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Chemical flame retardant consultation

WE NEED YOUR HELP

Flame retardants - more harm than good

The Government acknowledges the harm to health and the environment of chemical flame retardants in furniture and has published a consultation on new draft regulations, the aim being to reduce toxic chemical flame retardant usage and retain fire safety.

 

The intention is good but the approach is flawed and likely in practice to lead to the continued high use of toxic flame retardants.

We believe the harm caused by the chemicals used to meet the open flame test outweighs the fire safety benefit. We believe that the open flame test is mis-conceived as there is growing evidence that it offers negligible delay to fire ignition. We believe that the Government should look to the science. And we are concerned that the regulations have not given proper consideration to the re-upholstery business. Given a new report explaining the vulnerability of children to the effect of these chemical flame retardants we encourage a full response to this consultation.

This is a unique opportunity to promote a shift away from chemical flame-retardant use and towards more innovative, effective and sustainable solutions to fire safety.

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HAVE YOUR SAY

The consultation is now closed, thank you for taking the time to respond - every voice counts. 

We will keep you updated on the outcome of the consultation.

1

More harm than good

  • Studies have shown that chemical flame retardants used in furniture exacerbate smoke and fire toxicity.

  • Despite much of Europe and the whole USA using a smoulder test, these regulations contain an open flame test. Only with the very smallest flame size will we see the potential to design out chemical flame retardants.

  • The number of fire deaths in the UK is not out of kilter with the number of fire deaths in neighbouring countries - so there is no proof this open flame test helps fire safety.

  • Smoke alarms, sprinkler systems, public awareness campaigns, testing of imported furniture, regulating cheap chargers - these are all positive for fire safety.

2

Children

Children lack the enzymes needed to break down and remove toxic chemicals from their system. They mouth items, they spend more time close to the floor where the chemicals collect in dust, their metabolic pathways are too immature to metabolise the chemicals and they ingest more dust, breathe more air and consume more food relative to their body size when compared with an adult. 

 

Chemical flame retardants have been linked to impaired neurological development in children, reduced IQ and behavioural problems. With this information we question whether the benefit of flame retardant chemicals is worthwhile in any situation, for any piece of furniture.

3

Reupholstery and the circular economy

The reupholstery industry offers a meaningful contribution to the circular economy in repairing and recycling furniture.

 

An upholsterer would need each individual new filling material and top fabric open flame tested to be compliant with these draft regulations. This could see all top fabric and fillings treated with chemical flame retardants. This puts upholsterers at a competitive disadvantage - they are not able to create furniture that is free of chemical flame retardants.

 

Without an old fire label being present its not clear that an upholsterer would be able to work on a client's chair or sofa. Perfectly refreshable furniture would have to go to incineration, actively going against furniture recycling targets, while upholsterers lose their core business.

4

Upholstery Proposals

Whilst we support the composite product testing for the large manufacturers this is unworkable for small manufacturers and unworkable for upholsterers making bespoke products.

We propose that the re-upholstery industry use either smoulder resistant fabric or a certified wool interliner to achieve compliance. This follows the proposal of the Environmental Audit Committee.

We propose that natural filling materials (excluding latex) be excluded from the regulations.

We fully support the introduction of robust labelling requirements. These give consumers full disclosure. They also allow end of life assessment of whether incineration is strictly necessary due to contamination.

Why this matters

Help to stop the increased use of flame retardant chemicals

Harm

More info

1 / More harm than good

We are concerned that despite good intentions, there may not be a meaningful drop in the use of chemical flame retardants under this draft legislation:

 

(a) Under the new regulations the finished furniture article is fire tested. The manufacturer can innovate and design to achieve fire safety, which we support. However the regulations then propose that the foam be separately tested. This gives no real life additional fire safety benefit, yet doing so involves a quantity of unnecessary flame retardant chemicals and undermines the very essence of designing a product that resists ignition.

(b) Studies have shown that chemical flame retardants used in furniture exacerbate smoke and fire toxicity. The Fire Brigade Union supports increasing evidence that chemical flame retardants provide negligible delay to fire ignition, worsen fire conditions, and therefore will increase dangers to firefighter safety and welfare. We do not believe that the benefit of flame retardant chemicals can be examined without also looking at their proven harm. 

 

(c) despite much of Europe and the whole USA using a smoulder test, and the UK Environmental Audit Committee having recommended a smoulder test, these regulations contain an open flame test. Only with the smallest flame size will we see the potential to design out chemical flame retardants and then only for the companies with research and development departments large enough to dedicate time and money to these fire safe - chemical free design solutions. With the open flame test in the current law almost no UK sofas can be manufactured free of chemical flame retardants. 

 

(d) The number of fire deaths in the UK is not out of kilter with the number of fire deaths in neighbouring countries - who do not have a high use of flame retardants. We therefore do not see any evidence that the flame retardant chemical usage offers any discernable benefit.

 

(e) According to these regulations, manufacturers are required to consider alternatives to chemical flame retardants “if practicable” - we are concerned that this is not a robust obligation. There is every chance that the majority of manufacturers will continue business as usual - flame retardants in the foam and in the top fabric.

