S.U.N.Y FASHION INSTITUTE OF TECHNOLOGY

FIRE RETARDANTS IN COMMERCIAL FURNISHINGS A MASTER THESIS Presented to the Faculty of the Sustainable Interior Environments at the School of Graduate Studies, Fashion Institute of Technology In Partial Fulfillment of the Requirements for the Degree of Master of Arts in Sustainable Interior Environments

BY JESSICA NEWS MENTOR: JEAN HANSEN

MAY 2013

© 2013 Jessica News

This is to certify that the undersigned approve the thesis submitted by

Jessica News In partial fulfillment of the requirements for the degree of Master of Arts in Sustainable Interior Environments

_____________________________________________________ GRAZYNA PILATOWICZ, CHAIRPERSON

________________________________________________________________ JEAN HANSEN, MENTOR

________________________________________________________________ MARY DAVIS, DEAN, SCHOOL OF GRADUATE STUDIES

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ABSTRACT Bioaccumulation and potential negative health implications have raised concerns over the use of some fire retardant chemicals. In the design and building industry, fire retardants are required in some furnishings to meet building code requirements. This paper seeks to reveal the current state of affairs regarding fire retardants in commercial building furnishings. An outline of the history of fire retardants; the benefits and risks associated with their use; regulatory actions; and recent proceedings are presented. Because of the controversy surrounding some fire retardants, designers and those who specify furniture need to understand what fire retardants are used in furniture and how they are applied. As a part of this report, a study was conducted with furniture manufacturers to reveal construction methods, fire retardant materials utilized, and manufacturing approaches to meeting fire codes. It was determined through this study, that the application of a barrier material is used frequently to meet the strictest code requirements. Future research, however, is still needed to determine which fire retardant chemicals are being used.

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BIOGRAPHICAL SKETCH I have always had a profound interest in how spaces affect people. I went to design school with the hope of being able to help shape people’s experiences in our world. Since that first year of school I have been keenly attached to the definition of an interior designer, one who “protects and enhances the health, life=safety, and welfare of the public.” Three years into my profession, a colleague, Jean Hansen, gave a presentation about environmental chemicals in our building materials. I was astounded, to say the least. Before then, I had never known of the potential negative health implications of our materials and finishes selections. I had always seen materials and finishes as an opportunity to further a design concept and enhance the intended ‘feeling.’ I never would have thought my interest in impacting a person’s experience in space would include their physical health. But as an embodiment of the definition of an ‘interior designer,’ I felt it was my ethical responsibility to fully understand environmental toxins and help spread awareness of the prospective uncertainties. This paper is the culmination of two years of master’s level study in the Fashion Institute of Technology’s Sustainable Interior Environments program where I have begun my journey into understanding and advocating for healthy environments.

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DEDICATION This paper is dedicated to all researchers, and educators, and all those who question ‘accepted’ practices and who demand higher standards.

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ACKNOWLEDGMENT Special acknowledgement is given to Jean Hansen, my thesis mentor, a pioneer in her field and champion of design that ‘protects and enhances the health, life safety and welfare of the public.’ Thanks are also due to Grazyna Pilatowicz, the chair and founder of the Sustainable Interior Environments Masters Program at the Fashion Institute of Technology, for asserting research and sustainability in interior design education. Finally, very personal and special thanks are given to my colleagues, friends, and family who have supported me throughout all my endeavors. All of this would not be possible without your help.

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TABLE OF CONTENTS ABSTRACT ........................................................................................... iii BIOGRAPHICAL SKETCH...................................................................... iv DEDICATION ......................................................................................... v ACKNOWLEDGMENT ........................................................................... vi TABLE OF CONTENTS ......................................................................... vii LIST OF FIGURES .............................................................................. viii LIST OF TABLES ................................................................................ viii ABBREVIATIONS .................................................................................. ix CHAPTER 1: INTRODUCTION .............................................................. 10 STATEMENT OF THE PROBLEM.......................................................... 10 PURPOSE OF THE STUDY........................................................................................... 10 RESEARCH QUESTIONS ............................................................................................. 11 LIMITATIONS AND DELIMITATIONS ............................................................................ 12

CHAPTER 2: REVIEW OF LITERATURE ............................................... 13 PRIMARY ISSUES ..................................................................................................... 13 HISTORY ................................................................................................................ 13 BENEFITS AND RISKS ............................................................................................... 17 FIRE HAZARDS .................................................................................................................... 17 CONCERN OVER FIRE RETARDANT CHEMICALS .......................................................................... 18

RECENT PROCEEDINGS............................................................................................. 26 SUSTAINABLE BUILDING RATING SYSTEMS ............................................................................. 29 REGULATORY ACTIONS ........................................................................................................ 30

CHAPTER 3: ANALYSIS........................................................................ 36 RESEARCH METHODS ............................................................................................... 36 TYPE AND DESCRIPTION OF STUDIES ..................................................................................... 36

DATA ANALYSIS STRATEGIES .................................................................................... 38 RESEARCH FINDINGS ............................................................................................... 38

CHAPTER 4: RESULTS ........................................................................ 44 RESEARCH SYNTHESIS ............................................................................................. 44 CONSTRUCTION METHODS .................................................................................................... 44 FIRE RETARDANT MATERIALS ................................................................................................ 46 APPROACHES TO MEETING FIRE STANDARDS ............................................................................ 46

CHAPTER 5: CONCLUSION ................................................................. 48 REVIEW OF FINDINGS .............................................................................................. 48 LIMITATIONS ......................................................................................................... 48 IMPLICATIONS ........................................................................................................ 48 FUTURE RESEARCH ................................................................................................. 49 SUMMARY AND CONCLUSIONS ................................................................................... 50

REFERENCES ..................................................................................... 51 APPENDIX A: SAMPLE QUESTIONNAIRE ............................................. 58 APPENDIX B: COMMONLY USED FLAME RETARDANTS ..................... 59

