Dear California, You Owe America a New Couch

IMG_3300Sent to: tb117comments@dca.ca.gov
Bureau of Electronic and Appliance Repair, Home Furnishings and Thermal Insulation
4244 South Market Court, Suite D
Sacramento, CA 95834

Dear Governor Brown and Chief Blood:

After years of being duped by stooges from the chemical industry, you have finally taken a big step in the right direction.

Your proposed rule on flame retardants in furniture (TB 117-2013) would greatly improve the lives of both Californians and the rest of America, which buys furniture impacted by California’s standards, by allowing furniture makers to drop the use of IQ-destroying, fertility-lowering, carcinogenic chemicals.

In fact, your previous “fire safety” standards did not protect public safety, as tests by federal regulators show, because they delay a fire by only 2-3 seconds, while making smoke, toxicity and soot worse. A comprehensive paper by Arlene Blum and other leading scientists, “Halogenated Flame Retardants: Do the Fire Safety Benefits Justify the Risks?” from Reviews on Environmental Health in 2010 (pdf link here) explains, on pages 281-2:

Laboratory research on TB117 supports this lack of measurable fire safety benefit. A study at the National Bureau of Standards in 1983 showed that following ignition, the important fire hazard indicators (peak heat release rate and the time to peak) were the same in TB117-compliant furniture where the foam was treated with chemical flame retardants and in non-treated furniture. A small flame was able to ignite both regular furniture and furniture meeting the TB117 standard—once ignited, the fire hazard was essentially identical for both types.

A 1995 report from the Proceedings of the Polyurethane Foam Association provides further evidence that TB117 does not improve fire safety. Small open flame and cigarette ignition tests were performed separately on 15 fabrics covering TB117 type polyurethane foam, conventional polyurethane foam, and polyester fiber wrap between the fabric cover and the foam cores. The study found no improvement in ignition or flame spread from a small open flame or cigarette ignition propensity using TB117-compliant foam.

The authors also provide other reasons why the old California test, which exposed the internal foam directly to flame, is pointless — for one, because the fabric often also catches on fire and can provide its own ignition source.

In fact, though its not due to chemicals, the number of people (and children) who die in a fire has gone down dramatically over the past century, which makes sense when you think about the absence of headlines about cows allegedly knocking over lanterns and lighting whole cities ablaze. It’s a resounding victory for public safety measures, as these numbers from the National Fire Protection Association (pdf) indicate:

Out of a million Americans, average number who died of unintentional injury due to fire:
in 2007: 9

in 1992: 16

in 1977: 29

in 1962: 41

in 1947: 56

in 1932: 57

in 1917: 105

Nonetheless, California evidently was taken in by chemical company goons posing as fire safety “experts” touting lies and exploiting the tragic deaths of infants for their own profits.

Interestingly, California lacks a law that provides penalties under the law for lying to state officials or lawmakers. In contrast, federal law has criminal penalties for intentional deception of a federal official, and the federal rulemaking docket at the CPSC on flame retardants, curiously, does not have any comments on burned babies as a part of the submissions. My conclusion? You guys should get one of those laws that makes it illegal to lie to you about important things.

In this case, the consequences were awful. For all of us, really. Because of your terrible judgment, we have pounds of dangerous and pointless chemicals in our homes, in our indoor air, and in the bloodstreams of our children. As the Blum paper says:

Many of these chemicals are now recognized as global contaminants and are associated with adverse health effects in animals and humans, including endocrine and thyroid disruption, immunotoxicity, reproductive toxicity, cancer, and adverse effects on fetal and child development and neurologic function.

How many kids have you put at risk? Let’s make a rough estimate. A recent paper reported on by the New York Times, found flame retardants in the blood of 100 percent — every single! — toddler they tested. And a table under the Population tab on this page indicates that there are an estimated 50.7 million children in the U.S. ages 0-11 today. The CPSC study (pdf) as to chlorinated tris (just one of these chemicals) in 2006 specifically concluded:

The estimated cancer risk for a lifetime of exposure to TDCP-treated upholstered furniture was 300 per million. In children, the estimated cancer risk from exposure during the first two years of life alone was 20 per million. Both of these risks exceed one-in-a-million. A substance may be considered hazardous if the lifetime individual cancer risk exceeds one-in-a-million.

So the overall risk for a child from exposure to tris is 20 times 50 million children, or one thousand kids (extra) with cancer. And, sadly, childhood rates of the worst kinds of cancer are on the increase. According to the National Cancer Institute:

Over the past 20 years, there has been some increase in the incidence of children diagnosed with all forms of invasive cancer, from 11.5 cases per 100,000 children in 1975 to 14.8 per 100,000 children in 2004.

