Final Technical Report - Defra, UK - Science...
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GR241/Defra/2010 1 of 115 November 2010
Defra Contract No: SPMT09_011
Fire Retardant Technologies: safe products with optimised
environmental hazard and risk performance
Final Technical Report
For the attention of the Project Steering Group
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Fire Retardant Technologies: safe products with
optimised hazard and risk environmental performance
Final Technical Report
Authors:
Professor Gary Stevens GnoSys
Professor Baljinder Kandola University of Bolton
Mr Nicholas Morley Oakdene Hollins
GnoSys Report No: GR241
Date: 3 June 2010
GnoSys UK Ltd, University of Surrey, Guildford, Surrey, GU2 7XH
tel: (+) 1483 689599, fax: (+) 1483 9555, web: www.gnosysuk.com
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Summary
This project was commissioned by Defra as part of the Sustainable Consumption and Products programme
with the aim to review the available technologies for achieving fire retardant properties in key product groups, and to determine best practice in terms of achieving appropriate safety standards with minimal
environmental impact.
The objectives were to:
1. Provide a summary of the legislative landscape (including UK, EU and US developments, and covering both fire safety requirements and restrictions on substances used).
2. Provide a UK and EU market analysis to provide an insight into the key technologies currently
used in different products in the UK and EU and emerging trends.
3. Undertake a review of latest scientific knowledge and risk assessment conclusions of the
hazardous nature of fire retardants.
4. Undertake a review of alternative approaches to fire retardancy, including reactive technologies and physical barriers / use of naturally fire retardant materials, together with an indication of
relative costs of the different approaches.
5. Provide a recommendation, for each key product group, of the fire retardancy approach with the
best performance in terms of environmental impact. This would be accompanied by an assessment of the level to which this optimum approach is already employed by industry and, if
applicable, the ease with which it could be taken up by the mass market and associated costs.
Case studies which demonstrate that the recommended approach is achievable will be included where possible.
6. In the light of the study findings, review whether the latest criteria set under the EU Ecolabel for
(a) Textiles and (b) Bed Mattresses are fit for purpose and achievable by UK companies, and recommend overarching principles for how criteria should be set on fire retardancy in future
development of standards for these and for other product groups.
The study focused on the following consumer products:
1. Products covered by the Furniture and Furnishings (Fire) (Safety) Regulations 1988: "items which contain upholstery: beds, headboards, mattresses, sofa-beds, nursery furniture, garden furniture
which can be used indoors, furniture in new caravans, scatter cushions, seat pads and pillows and
loose and stretch covers for furniture".
2. Clothing textiles – nightwear, personal protective equipment and any other relevant categories.
3. Electronic and electrical equipment: specifically including televisions and computers (both
personal or office computers and portable computers including laptops, and notebook.
The study considered both consumer products and commercial products (for example, furnishings for public use areas which may be subject to more stringent fire protection standards).
All methods of achieving fire retardancy in products, including additive, reactive, barrier and other
relevant technologies or design solutions were included. Where appropriate, brominated compounds have been considered alongside mineral and organophosphate based substances.
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The study was focused on the specific UK situation in terms of fire safety legislation but it has also
attempted to take account of European and US legislative and technology developments and market
trends, to determine leading technologies and best practice in fire retardancy.
This report presents an overview of the study and its essential conclusions and recommendations with a
view to guiding UK policy making on EU Ecolabels and green public procurement. This report is
supplemented by 4 Annexes with more detailed information on the following topics:
1. Legislative Landscape
2. Review of the Fire Retardant Hazard and Risk Assessment
3. Alternative Fire Retardant technologies
4. Ecolabel Review and Awareness Study
The context for the recommendations made here is the existing EU Ecolabel scheme criteria examined
with respect to a framework for FR technology environmental performance assessment which contains an
hierarchical approach to the assessment of best environmentally performing FR technologies. This
approach is based on the premise that the avoidance of FR chemicals is to be preferred through either the
use of alternative intrinsically fire retardant materials or through product design to achieve the fire
retardancy required. This is consistent with the use of the precautionary principle applied to an assessment
of potential human and environmental exposure hazards associated with FR chemicals. The most general
approach would therefore seek to minimise human exposure and environmental impact.
The FR technology hierarchy adopted is assumed in each case to achieve the required product fire
retardancy in order to maintain and even improve fire safety standards.
Although subject to life cycle considerations, which are not explicitly treated in this study, we may
generally derive a prioritisation in order of increasing chemical safety based on green chemistry
principles:
Use of inherently fire retardant materials
Design of products
Use of chemical fire retardants
Conclusions
Legislative Landscape
Fire Safety
Most of the original 12 EU Member States have legislation in place defining fire safety standards for
bedding, mattresses and seats. Documentary evidence has not been found of regulation in the newer
Member States and it is unclear if the European Parliament will introduce legislation for the products
considered in this report.
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On comparing legislation and regulation in European member states it is clear that the UK has robust
furniture fire safety regulations and test methods in place. The UK Department of Business, Innovation
and Skills (BIS) is currently reviewing this position for the domestic area only and have recently carried
out a consultation on the Regulations and a reappraisal of the effectiveness of the Regulations including
the need for the Crib 5 test. This will be used to inform decisions on the future of these Regulations. In
contrast, most other European countries, with some niche exceptions, rely upon the General Product
Safety Directive (GPSD).
In UK the regulation is applicable to domestic furniture, where a furniture/seat should pass the cigarette
and match tests; upholstery, filling materials, loose filling and covers should also pass different
flammability tests. For non-domestic environments, in UK there is Fire Safety Regulatory Reform,
according to which the furniture, filling and cover materials should pass the flammability tests (usually
cigarette/ match test), but the criteria might differ based on the application area. Some member states
(Finland, France, Norway, Sweden, Spain, Portugal) have adopted the cigarette and match test for
domestic furniture, while Germany, Italy etc have regulations for furniture in public places only. The non-
domestic furniture in some EU member states only has requirements for cigarette/match tests. The US
regulations, however, require the testing of the furniture products or mock-up and not the components.
The UK also has robust nightwear safety regulations and test methods in place, which The Netherlands
has adopted. Some other European countries seek to prohibit highly flammable nightwear and related
textiles but others rely on the GPSD.
Regarding the fire safety of electronic products, the UK, along with other member states in Europe rely on
the GPSD and industry voluntary measures.
The GPSD acts as a safety net to prevent the placing on the European market of dangerous products
within the scope of the directive, and particularly,
a. where there are no specific safety regulations in place covering those products;
b. where those products do not comply with national safety regulations; or
c. which, even if they do comply with national safety regulations, are nevertheless
considered to be dangerous.
The need for further attention to fire safety in the GPSD has been acknowledged in a report from the
European Commission to the European Parliament and Council on the implementation of the GPSD.
Chemical Safety
The current primary regulation for all chemical safety in Europe, including fire retardants, is achieved
through two instruments which regulate and control the use of chemicals:
1. REACH (Registration, Evaluation, Authorisation and Restriction of CHemicals) regulation (Regulation (EC) No 1907/2006), and
CLP (Regulation on classification, labelling and packaging of substances and mixtures) (Regulation
(EC) No 1272/2008).CLP is hazard based and it is directly applicable to industry; it is legally binding
across all member states. It uses a system of warnings and hazards phrases to define intrinsic risks, based on the UN GHS definitions, which then trigger risk assessment under REACH.
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The risk assessment covers human health, physical and environmental hazards, over the full life cycle of a
product, and registrants must propose risk management measures to ensure the product‟s safe use.
Whilst not central to this report, a secondary instrument for chemical safety in Europe is the Water Framework Directive (WFD). Out of the 33 substances included in the WFD some will be monitored or
reviewed for identification as potentially hazardous substances, while others were identified as hazardous
substances to be phased out in 20 years. OctaBDE and decaBDE are listed among the substances to be
monitored, while pentaBDE is the only brominated flame retardant listed as a hazardous substance. No other brominated flame retardant is listed.
For electronic products the RoHS Directive (the Restriction of the use of certain Hazardous Substances in
electrical and electronic equipment) bans the placing on the EU market of new electrical and electronic equipment containing more than agreed levels of lead, cadmium, mercury, hexavalent chromium,
polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) fire retardants. The RoHS
directive prohibits the two PBDEs (pentaBDE and octaBDE).” From July 2008 decaBDE was also banned from use in electronics and electrical applications.
In Europe the primary concern in respect of decaBDE has been human health neurotoxicity and for the
environment it is the degradation to lower PBDE congeners that meet the PBT/vPvB (Persistence,
Bioaccumulation and Toxicity/ very Persistent very Bioaccumulative) criteria. A definitive decision on its risk assessment has yet to be taken and industry has been asked to perform further studies under pre-
REACH EC Regulations. However, in parallel, decaBDE came under the scrutiny of the Consumer
Product Safety Commission (CPSC) and the Environmental Protection Agency (EPA) in the US. The US EPA has listed decaBDE for risk reassessment under the IRIS programme. However, on the 16 December
2009, the EPA announced that the three leading suppliers of decaBDE to the US had agreed to a voluntary
withdrawal of decaBDE to take place over a 3 year period.
At the time of producing this report the Defra Advisory Committee on Hazardous Substances has posted advice on their website (23 September 2010) at:
http://www.defra.gov.uk/environment/quality/chemicals/achs/documents/achs-decaBDE-opinion-
100923.pdf. .
This concludes with advice to regulators that deca-BDE has the potential to undergo environmental degradation to Substances of Very High Concern (SVHCs). The next step
1 is for UK Government bodies
to discuss how to progress a risk management options analysis, and a preliminary discussion will take place later in November 2010. Depending on the findings of this analysis, there may be a need to prepare
an Annex XV dossier under REACH in due course, but this would be unlikely to happen until sometime
during 2011.
Ecolabels and Green Public Procurement
Risk phrases (regulatory hazard labelling phrases) are used in many national and international eco-
labelling schemes. Risk phrases were originally developed for as-manufactured chemicals and take no
account of exposure and thus risk to human health and the environment through the use of these chemicals in consumer products.
1 Steve Dungey – private communication, 1 November 2010
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The EU Ecolabel scheme follows the convention of other schemes, particularly the German Blue Angel
and the Nordic Swan. Due to the lack of risk assessments on individual chemicals Ecolabels generally use
the precautionary approach when defining criteria. Risk phrases have therefore continued to be used when defining chemical criteria for additives used in a variety of products. Risk phrases are defined in EU
Directive 67/548 in regard to classification, packaging and labelling of dangerous substances and are
applicable to all chemicals which represent a risk for health or for the environment.
The current EU Ecolabel contains exclusions for “additive” FRs in clothing and textiles where only reactive fire retardants are allowed plus restriction on certain risk phrases. In electronic equipment there is
exclusion of polybrominated biphenyls and polybrominated diphenylethers and low to medium molecular
weight chloroparaffins. In mattresses only reactive FRs are allowed and there are restrictions on certain risk phrases.
In December 2008 a discussion paper entitled “The path to sustainable use of chemicals in products: The
European Ecolabel as a signpost” was published by The European Environmental Bureau (EEB) and The European Consumers‟ Organisation (BEUC) with contributions by The Oeko Institute. This discussion
paper recommends that risk phrases should continue to be used in the Ecolabel scheme and also
harmonised with the Global Harmonised System of Classification and Labelling of Chemicals (GHS).
In 2005 the European Commission published a communication outlining the need for EU Member States to implement National Action Plans (NAP) for developing Green Procurement Policies (GPP). These
NAPs are non-legally binding but do allow Member States to raise awareness of greener procurement of
sustainable products.
The EU has developed GPP guidelines for the benefit of purchasing officials and companies wishing to
tender for contracts. Of the 10 product groups that have been established, office IT equipment and textiles
products are relevant to the current study and include statements regarding fire retardants. In all cases if
the product has obtained the EU Ecolabel then it will automatically comply with the procurement policy. Other so-called Type 1 Ecolabels are also acceptable.
Any criteria that form the basis for Ecolabel awards or which support Green Public Procurement would be
advised to align their criteria on chemical safety with that of the new CLP definitions of risk phrases and hazard statements. Consideration should also be given on the handling of chemical bans within the
decisions taken under the operation of REACH in the future. However, some care is required in handling
policy situations that may develop over the next 2 to 5 years as REACH becomes established.
Chemical Classification and Risk Assessment
European chemical risk phrases are used in EU Ecolabel criteria for FRs. These were originally defined in
Council Directive 67/548/EEC of 27 June 1967 on provisions relating to the classification, packaging and
labelling of dangerous substances. This has been progressively amended and is now in its 31st amendment
with current lists of risk phrases. Some older Ecolabel documents use these risk phrases.
The current new approach to classification is Regulation (EC) 1272/2008 on classification, labelling and
packaging of substances and mixtures (CLP) which entered into force on the 20 January 2009 and will
replace Directive 67/548/EEC (substances) and Directive 1999/45/EC (preparations). The most current version is available as Regulation (EC) No 790/2009 - of 10 August 2009 - amending Regulation (EC) No
1272/2008. More recent Ecolabel documents use the new chemical classification. In practice the so called
“risk phrases” are actually “hazard phrases”. It is these phrases that are used in Ecolabel criteria related to potentially harmful effects on the environmental and human health arising from exposure to fire retardants
and other chemicals. Under CLP, the EU is moving to replace the risk phrases by hazard phrases and
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Ecolabel criteria will need to follow suit. Annex VII of the regulations provides a conversion table from
R-phrase to H-statement.
Only 12 out of more than 400 known chemical FRs have undergone a full European risk assessment that is publicly available (although several more have been assessed by the UK, and many more will have been
assessed by Member States under the former new chemicals legislation). Of these only 6 have a
harmonised classification for intrinsic hazard in accordance with the CLP Regulation. Only 4 of the 30
alternatives to deca-DBE identified in international studies have a harmonised classification and only 2 of those appear in the European ESIS database. Although all FR chemicals should be classified by the
manufacturers and suppliers, public access to the data is not straightforward as we have found in
compiling data for this report (see Table 2 of Appendix 1). In many cases, we have been unable to find public data and in others we have had to apply in writing to the supplier for a copy of the MSDS.
Furthermore, although the MSDS may contain specific toxicity and carcinogenicity data, they do not
always contain the required R- and S-phrases and where they do, they do not always agree from one source to another (see for example 2,4,6 Tribromophenol in Table A2). In the context of Ecolabels, it is
unreasonable to assume that the person/ team compiling the data for the label should interpret the raw data
and devise the R-phrases for themselves. Ideally this should come from published EU harmonised
sources.
However, substances may not be classified either because the substance does not meet the criteria or there
are insufficient data to reach a conclusion. So, the absence of a chemical classification does not mean that
the chemical is safe, it may indicate that the chemical has not been assessed or is in the process of being assessed. In addition, CLP will define a new set of classifications (for January 2011), which will need to
be applied to all new and existing chemicals.
Are Current EU Ecolabel Criteria Fit For Purpose?
To answer this question we address some generic issues and the position of each product group considered
here in regard to the current EU Ecolabel criteria and those that might be considered in the future.
Use of Halogenated FRs
There is a drive from some retailers to replace chlorinated FRs (see Annexe 3), but environmental concerns about these compounds are not as great as those for brominated FRs. For example, some
of the chlorinated phosphorus FRs used in foams are not subject to adverse risk phrases - TCPP is
an example. Generally the non-chlorinated FRs will be more expensive, and there is uncertainty
about their FR effectiveness across different polymer types. In many cases these compounds also are not classified by the suppliers as hazardous, and since this may be based on limited datasets it
is uncertain if they would offer a better environmental performance. Until this is achieved under
the new CLP regulations, it would be perverse to exclude a compound like TCPP by an over-restrictive Ecolabel criteria centred on excluding all halogen containing and additive FRs,
especially when no risks are identified for the environment or consumers by EU risk assessments.
