It seems the OPSS is currently pressing FW/6 (working group at British Standards Institute) to base the new ignition standard for their new furniture regulations on the European standard EN 1021 Part 1 and 2. EN 1021 is for cigarette resistance (Part 1) and match/open flame resistance (Part 2) over a test rig to simulate an upholstered chair. It was originally based on the UK's cigarette and match tests (BS 5852 parts 1&2) with some differences, one of them significant.
 
Here's what's wrong with this plan (as every single member of FW/6 well knows):
 
1.         EN 1021 Part 2 is not as stringent as the UK's open flame test, e.g. the test flame is placed against the fabric for 20 seconds in the UK test but only for 15 seconds in the EN test. Why the difference? Well, it seems that the huge fibre-producing German company Trevira worked hard on the EN committee responsible to get this 5 seconds reduction, having discovered that their fibres will resist igniting for that period of time, but not for 20. The OPSS has banged on for years now about how they will not replace the existing open flame standard with one that is less stringent. The fact they now plan to do so indicates that they have finally twigged that they painted themselves into a corner over this.
 
2.         EN 1021 has some of the same key faults in common with BS 5852. For example, it does not cater for flammable materials close to the cover but not within the main body of say a sofa like the arms (the test rig is in effect two large furniture cushions, meaning that in practice cover material near the arms will ignite because items beneath and close to the cover do not have sufficient foam to protect against catching fire). And the fact that flame retardants wear off of fabrics easily means they will not comply with ignition tests soon after purchase in both test scenarios. 
 
3.         EN 1021 still leads to large volumes of flame retardants in furniture – e.g. some of the worst kinds, like the brominated varieties – in cover fabrics. The OPSS is supposed to be committed to reducing FRs in furniture. 
 
4.         The government itself proved in 2014/2015 that the open flame test in BS 5852 is not effective in practice; it does not prevent ignition. In 2014 it came up with a new open flame test that was effective and also would hugely reduce FRs in cover fabrics. Why therefore is the OPSS not using this to replace the existing test?
 
To summarise (if possible!): in 2014, the government proved that the UK match/open flame test is not effective and proposed a new test that was. From that point on, it delayed making changes, keeping in place a test that does not work and leads to millions of kgs of toxic flame retardants in UK furniture. In 2019, the Environmental Audit Committee recommended that the OPSS drop the open flame and fillings tests altogether. But instead, for the next five years the government created an impasse by setting up British Standards Institute to do the impossible: replace the existing open flame test (which does not work) with one that is just as stringent. BSI could not do so because no such standard exists or is possible to draft. Under pressure, the OPSS went out to consultation late last year on new regulations. It said these will be ready by October 2024 (they won't be). It intimated that the new standards to support the regulations would be ready about the same time. However, BSI told the government (but not the public of course) that it would be at least 2028 before new standards were ready. And that depended on the OPSS telling them what standards they wanted. Which they did not, and could not, do. Now, they are trying to rush through a EN standard equivalent even though:

• They could have done so ten years ago, if that was the answer, which it clearly isn't.
• The EN standard suffers many of the same faults at the current British standard, i.e. it is not effective in practice.
• The government knows that no EU country uses EN 1021 open flame test anyway, one reason being that they do not want large volumes of flame retardants in their furniture.

 
Not one person on FW/6 has made a stand over this, content for a mixture of reasons, most of them financial, to go along with this extended madness that results only in mass cancers and other illnesses in UK citizens, including babies and firefighters.
 
 
 
 
 
 
 

 
 
The furniture fire safety regulations have become a Gordian knot in which different strands tighten in on each other making the chances of ever unravelling it near to impossible. The confusion is added to by the fact that hardly anyone involved understands even their own part in it. Each strand is ambiguous and impossible to fully understand because of all the unknown factors that contribute to it. This produces contradictions such as abound in a recent UCLAN paper, but it seems even the authors are unaware of them; they're just looking to profit in various ways from the fact that the OPSS seems determined to keep flame retardants in UK furniture (because they are so profitable).
 
