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Lauren Ghelardini, Cory Hood, Corey Park, Jill Terner, July Tran, Lauren Westley, Yunran Zhang Spring 2015 Department of Environmental Health Sciences Columbia University Mailman School of Public Health A CRITIQUE OF COLUMBIA UNIVERSITY’S FIRE SAFETY STANDARDS FOR UPHOLSTERED FURNITURE & FURNISHINGS
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Lauren Ghelardini, Cory Hood, Corey Park, Jill Terner,

July Tran, Lauren Westley, Yunran Zhang

Spring 2015 Department of Environmental Health Sciences

Columbia University Mailman School of Public Health

A CRITIQUE OF COLUMBIA UNIVERSITY’S FIRE SAFETY

STANDARDS FOR UPHOLSTERED FURNITURE & FURNISHINGS

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Glossary

BDE Brominated Diphenyl Ether

CAL 117 California Technical Bulletin 117

CAL 117-2013 California Technical Bulletin 117-2013

CAL 133 California Technical Bulletin 133

CPSC Consumer Product Safety Commission

DfE Design for the Environment Program

DPHP Diphenyl phosphate

EPA Environmental Protection Agency

EU European Union

NFPA National Fire Protection Agency

NRDC National Resource Defense Council

OPFRs Organophosphate Flame Retardants

PBBs Polybrominated Biphenyls

PBDEs Polybrominated Diphenyl Ethers

PUF Polyurethane Foam

REACH Registration, Evaluation, Authorization, and Restriction of Chemicals

T3 Triiodothyronine

T4 Thyroxine

TSH Thyroid Stimulating Hormone

TBBA 2,3,4,5-tetrabromobenzoic acid

WHO World Health Organization

Acknowledgements

We thank Dr. Robin Whyatt and Whitney Cowell for assistance in writing section 6 (Health Effects) of

this white paper and Dr. Heather Stapleton for analyzing the indoor air samples.

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Table of Contents

1. Physical and Chemical Properties of Flame Retardants ............................................................. 6

2. History of Fire Safety Standards and Flame Retardant Use ....................................................... 6

3. New York Fire Safety Standards .............................................................................................. 11

4. Columbia University Fire Safety Standards ............................................................................. 11

5. Exposure ................................................................................................................................... 12

5.1 Prior Use Flame Retardants............................................................................................................. 13

5.1.1 Polybrominated diphenyl ethers (PBDEs) ................................................................................ 13

5.2 Current Use Flame Retardants ........................................................................................................ 14

5.2.1 Firemaster 550 .......................................................................................................................... 14

5.2.2 Non-Halogenated Organophosphate Flame Retardants (OPFRs) ............................................ 14

5.2.3 Chlorinated OPFRs ................................................................................................................... 14

6. Health Effects............................................................................................................................ 16

6.1 Prior Use Flame Retardants............................................................................................................. 16

6.1.1 PBDEs ...................................................................................................................................... 16

6.2 Current Use Flame Retardants ........................................................................................................ 17

6.2.1 Firemaster 550 .......................................................................................................................... 18

6.2.2 Non-Halogenated OPFRs ......................................................................................................... 18

6.2.3 Chlorinated OPFRs ................................................................................................................... 18

7. Indoor Air Sampling For the Current Use Flame Retardants ................................................... 19

8. Efficacy ..................................................................................................................................... 20

9. Alternatives ............................................................................................................................... 22

9.1 Alternative Chemicals ..................................................................................................................... 23

9.2 Alternative Policy & Technologies ................................................................................................. 24

9.3 Indirect Alternatives ........................................................................................................................ 24

10. Disposal................................................................................................................................... 25

11. Recommendations ................................................................................................................... 26

11.1 Recommendations for Columbia University Fire Safety .............................................................. 26

11.2 Disposal Recommendations .......................................................................................................... 26

11.3 Alternative Recommendations ...................................................................................................... 27

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Table 1. Flame retardants used in furniture and furnishings

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Table 1. Continued

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Executive Summary

An increase of fire safety regulations since the 1970s has led to expanded use of chemical flame

retardants in industrial and home furnishings. Today, as a result, humans in the U.S. are ubiquitously

exposed to such chemicals. The use of chemical flame retardants as a method to meet fire safety

regulations, such as California Technical Bulletins 117 (CAL 117) and 133 (CAL 133), can be partially

attributed to lobbying by the chemical and tobacco industries. The Columbia University Fire Safety

Policy self-subscribes to both CAL 117 and CAL 133 in order to adhere to New York City and New

York State Fire Codes.

Since the 1970s, polybrominated diphenyl ethers (PBDEs) have been the dominant class of flame

retardants used in furniture and furnishings in the U.S. However, owing to evidence of environmental

persistence, ubiquitous human exposure, and health effects, including adverse neurodevelopment and

endocrine disruption, these chemicals have been phased out of production. The major class of

replacement chemicals include halogenated (primarily bromine or chlorine) and non-halogenated

organophosphate flame retardants (OPFRs). Preliminary exposure assessment studies have documented

detectable levels of these replacements in humans and wildlife. Though research on the health effects of

these replacements is extremely limited, there is at least some animal and in vitro studies on all of the

compounds that provide evidence of carcinogenicity, endocrine disruption, atopy, and/or developmental

and reproductive toxicity. Thus it is not possible to recommend any of the replacement flame retardant

as safe substitutes for the PBDEs until further research is conducted and the data gaps are filled.

Research demonstrating that chemical flame retardants are efficacious at slowing fires and reducing fire

deaths are also extremely limited. In spite of extensive data searches, we were not able to find any

reliable studies. Although several studies conducted by flame retardant manufacturers have

demonstrated efficacy, our evaluation indicated significant problems in the study designs. Further, the

use of flame retardants has coincided with a number of other secular trends, including declining smoking

rates, increased use of smoke detectors and sprinkler systems, and improved building, fire, and electric

codes, making the efficacy of flame retardant use difficult to disentangle. Additionally, during a fire

flame retardants can increase the yield of carbon monoxide, irritant gases, and soot.

In 2013, the State of California Consumer Affairs introduced California Technical Bulletin 117-2013

(CAL 117-2013), an amendment to the dated CAL 117 statute of 1975. Importantly, the new standard is

designed to be met using methods and technologies that do not require the use of flame retardants, while

still providing fire safety.

With a growing literature supporting the adverse effects of flame retardants, limited evidence of

efficacy, and recent development of a new flammability standard, we recommend the following changes

are made at Columbia University: 1) Columbia University avoids purchasing furniture treated with

chlorinated organophosphate flame retardants that have been associated with evidence of

carcinogenicity until further research is conducted on exposure and health effects. 2) Columbia

University should continue to evaluate information that becomes available on the remaining flame

retardants currently used in furniture and furnishings as there are currently significant data gaps. 3)

Columbia University should shift away from policies such as CAL 117 that can only be met using flame

retardants, and toward alternative approaches for fire safety such as the installation of sprinklers and

furniture produced with fire barriers.

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1. Physical and Chemical Properties of Flame Retardants

For decades the foam inside sofa recliners, loveseats, and other furniture and furnishings has been

treated with flame retardants, many of which are toxic (1). Flame retardants are chemicals added to

products to delay fire ignition and prevent the spread of fire. Many products in the U.S. contain these

chemicals, including appliances and product cases, baby products, cable jackets, couches, mattresses,

plastic toys, wood, polyurethane insulation, upholstery foam, and upholstery textiles (2). Our report

focuses solely on flame retardants used in furniture and furnishings. For a list of these flame retardants,

including their abbreviation, full name, and chemical structure, please refer to Table 1 above. Table 2

below lists the major classes of flame retardants, details their current use status and summarizes their

production volume in pounds (3).

Table 2. Flame retardants by group including their current status and production volume

Phased out in US Phased out in Europe

PBDEs Yes Yes

Firemaster 550 No (10-60 million lbs produced/year) No

Non-Halogenated OPFRs No (1-540 million lbs produced/year) No

Chlorinated OPFRs No (10-100 million lbs produced/year) No

Flame retardants are classified by their chemical structure and by the presence of a halogenated

functional group (4). The majority of additive flame retardants used in furniture or furnishings are

halogenated and designed with bromine or chlorine. In addition to the presence or absence of halogens,

flame retardants are characterized as organophosphates if they contain a phosphorylated organic

backbone. Furthermore, flame retardants can be classified as either additive or reactive depending on

whether they are added to or bonded with the product. The majority of flame retardants used in

polyurethane foam are additive; as discussed in the exposure assessment below, these chemicals are

readily released from products and adhere to dust particles in the surrounding environment (5).

2. History of Fire Safety Standards and Flame Retardant Use

Flame Retardant Use is Historically Linked to Cigarette Smoking, Resultant Fire Deaths, and The

Tobacco Industry’s Reluctance to Develop Fire-Safe Cigarettes: History from the 1970s

In 1970, 37.4% of adults in the U.S. smoked cigarettes, down from 42.4% in 1965 (6). During this

period, household fires attributable to ignition of upholstered furniture from cigarettes was the leading

cause of fire-related deaths in the U.S. (7, 8). According to a 2002 investigation, approximately 1000

deaths and billions of dollars in property damages, health care, lost productivity, and fire and emergency

services are attributable to cigarette-related fires annually (9). Therefore, in addition to the continued

pressure from governmental bodies to limit advertising and increase labeling of tobacco products in the

1960s and 1970s, the tobacco industry was under intense public pressure and media scrutiny to develop

self-extinguishing or fire-safe cigarettes that would be less likely to start a fire if dropped or left

unattended around upholstered furniture (9).