Blanket bans by chemical moiety or reaction mechanism
A blanket banning of specific product categories, such as brominated or halogenated compounds,
is neither favoured by most FR manufacturers, nor by some of the product manufacturers.
However there is widespread acceptance that brominated compounds would likely not be acceptable in high-end environmentally-conscious products. There is also some movement to
remove halogenated FRs and replace them with non-halogenated FRs particularly in polyurethane
foam, although success to date is mainly in automotive applications, where ignition resistance
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requirements are less demanding. However, this move to improve the environmental performance
may be perverse because some chlorinated FRs satisfy the R-phrase criteria and potential
substitutes may be excluded solely because they are additive chemical FR technologies. In other cases the substitute compounds may not have a chemical classification (e.g. for lack of data) and
their environmental performance cannot be assessed for Ecolabel purposes.
Hence whilst a potential banning of all halogenated compounds from Ecolabel textile products
appears technically feasible, this is not supported by a consideration of their risk phrases. Such a
banning on chemical class alone is also not supported by the bulk of the organisations consulted
during this work.
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Use of a White List
The adoption of a white list similar to that adopted by Oeko-tex is generally not favoured. The use
of risk phrases was felt to be more flexible. However restriction to the FR white list used by
Oeko-tex was not believed to cause any particular cost issues, since many of the widely used FRs
were on the current list.
Textiles for Clothing and Furnishings
Design and inherent FR materials approaches to fire retardancy are possible for textile products, and there are successful examples in each product category. However they lead to the restriction
of choice for the consumer in some way, usually limiting the choice of covering or filling
materials, or may produce an inferior less durable product in the case of personal protective equipment. This may be acceptable to a degree, for example in sleepwear, as long as a single
material choice (e.g. in this case polyester) is acceptable to the consumer. In other cases it may be
unacceptable, such as the inability to use certain fabrics with conventional polyurethane foams,
even those containing better environmentally performing non-chlorinated phosphorus FRs. Costs would increase in all cases, sometimes substantially so.
Sleepwear and Personal Protective Equipment
With PPE, and, to a degree, in sleepwear it may be acceptable to use an inherent FR material as
long as a single material choice is acceptable to the consumer (e.g. Kevlar for PPE and polyester
for sleepwear). The use of modified acrylic/ cotton mixes should be investigated to increase the
range of materials available.
Appropriate review of the formaldehyde emission requirements for non-skin contact textiles
would make the Ecolabel more achievable for some PPE applications and allow the reactive
phosphonium based FRs to continue to be used while improvements are made to reduce the potential for formaldehyde release.
Interior Furnishings including Foam and Mattresses
Inherent FR approaches are possible for many textiles, for example the use of modified acrylic/cotton blends or polyester in coverings, but they may be seen as limited within the current
vast range of materials and constructions currently available. So these approaches should be used
when the additional cost reasonably permits it.
The potential use of interliners as a design alternative to eliminate chemical FR use may be of
limited use in gaining environmental improvement since it is believed that most interliners in the
UK are made of cotton, which would require treatment with FRs. An inherently FR synthetic
material might be used, but clarification is required as to whether or not thermoplastic liners such as polyester would be allowable. Inherently FR materials such as aramid would be possible, but
would cost approximately ten times more. So while technical alternatives do exist and are good
environmental performers (in risk phrase terms), their costs and market constraints may be prohibitive at this point in time.
The general approach to meet flammability requirements by a treated top cover (using a reactive
phosphonium based FR or equivalent) and by treated foam is accepted as workable. Brominated FRs in backcoated textiles have some advantages, largely around their flexibility in application
but their environmental performance is poor. This has recently been recognised by suppliers of
decaBDE to the US who have entered a voluntary agreement to remove this FR from use over the
next 3 years.
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There is also market acceptance that current brominated FRs will be excluded from Ecolabels
based on their risk phrases. It is recommended that brominated FRs with ATO synergists be
phased out for textiles in favour of phosphorus-based FRs and alternative synergists to ATO should be investigated. An additional option is to use polymeric brominated FRs which are
additive if their environmental performance proves to be acceptable. These may also be combined
with alternative synergists.
In regard to foam fillings, the chlorinated phosphorus FR compounds are currently the primary FR technology for FR foams. However non-chlorinated phosphorus FR compounds are starting to
become commercially available. These are for example being introduced into office furniture by
one foam manufacturer and their introduction into interior furnishings in households should be encouraged. Similarly, fire-blocker technologies currently used in the public transport industry
could be transferred to the domestic market or graphite impregnated foam (GIF), as used in the
aircraft industry.
Those non-chlorinated phosphorus based chemical FR technologies, which satisfy the Ecolabel
risk phrase criteria, may be considered as best environmental performers, particularly given the
potential difficulties of the costs and market acceptance of GIF-foams. However, these FRs would
not currently satisfy Ecolabel criteria that would exclude “additive” chemical FRs; such criteria would need to be modified to enable the use of such FRs. This could be made selective through
the use of exceptions or white list approaches.
The Oeko-tex white list approach is considered a reasonable attempt to meet environmental criteria. However, in the interior furnishings and related component sectors there is a preference
for the risk phrase approach rather than a white list approach, due to the greater flexibility that this
approach provides. Similarly, a blanket ban on specific product categories is not favoured.
Electronic Products
The use of inherent FR materials in casings and enclosures is possible but the costs may be
prohibitive particularly for the high performance polymers and composites that could be used.
The unacceptability of decaBDE, because of concerns over its degradation products, the exclusion
of all PBDEs in the EU Ecolabel, and some concerns expressed about antimony trioxide (ATO),
indicate that while the combined decaBDE/ATO FR system is one of the best fire performing
chemical FR technologies it is one of the poorest environmental performers. Other additive
chemical FR technologies such as phosphorus based FRs which satisfy current risk phrase criteria
perform well environmentally but care is required to ensure that these FRs meet the wider
materials processing, technical and fire performance requirements for the components that use
them. This may be achieved with viable options to decaBDE and an appropriate phase out
strategy for decaBDE in Europe would seem to be appropriate.
For printed circuit boards the reactive and brominated FR TBBPA satisfies the risk phrase criteria
as a monomer but it should be not be excluded on the basis of its elemental content alone. The
existence of inherent FR materials in high specification PCBs offers the best environmental
performance but the cost of adopting this technology in consumer electronic products is likely to
be prohibitive.
While the exclusion of some brominated FRs is justified on environmental grounds, such
exclusions should not be applied to all halogentated FRs that could be used in electronic product
applications.
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A number of chloro-phosphorus based FRs with good risk phrase-based environmental
performance are available which could be used in electronic products and these should not be
arbitrarily excluded on the grounds that they contain chlorine.
It is important to ensure that more of the alternatives to halogenated FRs are appropriately hazard
and risk assessed and only used if less hazardous than the chemicals they replace.
The electronics sector is prepared to accept a white list approach to FR acceptance. Technically, this is
attractive as it presents manufacturers with a definite albeit limited choice of acceptable FR technologies.
This would also simplify the recycling of these materials in the future. This contrasts with the view of the
textiles sector that preferred an R-phrase approach. Both groups stated they did not accept exclusion based
on additive and chemical class exclusions – these were seen as too restrictive.
Recommendations
Sleepwear
For children‟s sleepwear which is 100% untreated polyester, the material is able to meet current
Ecolabel criteria but it cannot be recommended for this application on this basis alone.
This recommendation recognises concerns over the tendency of this material to melt when heated in fire and which may cause serious burns to the wearer. While Ecolabel accept this material in regard
to its environmental performance, it would reject other materials containing additive FR technologies
and which perform more safely in fire. In this regard Oeko-Tex uses a white list approach to identify
up to 14 environmentally acceptable FRs which significantly broadens materials choice.
Many of the FR alternatives contain halogens and these should not be excluded unless they do not
meet the risk phrase criteria.
Maintain the limits on formaldehyde for skin contact sleepwear.
There are some FR treated cottons incorporating phosphorus or nitrogen-based FRs which are sold for children by some retailers. In this case some concerns exist in regard to skin irritation and loss of FR
performance caused by numerous washes. However, the main concern from the primary FR manufacturer active in this area is the low levels of formaldehyde required by the EU Ecolabel. While
this was thought to be achievable for sleepwear there may be merit in considering a relaxed limit in
no-skin contact uses.
Further work is required on the use of modified acrylic/ cotton mixes and the questions raised on
possible hydrogen cyanide emissions; these should not be recommended as inherent FR materials
until the question has been answered.
Modified acrylic / cotton mixes which produce a partially inherent FR textile have been criticised because of possible hydrogen cyanide emissions. Until this is resolved such fibre mixtures should not
be seen to reduce chemical hazards.
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Personal Protective Equipment
Use inherent FR materials where these are available.
The use of inherent FR materials (such as those based on aramid fibres) is to be recommended when there are no cost constraints. Where such constraints exist or where market choice is important then
chemical FR technologies will be required for use with more flammable materials.
Review the formaldehyde limit to enable the use of phosphonium salts to fire protect cheaper
textile materials.
The most commonly used durable commercial finishes are tetrakis hydroxyl methyl phosphonium chloride-urea condensate (eg, Proban, Rhodia Specialities Ltd) and N-methylol dimethyl
phosphonopropionamide (eg Pyrovatex, Huntsman, formerly Ciba). However, in view of the possible release of formaldehyde, this would be more generally acceptable for non-skin contact applications.
Alternatively, exempt phosphonium salts or add FR technologies containing them to a white list.
Materials treated with these FR technologies might be allowed under the current Ecolabel risk phrases if they were treated as an exemption with restrictions on use or they could be placed on a white list of approved FRs.
Continue to use different formaldehyde limits according to use of the material.
As the formaldehyde content is a general issue for this type of treatment, an alternative approach would be to introduce a more stringent free formaldehyde content for children‟s sleepwear, and a less stringent requirement for garments in contact with adult skin, and less so again for garments not in
contact with the skin. PPE would fall into the latter two categories, and so could be made permissible
for Ecolabel and green procurement purposes.
Use different technologies according to the specification and intended use of the PPE.
For high performance PPE applications, it is recommended that inherent fire retardant materials such as the aramids be considered and phosphonium based FR treated fabrics be allowed for lower
specification PPE by allowing the formaldehyde limit to be relaxed to a level that can be achieved for good quality treated FR finishes.
Furnishings and Furniture
FR technologies avoiding the use of chemicals
Covering fabrics from inherently fire retardant fibres
Use natural fire resistant materials such as wool or leather.
Wool fabric of high area density, i.e. ≥ 600 g/m2, can pass the required fire performance tests. If a
lighter wool fabric is used, it might need some fire retardant treatment (e.g. by the ZIRPRO-treatment
using hexafluoro zirconate or titanate by the exhaustion method) at nominal levels.
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Leather is inherently fire retardant. However, artificial leather fabrics require a chemical fire
retardant treatment to satisfy fire retardancy requirements.
Use a synthetic fire resistant material such as modacrylics with small amounts of additive FRs.
Inherent FR fibres based on modacrylics are expensive and could restrict consumer choice. However, some modacrylics contain small amounts of the additive FR antimony trioxide (ATO) to enhance
their fire retardancy. ATO has a risk phrase (R40) related to potential inhalation hazards but if it is
incorporated and physically well bound in the material the risks can be significantly reduced.
Use natural and synthetic blends to reduce cost and increase choice.
Blends of different fibres can also be used, e.g. wool/modacylic, wool/nylon blends, wool/FR viscose, etc. Blends of wool with other high performance fibres like Nomex, Kevlar, Basofil,
Polybenzimidazole, etc., can also be used, though the latter are very expensive.
Fire-blockers and Interliners
Use natural or synthetic fire resistant material or a mixture of both for fire blockers and
interliners.
Interliners made from inherently fire retardants fibres can further reduce the flammability of the product, both for domestic and non-domestic applications. In general if the covering material is made of > 75% natural fibres such as cotton or wool, it does not need to be fire retarded to pass the
Crib 5 test of BS5852: Part 2:1989. These barrier materials can be multi-layered which allows a
product to maintain its fire resistance even if one layer is compromised.
For domestic under S.I. 1324, interliners are tested to Schedule 3 using Crib 5 test of BS5852: Part 2 : 1982. A water soak requirement controls the viability of interliner FR treatment. For non-domestic
furniture BS7176: 2007 uses BS5852: 2006 and BS EN 1021-1 & -2: 2006. There are no constraints
on what/how interliners are used but open flame ignition sources up to BS 5852 Crib 7 can be applied (depending on end use scenario). Since this is an actual composite test the pass/fail outcome will
depend on physical/chemical make- up of both textile and filling.
Adopt transport sector fire-blocker designs in the domestic market.
Fire-blockers, made from inherently fire retardant fibres like oxidized acrylics and aramids, can make the product fire retardant. However, these materials are very expensive. Fire-blockers from oxidised
acrylics and aramids are commonly used for aircraft seats; their use is increasing in trains, buses and
coaches. So the adoption of design practice in the transport sector could create benefits in the
furniture product sector.
The barrier materials can also be a blend of inexpensive natural fibres and expensive synthetic fibres,
such as Basofil, Polybenzimidazole, Kevlar, Nomex, etc. Cost may be prohibitive for general
consumer markets.
Use fibreglass wrapped in an inherently fire retarded fibre to reduce cost.
GR241/Defra/2010 15 of 115 November 2010
A cheaper alternative is to use glass fibre wrapped in fabric of inherently fire retardant fibres (e.g. FR viscose) or plastic film made from neoprene, PVC which produces fire retardant species when
exposed to thermal degradation conditions and to fire.
FR technologies involving FR chemicals
Covering fabrics
Back-coatings:
Consider phasing out the use of classes of brominated FRs in backcoatings that are known to be
hazardous.
The environmental performance of a number of classes of brominated fire retardants (Br-FRs) and ATO in traditional back-coatings, such as decaBDE and HBCD, is poor and do not satisfy Ecolabel
requirements.
Investigate phosphorus-based FRs as an alternative to Br-FRs in backcoatings.
The use of volatile and possible vapour phase-active phosphorus-based FRs should be further explored and effective substitutes found. The only drawback is that these coatings will be fibre
specific and so cannot be used for all fibre types and blends.
Investigate alternative synergists to, and phase out the use of, ATO.
ATO, the most common synergist for Br-FRs, also has environmental issues related to its inhalation
toxicity, although these can be managed by effective matrix incorporation to reduce inhalation
exposure. This compound could be replaced by other synergists such as the zinc stannates. Stannates show synergism with halogenated compounds in some chemical finishes and when used as additive
fire retardants in polymers. However, zinc hydroxystannate and zinc stannate are more expensive
than ATO and so have not been used in commercial formulations. Consequently, the assessment of material and product fire performance using these alternative synergists has not yet been done.
Investigate the use of halogen-free back-coatings and other emerging technologies.
There are some halogen-free back-coating formulations available, such as MelaphosFR™ Dartex. However, it is not clear to which fibre types these will be applicable.
Thor has also developed alumina trihydrate (ATH) and exfoliating graphite containing coatings,
which work by providing physical fire barrier protection, but these may need to supplemented by
chemical FR technologies that are effective in the gas phase.
Additive fire retardants:
Use polymeric additives in synthetic fibre materials.
