The Case Against Flame Retardants in Furniture – Part One
This is intended to be a logic piece, rather than an academic publication. There won’t be many links in it – those can mostly be found on other pages on this site. It will raise questions about the heavy use of flame retardants in UK upholstered furniture and other products, with the intention of helping anyone interested to sort out the best route to take towards protecting their health and safety inside their own homes.
A good starting place to gain a basic understanding of flame retardants in products can be found at the website of the Green Science Policy Institute. This is a USA site; however, the flame retardants referred to, and how they turn up in products, is pretty much the same here in the UK. The fact that it is difficult to find similar guides in the UK is not insignificant.
I’ll put together various bits and pieces that may add to the overall picture; again, with the aim that anyone reading it can make up their own minds. I’m not claiming this page will be exhaustive but it should be a good starting place.
The bottom line reason for considering this issue is the fact that every home in the UK contains around 30-50 kgs of flame retardant chemicals in its sofas and mattresses and possibly around the same again in other products like duvets, carpets, curtains, electrical devices, etc, with the result that our homes contain the highest levels of FR dust in the world. Because these chemicals get into our systems, the UK also has the highest levels of FRs in mothers' breast milk and babies' blood.
The presence of FRs massively increased in the UK with the introduction of the Furniture and Furnishings (Fire) (Safety) Regulations in 1988. Before this, upholstered furniture – sofas, mattresses, cushions, etc – mostly did not contain any FRs (although they had been appearing in cover fabrics following the 1980 Regulations - see below). Increasingly, polyurethane foam fillings had been appearing in furniture which were highly flammable and gave off a degree of toxic smoke when they burned, including hydrogen cyanide. But it was this flammability that was given as the main reason the regulations were needed; not as flame retardant supporters now claim because furniture fillings were so toxic. They were toxic when they burned; however, modern furniture foam is much more toxic and not just when it burns, also in the form of FR dust (which was not a problem before). A few people high up in the fire services immediately began covering up these negative aspects of FRs and have continued to do so until the present day. Why? Well, a good place to start would be to ask the FBU's chief fire safety officer (who was recently forced to resign) about his additional and undisclosed "perks"; also, his mate in the other fire services union, CFOA, who resigned at about the same time. In the past few months (this is being written in August 2019), there has been a massive shake-up of the FBU taking place, with front-line firefighters seriously challenging why they have been kept in the dark for so long about the fact that because of FRs UK fires are some of the most toxic in the world and give first responders higher levels of cancer than normal. The FR-supporters are showing signs of being rattled which can only be a good thing where public safety is concerned.
In the lead up to the introduction of more stringent regulations, there was much pressure from the fire services and MPs such as Tony Blair to reduce the numbers of house fires started in upholstered furniture. It’s generally accepted that the fire in the Woolworths Manchester store's furniture department in 1979 that killed 10 people played a huge role in bringing in the regulations. The person who led the inquiry into that fire was firefighter Bob Graham. When Mr Graham retired from the fire services he went to work for the European Flame Retardants Association, a strong advocate for the use of FRs in furniture. He campaigned for many years to get the European Commission to raise furniture flammability standards in Europe to UK levels, which would have provided a huge new market for the FR industry. He very nearly succeeded, too, but eventually the Commission decided that it was not convinced that flame retardants were as harmless as the industry made out, and they opted to keep EU furniture relatively chemical-free. Apart from a brief (and clearly reluctant) appearance on the BBC's Newsnight" in December 2017, Mr Graham has recently re-emerged for reasons as yet undisclosed but in a phone call I had with him, he agreed that the match test in the Furniture Regulations does not work (and, as I pointed out to him, therefore the fillings test also does not work) and the mattress test is useless because bedding always catches fire and overcomes the fire resistance of the mattress. He does however still insist that the sofa fillings test is needed, albeit in defiance of reason and with no supporting evidence. I could speculate as to his motives in this but that requires another post.
Mr Graham is not the only firefighter to retire then go to work for the flame retardant industry. Another is Mike Hagen who likes to claim he’s independent when advising on fire safety yet is funded by hundreds of thousands of euros by the big three FR producers, and also receives support from Burson Marsteller, the massive PR company that works for them. It’s an open secret that currently serving fire officials are also in the pay of the FR industry – a factor that plays a huge part in ensuring UK homes continue to be polluted by FRs.