Such a knot suits the bad guys because they benefit from it remaining tied. Every time someone with good intentions tries to untie even a piece of it, the bad guys simply point to another bit of it and claim that that answers the question.
 
Having said that, I believe the following can be said about the Regs with a fair degree of certainty:
 
1. They are largely ineffective where fire safety is concerned, as confirmed by a government select committee in 2019 after a thorough investigation.
 
2. They lead to large amounts of flame retardants in UK furniture (though the types and amounts are hard to pin down), including banned chemicals such as DecaBDE. There is no evidence that these FRs contribute positively to a furniture fire but we do know they make it much more toxic. FRs also leach out of furniture and get into people causing all kinds of health problems. These problems should be used to off-set any advantage gained from the regs, but they are not.
 
3. There is no evidence that the regs save lives from fire and there is plenty of evidence from around the world that an absence of flame retardants makes no difference to the number of fire deaths.
 
4. The OPSS is cagey over actual stats but it seems that about 60 fire deaths a year result from fires starting in bedrooms or living rooms (where these regulated furniture products are mostly found). Also that most fire deaths occur in the elderly. We don't know exactly, but we must put at least some of those lives saved down to the increase in smoke alarms and decrease in smoking. If we ascribe say 33% to each, then the maximum lives saved by the regs is about 40. And that's if they actually worked. Which has to be set against the massive toxicity from flame retardants when they burn.
 
5. The OPSS states that smoke toxicity is the largest cause of death in fires but do not provide figures. Therefore, allowance has to be made for the possibility that more deaths are caused by the fact that flame retardants increase toxicity. And that's without mentioning the many illnesses caused by flame retardants in fires that are not even recorded.
 
6. On balance, then, even assuming all the 60 lives saved were from furniture fires (which is not the case, e.g. fires also start in TVs, carpets, curtains, bedding etc), the additional deaths caused by toxic FR inhalation probably balance out such a benefit. In other words, even if the regs were effective, it's reasonable to conclude that ditching them would make no net difference to lives saved, this being born out by the fact that the rest of the world has no such regs yet the drop in furniture fire deaths in recent years is the same as in the UK.

Dear Richard,
 
Elsewhere on this site I've posted my notes on the extraordinary (for all the wrong reasons) "stakeholder engagement" meeting you co-hosted with Sean Valoo on 18th September 2023. To remind readers, this was intended to be, the OPSS had said, an open discussion with stakeholders about the consultation proposals and a chance to have our questions answered. I and others thought, how on earth would they answer all these people's questions (around 80 names were on the copy list) in a 90 mins meeting?

For the record, this was the first full stakeholder meeting held by the government since a two-venue meeting in 2020 (London and Birmingham) which they blocked me from entering (which was why I was a little suspicious to have been invited to this one). And the previous full stakeholder meeting before that had been as far back as August 2015. So just three in 8 years on a subject of incredible importance for the health of the UK population.

As you know, Richard, this meeting was different in two ways. First, it was virtual only and second there was no way for any stakeholder to actually "engage" with it. We could not speak to you, and even the chat function was switched off. Instead we had you and Sean reading out the entire consultation document, which took an hour, despite the fact that everyone on the call had obviously already read it. Then you announced you were going to answer all our questions that we'd sent in for the meeting. Oh, but to help smooth the process, you had sorted the questions into themes; and it was these themes you would actually "answer". I'd put in some very detailed questions, as you'd no doubt expected, but oddly enough they didn't fit into any of your themes, so I didn't get any answers. I wasn't the only one.

I won't go into the details of this Q&A. Let's just say that nothing of any real meat was dealt with. There was one exception and the fact you Richard raised it suggested you really did need to deal with it: our old friend, smoke toxicity. I'm sure you were aware that at this time, the press was writing about high levels of cancers in firefighters, caused by smoke toxicity, and the FBU had just announced that it was going to tackle legislation that leads to flame retardants poisoning firefighters. 
The following exchange has been transcribed from the audio recording of this meeting made by the OPSS: https://www.youtube.com/watch?v=jkZsL_v0vnk
 
OPSS official: ". . . another question -  about why are we not addressing smoke toxicity through the New Approach?
          
