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

ii

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

iii

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.

iv

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.

v

DEDICATION

This paper is dedicated to all researchers, and educators, and all

those who question ‘accepted’ practices and who demand higher

standards.

vi

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.

vii

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

viii

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

ix

ABBREVIATIONS

ASTM American Standard Testing Method

BEARHFT Bureau of Electronic and Appliance Repair, Home

CBHF California Bureau of Home Furnishings

CDC Center for Disease Control and Prevention

CPSC Consumer Product Safety Commission

DecaBDE Deca=bromodiphenyl ether

DDC=CO Dechlorane Plus

EPA Environmental Protection Agency

HBCDD Hexabromocyclododecane

HHS Department of Health and Human Services

HRMS Gas chromatography=high resolution mass spectrometry

ICC International Code Council

LEED Leadership in Energy and Environmental Design

NCIDQ National Council for Interior Design Qualification

NIST National Institute of Standards and Technology

NFPA National Fire Protection Association

OctaBDE Octa=bromodiphenyl ether

OEHHA Office and Environmental Health Hazard Assessment

OSHA Occupational Safety and Health Administration

PBB Polybrominated Biphenyl

PBDE Polybrominated diphenyl ether

PentaBDE Penta=bromodiphenyl ether

POP Persistent Organic Pollutants

TB Technical bulletin

TBB 2=Ethylhexyl ester 2,3,4,5=tetrabromobenzoate

TBBPA Tetrabromobisphenol A

TBP Tribromophenol

TBPH 1,2= Ethylhexyl 3,4,5,6=tetrabromo=

TCEP Tris (2=chloroethyl) phosphate

TCPP Tris (1=chloro=2=propyl) phosphate

TDCPP Tris (1,3=dichloro=2=propyl) phosphate

TSCA Toxic Substances Control Act

UFAC Upholstered Furniture Action Council

UNEP United Nations Environment Program

WHO World Health Organization

10

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.

11

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.

12

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.

13

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

14

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.

FIGURE 1: AMERICAN FIRE CATASTROPHES AND SUBSEQUENT BUILDING CODE

CHANGES (ARNOLD, 2005)

15

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

16

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,

17

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.

18

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

19

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=

20

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).

FIGURE 2: SELECTED HUMAN AND WILDLIFE LEVELS OF PBDES

(HEALTHCARE WITHOUT HARM, 2006 )

21

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

22

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).

FIGURE 3: PBDES IN BREAST MILK AND FAT SAMPLES AROUND THE WORLD

(SCHECTER, PAVUK, PAPKE, RYAN, BIRNBAUM, & ROSEN, 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

23

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).

24

FIGURE 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).

POST-CONSUMER USE

(PRODUCT END LIFE)

CONSUMER USE

MANFUACTURING USE

INDUSTRIAL USECHEMICAL

MANUFACTURING

FOAM

MANUFACTURING

FURNITURE

MANUFACTURING

RESIDENTIAL AND COMMERCIAL FURNISHINGS

LANDFILL INCINERATION RECYCLING

MATERIAL STREAM

CHEMICAL STREAM

OCCUPATIONAL EXPOSURE

VOLATILIZATION

AND DEPOSITION

ONTO DUST IN

HOMES -

CONSUMER

EXPOSURE

MIGRATION TO

SURFACEWATER AND

GROUNDWATER

(ENVIRONMENTAL AND

GENERAL POPULATION

EXPOSURE)

COMBUSTION

BYPRODUCT

FORMATION AND

RELEASE

(ENVIRONMENTAL AND

GENERAL POPULATION

EXPOSURE)

ADDITIONAL

OCCUPATIONAL

EXPOSURES

25

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,

26

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).

FIGURE 5: APPLICATION OF THE SOURCE TO DISEASE PARADIGM (SCHECTER, DIOXINS

AND HEALTH INCLUDING OTHER PERSISTANCE ORGANIC POLLUTANTS AND ENDOCRINE

DISRUPTORS, 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

SOURCES

(PRODUCTS)

MICRO-

ENVIRONM

ENT

(AIR, DUST)

PERSONAL

EXPOSURE

(INHALATION,

INGESTION,

DERMAL

ABSORPTION)

INTERNAL

DOSE

(SERUM BREAST

MILK)

EARLY

EFFECT

(ALTERED

HORMONE

LEVELS)

DISEASE

27

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

28

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.

FIGURE 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

29

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

30

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).

31

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

32

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.

33

FIGURE 7 FLAME RETARDANT REPLACEMENTS

(HAWTHORNE, NIELAND, & EADS, FLAME RETARDANTS AND THEIR RISKS, 2012)

34

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

35

study intended to reveal exactly how furniture manufacturers are

currently meeting fire regulations.

36

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.

37

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

38

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

39

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

40

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

41

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.

42

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.

43

TABLE 1: QUESTIONNAIRE RESPONSES

44

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.

FIGURE 8: TYPICAL UPHOLSTERED FURNITURE CONSTRUCTION DETAIL

(KRASNY, PARKER, & BABRAUSKAS, 2001)

45

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.

46

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

47

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).

48

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. With the rising concerns over the potential negative

health consequences related to fire retardants, design industry

49

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.

50

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.

51

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APPENDIX A: SAMPLE QUESTIONNAIRE

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APPENDIX B: COMMONLY USED FLAME

RETARDANTS

60

61

62

63

64

65

(Bergman, et al., 2012)

66

67

68

69

70

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(Bergman, et al., 2012)