The Fire Retardant Dilemma www.greensciencepolicy.org All Images, Copyright 2008, Arlene Blum arlene@arleneblum.com 510 644 3164 1 1

Fire Prevention is in Everyone's Interest

Flame Retardants, Health, and Environment To achieve fire safety, flame retardant chemicals are added to products. Brominated and chlorinated flame retardant chemicals are often associated with health and environmental hazards. Some flammability standards, promoted by special interests, are not needed for fire safety. Other necessary flammability standards can be met by safer alternative chemicals and/or product redesign.

Halogenated Fire Retardants contain bromine or chlorine and carbon: Uses (in order, by volume in the U. S.) Electronics Insulation in Buildings Polyurethane foam Wire and cable

Most halogenated FRs are PBT’s Persistent Bioaccumulative Toxic Many are CMR’s Carcinogens Mutagens Reproductive Toxins

China Is a Growing User and Producer of Flame Retardants Starting July 1, 2008 the Fire Bureau of the Ministry of Public Security requires flame-retarding on products in public places The market share for the more toxic halogenated flame retardants chemicals is about 20% in the EU and U.S. and about 55% in China Production Capacity of Flame Retardants in China Guo Ruxin. Development situation of flame retardants. Sea- Lake Salt and Chemical Industry, 1998, 28(1): 43-44 Liang Cheng. Development trend and production situation of fire retardant in China. New Chemical Materials, 2001, 29(8): 5-8, in Chinese. Production situation and development trend of fire retardant. China Petroleum and Chemical Industry, 2003, 9: 22-26, in Chinese.

Fourth International Flame-retarding Exhibition Shanghai - September 2008 Flame-retarding textile, fiber, decoration material, carpet, blankets, and fabric Flame-retarding; lumber, decoration board, soft foam/hard foam of polyurethane Flame-retarding/fire proof coating, plastic of flame-retarding engineering, Flame-retarding wire cable and insulation material, Three previous International flame-retarding exhibitions attracted nearly four million The Fire Bureau of the Ministry of Public Security requirement on products in public places will bring a bright prospect to China’s flame-retarding industry. http://www.flameexpo.com/en/

Brominated Tris Flame Retardant Tris (2,3-dibromopropyl) phosphate Used to treat U.S. children’s sleepwear from 1975 to 1977. Up to 10% of the weight of fabric Not covalently bonded to fabric Absorbed in children’s bodies; metabolite found in their urine

Science, January 7, 1977 9 9

CPSC Bans TRIS-Treated Children's Garments FOR IMMEDIATE RELEASE April 7, 1977 10 10

Flame Retardants in U. S. Consumer Products Use in furniture and baby products foam driven by California’s Technical Bulletin 117 (TB117) Limited fire safety benefit Halogenated fire retardants such as chlorinated tris at levels of 3% or more in furniture & baby products manufactured in China for export to U.S.

PentaBDE used from 1980 to 2004 in the U. S PentaBDE used from 1980 to 2004 in the U.S. Most global use of pentaBDE was in North America. Chemical fire retardants delay but do not stop ignition. Kielhorn, Dr. J., and Dr. C. Melber, Environmental Health Criteria 205: Polybrominated Dibenzo-p- dioxins and Dibenzofurans. WHO (International Programme on Chemical Safety); Geneva, 1998. On the combustion and photolytic degradation products of some brominated flame retardants, Gunilla Söderström, University of Umea, Sweden 12 12 12

Major Flame Retardant Exposure Pathways Myrto’s slide Breast milk – major source for infants (breast milk levels correlate with dust levels – Wu, 2007) Meat, dairy, fish – food pathways (lipophilic), but indoor air/dust – major contributors to exposure (Birnbaum 2006, Schecter 2006, 2004, Wu 2007, Lorber,2008) – high binding affinity for particles Levels in CA marine fish much higher than marine fish from Canada, Europe, Japan (Brown, et al., Chemosphere 2006) E-waste – 1997-2007 – 500 million computers discarded in US CA Integrated Waste Management Bd – Nov 2001 Baseline Study 13

Human Exposure Flame retardants used in consumer products are found in house dust Stapleton, H. M., J. G. Allen, S. M. Kelly, A. Konstantinov, S. Klosterhaus, D. Watkins, M. D. McClean, and T. F. Webster. 2008. Alternate and new brominated flame retardants detected in U.S. house dust. Environ Sci Technol 42 (18): 6910-6. Toddlers have three times the levels of their mothers http://www.ewg.org/reports/pbdesintoddlers Californians have higher levels in their house dust and body fluids than residents of other states Kellyn S. Betts, Environmental Health Perspectives 116, A202 - 208, 2008 PBDE fire retardant concentration in household dust ng/g Source: Elevated House Dust and Serum Concentrations of PBDEs in California: Unintended Consequences of Furniture Flammability Standards? Zota, Ami R., Rudel, Ruthann A., Morello-Frosch, Rachel A., and Brody, Julia Green, Environ. Sci. Technol., 2008,  10.1021/es801792z