Jude: Yes, that's a challenging one. The key is, and the starting place in the New Approach, is . . . much of the 1988 regulations is about preventing ignition rather than reflecting and assessing risk post-ignition. And that's the approach we've agreed with senior colleagues and senior stakeholders like fire chiefs; that's the reason we're going down that approach and if we were to completely re-write the rule book it would pose a very long challenge, I think.
 
Let's pause here. I've been a leading expert on these regulations for over ten years, having regular contact with everyone that has a stake in them. Never once have I heard it suggested that "much of the regulations is about preventing ignition rather than reflecting and assessing risk post-ignition". I'm calling you out on this, Richard. Why did you make this clearly false statement about a key subject in fire deaths? Who put you up to it or did you think of it yourself? The sentence that follows is also clearly false since "senior colleagues and senior stakeholders like fire chiefs" could not possibly agree with your premise. But if they have in fact since agreed, then you need to produce evidence that they have: names and statements. But that's not your way, is it? Your way is to lie about key issues, linked to false conflations, all designed to get you personally (and your Department) off the hook, and to hell with fire toxicity that in just about every home fire in the UK is majorly caused by furniture full of flame retardants. To continue:
 
Valoo: Yeah, and I think you know there's appetite amongst us all to deliver a New Approach as soon as possible and I think that taking on the challenge of regulating for smoke toxicity would have delayed us being able to put forward proposals for a New Approach somewhat. 
 
The New Approach does not really exist, of course. And it's not new anyway. In the past, safety laws on the whole were prescriptive, like the furniture regs: they told you exactly what to do to be compliant. Then a different approach came in to EU (and therefore to the UK) safety legislation – also called New Approach - which was less prescriptive laws, like the General Product Safety Directive which pretty much just says that products must be "safe". It's up to the producer to discover what "safe" means, what standards should be applied and so on. Certain, shall we say, profit-minded fire safety big shots were also behind the Regulatory Reform (Fire Safety) Order 2005, governing the fire safety of non-domestic environments, including upholstered furniture. Again, in order to comply, the "responsible person" has to demonstrate that their premises and products are "safe". And, believe it or not, it's up to them to decide what that means. This replaced legislation that was much more prescriptive. The so-called new "New Approach" is trying to pull the same switcheroo with domestic furniture fire safety. To continue:
 
[Valoo] But, as Richard said, it is something we are considering and many of you raised [this] as an issue; and it's also something we're discussing with colleagues in [inaudible – Delup?] 
 
I think Sean Valoo is referring here to the Department for Levelling Up and this report by them: https://assets.publishing.service.gov.uk/media/6440f2596dda69000d11e15e/Independent_Review_of_the_Construction_Product_Testing_Regime.pdf
 
[Valoo] who have begun a project looking into the smoke toxicity of construction products, and that is a project that fell out of the Grenfell Inquiry, and so we're liaising with them to understand how we can adopt, and do some of what they're doing in that space in terms of, well, products more generally but also in terms of product [inaudible] fire safety.
 
Jude: And I guess the toxicity risk, as well as [kind of listening to the outputs from Delup there?], um, the new framework that our colleagues in the product safety review team are considering – they're looking to kind of consider hazards [inaudible] across different products, so if there is evidence that supports general requirements across certain sectors in relation to smoke toxicity, I'd encourage stakeholders to respond to that consultation as well but that in terms of general requirements that can be put in place across right across the framework, but also in the way we regulate upholstered furniture.
 
