The French national agency for food, environment, work and health safety (ANSES) has published two detailed reports assessing fire safety risks and risks relating to flame retardants used in upholstered furniture. These reports conclude that the lack of adequate statistics prevents reliable assessment of how many lives or fires could be prevented in France by use of flame retardants in domestic furniture, and concludes “Given the available data on health and environment and the potential related risks, the Agency cannot recommend to generalise the use of flame retardants in domestic upholstered furniture.”
Amongst other actions, the Agency suggests the establishment of a ‘positive list’ of flame retardants whose safety and effectiveness has been “demonstrated”.
Furniture fire statistics
In the first (2014) report, ANSES accepts the evidence from the UK, where furniture fire safety regulations were introduced in 1988, that deaths in fires starting in upholstered furniture fell 65% from 1985-1988 to 2002-2006, compared to a reduction of only 48% for deaths in other fires, but nonetheless suggests that it is not possible to calculate reliably how many lives are saved by the fire safety of upholstered furniture in the UK. This differs from the conclusion of the analysis carried out by Greenstreet Berman (2009) for the UK Government, which suggests that suggesting that the Regulations account for 54 fewer deaths, 780 fewer injuries and 1065 fewer fires per year, with an economic saving of UK£ 140 million per year.
ANSES notes that in the most recent available data (2012), France’s fire services attended 81 000 domestic fires and 250 000 home fires were declared to insurance companies, with 460 deaths, 1 300 serious and 13 000 light injuries. 70% of these home fires occurred during the day, but 70% of the deaths were in fires at night.
ANSES states that available fire statistics are “inadequate to conclude that fire safety treatment of upholstered furniture significantly contributes significantly to the [identified] reduction in the number and gravity of home fires.” This is because fire statistics are largely inadequate, rarely reporting the cause of the fire or the items which were ignited, making it difficult to quantify the contribution of upholstered furniture to fire deaths and injuries. Also, it is difficult in fire statistics to distinguish between effects of product fire safety requirements, increasing installation of smoke alarms and decreased smoking habits. ANSES underlines that certain populations are particularly at risk of fire and recommends actions targeted at such populations, for example communication of fire safety information to children and the elderly.
Risk assessment
The second ANSES report (2015) assesses the risk of migration of flame retardants from upholstered furniture materials (ten FR-material combinations were tested for polyurethane foams, textiles, backcoatings) and assesses the possible health and environmental risks of 22 flame retardants (established and partly “legacy” FRs, see list below) identified as widely used in existing upholstered furniture. Many of these FRs are no longer used (see FIRA UK reports summarised in this pinfa Newsletter). ANSES indicates that the limitations to this study are due to difficulties in obtaining information from the French furniture industry, and the fact that the fire safety industry associations (GTFI in France) can provide only indicative information on types of FRs used, but not precise application data (pinfa note: because this data is confidential to textile, foam and furniture companies).
ANSES carried out FR migration tests on 10 FR/substrate combinations (see below) in synthetic sweat at 50°C and in air at 23°C and 60°C. These tests show that for all of these FR-material combinations, migration of the FR (including of reactive FRs tested) into simulated sweat (at 50°C) was detectable. However, into air, ANSES found no detectable FR migration for any of the tested FR-material combinations, except for migration of one flame retardant TCPP out of polyurethane foam. ANSES indicated in the stakeholder meeting of 21st October that they are aware that their migration tests only cover a small number of FRs, and that they are prepared to carry out migration tests on other FRs used in upholstered furniture, for which industry will provide treated and analysed material samples.
Assessing toxicity and ecotoxicity data availability, ANSES notes that, as required by the European Chemical Regulation REACH, toxicity data for substances registered < 1 000 tonnes/year is mostly 28 day or 90 day animal studies, and for substances > 1 000 tonnes/year chronic toxicity and carcinogenicity animal studies. ANSES identifies possible health or environmental risks indicated in literature for a number of the flame retardants considered.
Based on the migration studies for these 10 material-FR combinations and the health and environmental data available, ANSES concludes that “available data does not enable the exclusion of potential toxicity for human health or effects on the environment” for all of the 22 FRs considered to be widely used in existing upholstered furniture.