If additive fire retardants are to be used in synthetic fibres, there is advantage in them being
polymeric in nature – this would increase their likelihood of satisfying REACH, provided they do not contain residual monomer and/or the monomers have been assessed as posing no hazard.
GR241/Defra/2010 16 of 115 November 2010
Chemical finishes:
Investigate replacing water-based finishes with surface modification by plasma technology.
For cotton and cotton/polyester blends, durable chemical finishes such as Pyrovatex (Huntsman, formerly Ciba) or Proban (Rhodia) are usually applied. The conventional water-based finishes could be replaced by surface modification by plasma technology. The interest in this has increased with the
recent development of atmospheric plasma machines for processing wide widths of fabrics although
no current fire retardant successful example exists at the present time.
Foam and other fillings
Investigate the use of graphite impregnated foam in the domestic market.
Physical fire protection of foam seating by the introduction of graphite impregnated foam (GIF) as an inherently fire-resistant foam is widely used in aircraft. GIF-foams may be recommended as the best
environmental performing technology but concerns exist on potential cost implications. They also have a need for additional chemical FRs to assist gas phase retardancy. Graphite-based foams have
been available in the UK for more than 20 years and early marketing efforts were strongly directed
towards the domestic furniture market. In the context of eco-label criteria, graphite is not a reactive FR, which puts it in the same position as melamine.
Investigate replacing halogenated phosphorus FRs with non-halogenated phosphorus FRs.
In regard to chemical FR technologies, the halogenated phosphorus based FR chemicals currently used for fire retarding foams could be replaced by non-halogenated phosphorus based fire retardant, such as triarylphosphate, organic phosphate ester with triphenyl phosphate. However, it is noted these
would be of the additive type and not reactive and while some may be able to satisfy the Ecolabel
risk phrase criteria they would be excluded because of not being reactive.
These constraints are unacceptable as no currently used polyurethane foams could satisfy the “additive” requirement. Also, a move to non-chlorinated FRs would increase costs and in some cases
substantially so.
Review and continue to develop nanocomposite foams as an alternative to conventional
polyurethane foams.
There has been a considerable amount of research in developing polymer nanocomposite foams, but
current findings suggests they still need other fire retardant to adequately pass fire performance tests.
However, most of the effort to date has been at a laboratory scale and are not yet commercially
available. So while this can rightly be seen as an emerging technology it is unlikely to provide the
required degree of fire retardancy on its own without the aid of other FRs. The benefit is the potential
reduction in the amount of chemical FR used.
Most FR foams for interior furnishings rely currently on additive chemical and physical FR
technologies, including those that would satisfy R-phrase criteria. The “additive” FR criteria
should not apply to foams unless viable alternatives are available.
GR241/Defra/2010 17 of 115 November 2010
Interior Furnishings
Use inherent fire retardant materials where possible.
Inherent FR approaches are possible for many textiles, for example the use of modified acrylic/cotton blends (i.e. a partially inherently FR blend) was used in the USA, albeit with different regulatory
requirements. There is also some use of inherently FR polyester in coverings. These provide
opportunities to use inherent FR materials options but they may be seen as limited within the current vast range of materials and constructions currently available.
Allow use of synthetic, inherently fire retardant interliners.
Technically, interliners may be used as a design alternative to eliminate chemical FR use. Consultation with users revealed a view that they may be of limited use in gaining environmental
improvement since it is believed that most interliners in the UK were of cotton, which would require
treatment with FRs. Inherent FR materials such as aramid would be possible, but would cost approximately ten times more. So while technical alternatives do exist and can be recommended as
good environmental performers (in risk phrase terms), their costs and market constraints may be
prohibitive at this point in time.
Encourage use of treated top cover and treated foam as a means of phasing out Br-FRs.
A general approach to meet flammability requirements by using a treated top cover (Pyrovatex or equivalent) and by treated foam works well technically and was seen by consultees as workable.
Brominated FRs in backcoated textiles have some advantages due to their flexibility in application.
However, the use of poor environmentally performing brominated FRs should not continue. There appears to be market acceptance that brominated FRs will be excluded.
Encourage a switch from halogenated phosphorus FRs to non-halogenated equivalents.
In regard to foam fillings, it is possible to replace chlorinated phosphorous based FRs with non-chlorinated ones and there was a general consensus from consultees that non-chlorinated FR compounds were starting to become commercially available for foams. These are for example being
introduced into office furniture by one foam manufacturer, with an eventual ambition of introduction
into interior furnishings in households. This switch should be encouraged assuming they are low hazard/risk.
Modify Ecolabel requirements that specifically exclude additive and/or chlorinated FRs to enable
the use of adequately classified non-chlorinated phosphorus chemical FR technologies.
For those non-chlorinated phosphorus chemical FR technologies which have an adequate classification to satisfy the Ecolabel risk phrase criteria, these should be recommended as best
environmental performers, particularly given the potential difficulties of the costs and market
acceptance of GIF-foams. However, these FRs would not currently satisfy the Ecolabel requirement that excludes additive chemical FRs. This requirement should be reviewed.
GR241/Defra/2010 18 of 115 November 2010
Mattresses
Encourage better design and use of inherent FR materials to obviate the need for FRs.
In the consultation, one example was found of a mattress manufacturer who has met the UK
legislative requirements on fire performance using a combination of materials (wool) and changes in
design (side seaming rather than tape edging) with no use of chemical FRs. Many of the materials in
conventional mattresses are polyester and polypropylene, and the flammability requirements can be met with non-halogenated compounds.
Encourage a switch from halogenated phosphorus FRs to non-halogenated equivalents while
recognising the needs of polyurethane foams.
Polyurethane foam mattresses currently require chlorinated or non-chlorinated phosphorus FRs. The chlorinated compounds are regarded as the standard FR chemicals, with non-chlorinated being less
well characterised with respect to environmental performance.
Electronic Products
Use inherently FR materials for casings and enclosures.
While this is recommended because the use of inherent FR materials in casings and enclosures is
possible, the costs may be prohibitive for the high performance polymers and composites that could
be used. Other life cycle factors such as weight and total energy use in manufacture may also limit
the use of metals.
Phase out decaBDE/ ATO FRs in favour of phosphorus-based FRs for casings and enclosures.
The unacceptability of decaBDE as a result of concerns over its degradation products, the exclusion of
most PBDEs in ecolabels, and the concerns expressed about ATO, indicate that while this is one of
the best fire performing FR technologies it is one of poorest environmental performers. Other additive
chemical FR technologies based on phosphorus based FRs which satisfy current risk phrase criteria
are the best performing but care is required to ensure that only those FRs that are chemically classified
and shown to be satisfactory should be included. This may be achieved with an appropriate phase out
strategy.
Allow brominated FRs in applications where they are chemically bound to the substrate, for
instance reactive TBBPA in printed circuit boards.
For printed circuit boards the reactive and brominated FR TBBPA is acceptable for current Ecolabel
purposes and should not be excluded on the basis of its bromine content. The existence of inherent FR
materials in high specification PCBs offers the best environmental performance but the cost of
adopting this technology in consumer electronic products would be prohibitive.
Review and restrict the use of exclusions to avoid inadvertent exclusion of potentially useful
chemical FRs in low hazard situations.
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While the exclusion of some brominated FRs is justified on environmental grounds, such exclusions
should not be applied to all halogenated FRs that could be used in electronic product applications.
A number of chloro-phosphorus based FRs with good risk phrase based environmental performance
are available which could replace brominated FRs and these should not be arbitrarily excluded. In
principle the same position could exclude many of the new polymeric brominated FRs in spite of their
potential low hazard status within REACH.
Ensure that alternative chemical FRs to halogenated FRs are hazard assessed and their
classification harmonised, and risk assessed if required, to give potential users confidence in
adopting alternatives that are known to be less hazardous than the FRs they replace.
One consultee commented that they had invested in replacement FRs only to find that these too failed
to satisfy ecolabel requirements.
Consider the use of a white list of acceptable FR chemicals.
Technically, a white list approach is attractive as it presents manufacturers with a definite albeit
limited choice of acceptable FR technologies. This would also simplify the recycling of these
materials in the future. Some electronic / electrical sector consultees were in favour of a white list
approach, which contrasted with the views expressed from the textiles sector. One of the problems
foreseen was the criteria for inclusion and the large amount of activity that would be generated from
various plastics and FR manufacturers that might make this process difficult to manage.
General Recommendations
There is significant scope to move towards design-based and intrinsic fire retardancy approaches
which can avoid the use of chemical FR technologies. However, adoption of these better
environmentally performing technologies, as measured by risk phrases and the use of exclusion
criteria in EU Ecolabels may not in all cases offer the best whole life environmental performance.
These may also exclude chemical FR technologies that are good environmental performers.
While adoption of non-chemical FR technologies is to be encouraged, it may take some time for
this to occur and it may be constrained by costs and other technical, environmental and market
factors. It is therefore prudent to maintain Ecolabel approval of safe and low hazard chemical FR
technologies that can play a role in maintaining product fire performance standards. This may
require that existing Ecolabel criteria be reviewed and modified to enable a balanced position to
be achieved which does not compromise human or environmental safety or compromise advances
in fire safety that have been achieved with existing FR technologies.
Exclusion of brominated FRs is technically possible for all product groups. Such exclusion is
required for those classes of brominated FR that produce unacceptable hazards and the application
of the precautionary principle is justified.
GR241/Defra/2010 20 of 115 November 2010
Exclusion of chlorinated FRs is also possible for almost all product groups, although their
possible substitutes in polyurethane based foam are not as well characterised with respect to risk
and fire performance.
The descriptions of terms such as “reactive”, “inherent FR” or “additive” was criticised by certain
respondents as sometimes misleading, and unable to describe accurately the way in which some
FR chemicals are incorporated or act.
There is general support for inclusion of a flammability criterion in the EU Ecolabel.
Consideration should be given to whether flammability is a key performance criterion of the
Ecolabel product groups considered here.
The setting of Ecolabel criteria should be closely allied to the process of REACH and CLP in
Europe and benefit from the hazard and risk data gathering exercises that form part of REACH for
all chemical FR technologies.
Harmonisation of the risk-phrase approach within Ecolabels with REACH and CLP should be
addressed, probably as a cross-cutting theme across all the Ecolabel criteria that use risk phrases.
Are the Current EU Ecolabel Criteria Fit For Purpose?
The existing EU Ecolabel criteria for the products considered here are too restrictive and are not
consistently based on the risk phrase approach to environmental performance. Meaningful and balanced
Ecolabel criteria are likely to be based on:
1. Encouragement to use non-chemical FR technologies such as product design and inherent FR materials. For GPP this would also require it being achieved at reasonable cost.
2. Exclusion of any chemical FRs that are known to be hazardous through appropriate risk-phrase
hazard assessment and, where appropriate, risk assessment. It is not appropriate to exclude all classes of brominated FRs due to the poor environmental performance of some classes.
3. Inclusion of chlorinated FRs that meet ecolabel hazard criteria.
4. Inclusion of both additive and reactive chemical FR types, as currently defined, but subject to
ecolabel criteria. Cease to use exclusion criteria based on “reactive” and “additive” terminology and avoid the use of such terminology in the setting of criteria.
5. Alignment of criteria setting with REACH and CLP in Europe; this should include consideration
of the effect of FRs being chemically and physically bound into materials rather than based on free molecule hazard assessments.
6. Regular review of the criteria to keep pace with hazard and risk information developments under
REACH and CLP. FR chemicals should not be used in ecolabel products unless they have adequate toxicity data to ensure that no classification is required in respect of the specific risk
phrases listed in the ecolabel. Absence of data and absence of classification should not mean that
an FR is acceptable.