You might here be referring to this consultation:          https://www.gov.uk/government/consultations/consultation-on-the-new-safety-regime-for-occupied-higher-risk-buildings/consultation-on-the-new-safety-regime-for-occupied-higher-risk-buildings But if so, I'm not sure why since it closed quite some time back and the government responded in Oct 2023. You appear to be saying that smoke toxicity occurs in all sorts of products and Levelling Up is looking at that therefore contact them and not us. The fact that in a home fire, the vast majority of smoke toxicity including the production of hydrogen cyanide comes from burning furniture is something that according to you doesn't concern the OPSS anyway because your regulations are only responsible for pre-ignition issues.

The "engagement" meeting closed soon after this exchange, with you Richard saying, "I think that gives a very good flavour of the questions you've been asking and thank you very much for joining us this morning. I think this has been a very productive session, from our perspective [!] . . . we hope it was useful."

On the surface, the above exchange actually encapsulates all that's wrong with how the government is dealing with what remains a massive scandal regarding public health and the truth about the Grenfell Tower fire tragedy. As I'm sure you're well aware, Richard: at least I can't think of any other reason why you would try and tell the world your department has no responsibility for smoke toxicity in home fires.

I had to keep re-listening to the recording to try to even hear what you were actually saying. Is this confusion deliberate? Well, I don't think it's conscious, as your relaxed body language indicates. It's actually I think more the result of a semi-deliberate policy of spreading one's true intent around several apparently related (but not really) issues, institutions and ideas in order to prevent anyone focussing on the real problem and, more importantly, who's responsible for it. And using the term "Delup" without explaining that this is a slang term for another government department (assuming that it is), suggests you're trying to hide something. At the very least it's disrespectful to your stakeholders.

In summary, I do not believe your claim about smoke toxicity not being your responsibility was a casual statement. You are trying to say that the regs, and your department, are not responsible for smoke toxicity, at Grenfell or anywhere else, because that is all a "post-ignition" matter.
As said, your claims that this approach has been agreed with senior colleagues is of course unverified: you don't say who they are exactly; it could mean only OPSS senior colleagues. Nor do you say where the notes of these discussions can be found. You just say it's been agreed "[with] senior stakeholders like the fire chiefs". 

During this consultation process and in the consultation document itself (page 21) OPSS has been leaning rather heavily on the NFCC to justify their decision to keep an open flame test in the regs; this for example from your consultation proposals:
 
The development of the proposed scope has been supported by research commissioned by the Office for Product Safety and Standards and carried out by research consortia consisting of UCLan, Birmingham University, Oakdene Hollins, and WhaleyResearch. The peer-reviewed Fire Risks of Upholstered Products research and subsequent discussions with the representatives of the London Fire Brigade and National Fire Chiefs Council have considered the extent of the fire safety risk posed by products while also reflecting their foreseeable use and the potential exposure of users to chemical flame retardants.
 
Note, however, that there is no mention here of any direct conversations between the NFCC and the OPSS. So when you Richard say you've "agreed with", you really mean that the OPSS commissioned some research which the NFCC was asked to contribute to (but not the FBU, nor the EAC, nor anyone in fact who might be opposed to the continuation of flame retardants in UK furniture). 
Stakeholders have written asking for the names of the people in the NFCC claiming this and some evidence of the research to back it up. As usual when faced with awkward questions, however, the OPSS did not reply.
​
I won't continue for now. The purpose of this letter is to put questions to you, Richard, as a member of the OPSS team responsible for the furniture regulations. You almost certainly won't respond, mainly because we both know you can't, not without lying further at any rate. My experience with officials like you is you have the enviable ability to convince yourself that you're right, even when all evidence and facts say you're not. This is a very convenient ability to possess since it allows you to side-step any conscience you may still possess. The fact is, however, that you Richard are acting directly against the public good and are responsible, personally, for ensuring that every person, and in particular children and firefighters, in this country will continue to be poisoned in their own homes for many years to come. I hope whatever rewards and promotions you receive in the civil service are worth it.
 
Regards,
 
Terry Edge

For a good overally summary of the situation as of today, read my article in the latest edition of Fire Safety Matters: https://www.flipsnack.com/E59F88BBDC9/fire-safety-matters-mar-2024/full-view.html (starts at page 24).
 
