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The Government has informed us that every name (identified by email address) that supports this letter will be
counted separately as a responder to the consultation.
Whether you are an upholsterer, or just a person desiring a safer home environment, please read the below letter and sign it by adding your details below.
By contributing to this letter, you are confirming that you would like to work without exposure to toxins, you would like children to grow up without exposure to flame retardants, and you would like your voice to be heard.
Department For Business and Trade
Response to the new approach to the fire safety of domestic furniture
We are concerned with the health and safety of using toxic chemical flame retardants (CFR) in furniture in the UK. The Government has openly recognised the toxicity of CFR to human health and the environment by insisting that all upholstered furniture is to be incinerated at end of life rather than sent to landfill. This is to avoid the flame retardants leaching out into our river systems, our environment and our bodies.
Once these flame retardants are released, by their incorporation in furniture, they cannot be taken back. They persist in our environment. First they release from furniture (off gassing) then they permeate skin or attract to dust or are inhaled in the air. A new study has pulled together evidence of exactly how harmful they are to a child. A young child lacks the enzymes to break down any toxicity, their metabolism is immature, they live close to the floor and they have hand to mouth behaviours. They are also small in size, so the CFR has more impact. By continuing with our practice of including flame retardants in furniture we are building a problem for the next generation. These chemicals are bio-accumulative so they build up in our bodies, and they will continue to build through our lifetimes. Flame retardants have been linked to impaired neurological development, to reduced IQ and to behavioural problems. They can also be endocrine disruptors, affect metabolism and be carcinogenic.
The Fire Brigade Union has concerns with the smoke toxicity and are concerned that the chemicals provide negligible delay and worsen fire conditions.
We had hoped that the new draft regulations on furniture fire safety would follow the recommendations set by the 2019 Government - in their paper Toxic Chemicals in Everyday Life. The recommendation was that we follow the United States in moving to a smoulder test - this test looks to a real life fire risk - and can be met without the use of toxic chemicals. We would also ask the Government to look to Europe, where there is no domestic “open flame test” (this is the UK fire standard leading to such high use of toxic flame retardants). It is noted that this UK fire standard has not lead to our fire statistics being measurably better than our CFR avoiding neighbours in Europe.
Sadly the new regulations go nowhere near far enough. On a positive, they recognise the concern with exposure of children and have excluded cot beds and prams from the regulations. But applying this same logic - sofas and all mattresses represent unacceptable exposure to young children.
The new regulations encourage manufacturers to design fire safe furniture (without CFR) but (1) the obligation is not concrete, it is “if practicable” and (2) even if they succeed in designing fire safe furniture the foam has to be separately tested - leading to continued high use of CFR - and an absence of logic.
On a positive, the new regulations insist that all flame retardant chemicals be labelled, but whilst the openflame test is still applied by these new regulations the risk is that the large majority of manufacturers look to their profit margins and continue business as usual, applying flame retardants to the top fabric, the foam and any other filling. The condition that chemicals be approved by UK Reach is of little worth as a safety net, as they are so far behind EU Reach in the chemicals they have restricted.
Upholsterers have unacceptable occupational exposure to these flame retardants as we lean into the seat of a sofa to fit the fabric, as we hand and machine sew through back coated fabric, our face close as we perforate holes. We cannot upholster whilst wearing gloves so our exposure is unavoidable. Fire safety is of paramount importance - smoke alarms, sprinker systems, reduced ignition propensity cigarettes, avoiding foam in white goods appliances, regulating cheap chargers that overheat, automatic cut offs on overheating electronics, safer lithium ion batteries and caring for the more vulnerable members of society who live alone. These are all positive and practical fire safety steps that seem to have been ignored in favour of a myopic approach of treating furniture with toxic chemicals.
In addition to our occupational exposure, there are a host of issues in the draft regulations that are detailed more thoroughly on the Eco-chair website that affect our business and the quality of the products we can offer. If furniture that we work on (bespoke or post 1950) all have either smoulder resistant CFR free top fabric or a smoulder resistant wool interliner, many of the following concerns would be met.
-1 Bespoke furniture - where we build a sofa/chair/headboard/footstool just for one client we are treated like a mass - manufacturer and need a full product burn. As we are micro businesses this would be prohibitively expensive and would kill this side of our business and kill this corner of creativie design. Care needs to be taken with the word “bespoke” because the mass manufacturers market their furniture as bespoke when the size or fabric is changeable.
- 2 1950-2024 furniture that does not have a fire label is not to be resold unless stripped back to the frame and reupholstered with layer by layer flame treated fillings and a new label applied. Bare in mind from 1950-1980 fire labels didn't exist and this era of furniture is greatly valued. This risks killing the antique and vintage markets and online vintage sellers. In practice most furniture is “refreshed” by applying new top fabric with small additions of filling, rather than being stripped back to the frame (which is more labour intensive and costly).
- 3 It is not clear whether we would be able to work on a client’s furniture if no fire label were present - this would eliminate over 50% of our business
- 4 We currently use natural materials like wool and coir and horsehair and hessian without CFR, is it the intention that these now have CFR added (CFR is not added for a pre 1950 frame so why add for a post 1950 frame)
- 5 You have placed the onus on the upholsterer to keep records of chemicals used for 10 years and ensure fire safety. We are almost all micro businesses reliant on the products offered to us by our suppliers. We struggle to obtain composition information.
- 6 The labelling of furniture that has been re-upholstered needs more thought - ideally for end of life disposal the furniture would be labelled with the chemical composition, but for this we are reliant upon our suppliers providing full labels.
- 7 Whereas a mass manufacturer with a large research and development department and a budget can focus their intentions on designing a chair for a full product burn test, the upholsterer cannot - and for us every layer of filling and fabric has to pass a test. That is likely to lead to the addition of CFR to each layer and competitively disadvantaging us vis-a-vis the mass manufacturer.
- 8 We are currently able to use a 75% natural top fabric with a wool interliner - may we still?
- 9 The size of a standard scatter cushion is 50cm square - these now fall inside the draft regulations leading to increased CFR, yet pillows do not.
The re-upholstery industry advocates for a smoulder test - being met by smoulder resistant top fabric (without CFR) or a smoulder resistant wool interliner.