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LIST OF FIGURES Figure 1: AMERICAN FIRE CATASTROPHES AND SUBSEQUENT BUILDING CODE CHANGES 14 Figure 2: SELECTED HUMAN AND WILDLIFE LEVELS OF PBDEs ........................................... 20 Figure 3: PBDES IN BREAST MILK AND FAT SAMPLES AROUND THE WORLD ........................ 22 Figure 4 SIMPLIFIED LIFE CYCLE FOR A FLAME RETARDANT CHEMICAL ............................. 24 Figure 5: APPLICATION OF THE SOURCE TO DISEASE PARADIGM ......................................... 26 Figure 6: RED LIST COMPARISON ........................................................................................... 28 Figure 7 FLAME RETARDANT REPLACEMENTS ....................................................................... 33 Figure 8: TYPICAL UPHOLSTERED FURNITURE CONSTRUCTION DETAIL ............................... 44

LIST OF TABLES

Table 1: QUESTIONNAIRE RESPONSES ................................................................................... 43

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ABBREVIATIONS ASTM BEARHFT CBHF CDC CPSC DecaBDE DDC=CO EPA HBCDD HHS HRMS ICC LEED NCIDQ NIST NFPA OctaBDE OEHHA OSHA PBB PBDE PentaBDE POP TB TBB TBBPA TBP TBPH TCEP TCPP TDCPP TSCA UFAC UNEP WHO

American Standard Testing Method Bureau of Electronic and Appliance Repair, Home California Bureau of Home Furnishings Center for Disease Control and Prevention Consumer Product Safety Commission Deca=bromodiphenyl ether Dechlorane Plus Environmental Protection Agency Hexabromocyclododecane Department of Health and Human Services Gas chromatography=high resolution mass spectrometry International Code Council Leadership in Energy and Environmental Design National Council for Interior Design Qualification National Institute of Standards and Technology National Fire Protection Association Octa=bromodiphenyl ether Office and Environmental Health Hazard Assessment Occupational Safety and Health Administration Polybrominated Biphenyl Polybrominated diphenyl ether Penta=bromodiphenyl ether Persistent Organic Pollutants Technical bulletin 2=Ethylhexyl ester 2,3,4,5=tetrabromobenzoate Tetrabromobisphenol A Tribromophenol 1,2= Ethylhexyl 3,4,5,6=tetrabromo= Tris (2=chloroethyl) phosphate Tris (1=chloro=2=propyl) phosphate Tris (1,3=dichloro=2=propyl) phosphate Toxic Substances Control Act Upholstered Furniture Action Council United Nations Environment Program World Health Organization

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CHAPTER 1: INTRODUCTION STATEMENT OF THE PROBLEM Commercial construction operates under federal and state codes, ordinances, and other restrictions meant to protect the safety of building occupants. Fire codes are law and thus essential concerns for every building today. To meet fire code regulations, special considerations apply to many building’s design elements, including furniture. Furniture is frequently treated with fire retardants in order to meet strict life safety regulations. Fire retardants however have come under scrutiny, associated with multiple negative health implications.

PURPOSE OF THE STUDY The National Council for Interior Design Qualification (NCIDQ) is an international organization responsible for setting standards for the interior design and interior architecture profession. The NCIDQ defines interior design as “a scope of services performed by a professional design practitioner; qualified by means of education, experience and examination, to protect and enhance the health; life safety and welfare of the public”(National Council for Interior Design Qualification, Inc, 2004, p. 1). Therefore all interior design professionals are responsible for creating interior environments, which protect the health, safety, and welfare of the public.

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In order to truly protect the health, life safety, and welfare of the public, interior designers must abide by life safety building codes. Along with many aspects of life safety these codes set the standards for flammability of materials and furnishings, but do not address the negative health implications associated with fire retardants. How can interior designers ensure that they are meeting building codes and protecting the public from the threat of fire, while limiting the public’s exposure to potentially harmful fire retardant chemicals? To provide designers with the knowledge and ability to specify safer commercial furnishings which meet life safety building code, this study will seek to examine the issues related to fire retardants in commercial furnishings. The purpose of this study is therefore, to raise awareness in the building industry, educate designers and those who specify furniture, and promote safer manufacturing practices in the furniture industry.

RESEARCH QUESTIONS To address the growing concerns over fire retardants in the building industry, those who specify furniture must fully understand how commercial furniture manufacturers are meeting strict fire codes. This research seeks to understand the process of making commercial furniture fire retardant. The intent of this research is to explore and document the existing state of affairs with regards to fire retardants in the commercial furniture manufacturing.

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LIMITATIONS AND DELIMITATIONS This study examines fire retardants, any means or methods used to resist burning, utilized on the commercial grade furniture within public occupancies in the United States (Merriam=Webster, 2012). The study mainly inspects typical fire protection treatment of upholstered furniture assemblies. Data will be examined within the context of life safety codes specific only to commercial building types. The primary research gathered for this study is obtained from willing participants and thus does not reflect the entirety of the industry. Information about manufacturing processes is sometimes proprietary and, thus, difficult to obtain. The information gathered reflects the opinions of the willing participants only. These factors limit both the quantity and quality of the information gathered.

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CHAPTER 2: REVIEW OF LITERATURE PRIMARY ISSUES There is a rising concern over the use of flame retardants in furnishings. The history of fire retardants; and the benefits, risks, and regulatory actions associated with their use, provide a framework to the recent proceedings regarding fire retardants in the building industry. Investigations of these topics provide some understanding of the current state of affairs in commercial building furnishings. Further study will be required to understand how furniture manufacturing is impacted by rising concerns over the use of flame retardants in furnishings.

