Dow Responds to Flawed Environmental Health News Story on PolyFR


In response to the Environmental Health News article “Environmentally friendly flame retardants break down into potentially toxic chemicals”, we find it unfortunate that EHN elected to reach out to us only after the article was published as we do have familiarity with the content of the studies conducted by University Duisburg-Essen and Christoph Koch. If we had been contacted, we would have been able to provide context and insight that could have brought the EHN article a more balanced perspective.  

We absolutely reject the inference from the Green Policy Science Institute, and reinforced in the article, that this is a regrettable substitution.

Dow shares the same commitment as the green building industry to advancing greener, safer chemistry, evidenced by our decades of sustainability leadership and in particular our 2025 Sustainability Goal on Safer Materials for a Sustainable Planet.  This intent motivated our election to develop PolyFR, and we firmly believe this technology is a step in the right direction to improve the sustainability profile of flame retardants used in polystyrene foam insulation.  The 2014 EPA Design for the Environment study supports this technology as the best option available.

Dow has conducted extensive testing on the safety profile of PolyFR, including degradation.  Our findings have been presented in recent years at notable forums such as the Society of Environmental Toxicology and Chemistry, Fire and Materials, and Green Chemistry & Engineering conferences.

We have been aware for many years of the work conducted by Christoph Koch, and over the past several years have provided comments on this series of studies.  Many of our comments were not reflected or acknowledged in the published papers.  We agree with the author’s own perspective that PolyFR may degrade differently when incorporated into polystyrene foam insulation.  This acknowledgment clearly suggests that inferences made for PolyFR from the Koch study should be treated very carefully. Since this technology was developed specifically for polystyrene foam insulation, and because the specific environment in which the fire retardant is exposed to has a profound influence on the degradation performance of the fire retardant, conclusions regarding the safety performance of the fire retardant should only be drawn by studying conditions that are fully relevant to the application itself.  Potential environmental impact should have been validated by studying degradation within polystyrene foam insulation, which was omitted in the scope of this study.