 

(f) We are aware that chemicals migrate out of foam and furniture, so is it only when furniture is new that these flame retardant chemicals offer any benefit and in weighting benefit versus harm has this migration been taken into account? (see the FIRA website which says the flame retardant chemicals survive 3-6 washes).

 

(g) is the flame retardant treatment of sofas safe for children when the Whaley Report refers to the sofa as a “reservoir of chemical flame retardants”

2 / Children

We fully support the exclusion of children’s products from the regulations. Children lack the enzymes needed to break down and remove toxic chemicals from their system. They mouth items, they spend more time close to the floor where the chemicals collect in dust, their metabolic pathways are too immature to metabolise the chemicals and they ingest more dust, breathe more air and consume more food relative to their body size when compared with an adult. 

 

Chemical flame retardants have been linked to impaired neurological development in children, reduced IQ and behavioural problems. With this information we question whether the benefit of flame retardant chemicals is worthwhile in any situation, for any piece of furniture.

 

The US government noted that the harm from FR chemicals clearly outweighed any debatable benefit before changing their fire regulations - the UK should do the same.

3 / Reupholstery and the circular economy

The reupholstery industry offers a meaningful contribution to the circular economy in repairing, refreshing, renewing and recycling furniture and in designing and building one off quality long lasting bespoke pieces, yet the regulations as drafted disproportionately harm the industry.

For upholsterers creating one off entirely bespoke designs and having these built on a one off basis by a carpenter is a meaningful part of their business. This is also a skillset as a country that we should want to preserve as these products tend to be well built and built to last. However this part of our business will be rendered impossible if the entire item needs to be burnt. Truly one off bespoke furniture needs to be treated differently by these regulations. 

 

Where an upholsterer receives a client’s sofa, needs to strip out degraded fillings and replace these fillings, each individual filling material and fabric would need fire testing to be compliant with these draft regulations. That could see inherently flame resistant materials such as horsehair and wool being chemically treated just to pass this test. These materials have been used for centuries, tend to singe not burn and do not present a material fire risk. Furthermore, when upholstered using traditional methods filling materials are heavily compressed, thereby increasing their density and fire resistance. As every upholsterer compresses to a unique density this would in practice be very difficult to test. 

 

Where an upholsterer receives a client’s sofa and due to a slight degradation in fillings the upholsterer chooses that the most cost effective way forward is to add a small level of new filling materials - in this case the upholsterer might have to turn the business away unless the chair was provided with an intact existing fire label. Most of the chairs and sofas we are handed for re-covering and “adding” filling material do not still have a fire label still intact. We risk losing the majority of our overall business if this were the case and perfectly refreshable furniture would have to go to incineration.

 

Where an upholsterer buys old chairs or sofas at auction or markets, intending to restore them, recover them and resell them - this would only be possible if a fire label was intact (or the chair pre-dated 1950).  This could lead to the loss of our mid century modern furniture design history and the decimation of the antiques business and vintage sellers like ebay, Etsy, Interior, 1st Dibs and the Saleroom.

 

A workable solution to the above problems would be for the upholsterer to either apply a fire safe 100% natural interliner immediately under the fabric top cover, or for the fabric top cover to be certified as smoulder resistant. The top fabric supplier should be responsible for certification of the smoulder resistance status. They should publish whether this had been achieved with or without chemical flame retardants and clearly label chemicals used.  The top fabric supplier should be accountable for providing the upholsterer with the relevant fire label for them to attach.  

4 / Robust labelling

We fully support the introduction of robust labelling requirements and we would like to see:

  1. The chemicals listed for each individual filling material

  2. The chemicals being clearly identified with their common chemical acronym

  3. A separate label for the reupholstery industry identifying either that an interliner has been used; or that the top fabric was smoulder resistant. Fabric can be smoulder resistant without the use of chemical flame retardants. If the client chooses a fabric that has been chemically treated then the chemicals should be clearly identified. Old fire labels (if any) would also be reaffixed to the furniture.

  4. The responsibility for providing a label for a chemically treated top fabric should rest with the manufacturing fabric house.

 

Historically we have, despite best efforts, had little success in obtaining information from suppliers or fabric houses on the chemicals used or the safety data sheets for products. We do not have the buying power of the manufacturers to insist upon this information and as such we would like to see the obligation fall on the fabric companies. The vast majority of upholsterers are micro-businesses often sole traders. We largely purchase filling materials from a small cohort of upholstery suppliers and we have little contact with manufacturers. Our buying power is small and historically we have struggled to acquire details on filling material ingredients and chemical treatment. 

 

We believe the labelling per component part is necessary for end of life recycling and moving to a circular economy. It is also important for the occupational health of an upholsterer.

Natural materials
Toxic smoke
Chidren

Links

1 / The new draft regulations

The government are seeking views on a proposed new approach to the fire safety of domestic upholstered furniture and furnishings.
Read the new draft regulations

2 / Open letter

An open letter to the Government was sent by upholsterers concerned about their occupational exposure. 

Open Letter

Studies

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