7. A fire retardancy criterion to ensure the fire performance of products is not compromised.
GR241/Defra/2010 21 of 115 November 2010
Contents
SUMMARY ................................................................................................................................. 3
1 BACKGROUND ..................................................................................................................... 26
2 AIMS AND OBJECTIVES ...................................................................................................... 26
3 SCOPE OF THE PROJECT .................................................................................................... 27
4 STRUCTURE OF THE REPORT ........................................................................................... 27
5 LEGISLATIVE LANDSCAPE ................................................................................................ 29
5.1 Overview ........................................................................................................................................................ 29
5.2 Fire Safety Legislation ................................................................................................................................... 29
5.3 General Product Safety Directive .................................................................................................................. 32
5.4 Chemical Safety in Europe ............................................................................................................................ 33
5.5 Chemical Safety Specific to the Electronics Industry ................................................................................... 34
5.6 US Safety Legislation ..................................................................................................................................... 35
5.7 Comparison of the UK and US Nightwear Regulations ................................................................................ 37
5.8 Comparison of UK and US Furniture Regulations ....................................................................................... 38
5.9 The Use of Risk Phrases ................................................................................................................................ 39
5.10 Green Procurement Policy in Europe.......................................................................................................... 40
6 GLOBAL AND EUROPEAN FIRE RETARDANT MARKET ................................................. 41
6.1 Europe, USA and Asia ................................................................................................................................... 41
6.2 Europe ............................................................................................................................................................ 42
6.3 Fire Retardant Manufacturers and their Product Ranges ........................................................................... 44
6.4 Market survey ................................................................................................................................................ 45
6.1 Survey Findings ............................................................................................................................................. 46
6.2 Survey Conclusions ........................................................................................................................................ 52
7 FR TECHNOLOGY SURVEY ................................................................................................ 52
GR241/Defra/2010 22 of 115 November 2010
7.1 Survey Structure and Participation .............................................................................................................. 52
7.2 FR Producers ................................................................................................................................................. 53
7.3 Product Producers ......................................................................................................................................... 54
7.4 FR Technology Costs ..................................................................................................................................... 55
7.5 Ecolabel Response from the FR Technology Survey ..................................................................................... 56
7.6 Some Respondent’s General Comments........................................................................................................ 59
8 FIRE RETARDANCY – AN INHERENT SAFETY DILEMMA ............................................... 60
9 EUROPEAN RISK PHRASES ................................................................................................ 61
10 RISK AND HAZARD ASSESSMENT.................................................................................... 62
11 HIERARCHY FOR HUMAN AND ENVIRONMENTAL SAFETY ........................................ 63
12 ALTERNATIVE FR TECHNOLOGIES AND RECOMMENDATIONS ................................. 64
12.1 Textiles ......................................................................................................................................................... 65
12.2 Furniture and Furnishings .......................................................................................................................... 71
12.3 Electronic Products Recommendations ....................................................................................................... 80
13 FIRE RETARDANTS AND THE EU ECOLABEL ................................................................ 84
13.1 Overview ...................................................................................................................................................... 84
13.2 Introduction ................................................................................................................................................. 84
13.3 Criteria for Improved Environmental Performance in Ecolabel ................................................................ 85
13.4 Stakeholder Comments on Criteria Options for Textiles and Mattresses .................................................. 88
13.5 Stakeholder Comments on Criteria Options for Electronic Equipment ..................................................... 89
13.6 General Comments ...................................................................................................................................... 90
14 GENERAL COMMENTS AND RECOMMENDATIONS ...................................................... 91
Flammability criterion within Ecolabel .............................................................................................................. 92
Information on newer FRs .................................................................................................................................. 92
15 ARE THE CURRENT EU ECOLABEL CRITERIA FIT FOR PURPOSE? ............................ 92
GR241/Defra/2010 23 of 115 November 2010
APPENDIX 1: SUMMARY TABLES OF FR CHEMICAL RISK ASSESSMENT AND
CLASSIFICATION ................................................................................................................... 94
APPENDIX 2: EXISTING, SUBSTITUTION AND EMERGING TECHNOLOGIES FOR FIRE
RETARDANT NIGHTWEAR.................................................................................................. 103
APPENDIX 3: EXISTING, SUBSTITUTION AND EMERGING TECHNOLOGIES FOR FIRE RETARDANT INTERIOR FURNISHINGS ............................................................................. 105
APPENDIX 4: EXISTING, SUBSTITUTION AND EMERGING TECHNOLOGIES FOR FIRE
RETARDANT ELECTRONIC PRODUCTS ............................................................................ 111
ANNEXES:
Annexe 1: Legislative Landscape
Annexe 2: Hazard and Risk Assessment
Annexe 3: Alternative FR Technologies
Annexe 4: Ecolabel Review and Awareness Study
GR241/Defra/2010 24 of 115 November 2010
Glossary of Abbreviations
Fire retardants:
ATO Antimony trioxide
2EHDPP 2-Ethylhexyl diphenyl phosphate
BDE Bromodiphenyl ether (e.g. decaBDE, pentaBDE, octaBDE) BFRs Brominated fire retardants
CDPP Cresyl diphenyl phosphate
EBP Decabromodiphenyl ethane (Ethane, 1,2-bis(pentabromophenyl) FR Fire retardant
HBCD Hexabromocyclododecane
HCCD Hexachlorocyclododecane IDDPP Isopropyl phenyl diphenyl phosphate
IPPDP Tris(isopropyl phenyl) phosphate
IPTPP Isodecyl diphenyl phosphate
LCCP Long chain chlorinated paraffins MCCP Medium chain chlorinated paraffins
PBBs Polybrominated biphenyls
PBDEs Polybrominated diphenyl ethers PDBS Polydibromostyrene
SCCP Short chain chlorinated paraffins
TBBPA Tetrabromobisphenol A TBBE tetrabromobenzoate ester
TBPA Tetrabromophthalic acid anhydride
TBPDPP Tertbutyl phenyl diphenyl phosphate
TCCP tri (2-chloropropyl) phosphate TCP Tricresyl phosphate
TPP Triphenyl Phosphate
TRIS Tris(2,3-dibromopropyl) phosphate TPRDP Tetraphenyl resorcinol diphosphate
TXP Trixylenyl phosphate
V6 2,2-Bis(ChloroMethyl) TriMethylene Bis[Bis(2-ChloroEthyl) Phosphate]
Organisations:
BSEF Bromine Science and Environment Forum
EA Environment Agency of England and Wales
EBFRIP European Brominated Fire Retardants Industry Panel ECHA European Chemicals Agency
EFRA European Fire Retardants Association
ESIS European Chemical Substances Information System EPA US Environmental Protection Agency
IRIS Chemicals database of US EPA
OECD Organisation for Economic Co-operation and Development
ORATS Online European Risk Assessment Tracking System - provides information on the progress of implementation of ESR
SCHER Scientific Committee On Health And Environmental Risks
UKCCRMP UK Coordinated Chemical Risk Management Programme
Regulations and related terms:
B Bioaccumulative in the environment
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CICAD Concise International Chemical Assessment Documents
C&L Classification and Labelling
ESR Existing Substances Regulation (Council Regulation (EEC) No 793/93) ESD Emission Scenario Document
P Persistent in the environment
PBT Persistence, Bioaccumulation potential and Toxicity
vPvB very Persistent, very Bioaccumulative REACH Registration, Evaluation and Authorisation and restriction of Chemicals
SVHC Substance of Very High Concern
RoHS Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2008 (the “RoHS Regulations”), EU Directive 2002/95
SIDS Screening Information Datasets
SIARs SIDS Initial Assessment Report SIAPs SIDS Assessment Profile
T Toxic in the environment
WEEE Waste Electric and Electronic Equipment Directive (January 2007)
WFD Water Framework Directive (2000/60/EC)
Voluntary Schemes:
VECAP Voluntary Emissions Control Action Programme
Organisations, Directives and Acts:
BIS Department of Business, innovation and Skills
BSEF Bromine Science and Environment Forum
CAA (US) Clean Air Act
CHIP Chemicals (Hazard Information and Packaging for Supply) Regulations CLP Regulation on classification, labelling and packaging of substances and mixtures
COSHH Control of substances Hazardous to Health
CPSA (US) Consumer Product Safety Act CPSC (US) Consumer Product Safety Commission
DPD Dangerous Preparations Directive 1999/45/EC
DSD Dangerous Substances Directive 67/548/EEC EBFRIP European Brominated Fire Retardant Industry Panel
ECHA European Chemicals Agency
EFRA European Fire Retardants Association
EPA (US) Environmental Protection Agency ESR Existing Substances Regulation (Council Regulation (EEC) No 793/93)
EUP Energy Using Products (EUP) Directive 2005/32/EC
FFA (US) Flammable Fabrics Act FHSA (US) Federal Hazardous Substances Act
GPSD General Product Safety Directive
IPPC Directive on Integrated Pollution Prevention and Control, 2008/1/EC NFPA (US) National Fire Prevention Association
NONS Notification of New Substances Regulations (Council Directive 67/548/EEC)
REACH Registration, Evaluation, Authorisation and Restriction of Chemicals
RoHS Restriction of the use of certain Hazardous Substances TSCA (US) Toxic Substances Control Act
WEEE Waste Electrical and Electronic Equipment directive
WFD Water Framework Directive Directive 2000/60/EC
GR241/Defra/2010 26 of 115 November 2010
1 Background
This is the final technical report of a project conducted by GnoSys UK Ltd, Oakdene Hollings and the
University of Bolton for the Department for the Environment, Fisheries and Rural Affairs (Defra) concerning “Fire Retardant Technologies: safe products with optimised environmental performance”
2.
The report is intended to support policy making within Defra‟s Sustainable Consumption and Production
programme3 particularly in the area of EU Ecolabels and Green Public Procurement.
2 Aims and Objectives
The aim of the project was to review the available technologies for achieving fire retardant properties in
key product groups, and to determine best practice in terms of achieving appropriate safety standards with minimal environmental impact.
The objectives were to:
1. Provide a summary of the legislative landscape and how it has changed (including UK, EU and US developments, and covering both fire safety requirements and restrictions on substances used).
2. Provide a UK and EU market analysis to provide an insight into the key technologies currently
used in different products in the UK and EU and emerging trends.
3. Undertake a review of latest scientific knowledge and risk assessment conclusions of the
hazardous nature of fire retardants.
4. Undertake a review of alternative approaches to fire retardancy, including reactive technologies
and physical barriers / use of naturally fire retardant materials, together with an indication of relative costs of the different approaches.
5. Provide a recommendation, for each key product group, of the fire retardancy approach with the
best performance in terms of environmental impact. This would be accompanied by an assessment of the level to which this optimum approach is already employed by industry and, if
applicable, the ease with which it could be taken up by the mass market and associated costs.
Case studies which demonstrate that the recommended approach is achievable will be included
where possible.
6. In the light of the study findings, review whether the latest criteria set under the EU Ecolabel for
(a) Textiles and (b) Bed Mattresses are fit for purpose and achievable by UK companies, and
recommend overarching principles for how criteria should be set on fire retardancy in future development of standards for these and for other product groups.
2 The original title used by Defra, and subsequently re-titled, was “Flame Retardant Technologies: safe products
with optimised environmental performance” 3 www.defra.gov.uk/environment/business/scp/index.htm.
GR241/Defra/2010 27 of 115 November 2010
3 Scope of the Project
The scope of the project and this report relates to a selected group of products in consumer use and
appropriate public use, the types of technology that can confer fire retardancy and how this is influenced by geographical differences in regulation and legislation with a focus on the UK, Europe and the United
Sates.
Products:
The study focused on the following consumer products:
1. Products covered by the Furniture and Furnishings (Fire) (Safety) Regulations 1988: "items
which contain upholstery: beds, headboards, mattresses, sofa-beds, nursery furniture, garden
furniture which can be used indoors, furniture in new caravans, scatter cushions, seat pads and pillows and loose and stretch covers for furniture"
4.
2. Clothing textiles – nightwear, personal protective equipment and any other relevant
categories.
3. Electronic and electrical equipment: specifically including televisions and computers (both
personal or office computers and portable computers including laptops, notebook and
notebook.
Types of product application: The study considered both consumer products and commercial products
(for example, furnishings for public use areas which may be subject to more stringent fire protection
standards).
Types of fire retardant (FR) technology: The study considered all methods of achieving fire retardancy
in products, including additive, reactive, barrier and other relevant technologies or design solutions.
Where appropriate, brominated compounds have been considered alongside mineral and organophosphate
based substances.
Geographical scope: The study was focused on the specific UK situation in terms of fire safety
legislation but it has also attempted to take account of European and US legislative and technology
developments and market trends, to determine leading technologies and best practice in fire retardancy.
4 Structure of the Report
This report brings together the results of seven other reports in this project to produce an overview of the
study and its essential conclusions and recommendations with a view to guiding UK policy making on EU
Ecolabels and green public procurement.
The consumer products of interest include:
4 HMG (1988), “The Furniture and Furnishing (Fire) (Safety) Regulations 1988”, Statutory Instrument 1988 No.
1324, Consumer Protection; and, HMG (1989), “The Furniture and Furnishing (Fire) (Safety) (Amendment) Regulations, 1988, Statutory Instrument 1988 No. 1324, Consumer Protection
GR241/Defra/2010 28 of 115 November 2010
1. Textiles
2. Interior Furnishings and Furniture
3. Mattresses
4. Televisions
5. Computers
Seven earlier reports from the study to date are used and are attached as annexes; these include:
Annexe 1: Legislative Landscape5
Annexe 2: Hazard and Risk Assessment6
Annexe 3: Alternative FR Technologies 7
Annexe 4: Ecolabel Review and Awareness Survey 8
The reader is encouraged to consult these for more detailed information which supports the observations
made in this report.
The context for the recommendations made here is the existing Ecolabel scheme criteria and makes use of
the framework for FR technology environmental performance assessment presented in the Ecolabel
Criteria and Principles report 8.
In brief, a comparison of various Ecolabel schemes in Europe provides criteria for the environmental
assessment of products containing FRs – these generally contain:
A risk phrase approach to chemical safety – this is based on the precautionary principle applied to
risk phrases drawn from current chemical hazard based classification in Europe, not formal
European risk assessment findings.
The use of exclusions and exemptions – sometimes of whole classes of compounds, such as
organohalogens, often combined with specific exemptions of particular compounds.
The exclusion of “additive” FRs and the retention of “reactive” FRs for mattresses and textiles.
It is noted that no attempt was made in this work to consider environmental performance in terms of life
cycle environmental impact assessment with a consideration of for example energy and water use, waste
production and environmental emissions across the whole life cycle from component manufacture to end
of product life. Such life cycle assessment (LCA) is possible but is beyond the scope of the current
project.
5 Legislative Landscape, GR223, May 2010 6 Review of hazard and risk assessment of FR technologies, GR230, May 2010 7 Review of Alternative Fire Retardant Technologies, GR233, May 2010 8 Ecolabel Review and Awareness Survey GR233, May 2010
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5 Legislative Landscape
5.1 Overview
The legislative landscape report is provided in Annexe 1. It summarises the current UK and EU regulatory position on fire safety regulation. In the EU this is influenced by the General Product Safety Directive (GPSD). However, in Europe in general there is greater reliance on fire test standards than regulation in
many areas of consumer use of products, whereas there is greater regulation of fire safety in public places.
Exceptions are the Nightwear and Furniture fire regulations which apply in the UK and have parallels in
US State legislation.
Chemical safety in Europe is also reviewed and the current implementation of the REACH and CLP
directives is discussed which have a direct bearing on fire retardant hazard identification, classification
and risk assessment. Consideration is also given to Chemical safety regulations as reflected in the WEEE and RoHS directives.
Chemical and fire safety regulation has also been reviewed for the US at both Federal level and State level
where it was possible to obtain State related information.
The EU Ecolabel scheme and related schemes in European countries are also reviewed, as is the general position of Green Public Procurement policy in Europe and that adopted by a variety of member states.
5.2 Fire Safety Legislation
Most of the original 12 EU Member States have legislation in place defining fire safety standards for
bedding, mattresses and seats and these have been extensively reviewed by Sainrat9 and by Guillaume
10.
In the UK the regulation is applicable to domestic furniture, where a furniture/seat should pass the
cigarette and match tests; upholstery, filling materials, loose filling and covers should also pass different
flammability tests. For non-domestic environments, in UK there is Fire Safety Regulatory Reform,
according to which the furniture, filling and cover materials should pass the flammability tests (usually
cigarette/ match test), but the criteria might differ based on the application area. Some member states
(Finland, France, Norway, Sweden, Spain, Portugal) have adopted the cigarette and match test for
domestic furniture, while Germany, Italy etc have regulations for furniture in public places only. The non-
domestic furniture in some EU member states only has requirements for cigarette/match tests. We have
not so far found documentary evidence of regulation in the newer Member States and it is unclear if the
European Parliament will introduce legislation for these products.
5.2.1 Observations on Furniture for Specific Countries
Most countries use EN ISO 12952-1 and 2 to regulate ignition by cigarettes in bedding, EN 597-1 for
ignition by cigarettes in mattresses and EN1021-1 and 2 for ignition by cigarettes and matches
9 Sainrat A, Regulatory Trends and Standardization towards the Reaction of Fire or the Upholstery Furniture in
France and in Europe. Proceedings of Fire Retardants 2006, Interscience Publications, London, 2006 10 http://www.see.ed.ac.uk/FIRESEAT/files08/04-Guillaume.pdf E. Guillaume, C. Chivas, A. Sainrat, „ Regulatory
Issues and fire retardant usage in upholstered furniture in Europe
GR241/Defra/2010 30 of 115 November 2010
respectively in seats and coverings for domestic and non-domestic furniture. Specific additional /
alternative test methods used include:
France, Spain and Portugal use NF D 60013 (no ignition by 20g paper cushion equivalent
burner) to regulate seat covers in public places and NF P92501 and NF P92507 (classification
M3) to regulate ignition of seat frames in public places.
France, Spain and Portugal also use GPEM-D1-90 procedures (No ignition by higher ignition
sources) to further regulate fire in mattresses in prisons.
UK makes, in addition, extensive use of BS5852 part 2 1982 (as defined in the regulations),
which incorporates Crib 5 to regulate fire risk from higher ignition sources in filling materials
and interliner fabrics. This is currently the subject of study and a consultation exercise by the
Department of Business Innovation and Skills (BIS) - it is possible that this position may change
in the future.
Germany test seats to DIN 4102
Italy uses DM26/06/1984 and CSE RF 4/83 (No ignition by a 40 mm high fire during 20, 80,
140(s)) to regulate seat and mattress fillings.
Sweden has no specific regulations only recommendations to standard EN tests from the
consumer agency. It did however introduce a partial ban on the use of decabromodiphenylether
in January 200711
.
Norway introduced the Pollution Control Act in 1981, section 1 of which states that “the purpose
of the Act is to protect the outdoor environment against pollution and to reduce existing
pollution and waste.” Also the Product Control Act “to prevent products from causing damage
to health or disturbances of the environment” and in 2004 (amended in 2007) the Greenhouse
Emissions Act “to limit emissions of greenhouse gases in a cost-effective manner”12
. These
acts have been implemented by regulations relating to pollution control, recycling of waste and
the restriction of use of certain chemicals, including some fire retardants such as penta- and octa-
dibromdiphenyloethers. The government has also proposed, but as of 2008 had not ratified,
restrictions on the use of a further 10 fire retardant chemicals.
