Use and Regulation of Flame Retardants in Textiles

Consumer Product Safety Commission (CPSC) official Dale Ray once said, We did
not find flame retardants in foam to provide any significant protection (Chicago
Tribune, 2012), and a growing body of evidence supports this claim.
Flammability Standards
Many textile products contain flame retardants to meet flammability or fire safety
standards. Flame retardants inhibit or slow down fire, and their use seems justified:
nobody wants their bed or couch to catch fire and result in flashover. However,
scientific research proves that not all flame retardants are safe. Some are not
chemically bound, which means they may be released from the product and
absorbed into the bodies of consumers. Many such flame retardants have been
found to be toxic, bioaccumulative and/or persistent. They can be hazardous for the
immune, reproductive, endocrine, or nervous systems, particularly in developmental
stages. These serious health and environmental concerns have resulted in several
countries either banning or restricting the use of specific flame retardants. In
addition to health concerns, the efficacy of some flame retardants is in question:
many have not been adequately tested for safety or provide insignificant fire safety
benefit.
The flame retardants of utmost concern include halogenated/organohalogen flame
retardants and organophosphorous flame retardants. Halogenated flame retardants
contain bromine or chlorine bonded with carbon, while organophosphorous
retardants contain phosphorus bonded with carbon. The most common use of these
flame retardants (by volume) is in polyurethane foam. The most widely used
questionable flame retardants are polybrominated diphenyl ethers (PBDEs), tris(2,3dibromopropyl) phosphate, hexabromocyclododecane (HBCD), polybrominated
biphenyl, asbestos, polychlorinated biphenyl, tris(1-aziridinyl)phosphine oxide
(TEPA), and polybromobiphenyls (PBB).These flame retardants are subject to
varying levels of restriction or ban in different countries. Most research around
4000 scientific articles to date focuses on PBDEs, including decaBDE, octaBDE,
and pentaBDE. Newer flame retardants that are questioned are chlorinated tris and
Firemaster 550.
The San Antonio Statement and the Stockholm Convention have played a significant
role in raising legitimate concerns and awareness around the issue of fire retardant
toxicity. Over 200 scientists from 30 different countries signed a statement
declaring that when chlorinated and brominated flame retardants burn, they release
not only smoke or carbon monoxide but also highly toxic substances such as dioxins
and furans. Further, the Stockholm Conventions review committee has issued a list
of persistent organic pollutants (POPs) that should be banned worldwide. POPs
include HBCD, pentaBDE, and octaBDE. PentaBDE actually has a similar chemical

structure topolychlorinated biphenyls (PCBs), furans, and dioxins, which are known
human toxicants. Attention has now shifted to decaBDE.
PBDEs and HBCD are found not only in developed countries including the US,
Canada, Europe, and Norway, but also in developing countries such as Kenya,
Mexico, Mozambique, Philippines, Turkey, and Uruguay (IPEN, 2005).Unfortunately,
the flame retardant industry has a history of replacing banned flame retardants with
new toxic flame retardants. For example, when PBDEs were being phased out, they
were replaced by Firemaster 550, which is equally hazardous. Arlene Blum,
Executive Director of the Green Science Policy Institute, believes that instead of
adding new fire retardant chemicals that ultimately may be shown to cause health
problems, we should be asking whether we need to use these chemicals or if there
are other ways to achieve equivalent fire safety.
Regulatory Status
Europe
The European Unions (EU) legislative framework on chemicals has been
streamlined by REACH the Regulation on Registration, Evaluation, Authorisation
and Restriction of Chemicals. The EU has put a complete ban on the following flame
retardants:

Tris(2,3 dibromopropyl) phosphate (TRIS),

Tris(1-aziridinyl)phosphine oxide (TEPA),
Polybromobiphenyls (PBB)
PentaBDE
OctaBDE
HBCD (unless authorised)

DecaBDE is not yet banned in the EU; however, it is duly registered under REACH
and regulatory assessment on the substance is ongoing. It is banned in electronics
but permitted in other products. TCEP and HBCD have been listed in the Candidate
List of Substances of Very High Concern for Authorisation with a specified sunset
date in 2015.
Norway
Norwegian legislation generally follows EU legislation and implements REACH
regulation. However, it also banned the use, production, import, and export of
decaBDE in 2008. Norway also plans to eliminate all brominated flame retardants by
2020. It has already banned pentaBDE, octaBDE, decaBDE, and PBB. A priority list
has been prepared specifying chemicals to be phased out, both in terms of
emissions and use, by 2020. The list includes pentaBDE, octaBDE, decaBDE, HBCD,
and TBBPA, bisphenol A, DEHP, SCCPs, PFO A, PFO S, perchloroethylene,
trichloroethylene, and triclosan.