Despite these findings, the tobacco industry claimed they could not create fire-safe cigarettes due to a

variety of physical and chemical challenges. In addition to research concerns, they maintained that

prototypes of self-extinguishing cigarettes tasted worse, were harder to smoke, and were less desirable to

consumers, making them an unattractive investment (10). Interestingly, several patents issued to private

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companies provide evidence that by the early 1970s, research to make a realistic, publically acceptable

cigarette was well under way (9, 11). In 1974, a bill mandating cigarettes be made to “self-extinguish”

passed through the Senate, but was killed in the House of Representatives, presumably as a testament to

the power and influence of the Tobacco Institute, a tobacco industry trade group (11). At this point in

history, the tobacco industry’s agenda shifted from fire-safe cigarettes as a way to reduce household

fires, which they saw as a detriment to their profitability, to that of reducing the flammability of

upholstered furniture and furnishings.

The tobacco industry used funding, media power, and the faces of concerned firefighters to promote the

passage of fire safety standards requiring the use of flame retardants on household materials and items.

However, the degree to which they influenced legislation on the regulation of flammable fabrics is

uncertain. In the early 1970s, concerns about the growing number of fire-related fatalities prompted the

newly formed Consumer Product Safety Commission (CPSC), a government body created to regulate

the safety of consumer products, to begin testing and regulating the flammability of clothing (12). In

November of 1972, the Federal Register stated that it was necessary to regulate the flammability of

upholstered furniture and in 1973, the CPSC took over the issue (12). During this period, methods for

testing whether a product meets flame retardant standards were developed by public and private

partnerships but ultimately the CPSC did not set federal standards (12).

Coincidentally in 1973, Polybrominated Biphenyl (PBB) flame retardants were removed from the U.S.

market after an accident in which 2,000 pounds of PBBs were inadvertently mixed with animal feed in

Michigan, subsequently exposing roughly 10,000 residents via consumption of contaminated meat, milk,

butter, cheese, and eggs. This accident had large health and economic consequences; roughly 30,000

head of livestock and 1.6 million chickens were destroyed and 90% of Michigan residents had detectable

levels of PBBs in their blood for several years following the accident (13).

1975: California Technical Bulletin 117

Following discussions of flammability standards for upholstered furniture at the federal level and the

tobacco industry’s influence on the use of flame retardant chemicals, the state of California passed

legislation in 1975 mandating flammability standards for furniture components (12). The mandatory

legislation, California Technical Bulletin 117 or CAL 117, required an “open flame” test for all

components of upholstered furniture except for the frames and fabric itself (14). There are different test

requirement for different fabrics, but for polyurethane foam, a sample pillow of cushion of at least

13”x13” is required to withstand a 12 second flame without losing more than 5% of its weight (14). This

was intended to prevent home fires caused by small open flame sources such as candles (15). While

CAL 117 does not directly require application of flame retardant chemicals, it is highly unlikely that any

component of upholstered furniture, specifically polyurethane foam would be able to pass this test

without their addition (14, 15). Additionally, CAL 117 does not require testing of external fabric, is

often the primary contributor to the high flammability of upholstered furniture (16).

Since CAL 117 is state level legislation, it only applies to furniture sold within California (14).

However, as it would be cumbersome and expensive for companies to manufacture products specifically

for one state, the majority of companies design all furniture and furnishing to meet the California

standards. This approach was also taken to avoid potential litigation from burn victims who could claim

that a fire was due to untreated foam. Over time, other states began to adopt similar fire safety

legislation that required flame retardant chemical application. A study conducted on 102 samples of

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polyurethane foam from couches purchased between 1985 and 2010 in the U.S. concluded that 85%

contained flame retardant chemicals (15). Thus, CAL 117 has essentially been the flammability standard

for the entire U.S. population for decades.

Big Tobacco Organizes Fire Marshals: History from the 1980s

To improve their credibility regarding the promotion of fire resistant furniture, the tobacco industry

sought to engage with a group that was well-respected regarding fire safety. The Tobacco Institute was

the prime tobacco industry interest group and gave millions of dollars to fire groups, in addition to

paying consultants to woo fire officials. A memo from 1984 outlines a meeting of Philip Morris

executives discussing this strategy. In 1989, the former Vice President of the Tobacco Institute, Peter

Sparber, formed and then steered the National Association of State Fire Marshals, an organization of the

top fire official from each state (16, 17). Sparber had left the Tobacco Institute to form his own lobbying

firm, but kept the Institute as a main client. This enhanced his credibility and allowed him to appear as

though he had the marshals’ and the public’s best interest at heart. The marshals thought Sparber’s work

to protect the community from fires was voluntary. However, he was actually paid $200 an hour by the

Tobacco Institute to work on projects such as a petition to include flame retardants in furniture.

These low profile, taxpayer-funded government appointees were given the star treatment by the tobacco

industry, including gifts of nice wines, hospitality suites, and free mountain bike rentals. The marshals

were also provided with talking points through media-training seminars to improve public speaking

skills. Sparber set the association’s national agenda and passed along internal documents and

information on the marshal’s work to the Tobacco Institute, which in turn relayed it to cigarette

companies. The wooing of the marshals and the influence of Big Tobacco within the association

worked; the fire marshals passionately fought for the tobacco industry’s political agenda, although they

were unaware of it (16).

California Technical Bulletin 133: Continuing into the 1990s

With the Tobacco Institute and the National Association of Fire Marshals firmly behind the increased

use of flame retardants, California developed California Technical Bulletin 133 (CAL 133) in 1992, a

second piece of fire safety legislation that mandated a “full burn” or “composite” test on upholstered

furniture in areas of public buildings and public assembly with ten or more pieces of seating furniture;

however, the standard does not extend to residential furniture (18). This composite test requires that a

square gas burner is placed on the test furniture, ignited, and burned for 80 seconds (18). A variety of

specific measurements are taken including, temperature, mass loss of furniture, concentrations of carbon

dioxide, unburned hydrocarbons, opacity of smoke, and heat release based on oxygen consumption (18).

In order to pass, certain thresholds must be met for each of these measurements. This often requires that

flame retardants are applied to the foam, fabric, and/or barrier cloth components of furniture, but their

application is not explicitly stated as necessary to meet the standard (19). Exceptions to CAL 133 are

made for rooms with automatic sprinkler systems depending on the municipality. For instance, Boston

and Ohio do not allow for any exceptions in the presence of sprinklers, while California, Massachusetts,

and Illinois do (12, 19). Even with these exceptions, CAL 133 increased the use of flame retardants

across the country by both increasing the quantity used in an individual piece of furniture and by

requiring more public and private spaces to comply with the standard.

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The Tobacco Institute Shuts Down, Leading to Fire-Safe Cigarette Legislation: 1999

In 1999, the Tobacco Institute shut down as part of a court settlement. A number of states subsequently

passed laws requiring fire-safe cigarettes, thereby further eliminating Big Tobacco’s interest in

promoting flame retardant policies. This settlement also resulted in the public release of a wealth of

internal documents, many of which have been used as evidence of the tobacco industry’s role in

lobbying for flame retardants. Since the closing of The Tobacco Institute, the chemical industry has

stepped in to sponsor the National Association of State Fire Marshals, which continues to work towards

stopping bills that restrict the use of flame retardants (16).

Chemical Industry Creates a Front Group: Citizens for Fire Safety Institute: Moving into 2007

In 2007, the flame retardant chemical industry created its own group to lobby for its interests, while

trying to maintain an innocuous and credible appearance. To achieve this, they formed the Citizens for

Fire Safety Institute, an organization that described itself as a “coalition of fire professionals, educators,

community activists, burn centers, doctors, fire departments and industry leaders, united to ensure that

our country is protected by the highest standards of fire safety.” Its website claimed that the group

worked with the international firefighter’s association, the American Burn Association, and a federal

agency. However, during a journalistic investigation, the Chicago Tribune uncovered that the group was

actually a trade association whose members solely consisted of the three largest manufacturers of flame

retardants: Albemarle, ICL Industrial Products, and Chemtura. Additionally, all of the organizations that

Citizens for Fire Safety Institute claimed to work with have stated that they, in fact, do not work

together. Moreover, the executive director of the organization previously served as a political advisor to

tobacco executives. Between 2008 and 2010, the group received $17 million in funding solely from

membership dues and that money’s interest. This was spent almost entirely on lobbying efforts in state

legislatures, which were the political battleground for legislation addressing the health effects and

ubiquity of flame retardant exposure.

This industry front group continued to use misrepresentation as their main tactic in blocking state

legislation restricting the use of flame retardants. Citizens for Fire Safety Institute paid people to serve

as witnesses at legislative hearings, either directly or through donating to groups that the witness was a

part of. This sponsorship was not disclosed to the committees. The testimonies framed anti-flame

retardant advocates as overzealous, elitist environmentalists, while the community affected by the

proposed legislation was framed to be poor, minority children who would suffer even more fire deaths

than they already disproportionately bear. A prestigious burn doctor sponsored by Citizens for Fire

Safety Institute promoted burn victims as the ‘face’ of the pro-flame retardant agenda, falsifying a story

about a baby’s death from a fire that could have been prevented with flame retardants (16).