I will for now keep this state of play report to headline points. If anyone wants more information, you can reach me via the Contact page on this site.
 
Bottom line, despite the OPSS's lies to the contrary, there will in effect be no changes to the current regulations until at the very earliest 2028 (which internally British Standards are claiming) and even then it is unlikely that the changes will produce fire-safe furniture with any significant reduction in flame retardants.
 
 
ELEPHANT ONE: THE CURRENT REGS ARE INEFFECTIVE
 
This site is full of the evidence to support this assertion; in short that:
 
1.         The government's own evidence that the regs are ineffective, contained in the papers (still online) supporting its 2014 consultation on a new match/open flame test that would have been effective.
 
2.         The Environmental Audit Commission's final report in 2019 (into toxic chemicals in everyday life) which confirmed that the regs are ineffective and recommended the government drop the open flame and fillings test immediately. 5 years on and it has no intention of doing so.
 
3.         The USA dropped its open flame test a few years back because it has no effect on preventing furniture fires. And the rest of Europe does not utilise the EU open flame standards.
 
4.         There is no evidence that the current tests have ever saved any lives from fire.
 
In support of its proposal to retain the 3-test system in its 2023 consultation on the furniture regs, the OPSS cites the National Fire Chiefs Council as apparently insisting the open flame test is retained. Several people have asked them to provide names and papers accordingly from the NFCC but the OPSS just ignores them.
 
However, in its response to the 2023 consultation the NFCC says this:
"Although the Furniture and Furnishings (Fire) (Safety) Regulations 1988 have significantly reduced deaths by fire, NFCC agree that a new approach is needed to ensure that domestic upholstered furniture continues to be fire safe and to ensure high levels of consumer protection in the modern home." 
Once again, no evidence is offered in support of these claims. The fact is there is no evidence at all that the FFRs have "significantly reduced deaths by fire". The UK's reduction in fire deaths is pretty much the same as other countries including those, like New Zealand, that do not have any fire safety requirements for furniture. The NFCC wants our furniture to continue to be fire safe, except of course it isn't. It is also suspiciously in line with the OPSS's major contradiction over the so-called new approach, i.e. if the regs are providing fire safety, why do we need new standards?
 
ELEPHANT TWO: WEAR
 
This is probably the biggest elephant and as such is rarely if ever mentioned outside of industry and government. Flame retardants – as Professor Stuart Harrad has been demonstrating in his research for many years – wear off of furniture pretty much as soon as the first person sits or sleeps on it. 
 
In short, everyone inside the furniture business knows that soon after you purchase a piece of furniture, and even if it has been treated properly with flame retardants (an increasingly big "if" especially when industry knows that Trading Standards have for many years not been enforcing the regulations), it's not long before that piece no longer complies with the regs. Which makes a mockery of the OPSS's new proposals that include second-hand furniture.
 
This subject was raised recently in the British Standards Institute's working group, FW/6, which has been commissioned by the OPSS to come up with new furniture standards. It was universally accepted as a key issue and there was talk of undertaking wear tests which would almost certainly show, said a leading test house expert, that the regulations are "redundant". An awkward silence followed him and a resounding silence has followed ever since, with no such work undertaken. 
 
 
ELEPHANT THREE: THE CURRENT SYSTEM IS HUGELY PROFITABLE
 
At a rough estimate, the furniture regulations are worth around £4 billion a year, split between these industries: the furniture makers (who profit from the trade barrier the regs represent), flame retardant producers, the chemical treatment industry (that would probably go out of business if the regs were made safe and FR-free), the mighty foam industry, and the test house industry.
 