From a consideration of this information it is clear that the UK has robust furniture fire safety regulations and test methods which make use of historic fire test methods captured in British Standards. BIS is
currently reviewing this position and have recently carried out a consultation on the Regulations and
carried out a reappraisal of the effectiveness of the Regulations and the need for the Crib 5 test13
. This will be used to inform decisions on the future of these Regulations. In contrast, most other European countries
with some niche exceptions, rely upon the General Product Safety Directive.
5.2.2 Nightwear Regulations
The US and some EU countries have specific regulations in place for (children‟s) nightwear. In the EU these are based on BS EN 14878 Textiles - Burning behaviour of children's nightwear and tested to BS
EN 1103 (no surface flash, 520mm trip thread severed in not less than 15s).
11 http://www.kemi.se/templates/News____3803.aspx 12 http://www.sft.no/english/english/Legislation/ 13 http://www.berr.gov.uk/files/file54041.pdf.
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Specific variations are:
The UK uses The Nightwear (Safety) Regulations 1985, which specifies test methods S5722
(1984 and BS 5438 1976 as amended on 30 April 1981) and pre-washing according to BS 5651
(1978)14
. On the whole, the flammability performance requirements of the UK Regulations are
more stringent than in BS EN 14878; however some requirements in BS EN 14878 are a little
more onerous15
.
For example,
- BS EN 14878 requires testing to BS EN 1103, which includes „no surface flash‟, whereas UK regulations do not have such requirement.
- For pyjamas: BS EN 14878 includes two levels of fabric performance for flammability,
dependent upon the garment styling. While these performance requirements are low by comparison with the UK Regulations, they will eliminate the most hazardous fabrics and
design combinations.
- For other nightwear garments such as nightdresses and dressing gowns (but not cotton terry towelling bath robes) the requirements of the UK Regulations are more onerous than
BS EN 14878.
- BS EN 14878 includes a toxicity assessment for all applied fire retardants such as those
which might be applied to cotton fabrics. The UK Regulations do not include any requirements for assessing fire retardants.
The Netherlands uses The Nightwear (Safety) Regulations 1985, tested to NEN 1722 (based on
EN ISO 6941).
Sweden uses KOVFS 1985: 8 using test US 45°/ ASTM D1230
Norway uses the Directive on prohibition of highly flammable textiles and ASTM D 1230
Switzerland uses Verordnung RS 817.023.41; Section 5; Article 16 et seq and EN 1103.
Ireland introduced specific regulations in 1979 (S.I. No. 215/1979)16, to “prohibit the
manufacture, assembly or sale of children's nightdresses unless they comply with the
prescribed flammability requirements of Irish Standard 148: 1966 as amended”. Standard 146
is available from the UCD James Joyce Library17
.
From a consideration of this information it is clear that the UK has robust nightwear safety regulations and test methods in place and The Netherlands has adopted this. Some other European countries seek to
prohibit highly flammable nightwear and related textiles but others rely on the General Product Safety Directive.
14 http://www.berr.gov.uk/files/file25421.pdf 15 http://www.berr.gov.uk/files/file48151.pdf 16 http://www.irishstatutebook.ie/1979/en/si/0215.html 17 http://www.ucd.ie/library/about/branch_libraries/jjl_library/index.html
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5.3 General Product Safety Directive
In the EU, the General Product Safety Directive (GPSD)18
is the primary instrument to protect consumer health and safety with regard to products; it does not consider effects on the environment. The horizontal
scope of the legislation laid down in the directive (2001/95/EC) means that all products are covered unless
specific legislation has been drawn up for a particular product and all member states have incorporated the regulations into their national law. The GPSD specifically lays responsibility on manufacturers to ensure
the safety of their products, chemically and physically in terms of both human health and the environment.
It is important to note: -“the Directive provides a generic definition of a safe product. Products must
comply with this definition. If there are no specific national rules, the safety of a product is assessed in
accordance with:
European standards,
Community technical specifications,
codes of good practice,
the state of the art and the expectations of consumers.”
However, it should also be noted that the GPSD is not displaced in the UK by national safety regulations (i.e. non-EU legislation) made under Section 11 of the Consumer Protection Act 1987. For example, the Furniture and Furnishings (Fire) (Safety) Regulations 1988 do not implement EU legislation and therefore
do not negate the application of the GPSD to furniture and furnishings products.
The GPSD therefore acts as a safety net to prevent the placing on the European market of dangerous
products within the scope of the directive, and particularly,
a) where there are no specific safety regulations in place covering those products;
b) where those products do not comply with national safety regulations; or
c) which, even if they do comply with national safety regulations, are nevertheless considered to
be dangerous19
.
The need for further attention to fire safety in the GPSD has been acknowledged in a report from the European Commission to the European Parliament and Council on the implementation of the GPSD
(2001/95/EC) 20
. It makes direct reference to actions to improve fire related safety and the need to further
address and improve fire safety for residential environments and the trade-offs needed in the use of fire
retardants in relation to fire safety and protection of health and the environmental. In section 3.5.4. on Preparation of Future Standardisation Mandates (on page 12) it states:
“In the area of accidents and injuries due to fires and fires, the Commission continues to develop its
strategy to improve the fire safety of residential environments. The Commission is looking at ways of improving the safety of flammable surfaces and materials used in homes, such as furniture, furnishings,
clothing and TV sets. There are a number of European voluntary standards in this area, but discussions
with the Member States have made it clear that the solutions offered by these standards are not fully satisfactory, especially as far as the use of fire retardants is concerned. A key preliminary step is
therefore to acquire comprehensive knowledge of the chemicals used as fire retardants, with a view to
18 http://ec.europa.eu/consumers/safety/prod_legis/index_en.htm#sect
19 http://www.berr.gov.uk/files/file52889.pdf 20 Report from the EC to the European Parliament and Council on the implementation of the GPSD (2001/95/EC), http://ec.europa.eu/consumers/safety/prod_legis/docs/report_impl_gpsd_en.pdf
GR241/Defra/2010 33 of 115 November 2010
creating a satisfactory trade-off between fire safety and health and environment protection to be reflected
in safety standards”.
5.4 Chemical Safety in Europe
The current primary regulation for all chemical safety, including fire retardants, is achieved through two instruments:
1. REACH (Registration, Evaluation, Authorisation and Restriction of CHemicals) regulation21
(Regulation (EC) No 1907/2006), and
2. CLP (Regulation on classification, labelling and packaging of substances and mixtures)
directive22
(Directive 2006/121/EC and Regulation (EC) No 1272/2008), which regulate and
control the use of chemicals.
Prior to REACH it was the responsibility of member state regulators to carry out risk assessments as part of existing chemicals regulations i.e. the Dangerous Substances Directive 67/548/EEC (DSD), the
Dangerous Preparations Directive 1999/45/EC (DPD), the Existing Substances Regulation (Council Regulation (EEC) No 793/93) (ESR) and the Notification of New Substances Regulations (Council
Directive 67/548/EEC, last amended in 1992 as 92/32/EEC) (NONS). REACH and CLP directly replaces
them, the latter two regulations having been revoked
In contrast, REACH makes industry bear most responsibility to assess and manage the risks posed by
chemicals and provide appropriate safety information to their users.
Under REACH chemicals made or imported in quantities greater than 1 tonne per year must be registered
and their risks to health and the environment evaluated. Chemicals categorised as “substances of very high concern” may be prioritised by member states and added to the Annex XIV candidate list. Their
manufacture, sale or use must either be phased out by an agreed “sunset date” or authorisation sought for
their continued use. The use, sale or manufacture of chemicals posing an unacceptable risk that cannot be adequately controlled will be restricted or banned. The whole process is managed by the European
Chemicals Agency (ECHA), which was created under the REACH Regulation.
CLP was introduced by the EU as part of its commitment to the UN-adopted Globally Harmonised
System of Classification and Labelling of Chemicals23
- (UN GHS). CLP is hazard based and it is
directly applicable to industry; it is legally binding across all member states.
CLP is hazard based and it is directly applicable to industry; it is legally binding across all member states.
It uses a system of warnings and hazards phrases to define intrinsic risks, based on the UN GHS
definitions, which then trigger risk assessment under REACH. The risk assessment is now extended
beyond hazards to health, to include physical and environmental hazards, over the full life cycle of a
product.
21 http://guidance.echa.europa.eu/about_reach_en.htm 22 http://guidance.echa.europa.eu/docs/guidance_document/clp_introductory_en.pdf?vers=24_08_09 23 http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html.
GR241/Defra/2010 34 of 115 November 2010
It should be noted that any criteria that form the basis for Ecolabel awards or which support Green Public Procurement would be advised to align their criteria on chemical safety with that of the new CLP
definitions of risk phrases and hazard statements. Consideration should also be given on the handling of chemical bans within the decisions taken under the operation of REACH in the future. However some
care is required in handling policy situations that may develop over the next 2 to 5 years as REACH
becomes established.
5.5 Chemical Safety Specific to the Electronics Industry
The EU WEEE directive was incorporated into UK law in 2007 as statutory instruments 328924
and (amended) 3454
25. According to the UK Environment Agency “The WEEE Directive aims to both reduce
the amount of electrical and electronic equipment being produced and to encourage everyone to reuse,
recycle and recover it”. In the UK the Restriction of the Use of Certain Hazardous Substances in
Electrical and Electronic Equipment Regulations 2005 (Statutory Instrument 2005 No.2748)26
came into force on 1 July 2006, which restricts the use of hazardous chemicals such as FRs in new equipment.
Together, they put legally binding health and environmental requirements onto EEE product
manufacturers and further pressure to phase out potentially toxic fire retardants.
The RoHS Directive (the Restriction of the use of certain Hazardous Substances in electrical and
electronic equipment) was introduced in the EU in July 2005 and responsibility for its management in the
UK was passed to the National Measurements Office. The UK regulations implement EU Directive 2002/95 which bans the placing on the EU market of new electrical and electronic equipment containing
more than agreed levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl
(PBB) and polybrominated diphenyl ether (PBDE) fire retardants.
Also in July 2005, the European Parliament and Council adopted the final text for the Energy Using Products (EUP) Directive 2005/32/EC. Stevens and Goosey
27 have pointed out that these regulations will
required the industry to make a number of changes in the way it operates. They suggest the following
changes will be necessary:
“restrictions and limitations on the types of materials that can be used in electronics
end-of-life recovery, reuse and recycling requirements for materials including selective
materials recycling
enhancements in the energy efficiency of products, in terms of both the manufacturing
and use phases
adoption of a more holistic approach, embracing all aspects of the product life- cycle
from design through to end-of-life, including recycling and reuse
the adoption of more sustainable business practices which will include materials
sourcing and improved materials stewardship along the supply chain
24 http://www.opsi.gov.uk/si/si2006/uksi_20063289_en.pdf 25 http://www.opsi.gov.uk/si/si2007/pdf/uksi_20073454_en.pdf?lang=_e 26 http://www.opsi.gov.uk/SI/si2005/uksi_20052748_en.pdf 27 Stevens GC, Goosey M, “Materials Used in Manufacturing Electrical and Electronic Products”, Chapter 2,
Advances in Fire Retardant Materials, October 2008. ISBN: 9781420079616.
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the development of new materials that improve product performance and offer greater
ease of recycling and reuse.”
The RoHS directive prohibits the two polybrominateddiphenyl ethers (PBDEs) (pentaBDE and octaBDE).” More recently decaBDE has also been banned despite initially receiving a positive risk assessment for human exposure in a European risk.
In Europe the primary concern for human health is neurotoxicity and for the environment it is the
degradation to lower PBDE cogeners that meet the PBT/vPvB criteria. A definitive decision could not be taken on its risk assessment based on existing information, and so Industry was asked to perform further
studies under pre-REACH EC Regulations.
In parallel, decaBDE came under the scrutiny of the Consumer Product Safety Commission (CPSC) and the Environmental Protection Agency (EPA) in the US. The US EPA listed decaBDE for risk
reassessment under the IRIS programme. However, on the 16 December 2009, the EPA announced that
the three leading suppliers of decaBDE had agreed to a voluntary withdrawal of decaBDE to take place
over a 3 year period. At the time of producing this report it is not known if a similar voluntary action will be taken in Europe.
5.6 US Safety Legislation
5.6.1 Federal Legislation
The CPSC and EPA in the US have federal responsibility for human and environmental health and safety respectively. All of the US Acts have effective European counterparts and the essential outcomes are the
same despite differences in approach. We highlight below the primary federal legislation that is of greatest
relevance to this study. Annexe 1 should be consulted for other information on relevant US legislation.
CONSUMER PRODUCT SAFETY ACT (CPSA) 1972
The CPSA is the over-arching federal legislation that governs products safety in all product areas, much like the EU General Product Safety Directive. The act also set up the US Consumer Product Safety
Commission (CPSC), whose web site (http://www.cpsc.gov/) defines the act as follows:
“The CPSA, enacted in 1972, is the umbrella product safety statute. It established the Consumer Product
Safety Commission, defines its basic authority, and provides that when the CPSC finds an unreasonable risk of injury associated with a consumer product it can develop a standard to reduce or eliminate the
risk. The CPSA also provides the authority to ban a product if there is no feasible standard, and it gives
CPSC authority to pursue recalls for products that present a substantial product hazard.”
The CPSA subsumes and incorporates the FLAMMABLE FABRICS ACT (FFA) 1953
FEDERAL HAZARDOUS SUBSTANCES ACT (FHSA) 1960
The Purpose of the FHSA is clearly defined by the CPSC. In regard to FRs or materials and products containing them the FHSA requires that hazardous household products bear cautionary labelling in
relation to any product that is toxic, corrosive, flammable or combustible, an irritant, a strong sensitizer
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and if the product could cause substantial personal injury or substantial illness during normal handling and
use, including reasonable foreseeable ingestion by children.
The FHSA gives the CPSC authority to ban by regulation a hazardous substance if it determines that the product is so hazardous that the cautionary labelling required by the act is inadequate to protect the public.
CONSUMER PRODUCT SAFETY IMPROVEMENT ACT (CPSA) 2008
The CPSA has recently been replaced by the Consumer Product Safety Improvement Act. The CPSC
defines the purpose of the act as:
“To establish consumer product safety standards and other safety requirements for children‟s products
and to reauthorize and modernize the Consumer Product Safety Commission.”
In addition to the CPSC, the National Fire Prevention Association (NFPA) issues standards and guidance on fire safety, including the following standards and recommendations related to furnishings, fillings and
textiles. The NFPA is a non-statutory, non-profit making trade body, which does not have the power to
enforce standards. They may however be references in Federal or State legislation as legal requirements within any particular act.
5.6.2 US State Legislation
Chemical Safety
The Chemicals Policy Initiative at the Lowell Centre for Sustainable Development, University of Massachusetts 28 has identified 32 acts proposed in the last 6 years to limit the use of particularly
polybromodiphenylethers as FRs. They cover 15 states, 5 acts have been enacted, 5 have been killed off and the fate of the remainder is currently undetermined.
State legislatures also have the ability to enact legally binding “codes”, some of which could be viewed as
contradictory in isolation; an example is the following from California‟s Health and Safety code: Section 13115 (and subsequent sections) states that: “It is unlawful for any person, firm or corporation
to establish, maintain or operate .... unless .... all tents, curtains, drops, awnings and all decorative
materials, are made from a non-flammable material or are treated and maintained in a fire-retardant
condition.”. In addition, section 108922 states that “On and after June 1, 2006, a person may not
manufacture, process, or distribute in commerce a product, or a fire-retarded part of a product,
containing more than one-tenth of 1 percent of pentaBDE or octaBDE ....”.