It's very difficult to find online many details of the Woolworths fire Inquiry, but there is evidence that there were five fires altogether in Woolworths stores in the 70s. One was just a month after the Manchester fire, this time in a pile of pillows. When the regulations came in, they included fire resistant requirements for pillow fillings. No one is able to say why, when no other bedding was included, but the result is that we are all sleeping with our heads close to a lot of FRs.
Following the fire in 1979, there was huge pressure on the Government to update the existing furniture regulations, specifically to include foam fillings. This pressure resulted in new regulations being issued in 1980. However, they did not include a fillings test. The Government argued that the match test (to prevent ignition of cover fabrics) would protect fillings. Mr Graham and others continued to lobby heavily for a fillings test, however, drawing attention to new fire tragedies especially ones including child deaths. They eventually got their way in 1988. However, the match test was retained, which on the face of it defies logic: with a separate fillings test why retain a covers test that is supposed to protect the fillings? Well, one reason may have been that FRs were now appearing in cover fabrics because of the match test, which was a highly profitable new market for the industry, never mind that the nastiest kinds of FRs, the brominated varieties, tend to be used in covers.
So, during the build-up to the implementation of the 1980 and 1988 regulations, the flame retardant industry was heavily involved, sitting on the various working groups advising on what the requirements should be. And while both sets of regulations did not stipulate the use of FRs, the tests were sufficiently stringent that it was going to be extremely difficult to meet the requirements without using them.
The main argument the FR industry used (and continues to use) was that FRs give you 12-14 mins escape time from a fire. However, there are some problems with this claim:
* See Richard Hull/Anna Stec's paper in Chemosphere Dec. 2017 – piece below with link**. Canadian TV also ran tests with FR-treated and non-treated upholstered chairs to find only around a minute's difference in them fully catching fire. And a recent BBC TV programme looking at the benefits of sprinklers inadvertently proved the case against FRs, i.e. it set light to a typical bedroom set-up and regardless of the FRs in the mattress, the entire room was aflame within 3 minutes. There are also numerous videos on YouTube, made by UK fire services, which show how a bedroom fire is fully developed in less than 3 minutes, despite the presence of huge amounts of flame retardants in the mattress; example here.
What is the proof that FRs work with regard to the Furniture Regulations?
In fact there is no proof at all that FRs are necessary for the regulations to be effective. The question that has been researched on two occasions is: are the regulations effective? To answer this question two elements have been utilised:
1. UK fire statistics
2. An analysis of these statistics by government-commissioned bodies
Where fire statistics are concerned, the UK keeps pretty good detailed records, as made by firefighters who deal with a fire, answering mostly tick-box questions like, 'What was the item first ignited', etc. Items first ignited can be products covered by the regulations, such as sofas and mattresses. So, for example, we know that around 2014, there were something like 50 fire deaths a year from fires in products covered by the regulations. It's worth noting, however, that no record will be kept of fires that were put out/went out because then obviously the fire brigade were not called to the premises.
Where analysis of these statistics is concerned, the government has commissioned two reports into the effectiveness of the regulations: in 2000, undertaken by the University of Surrey and in 2009, undertaken by Greenstreet Berman Ltd. The former concluded that the regulations were saving around 70 lives per year and the latter around 54 lives per year. The drop in lives saved was put down to factors such as increased smoke alarms and a decrease in smoking at home.
It is perhaps significant that the University of Surrey received/receives funding from the FR industry and that Professor Gary Stevens who was responsible for the report in 2000, wrote a more detailed one a few years later on the effectiveness of the UK regulations, this time commissioned by the European Flame Retardants Association. The same people, by the way, who paid Bob Graham's wages for many years.
What Stevens managed to establish is the notion that you can say that a life was saved by the regulations. This has not been challenged, at least not in the UK, but when looked at logically it doesn't hold up, simply because if the regulations work then the fire will not develop in the first place; which means no one outside the home knows it occurred; which means no one knows that a life was saved. If on the other hand the fire develops and you have to escape the house, then the regulations haven't done their job. On that last point, it would be easier to say that the regulations failed to save 50 lives in 2014.
