AHFA Flammability UpdateAHFA Flammability Update

Bob LuedekaMarch 20, 2008

Bob LuedekaMarch 20, 2008

TopicsTopics

• 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

CPSC 16 CFR Part 1634CPSC 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

CPSC 16 CFR Part 1634CPSC 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?

Fire Retardant IssuesFire 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

Claims Need Rebuttal From FR ProducersClaims Need Rebuttal From FR Producers

BackgroundBackground

Halogenated products

Brominated ChlorinatedNote: PentaBDEs no longer being used

by US foam industry

Non-halogenated

Phosphorus

Halogenated products

Brominated ChlorinatedNote: PentaBDEs no longer being used

by US foam industry

Non-halogenated

Phosphorus

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.

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.

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.

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.

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.

California TB117California 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.

FR Additive DevelopmentsFR 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.

Bob Luedeka865-690-4648pfa.org