Health and Environmental impacts of Technical Bulletin 604 (TB 604)

The Bureau of Home Furnishings and Thermal Insulation’s (BHFTI) is moving forward with TB 604, a flammability standard for filled bed clothing. The Consumer Product Safety Commission (CPSC) is considering a similar regulation.

With the requirement for fire safe cigarettes in California beginning January 1, 2007, a voluntary standard for fire-safe candles, and a stringent flammability standard for mattresses, the estimated fire death reduction used to motivate the bed clothing standard needs to be reevaluated. Early estimates suggest that fire-safe cigarettes could lead to a 50 to 66 percent reduction in fire deaths. The CPSC estimated that the current mattress flammability standard would reduce bedding fire deaths by up to 80 percent. Furthermore, new scientific studies show potential negative impacts on human health and the environment from chemicals and materials that are likely to be used to meet TB604.

TB 604 does not require any health or safety information regarding the fire retardant materials and chemicals used to meet it. It would lead to toxic chemicals or those lacking adequate with health information in the beds of Californians. This is of special concern for pregnant women and young children who are the most vulnerable to endocrine disruptors, carcinogens, mutagens, and neurological and reproductive toxins. Since spermatocytes are the most rapidly growing cells in adults, men also need to be protected as well from toxic materials in their beds.

This use of fire retardant chemicals in consumer products has a long problematic history. Fire retardant chemicals and materials used in the past, such as polybrominated biphenyls (PBBs), polychlorinated biphenyls (PCBs), Tris (2,3-dibromopropyl) phosphate, halons, asbestos, and penta and octaBDEs, continue to be found in the environment and/or have adverse impacts on human health, even though many of these chemicals were banned or otherwise regulated as much as thirty years ago. Such chemicals should not be used without a demonstrated need as well as health information.

Biomonitoring studies have detected fire retardant chemicals in the blood, urine, and breast milk of nearly all Californians tested. According to a new study from the Silent Spring Institute, California dust contains 10 times the toxic PBDEs found in dust from other states and 200 times the level found in the EU. Californians have twice the level of toxic PBDE in their bodies compared to residents of other states. This is believed to be due to TB117, a furniture flammability standard unique to California, which has been met by toxic fire retardants in furniture and baby products in California.

Scientific studies postulate a relationship between some fire retardant chemicals and adverse birth outcomes, autism spectrum disorders, learning disabilities, hyperactivity, cryptorchidism, reduced fertility and sperm counts, and other negative neurological and reproductive impacts.

Hazards to firefighters from inhalation of toxic byproducts of burning fire retardant materials are also of concern. Fire fighters have significantly elevated rates of multiple myeloma, non-Hodgkin’s lymphoma, prostate, and testicular cancer. These four types of cancer can all be related to exposure to dioxins and/or furans. Dioxins and furans are produced at high levels when halogenated fire retardant chemicals burn.

Before proceeding, scientific data must be obtained to demonstrate that materials and chemicals to be used in bed clothing to meet TB604 will not cause neurological and developmental disorders in the developing fetus and child.

An estimated average of one pound per person per year of filled bedding materials are purchased and disposed of annually by each citizen of California. This totals about 20 million pounds each year. Although no specific materials are required by the BHFTI to meet TB 604, the standard is likely to result in the manufacture, introduction into homes, and disposal into the environment of large amounts of toxic or potentially toxic materials and chemicals annually.

The California Green Chemistry Initiative calls for the design of products and processes that reduce or eliminate the use and generation of hazardous substances at all stages of the life of a product. Toxic monomers are used in the manufacture of the inherently fire resistant polymer materials, and then again found at the end of life when they are disposed of in landfills. This is in contradiction to the fundamental premise of the Green Chemistry initiative.

BHFTI should require that, prior to use in bed clothing, furniture, or other consumer products, manufacturers of fire retardant chemicals and materials must provide complete toxicity information[1] for any flame retardant material used, as well as a complete life-cycle analysis of the pollution potential of these materials. These data should be reviewed by the Office of Environmental Health Hazard Assessment (OEHHA), the Department of Toxic Substance Control (DTSC), or an equivalent authoritative body with no conflict-of-interest. A detailed summary of this toxicological information should be made publicly available.

In addition, all chemicals and materials used to treat bed clothing must be labeled, so that consumers and especially pregnant women and parents of young children can make informed choices about exposure to potentially toxic materials.

Efforts to improve fire safety should not come at the expense of increasing human and environmental exposure to potentially toxic chemicals and materials for which there is inadequate health and safety information.

[1] Complete toxicity information includes identification of the chemical and its major transformation products with CAS numbers and chemical structures; physical properties, including hydrolysis, aerobic and anaerobic half-lives, water solubility, Koc, and Kow; animal test data on carcinogenicity, reproductive and developmental toxicity, neurotoxicity, acute toxicity, endocrine disruption potential; and major transformation products that are produced on decomposition and metabolism of the compounds in the environment.