The only possible, albeit rough, guide is to look at the rate of decline in fire deaths since the regulations were introduced in 1988. Home fire deaths have indeed decreased in the past 30 years but the regulations are only one factor; others include a massive increase in smoke alarms and a big decrease in smoking at home over the same period aided by the introduction in 2011 of an EU standard requiring all cigarettes to be self-extinguishing if left unattended. New Zealand has similar furniture to the UK but no flammability regulations; however, its rate of decline in home fire deaths pretty much mirrors the UK's over the same period. Bob Graham challenged this comparison in his recent phone call with me, claiming that the population of New Zealand is lower than the UK's without, it seems, understanding that the rates are based on deaths per million.
But probably the biggest blow to the belief that the regulations save lives is in BIS's 2014 consultation document and Technical Annex. These, along with Trading Standards' confirmations in the field, prove that the 'match' test in the regulations fails to prevent sofas from igniting in up to 90% of cases. And of course, if an ignition flame is not put out by the match test, the cover fabric will soon be ablaze, and the rest of the sofa is going to go up in flames regardless of whether or not the fillings pass the fillings test.
Again, this appears to be confirmed by New Zealand's stats matching the UK's, i.e. New Zealand does not have a match test protecting its sofas.
At the very least, therefore, the flame retardants used in UK cover fabrics are doing nothing to prevent fires. But they are making those fires far more toxic than a New Zealand fire.
Are FRs in fillings helping to prevent fires?
The foam fillings test is undertaken by setting light to what's called a 'crib 5'. This is a small frame of pine wood stuffed with 18 gms of paper. It's meant to replicate a home fire where flame has set light to papers/materials resting on a sofa. The EU does not have a furniture fillings test such as this mainly because other EU countries believe flammability tests should only be on the prime subject, e.g. the sofa, and the fire source (cigarettes, matches) and not other items that might be on it.
Be that as it may, the prime problem with the crib 5 test is that it does not cater for what happens when the cover fabric catches fire. And here we have a conundrum: if the match test works and puts out flame that falls on covers, why do we need a fillings test? Because if the cover flame is not put out, the resulting cover fire is going to much more severe than the crib 5 representation, and the fire is going to take hold of the fillings anyway.
The UK is the only country in the world to have a separate furniture fillings test - perhaps for the reasons suggested above.
(Part 2 to follow)
** Proof that flame retardants in UK furniture increase fire deaths
From a UCLAN press release dated 14th December 2017:
Professor Richard Hull unveils new research
Breakthrough research has revealed that flame retardants used in domestic furniture increase the amount of toxic chemicals produced when it burns, increasing the likelihood of death following the outbreak of a fire.
Full press release available here:
Full Chemosphere paper here: chemosphere_paper.pdf
It's important to bear in mind that the testing research undertaken to inform this paper was carried out on furniture constructs that actually pass the current match test in the Furniture Regulations. In other words, even if your sofa complies with the match test, you are still at risk from toxic poisoning should it catch fire. However, the findings of the government and Trading Standards shows that up to 90% of UK sofas actually fail the match test in practice.
Which means the danger from toxic poisoning is even greater than this paper describes.
BEIS recently issued a statement to a journalist claiming that there is no evidence the Furniture Regulations are not effective. This is a total lie, brazenly made in the face of BEIS's own published evidence - available on their own website - that the current match test mainly fails in practice.
In short, the Department for Business, Energy and Industrial Strategy is knowingly keeping the entire country at risk from toxic poisoning, and sitting on the solution it came up with in 2014 but has been too gutless or corrupt or both to implement it.
The Case Against Flame Retardants - Part Two
On my blog page for 27th October 2019, I introduce the email reproduced below. It came about because we saw that a “European Fire Safety Week” conference is being held in Brussels from 18-21 November 2019. It looks very respectable, organised by the European Fire Safety Alliance, which also looks respectable. The EFSA, however, is funded by several chemical companies, including the big three flame retardant producers, Lanxess, ICL and Albemarle. This is what they try do: buy respectability to use as a front for pushing their toxic products. And they buy people who appear respectable, too; who claim they are motivated purely by the desire to improve fire safety.