In fact, it appears that a person’s lifetime risk of dying of cancer is 192 times their risk of dying in a fire:

Lifetime odds of death for selected causes, United States, 2008*

Total, any cause 1 in 1

Heart disease 1 in 6

Cancer 1 in 7


Exposure to smoke, fire, and flames 1 in 1,344

And that’s just for cancer risks. There’s also reproductive harm, attention deficit issues, and other health damage linked to flame retardants. For just one example, here’s sobering coverage of a 2012 study linking maternal-fetal levels of PBDEs, another ubiquitous flame retardant found in 97 percent of the study subjects, to delayed development in the child at age 7.

In sum, you’ve royally screwed up. The best thing to do when you’ve made a colossal error in judgment? Apologize and try your best to make it right.

There’s really no two ways about it, California: you owe Americans a new couch. One that won’t poison our homes and make our children sick. One that won’t show up in our bloodstreams, ‘fer Pete’s sake.

Seriously. This is really not too much to ask, given the harm you’ve caused. IMHO, the chemical companies could pay for it out of the profits they made peddling all that cancerous stuff. Certainly, the good people of California, who have the highest levels of flame retardants in their bodies in the world, have suffered enough.

At any rate, I look forward to hearing from you. A (flame-retardant-free) loveseat in a nice brown or beige would do just fine.

All best,

Laura

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Related posts:

Must Read: Today’s Great New York Times Story on Toxic Sofas

Red sofa

Red sofa (Photo credit: Wikipedia)

I’ve been under the weather with viral bronchitis all week, but was cheered to see this long and wonderful article today in the New York Times featuring a personal heroine of mine, Arlene Blum.

Most shocking from the piece? This information from a new study on flame retardants in the blood of toddlers (the emphasis is mine):

Most disturbingly, a recent study of toddlers in the United States conducted by researchers at Duke University found flame retardants in the blood of every child they tested. The chemicals are associated with an assortment of health concerns, including antisocial behavior, impaired fertility, decreased birth weight, diabetes, memory loss, undescended testicles, lowered levels of male hormones and hyperthyroidism.

The article talks about the California rule on flame retardants, now under reconsideration in that state. It also notes the need for a federal bill that would better regulate chemical safety, like the Safe Chemicals Act that just got a hearing in the Senate. And it makes clear the problem that new chemicals remain under a shroud of secrecy, under rules that allow the chemical industry to deem them “proprietary” despite being in all of our living rooms:

Logic would suggest that any new chemical used in consumer products be demonstrably safer than a compound it replaces, particularly one taken off the market for reasons related to human health. But of the 84,000 industrial chemicals registered for use in the United States, only about 200 have been evaluated for human safety by the Environmental Protection Agency. That’s because industrial chemicals are presumed safe unless proved otherwise, under the 1976 federal Toxic Substances Control Act.

When evidence begins to mount that a chemical endangers human health, manufacturers tend to withdraw it from the market and replace it with something whose effects — and often its ingredients — are unknown. The makeup of the flame retardant Firemaster 550, for instance, is considered a proprietary trade secret. At a recent conference, Stapleton discussed a small, unpublished study in which she fed female rats low doses of Firemaster 550. The exposed mothers’ offspring gained more weight, demonstrated more anxiety, hit puberty earlier and had abnormal reproductive cycles when compared with unexposed offspring — all signs that the chemical disrupts the endocrine system.

The article also notes how difficult it is to find furniture without chemicals in it, which is certainly the case. In addition to the options I’ve laid out in prior posts, linked to below, I’ve recently found a few new cheaper possibilities:

  • First, I found a wonderful mid-century modern chair on Craigslist for a little more than $100 with the original mid-60s upholstery. Since these flame retardant chemicals generally entered furniture after 1975, it’s likely fine, though I didn’t have any testing done. Other wood-framed mid-century pieces, including sofas, could be fitted with custom-made cushions, which I’ve ordered from Etsy for some of our current furniture, or, if you’re crafty, even made by hand.
  • Futons are an option– according to a wonderful reader of this blog, SallyS, there are evidently a range of cushion options, including organic. Again, Craigslist may be an option for cheap solid wood frames.
  • Also on Craigslist, I scored a 20-year-old Italian-made leather chair for a very reasonable sum. Given its foreign make and age, I’m guessing, again, that this is likely ok. While I realize that very-old-and-foreign-made-and-still-desirable-for-my-sitting-room is likely a small category, I figured it was worth a mention…

If you’re hunting for more options, please check out the posts below as well as the incredibly helpful comments from resourceful readers for some greener manufacturers and other DIY ideas.

More resources on flame retardants and furniture: