Sent to: firstname.lastname@example.org
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:
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.
- Ouch, Couch! A Sad Sofa Saga, Part One
- Ouch, Couch! A Sad Sofa Saga, Part Two
- Sofa Saga, Part Three: An Interview with Flame Retardants Expert, Heather Stapleton
- Sofa Saga, Part Four: Some Success! Two Great Sources for Greener Sofas
- Must Read: The Chemical Industry’s Big Fat Liar on Flame Retardants
- Curb Alert: Free (Toxic) Sofa
- California Governor Brown Orders State to Change Flame Retardant Rule
- Burning Questions: An FAQ on Flame Retardants in Furniture
- Must Read: Today’s Great New York Times Story on Toxic Sofas
- More Misadventures with Flame Retardants: So.Much.Fun.
- All Frothy Over Flame Retardants in Foam
- New Study Released Today Confirms: 85 Percent of Sofas Contain Toxic Chemicals
- Must Read: Flame Retardant Chemicals in My Gatorade?
- And now, for some things YOU can do on Flame retardants…