August, 2003 California Bans Penta and Octa-BDE November, 2003 Great Lakes Chemical Co. agrees to cease Penta production. Replacements: Firemaster 550 Chlorinated Tris 15 15

Where should all the PBDE furniture go? My couch was 5 percent toxic PBDEs. Do Californians have a time bomb of mutagen, carcinogens, neurological and reproductive impacts from the furniture in their homes? Where should all the PBDE furniture go? 18 18

Widespread Environmental Impacts Brominated Flame Retardants in the Arctic Arctic Monitoring and Assessment Programme (AMAP) and Arctic Council Action Plan to Eliminate Pollution of the Arctic (ACAP): Jan 2005 Chlorinated, brominated, and perfluorinated compounds, polycyclic aromatic hydrocarbons and trace elements in livers of sea otters Kannan K, et al. J Environ Monit. 2008 Apr;10(4):552-8. Bioaccumulation and biotransformation of 61 polychlorinated biphenyl and four polybrominated diphenyl ether congeners in juvenile American kestrels. Drouillard KG, et al. Environ Toxicol Chem. 2007 Feb;26(2):313-24. Fireproof killer whales (Orcinus orca): flame retardant chemicals and the conservation imperative in the charismatic icon of British Columbia, Canada Peter S. Ross Can. J. Fish. Aquat. Sci. 63: 224–234 (2006) Persistent pollutants in nine species of deep-sea cephalopods Unger, M.A. et al., Mar. Pollut. Bull. (2008), doi:10.1016/j.marpolbul.2008.04.018 Brominated Fire retardants found in Tasmanian devils The Australian, January 22, 2008

A PBDE Exposure ‘‘Time Bomb’’ Current exposure to PentaBDE: 80% indoor air and dust, 20% diet. Penta is ‘‘bleeding’’ into the outdoor environment. Owing to its persistence, it will amplify in food chains. Our main exposure route likely to shift from indoor air and dust to diet. Critical needs: (a) reduce the existing indoor reservoir (b) manage the end-of-life. Harrad and Diamond, Exposure to to PBDEs and PCBs: current and future scenarios, 2006 Atmospheric Environment

The legacy PBDE problem: Capture indoor reservoir and manage end of life Step 1: Identify Step 2: Remove Step 3: Disposal _____ Burn Landfill -Degradation by bacteria? Research needed for end of life solutions _______ Dr. Hee-Joo Kim (heekim@ucdavis.edu) in the Bruce lab has recently developed a dipstick immunoassay for BDE-47 using the BDE-47 antibody and a novel reagent phage peptide. Some regulators or public concerning the occurrence of BDE-47 banned in furniture foam can easily perform the assay within 1 hour after simple extraction and immediately check positive or negative result with naked eyes. This phage-peptide-involved immunoassay is remarkably upgraded from current hapten-based competitive immunoassay for BDE-47.  Please see pictures below showing the occurrence of BDE-47 in furniture form samples supplied from you. The occurrence of BDE-47 in furniture foam samples only developed the dark circles on the dipstick strip. Ki-Chang told me that one slide for the dipstick assay should be OK. So I send you just one slide which shows the result of blind test with the extracts of furniture foams. In the slide, the PHAIA refers to the phage anti-immunocomplex assay which is a non competitive sandwich type assay. Unlike competitive assay, this non competitive assay is very useful for on-site rapid screening. The attached slike show the comparison of two assays (96-well based assay Vs. dipstick assay) for the extracts of six furniture forms. The positive detections by the 96 well-based assay (PHAIA) show the black spots on the membrane strips for the same sample. Dipstick immunoassay for BDE-47 developed by Hee-Joo Kim, Bruce Hammock and team. (can perform the assay with BDE-47 antibody and novel reagent phage peptide within 1 hour after simple extraction ) .

What we can do now: What about Yucca Mountain?

Solutions Only use fire retardant chemicals when a fire safety need is established. Fire retardants slow fires. Alternative strategies can prevent or stop them.