If the EAC's recommendations in 2019 were put into effect, all that profit would disappear overnight. Hence, all the hard work by the OPSS and industry to make sure they aren't. Not to mention: 
 
 
SNOUTS IN THE TROUGH
 
The British Standards Committee, FW/6, that was charged with developing new standards for the new furniture regulations has, as reported, not even started work on any new standards some five years after being commissioned. This blog has reported on the reasons why, not least the "impasse" (word used by at least two Chairs of FW/6) created by the OPSS on the one hand saying it needs new standards, while on the other a) not giving any useful indication of what that means and b) failing to explain why it is also simultaneously claiming that the existing standards offer the "gold standard" for furniture flammability that is the envy of the rest of the world.
 
Although several people on FW/6 have complained about this and other contradictions in the process, I was the only one who called out the bottom line, specifically when I told the committee that I appeared to be the only one on it who cared more about public health than industry profit. Following which there was a resounding silence. Later, I was thrown off the committee, because, apparently, two committee members (unnamed of course) later complained to BSI later that what I'd said was "inappropriate".
 
With my removal, guess what? The OPSS started to attend meetings of FW/6 again. They were well over the permitted absence levels under BSI rules and should therefore have been removed from the committee. They'd also claimed that the reason they weren't attending was because I was on the committee! Which if nothing else shows where BSI's priorities regarding protecting their committee members lie. (Just to remind you, when the OPSS heard that BSI had invited me to join this committee, they demanded BSI attend an emergency meeting where they ordered my removal, claiming that I'd been "physically violent" with their staff. My lawyer challenged this and the OPSS then claimed they had not made this accusation, but with BSI contradicting them by informing me what was actually said by the OPSS.)
 
The fact is that no one on FW/6 has complained about my treatment, which kind of supports my contention. Every single one of them is essentially putting profit before health or, as is the case with the "greens", putting their continuing presence on the committee before actually challenging the government. "We must keep our feet under the table," as one of them told me.
 
All of them, therefore, support the continuing use of high levels of flame retardants in UK furniture for many years to come. And with this guaranteed continuance of fire safety laws that do not work, there is of course a very lucrative market also remaining in place. Both for flame retardants and any "alternatives" that people might be working on.
 
And there's one group of snouts in the trough that has become quite prominent. These are scientists, fire experts and even cancer prevention people, who have recently issued a batch of papers – some even paid for by the OPSS! – that focus heavily on reducing flame retardants while not changing the current requirements of the regs (which would be the fastest and most effective way to eliminate FRs). One of these is a leading fire toxicology expert I worked with for many years. He is well aware of the ineffectiveness of the fire regs and indeed pointed it out in one of his earlier papers. He is also very well aware of the massively increased toxicity of fires in furniture that contains flame retardants. He no longer mentions that the regs don't actually prevent fires; nor that their continuing existence (while all sorts of delays remain in place) means that hundreds if not thousands of adults, children and firefighters are suffering cancers and other illnesses. Instead he strongly implies that they would work if they had the right resistance measures in place. He is working with a leading foam manufacturer to develop FR-free foam fillings, while at the same time developing FR-free interliners that can pass the open flame test. He doesn't appear to be aware that, even if they develop such things, the extra cost entailed will almost certainly mean furniture manufacturers continue to use flame retardants instead. Maybe he's hoping public opinion will eventually work against FRs sufficiently for the industry to have to shell out for alternatives. He's built a gang of similar scientists with profit gleams in the eye which the OPSS is only too pleased to back. 
 
Is their behaviour worse than that of the FR industry? Well, you decide. Without me on FW/6 no one else is going to challenge them.
 
 
 
edit.

Yesterday, I sent the email below to over a hundred OPSS stakeholders, including a few members of the OPSS. I attached to it an article in Private Eye's edition of yesterday (see Media Coverage page):

Dear All,
 
Please see attached scan of an article that appears in today's Private Eye. I believe this is a succinct and truthful summary of the current situation regarding the furniture fire safety regulations.
 
OPSS people on this copy list are more than welcome to provide evidence and facts (i.e. not just opinion) that this article is untruthful or misrepresentative. 
 