Fire Safety in Furniture and Bedding
California also has the equivalent of the UK‟s Furniture and Furnishings (Fire) (Safety) Regulations 1988 regulations in the form of the Home Furnishings and Thermal Insulation Act, which is contained in the
California Business and Professions Code Division 8, Chapter 3, § 19000-19221. It established the Bureau
of Home Furnishings and Thermal Insulation which regulates fire safety and testing in mattresses and
proposed for bedding.
28http://www.sustainableproduction.org/proj.chem.abou.shtml
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Thus “On February 16, 2006, the Consumer Product Safety Commission (CPSC), a federal agency,
adopted new regulations beginning at 16 CFR part 1633, that require mattresses, mattress sets, and
futons manufactured on or after July 1, 2007, to resist ignition to an open fire source such as a candle, match or cigarette lighter.” We encourage the industry to use innovative methods and products to
increase fire resistance without compromising the environment. All proposed methods to comply with TB
604 must strictly adhere to state and federal laws.”
Although the regulations do not specifically require the use of chemical FR technologies in furnishing materials (Technical Bulletin 604 (TB 604) is a performance-based standard that does not prescribe the
use of fire-retardant chemicals, pre-determined methods, or specific materials) they do lay down strict fire
safety limits for mattresses (currently) and new proposals for bedding, which can only be attained by the use of retardants.
5.7 Comparison of the UK and US Nightwear Regulations
UK Nightwear (Safety) Regulations 1985, BS EN 14878 and US 16CFR parts 1615 and 1616
BS EN 14878 covers nightwear garments, and fabrics intended for nightwear for babies and
children from birth up to age 14 years only. The UK Regulations apply to nightwear for
children up to age 13 and adults, and all garments for babies. The US standards 16 CFR parts 1615 and 1616 cover sizes up to 6 and 7 to 14, respectively.
UK and US regulations require testing of fire spread. In the UK there is an additional
requirement to test for flash resistance - BS EN 14878.
BS EN 14878 standard has performance requirements for pyjamas and bath robes, as well as a
requirement for a toxicology assessment of applied fire retardant finishes.
BS EN 14878 and US regulations do not require specimens to be tested after washing (except
to assess durability of applied fire retardant finishes). The UK Regulations require all specimens to be tested after washing.
BS EN 14878 includes a toxicity assessment for all applied fire retardants such as those which
might be applied to cotton fabrics. The UK and US regulations do not include any
requirements for assessing fire retardants.
Labeling is compulsory under the UK regulations. Labels must meet strict criteria, including
legibility and durability of test. The US regulations also require labeling with precautionary
instructions. Under BS EN 14878, labeling is optional but if taken, the text to be used is
prescribed.
The General Product Safety Regulations 2005 (GPSR), under which BS EN 14878 can be
used to assess safety of products, apply for the lifetime of the product, i.e. to new and second-
hand products. The UK Regulations do not apply to second-hand garments.
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5.8 Comparison of UK and US Furniture Regulations
In UK the Furniture and Furnishings (Fire) (Safety) Regulations 1988, revised in 1993 cover furniture in domestic environment. In addition Regulatory Reform (Fire Safety) Order 2005 covers fire safety of
furniture and furnishings in non-domestic environments. For both domestic and non-domestic
environments, the furniture/seat and the components, ie upholstery, filling materials, loose filling and covers should pass different flammability tests, hence the regulations prohibit the use of flammable
materials.
In the US standard 16 CFR Part 1634 covers residential upholstered furniture, whereas for bed mattresses there are separate standards, Part 1632 and 1633. The US regulations require the testing of the furniture
product and not the components, hence permit the use of more flammable filling. There is no harmonised
European standard, however member states have different criteria, eg, France has regulation for domestic (N°200-164) and non-domestic (U 23 (Health), AM 18 (Spectacle) and GPEMD1 – 90 (Prisons)); Finland
for domestic (N°743/1990, N°479/96) and guidelines for non-domestic, and Germany for seating in
Cinemas. Sweden and Norway have no regulations but recommendations from consumer agency.
Comparison of the UK, US and European Regulations
The UK Furniture and Furnishings (Fire) (Safety) Regulations 1988 involve all types of
upholstered furniture used in domestic environment, but do not include bedding, duvets,
pillowcases and curtains. The US standard 16 CFR Part 1634 covers residential upholstered
furniture, whereas for bed mattresses there are separate standards, Part 1632 and 1633. No other European countries have regulations for domestic furniture.
The UK non-domestic furniture and furnishing materials are covered by Regulatory Reform (Fire
Safety) Order. The Regulatory Reform (Fire Safety) Order 2005 became law in October 2006 and
introduced significant change to workplace fire safety responsibilities. This has replaced over 70 separate pieces of fire safety legislation, such as the Fire Precautions Act 1971, The Fire
Precautions (Factories, Offices, Shops and Railway Premises) Regulations 1976, Fire Precautions
(Workplace) Regulations 1997 and (amendment) 1999, Fire and Rescue Services Act 2004, etc
with a simple, single Order. It has abolished the requirement for certain premises to hold a fire certificate and instead requires any person who exercises some level of control in any non-
domestic premises to take reasonable steps to reduce the risk from fire and ensure occupants can
escape safely if a fire does occur.
All non-domestic premises, including the common or shared parts of blocks of flats or houses in
multiple occupation are covered by the Order, and may be inspected by their local Fire and
Rescue Authority. The main requirements of the Order are to carry out a fire risk assessment
identifying the risks and hazards, and eliminate or reduce the risk from fire. This also includes using fire-safe products, which pass the required flammability tests.
With regards to upholstered furniture, all furniture must pass the cigarette test, filling materials must be
fire retardant and covers must pass the match test. This is according to the advice in BS7176 and local fire
officers will require the appropriate test certification in place before issuing fire safety certificates. Areas falling outside of BS 7176 : 2007 will still require fire certification and fire officers use codes of practice
to decide the levels of fire testing required.
The Hazard categories contained within BS 7176: 2007 help identify various „hazards‟ posed by the proposed end use. These are linked directly to the ignition sources used for testing. Hazard categories are
provided as a guide ranging from “low hazard” in office and schools to “very high hazard” in prison cells
and include:
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All furniture that meets the requirements is required to be labelled when new with display labels and
permanent labels.
France and Germany have regulations for specific public places. In France regulation U23 (Health) covers bedding (tested to EN ISO 12952-1 and 2) and mattresses (tested to EN 597) for hospitals; AM 18
(Spectacle) for seats (tested to NF D 60013, NF P92501 and NF P92507) at public places and GPEMD1
– 90 (Prisons) for mattresses used in prisons (tested to EN 597-1, 2). Other countries have only
recommendations.
The NHS in UK has also to comply with the Regulatory Reform (Fire Safety) Order 2005. The
Health Technical Memorandum (HTM) 05-03 Fire code – Fire safety in the NHS, Part C: Textiles
and furnishings, provides details of all fire standards that should be used when supplying products
to NHS trusts and healthcare premises.
The UK and US regulations have flammability requirements for seats and separate requirements
for different components (e.g., filling material, upholstery used in the furniture.)
Safety labeling is compulsory under the UK regulations. The US regulations also require labeling with precautionary instructions.
All regulations require no ignition and smouldering by cigarette and in some cases by match. The
UK regulation has the additional Source 5 (or Crib 5) test requirements (within BS 5852:Part 2:
1982) for PU foam fillings/interliner fabrics and flame 2 requirements for other fillings. The US 16 CFR Part 1632 requires cigarette test without and with sheets on them. Part 1633 involves
open fire test, where the mattress is ignited with a propane burner and the heat release rate and
energy released from the specimen is measured.
A recent report commissioned by the UK department for Business Innovation and Skills (BIS) on
the effectiveness of the UK furniture fire regulations29
has confirmed earlier work by Stevens et al
30 on the benefits arising from the and shown that the Crib 5 test is essential to maintaining the
benefits. Currently many products covered by the regulations are fire protected using chemical FR
technologies.
5.9 The Use of Risk Phrases
Risk phrases (regulatory hazard labelling phrases) have been used in many national and international eco-labelling schemes. The EU Ecolabel scheme followed the convention of other schemes, particularly the
German Blue Angel and the Nordic Swan. In reality, the statements which are assigned to the risk phrases
are in fact hazard statements. It is important to distinguish between risk and hazard.
29 http://www.berr.gov.uk/files/file54041.pdf. 30 Emsley AM, Stevens GC, “Risks and Benefits of Fire Retardants in Consumer Products”, Chapter 13, Woodhead
Publishing, 2008. ISBN: 9781845692629. See also, Emsley AM, Lim L, Stevens GC, Williams P, “International
Fire Statistics and the Potential Benefits of Fire Counter-Measures”, PRC/92/2005/EFRA, February 2005; and,
Emsley AM and Stevens GC, "Effectiveness of the Furniture and Furnishings (Fire) (Safety) Regulations 1988," for the Department of trade and Industry, URN 00/783, June 2000 (49 pages)
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The most commonly used definition of a hazard is that associated with any source of potential damage,
harm or adverse health effects on something or someone under certain conditions. Risk on the other hand
is defined as the chance or probability that harm, damage or adverse health effects will ensue if exposed to a hazard. Risk phrases therefore do not take into account the likely exposure to a hazard and the
corresponding dose response. Because of the lack of risk assessments on individual chemicals used in
products throughout the life cycle of the product and even more so, risk assessments on combinations of
chemicals used in products, ecolabels generally use the a precautionary approach when defining certain Ecolabel criteria. Risk phrases have therefore continued to be used when defining chemical criteria for
additives used in a variety of products. R-phrases are defined in EU Directive 67/548 relative to
classification, packaging and labelling of dangerous substances and are applicable to all chemicals which represent a risk for health or for the environment.
EFRA31
has made the point that these R-Phrases were adopted for the manufactured chemical and are not
suitable for the purposes of use in products that might contain dilute or small quantities. R-phrases take no account of exposure, and thus risk to the environment or to human health through the use of the chemical
in consumer products.
In December 2008 a discussion paper entitled “The path to sustainable use of chemicals in products: The
European Ecolabel as a signpost”32
was published by The European Environmental Bureau (EEB)33
and The European Consumers‟ Organisation (BEUC)
34 with contributions by The Oeko Institute e. v.
35. This
discussion paper recommends that R-Phrases should continue to be used in the Ecolabel scheme but also
harmonise with the Global Harmonised System of Classification and Labelling of Chemicals (GHS)36
.
5.10 Green Procurement Policy in Europe
In 2005 the European Commission published a communication37
outlining the need for EU Member States
to implement National Action Plans (NAP) for developing Green Procurement Policies (GPPs). A list of
European Public Procurement Legislation has been provided by the European Commission38
. An update of National Strategies for Green Procurement is available
39. These NAPs are non-legally binding but do
allow Member States to raise awareness of greener procurement of sustainable products.
The EU has developed GPP guidelines for the benefit of purchasing officials and companies wishing to tender for contracts. Of the 10 product groups that have been established, office IT equipment
40 and
textiles41
products are relevant to the current study and include statements regarding fire retardants. In all
cases if the product has obtained the EU Ecolabel then it will automatically comply with the procurement
policy. Other so-called Type 1 Ecolabels are also acceptable.
31 EFRA position paper on fire retardants and Ecolabel 32 http://www.eeb.org/publication/2008/Dec08-Ecolabel+Chems-FINAL.pdf 33 http://www.eeb.org/ 34 http://www.beuc.org/Content/Default.asp 35 http://www.oeko.de/home/dok/546.php 36 GHS 3rd Revised Edition July 2009 37 (COM 2004) 38 Final 28th January 2004 “Stimulating Technologies for Sustainable Development: An
Environmental Technologies Action Plan for the European Union”;
http://eur-lex.europa.eu/LexUriServ/site/en/com/2004/com2004_0038en01.pdf 38 European Public Procurement Legislation (Website Update 06-10-09) 39 National Strategies for GPP 40 EU GPP procurement criteria for office IT equipment 41 EU GPP procurement criteria for textile products
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6 Global and European Fire Retardant Market
6.1 Europe, USA and Asia
According to a survey carried out by SRI Consulting42
, the total market for fire retardants in the United States, Europe and Asia in 2007 amounted to about 1.8 million metric tons, Figure 1, and was valued at
$4.2-4.25 billion,
Figure 2. This market was expected to grow at an average annual rate of about 3.7% per year on a volume
basis over the period 2007-2012.
Figure 1 Volume consumption of fire retardants in the USA, Europe and Asia
Data Source: SRI Consulting
In terms of tonnage, brominated FRs are second only to the inorganic compounds such as ATH, although
this is totally due to the large use of these compounds in Asia. Brominated fire retardants do, however, have the greatest market value.
42 SRI Consulting Report on Fire Retardants Published December 2008
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Figure 2 Value of fire retardants worldwide
Data Source: SRI Consulting
6.2 Europe
With regard to the European Union (EU-25), an EFRA43
members survey carried out in 2007 gave an
estimated consumption of fire retardants for 2006 of about 465,000 tonnes. The breakdown of FR types is
shown in Figure 3. From the SRI study which captured volume consumption in 2007, the tonnage was
estimated at 580,000, which is approximately a 25% increase on the 2006 data produced by EFRA. The SRI study also gave a breakdown of consumption for the Western European countries (EU-15) and the
Eastern European/Russian countries of 530,000 tonnes and 50,000 tonnes respectively.
43 European Fire Retardants Association
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It was expected that the Eastern European countries would have a greater increase in consumption than
the Western European countries over the period 2007-2012 due to rising safety standards and
harmonization with EU legislation.
The largest fire retardant category in terms of EU tonnage is that associated with inorganic compounds
such as aluminium hydroxide (ATH) and magnesium hydroxide (MDH). These compounds may generally
be used in combination with other fire retardants including synergists such as antimony trioxide and zinc
stannates, all of which are classified as “additive” fire retardants. Under some new EU Ecolabel criteria for textiles and electronic products this group of additive fire retardants would not be acceptable, despite it
accounting for the majority of fire retardants in use.
Figure 3 Types and proportions of fire retardants used in the EU-25 in 2006 44
Data Source: EFRA Members Survey 2007
A study by TN SOFRES45
Consulting with parts published by EFRA the quantity of plastics used in electronic and electrical products in the EU totalled 1.45 million tonnes in 2004. Of this, 30% (450,000
tonnes) had some form of fire retardancy applied. The proportion of this group that was halogenated FRs
was estimated at 41% or 186,000 tonnes,
44 – note: Melanine-Based should read Melamine-Based
45 http://www.tnsglobal.com/
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Figure 4.
There is no doubt that the use of fire retardants will increase in the future but because of an increasing awareness of potential human and environmental impacts throughout the complete life cycle of fire
retarded products, it is likely that the consumption profile of the various FR types will change
significantly reflecting growing pressure for the banning of brominated compounds and halogenated
compounds in general. This of course will be balanced by more demanding national and international fire standards and regulations.
Growth rates for the individual groups of fire retardants vary widely, between 5% growth (ATH, MDH,
APP, zinc stannates, melamine derivatives) and 5-10% decline (TBBPA/ATO), depending on developments in government regulations, replacement of one (halogenated) fire retardant chemical by
another (non-halogenated) compound, and new product applications.
