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AHFA Flammability Update. Bob Luedeka March 20, 2008. Topics. CPSC Proposed Rule: Standard for the Flammability of Residential Upholstered Furniture 16 CFR Part 1634 Fire Retardant Issues. CPSC 16 CFR Part 1634. Addresses much of the risk Good starting point

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AHFA Flammability Update

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AHFA Flammability Update

Bob LuedekaMarch 20, 2008


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Topics

  • CPSC Proposed Rule: Standard for the Flammability of Residential Upholstered Furniture 16 CFR Part 1634

  • Fire Retardant Issues


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CPSC 16 CFR Part 1634

  • Addresses much of the risk

  • Good starting point

  • Could be amended later to address small open flame


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CPSC 16 CFR Part 1634

  • Protocol needs to be investigated.

  • Is it reproducible?

  • Representative of composite furniture performance?


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Fire Retardant Issues

  • News coverage continuing regarding FR concerns

  • NGOs posturing to pass CA AB706

  • Calif. Bureau of Home Furnishings has been quiet about TB117, prefers to see a national standard


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Claims Need Rebuttal From FR Producers


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Background

Halogenated products

Brominated Chlorinated

Note: PentaBDEs no longer being used

by US foam industry

Non-halogenated

Phosphorus


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Killer Couches:

Claim: Handheld XRF guns can be used to detect halogenated compounds in upholstered furniture.

Response: XRF guns can detect some brominated compounds on the surface of foam and fabric. Accuracy is unknown. XRF guns cannot detect chlorine compounds.


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Killer Couches:

Claim: Halogenated compounds migrate from furniture to household dust.

Response: So far, that’s unproven speculation focused on PBDE compounds. Migration of today’s FR foam additives has not been reported.


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Killer Couches:

Claim: There is no way to safely dispose of furniture treated with halogenated FRs.

Response: There is no evidence of hazard or risk in the customary disposal of furniture treated with halogenated FRs.


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Killer Couches:

Claim: Halogenated fire retardants are not used in TB133 furniture.

Response: Halogenated compounds are common ingredients in melamine-modified FR foam.


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Killer Couches:

Claim: Latex is both fire safe and free of fire retardant chemicals.

Response: Latex is flammable and subject to the same regulation in upholstered furniture as polyurethane foam. Large amounts of FR additives are required in latex foam to meet California TB117.


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California TB117

  • AB706 would require the Bureau to revise TB117.

  • PFA requested suspension of the open flame portion of TB117 until more is known about the safety of today’s FR technologies.

  • The Bureau has not commented.


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FR Additive Developments

  • FR suppliers are developingnon-halogenated alternatives.

  • PFA foam manufacturers, AHFA and FR suppliers recently met to discuss issues and concerns.

  • FR suppliers are working to satisfy EPA evaluation requirements on existing and developmental FR products.


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Bob Luedeka

865-690-4648

pfa.org


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