ANSES conclusions
The recommendations of the ANSES report, transmitted to the French ministry for consumer affairs (DGCCRF) are:
- Not to generalise use of flame retardants in upholstered furniture
- Systematic collection of information about fire causes in order to identify risk situations, including from insurance company statistics
- Regular maintenance of “autonomous” (battery) smoke alarms, installation of which is obligatory in all French homes since March 2015.*
- Installation of residential fire extinguishers
- Regular verification of electrical and gas installations in housing
- Fire prevention information and escape training of populations potentially vulnerable to fire risk, including via fire services, public authorities, insurance companies
- Public communication campaigns about domestic fire risks, and evaluation of their results
Develop an inventory of materials containing flame retardants, concentrations of FRs in different materials, in particular those imported into the EU - Improvement of knowledge concerning the health and environmental effects of flame retardants
- Develop methods for measuring flame retardant emissions from upholstered materials in real use conditions, including adaptation of these methods to take into account material ageing
- Life cycle analysis studies of upholstered furniture to address losses of FRs into the environment and improve protection of workers in recycling activities
- Develop furniture fire tests which are realistic as regards conditions for fires starting and developing in homes. This requires better knowledge of real fire situations
- Envisage the establishment of a “positive list” of flame retardants whose non-toxicity and whose effectiveness in real applications has been established
* pinfa editors note: battery powered, non mains connected (“autonomous”) smoke alarms, as required in France, are illegal for sale in the UK, because it is known that batteries are very often removed or not replaced when empty. Also in France, there is no obligation to verify that smoke alarms are installed or operative, for example when renting or selling accommodation.
pinfa response: proposals to move forward
pinfa welcomes the ANSES assessment as a significant step towards improving home fire safety in France.
The report indicates concerns about possible health and environmental risks posed by certain flame retardants used in the past. pinfa addresses the concerns of fire safety, environment and human health and commitment to collaboration as communicated by pinfa’s mission statement. Accordingly pinfa is open to a constructive dialogue with ANSES.
ANSES, Agence Nationale de la Sécurité Sanitaire, Alimentation, Environnement, Travail (French national agency for food, environment, work and health safety ) www.anses.fr
ANSES press release summarising reports’ conclusions, 22/10/2015, in French: “Pour prévenir le risque d’incendie domestique en France, privilégier des mesures alternatives au traitement des meubles rembourrés par des retardateurs.
Annex: ANSES lists of flame retardants and materials tested
The FR-material combinations tested for FR migration(from ANSES report II table 12 page 45/243)
Foam
– Polyurethane foam + TCPP
– Polyurethane foam + TDCPP
– Polyurethane foam + TPP
Induction
– Cotton – PVC with ATO and phosphorus FR
– Cotton – PVC with phosphorus FR
– Jersey PA – PVC with ATO and phosphorus FR
– PET – PU with ATO and brominated FR
Backcoating
– Back coating leather polyester DBDPE and ATO
Reactive FRs
– Cotton, cotton/polyester with THCP (Proban)
– Cotton with DMPPA
– Cotton with phosphonic acid / (Bis) guanidinium phosphate
Additive FRs
– Polyamide fibres with melamine polyphosphate
– Polypropylene fibres with DBDPE and ATO
– Polyester with RDP
The 22 FRs for which health and environment data is assessed:
Halogenated FRs and their synergists
1. DBDPE Decabromodiphenylethane, CAS 84852-53-9
2. DecaBDE Decabromodiphenylether, CAS 1163-19-5
3. HBCD Hexabromocyclododecane, CAS 25637-99-4
4. TBPH Bis(2-ethylhexyl) tetrabromophtalate, CAS 26040-51-7
5. TDCPP Tris(2-chloro-1-chloromethyl) phosphate, CAS 13674-87-8
6. TCPP Tris (1,3-dichloro-2-propyl) phosphate, CAS 13674-84-5
7. Antimony trioxide, CAS 1309-64-4
8. V6 2,2-bis(chloromethyl)trimethylene bis(bis(2-chloroethyl)phosphate), CAS 38051-10-4
9. Zirconium potassium hexafluoride, CAS 16923-95-8
PIN FRs
10. Phosphoric acid, CAS 7664-38-2
11. Phosphonic acid, CAS 6303-21-5
12. BPADP / BAPP Bisphenol A Bis-(diphenyl phosphate) CAS 181028-79-5 or 5945-33-5
13. IPTPP Tri(isopropylphenyl)phosphate, CAS 68937-41-7 or 26967-76-0
14. Melamine, CAS 108-78-1
15. Melamine phosphate, CAS 20208-95-1
16. (Bis) guanidinium phosphate, CAS 5423-23-4
17. RDP Resorcinol Bis-diphenylphosphate, CAS 57583-54-7
18. DMPPA Dimethylphosphono-N-hydroxymethyl-3-propionamide, CAS 20120-33-6
19. TCP Tricresyl phosphate, CAS 1330-78-5
20. THCP Tetrakis (hydroxymethyl) phosphonium chloride, CAS124-64-1
21. TPP Triphenyl phosphate, CAS 115-86-6
22. Zirconium acetate, CAS 7585-20-8
Data were also collected for 6 other FRs which were not in fact assessed, because considered to be not widely used in upholstered furniture.
1. TBBPA Tetrabromobisphenol A, CAS 79-94-7
2. TCEP Tris (2-chloroethyl) phosphate, CAS 51805-45-9
3. Phosphonic acid copolymer, no CAS number
4. TEHP Tri ethyl hexyl phosphate, CAS 78-42-2
5. TOCP Tri-o-cresyl phosphate, CAS 78-30-8
6. TBEP Tris(2-butoxyethyl) phosphate, CAS 78-51-3