Sweden
In addition to REACH regulation, Sweden imposed a ban on decaBDE in textiles and
furniture in 2006, but reversed it when it was challenged by the EU.
North America
No federal US regulations currently exist to restrict flame retardants; however,
different states impose varying restrictions. The US signed the Stockholm Treaty in
2001, but it has not been ratified yet. However, US production of pentaBDE and
octaBDE was phased out in 2004 and would now require pre-manufacture
notification (PMN) under the Toxic Substances Control Act (TSCA). Many states have
banned pentaBDE and octaBDE. Surprisingly, decaBDE is largely untouched despite
the fact that it actually degrades to form lower brominated flame retardants like
octaBDE and has been listed as a chemical of high concern by GreenScreen
for Safer Chemicals. Clearly, it should be eliminated from the environment.
In the absence of national standards, some US states including Washington, Maine,
Hawaii, Maryland, Vermont, and Oregon independently banned the use of decaBDE.
Canada banned the manufacture of decaBDE in 2008; however, its sale, use, or
import is unrestricted. HBCD has been included in the Stockholm Conventions POPs
and is therefore subjected to a global ban.
According to the American Chemistry Council (ACC), The US Environmental
Protection Agency (EPA) issued a significant new use regulation (SNUR) for the use
in textiles of six polybrominated diphenyl ethers (PBDEs) in 2005, and proposed a
SNUR for decaBDE and HBCD in 2012, but has not yet finalized the proposal. The
three major manufacturers of decaBDE had phased out production by the end of
2013.
Laxmi Ravikumar, a technical specialist at Intertek, provided a list of proposed
regulatory restrictions or bans on certain flame retardants of high concern:
1. Delaware and Illinois: Restricting Tris flame retardants from 1 July 2014, and a
year later banning Tris flame retardants in childrens products and residential
furniture
2. Massachusetts: Restricting the sale of childrens products and residential
furniture containing Tris flame retardants and PBDEs from1 January 2014
3. New York: Restricting TDCPP, TCPP, TPP, Firemaster 500 and other
phosphorus-bromine flame retardants in residential furniture and childrens
nap mats
4. Washington: Restricting TBB, antimony, TBPH, chlorinated paraffins, TCPP,
TDCPP, TCEP, hexabromocyclododecane and tetrabromobisphenol-A in
childrens products and residential upholstered furniture

5. US Senate bill: Restricting TBBPA, antimony trioxide, TBPH, chlorinated

paraffins, TDCPP, TCEP, hexabromocyclododecane and decabromodiphenyl
ether in childrens products and residential upholstered furniture
Asia
Betts (2008) stated that several Asian nations have similar restrictions to those of
US states.
Regulatory Issues
Regulation of chemicals in the US is largely ineffective. Arlene Blum has stated that
62,000 chemicals in commerce are exempt from regulation under the US
TSCA(1976)and 20,000 new chemicals have been introduced to date, 85% without
health data and 67% with no data at all. Also, regrettable substitutions are occurring
in kids clothing, baby products and many other products. Brominated Tris in kids
pajamas has been replaced with chlorinated Tris, a known carcinogen. Similarly,
pentaBDE in baby products has been replaced by chlorinated Tris, Firemaster 550,
and phosphates. Chlorinated Tris was voluntarily removed from kids pajamas by
some companies, but it was not banned and a 2011 study of baby products
revealed that it was still the most common used flame retardant. New toxic flame
retardants are being added to these products due to the weak chemical regulatory
policy in the US. Especially when it comes to chlorinated Tris, the EPA seems
powerless: it continues to be used despite its hazardous properties.
The Chicago Tribune highlights that the 1976TSCA doesnt protect human health
and that it allows manufacturers to sell products without proving they are safe
and to treat the formulas as trade secrets. Once health effects are documented, the
law makes it almost impossible for the EPA to ban chemicalsTo ban a chemical
already on the market, the EPA must prove that it poses an unreasonable risk.
Federal courts have established such a narrow definition of unreasonable that the
[US] government couldnt even ban asbestos, a well-documented carcinogen that
has killed thousands of people who suffered devastating lung diseases.As a result,
the EPA resorted to encouraging manufacturers to conduct voluntary phase-outs.
On a positive note, Canada and 24 US states are required to abide by laws
mandating that cigarettes must be fire-safe. As cigarettes are considered to be one
of the main sources of ignition in sofas and couches, the nonprofit Coalition for FireSafe Cigarettes contends that these kinds of laws will definitely affect the 60% of
the North American population. Access to information and labelling of alternatives
must also be improved so that safer alternatives dominate the market.
Regulatory Compliance
One of the most common textile labels reads:

This article meets the flammability requirements of California Bureau of Home

Furnishings Technical Bulletin 117.
Technical Bulletin 117 (TB117) is a 1970s standard that gradually became a defacto
global standard. It required foam-containing products to pass a test of exposing raw
foam against candle fire for 12 seconds. It encouraged manufacturers to use flame
retardant chemicals so that the product passed the test. However, it fails to
consider real-time conditions. The flame ignites the covering fabric first and then
engulfs the foam inside. Flame retardants werent actually delivering any benefit. In
February 2013, the California regulatory authorities amended TB117 and the new
standard became TB117-2013. This standard does not require products to pass the
test of withstanding an open flame, but only requires a smoldering test for the
covering fabric. While the standard does not ban the use of flame retardants, it is
expected to help discourage it. Consumers should be educated to look for the
TB117-2013 label only, and avoid the TB117 label. It should also be noted that
products labeled PBDE free might still contain PBDE.
The federal mattress standard, 16 CFR 1633, requires a mattress to pass a test of
lengthy ignition. It focuses on the fabric covering the foam of the mattress and
discourages the use of flame retardants.