In addition to misrepresenting the issue at legislative hearings, Citizens for Fire Safety Institute ran

media campaigns using strong fear tactics, such as a video titled “Killer Couches!” which showed a

couch on fire, ominous music in the background, and the words “Are you sitting comfortably?” These

fear tactics, fabricated emotional and ethical appeals, and a lack of disclosure of the connection between

the industry front group and the witnesses helped the industry block several proposed bills, such as the

California State Assembly’s 2009 proposal to exclude baby products from the state’s flammability

regulation and California Senate’s 2011 proposal to significantly reduce the use of flame retardants.

Since the release of the Chicago Tribune’s investigative report, chemical companies have claimed that

they have cut ties with the Citizens for Fire Safety Institute and will lobby through the American

Chemistry Council, the main lobbying group for the chemical industry (16).

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CAL 117-2013

The Chicago Tribune exposé, printed in May 2012, started the national conversation regarding the

efficacy and safety of flame retardant chemicals (16). In June 2012, the Governor of California, Edmund

Brown, made a public statement calling for a reassessment of flammability standards by the State’s

agencies (20) He mentioned the growing body of evidence suggesting flame retardants are associated

with several adverse health effects in vulnerable population such as children, women of reproductive

age, and firefighters (20). Activist groups such as the San Francisco Firefighters Cancer Prevention

Foundation were extremely vocal about their concern for health effects and organized around

amendments to CAL 117 and 133 (21). Additionally, later in 2013, HBO aired a documentary entitled,

“Toxic Hot Seat” in which the corruption, efficacy concerns, and adverse health effects associated with

flame retardants are depicted for a mass audience (22).

As a result of grassroots organization and advocacy by firefighters in California, Technical Bulletin 117-

2013 (CAL 117-2013) was passed in January 2013 and came into effect as of January 2014 (23). This

standard requires a “smolder test” for fabrics and is novel in that compliance is feasible without flame

retardant chemicals (19, 24). CAL 117-2013 consists of three tests used to evaluate the cigarette

ignition resistance of upholstery cover fabrics, barrier materials, and resilient filling materials used in the

manufacture of upholstered furniture (24). In each test, the test material is placed directly on a

fiberglass board on which a lit cigarette is then allowed to “smolder”. The material is considered to pass

the “smolder test” if a cigarette burns its full length and the material ceases to smolder (24).

Interestingly, while this test better models a real-life fire than the previous test, which solely tested the

flammability of the polyurethane foam, it still does not necessarily test for the interaction between

various furniture components, including both the foam and the upholstery cover fabrics (23).

The passage of CAL 117-2013 is a clear indication of a shift in the view of fire safety and the role that

flame retardants play. CAL 117-2013 has the potential to improve fire safety without relying on these

chemicals and has encouraged manufacturers to switch to less flammable fabrics (25). Instead of

injecting chemicals into polyurethane foam, manufacturers can now line furniture with a fire shield, or

use non-flammable materials (26). Public building occupancies can also either choose to comply with

CAL 117-2013, rather than CAL 117, if the space is fully protected by an automatic sprinkler system

(19).

While this shift away from flame retardants may result in health benefits while also assuring fire safety,

it is not easy to determine whether or not furniture is treated with flame retardant chemicals as labeling

is not required. Here, we provide a set of guidelines to help a consumer determine whether or not

furniture or furnishings contain flame retardants:

1. Furniture that does not contain polyurethane foam usually does not contain flame retardant

chemicals.

2. Furniture containing polyurethane foam purchased or reupholstered in California after 1975 or

furniture with a specific label stating compliance with TB 117 likely does contain flame retardants.

3. Furniture purchased prior to 2000 outside of California has about a 50% chance of containing flame

retardant chemicals (27). A list of companies that currently produce flame retardant-free furniture

can be found in the Appendix.

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3. New York Fire Safety Standards

New York State and New York City Fire Safety Legislation

The New York State Legislation Uniform Codes contain statewide information regarding fire codes in

both residential and other buildings (28). These codes do not apply to New York City, which has its own

Fire Code. The Columbia University facilities are bound by the 2008 Fire Code, which classifies all

university and college facilities and occupancy spaces as Class B business establishments (29).

Information pertinent to the Columbia University Fire Safety Policy can be found in chapters 8 and 27

of the New York City Fire Code, as well as National Fire Protection Association (NFPA) standards 701

and 267 (29). Stated in the codified rules of the city under Title 3, Chapter 8, Section 805, decorations in

college and university facilities must be flame resistant in accordance with the tests specified in NFPA

701, which has similar requirements to CAL 117 (30). Chapter 27, Section 2706, of the New York City

Fire Code refers to standards for Hazardous Materials in non-production chemical laboratories,

including curtains and laser curtains in Columbia University’s laboratories (30).

In parallel with a voluntary phase-out by the chemical industry, in 2004 New York State passed an

environmental law that codified the prohibition of production and use of two of the three major

commercial PBDE formulations, pentaBDE and octaBDE (31). Twelve other states and the District of

Columbia currently ban both pentaBDE and octaBDE as well (31). Additionally, beginning in December

2013, New York State banned the sale of any products intended for children under 3 years old that

contain the flame retardant Tris (1,3-dichloro-2-propyl) phosphate (TDCPP), also referred to as

Chlorinated Tris (31). Regulations regarding chemicals in children’s clothing date back to the 1970s

when concerns over children’s vulnerability to these chemicals came to light (12). As of 2015, decaBDE

has not been banned in New York State or New York City (28). However, in 2004 New York State

formed a Task Force on Flame Retardant Safety to assess the cost, effectiveness, and adverse health

effects of decaBDE and any viable alternatives (28). Simultaneously, the U.S. Environmental Protection

Agency (EPA) announced in 2009 that all major U.S. based producers and importers of decaBDE must

phase out production, importation, and sale by the end of 2012 as a result of increased evidence for

adverse health effects (28). From the final state report published in March 2013, New York State agreed

with EPA’s recommended voluntary phase-out of decaBDE (28).

4. Columbia University Fire Safety Standards

In 2009, the Columbia University Fire Safety Policy was updated to reflect amendments to the New

York City Fire Code, including sprinkler exemptions consistent with CAL 133 requirements (29).

Currently, the policy must meet the Fire Safety codes of the city and follow CAL 117 and CAL 133 for

certain spaces and situations, which are detailed below.

Rooms and spaces are split into three categories (29):

Any offices, public areas, and places of public assembly, including classrooms that are protected by

an automatic sprinkler system must meet the flame resistant requirements of CAL 117. However,

any of these spaces that are not protected by a sprinkler system must meet CAL 133.

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Laboratory space must comply with New York City Fire Codes or be exempted through an affidavit

as described in the New York City Fire Code Chapter 8.

Regardless of the presence of an automatic sprinkler system, all dormitory and hospital occupancies

must meet the CAL 133 requirements for upholstered furniture, curtains, drapes, and carpets.

Mattresses have specific city code testing requirements based on national guidelines outlined by

NFPA 267.

5. Exposure

In this section we discuss 12 flame retardants that are commonly used in furniture and furnishings. We

refer to each by commonly used abbreviations, however, full names can be found in Table 1 at the

beginning of this document. PentaBDE and decaBDE are brominated flame retardants that were

voluntarily phased out of production in 2004 and 2013, respectively. TCEP, V6, TCPP and TDCPP are

chlorinated organophosphate flame retardants. TBPP and MPP Mix are two non-halogenated

organophosphate flame retardants. Firemaster 550, which has been widely used following the phase out

of PBDEs, is a commercial mixture containing TBB, TBPH and TPP. TPP is a non-halogenated

organophosphate that is also a primary component of MPP Mix and TBPP. All flame retardants included

in this section are additive and commonly used in polyurethane foams. Over time they are released from

the material and enter the indoor environment. Depending on their persistence, some chemicals can exist

for a long period of time and continue to accumulate in the environment. All the flame retardants

described in this section are detected in the indoor environment, primarily in dust, but also occasionally

in air. Air sampling data are limited and not available for many of the newer flame retardants. Since

flame retardants are primarily present in indoor dust, incidental ingestion of dust is a major route of

exposure. Inhalation may be a second exposure route for some flame retardants, while dermal absorption

does not appear to occur in most cases. Table 3 below summarizes the major chemical and exposure

properties for each flame retardant examined here, including: environmental persistence,

bioaccumulation, biological half-life, sources and routes of exposure.

Table 3. Properties of flame retardants used in furniture and furnishings

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5.1 Prior Use Flame Retardants

5.1.1 Polybrominated diphenyl ethers (PBDEs) There are three types of commercial PBDE products, pentaBDE, octaBDE, and decaBDE each of which

contains a mixture of PBDE congeners (32). Here, we focus on penta and decaBDEs as these are the

primary brominated flame retardants found in furniture and furnishings. The relative proportions by

weight of various PBDE congeners in the commercial pentaBDE mix are as follows: BDE 99 (43%),

BDE 47 (28%), BDE 100 (8%), BDE 153 (6%), and BDE 154 (4%) (32). PentaBDE is typically used at

levels approximately 3% to 6% of the weight of the polyurethane foam. DecaBDE is comprised solely

of BDE 209, however, it is known to degrade to lower congeners in the environment (33).