Figure 4 Halogenated fire retardants used in electronic and electrical products in the EU
Data Source: Presentation at the “Where are WEEE going” workshop, Antwerp October 2004
6.3 Fire Retardant Manufacturers and their Product Ranges
Over the last few years, there has been increased activity in mergers and acquisitions of companies
involved in the manufacture and production of speciality chemicals. The impact of existing and new legislation in fire protection and also new legislation with respect to chemicals and the environment has
caused some companies to alter their strategic outlook. In particular, large companies manufacturing
products that contain furnishing fabrics such as IKEA has a policy of not having any brominated fire retardants in any of their products. Similarly, the automotive industry is looking to eliminate halogenated
fire retardants from car interiors and companies such as Apple, Hewlett-Packard, IBM, Motorola,
Panasonic and others are aiming to completely eliminate bromine-based and other halogenated fire
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retardants from their electronic and electrical products. The perceived non-environmentally acceptable use
of these fire retardants has caused the speciality chemicals companies to branch into new systems and/or
challenge the environmental positioning of the end users.
Annexe 3 provides a detailed commentary on the FR products manufactured and sold by the primary FR
producers globally. This includes:
• The Thor Group
• Schill + Seilacher Aktiengesellschaft • Trevira fire retardant textile yarns
• Clariant Pigments and Additives Division
• Avocet Dye and Chemical Company Ltd • Albermarle Corporation
• Avocet Dye and Chemical Company Ltd
• Joseph Storey & Co Ltd (part of Petroferm) • William Blythe Ltd
• Budenheim Ibérica
• Chemtura Corporation
• Rhodia • Huntsman
• ICL Industrial Products
6.4 Market survey
6.4.1 Objectives
The market survey set out to determine which fire retardants are used in products available to UK
markets, across all sectors. This included establishing which chemicals are used, how many companies are handling products containing fire retardants, what level of these are additive and obtaining stakeholder
opinion on effects of restricting these sort of fire retardants for Green Public Procurement policy (GPP),
on supply chains and market structure. It also evaluated level of awareness of the EU Ecolabel, the
Flower, across relevant sectors.
6.4.2 Scope
The study focused on the same product groups as those featured in the overall project. This includes textiles such as soft furnishings, mattresses, nightwear and personal protective equipment (PPE), and
electronic equipment including TVs, laptops and personal computers (PCs).
6.4.3 Methodology
There are numerous products in the UK containing fire retardants, and the initial task involved selecting
manufacturers, suppliers, trade associations and retailers of these products to interview. An initial internet search, combined with the in depth knowledge of industries operating in these areas provided a list of over
100 companies to contact. These were telephoned, and then followed up with either an arranged
telephone interview, or emailed questions regarding current fire retardant use, potential to adapt to non additive use only, and awareness/opinion of the EU Flower Ecolabel.
6.4.4 Participation
A total of 116 companies were approached, the majority being manufacturers, but input was also taken
from suppliers, retailers and trade associations. Forty seven responses were given, though these were not
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equally distributed across all sectors, with PPE representing the largest responding group. Of those that
responded, 60% use fire retardants somewhere in their products.
Figure 5 Respondents using fire retardants
Due to uneven representation, however, this should not be viewed as typical across the sectors; for example, all electronics manufacturers used fire retardants, though fewer respondents in this sector replied
than in textiles.
It is worth noting that fabric manufacturers addressed multiple product markets such as fabrics for nightwear and PPE, or mattress covers and upholstery. In some areas the respondent number was inflated
due to the inclusion of the additional „textile other‟ stakeholders who may have commented.
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6.1 Survey Findings
Overall, companies were largely poorly informed or did not have a good understanding of how to find out
information/ who was responsible for the fire retardant use. In particular, those further along the supply
chain seemed to have little awareness of what chemicals were used, and as long as flammability
regulations were met, and certificates provided, many believed they had no further responsibility.
Companies using additive fire retardants were typically using a range of both additive and reactive – often
with inherently fire retardant fabrics used as a first option. Several applications required the use of both,
sometimes acting in combination with each other.
Figure 6 Types of fire retardant used by respondent companies
6.1.1 Textiles/mattresses
The range of applications for fire retardants in textiles is wide, with the key areas being protective or workwear, children‟s nightwear, foam (for use in furnishings etc), mattresses and soft furnishings. In
general however, there was typically a fairly good awareness of the Ecolabel, and good feedback with regards to potential applications.
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The prospect of removing additive fire retardants in order to comply with Ecolabel criteria (or for GPP)
was felt to be highly restrictive, even not technically possible, for certain applications.
Technical feasibility
Several textile companies responded that they use inherently fire retardant materials in preference to
chemical fire retardants. For children‟s nightwear in particular, two companies highlighted customers
concerns for children‟s health, and problems with allergies/rashes being caused (realistically or perceived
to be is uncertain) by proximity to material treated with fire retardant chemicals. Similar reasons were given by one mattress manufacturer and a fabric supplier. In all such cases, a specific fire retardant could
not be named, and evidence appeared to be very anecdotal.
A large department store has restricted the use of fire retardants in children‟s nightwear, with the simple explanation of „toxicity‟, and a second, large supermarket had also restricted fire retardant use in similar
products, due to concerns of skin irritations. Whether these stances are based on real, or even current,
issues, could not be determined. In a separate interview, an expert in fire retardant use in textiles iterated frustrations at emotive media portrayals of dangerous chemical use – citing articles that are several years
out of date, and referring to substances that are banned, still being circulated and causing unnecessary
apprehension in retailers who are not necessarily informed of recent information.
Most textile sectors did seem to have alternatives to chemical fire retardants available, with examples found in mattresses, upholstery and nightwear. The PPE (personal protective equipment) sector does
produce garments composed of inherently fire retarded materials, such as Kevlar, but these were felt to be
unsuitable for all applications. Kevlar, for example, was said to have little UV stability, and textiles used for webbing and narrow fibres would not be reliable being produced from this style of fabric. Reactive
fire retardants are suitable for several PPE applications, with Proban the most commonly used in this
sector. Highly specific PPE applications, for example aluminium smelting, however, can be more
difficult. Due to the characteristics of this work, only specific fire retardants can be used.
One manufacturer of PPE found the concept of changing to reactive fire retardants only, particularly
concerning: -
„There are too many industries to supply, with too wide a range of needs. Additive may be more suitable for certain applications - product A won‟t fit product B, which won‟t fit product C, just to meet
sustainability criteria.‟
The key exception, where no viable, currently available technologies are believed to exist, is polyurethane (PU) foams.
Degree of Choice
For nightwear, the alternative options are numerous and easily available, simply replacing cotton with
polyester, for example, will meet many flammability regulations. Other applications however, have a far greater likelihood of encountering fires or flammable substances, and as such need more protection.
There are also additional characteristics – such as tensile strength and durability – which need to be taken
into consideration. PPE gives several choices of both inherently fire retardant materials such as Kevlar and Nomex, as well as reactive fire retardants.
PU foam is the single textile application where there appear to be no alternative options than additive fire
retardants, available on the current market. A foam industry stakeholder stated
„While a few chemically reactive fire retardants are available (to the foam industry) they are in
themselves inadequate for levels of fire safety such as those the UK has in place. Chemically reactive
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substances are used on a very limited basis in combination with additive fire retardants which remain
pivotal to (meet) UK Statutory Instruments.‟
It was also noted, that whilst research in this area is ongoing, there is no technology that has passed, or is near to passing, the stringent testing processes and likely to come onto the market in a commercially
viable manner, in the near future.
It is also worth acknowledging, however, that foam is not the only available filling method, and two
mattress manufacturers were interviewed, that do not require the use of fire retardants at all, through the use of improved design and use of inherently fire retardant materials.
Cost of Implication
For nightwear, fire retardants are not in such wide use as other areas, due to other concerns discussed above. The alternative fabric choice and availability reflects in the cost, and no financial concerns were
highlighted for sleepwear.
Several members of the PPE industry indicated concerns of cost increase for „everyday‟ PPE (i.e. not including those niche applications, or the very heavy protective wear). Additives were felt to be a cost
effective way of meeting flammability regulations, though reactive were available to most. However,
even one industry member unofficially emphasised the worry that restriction of additive fire retardants
may result in competitive disadvantage against non-EU manufacturers.
In niche PPE applications, one manufacturer expressed a concern over reliance on inherently retardant
materials, which are significantly more expensive. This was felt to potentially encourage companies to
„duck the issue‟, or in the case of GPP, simply cause purchasers to disregard policy in place of financial aspects.
Ecolabel Awareness
The textile industry generally had a good awareness of the Ecolabel – with 78% of respondents
recognising the certification. The general concept was well received, and a „single – stand alone‟ label that considered whole life was regarded as most beneficial. However, managing the often large and
complex supply chain and customer/public awareness was a concern of many.
No company considered the EU Ecolabel the optimal ecolabel to use, with Oeko-Tex® (Standard 100) mentioned on several occasions. In particular, PPE manufacturers were well aware of the Flower (82%
recognition from those who responded), but rated Oeko-Tex® highly, with 50% of PPE manufacturers
suggesting they used it, or were more likely to use it, without prompting. This was typically due to customer drive, and therefore marketing for future sales. The EU Ecolabel was not perceived to be a well
recognised tool for sales to the general public, yet was considered to be one of the more difficult to obtain.
Oeko-Tex® was considered a sufficient environmental standard, which created challenges to obtain, but
was achievable.
The furniture industry was hesitant regarding the use of reactive fire retardants only. This was felt to have
been a barrier to application to the Ecolabel previously. However, should this become a selection criteria
for GPP, it was felt strong resistance result to the policy.
Foam industry members were strongly against the reactive only criteria for Ecolabel, and suggested it
would act as an absolute barrier to their application for certification. It was suggested by one industry
member that this stipulation created inequality for different products, stating:
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„{The Ecolabel restriction of additives in foam} does not bring about fair levels of „sustainability‟ across
different CMR (carcinogenic, mutagenic and toxic to reproduction) substances being Ecolabelled - e.g.
carcinogens in hardwood.‟
Both respondents also stressed that the method of using reactive versus additive criteria was not a
scientifically sound method of testing sustainability.
6.1.2 Electronics
Fewer responses were received from the electronics sector, with only five companies giving useful detail. Each of those who did respond, however, carried a range of products which contained fire retardants.
Unlike the textiles sector, none of the organisations offered fire retardant free products.
Getting information was more difficult for this sector; particularly as very little manufacture is carried out
in the UK, or often the EU. Approaching overseas head offices received little in way of response, and UK
representative offices were typically offering sales advice only. The knowledge and understanding of the Ecolabel, however, was higher than within the textiles sector, with each organisation being aware.
Technical Feasibility
Fire retardants used in electronic products are more numerous than in textiles, with different chemicals
needed for the varying components. Only one company was uncertain if additive fire retardants were
used in their products, with two reactive chemicals used for the PWB and cables, but various used for
components. Typically most products used both additive and reactive fire retardants, though televisions were seen to require higher levels of additive (and fire retardants in general) than laptops.
The use of R-phrases was generally an accepted method of determining environmental safety issues,
though it was highlighted by two companies that the specific chemicals (and specific fire retardant groups, e.g. brominated) should be targeted more than additive R phrases. Should all additive retardants be
restricted (in the same way as in textiles), significant difficulties were anticipated.
Degree of Choice
The electronics sector seemed to have less understanding of alternative fire retardants , although this is
largely due to the wider range of chemicals used and more complex component composition within the
product.
Cost of Implication
Additional cost of compliance with Ecolabel criteria was not felt to be significant. One large company stated the additional costs of adherence were low enough for absorption by themselves, with no additional
cost to customer. However, it was noted that this might not be as possible for smaller manufacturers.
Ecolabel Awareness
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All companies interviewed were aware of the EU Ecolabel and its Flower logo . While awareness was
100%, the overall opinion of the label was fairly weak. It was considered that more emphasis in the
electronics industry is placed on energy labels, and consumers within the UK were not familiar with it as a purchasing incentive. One organisation iterated;
„Until the profile of the (EU) Flower is raised, it will have no influence on company practices‟.
Another organisation, who manufactures several Ecolabel products, was uncertain about the effectiveness
of any label for this subcategory of products;
„Customers in the UK are driven by touch, and look of products such as televisions and computers.
Ecolabelling is more effective for less aesthetic product categories, such as white goods‟.
The issue of additive fire retardants being subject to risk phrases, whilst reactive are not, caused some mixed opinions, with one chemical company suggesting that the same restrictions should be placed on
both, ensuring the risk is non existent.
6.1.3 Chemical industry
The general feel by fire retardant manufacturers interviewed was that whilst the general notion of the
Ecolabel was a valuable one, the exact details of exclusion were perhaps not as well defined as they could be. One manufacturer producing both reactive and additive fire retardants felt the products they produced
were environmentally sound, and the emphasis should be taken away from additive automatically being
unsustainable. Individual chemicals should be excluded, or groups such as those containing bromine,
heavy metals or antimony. This was an issue iterated by several other stakeholders also, with several Ecolabel restricted chemicals (for textiles/foam) considered „non-harmful to environment or people‟.
6.1.4 Products without fire retardants
In all of the textiles subsectors, barring PU foam, examples were found of companies producing products
with flammability regulations adhered to by means other than the use of chemical fire retardants. These
were discussed in individual sections, but all were due to one or both of two factors – inherently fire retardant material, and improved design.
The flammability of fibres and fabrics varies greatly, with the natural cellulosic fibres in cotton, for
example, offering little resistance, whereas synthetics such as aramids often self extinguish. The degree of adherence to flammability regulations from these intrinsic characteristics varies depending on end
application, but the most common fabric flammability hierarchy is shown below:
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Cotton/linen
Rayon/lyocell
Acetate
Acrylic
Nylon, polypropylene, polyester and spandex46
Wool and silk
Modacrylic and saran47
Aramid, novoloid and melamine
Several nightwear brands met flammability regulations by using polyester. One mattress manufacturer
used wool, cashmere and silk mixes to fill their products, reducing the need for chemicals. Another
supplier to the mattress industry did use fire retardants in some products, but offered more unusual alternatives such as animal hair. These alternatives could be fairly expensive, however.
The second method of avoiding fire retardants is design, though this tends to be alongside the use of
inherently fire retardant materials. Using mattresses as an example again, one company who specialise in
organic beds, carried out three years of research to create processing methods for wool, to recreate the textures available with foam and other mattress fillings. They also re-evaluated the typical design of a
mattress in order to overcome flammability issues. In a common mattress the top and side panels are
fixed together using a tape machine. This causes a ridge around the edges of the product, which requires cotton stripping and over-sewing – and becomes one of the key areas tested for flammability regulation
certification. By redesigning the construction, a new mattress was produced without the ridge and
therefore with less problem areas for flammability.
6.2 Survey Conclusions
Outside of the chemical industry, companies were generally poorly informed of the fire retardants used
within their products, particularly those at the later stages of the supply chain. There was little awareness
of who was responsible or even which department should be approached. There was also a strong feeling of limited responsibility bar the passing of safety regulations; as long as a company was certified, little
attention was given to the actual chemicals used.
46 Spandex is a polyurethane-polyurea copolymer (invented by DuPont). Other names used are Lycra or Elastane. Also available
as a flame retardant elastomeric composition comprised of either spandex type polyurethane having incorporated into the polymer chain halogen containing polyols or conventional spandex type polyurethanes in a physical admixture with flame retardant additives or fluoroelastomeric resins in physical admixture with flame retardant additives
47 Saran is the trade name for a number of polymers made from vinylidene chloride (especially polyvinylidene chloride or PVDC), along with other monomers. Saran is a registered trademark of the Dow Chemical Company.
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In contrast, some companies took a very cautious approach, for example, banning fire retardant use
altogether in children‟s nightwear or in mattresses. This was accomplished using inherently retardant
fabrics and incorporating innovative design into products at the point of conception. Whilst not suitable for all product groups, and currently only limited examples are available, this could be an approach worth
investigating further.