This email calls out and challenges one of these flame retardant supporters, Mike Hagen. Hagen is an ex-firefighter who has run or been part of various fire safety organisations which are always supported one way or another by the flame retardant industry.
This is I believe a good example of how to understand better the case against flame retardants. If and when Mr Hagen responds, I will of course let everyone know. [Update: as of 12 November, Mr Hagen has not replied; see further below for the email I sent him accordingly. Further update: as of 13 January 2020, Mr Hagen has not replied.]
From: Terry Edge
Date: Wednesday, 23 October 2019 at 16:50
To: Mike Hagen
Cc: Numerous, including interested MPs and FBU members
Subject: Attention of Mike Hagen
You will by now have seen the Environmental Audit Committee’s recent recommendation to the Department for Business, Energy and Industrial Strategy, i.e. that the government should change the Furniture Regulations, which currently do not work, so as to employ just a smoulder/cigarette test (same as the US and the EU in practice) which would remove the need for flame retardants in our furniture. You probably also saw BEIS’s subsequent response to its 2016 consultation (which amongst other things repeated its 2014 findings that the current match test fails) which in effect states that instead of adopting this recommendation it is scrapping the previous 10 years of reviewing the Regulations to start again. In the meantime, the UK will be stuck with the existing requirements for many years to come. The fire sector and industry has been oddly silent about this turn of events.
The European Fire Safety Alliance (of which you are a Core Group Member) states on its website:
“The European Fire Safety Alliance believes . . . that domestic fire safety should be a matter of great concern for society in general and a top priority for all those in whom we entrust our families’ care and welfare. Moreover, it is often the most vulnerable (children, elderly people, people with disabilities, low income families) that are affected by these tragedies.”
You were present as a member of the Fire Sector Federation Panel when it met the Department for Business, in a meeting chaired by Sir Ken Knight, on 30 October 2014, in the House of Commons. You will recall that at this meeting the FSF failed to find any fault with BIS’s evidence that the current match test does not work (and that the new one will). Your panel agreed that the new test could go ahead after you came up with a new test foam formula (even though this was not needed). At the following meeting at BIS on 16th December 2014, your FSF panel was represented by Sir Ken Knight, Dave Sibert and Jon O’Neill. They gave a slide show presentation which essentially reaffirmed their agreement that the current match test does not work. They insisted that the British Standards Institute be given 12 months to come up with a new test foam formula. This was not specifically agreed to at this meeting but the FSF later talked the Minister, Jo Swinson, into commissioning BSI along these lines. BSI in the event, however, declined the work as not appropriate for them. The new test was then blocked and the current test remains in place. I’m sure you must therefore be concerned that BEIS in its recent announcement stated that it will ask BSI to come up with new furniture flammability requirements.
In short, you were part of a panel that agreed the current match test does not work; therefore that UK furniture is not fire-safe. This surely must be “a matter of great concern” for the Fire Safety Alliance. Yet the EFSA website states:
“Only the UK and Ireland have introduced stringent fire safety standards for upholstered furniture. Adopted in 1988, the UK furniture and furnishings fire safety regulation has been a major factor in the reduction of domestic fire deaths and injuries over the last twenty years. Similar high standards of fire safety do not exist in any other Member State where consumers are therefore completely exposed to the dangers of upholstered furniture fires – especially foam-filled furniture. Indeed, once involved, foam-filled furniture creates a major increase in the fire hazard of any kind of domestic fire.”
Which is puzzling, in light of the fact you know the current Regulations do not actually work. In your submission to the EAC you state: “I have vigorously promoted the cause of safer furniture as I, like most in the professional fire sector know modern furnishings are the main risk factor in fire deaths in the home.” Why therefore are you not raising awareness of the fact that BIS proved (and the FSF agreed) that the current Furniture Regulations mean every home in the country contains unsafe furniture, both in terms of flammability and the toxicity of the flame retardants that are used to meet requirements that don’t even work?