PBDEs persist in human tissue from months to years, depending on the congener, with higher

brominated molecules typically having shorter half-lives (34). Nationwide studies of PBDEs

demonstrate nearly ubiquitous exposure in the U.S., with levels detected in human serum, breast milk

and adipose tissue (See Figure 1). Although it was voluntarily phased out in 2004, due to its high

persistence, pentaBDE remains a ubiquitous environmental pollutant and studies suggest its component,

BDE 47, contributes the most to human exposure. In a 2011 study based in California that measured

pentaBDE and decaBDE concentrations in furniture found that 50% and 100% of house dust samples

contained pentaBDE and decaBDE, respectively (35). The main routes of exposure to pentaBDE for

adults are incidental ingestion of dust (66%), inhalation (17%) and consumption of food, specifically

fatty fish or other animal products with high fat contents (17%). Estimates suggest children engage in

approximately 18 hand-to-mouth behaviors every day, providing a direct route of exposure to indoor

dust, which helps to explain their intake of approximately 100-200 mg of dust per day, compared to the

20-50 mg estimated to be ingested by adults (36). Accordingly, children and adults are estimated to

ingest approximately 16 mg and 3.25 mg of pentaBDE per day, respectively (37). Historically, decaBDE

has been produced at a higher level than pentaBDE, however, pentaBDE is more persistent and

bioaccumulative in the environment and therefore is typically detected at higher concentrations.

Figure 1. Total PBDE concentrations in biologic samples (ng/g lipid) as a function of the year and

sampling location (adapted from: (38)).

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5.2 Current Use Flame Retardants

5.2.1 Firemaster 550

Firemaster 550 is comprised of at least 14 phosphate compounds of various concentrations (39)

including the brominated flame retardants TBB and TBPH, which are found at an approximate

proportion of 4:1 by weight (15). Firemaster 550 is commonly used in polyurethane foam as a substitute

for pentaBDE. In previous studies, both TBB and TBPH were detectable in air samples, marine mammal

tissue, and wastewater sewage sludge, which demonstrates that Firemaster is released into the

environment. In a study conducted by Stapleton et al (15), Firemaster 550 was the second most detected

flame retardant in polyurethane foam samples following the phase-out of pentaBDE in 2005. Likewise,

among indoor dust samples collected from 20 houses in Boston, Massachusetts, TBB and TBPH were

detected in 94% (median=322 ng/g) and 100% of samples (median=234 ng/g), respectively (40).

Once absorbed, TBB is biotransformed in the liver to 2,3,4,5-tetrabromobenzoic acid (TBBA), which is

eliminated in urine and has been proposed as a potential biomarker of Firemaster 550 exposure (41). A

study examining concentrations of TBBA in urine samples and concentrations of TBB and TBPH in

dust samples and hand wipes demonstrated a high correlation, providing evidence that TBBA reflects

exposure to TBB and TBPH in house dust (41). A study performed in paired mothers (n=22) and

children (n=26) residing in the U.S. detected TBBA in 27% of mother and 70% of child urine samples,

indicating children have high exposure to TBB and likely Firemaster 550 (42).

5.2.2 Non-Halogenated Organophosphate Flame Retardants (OPFRs)

A study examining TPP, a component of Firemaster 550, TBPP and MPP Mix, in 53 houses in North

Carolina detected TPP in 100% of dust samples. (43). Humans are exposed to TPP via inhalation and

ingestion of contaminated dust and food. Diphenyl phosphate (DPHP), a metabolite of TPP, is a useful

biomarker when measured in urine and was detected in 90.6% of urine samples collected from

participants in the North Carolina cohort. Interestingly, the researchers also found that the levels of

DPHP in urine samples among women were almost two times higher than among men (43), suggesting

this population might be particularly susceptible to heightened exposure. In a second study examining

urine samples collected from paired mothers (n=22) and children (n=26), DPHP was detected in 100%

of maternal urine samples and 92% of child urine samples (42).

TBPP consists of mixture of non-halogenated organophosphate flame retardants. About 40% of the

TBPP mixture consists of TPP. TBPP has low volatility based on its chemical features and preliminary

studies estimate an average half-life of one day depending on the mixture (44).

MPP Mix is a mixture of organophosphate flame retardants that do not contain halogens. Like

Firemaster 550, TPP is a primary component of MPP Mix (see above for more information on TPP).

Exposure data on MPP Mix are limited, however, a Japanese study found detectable levels in 100% of

dust samples collected from elementary schools (n=18) and households (n=10) with a median level of

6800 ng/g (45).

5.2.3 Chlorinated OPFRs

TDCPP is a chlorinated phosphate ester. It is currently used as a flame retardant in many products

including polyurethane foam. While PBDE was the most prevalent flame retardant before its voluntary

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phase-out in 2004, TDCPP is currently the dominant flame retardant used in products and has been

documented in office furniture at levels up to 5% by weight (37). In a study examining flame retardants

in residential couches purchased from 1985 to 2010, Stapleton et al. (40) found that among couches

purchased before 2005, PBDEs were detected in 39% and TDCPP was detected in 24%. For couches

purchased after 2005, TDCPP was detected in 52%, while Firemaster 550 was detected in 18%. These

results suggests that TDCPP is one of the most prevalent flame retardants and was in use prior to the

phase out of the PBDEs.

In a study examining TDCPP in house dust (n=50), researchers found detectable levels in 96% of

samples, with a geometric mean concentration of 1890 ng/g. Likewise, TDCPP has been detected in air

samples collected from residences (46). Ingestion and inhalation are two common routes of exposure to

TDCPP and animal studies indicate it is also rapidly absorbed dermally (47). Once absorbed TDCPP is

metabolized to BDCPP and excreted in urine (47). A study (48) examining the association between

urinary BDCPP and TDCPP levels in office dust found TDCPP was detected in 99% of the dust samples

(median = 4.43 μg/g) and BDCPP was detected in 100% of urine samples (median = 408 pg/g)

collected from adult office workers (n=29).

TCEP is commonly used in furniture foam, polyvinyl chloride, electronics and various building

materials and it has been detected in indoor air with concentrations ranging from 1.4 - 15 ng/m3 (49). A

Japanese study that measured TCEP in dust detected TCEP in 96% of samples with median levels of

500 ng/g and 2700 ng/g for samples from elementary schools and households, respectively (50).

TCPP is a non-volatile flame retardant often used in flexible polyurethane foam and some building

materials. TCPP shares a similar structure with TCEP and it is often used as a replacement for TCEP

(37). In a study of indoor dust, concentrations of TCPP were found to be much higher than

concentrations of TCEP suggesting an increase in the use of TCPP (49). A Swedish study examining

indoor air concentrations found TCPP levels ranged from 91-850 ng/m3 in 3 samples (49). Similarly, a

study completed in ten work environments in Stockholm, Sweden, found TCPP, TCEP and TDCPP in

all air and dust samples and concluded these chemicals accounted for 75% of the total mean

concentration of phosphate ester flame retardants. Among these, TCPP was found to have the highest

concentration in office settings whereas TCEP was found at high levels in homes, daycares and offices

(50).

V6 is mainly used in polyurethane foam for products in the automotive (50-70%) and furniture (25-

50%) industries (51). The chemical structure of V6 is very similar to TCEP and it often contains TCEP

as an impurity. According to a European Union (EU) Risk Assessment report, TCEP is found at levels

of 4.5-7.5% in V6 products on average (52). Baby products produced using V6 may contain

considerable amount of TCEP as a component (51). In a study conducted in 2009, researchers detected

V6 in 70% of dust samples collected from 29 houses in Boston, Massachusetts. In these samples, the

concentration of V6 ranged from <5 to 1110 ng/g with a median value of 12.5 ng/g. TCEP and V6 were

found to be significantly correlated in dust samples, suggesting V6 is a major source of TCEP. The

median concentration for TCEP was 50.2 ng/g, which was higher than that of V6 (51). One plausible

reason to explain this result is that TCEP may have greater migration away from polyurethane foam due

to its higher vapor pressure compared to V6 (51).

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6. Health Effects

6.1 Prior Use Flame Retardants

6.1.1 PBDEs Research on the health effects of PBDEs has increased exponentially in the past decade (53). Mounting

evidence indicates the greatest concerns relate to developmental neurotoxicity. As such, we provide an

overview of major neurodevelopmental findings and briefly review effects observed for other health

endpoints. When sufficient data were not available for human subjects, we present results from studies

conducted in laboratory animals.

Recently, the neurodevelopmental and neurobehavioral effects of PBDE exposure were systematically

reviewed by Roth et al. (54). Of the studies conducted to date, Roth et al. classified two as high quality

(55, 56) and four as moderate quality (57-60). In conjunction with a recent study by Chen et al. (61) not

included in the review, these studies collectively provide evidence that prenatal (maternal blood, cord

blood) or early childhood (breast milk, child blood) PBDE exposure is associated with reduced fine

motor skills, impaired cognition (verbal skills, perceptual reasoning, IQ) and disrupted behavior

(attention, anxiety, hyperactivity and impulsivity) among children. The results from numerous animal

models support these findings and are summarized in a review article by Costa et al. (62). For example,

exposure to PBDEs in mice and rats has been associated with reduced habituation to environmental

surroundings, which is considered to be a correlate of hyperactive behavior in humans. Similarly, studies

examining prenatal exposure in mice have observed hyperactivity in the offspring of exposed, but not

control, mice. In addition to behavioral alterations, postnatal exposure to PBDEs has been associated

with cognitive impairments related to learning, memory and visual discrimination in multiple murine

models.

