1. Flammability Standards, Flame Retardants, and Healthy Buildings
Arlene Blum, PhD
Green Science Policy Institute

2. We can reduce harmful chemicals for a healthier world.
SixClasses.org
We can reduce harmful chemicals for a healthier world.

3. Periodic table of elements
Halogens 3

4. SixClasses.org F Cl Br 4 Fluorinated chemicals9 F
Fluorinated chemicals
stain and water repellants 17 Cl
Chlorinated antimicrobials
triclosan and triclocarban 35 Br
Flame retardants
brominated, chlorinated, phosphate
Regrettable substitutions.
Endocrine disrupting plasticizers
BPA, phthalates, etc.
Some solvents
benzene, methylene chloride, xylene, etc.
Some heavy metals
lead, mercury, chromium, cadmium, arsenic, etc. 4

5. Flame retardants are used to meet flammability standards
1973 Furniture flammability standard TB117 (Standard mandated by California legislation)
1976 Uniform Building Code for foam plastic insulations (Private code body)

6. Why are flame retardants in furniture & baby products?
California Technical Bulletin 117:
Required filling inside furniture to withstand a small open flame for 12 seconds
No significant fire safety benefit
(fires start in fabric covers, not in fillings)
The Bureau was founded in 1906 after the great San Francisco earthquake. No other state has anything similar.
Filling materials  foam inside furniture
TB117 was a de facto standard across the US and Canada because CA is a major portion of the market.
TB117 does not apply to toddler sleep mats, mattress pads, or carpet cushion but it is still followed for these products
TB117 requires the foam inside furniture to withstand a 12-second exposure to a small open flame. However in a real-life fire, fabric ignites first, exposing the interior foam to a much larger flame. When this happens, flame retardants in foam do not prevent ignition of the foam or reduce the severity of the fire.
Babrauskas, V. et al. Flame Retardants in Furniture Foam: Benefits and Risks. Fire Safety Science. 2011; 10:
Talley, TH. Phases 1&2, UFAC Small Open Flame Tests and Cigarette Tests. Annual AFMA Flammability Conf
Mehta, S. Upholstered Furniture Full Scale Chair Tests – Open Flame Ignition Results and Analysis. Bethesda, MD: U.S. Consumer Product Safety Commission; 2012.
Babrauskas, V. Upholstered Furniture Heat Release Rates: Measurement and Estimation. Journal of Fire Sciences Jan1;1(1):9-32 10

7. PentaBDE flame retardant
PCB
Used from 1975 to 2004 to meet TB117.
Chemical structure similar to PCBs, dioxins & furans.
Globally banned as a persistent organic pollutant (POP)
PBDE
PBDEs are halfway between PCBs and dioxins in structure and also in some biological properties.
We can have pounds of PBDEs in our homes or offices.
Most usage of pentaBDE was to meet TB117.
Dioxin
Furan
Combustion Products

8. Firefighters Elevated rates of multiple myeloma non-Hodgkin’s lymphoma
prostate and testicular cancers
Associated with dioxin/furan exposure.
This study was a meta-analysis of 32 studies including ~110,000 firefighters
G.K. LeMasters, et al, Journal of Occupational and Environmental Medicine 48(11): (2006).
R.D. Daniels, et al, Occupational and Environmental Medicine oemed Published Online First: 14 October 2013

9. Animal health effects
Chronic toxicity: long term impacts
Endocrine disruption: Interference with thyroid hormone action
Neurodevelopment: Decreased memory, learning deficits, altered motor behavior, hyperactivity
Reproductive system effects: Abnormal gonadal development, reduced ovarian follicles, reduced sperm count
Immune suppression
Cancer
Most of these studies were done with pentaBDE, some with octaBDE or decaBDE.
These were done by many different independent scientists using many different animal models and published in peer-reviewed journals.
Thyroid hormone is critical for normal development of the brain and nervous system. PCBs are also thyroid disruptive.
Reproductive effects- both male and female.
Immune suppression- makes more susceptible to disease including cancer
Cancer- both decaBDE and tris (TDCPP) are carcinogens
Meeker JD et al. Polybrominated diphenyl ether (PBDE) concentrations in house dust are related to hormone levels in men. The Science of the total environment May 1;407(10):
Chevrier J et al. Polybrominated diphenyl ether (PBDE) flame retardants and thyroid hormone during pregnancy. Environmental Health Perspectives Oct;118(10):
Herbstman JB et al. Prenatal exposure to PBDEs and neurodevelopment. Environmental Health Perspectives May; 118(5):712-9.
Eskenazi B et al. In Utero and Childhood Polybrominated Diphenyl Ether (PBDE) Exposures and Neurodevelopment in the CHAMACOS Study. Environmental Health Perspectives. 2012; (November).
Roze E et al. Prenatal exposure to organohalogens, including brominated flame retardants, influences motor, cognitive, and behavioral performance at school age. Environmental Health Perspectives Dec; 117(12):
Shaw SD et al. Halogenated flame retardants: do the fire safety benefits justify the risks? Reviews on environmental health. 2010;25(4):

