1. TERRY EDGE
Furniture and Furnishings (Fire) (Safety) Regulations lead official at DTI/BIS/BEIS
Responsible for the new ‘Match Test’ for the FFRs in 2014
– remains unimplemented
Freelance fire safety consultant since 2016
Member of the Grenfell Fire Forum

2. The fire safety of products regulatory regime in Ireland/UK/EU
IT'S COMPLICATED! - MORE SO IN IRELAND
IT'S INCONSISTENT! - MORE SO IN IRELAND
SOME OF IT IS UNJUSTIFABLE - AND WILL BE MORE SO IN IRELAND AFTER BREXIT
SOME OF IT DOESN'T WORK!

3. The fire safety of products regulatory regime in Ireland/UK/EU
SOME OF IT IS CRIMINAL! - UNENFORCED IN IRELAND
IT'S MORE TOXIC THAN WE THOUGHT!
INDUSTRY IS LARGELY IN CONTROL OF THE FIRE SAFETY REGIME
I DON'T KNOW EVERYTHING - PLEASE SPEAK UP IF I GET SOMETHING WRONG

4. Domestic product fire safety
Ireland: European Communities (General Product Safety) Regulations 2004 (EU law) - 'Voluntary'
UK: General Product Safety Regulations 2005 (EU law) - 'Voluntary'
EU: General Product Safety Directive (2001/95/EC) - 'Voluntary'

5. Domestic furniture fire safety
Ireland: Industrial Research and Standards (Fire Safety) (Domestic Furniture) Order 1988/ Prescriptive (uses same BS standards as UK, e.g. 'crib 5' for fillings)
UK: The Furniture and Furnishings (Fire) (Safety) Regulations Prescriptive
EU: EN1021 parts 1&2, match and cigarette test under the General Product Safety Directive/Regulations - 'Voluntary'

6. Furniture fire safety regulations in Europe
Only exist in UK and Ireland
Acknowledged barrier to trade
EU Treaty allows exceptions on proven safety grounds
UK fire stats convinced but the two government reports on furniture fires are challengeable
Ireland's Furniture Regulations justified by the UK's stats
Not possible for Ireland after Brexit

7. Furniture and Furnishings (Fire) (Safety) Regulations 1988
Three main tests: match, cigarette and ‘crib 5’ fillings
Claimed to be saving around 54 lives per year (2009) but this is now challengeable
In 2014, BIS (now BEIS) consulted on a new match test – current match test revealed to be failing by up to 90%
UK’s leading test experts confirm current test fails, new one valid
New test blocked by vested interested
In Sept. 2016, BEIS consults again with same new match test
To date, no government response, no implementation

8. Non-domestic furniture/product fire safety
NSAI: "The fire safety of upholstered furniture supplied into the non-domestic market is complex. It is heavily influenced by the end use of the premises in which the furniture is intended to sit.”
UK: Regulatory Reform (Fire Safety) Order 2005
Ireland: Fire Services Act 1981 & 2003, Building Regulations (Amendment) Regulations 2006 Part B (Fire Safety), Code of Practice for Fire Safety of Furnishings and Fittings in Places of Assembly/Preschools, etc

9. Inconsistencies, overlaps, etc
Different departments, different aims
Different principles – prescriptive vs voluntary
Both domestic and non-domestic laws can apply in the same building
Furniture flammability requirements different – new match test and/or EU standards more compatible
Domestic don’t apply to consumers, e.g. means you can have highly flammable furniture in a tower block

10. Inconsistencies – standards, enforcement
Ambulatory/updated standards – standards-making bodies vs government – business influence growing, others’ weakening
UK Trading Standards: Resources constantly cut, losing expertise, Fines under the Consumer Protection Act 1985 inadequate (max. £5,000 and/or 6 months jail)
Ireland Competition and Consumer Protection Commission: Fines range from max. 3,000 euros for first offence, rising to 60,000 euros and beyond for repeat offenders BUT: never enforced the Irish Furniture Regulations (as of 2015), wrongly advises importers
Result - fire safety of furniture in Ireland dubious

11. Flame retardants in products
Massive world-wide rise since the 70s
UK (and probably Ireland) have the highest levels of FR dust in world
Mounting evidence that they cause cancers (e.g. thyroid) and other illnesses, with children particularly vulnerable
USA and EU moving away from FRs
UK and Ireland last stronghold for the FR industry

12. Flame retardants in products
Chemosphere Dec. 2017, paper by Richard Hull and others, concluded that a UK/Ireland sofa treated with FRs is more dangerous than an untreated EU sofa.
Richard Hull (on ’Newsnight’, BBC): "We burnt two kinds of sofas: UK furniture flammability regulations sofas with flame retardants and a European sofa without flame retardants and we found that the UK sofa burnt slightly slower than the European sofa but in doing so it produced between two and three times as much toxic gas as the European sofa."

13. Grenfell Fire Tragedy
Fire-spread and toxic fumes greater than should have been due to failed match test
Some fire-fighter officials paid by the FR industry
Chair of Inquiry experts panel played role in blocking new match test
Inquiry/experts panel/Hackitt review refusing to look at the Furniture Regs
Also excluding independent experts and residents

14. Summary, Issues
Lack of compatibility and rationalisation between domestic and non-domestic product fire safety legislation:
Different government Departments/Overlapping and unresolved areas of scope/Inconsistencies of standards type and regulations
Unjustified barrier to trade
Large volumes of Flame retardants that don’t work just damage health/environment

15. Possible ways forward
Brexit will change everything for Ireland, one way or another
Irish authorities/standards makers press Grenfell Inquiry/Hackitt review to rationalise and put right current fire safety regime
Press BEIS amend the FFRs; or drop Irish furniture regs - do what the rest of the EU does
Work to make domestic and non-domestic standards compatible

16. terryedge@ntlworld.com www.toxicsofa.com