Alteration of thyroid hormone homeostasis has been investigated as the mechanism underlying the

observed associations between PBDE exposure and disrupted neurodevelopment. Thyroid hormones

play a critical role in brain development during gestation and early life (63). Conversely, results from

research conducted in laboratory animals have consistently demonstrated a relationship between prenatal

exposure to PBDEs with decreased serum thyroxine (T4) and increased thyroid stimulating hormone

(TSH) levels (64). Several prospective birth cohort studies have examined associations between prenatal

PBDE exposure and disrupted thyroid hormone homeostasis, however results are limited and have been

inconsistent. In the largest study conducted to date (n=380), cord blood PBDE levels were associated

with decreased levels of total triiodothyronine (T3) and T4, but increased free T3 and T4. Smaller

studies have detected a mix of results including decreased T4 (65), increased T4 (66), decreased TSH

(67), and increased TSH with no change in T4 (68).

Likewise, results from studies examining thyroid hormone disruption in adults have been inconsistent.

In an occupational study of male workers, exposure to decaBDE via inhalation was associated with an

increased prevalence of hypothyroidism (69) and in an observational study conducted among 110 men

consuming fatty fish caught from the Baltic Sea, researchers detected a weak negative correlation

between BDE 47 (a component of pentaBDE) and plasma TSH levels (70). Similarly, among a cohort of

healthy adult male sport fish consumers (n=308) in the U.S., higher PBDE serum concentrations were

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associated with altered free and bound T4, T3 and TSH levels. These researchers also detected a positive

association between BDE 47 with altered testosterone levels (71).

Few other studies have examined the relationship between PBDEs and altered sex hormone levels in

humans. One existing study conducted cross sectional analyses among a cohort of adult men (n=24)

recruited from a fertility clinic in the U.S., and found PBDE (BDEs 47, 99, 100) levels measured in

house dust were associated with a number of hormonal endpoints, including lower free androgen index

(significant at the 0.05 level), luteinizing hormone, follicle stimulating hormone, and higher inhibin B,

sex hormone binding globulin, and free T4 (72).

Limited studies have demonstrated effects between PBDEs and adverse reproductive, and

developmental outcomes. This literature includes findings from one epidemiologic study examining

PBDE exposure and fecundability. Among a cohort of 202 women in California, Harley, et al. found

blood PBDE (BDEs 47, 99, 100, 153) concentrations were positively associated with self-reported

duration to pregnancy. In a separate study examining adult men, serum PBDE levels have been

associated with decreased sperm motility and concentration (73, 74).

Several studies have examined the relationship between PBDE exposure and adverse birth outcomes,

including preterm birth, low birth weight, and still birth, however existing studies suffer from several

methodological limitations (i.e. small sample size, poor confounder control) and have conflicting and

inconclusive results (75-78). One prospective study found breast milk PBDE levels were significantly

higher among infants with cryptorchidism (n=95), a male reproductive tract abnormality, compared to

healthy boys (n=185) (79).

As a result of these findings, pentaBDE and decaBDE were voluntarily phased out of production in the

U.S. in 2004 and 2013, respectively. In addition, some states have legally banned their use and they have

been listed as persistent organic pollutants by the Stockholm convention, which aims to identify and

reduce the release of pollutants that are resistant to environmental breakdown and have known human

health and ecotoxic effects (80).

6.2 Current Use Flame Retardants

As discussed previously, three main classes of flame retardants are currently being used on furniture and

furnishings in the U.S. These include Firemaster 550, the non-halogenated organophosphates and the

chlorinated organophosphates. In spite of widespread human exposures to these compounds, evaluation

of their health effects is extremely limited. In sharp contrast to the extensive epidemiologic research on

the health effects of PBDEs, there have only been two, small epidemiologic studies conducted in men

that have evaluated the endocrine disrupting effects associated with exposures to chlorinated

organophosphates. In vitro analyses have also been conducted to evaluate risk of endocrine disrupting

potential and a number of the compounds have been tested in zebrafish as well as other fish models. The

zebrafish model is an established relatively high-throughput model for evaluating developmental and

neurotoxic effects (81) but its relevance to human health has not been fully characterized. Risk of

carcinogenicity and mutagenicity has been assessed in experimental bioassays for some of the

chlorinated flame retardants. Based on results of this body of literature, a recent review concluded that

due to adverse health effects, none of the flame retardants currently used on furniture and furnishings in

the U.S. are recommended as suitable replacements for the PBDEs (82). The only compound that was

recommended was MMP Mix but it is generally contaminated by TPP, which has been shown to be an

endocrine disruptor, teratogen and developmental and reproductive toxicant (81, 83). However, caution

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should be used when interpreting this recommendation given that data on the health effects of the

current use flame retardants are limited as described below.

6.2.1 Firemaster 550

Firemaster 550 has been marketed as a replacement for PBDEs and is currently the second most

commonly detected flame retardant in polyurethane foam in the U.S. (84, 85). Relatively little is known

about its potential for toxicity (81) and to date, no epidemiological studies have been conducted on the

health effects of Firemaster 550. A recent analysis found the mixture contains TPP, TPP isomers and

two brominated compounds, TBB and TBPH (86). The latter are high production chemicals and have

been shown to be genotoxic in fish models (reviewed in (87)). In vitro studies suggest TBB and TBPH

are endocrine disruptors that interact with estrogen and androgen receptors and alter hormone synthesis

(88). A recent exploratory study in rats found that exposure to Firemaster 550 during gestation and

lactation increased serum T4 levels in the dams and resulted in advanced female puberty, weight gain in

both sexes, changes consistent with metabolic syndrome and altered exploratory behaviors among the

offspring (86). Results from a medaka fish model also suggest TBB and TBPH impair fecundity (84).

TPP may be a teratogen based on preliminary data using a zebrafish model and is also a potential

endocrine disruptor and developmental toxicant (81, 82, 89).

6.2.2 Non-Halogenated OPFRs Little information is available on the toxicity of MPP Mix. TPP is a primary component of MPP Mix

and as discussed below is associated with potential toxicities.

6.2.3 Chlorinated OPFRs Four chlorinated organophosphates are used as flame retardants in furniture and furnishing of which

TDCPP is the most studied. To date, only two epidemiological studies have examined the relationship

between chlorinated organophosphate flame retardants and health endpoints in humans. Meeker et al.

(83) conducted a cross-sectional analysis to examine the association between TDCPP and TPP analyzed

in household dust with thyroid hormone levels and semen quality parameters. Men between the ages of

18 and 54 years were recruited from a U.S. infertility clinic either because they or their partner were

infertile. Of those enrolled, dust from 50 households was analyzed for TDCPP and TPP. Blood and

semen were analyzed for hormones (serum luteinizing hormone, follicle-stimulating hormones,

estradiol, prolactin, and thyroid hormones) and semen quality (concentration, mobility, morphology),

respectively. The authors detected the following significant associations: 1) TDCPP was associated with

decreased free T4 and increased prolactin and, 2) TPP was associated with decrease in sperm

concentration. Based on these findings, the authors conclude chlorinated organophosphate flame

retardants measured in house dust may be associated with altered hormone levels and sperm

concentrations.

An observational study based in Japan examined associations between 11 organophosphate flame

retardants measured in house dust (n=182) with asthma and allergies among the residents. In adjusted

analyses, the researchers found significant associations between TCPP and TDCPP with an increased

odds of atopic dermatitis (90).

In animal studies, researchers have shown TDCPP to be carcinogenic and mutagenic in rats, leading to

its classification as a carcinogen by the CPSC and the World Health Organization (WHO) (82, 87).

Based on dermal exposure, the CPSC estimated a lifetime cancer risk from use of TDCPP in furniture

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foam of three cancers per 10,000 individuals (3 X 10-4) (87). TDCPP has also been shown to be a

teratogen, endocrine disruptor and neurotoxicant in zebrafish models and in in vitro models (81, 82, 91).

TCPP and TCEP are carcinogens in experimental bioassays. TCPP alters neurodifferentiation in

zebrafish models and TCEP has been shown to be neurotoxic to rats and mice and to induce adverse

reproductive effects in rats (reviewed in (82). Fewer data are available on V6 and may be less toxic,

however there are some indications that it may act as an endocrine disruptor. Additionally the V6 mix

contains TPP which has evidence of toxicity as described above.

In conclusion, the extensive data gaps that exist for most of the current-use flame retardants make

assessment of their potential health effects extremely challenging. Given the evidence of carcinogenicity

for a number of the chlorinated flame retardants (TDCPP, TCPP and TCEP) it is prudent to avoidance

use of these compounds pending additional research to more fully characterize the dose-response

relationships. All of the remaining current-use flame retardants have at least some evidence of toxicity.

Thus is it not possible at this time to identify any that can currently be considered safe until additional

research is undertaken to fill the substantial data gaps.