HISTORY The matter of controlling building fires has existed since human beings first started building. In Colonial North America, early building techniques, typically construction of combustible wood, combined with the rapid growth of cities lead to almost daily building fires. The Industrial Revolution and growth of manufacturing, resulted in an increased density of city buildings and a rise in populations in the United States. Conflagrations, or fires that spread from building to building, often led to massive destruction in many growing cities. (Cote & Grant, 1988). The great Chicago fire of 1871 demolished a third of the city’s buildings causing 168 million dollars in damage and an estimated 250 deaths. In 1872, 30 city fire departments responded to the great Boston 13

fire that destroyed 60 acres and caused 75 million dollars of damage. In 1906, San Francisco experienced an earthquake followed by a fire that burned for two days causing $350 million dollars in damage, approximately 450 deaths, and left 300,000 people homeless (Arnold, 2005). Many other notable and largely destructive fires have been experienced throughout American history. BUILDING CODES AND STANDARDS Major fire events, like those noted above, frequently were followed by development or revision of building codes and regulations. Below is a timeline of major American fire catastrophes and subsequent building code changes and technology development.

F IGURE 1: AMERICAN FIRE CATASTROPHES AND SUBSEQUENT BUILDING CODE CHANGES (A RNOLD , 2005)

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The fire disasters in the nation’s history have continually prompted a need to better understand the causes, characteristics, and behaviors of fires. In 1894 the Underwriters Electrical Bureau, now Underwriters Laboratories Inc. was established to investigate the cause of fires. Following, in 1896, the National Fire Protection Association (NFPA) was established. Early 19th century innovations led to the development of tools to measure temperature and heat flow. These inventions coupled with the discovery of thermoelectric effect and thermodynamics created a platform for the modern scientifically based fire testing methods that we know today. It was less than 200 years ago that these innovations initiated the fire tests for buildings and building materials, which have eventually led to the development of the many building codes and standards that we have today (Lawson, 2009). There are currently around 93,000 building standards in the United States. Standards are typically developed by organizations as model codes which are then individually referenced into local jurisdictions building codes. The two model code organizations, which develop most of all of the United States standards, are the NFPA and the International Code Council (ICC). Model codes and standards are enacted into law by local state legislation. Additionally, through Congress, the Consumer Product Safety Commission (CPSC), the Department of Health and Human Services (HHS), and the Occupational

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Safety and Health Administration (OSHA) can issue federal safety regulations (Cote & Grant, 1988). “On 29 November 1972 the Federal Register stated, on behalf of the Department of Commerce, that a flammability standard or other regulation might be needed for upholstered furniture (Hirschler, 1994, p. 10).” The flammability of upholstered furniture has been a major concern since the late 1960s. With furniture fires typically being the result of ignition from smoking materials, usually cigarettes, it was believed that a solution would be to increase smolder resistance of the furniture. The National Bureau of Standards, the National Institute of Standards and Technology (NIST), today, and the Upholstered Furniture Action Council (UFAC), a private organization funded by furniture manufacturers began the effort to develop test methods for upholstered furniture. NIST developed the cigarette ignition test, later standardized by the NFPA (261) and the American Standard Testing Method (ASTM) E1352. The CPSC deferred mandatory federal regulation of a standard in 1979. The California Bureau of Home Furnishings (CBHF) however developed two Technical Bulletins (TB), TB 116 and TB 117 (Hirschler, 1994). Today California TB 117 is a requirement for all furniture sold in the state of California (Hirschler, 1994). For this reason, most furniture in the US is manufactured at minimum to meet TB 117, which has thus become the de facto national standard for furniture (Babrauskas, Blum, 16

Daley, & Birnbaum, 2011). TB 117 is a performance based standard requiring that cellular materials and filling materials of furniture are tested for flame and smolder resistance. For this standard, furniture components are tested individually (State of California Department of Consumer Affairs Bureau of Home Furnishings and Thermal Insulation., 2000). To address flaming ignition of furniture, CBHF also developed TB 133 (Hirschler, 1994). TB 133 is, like TB 117, a performance based standard. TB 133 is a composite test, meaning the components are tested together in an assembly. This test requires seating to abide by limits of temperature, smoke, and carbon monoxide release. TB 133 is intended for seating furniture in public occupancies (State of California Department of Consumer Affairs Bureau of Home Furnishings and Thermal Insulation., 1991).

BENEFITS AND RISKS FIRE HAZARDS In the United States, in 2012, there were 484,500 structure fires, causing 2,640 civilian deaths, 15,635 civilian injuries, and $9.7 billion in property damages (NFPA, 2012). Fire is a real problem in the building industry and furniture has continually been linked as a source for fire development. The NFPA reported that between 2005 and 2009, 7,040 home fires began first with upholstered furniture (Ahrens, 2011). Flame retardant’s purpose is to suppress the growth of flames and spread of a fire. 17

CONCERN OVER FIRE RETARDANT CHEMICALS Despite the intended protection they provide, fire retardants in furniture have become controversial. Recently, there has been a rise in questions regarding the potential negative health impacts associated with their use. “From the early 1980s through the late 1990s, autism increased tenfold; from the early 1970s through the mid=1990s, one type of leukemia was up 62 percent, male birth defects doubled, and childhood brain cancer was up 40 percent. Some experts suspect a link to the man=made chemicals that pervade our food, water, and air. There's little firm evidence. But over the years, one chemical after another that was thought to be harmless turned out otherwise once the facts were in (Duncan, 2006).” To address furniture flammability and meet the regulations outlined above, furniture components are frequently treated with fire retardant additive and reactive chemicals. Flame retardants can be typically divided into three groups: Antimony and other inorganic compounds, halogenated compounds, and phosphorous compounds. Different chemical compound are chosen based on the application needed. (Ash & Ash, 1997) More than 175 flame retardant compounds are on the market today (Wilsor, 2004). Some common flame retardants discussed in this paper are: Hexabromocyclododecane (HBCDD), Tetrabromobisphenol A (TBBPA), Tris (1=chloro=2=propyl) phosphate (TCPP), and the Polybrominated 18