The last time Private Eye ran an article on the regulations, the OPSS went on a witch hunt to find out who'd provided the information for it. The subject of that article was the fact that the OPSS had appointed an "expert panel" (which it quotes in the current consultation documents, anonymously) with 10 out of the 11 members being strong supporters of flame retardants. The OPSS had been advised by other government departments that these appointments were not in keeping with government good practice guidelines, e.g. they should have sent out an open invitation for relevant people to apply. Anyway, their main reaction to the article was not to explain their actions but to track down whoever had leaked the information. They decided on an official in another Department as being guilty (of simply informing the public of the truth, by the way) and proceeded to destroy his career, hounding him out of his job. This was a good man, a true expert in flame retardant harms. In 2015, for example, he gave a talk at a BEIS stakeholder meeting on the review of the regulations, taking issue with the flame retardant representatives present, citing much evidence of the harm these chemicals cause to human health, and how they enter the food chain on a daily basis. Which, incidentally, indicates just how far BEIS/OPSS have departed from good government practice in recent years. I'm sure I'm not the only one, for example, to note that they still have not provided details, including names, of their experts panel. If there was nothing to hide about these experts, the OPSS would of course be only too happy to tell us all about them.
 
The fact that the OPSS discovered that the official they pursued was innocent of the supposed crime didn't stop them hounding him. Why? Well, and this is pure speculation of course, the flame retardant industry would not have been happy about that article because it exposed their common practice of infiltrating what are supposed to be neutral, balanced, experts committees which then for example push the line, as in the current consultation documents, that the "new approach" is the way to go (and with it the retention of huge volumes of flame retardants in our furniture). It also of course exposes the OPSS's continuing and unexplained support for the flame retardant industry (while at the same time claiming that it is trying to reduce chemicals in furniture). In other words, someone had to be made an example of. A practice quite common for the OPSS, as I well know of course.
 
I suggest to the OPSS that instead of mounting another witch hunt (when there would not be much point anyway in the circumstances) a better use of its time would be to put right the clear bias it has shown for some years now towards maintaining the chemical status quo of the regulations and falsely promoting the opinion that they provide fire safety. It would also be nice if they apologised to the man whose career they unnecessarily destroyed. But on past behaviour I suspect that is somewhat unlikely.
 
Regards,
 
Terry Edge

On 2 August 2023, the Office for Product Safety and Standards launched a new consultation on proposed changes (such as they are) for the Furniture and Furnishings (Fire) (Safety) Regulations 1988. To run alongside it, we are launching:
 
 
THE CAMPAIGN FOR SAFE FURNITURE
 
The situation:
 
Every person in the UK is being poisoned in their own homes - contracting cancers, respiratory diseases, thyroid illnesses and more, with children particularly vulnerable - because they contain the world's highest levels of toxic flame retardant chemicals, mostly in our furniture, employed to comply with the UK's tough furniture fire safety laws which the government itself proved nine years ago do not even work! 
 
This campaign is to help bring about non-toxic upholstered furniture that provides the same fire safety the rest of the world enjoys and which will bring and end to citizens and firefighters suffering cancers at rates way above normal.
 
What you can do:
 
The Office for Product Safety and Standards has just gone out to consultation - for the third time! - on their proposals for new furniture fire safety standards. They say they want to hear from you, and the public can in fact make all the difference. When first California then the rest of the USA wanted to change its furniture fire standards for the better, getting rid of all toxic flame retardants, there were literally hundreds of comments of support by the public sent in to the consultation. By contrast, the previous two UK consultations received no public responses at all. This is no one's fault, since the public has been largely kept in the dark about this massive scandal. But now is your chance to make a difference, because if the OPSS receives hundreds, even dozens of complaints, believe me it will be forced to act finally in the public interest.
 
The consultation and ways to respond to it can be found here. I recommend simply writing your response direct in an email to the address provided. Otherwise you will have to go through their entire series of questions which is time-consuming and confusing because frankly no one, least of all the OPSS, understands what's behind all of their and confusing specific questions. Keep it simple!
 