7. Indoor Air Sampling For the Current Use Flame Retardants

As there has been extremely limited prior air sampling for the current-use flame retardants, we

conducted indoor air samples over two weeks in the conference room at the Department of

Environmental Health Sciences (EHS) at Columbia University Mailman School of Public Health. The

EHS Department was recently renovated and the furniture was

purchased after the phase out of PBDEs. The current furniture

meets the CAL 117 standard given that the room contains a

sprinkler system. The air sampling was conducted at 1.5 liters

per minute over two weeks (336 hours with a total of 30.2

cubic meters of air drawn through the samplers). We collected

fine particulates <2.5 µm on a quartz microfiber filter and semi-

volatile vapors and aerosols on polyurethane foam (PUF) plug

backup. The samplers were prepared at Southwest Research

Institute and were precleaned prior to use in Soxhlet extractors,

first for 24 hours with high-purity acetone, next for 48 hours

with high-purity hexane, again for 24 hours with acetone, and

then dried with purified nitrogen. At the conclusion of the two

weeks, the samplers were frozen and shipped, along with a field

blank, on dry ice to the laboratory of Dr. Heather Stapleton at

Duke University for analysis. We included a field blank as the

flame retardants are ubiquitous and we anticipated the

possibility of contamination within the sampling train. The

filters and PUF plug were Soxhlet extracted using 50-50 hexane:acetone for 16 hours. Isotopically

labeled standards were spiked in the samples prior to extraction. Extracts were concentrated to about 1.0

ml and analyzed directly by gas chromatography-mass spectrometry (GS/MS). Compounds measured

included three chlorinated organophosphates (TDCPP, TCEP, TCPP) and TPP since it is a constituent of

the other types of current-use flame retardants. We extracted the ng/extract of each compound detected

in the field blanks from the ng/extract of each compound detected from the two air samples prior to

calculating final concentrations. Results are presented in Table 4 below.

Figure 2. Air sampling set up

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As can be seen, the chlorinated organophosphate flame retardants were detected in the field blank

indicating that there was contamination at some point along the sampling train. However, concentration

were lower than it the two air samples. Results from the two air samples indicate that the chlorinated

organophosphate flame retardants were used on the furniture in this room and are able to volatilize into

the surrounding air. We did not detect PBDEs or Firemaster 550 in our samples, however, we cannot

conclude the absence of these chemicals based on our findings, only that they were not present in the air.

TCPP was detected at much higher concentrations that the other two chlorinated organophosphates

indicating that it was the main flame retardant used as volatilities are reasonably comparable: all are

semi-volatile; vapor pressure of TCEP > TCPP > TDCPP. As discussed above, both TDCPP and TCEP

are carcinogens in experimental bioassays and are associated with other potential adverse health effects.

No studies have assessed the carcinogenicity of TCPP but the EU has concluded that it should be

considered a potential carcinogen given that its structure is similar to TDCPP and TCEP. TCPP also has

other potential adverse health effects. Data do not exist to conduct any risk assessments for these

compounds via inhalation exposure.

8. Efficacy

Fires are complex and vary enormously depending on a number of factors that either increase or

decrease the intensity of the fire. Flame retardants are designed to delay or inhibit combustion, a four

step process that includes: preheating, volatilization/decomposition, combustion, and propagation or

spread of the fire (92). Flame retardants, depending on the specific mode of action, can act at any step

in the process. For example, halogenated flame retardants capture free radicals, which are produced

during the combustion phase and necessary for fire propagation (93) and organophosphate flame

retardants increase char formation during burning, thus creating a physical barrier between the ignition

source and the material, which slows the burning process (13). Flammability standards vary in design

and by the method for testing a material. A material may perform differently given variable conditions,

such as the source, duration, or location of a flame or heat source (94). As previously reviewed, some

standards, such as CAL 117, require that individual components, such as flexible polyurethane foam and

other filling materials in furniture withstand a small open flame (95). Other standards require testing of

the entire manufactured article. Given the variability and complexity of fires, a single standard that

mandates testing the performance of an uncovered material when exposed to a small, open flame may

not reflect the overall flammability of the product (96).

The implementation of different flammability standards has led to the increased use of flame retardants

over the last 30 years. However, it is uncertain whether these standards, such as CAL 117, are effective

at preventing fires (94). Flame retardant manufacturers continually point to a large, government funded

study to back their claim that flame retardants increase the duration of time to escape fires by 15-fold,

thereby serving as an effective method for reducing residential fires and saving lives. Yet, the lead

Table 4. Flame retardants detected in the EHS conference room (ng/m3

)

Sample 1 Sample 2

TDCPP 0.60 1.10

TCEP 4.06 2.13

TCPP 348.5 490.4

TPP <MDL <MDL

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author of the study, Vytenis Babrauskas, states that industry officials grossly distort the research

findings (16). In fact, the often cited study did not examine CAL 117, which industry was defending.

Rather, the study surveyed materials containing flame retardant formulations at significantly higher

concentrations than would be required to meet CAL 117 (94). Moreover, the study tested fully

furnished rooms in which numerous combustibles were incinerated (97), conditions that are drastically

different than those used to test the CAL 117 standard (94).

Earlier work by Babrauskas (1983) at the National Bureau of Standards showed that subsequent to

ignition, there was no significant difference in important fire hazard indicators between untreated

furniture and CAL 117-compliant furniture treated with flame retardants (98). A small flame source was

able to ignite both CAL 117-compliant furniture and non-compliant furniture, and, once ignited, there

was no difference in fire hazards for either type (99). Taken together, this research suggests that CAL

117 is an ineffective standard to reduce small scale furniture ignitions, and thus is not an effective

approach for increasing fire safety (94, 100). Furthermore, the use of flame retardants has been shown to

increase toxic fire effluents during combustion. During a fire, carbon monoxide is converted to carbon

dioxide through a reaction with hydroxyl radicals. Halogenated flame retardants prevent this reaction,

increasing the yield of carbon monoxide (101). Flame retardants also inhibit the conversion of other

hydrocarbons to carbon dioxide and water, significantly increasing smoke yield. Thus, in addition to the

health effects of chronic exposure to these flame retardants reviewed in Section 6, flame retardants

increase fire effluents, such as carbon monoxide, soot, and irritant gases, which collectively contribute to

fire deaths and fire-related injuries by hindering the ability to escape (94, 102).

A primary piece of evidence cited by the flame retardant industry consists of data from a Swedish

document that have been incorrectly extrapolated (16). The 50 page report, written by a Swedish federal

board, examined the number of total electrical fires in Sweden by analyzing the cause of fires in Western

Stockholm in 1995 and 1996. Despite study conclusions that electrical fires were less common than

previously thought, the chemical industry focused on the fact that one-fourth of the fires were caused by

televisions (16). Industry researchers extrapolated these results to calculate Europe’s total number of

television fires per million sets annually. They concluded the results were much higher than rates found

in the U.S. (16). The logical explanation, in their opinion, was that this was due to the application of

flame retardants to U.S. televisions.

The industry’s process of calculating and comparing television fires per million sets was fundamentally

flawed and disregarded the basic principle that broad conclusions should not be drawn from small or

unrepresentative samples (94). Furthermore, this model—known as the Simonson model—only

considered television fires due to internal ignition (94). By only accounting for a single type of ignition,

the number of fires was reduced from 13 per million sets to 5 per million sets. In contrast, the model did

not restrict television fires that occurred in Europe to internal ignition fires. Ultimately, the model used

dissimilar data sources, which skewed the results unreasonably low and high for the U.S. and Europe,

respectively.

Alternative fire prevention methods, such as smoldering “fire-safe” cigarettes, can prevent fires and

reduce the unnecessary addition of hazardous chemicals to residential products. Although the use of

flame retardants has increased over the years, rates of smoking have decreased. There has been a 60%

decrease in fire deaths in the U.S. since 1980, which parallels the decrease in cigarette smoking (94).

The importance of this secular trend is highlighted by Shaw et al. (2010), who state, “the reduction of

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smoking, through a combination of education, taxation, and location restriction policies has proven the

single most effective fire safety strategy” (87). Furthermore, other fire safety mechanisms, such as

improved building, fire and electrical codes, smoke detectors, and sprinkler systems have contributed to

the decrease in U.S. fire deaths. Collectively, these trends suggest that the decrease in fire deaths and

office fires, as noted in the graph below, can be largely attributed to the decrease in smoking and

improved fire safety mechanisms--rather than the increased use of flame retardants.

Figure 3. Office property fires by year, 1980-2011 (Adapted from: (103))

9. Alternatives

Mounting concerns regarding the widespread use and associated health effects of flame retardants have

fueled the creation and implementation of flame retardant alternatives. The U.S. government and the

European Commission have each invested in initiatives to create and identify flame retardant

alternatives. Under the jurisdiction of the EPA, the Design for the Environment (DfE) program helps

identify alternatives for multiple chemicals that perform as well or better than current chemicals, and are

safer for human health and the environment. Owing to the reduced stringency of CAL 117-2013, many

of these alternatives enable companies to pass flammability tests without the use of chemicals. As part

of this program, assessments of alternatives have been conducted. Results provide evidence that

encourage chemical companies to switch to safer methods for meeting current flammability standards

(104). The DfE has performed assessments analyzing alternatives for decaBDE as well as flame

retardants used in flexible polyurethane foam (105, 106).

The European Commission has also invested in a similar program that focuses on identifying and

analyzing substitution options for specific brominated flame retardants. ENFIRO assesses the production

and application, environmental safety, and the life cycle of potential alternative options (107). This

project uses an approach that provides an environment-compatible substitution that is viable for use by

the industry, and can be used for other substitution studies performed under Registration, Evaluation,

Authorization, and Restriction of Chemicals (REACH), the EU’s regulation focused on chemical

identification and safety (107). Using a top-down approach, the U.S. and Europe look to begin the

process of identification and implementation of alternatives to substitute harmful flame retardant

products that are currently in extensive distribution and production.