Diphenyl Ether (PBDE) class including Penta=bromodiphenyl ether (PentaBDE), Octa=bromodiphenyl ether (OctaBDE), and Deca= bromodiphenyl ether (DecaBDE). See Appendix C for a list of bromine, chlorine, and phosphorous containing flame retardants, their chemical number, common abbreviation, structures, and trade names. The fire retardant compounds raising most public concern today are those belonging to the halogenated class. Halogenated flame retardants are chemical compounds of the halogen elements bonded with carbon, otherwise known as organohalogens. The organohalogens of bromine or chlorine are the most efficient at reducing the propagation of fire. They do this by interfering with oxygen in the gas phase and enhancing charring (Kolic, et al., 2009). They are thermally stable and thus serve as successful fire retardants that resist decomposition. This property, however, also causes the compounds to persist in the environment many years after use (Eljarrat & Barcelo, 2011). BIOACCUMULATION Technologies such as Gas Chromatography=High Resolution Mass Spectrometry (HRMS) have lead to enhanced detection and analysis of flame retardants in the environment. In Playing with Fire: The Global Threat presented by Brominated Flame Retardants Justified Urgent Substitution, Santillo and Johnston report on studies tracking flame retardants in the environment. In the article, they recap evidence from Christensen’s 2002 studies of PBDEs in Greenland and levels of Tetra= 19

and PentaBDE in fish and mussel tissue and an increase in levels of Canadian wildlife. Another featured study by Sellstrom and Jakobsson reveals levels of DecaBDE in the eggs of peregrine falcons (Santillo & Johnston, 2003). TBBPA has been reported in river sediments in Japan and Sweden and HBCDD in contaminated rivers (Sjodin, Patterson, & Bergman, 2003). In 2003, scientist from several laboratories across the United States and Canada published, Polybrominated Diphenyl Ether Flame Retardants in the North American Environment, which outlines results of soil, sediment, air, and aquatic levels of PBDEs in North America in comparison to other global contamination studies. Through various investigations, the publication finds that environmental concentrations of PBDEs appear to be increasing throughout each tested area (Hale, Alaee, Manchester=Neesvig, Stapleton, & Ikonomou, 2003).

F IGURE 2: SELECTED HUMAN AND WILDLIFE LEVELS OF PBDE S (H EALTHCARE W ITHOUT H ARM , 2006 )

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BIOMONITORING Rising levels of PDBEs have been recorded not only in the environment and wildlife but also in humans. Polybrominated Diphenyl Ethers in the Environment and in People: A Meta'Analysis of Concentrations documents an exponential increase in PBDE levels in human blood, milk, and tissues that continually doubles every four to six years (Hites, 2004). Figure 2 documents and compares levels of PBDEs in the environment and human milk. In California where strict regulations exist for fire retardant furniture, San Franciscan women were measured to have PBDE levels three times higher than Swedish women, ten times higher than German and Canadian women, and twenty=five times higher than Spanish women (Healthcare Without Harm, 2006 ). Concentrations of PBDEs, Tribromophenol (TBP), and TBBPA have been shown to have increased more than six fold in Norwegian men and women between 1977 and 1999 and are still on the rise. (Santillo & Johnston, 2003) A review on human exposure to brominated flame retardants—particularly polybrominated diphenyl ethers, also notes how pervasive PBDE is in the general population; however their study found that TBBPA is accumulated only through continuous exposure (Sjodin, Patterson, & Bergman, 2003). Biomonitoring has been used to determine individual body burden by organizations such as the Center for Disease Control and Prevention (CDC), and California’s Office and Environmental Health Hazard 21

Assessment (OEHHA). In 2008, the Environmental Working Group (EWG) led the first study determining that levels of fire retardant chemicals in children were measuring higher than levels in their parents. High levels of DecaBDE were also found in mother’s breast milk and in 10 out of 10 tested newborn’s umbilical cord blood (Environmental Working Group, 2008).

F IGURE 3: PBDES IN BREAST MILK AND FAT SAMPLES AROUND THE WORLD (S CHECTER , P AVUK , P APKE , R YAN , B IRNBAUM , & R OSEN , 2003)

EXPOSURE ROUTES How exactly are children’s’ body=burden of fire retardant chemicals higher than their parents? Some flame retardant chemicals have been shown to bioaccumulate and enter human populations through food

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intake (Sjodin, Patterson, & Bergman, 2003). Other sources could include inhalation and dermal absorption. It is believed that children are exposed to flame retardants through ingestion of contaminated breast milk. They also have higher hand=to=mouth activity and are thus more likely to ingest the high concentrations of chemicals found in settled household dust (Schecter, Dioxins and Health Including Other Persistance Organic Pollutants and Endocrine Disruptors, 2012). Flame retardant chemicals are released into the environment throughout their life cycle. Figure 4, on the following page, shows the use stages of flame retardant materials and subsequent release locations for associated chemicals. In industrial use, workers may be exposed to fire retardant chemicals in manufacturing and recycling. Consumers may be exposed to chemicals by ingestion, dermal absorption, or inhalation of dust in their homes. After use, the fire retardant materials can be landfilled, incinerated, or recycled. When landfilled and incinerated, chemical byproducts are released into the environment where the general population may be exposed (EPA, 2012).

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CHEMICAL MANUFACTURING

INDUSTRIAL USE

OCCUPATIONAL EXPOSURE

MANFUACTURING USE

FOAM MANUFACTURING

CONSUMER USE

RESIDENTIAL AND COMMERCIAL FURNISHINGS

POST-CONSUMER USE (PRODUCT END LIFE)

MATERIAL STREAM CHEMICAL STREAM

FURNITURE MANUFACTURING

LANDFILL

INCINERATION

RECYCLING

MIGRATION TO SURFACEWATER AND GROUNDWATER (ENVIRONMENTAL AND GENERAL POPULATION EXPOSURE)

COMBUSTION BYPRODUCT FORMATION AND RELEASE (ENVIRONMENTAL AND GENERAL POPULATION EXPOSURE)

ADDITIONAL OCCUPATIONAL EXPOSURES

VOLATILIZATION AND DEPOSITION ONTO DUST IN HOMES CONSUMER EXPOSURE

F IGURE 4 SIMPLIFIED LIFE CYCLE FOR A FLAME RETARDANT CHEMICAL (EPA, 2012)