Obviously, you need to understand what you are saying in your response. However, time is short and the OPSS has shown many signs that it intends to go ahead with its proposals whatever anyone says; therefore, it's vital that we respond in numbers on key points. There is plenty of information on this blog to guide you, including the site page "OPSS's 2013 consultation".
 
Here are a few suggested points you might make:
 

• These new proposals will do nothing about the fact the current regulations are not fit for purpose and just make our furniture more toxic with high levels of flame retardant chemicals, both wearing off into our homes and by making home fires much more toxic, e.g. full of hydrogen cyanide fumes that are deadly. Please, therefore, implement the recommendations of the Environmental Audit Committee in 2019, to follow the rest of the world in providing just a cigarette/smoulder test which will eliminate flame retardants from our furniture.

 

• Also as recommended by the Environmental Audit Committee, please take children's mattresses and other child upholstered products out of scope of these regulations immediately, as the USA has done with its furniture flammability requirements.

 

• Please also follow the lead of the USA and ban flame retardants from upholstered furniture products.

 

 
 
I am looking at a fat folder of notes from and about meetings that took place between the Department for Business and a very wide range of stakeholders towards reviewing the Furniture Regulations. They cover a period of 18 months from around December 2010 to June 2011. There are masses of details and suggestions from experts on every aspect of furniture fire safety. They cover many meetings of the main Advisory Group and three sub-groups looking at Traceability, Testing and Definitions. 
 
In his Introduction to the 7 December 2010 meeting of the Advisory Group, Mitchell Leimon (head of the Product Safety Team, now the OPSS, at BIS) said:
 
"BIS is very keen that this review is a collaborative and open process". And a glance at all these notes confirms that it was indeed. For some years now, however, there has been virtually no collaboration on the furniture regulations. And the new proposals from the OPSS have been largely invented by them at the last moment with little to no reference to any of this good work done so long ago. For example, this meeting note then lists points made so far by the Group (see photo above).
 
Fourteen years on and NONE of these points has been dealt with, and are mostly not dealt with at all by the new OPSS consultation proposals (although including outdoor furniture fully in scope has now been proposed). 
 
Many of them appear to have completely escaped the OPSS's notice, like "Harmonise test house practices in applying the FFRs' test requirements". In fact the practice continues of furniture manufacturers simply trawling around the test houses, gathering 'fail's until they hit one that scores a 'pass'. The OPSS knows – or rather it should know – that the Food Standards Agency has the power to make test houses give up their logs of tests made in order that they can discover which companies are cheating in this way. 
 
As for "Capture the knowledge of the FFRs while it still exists" – well, I'm quoting here from knowledge that I'm fairly certain has not been capture by the OPSS; buried alive more like! 
 
The point is that many of the people and organisations involved in these meetings are still involved today. So, why aren't they protesting about the incredible lack of progress made since 2011? Why aren't they objecting to all that time and effort they wasted informing the government of what should be changed in the regs? 
 
Well, unfortunately, the OPSS can get away with this because manufacturers and retailers are terrified that if they object, then it will be made apparent to the public that they have knowingly done nothing about preventing customers being poisoned in their own homes at least since 2014 when the government proved the regulations are not effective. 
 
Why does the OPSS want to continue backing safety measures it knows do nothing but poison customers and make fires more toxic? Because the number one motive of civil servants, individually and collectively, is to cover one's back. These new proposals guarantee further long delays by which time all involved at the OPSS in these regulations will have moved on to other jobs and therefore out of the firing line.
 
As for all this knowledge that has been ignored: well, either the OPSS is in possession of it or it isn't. If the former, then why aren't they sharing it all with the world? If the latter, why aren't they asking if anyone has copies that they can add to the current review? The fact is, it's unlikely they have copies for two reasons: first, for many years electronic files at the Department for Business were/are badly stored and/or lost, therefore in effect unrecoverable; second, for the past nine years or so a culture has developed in government and the civil service of not keeping notes and records. Why this is the case should be obvious by now.