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9.1 Alternative Chemicals

While health and environmental considerations are important when selecting an alternative chemical

flame retardant, foam quality should also be considered. For this reason, the most environmentally

sound options may not be the most practical. Balancing the most practical with the healthiest option is

part of this complex decision making process.

In addition to balancing the practical aspects with the environmental aspects of alternative flame

retardants, the mode of exposure for the general population is also important. Gaseous flame retardants

generally do not exist outside of the manufacturing arena, therefore, exposures to liquid and solid forms

of flame retardants are of primary concern to the general public (108). Inhalation is the greatest concern,

because liquid chemicals can be inhaled if vaporized, and solids may break down into small particulate

that can be inspired. Inhalation of the dust that contains this small particulate is one of the main routes of

exposure, as simply sitting on a piece of furniture can release it into the air. Additionally, dermal

exposure can result from handling materials treated with flame retardant chemicals. Ingestion can occur

if the chemical, or its byproducts, makes its way into the water supply or bioaccumulates in consumable

aquatic organisms. Additionally, children can ingest the dust containing flame retardant particulate, as

they have high hand to mouth contact.

The EPA has identified two positive flame retardant attributes, high biodegradability and low

bioaccumulation/bioavailability potential, that inform the chemical’s life cycle (108). Emphasizing

products treated with chemicals that adhere to these attributes will lead to potentially safer and greener

choices. The use of readily biodegradable chemicals in flame retardants increases their environmental

friendliness as these chemicals dissolve more quickly in treatment plants and are thus less pervasive in

the environment. However, it is also important to consider potential breakdown products as these may

be more harmful than the parent compounds.

Similar to biodegradation byproducts, effluent caused by combustion of flame retardant chemicals is a

concern. If furniture burns in a fire, or if products using chemical flame retardants are destroyed in an

incinerator, potentially harmful byproducts can be released into the environment. Consequently, when

selecting furnishings for residential or commercial use, consideration of not just the primary flame

retardant chemicals used, but the potential for these compounds to release noxious compounds into the

environment when they are burned is prudent.

The second positive attribute for flame retardants is low bioaccumulation potential and low

bioavailability. This dual attribute can be met by using chemicals that both have large molecular size

and high molecular weight. Large molecules are less likely to be passively absorbed by aquatic animals,

and heavy molecules tend to be less volatile. When possible, it is preferable to select chemicals that have

a low bioconcentration factor. However, these data are not always available, therefore environmentally

conscious companies typically rely on an octanol-water partition coefficient. Chemicals with a

coefficient of greater than eight have a lower, and more desirable, bioaccumulation potential (96).

Additionally, flame retardants that are incorporated into the product at the beginning of the

manufacturing process are generally more tightly bound to the foam substrate and consequently are less

likely to leach into the environment where they can bioaccumulate in animals and be inhaled or ingested

by humans. Further, additives that are mixed in the manufacturing of a product have greater potential to

Page 25: White Paper Final

24

bioaccumulate, as they are not as tightly bound to the foam. Therefore, selecting products that do not use

additives, or use fewer of them is another way to mitigate hazards to environmental and human health

(96).

9.2 Alternative Policy & Technologies

Cover fabrics and barrier technologies can reduce fire propagation by preventing the ignition source

from reaching the inner foam of a piece of furniture (108). Consequently, the risk of releasing harmful

combustion byproducts is reduced. As discussed previously, the intent of CAL 117-2013 is to “produce

upholstered furniture which is safer from the hazards associated with smoldering ignition”. Importantly,

the standard is intended to be met using cover fabrics and barrier methods that do not include flame

retardants (109). Three types of barrier materials that could be used to meet CAL117-2013 are outlined

below.

One current approach to creating flame retardant barrier materials makes use of nanomaterials (110).

Nanomaterials are inherently non-flammable fabrics that have flame retardants directly incorporated into

the textiles themselves, as opposed to being sprayed on to the surface. Nanoclays are another burgeoning

approach to flame retardants. By incorporating naturally-occurring montmorillonite clay into fabrics,

manufacturers can significantly slow the breakdown of material and the release of combustible

molecules.

Graphite impregnated foam is another alternative technology (96). It is self-extinguishing and highly

resistant to combustion. Although it is a newer technology and caters primarily to niche markets, such as

airplane seating, it can be used to design comfortable and attractive seating arrangements. This is in

comparison to furniture designs that simply exclude the use of filling or fabric altogether, which would

be uncomfortable.

Surface treatments of furniture are a third alternative, however they may not be cost effective as

treatments may wash off or degrade over time, giving rise to concerns regarding environmental

contamination and dermal exposure (110). Additionally, the process of achieving uniform distribution of

the treatment and then allowing it to dry is time consuming and expensive.

Finally, the Natural Resources Defense Council (NRDC) has compiled a fact sheet identifying major

furniture purveyors that meet the CAL117-2013 standard without using flame retardant chemicals (1). In

a survey of major furniture stores, the NRDC asked whether each store had plans to manufacture

furniture that was CAL117-2013 compliant without using chemicals, as well as how the store planned

on making these furniture items identifiable to customers. While not all of the companies responded to

the survey request, the results indicate that at least six of the major retailers contacted are moving

towards removing flame retardants from their products while maintaining crucial fire safety standards.

9.3 Indirect Alternatives Finally, architectural changes such as increased sprinkler coverage can serve to reduce the need for

flame retardants in furniture. Enforcing policies that prevent the use of dangerous products, such as

halogen desk lamps, in offices can also mitigate the need to use flame retardant chemicals. Though

inherently flame-resistant alternatives are available, they are typically prohibitively expensive. Research

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25

continues to move forward to develop safe flame retardants for use in furniture and furnishings that are

also economically feasible for consumer products.

10. Disposal

As discussed, flame retardants enter the environment as a result of their additive nature, are resistant to

breakdown and are easily transported throughout the environment. For example, research has

documented increasing levels in the Arctic environment, despite the limited production of these

chemicals in close proximity to Arctic regions. Flame retardants can also be released into the

environment when the manufactured products are burned or discarded in areas of sunlight exposure

(111). When these materials are burned or discarded in dumps and exposed to sunlight, the plastics melt

and release the residue they were manufactured with (111). Due to the long lifespan of these products, it

is likely that these chemicals will continue to pervade food chains and the global environment. As tons

of flame retardant containing materials have been dumped in landfills, and continue to be dumped to this

day, the need for safer disposal of such materials is a priority.

Currently, there are three conventional methods for disposing of flame retardant-containing furniture:

(1) landfilling, (2) reuse & recycling, and (3) incineration (87). Landfilling is the most common form of

disposal, as it is the cheapest and easiest option of the three. Even though complex landfill linings exist

to prevent leaching of material from landfills, the lifespan of these linings is limited. Furthermore, as

flame retardants are not categorized as ‘hazardous waste’, they are not prioritized for safety by landfill

regulations (112). This also means that air monitoring for detection of flame retardant chemicals is not

required for landfills. Owing to this dearth of regulation, little effort has been put into the development

of safe disposal technologies for materials with flame retardants. Until flame retardants are federally

classified as hazardous waste, emphasis on reducing production is the best option for reducing

environmental contamination and human exposure.

With the increased option of buying furniture without flame retardants, reuse and recycling has become

the second most common form of conventional disposal methods. However, as many families who can

afford to replace their furniture donate their old items for second-hand use, the burden of this harmful

exposure falls disproportionately on economically disadvantaged populations, which is an

environmental justice concern (112). These patterns likely contribute to higher body burns for these

populations, whom are predisposed to living near landfills and thus obtaining higher exposures from

landfill leaching. As mentioned by Jason Schneider (112), reuse and recycling is not the proper method

to reduce exposure to and circulation of flame retardants, especially as furniture and industry

manufacturers claim that each owner of a piece of furniture will likely hold onto that piece for about ten

to fifteen years.

Although proper disposal options are limited, the most promising technology for responsible disposal of

furniture with flame retardant chemicals is incineration and combustion. However, it is important that

these incineration methods be carefully controlled to prevent the release of any associated and harmful

by-products, including dioxins and dibenzofurans (112). Further development of these emerging

methods is critical to the process of reducing worldwide exposure to flame retardants.

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26

11. Recommendations

11.1 Recommendations for Columbia University Fire Safety

First and foremost we recommend that Columbia University avoids purchasing furniture treated with

chlorinated organophosphate flame retardants that have been associated with evidence of

carcinogenicity until further research is conducted to assess the dose-response relationships. Second,

Columbia should continue to evaluate information that becomes available on the remaining flame

retardants currently used in furniture and furnishings as there are currently significant data gaps and we

are unable to determine whether any can be considered safe, given the limited data available and

preliminary evidence of toxicity on all of the compounds. As more adverse health effects of flame

retardants become apparent and alternative methods such as sprinklers and barriers are considered more

efficacious, Columbia University should continue to shift policies away from requiring flame retardant

applications on upholstered furniture. Below are plausible options to decrease flame retardant exposures

for Columbia University staff, faculty, and students:

1. If New York City adjusts the Fire Code to meet CAL 117-2013 for assembly and dormitory

occupancies, Columbia University can adjust the Fire Safety Policy to mirror these changes and

allow for less-stringent flame retardant application. Additionally, any space that is protected by an

automatic sprinkler system can then be required to meet the CAL 117-2013 standards rather than

CAL 117 or CAL 133.

