September 3, 2013
Ms. Diana Godines
California Bureau of Electronic Appliance and Repair, Home Furnishings and Thermal Insulation
4244 South Market Court, Suite D
Sacramento, CA 95834-1243
Dear Ms. Godines:
As a nonprofit organization dedicated to improving public health, the National Research Center for Women & Families strongly supports the proposed revisions of California’s flammability standards for upholstered furniture and other products. The use of flame retardants is pervasive, and these chemicals harm human health and the environment without providing measurable benefits in improving fire safety. Because many manufacturers apply California’s standards to furniture and other products sold nationwide, revision of Technical Bulletin 117 will have a profound and positive effect on the health of adults and children in California and across the country. We encourage you in your agency’s efforts to create safer alternatives and standards in order to protect the public health from these dangerous chemicals.
The proposed regulations require that furniture manufacturers test their furniture to ensure that it is smolder resistant. These tests will provide better fire safety than the previous open-air flame retardant requirements. Fire retardant materials have not been shown to be effective in preventing fires. In December 2010, almost 150 scientists worldwide from a variety of disciplines joined in a statement critiquing flame retardants, stating the following:
Many brominated and chlorinated flame retardants lack adequate toxicity information, but the available data raise concerns. . . Many different types of brominated and chlorinated flame retardants have been incorporated into products even though comprehensive toxicological information is lacking . . . Brominated and chlorinated flame retardants can increase fire toxicity, but their overall benefit in improving fire safety has not been proven.[end DiGangi J, Blum A, Bergman Å, de Wit CA, Lucas D, et al. (2010) San Antonio Statement on Brominated and Chlorinated Flame Retardants. Environmental Health Perspectives 118(12): doi:10.1289/ehp.1003089] (emphasis added).
Moreover, the proposed regulations will use new technology, such as smolder-resistant materials, that eliminate the need of furniture manufacturers to cover their products in flame retardant chemicals that have health risks. Research indicates that exposure to these chemicals may be associated with disruption of hormones, neurological underdevelopment, reproductive abnormalities, and cancer.[end Brown P., Cordner A. (2011). Lessons Learned From Flame Retardant Use And Regulation Could Enhance Future Control Of Potentially Hazardous Chemicals. Health Affairs 30 (5): 906-14. Retrieved from ABI/INFORM Global (accessed June 21, 2012).] Because adverse health reactions can take years to develop, it will take many years of longitudinal research to determine all the deleterious effects that these flame retardants already had on children and adults. Due to their widespread use in consumer products as well as their presence in wildlife and the environment, potential exposure is significant throughout the United States, which is a serious public health concern.
In summary, we strongly support the modified revision of California’s Technical Bulletin 117 and greatly appreciate your agency’s work on this issue. Please let us know if we can be of any help in supporting your efforts.
Diana Zuckerman, PhD
National Research Center for Women & Families
For more information, contact Paul Brown at the National Research Center for Women & Families at firstname.lastname@example.org or (202) 223-4000.