10. PentaBDE human health associations 14
Higher pentaBDE
associated with
lower birth weight
impaired attention
poorer coordination
lowered IQ
Neurological effects- related to learning and development. altered behaviors including hyperactivity.
Disruption of developmental processes results in permanent, irreversible damage.
New studies- possible obesogens
longer time to get pregnant
altered thyroid hormones
Eskenazi et al, 2010, 2011, 2012

11. Flame retardants move from products to people 1
Levels observed in cats are 10 – 100x those seen in humans due to their grooming behavior.
Levels in toddlers are ~3x higher then in adults due to hand-to-mouth behavior.
Jones-Otazo HA et al. Is house dust the missing exposure pathway for PBDEs? An analysis of the urban fate and human exposure to PBDEs. Environmental Science & Technology Jul 15;39(14):
Zota AR et al. Elevated house dust and serum concentrations of PBDEs in California: unintended consequences of furniture flammability standards? Environmental Science & Technology Nov 1;42(21):
Watkins DJ et al. Exposure to PBDEs in the office environment: evaluating the relationships between dust, handwipes, and serum. Environmental Health Perspectives Sep;119(9):
Dye JA et al. Elevated PBDE levels in pet cats: sentinels for humans? Environmental Science & Technology Sep 15;41(18):
Venier M, Hites RA. Flame retardants in the serum of pet dogs and in their food. Environmental Science & Technology May 15;45(10):

12. THE PROBLEM: 17 Most Chemicals Are NOT Effectively Regulated in the U
THE PROBLEM: 17 Most Chemicals Are NOT Effectively Regulated in the U.S.
The U.S. Toxic Substances Control Act (1976)
62,000 chemicals in commerce “grandfathered”
20,000 new chemicals have been introduced
85% have no health data
67% have no data at all
The EPA has tried unsuccessfully to regulate asbestos use. They have given up trying to regulate any of the 62,000 chemicals “grandfathered” in when TSCA was implemented in 1976.
Michael Wilson, Green Chemistry in California:

13. Regrettable Substitutions?
MUTAGEN X
TOXIC, PERSISTANT, BIOACCUMULATIVE X
Kid’s PJs
Brominated Tris
Furniture, baby products
PentaBDE
MUTAGEN X
CARCINOGEN X
brominated tris banned from PJ’s 1977
The use of chemicals flame retardants has followed a cycle of regrettable substitutions, where a chemical with known hazards or risks is phased out and replaced by one which is often similar in chemical structure or properties, but about which there is little or no environmental or health-related data.
“Regrettable substitution: An alternative about which we know very little and presume safety, later coming to learn otherwise
AND/OR
An alternative that presents different hazards or risks than the original, thus representing trade offs rather than improvements.”
(Singla, V. GSP Blog post 10/10/ )
Chlorinated Tris
Chlorinated Tris
OBESITY, ANXIETY?
Firemaster 550
Phosphates
TOXICITY??

14. Do we need them? Flame retardants in furniture foam do not significantly slow ignitions
Do not prevent fires or decrease fire hazard
If you drop a cigarette or match on something, what burns first? The cover/fabric.
Studies found that the cover will catch on fire whether or not there are FRs in the filling; once it starts burning you have a larger flame that overwhelms the flame retardants in the foam. Studies at the consumer product safety commission found no practical significant difference between the fire performance of furniture with and without flame retardants.
TB117 requires the foam inside furniture to withstand a 12-second exposure to a small open flame. However in a real-life fire, fabric ignites first, exposing the interior foam to a much larger flame. When this happens, flame retardants in foam do not prevent ignition of the foam or reduce the severity of the fire.
Babrauskas, V. et al. Flame Retardants in Furniture Foam: Benefits and Risks. Fire Safety Science. 2011; 10:
Talley, TH. Phases 1&2, UFAC Small Open Flame Tests and Cigarette Tests. Annual AFMA Flammability Conf
Mehta, S. Upholstered Furniture Full Scale Chair Tests – Open Flame Ignition Results and Analysis. Bethesda, MD: U.S. Consumer Product Safety Commission; 2012.
Babrauskas, V. Upholstered Furniture Heat Release Rates: Measurement and Estimation. Journal of Fire Sciences Jan1;1(1):9-32.
no flame retardants
with flame retardants
BUT do cause health problems
Babrauskas 1983; Talley 1995; Mehta 2012

15. Playing with Fire 15 Google Pulitzer Prize Goldsmith Prize
Finalist
Goldsmith Prize
Investigative Reporting
Environmental Journalists Society
Environmental Reporting
Gerald Loeb Award
Business and Financial Journalism
National Press Club
Consumer Award 15 15

16. California Flammability
Standard TB
Implement on January 1st, 2014
Mandatory on January 1st, 2015
85% fabrics already pass
15% need non-FR polyester batting between fabric and foam