HEALTH EFFECTS Exposure to fire retardant chemicals is a concern due to the potential for toxicity. There is not a complete understanding of how these chemicals and their byproducts affect humans or animals. Toxicology and epidemiology databases are limited and studies that have been conducted are few and report conflicting findings (Birnbam & Staskal, 2004). Studies finding toxic affects emphasize some fire retardants as endocrine disruptors, neurotoxins, and reproductive toxins (Eljarrat & Barcelo, 2011). 24

In a study sponsored by World Health Organization (WHO), United Nations Environment Program (UNEP), and International Labour Organization, TCPP was found to have low to moderate acute toxicity by oral, dermal, and inhalation routes in rodents. Rabbit eye and skin irritancy was also noted. In a study with mice, Tris (1,3=dichloro=2= propyl) phosphate (TDCPP) exposure of approximately 1800 mg/kg body weight per day caused death within one month. In a two year feeding study, cancer was developed in both female and male rats, regardless of exposure level. Kidney, testicular, and brain tumors were also developed. No studies of the effects of TCPP or TDCPP on humans have been undertaken, to date (IPCS, 1998). Data in laboratory studies of amphibians, birds, fish, mice, and rats has shown PBDE to disrupt the thyroid, ovarian, and androgen functions. In studies of rodents in the developmental stages, PBDE exposure affected liver enzymes, thyroid hormone levels, caused reproductive damage, immunotoxicity, and had neurotoxic effects (Shaw, et al., 2010). Some concerns over the potential toxicity of PBDEs, stems from their chemical similarity to polybrominated biphenyls (PBBs). PBBs were removed from production in the United States after a 1973 contamination of animal feed, which resulted in the extermination of 1.6 million chickens and 30,000 livestock (Wilsor, 2004). Effects from exposure reported in residents included skin disorders, pain, nausea, 25

hair loss, and changes in liver enzymes. A study assessing neurological symptoms, reported diminished performance of males associated with PBB serum concentrations (Schecter, Dioxins and Health Including Other Persistance Organic Pollutants and Endocrine Disruptors, 2012). Even today, some of the population still carry PBB body burden (Wilsor, 2004).

SOURCES (PRODUCTS)

MICROENVIRONM ENT (AIR, DUST)

PERSONAL EXPOSURE (INHALATION, INGESTION, DERMAL ABSORPTION)

INTERNAL DOSE (SERUM BREAST MILK)

EARLY EFFECT (ALTERED HORMONE LEVELS)

DISEASE

F IGURE 5: APPLICATION OF THE SOURCE TO DISEASE PARADIGM (S CHECTER , D IOXINS AND

H EALTH I NCLUDING O THER P ERSISTANCE O RGANIC P OLLUTANTS

AND

E NDOCRINE

D ISRUPTORS , 2012)

RECENT PROCEEDINGS In the summer of 2011, the Chicago Tribune unleashed an investigative research series aimed at revealing collusion in the flame retardant industry. The growing series unveils deceptions, from the chemical company funded ‘Citizens for Fire Safety’ advocacy group to politicking by the Tobacco industry, and campaigning to resist impacts and bad publicity. The series intends to reveal how industry and 26

economy have been controlling flame retardants. The articles expose a web of interrelationships between chemical companies using distorted information to ‘sell’ fire retardants in furniture as a necessity. The Chicago Tribune notes that ‘makers of flame retardants manipulate research findings to back their products, and downplay health risks (Roe & Callahan, 9).” Controversies regarding the fire retardant industry paired with rising concerns over the potential health implications of fire retardant chemicals, have caused many organizations across multiple disciplines to act. From design and construction firms, to not=for=profits and government organizations, groups are raising awareness and beginning to address the concerns.

RED LISTS Several companies and organizations have internally begun to restrict usage of controversial flame retardant chemicals. Perkins + Will, an architectural firm, has developed a precautionary list for a number of chemicals used in the building industry. PBDEs as well as some inorganic, inorganic synergist, and organic phosphate flame retardants are included (Perkins + WILL, 2012). The internet mogul, Google, has sought to eliminate known toxins from buildings by utilizing a ‘red list’ of chemicals to avoid. Halogenated flame retardants are one of the chemicals they have included on their list (Hiskes, 2011). Google’s red 27

list was developed with guidance from the Living Building Challenge, who also has a red list which includes flame retardants. The figure below demonstrates the overlap in fire retardants seen in these red lists.

F IGURE 6: RED LIST COMPARISON

As a part of the Healthy Hospital Initiative, Kaiser Permanente, a large health=care organization, has developed a sustainable scorecard to guide product purchases. They require product manufacturers to indicate if their products contain Bromine and Chlorine=based compounds such as TBBPA, HBCDD, DecaBDE, OctaBDE, PentaBDE, TCPP, TDCEP and Dechlorane Plus (DDC=CO) flame retardants. Kaiser Permanente uses and distribute these scorecards for other healthcare organizations to use when researching and comparing products (Kaiser Permanente, 2008). In the global arena, the San Antonio Statement, a joint project of the International Panel on Chemical Pollution, International POPs 28

Elimination Network, and Green Science Policy Institute was created to publically raise concerns about the dangers associated with certain flame retardants. The Statement was endorsed by more than two hundred scientists from around the world in 2010 (IPEN). The Stockholm Convention, a global treaty aimed at eliminating Persistent Organic Pollutants (POP) from the environment, recognized flame retardant concerns from the start. The Convention established a list of initial POPs known as the dirty dozen, which included PCBs. In 2009, the polybrominated flame retardants, PentaBDE and OctaBDE were also added to the list. One hundred and seventy=nine parties are participating in the treaty today and seeking to reduce or eliminate the listed flame retardants. (Secretariat of the Stockholm Convention = UNEP, 2008).