Fire Safety Without Toxic Chemicals Preventing ignition is less expensive, more effective, and healthier than adding toxics to slow ignition Fire deaths in the US are rapidly declining due to: 50% decrease in cigarette consumption since 1980 Enforcement of improved building, fire and electrical codes Increased use of sprinklers and smoke detectors Introduction of fire-safe cigarettes and candles

U.S. Home Fire Deaths, 1981-2005 http://www.nfpa.org/assets/files/PDF/OS.fireloss.pdf 25

Decline in Fire Deaths 2000-2004 compared to 1980-1984 California - 40% Georgia - 36% Illinois - 45% Michigan - 38% New York - 48% Ohio - 41% Pennsylvania Texas - 37% “U.S. UNINTENTIONAL FIRE DEATH RATES BY STATE” John Hall, NFPA, December, 2008 Table 1. Unintentional Fire, Flame or Smoke Deaths, by State, 1980-2004 (5 year averages) States shown are those with the highest number of fire deaths in 1980-1984. Note: Airplane post-crash fires and in-flight fires are not included, nor is the New York social club fire of 1989 (possibly treated as homicide by fire), the Oklahoma City office building bombing, or the World Trade Center collapse (fire caused collapse, which was the proximate cause of death). Source: National Center for Health Statistics mortality data sorted by International Classification of Diseases codes, as sorted and analyzed by U.S. Consumer Product Safety Commission (1980-1998) and National Safety Council (1999- 2004). Deaths included are those coded E890-E899 (1980-1998) and X00-X09 (1999-2004). Figures do not include codes F63.1 (pathological fire setting) and W39 (fireworks discharge), which would add less than 1% to the total each year. Figures do not include codes X76 and X97 (suicide or homicide by smoke, fire of flames), which would add about 9% to the total each year. These four codes are included in state-by-state analyses by the U.S. Fire Administration. Figures do not include fire deaths in vehicles, which would add about 20% to the expanded total (with X76 and X97) each year. “US Unintentional Fire Death Rates by State” National Fire Protection Association, 2008 26

No Data to show a Reduction in Fire Deaths from Retardants in Furniture Foam in California “U.S. fire data is not detailed or complete enough to show whether adding fire retardant chemicals to furniture foam in California since 1980 has made a measurable difference in fire deaths in that state.” Marty Ahrens, Fire Analysis Services, NFPA

NFPA estimates 750 lives/year saved by fire-safe cigarettes On October 25, 2007, Reynolds American Inc. announced product-wide switch to fire-safe cigarettes Jim Shannon, NFPA’s president, said in an “If cigarette manufacturers had begun producing only fire-safe cigarettes 20 years ago an estimated 15,000 lives could have been saved by now.” NFPA press release RJReynolds Tobacco Co, (35% of the market) is phasing in RIP cigarettes for all it’s brands with full distribution within two years. Phillip Morris will follow suit. Merit are already fire safe in every state. Fire safe since 2001. All US cigarettes fire safe withiin two years. 28

Should we fire retard: Electronics housings? Insulation? Bed coverings? Children’s products? Furniture foam

International Electrotechnical Commission           International Electrotechnical Commission Worldwide electronics industry standards would have required plastic enclosures for consumer electronics to resist external candle ignition -proposed in 2002 -an estimated additional 1.7 billion pounds of fire retardant chemicals would be required annually Candle fires in computers and other consumer electronic enclosures pose a negligible hazard

Case against Candle Resistant Electronics

Firefighters oppose adding halogenated fire retardants to electronic housings Firefighters have significantly elevated rates of multiple myeloma, non- Hodgkin’s lymphoma, prostate, and testicular cancer. These four types of cancer can be related to exposure to dioxins and/or furans. G.K. LeMasters, et al, Journal of Occupational and Environmental Medicine 48(11): 1189-202(2006).

Conformity, January 2009

Halogenated Fire Retardants are used in Insulation materials Hexabromocyclododecane (HBCD) is in all polystyrene insulation, On the first EU list of sixteen “Substances of Very High Concern”. Persistent, Bioaccumulative, Toxic (PBT) Found in household dust, breast milk, sewage sludge Used to insulate cement foundations from soil. No fire hazard Slows fires by second and then burns to produce toxic brominated dioxins

No fire hazard has been demonstrated for these baby products Baby Products Can Contain Fire Retardants Brestfriend said that the chemical in its nursing pillow wasn't a PBDE. It was Albemarle Antiblaze V6 and perfectly safe.  A V6 is 2,2-Bis(Chloromethyl) Trimethylene Bis(Bis(2-Chloroethyl) Phosphate). It’s 37% chlorine. Graco baby stroller with 3% TDCP or chlorinated Tris in the foam found within the padding.  No fire hazard has been demonstrated for these baby products

In December 2007 the Consumer Product Safety Commission (CPSC) proposed a national furniture flammability standard that can be met without fire retardant chemicals in foam. “No one wants to trade fire risks for chemical toxicity risks."  CPSC Commissioner Thomas Moore

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Ppts from meeting at: www.greensciencepolicy.org 41 41 41