17. TB117 and baby products 17 December 2010: three exempted
January 1, 2014: 15 more exempted
TB117 and baby products 17 17

18. What can consumers do? http://greensciencepolicy.org/consumers
Vacuum, wet mop and hand wash to reduce exposure to dust
Buy furniture with a TB label as they become available.
Ask for products without flame retardants 18

19. Recent Policy Actions California Furniture standard TB117-2013
Smolder standard for cover fabric where fires start
Increased fire safety
Flame retardants not needed
California Assembly Bill 127 for buildings
Re-evaluates insulation flammability standards
“Provide manufacturers with flexibility in meeting the flammability standards, with or without the addition of chemical flame retardants…”
FR foam test was passed first and later a stringent test for flashover a thermal barrier, concrete or masonry was passed but no one appears to have revisited the earlier foam FR test to determine if it still provided any benefit.
thermal barriers (such as gypsum board, concrete or masonry) provide adequate protection of foam plastics, which is not improved by the use of flame retardants chemicals to meet the test.
When faom is behind a thermal barrier such as sheetrick wall, concrete, or masonry adding flame retardants downt’ increase fire safety and provided a potentail for harm
do not to have to meet flame spread and smoke developed requirements and don’t need added flame retardants.
By changing these codes, the potential for health and ecological harm from the use of flame retardant chemicals would be reduced and the fire safety of buildings would be maintained.    - 19

20. Plastic foam insulations
polystyrene (XPS and EPS)
polyurethane
polyisocyanurate
More information:
TCPP
HBCD 20

21. HBCD animal health effects
Thyroid disruption
Affects the developing nervous system
Developmental neurotoxicity in mice
Covaci et al (2006). Hexabromocyclododecanes (HBCDs) in the environment and humans: a review. Environmental Science and Technology 40(12),
Marvin et al (2011). Hexabromocyclododecane: current understanding of chemistry, environmental fate and toxicology and implications for global management. Environmental Science and Technology, 45(20),
Eriksson et al (2006). Impaired behavior, learning and memory in adult mice neonatally exposed to hexabromocyclododecane (HBCDD). Environmental Toxicology and Pharmacology, 21(3),
HBCD is bioaccumulative
Average HBCD (ng/g)

22. EmeraldTM 3000 CAS:
Regrettable substitution? Little is known about possible health effects or environmental toxicity of Emerald 3000 or possible breakdown products. Little data has been provided by industry, and independent research has not yet occurred.
Many key exposure routes (production of the flame retardant and of insulation products, thermal cutting during installation, and disposal) remain problematic, and are unknown.
Zhang et al (2012). Co-Release of Hexabromocyclododecane (HBCD) and Nano- and Microparticles from Thermal Cutting of Polystyrene Foams. Environmental Science and Technology ,
Copolymer of polystyrene and brominated polybutadiene
Replacement for HBCD in EPS and XPS insulation
Chemtura production plant being built in China
EPA predicts possibly
-toxic from inhalation?
-persistent, and bioaccumulative
January 2012

23. TCPP animal health studies
TCEP
CARCINOGEN
Potential carcinogen
Accumulates in liver and kidneys
Affects nervous system development
More study needed ?
TCPP
Crump et al (2012). Effects of tris(1,3-dichloro-2-propyl) phosphate and tris(1-chloropropyl) phosphate on cytotoxicity and mRNA expression in primary cultures of avian hepatocytes and neuronal cells. Toxicological Sciences, 126(1),
Dishaw et al (2011). Is the PentaBDE replacement, tris(1,3-dichloro-2-propyl) phosphate (TDCPP) a developmental neurotoxicant? Studies in PC12 cells. Toxicology and Applied Pharmacology, 256(3),
van der Veen and deBoer (2012). Phosphorus flame retardants: properties, production, environmental occurrence, toxicity, and analysis. Chemosphere, 88(10),
TDCPP
CARCINOGEN

24. Is there a fire safety benefit?

25. Majority of fire deaths from inhalation of toxic gases
Average percent of flame and fire deaths by cause,
2% other
22% both
Studies have shown that plastics containing the flame retardant HBCD produce more soot, smoke, and carbon monoxide when burned compared to non-HBCD containing plastics.
(Babrauskas, 1992; Babrauskas, 2012; Schnipper et al., 1995; Stec and Hull, 2011; Purser, 2000; Wichman, 2003)
According to UK fire statistics, since the 1960s, the proportion of total fire deaths and injuries resulting from toxic gas inhalation has increased. (Hull, 2013)
63% smoke inhalation
28% burns
Hall, NFPA 2011

26. Take Home Points
Many flame retardants are associated with adverse health effects.
No evidence that flame retardants in home furniture, baby products, and building insulation behind thermal barriers improve fire safety.
Widespread contamination of water, food, and soils; distributed globally by air and water circulation; end up in food supply.
Use can be reduced and fire safety maintained or increased 28