SUSTAINABLE BUILDING RATING SYSTEMS In design and construction, several building rating systems have been developed to award certifications to buildings which meet a specified set of criteria. In the past, the criteria for sustainable building rating systems have included considerations such as a building’s energy consumption, water efficiency, and indoor environmental quality. Today, building rating systems have begun to incorporate the elimination of harmful toxins as criteria for certification. The US Green Building Council’s Leadership in Energy and Environmental Design (LEED) certification system, launched a pilot credit in 2010 aimed at reducing 29

halogenated flame retardants (USGBC, 2011). The Living Building Challenge certification program requires participants not to include any halogenated flame retardants including but not limited to PBDE, TBBPA, HBCCD, DecaBDE, TCPP, TDCEP, and DDC=CO (International Living Future Institute, 2012).

REGULATORY ACTIONS On February 8th of 2013, California proposed revisions to the flammability standard TB 117, the standard which requires all residential furniture pass flame resistance testing. The proposed changes would update the 1975 version of the standard, to require a smolder test for fabric with mock=ups of cushions rather than tests for the foam only. Eighty=five percent of the furniture sold today would pass this new smolder requirement (Environmental Health Sciences, 2011). One day prior to the public hearing, the Bureau of Electronic and Appliance Repair, Home Furnishings and Thermal Insulation (BEARHFTI) had already received 30,097 comments and 66,000 petitions in response to the proposal for the standard’s revision (Department of Consumer Affairs, 2013). Although many support the changes which would lessen the need for fire retardant chemicals in foams, others are concerned over the safety of the new standard, worried it will increase the propensity for fires (Betts, 2008).

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At the same time that regulations regarding furniture are being considered, the controversial flame retardant chemicals are also being investigated federally. On March 27th of 2013, the United States Environmental Protection Agency (EPA) announced plans to assess 20 flame retardant chemicals as a part of the Toxic Substances Control Act (TSCA) work plan. Full risk assessment will be conducted for 2= Ethylhexyl ester 2,3,4,5= tetrabromobenzoate (TBB), 1,2= Ethylhexyl 3,4,5,6=tetrabromo=benzenedicarboxylate or (2=ethylhexyl)=3,4,5,6 tetrabromophthalate (TBPH), Tris(2=chloroethyl) phosphate (TCEP), and HBCDD. Because there is not sufficient data for assessment of all the 20 chemicals, eight others with similar characteristics will be grouped and reviewed with those listed above to advise the assessment (EPA, 2013). “To ban a chemical already on the market, the EPA must prove that it poses an "unreasonable risk." Federal courts have established such a narrow definition of "unreasonable" that the government couldn't even ban asbestos, a well=documented carcinogen that has killed thousands of people who suffered devastating lung diseases. (Hawthorne, Chicago Tribune , 2012)” In the past, the EPA has enacted TSCA action plans for some other flame retardant chemicals. Currently, risk management actions are being pursued for HBCD, PentaBDE, OctaBDE, and DecaBDE. However only a quarter of the over 80,000 industrial chemicals in use in the United States today have ever been tested for toxicity. In the Chicago 31

Tribune series, writers question how fire retardants currently on the market differ from those banned in the past. According to one particular article, the 1976 Toxic Substances Control Act limits the government’s ability to regulate chemicals. The chart below outlines flame retardant chemicals that have been banned and replaced.

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F IGURE 7 FLAME RETARDANT REPLACEMENTS (H AWTHORNE , N IELAND , & E ADS , F LAME

33

RETARDANTS AND THEIR RISKS ,

2012)

In 2004, the European Union banned PentaBDE from sale. As a result, United States manufacturers phased the chemical out of production along with another PBDE congener, OctaBDE (EPA, 2012). PentaBDE was the primary flame retardant used in furniture foam from 1980 to 2004 (Shaw, et al., 2010). “Alternative chemical flame retardants have since been used and identified as PentaBDE replacements in polyurethane foam. However, basic information on these alternative flame retardants, such as chemical identity, specific product applications, and volumes used, are typically not available, significantly restricting human and environmental health evaluations. Many of the chemical ingredients in flame retardant mixtures are proprietary and are not disclosed by the chemical manufacturers, even to manufacturers using these chemicals in their final end products (e.g., furniture) (Stapleton, et al., 2011).” With continual concern over the bioaccumulation of certain flame retardants and potential toxicity, it is important to understand the use of flame retardants in furniture. The history of fire retardants; and the benefits, risks, regulatory actions, and recent proceedings outlined above provide some understanding of the use of flame retardants. Further study is required to understand how furniture manufacturing is impacted by rising concerns over the use of flame retardants in furnishings. The remainder of this paper outlines the methods and results of a primary research 34

study intended to reveal exactly how furniture manufacturers are currently meeting fire regulations.

35

CHAPTER 3: ANALYSIS RESEARCH METHODS The existing state of affairs with regards to flame retardants in furniture has been examined above. To test the application of the knowledge gained and to fully understand the process of making commercial furniture fire retardant, primary research with selected furniture manufacturers was conducted. An analysis of the method of research is presented in this chapter.

TYPE AND DESCRIPTION OF STUDIES Research has been developed through a grounded theory study, in which data was collected to inform a theory. Descriptive studies with quantitative data were used to support and advise the research.

DATA COLLECTION STRATEGIES Qualitative data was collected through a multi=method approach. Data collection was flexible as to allow the data to inform the study and change over time. Initially, however, data collection focused on gathering secondary research to inform the primary field studies. The secondary research can be found in Chapter 2’s Review of Literature. Secondary research was gathered from various sources. A complete understanding of the history of fire retardants and life safety codes for public spaces developed the frame for the remaining research.