Incidentally, you also state in your EAC submission that: “In every piece of communication I made when in the role [running the Fire Safety Platform], including every meeting I held with Mr. Edge and/or his department, I always made clear who provided the funding from other sponsors but the majority was from the FR industry”. This, however, is not true. You did not tell me you were funded by the FR industry when you and Bob Graham took me out to dinner in Brussels in December 2012, the night before a meeting at the European Parliament where the FR market might potentially have been under attack – a dinner, I seem to recall, that was paid for by Chemtura, with one of its employees also present. And you did not tell me or my departmental managers at the FSF meeting in December 2014 about your funding arrangements. The only time you mentioned funding to me was when we had a coffee together in Victoria, I believe in late 2013. Then, you said it did not affect your independence; however, you spent most of that meeting trying to persuade me that the current match test works fine and doesn’t need changing. You also did not tell me the level of your funding; however, we can see from here – https://lobbyfacts.eu/representative/369bf8b0193b4c098c4b573d4627b004/fire-safety-platform - that the Fire Safety Platform spent over 120,000 euros in lobbying in 2013. I suppose you’ll say it’s just a coincidence that the European Commission let it be known in December 2012 that it no longer would support raising EU furniture flammability levels to the UK’s unless it could be done without flame retardants; also that 2013 was the year in which BIS announced its plans to change the match test which would hugely reduce flame retardants in UK furniture.
You may have seen that Bob Graham appeared on the BBC’s “Newsnight” in December 2017 where he admitted to also having been funded by the same FR companies but insisted, like you, that he did things “in my own way”. You can perhaps understand why many of us are somewhat sceptical about such claims for independence, especially in light of the FR industry’s long track record in fighting any fire safety changes that would reduce their sales.
You may be aware that the issue of the toxicity of flame retardants and fire safety in furniture is currently being debated by the All Party Parliamentary Fire Safety and Rescue Group. At its last meeting, the issue was briefly debated between myself and Bob Graham. The APPFSRG has pledged to devote its next meeting to a fuller debate on what is clearly a very important subject. In the meantime, I am advising the new Contaminants Group in the FBU, which is determined to reduce the toxicity of the fires its members face on a daily basis, particularly those involving burning flame retardants. Given that you and the Fire Safety Alliance are campaigning for the rest of the EU to adopt the same requirements as the current UK Regulations (even though they don’t work) and with it, clearly a huge increase in flame retardants in European furniture, I and others, such as my FBU colleagues (copied in), would be grateful for your answers to the following questions:
In your EAC submission you state that: “The fact that Mr. Edge has deliberately misled Committee members as they go about their important business should create concerns for you with regard to the validity of his evidence.” Well, here’s your chance to prove what at present can only be taken as opinion – by answering the four questions above, but with evidence, please, not just opinion stated as fact.
Not having heard from Mr Hagen, I sent him this email today, 12 November 2019:
From: Terry Edge
Date: Tuesday, 12 November 2019 at 15:48
To: <MIKE@CITCNEPAL.ORG>, <email@example.com>, <firstname.lastname@example.org>
Subject: Re: Attention of Mike Hagen
We’ll take your lack of response as clear evidence that you do not have answers to the four questions [I asked you]. In light of which, can you and/or the European Fire Safety Alliance please desist from insisting that the UK’s Furniture and Furnishings (Fire) (Safety) Regulations 1988 provide fire safety. Instead, can you please tell the truth: that the UK government has proved they aren’t fit for purpose and research has shown that UK furniture is actually more toxic when it burns than untreated EU furniture.
We note that your “European Fire Safety Week” is dedicating a session on 21 November to “Furniture Fire Safety”. In the blurb for this event, it says:
“Despite overwhelming efforts in protecting human lives, fires still remain an important cause of deaths worldwide. Of this, approximately 90% occur in the domestic area, mostly due to fires starting from our upholstered furniture such as sofas and beds. In light of this alarming picture, how can we make sure that our furniture is fire safe for people, their belongings and fire fighters?”
Again, we would be grateful if the “how” referred to does not include the misleading advice that the rest of Europe should adopt the same measures as the UK’s Regulations or that flame retardants make fires safer. I’m sure my colleagues in the FBU would also be grateful if you told the truth about the higher levels of toxicity found in fires where flame retardants burn, and the adverse effects of them upon firefighters’ health.