koch Study As Press Remain Silent on Bias and Omissions

The International Bromine Council (BSEF), a global organization of scientists and engineers working on bromine-based technologies, is voicing strong concern with the “unprofessional behaviour” on display in a recent study on Polymeric Flame Retardant led by Christoph Koch. BSEF secretary general Dr. Kevin Bradly calls Mr. Koch to account for “withhold[ing] from the reader clearly relevant data, thus giving a distorted and erroneous picture” of the facts.


In an earlier study, Koch et al subjected Polymeric FR to a series of degradation experiments. Under unrealistic conditions, which do not represent normal conditions of use, the study found a range of degradation products (ca. 75) and identified 3 potential degradation products[2.

A follow up study by the same authors[3 subjected these 3 degradation products of Polymeric FR to several standard OECD ecotoxicity tests. The study also tested a 4th substance, which was not found in the above study.

The study did not find any meaningful acute effects.” said Dr Kevin Bradley, BSEF Secretary General. “The authors themselves indicate that “If at all, effects can only be found at extremely high concentrations, which are presumably not to be expected following degradation of “polymeric FR””. In a chronic test, the authors found an effect level when testing a mix a 4 substances[4. However, using a worst case scenario where these products may reach the environment the authors conclude that environmental levels are about 10,000 times lower than their effect level, so no risk is to be expected. Moreover, they conclude that “…with proper precautional care (sic), such products might never end up in the environment”.

Commenting on this finding, Dr Bradley said “It is regrettable that these results were not discussed in the first (degradation) paper by the same authors. This would have helped put the results into context. Unfortunately the authors decided to not mention this finding in that paper, despite the fact that the results were available at the time. In our view, it is unprofessional behaviour, from a science research perspective, to withhold from the reader clearly relevant data thus giving a distorted and erroneous picture.”

About BSEF

BSEF is the international bromine producers organisation. Since 1997, the organisation has been working to foster knowledge on the uses and benefits of bromine-based solutions. BSEF strongly believe in science and innovation. Through investments in research and development BSEF members create robust bromine-based technologies meeting the needs of society. The members of BSEF are Albemarle Corporation, ICL Industrial Products, Lanxess and Tosoh Corporation.

[1] 5-bromosalicylic acid, 2,4,6-tribromo-3-hydroxybenzoic acid, and 3,5-dibromo-4-hydroxybenzoic acid

[2] Science of the Total Environment 656 (2019) 101–107

[3] An EC50 value of 187 ug/L per substance


As we previously detailed Mr. Koch’s latest research fails to test Polymeric FR in real-world applications, and ignores his own companion study, which undermines his conclusions.

We reached out to Mr. Koch with our concerns throughout the research process, but he failed to include the data we provided. We reached out again after publication to get answers, but he continues to ignore us.

When the study was first covered in Environmental Heath News, without even a request for comment from DowDupont, we had to push for an update to make sure our perspective was included. Some more recent reporting did provide a more balanced view.

We also contacted Environmental Science & Technology, which published the study, and its parent company, ACS Publications, about the clear conflict of interest created by Mr. Koch’s employment at Rockwool, which makes an insulation that competes with foam. ES&T has agreed to our request for space in their publication to respond to the study.

We continue to pursue all options to make sure readers know the truth.