36

Life safety building code research was informed by the 2012 version of the International Building Code book and the International Code Council resources. Primary research was gathered predominantly through interviews and questionnaires with furniture manufacturers. Interviews were conducted with furniture manufacturer’s technical specialist, foam suppliers, and other industry members involved in fire retardant research. Case studies were conducted involving three different lounge chairs from three different reputable commercial manufacturers. All chairs analyzed are able to be manufactured to meet the most stringent fire codes. Questionnaires and correspondence with the manufacturers were conducted to evaluate how the chairs are constructed to meet fire codes. Questions were posed about the chair’s internal components, fire retardant products and usage, fire retardants application methods, fire testing procedures for TB 117/NFPA 260, TB 116/NFPA 261 and TB 133/NFPA 266, and alternative methods for providing fire retardant treatments. Questionnaires were used to gather quantitative data to support the research. Questionnaires were distributed to select commercial furniture manufacturers regarding a pre=selected upholstered chair. The questionnaires for manufacturers were intended to reveal manufacturer’s fire retardant usage, the products they typically use to pass TB 37

117/NFPA 260, TB 116/NFPA 261 and TB 133/NFPA 266, if alternatives are available, and if alternatives are frequently specified.

DATA ANALYSIS STRATEGIES To synthesize and analyze, primary data was categorized by the origin of the source. Using a comparative method, data was analyzed and compared against information gathered from each source. These findings will inform further investigations, to fill in gaps in current industry knowledge. The results from the questionnaires intend to reveal information regarding typical manufacturing processes and fire retardant usage. Secondary data is intended to document current knowledge regarding the history of fire retardants; and the benefits, risks, and regulatory actions associated with their use. Secondary data was used to inform questionnaires and interview questions. It was also used in conjunction with primary data to formulate conclusions. Interview data assisted in gathering source information and was used to confirm the current state of knowledge regarding fire retardants and their use in commercial furniture. Interview data gathered also helped inform sources of further research.

RESEARCH FINDINGS

38

Three manufacturers provided responses to a questionnaire about one of their upholstered lounge chairs. For the purpose of this study, we will be referring to these three manufacturers as Manufacturer A, Manufacturer B, and Manufacturer C. A copy of the questionnaire is available in Appendix A. When asked about the typical construction methods for their upholstered lounge chairs, the three manufacturers responded similarly, although providing varying amount of detail in their responses. Two of the chairs are constructed with a wood frame and one is constructed with a steel frame. All three chairs feature foam and an upholstery fabric, which will vary based on purchaser’s selection. The manufacturers all have a steel component to their chair bases. Manufacturer B utilizes nylon strands where Manufacturer C utilizes elastic webbing in their suspension. All three manufacturers responded that this is a typical construction method for their upholstered lounge furnishings. The three manufacturers had different responses when asked about whether fire retardant treatments are applied to the chair. Manufacturer A responded that fire retardant options are available on all their products. Manufacturer B replied yes, but referenced later responses to questions about how their chair meets fire test requirements. Manufacturer C replied that no treatments were applied, although a fireguard is upholstered over the unit prior to the upholstery 39

fabric application. They also noted that special foam is utilized when intending to meet TB 133 testing. When asked to describe the fire testing procedures all the manufacturers responded that chair testing is performed by an independent lab or the supplier. Manufacturer B did reply that TB 133 is a composite test of the entire chair in which open flame is exposed to the chair for 80 seconds and that the total duration of the test is up to an hour. When the flame is removed, if there is no evidence of flame or smoke than the test concludes, and the chair would pass the requirements for TB 133. Manufacturer B replied that they do not test to the NFPA260 standard. The manufacturer noted that given the raw materials they use to comply with the TB 117, they should comply with NFPA 260. The manufacturer also provided the testing report provided by the third party testing lab, Intertek, which outlines the testing procedure and results for the chair. The manufacturers were then asked to describe how their chair’s construction and/or what treatment processes are required for the chair to meet fire testing requirements outlined in TB 117/NFPA 260, TB 116/ NFPA 261, and TB 133/NFPA 266. For each question, Manufacturer A replied that they only test to TB 133 and did not provide a description of how their chairs are manufacturer to meet TB 117/NFPA 260 or TB 116/NFPA 261. To 40

comply with TB 133 testing, manufacturer A wraps a barrier product called 810054 Fire Guard F187 between the foam and the upholstery fabric or leather. Manufacturer B replied that TB 117 addresses foam and fabric. They note that no fire retardants are added to the fabric to meet TB 117 however, fire retardants are standard in the slab stock foam they purchase. The respondent noted that the slab stock foam is TB 117 rated and that they purchase their foam from a large distributor with little or no control over the ingredients included in the process. They also note that they are unsure of the specific fire retardant used but it is likely they are halogenated, either brominated or chlorinated. Manufacturer B replied that they do not test to TB 116/NFPA 261. For TB 133/NFPA 266, by special order, Manufacturer B provides a barrier cloth which contains PBDE flame retardants. The barrier cloth is laminated to the fabric then attached to the chair using standard manufacturing methods. The manufacturer notes that only 20=30 pieces have been sold in the past two years however they are seeking an alternative to this barrier cloth. Manufacturer C responded that all furniture construction is manufactured to conform to TB 117. Upholstery is not apart of this construction, as it is not produced by the furniture manufacturer. NFPA 260 is met by using Perflex AC/Blue line Braided Welt Cord (#aB0097) which contains soft pliable aluminum foil to dissipate heat. 41

Manufacturer C meets TB 133 requirements by using a fireguard barrier to completely encapsulate the upholstery materials or “FIRERETARD especially [a specially] formulated foam material”. The manufacturer notes that they determine which method to use depending on the product and will certify that the furniture will pass TB 133 with either method when used in conjunction with fabrics which pass TB 117. In conclusion, each manufacturer was asked if there are any special construction options related to fire retardant treatments for the chair. Manufacturers B and C replied “no” while Manufacturer A referenced another section. It is not clear to the researcher if Manufacturer A offers any other manufacturing options related to fire retardant treatments. Responses from the three manufacturers are charted below for reference and comparison.

42

T ABLE 1: QUESTIONNAIRE RESPONSES

43

CHAPTER 4: RESULTS RESEARCH SYNTHESIS Input provided directly from furniture manufacturers in combination with secondary research provides some understanding of upholstered furniture construction methods and answers questions regarding how manufacturers approach fire testing. Further research is required to confirm what fire retardant treatments are applied to meet the required standards.