2. There is a current exemption in the New York City Fire Code and Columbia University Fire Safety

Code for offices, public areas, and areas of public assembly to comply with CAL 117 requirements

instead of CAL 133 requirements if protected by an automatic sprinkler system (29). Therefore, we

recommend increasing sprinkler system installation in these spaces wherever feasible. While

expensive, increasing the amount of public areas with automatic sprinkler systems will allow for

legal exemption within the current policy framework and does not rely on larger New York City Fire

Code amendments (29). Furthermore, retrofitting older buildings to include automatic sprinkler

systems would make Columbia University eligible to receive insurance premium credits, thus

making retrofitting financially appealing.

3. Likewise, we recommend conducting a cost-benefit analysis to determine the true cost of university

fires, the true cost of retrofitting university buildings, and the true cost of alternative barrier methods.

This information will help determine the most cost-effective method for reducing fires and flame

retardant exposure.

4. Lastly, we recommend that the University advocate for financial support from both the local and

state governments to assist in updating the furniture and furnishings used across the Columbia

University campuses.

11.2 Disposal Recommendations

It is important to recognize that any furniture Columbia University believes should be replaced with

flame retardant free furniture must be disposed of safely and responsibly. However, as flame retardants

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are not classified as hazardous material by the government, there are no existing protocols for disposal

of these chemicals. The majority of flame retardant-containing furniture is discarded into landfills,

where the chemicals can leach out into the environment, contaminate food chains, and further expose

human populations.

The safest method for disposal of halogenated flame retardants is likely through use of polychlorinated

biphenyl (PCB) incinerators. PCBs were widely used in applications requiring flame retardant materials

until the 1970s. These compounds were banned in 1978 under the Toxic Substances Control Act due to

their toxicity, persistence, and accumulation in the environment (113). As a result of this regulation,

specific disposal methods, such as high-heat incinerators, are required for disposal of materials made

with PCBs (113). These incinerators must reach very high temperatures and have complex filters to

ensure that toxic effluents are not released from this process. As flame retardants, such as PBDEs, have

similar chemical structures to PCBs, it is reasonable to assume that these incinerators are the safest

method for disposal of other halogenated flame retardants. As of October 2011, there are seven PCB

incinerators in the country, although none are located in New York or the surrounding states (114).

11.3 Alternative Recommendations

Under CAL117-2013, furniture companies can use alternative technologies to meet flame resistance

requirements. These technologies have been implemented, or are going to be implemented, by multiple

furniture companies. The NRDC performed a survey in 2014 to determine the extent of flame retardant-

free furniture distribution by major furniture companies (1). This survey found there are eight major

furniture companies that sell furniture without flame retardant additives, although the number of

companies continues to grow. The companies identified by the NRDC include: The Futon Shop, Crate &

Barrel, La-Z-Boy, Williams-Sonoma, IKEA, and Interline. These companies and an additional two

companies, Ethan Allen and Wal-Mart, have also made a commitment to remove added flame retardants

from their furniture. However, this survey did not mention which alternatives these companies have

decided to implement.

Table 5. Furniture manufacturers that currently produce flame retardant free furniture

California Other states

§ Cisco Home (www.Ciscohome.net)

§ Eco-Terric (www.ecoterric.com)

§ EcoBalanza (www.greenerlifestyles.com

§ Ekla Home (www.eklahome.com)

§ Furnature (www.furnature.com)

§ Green Sofas (www.greensodas.com)

§ Viesso (www.viesso.com)

§ The Futon Shop (www.thefutonshop.com)

§ LEE Industries (www.leeindustries.com)

§ Corinthian (www.corinthianfurn.com)

§ Drexel Heritage (www.drexelheritage.com)

§ EcoSelect (www.ecoselectfurniture.com)

§ Endicott Home (www.condosofa.com)

§ LEE Industries (www.leeindustries.com)

As previously discussed there are currently three general types of alternatives that can be used to meet

fire safety standards under CAL117-2013, including barrier methods, graphite impregnated foam, and

surface treatments (115). Although regulation has allowed for the use of these alternatives, health and

environmental hazards associated with these alternatives have yet to be fully addressed and identified.

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For example, one type of barrier method includes use of nanoclays, such as montmorillonite clay (110).

Although it has been shown to be an effective flame retardant, there are concerns that the small size of

these nanoclays could result in adverse health effects. One study concluded that the toxicity from

nanoclays appears to be minimal, however, more research is needed to fully understand their impact on

human and environmental health (110). Additionally, this study mentions nanoclays are less toxic than

surface treatments, which are costly, ineffective, and can leach into the environment (110, 115).

Furthermore, although graphite impregnated foam has been described as a good alternative to the use of

flame retardant chemicals, it has only been used in niche markets, such as airplane seating (115). As a

result, it may be difficult to apply this technology to the much more expansive residential and

commercial furniture industries.

Although increased use of alternative technologies are an important step away from the use of flame

retardant additives, data gaps regarding the efficacy and hazards of these alternatives is critical.

Furthermore, we recommend Columbia University makes an effort to further understand which

alternative technologies furniture companies are using to avoid chemical flame retardants. This

information is critical to informing which companies are the safest to purchase from.

Although flame retardants have been proven ineffective in preventing furniture fires and have been

linked to serious adverse health effects, they have been used in furniture for decades and continue to be

used. Therefore the U.S. population is ubiquitously exposed to measurable amounts of flame retardant

chemicals in their daily lives. California Technical Bulletin 117, and later California Technical Bulletin

133, encourage the use of a large volume of flame retardants in furniture and have become a precedent

for other states. New York City and New York State have fire resistant standards in line with the

National Fire Protection Association guidelines yet Columbia University has adopted the stricter

California Technical Bulletins. Columbia University’s strict adherence to these bulletins is endangering

the health of the students, faculty, and staff who work and live in these locations, while not providing

adequate fire protection as compensation. The above recommendations aim to mitigate some of the

potential adverse health effects associated with flame retardant exposure and should be seriously

considered by Columbia University.

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29

CA

L 1

17

(A-P

art

II)

A 1

3”x

13”

pil

low

or

cush

ion e

xpose

d t

o a

1.5

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ame

from

a B

unse

n b

urn

er f

or

12 s

econds.

To p

ass

the

sam

ple

must

not

lose

more

than

5%

in w

eight.

Note

that

shre

dded

poly

ure

than

e fo

ams

(pil

low

s or

cush

ions)

can

be

flam

e re

tard

ant

foam

.

CA

L 1

33

A

squar

e gas

burn

er i

s pla

ced o

n t

he

test

furn

iture

, ig

nit

ed, an

d b

urn

ed f

or

80 s

econds.

Consi

der

ed a

full

burn

tes

t

(com

posi

te t

est)

. T

emper

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ass

loss

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the

furn

iture

, co

nce

ntr

atio

ns

of

carb

on d

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ide,

unburn

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carb

ons,

opac

ity o

f sm

oke,

and h

eat

rele

ase

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ed o

n o

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on a

re t

aken

. S

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ard i

s in

tended

to c

over

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c

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mbly

sp

aces

wit

h m

ore

than

10 p

iece

s of

upho

lste

red f

urn

iture

for

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CA

L 1

17-

2013

Sm

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d

cigar

ette

. T

hre

e te

sts:

1)

Cover

Fab

ric

Tes

t, 2

) B

arri

er M

ater

ials

Tes

t, 3

) R

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Fil

ling M

ater

ials

Tes

t. C

rite

ria

to p

ass:

1)

Conti

nues

to s

mold

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fter

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inute

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of

more

than

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r tr

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o a

n o

pen

fla

me,

2)

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nues

to

smold

er a

fter

45 m

inute

s or

char

of

more

than

2”

or

tran

siti

on t

o a

n o

pen

fla

me,

3)

Conti

nues

to s

mold

er o

r tr

ansi

tions

to

open

fla

me

or

subst

rate

has

more

than

20%

mas

s lo

ss. N

ote

: st

andar

d i

s in

tended

to b

e an

alt

ernat

ive

to C

AL

117.

NY

C S

ec 8

05

-

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Tes

t 1 o

r T

est

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rate

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n N

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01. A

ppli

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tions

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roup A

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mon a

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Gro

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nd B

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es;

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din

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r in

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spac

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s a

publi

c gat

her

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lace

.

NF

PA

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1)

Pea

k h

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rele

ase

must

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ed 2

50kW

, ex

cept

if r

oom

is

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y s

pri

nkle

red, 2)

Tota

l en

erg

y r

elea

sed i

n t

he

firs

t 5

min

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s of

the

test

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l not

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J, e

xce

pt

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mbli

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es f

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and t

hen

expose

d t

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ame

for

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(11

” lo

ng f

lam

e fo

r 2 m

inute

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r th

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scal

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mal

l sc

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lam

e m

ax i

s

2 s

econds,

char

len

gth

les

s th

an 3

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o d

rip b

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all

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ed.

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ge

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e: a

fter

fla

me

max

is

2 s

econds,

char

len

gth

les

s th

an

10”,

no d

rip b

urn

all

ow

ed. S

mal

l sc

ale

and l

arge

scal

e der

ivat

ions.

Page 31: White Paper Final

30

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