1. AHFA Flammability Update Bob Luedeka March 20, 2008

2. Topics CPSC Proposed Rule: Standard for the Flammability of Residential Upholstered Furniture 16 CFR Part 1634 Fire Retardant Issues CPSC Proposed Rule: Standard for the Flammability of Residential Upholstered Furniture 16 CFR Part 1634 Fire Retardant Issues

3. CPSC 16 CFR Part 1634 Addresses much of the risk Good starting point Could be amended later to address small open flame Addresses much of the risk Good starting point Could be amended later to address small open flame

4. CPSC 16 CFR Part 1634 Protocol needs to be investigated. Is it reproducible? Representative of composite furniture performance? Protocol needs to be investigated. Is it reproducible? Representative of composite furniture performance?

5. Fire Retardant Issues News coverage continuing regarding FR concerns NGOs posturing to pass CA AB706 Calif. Bureau of Home Furnishings has been quiet about TB117, prefers to see a national standard News coverage continuing regarding FR concerns NGOs posturing to pass CA AB706 Calif. Bureau of Home Furnishings has been quiet about TB117, prefers to see a national standard

6. Claims Need Rebuttal From FR Producers

7. Background Halogenated products Brominated Chlorinated Note: PentaBDEs no longer being used by US foam industry Non-halogenated Phosphorus

8. Killer Couches: Claim: Handheld XRF guns can be used to detect halogenated compounds in upholstered furniture. Response: XRF guns can detect some brominated compounds on the surface of foam and fabric. Accuracy is unknown. XRF guns cannot detect chlorine compounds. Killer Couches: Claim: Handheld XRF guns can be used to detect halogenated compounds in upholstered furniture. Response: XRF guns can detect some brominated compounds on the surface of foam and fabric. Accuracy is unknown. XRF guns cannot detect chlorine compounds.

9. Killer Couches: Claim: Halogenated compounds migrate from furniture to household dust. Response: So far, that’s unproven speculation focused on PBDE compounds. Migration of today’s FR foam additives has not been reported. Killer Couches: Claim: Halogenated compounds migrate from furniture to household dust. Response: So far, that’s unproven speculation focused on PBDE compounds. Migration of today’s FR foam additives has not been reported.

10. Killer Couches: Claim: There is no way to safely dispose of furniture treated with halogenated FRs. Response: There is no evidence of hazard or risk in the customary disposal of furniture treated with halogenated FRs. Killer Couches: Claim: There is no way to safely dispose of furniture treated with halogenated FRs. Response: There is no evidence of hazard or risk in the customary disposal of furniture treated with halogenated FRs.

11. Killer Couches: Claim: Halogenated fire retardants are not used in TB133 furniture. Response: Halogenated compounds are common ingredients in melamine- modified FR foam. Killer Couches: Claim: Halogenated fire retardants are not used in TB133 furniture. Response: Halogenated compounds are common ingredients in melamine- modified FR foam.

12. Killer Couches: Claim: Latex is both fire safe and free of fire retardant chemicals. Response: Latex is flammable and subject to the same regulation in upholstered furniture as polyurethane foam. Large amounts of FR additives are required in latex foam to meet California TB117. Killer Couches: Claim: Latex is both fire safe and free of fire retardant chemicals. Response: Latex is flammable and subject to the same regulation in upholstered furniture as polyurethane foam. Large amounts of FR additives are required in latex foam to meet California TB117.

13. California TB117 AB706 would require the Bureau to revise TB117. PFA requested suspension of the open flame portion of TB117 until more is known about the safety of today’s FR technologies. The Bureau has not commented. AB706 would require the Bureau to revise TB117. PFA requested suspension of the open flame portion of TB117 until more is known about the safety of today’s FR technologies. The Bureau has not commented.

14. FR Additive Developments FR suppliers are developing non- halogenated alternatives. PFA foam manufacturers, AHFA and FR suppliers recently met to discuss issues and concerns. FR suppliers are working to satisfy EPA evaluation requirements on existing and developmental FR products. FR suppliers are developing non- halogenated alternatives. PFA foam manufacturers, AHFA and FR suppliers recently met to discuss issues and concerns. FR suppliers are working to satisfy EPA evaluation requirements on existing and developmental FR products.

15. Bob Luedeka 865-690-4648 pfa.org