CONSTRUCTION METHODS It is observed that most commercial upholstered furniture is constructed in a similar manner, with a frame, support webbing, foam padding, and fabric.

F IGURE 8: TYPICAL UPHOLSTERED FURNITURE CONSTRUCTION DETAIL (K RASNY , P ARKER , & B ABRAUSKAS , 2001)

44

FIRE TESTING PROCEDURES Commercial manufacturers send products to independent laboratories for testing. The three manufacturers participating in the study only tested to TB 133 requirements. It may be inferred that manufacturers test to this standard because it is a component test requiring a mock=up. The study’s participating manufacturers did not mention testing for TB 117. Two of the manufacturers mentioned however that all furniture construction, not upholstery, meets TB 117 requirements. One of the manufacturers even mentioned the slab stock foam being TB 117 rated. Because all components of furniture are individually tested in the TB 117 standard, are manufacturers simply procuring TB 117 compliant materials to construct the furnishings? The Association of Contract Textiles has set TB 117 as a standard performance guideline for contract fabrics (ACT, 2010). The Polyurethane Foam Association notes TB 117 as the most commonly used test for flexible polyurethane foam products (Stone, 1998). Therefore, it seems, most fabric and foam are manufactured to meet TB 117 standards. Further study is needed to determine how the study’s participating manufacturers are meeting TB 117 requirements without testing.

45

FIRE RETARDANT MATERIALS Only one of the participating manufacturers for the study confirmed use of fire retardant materials in their foam. The manufacturer was not able to provide any information about the specific fire retardant chemical used. The Polyurethane Foam Association (PFA) reported that typical US fire retardant additives for foam are either mixtures of brominated flame retardants and phosphate esters such as Firemaster 550 and 600, or chlorinated phosphate esters such as TDCP. According to the PFA, non=halogenated flame retardants have a small but growing base. The Polyurethane Foam Association also notes that phosphorous=based flame retardants are only useful in foams requiring firm densities, and that OctaBDE and DecaBDE have not been used successfully (Luedeka, 2011). According to this statement, it could be inferred that flexile polyurethane foam in the United States is treated with either brominated flame retardants or phosphate esters or chlorinated phosphate esters.

APPROACHES TO MEETING FIRE STANDARDS From both this study and secondary research sources, it is perceived that furniture manufacturers are meeting TB 133 standard by wrapping foam with a barrier material. In Halogenated Flame Retardants: Do the Fire Safety Benefits Justify the Risks? , fireproof barrier fabric or batting (such as fiberglass or Kevlar based materials) is

46

discussed as one of two options to meet the strict TB 133 requirements. It is also stated that a fire retarded upholstery fabric or inherently fire retardant fabric can be used with high=risk use specially designed foam (Shaw, et al., 2010). Manufacturer C also reported this as an option to meet TB 133. The EPA has reported that barrier technologies could be an alternative approach to traditional methods. Layering allows a product to maintain its fire resistance even after another layer is compromised. Some barrier materials are natural fibers such as cotton with a chemical treatment, typically boric acid. Another option is a blend of synthetic materials, such as Kevlar, Nomex, polybenzimidazole, VISIL, Basofil and natural fibers. A third option is to utilize synthetics fibers with inherent flame resistance. Fire=retardant films, such as Neoprene, are also being utilized (EPA, 2012).

47

CHAPTER 5: CONCLUSION REVIEW OF FINDINGS Although there are some similarities in responses from all three respondents, exact conclusions cannot be draw about how exactly commercial furniture manufacturers meet all the fire safety regulations. It seems a standard practice to wrap foams in=order to meet TB 133; however the study did not reveal which materials are being used to encase the foam. It is also unclear from the study how manufacturers are meeting TB 117.

LIMITATIONS The results of this study are a reflection of the time in which this report was written. The primary research gathered for this study is obtained from willing participants and thus does not reflect the entirety of the industry. These factors limit both the quantity and quality of the information gathered.

IMPLICATIONS This study reveals a gap in the design industry’s knowledge. From information presented in this paper, designers and those who specify furniture should have been made aware of the controversies surrounding fire retardants. health

With the rising concerns over the potential negative

consequences

related

to

fire

48

retardants,

design

industry

professions need a better understanding of manufacturing processes. Designers should seek information about specific chemicals utilized in product they are specifying.

By pushing for transparency in products

and processes, designers can have an impact on the furnishing industry.

FUTURE RESEARCH Future Research is required to truly understand how manufacturers are meeting strict fire regulations. Since some furnishing components are procured, more research is required to determine how fire retardants are used in those components. This applies to components such as fabrics and filling materials. Because of the complicated supply chains involved in manufacturing, future research may be more viable if conducted first with raw material and/or component suppliers. Upholstered furniture fabric and foam suppliers may be able to better supply information regarding specific treatments applied to products prior to their distribution to furniture manufacturers. With the pending changes in TB 117, research needs to be conducted with product suppliers and furniture manufacturers to reveal if and how processes will change. It may also be useful to study the use and application of barrier materials in furnishings, as the changes to TB 117 could increase usage of those materials.

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SUMMARY AND CONCLUSIONS In order to truly protect the health, life safety, and welfare of the public, interior designers must understand the implications of all their decisions. Designers shape interior environments but must abide by building codes and standards. It is important for interior designer to understand how furniture manufacturers are meeting these codes. Although construction methods for commercial upholstered furniture seemed similar across all study participants, more research is required to expose exactly how manufactures are meeting fire codes and which, if any, fire retardant materials are utilized. Designers must demand more information, a higher standard, and quality and safety in processes and products.

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APPENDIX A: SAMPLE QUESTIONNAIRE

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APPENDIX B: COMMONLY USED FLAME RETARDANTS

59

60

61

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63

64

(Bergman, et al., 2012)

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68

69

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(Bergman, et al., 2012)

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