The exclusion of “additive” fire retardants was generally not well received across the sectors, or at least
not without exclusion options for certain applications – in particular PU foam. It was also apparent that several stakeholders were not convinced of the suitability of this approach as a way to determine
sustainability, or define environmentally harmful substances. R-phrases were well accepted, and, for
textiles at least, selection factors more in line with the Oeko-Tex Standard 100 were felt to be preferable.
Awareness of the EU Ecolabel Flower was generally good, though not necessarily by individuals (several
interviewees had not heard of it but found their company had looked into it). The soft furnishings
industry had the least recognition of the Ecolabel, with the electronics industry having the greatest awareness, with all companies interviewed having prior knowledge of it. The actual criteria for fire
retardant use was, however, poorly understood for most sectors, and little comprehension of „additive‟ or
„reactive‟ as descriptive terms was apparent.
The use of the Ecolabel was theoretically applauded, but many companies felt the profile is not yet strong enough for any real influence on consumer behaviour, and therefore, on company behaviour. It was noted
that the use of the Ecolabel in GPP, would quite probably change this, and therefore it is important the
exact factors used for criteria are effective now.
7 FR Technology Survey
7.1 Survey Structure and Participation
The FR Technology survey reported in Annexe 3 sought to provide insight into the key chemical fire
retardant technologies used in the consumer products of interest and alternative non-chemical fire retardant technologies currently used in different products in the UK and EU and to identify emerging
chemical and non-chemical technologies. Product manufacturer‟s awareness of and views on the EU
Ecolabel scheme and FR related criteria were also sought in a separate survey.
The FR technology survey contacted 400 organisations from a wide range of fire retardant producers,
product manufacturers, trade associations and other stakeholders were invited to participate in the survey
and to make other organisations aware of the survey. The key findings of the survey are reported in Annex 3. The total number of people who started the survey was 101 but only 57 submitted completed forms.
The others left the survey or did not continue after registering. In all cases this followed the participants
visit to the page containing Defra's confidentiality statement.
Those who completed the survey consisted of:
1. Fire Retardant Producers 15
2. Product Producers 24
3. Others Stakeholders 18
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7.2 FR Producers
7.2.1 Supply of FRs
The chemical FR technology represented by responding FR producers were in order of priority:
Phosphorous based
Inorganic and Polymeric
Organic - Brominated and Chlorinated.
It should be noted that a number of phosphorus FRs contain chlorine and a number of polymeric FRs are
brominated.
Other types not listed included:
Chemical FRs for fire/ explosion suppression,
Nitrogen based and
Reactive fire retardants.
EBFRIP indicated that their member companies produce all types of brominated FRs, some of which are
polymeric. Respondents did not qualify what they mean by “Reactive” or “Polymeric” so we rely on the
definitions provided in the survey guidance.
Most of the fire retardant producers who participated in the survey individually produce more than 1000
tonnes. The major FR types are supplied in solid form, but one company respondent indicated that they
also produced Br-based and polymeric additives in liquid form.
Most companies indicated that their FR particles size was greater than 1000nm and only a few indicated
that their products are nano sized with just two reporting particle sizes less than 10nm.
There is no clear indication as to whether the organic and polymeric fire retardants are mixtures with other
functional FRs and synergists which may be organic or inorganic.
7.2.2 FRs in Consumer products
FR producers supply FRs to all of the structural components used in furniture; mainly foam followed by coverings. 5 producers also supply to the nonwoven felt and interliner markets.
The major application of FRs in textiles is in backcoating, followed by fabric treatment. Other
components listed were vinyl coated fibre and woven fibre and finishing. In one case this includes FRs supplied to the transportation sector including automotive.
Two respondents in the consumer electronic products section indicated that virtually all electronic and
electrical products including wires, cables and connectors are treated with fire retardants Most FR producers supply FRs to all of the equipment considered in the survey. Others that were specified by
respondents include mobile phones, MP3 players, connectors, printed circuit boards, transportation,
including automotive coating and instrumentation for cooling applications.
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7.3 Product Producers
The greatest number of producers who responded was textile manufactures followed by furniture and consumer electronics producers. This is in line with the level UK and European manufacturing in these
sectors.
Furniture 8
Textiles 12
Consumer Electronics 5
No nightwear producers participated in the survey. However, two participants did complete the textile section in relation to nightwear. One of them claimed production of all the categories of nightwear while
the other, who suppliers textiles to the furniture industry, also indicated that they produce synthetic fabrics
for nightwear.
Furniture producers use FRs in all of their components: foam, covering, frame, mattress filling,
nonwoven felts and interliners.
Textile producers use FRs in all the primary components: fibre, fabric, backcoating, chemical finishes
and lamination.
Consumer electronics producers use FRs in all of the products considered here with the leading product
being LCD TVs. Portable computers came next followed by equal numbers of desktop computers,
monitors and plasma TVs. This is line with findings from the FR producers.
7.3.1 Fire retardant technologies used in products
Respondents were invited to read the definition of the list of technologies presented. These were:
Fire Retardant Technologies
Chemical FR (bulk addition)
Inherent FR Fibre
Barrier layer
Intumescence
Product Design
Melt blending
Solution blending
Chemical finishing
Chemical Fire Retardant Technologies:
Additive
Reactive
Bromine based
Chlorine based
Phosphorus based
Intumescents
Organic
Inorganic
Polymeric
Nano
The technology most used is bulk addition of chemical FRs. Barrier layer technology is the next most
popular followed by inherent FR fibres.
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“Additive” chemical FR technologies are the most commonly used with phosphorus based FRs second
and equally popular in furniture and electronics. The furniture industry seems to use the full range of the
technologies listed except for nano.
Textiles scored highest with additive technologies but again this product set uses the whole range of
technology listed except for nano. Similarly, the electronics sector scored on all the technologies except
for intumescents and nano.
The general conclusions are summarised in the following table:
Application Most popular Second most
popular
Third choice
Technology
types
furniture and
textiles bulk addition barrier layer
inherent FR
fibre
consumer electronics
bulk addition
product design,
melt blending and
barrier layer
FR types
furniture and
textiles
“Additive” chemical FR
technologies
phosphorus based FRs
consumer
electronics
“Additive” chemical FR
technologies
phosphorus based FRs
7.4 FR Technology Costs
7.4.1 Current Technologies
Actual Cost per Product Unit
Participants were asked to specify the costs, either actual or estimated, for each single unit of product (i.e.
a single item or for 100m of textile) they produced. Eleven respondents answered this question; about two
thirds of them quoting in £ pounds while the rest in € euros.
For Actual Added Cost per unit, the largest response was in the range € 21-50 for furniture. The next highest category was between €.0-1 for consumer electronics. There were no respondents claiming costs
greater than €50 per unit. The major technology used in both cases is brominated-FR (we assume in many
cases that ATO is also present as a synergist).
For Estimated Cost per unit the largest response was the range €2-5, with fewer in the ranges €0-1 and
€6-10. Both chemical FR bulk addition and chemical FR phosphorus based were identified as major
technologies in the estimated costings.
The majority of respondents claimed that the extra cost per unit of their product to be greater than 10%, where bulk addition, bromine based and phosphorus based were identified as the major FR technologies
used.
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7.4.2 Future FR Technologies
Participants were requested to provide information on their estimated cost for future fire retardant technologies specifying Actual Estimated Cost, Estimated Expected Cost and Estimated % Additional
Cost for the whole product.
The main FR technologies identified in this section were chemical FR bulk addition and chemical FR phosphorus based technologies which are now cited more than brominated FRs.
For Expected Cost per product: all the participating product producers indicated € 0-1 only. These were
for bromine based, bulk addition, and phosphorus based and chemical FR polymeric technologies.
The Estimated Expected Costs were generally higher than the Actual Expected Costs; 50% of the respondents indicated € 2-5 per unit product followed by 40% at € 0-1. The other 10% indicated € 6-10.
The higher cost may reflect uncertainty and caution when estimating costs.
The Estimated Percentage Addition to product cost reflected closely the Estimated Expected Costs in the FR technologies. The majority of product producers indicated 0-0.2% addition to their cost of product
using future technology based technologies also featured.
7.4.3 Some comments on costs
One respondent commented that there is the potential for increased costs to their company resulting from the loss of certain retardant technologies arising from legislative concerns.
One participant from a trade association commented that he is completely unaware of any emerging
technology that will render flexible PU foam compliant with UK flammability requirements. He stated
that should innovators believe they have appropriate technology, it is important to establish not just
economical viability but independent verification of compliance with current UK ignition resistance legislation and equivalent or better post-ignition characteristics. He concluded that it would also be
important to verify other performance standards such as durability and acceptable HSE profile.
7.5 Ecolabel Response from the FR Technology Survey
There is a requirement in the current Ecolabel criteria for textile products, which include clothing, bed linen and indoor textiles and other products containing textiles such as furnishing fabrics, that no additive
FRs are permitted, only reactive fire retardants are allowed.
As shown in the response count below, the majority of respondents consider that this Ecolabel criterion is too restrictive and a barrier to applying for an Ecolabel. About 14% thought it sensible while about 11%
thought it was an effective way to reduce environmental impact.
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This section of the survey provoked the most comments from respondents. Some of these are summarized
below:
• The criteria do not distinguish between mono molecular and polymeric additives.
• It is better to have inherently fire retardant materials
• This participant‟s fire retardant is non hazardous and has no environmental impact
• There is confusion in the understanding of the definition of “reactive” between the ecolabel
regulators and the textile industry. The regulatory requirements for fire protection in the UK and
Ireland cannot be achieved for any products granted an ecolabel. Therefore the ecolabel system
for textile products will not be usable in these countries.
7.5.1 Ecolabel for Electronic Products
In contrast to textiles and furnishings, the Ecolabel criteria established for electronic products, which include personal computers, portable computers and TVs, the use of fire retardants is restricted by certain
Risk Phrases, but both additive and reactive fire retardants are allowed.
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Again, as shown in the response count, the majority of respondents were of the opinion that the current
Ecolabel criteria requirement for electronic products is too restrictive and a barrier to applying for
Ecolabel. About 22% thought it sensible while about 11% thought it was an effective way to reduce environmental impact.
The main contributed comments in this section include:
• the need to distinguish between mono molecular and polymeric additives is not in the criteria.
• FRs should be assessed through a consistent comparative hazard assessment framework.
• both additive and reactive FRs should be permitted.
Comments were also made that the list of R-phrases is too restrictive and that they relate to hazard and not risk. There was concern that account had not been taken of the classification and labelling status of current
commercial FR technologies - this was cited as a reason why ecolabel requirements cannot be achieved
for most commercial FR systems.
7.5.2 Ecolabel for Bed Mattresses
In the criteria established for bed mattresses, there is a requirement that no additive fire retardants are used in PU and Latex foams. Only reactive fire retardants will be allowed.
The majority of respondents were of the opinion that the current Ecolabel criteria requirement for bed
mattresses is too restrictive and a barrier to applying for Ecolabel. About 8% thought it sensible, the same number thought it was an effective way to reduce environmental impact.
7.6 Some Respondent’s General Comments
• There is no commercial system which can meet the ecolabel criterion for foam, because the ecolabels regulators (Commission and the EUEB) seem to have a definition of “reactive” which is
different from that used normally in the industry, and this may have led to confusion.
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• The confusion over the definition of “reactive” also means that the regulatory requirements for fire
protection in the UK and Ireland cannot be achieved for any bed mattresses granted an ecolabel.
Therefore the ecolabel system for bed mattresses will not be usable in these countries.
• “Totally ill-conceived and impractical. No science has been presented in support of the new
requirements, and because decision making lacked manufacturing industry consultation there is a complete un-awareness of what is industrially realistic. The new eco-label rules now exclude
substances shown to be risk-free to consumers and environment. If fire retardants are now required
to be chemically reactive why does the same not apply to all other substances in eco-labelled articles and why are naturally occurring CMR substances allowed to be present in naturally sourced
products?
FIRA International Ltd
Effectiveness of the current domestic regulations.
The UK has the most stringent fire safety requirements for furniture in Europe, but they have been proved
to be truly effective in saving lives and are fully supported by the industry.
It estimated the effectiveness as saving 54 lives per annum (780 fewer non fatal injuries) and 1,065 fewer
fires. This equates to a monetary saving of £140 m per annum. 60% of this saving was attributed to the
fire retardants used with the fabrics 48
.
Environmental effects of fires
The environmental impact of fires would increase if less effective fire retardants were used.
Not only is there an environmental impact in terms of CO2 emissions from the fire itself, but then also the
additional impact of re-building/re-furbishing the buildings affected.
Fire retardant types
FIRA would recommend that fire retardant coatings are not used, as they can either be washed off,
affected by cleaning or wear, and thus have their effectiveness reduced.
International Antimony Association
“Antimony trioxide has an R40 phrase because of the potential risk via inhalation of the fine particles
during production of the antimony trioxide itself. Once it is encapsulated in the resin (masterbatch form) and sold to the plastics or textile industry, the EU and OECD experts all concluded that there is no risk
whatsoever”.
48 Note that the report for BIS actually states that of the estimated benefits “50% was attributed to the cigarette test;
10% to the match test; and 40% to the Crib 5 test. These estimates are approximations and should not be treated as literal or exact value.” No mention was made of savings attributed to fire retardants.
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8 Fire Retardancy – An Inherent Safety Dilemma
It is noted that the key performance-defining characteristic of the ecolabelled product groups are not their
fire retardancy but primarily other criteria including chemical safety in relation to potential hazards to
people and the environment. However, it is clear from the survey work conducted in this study, that
various groups think it would be helpful to include a fire retardancy criterion for those products that must
offer satisfactory fire performance either through national regulations such as the UK Nightwear (Safety)
Regulations 1985, the Furniture and Furnishings (Fire) (Safety) Regulations 1988, and to meet the general
requirements of the General Product Safety Directive.
There is a clear need for greater harmonisation of national product flammability requirements to achieve
consistent consumer product safety standards to reduce human death and injury risks from fires in the
home. It is fire safety requirements that will determine if a particular FR technology is satisfactory for the
purpose of achieving fire retardancy in a particular product whose potential fire loading and reaction to
fire may be very different from another product. At present, differing national regulations on fire safety
may lead to conflict when considering potential human exposure and environmental risks posed by
different FR technologies.
Such differing requirements mean that a set of environmental criteria in a national ecolabel may be
insufficient to allow another country‟s minimum flammability requirements to be met while retaining
reasonable product cost and choice.
Particularly in the area of textile and furniture products, the UK is generally more stringent on product
flammability restrictions than many other countries. Hence EU Ecolabel criteria should be proposed by
the UK on the basis of appropriate environmental hazard and risk assessments and where those criteria do
not compromise or threaten the integrity of national flammability standards. This presents an inherent
dilemma.
Similarly, the use of risk phrases (based on chemical classification hazard statements) within the EU
Ecolabel may be regarded as inferior to rigorous approaches to chemical risk assessment, approaches that
Europe has relied upon to both assess and manage chemical risks and which will continue under the new
REACH regulations.
However, given the paucity of detailed chemical risk assessments for FRs (and other chemicals)
worldwide it is reasonable that the “risk phrase” hazard approach be used within EU Ecolabels. This
position is likely to remain for some time until a much larger number of risk and hazard assessments have
been completed.
While this debate lies outside of the scope of this report, we guardedly use the current framing of the EU
Ecolabel, including its risk phrase assessment approach, and we acknowledge the current exclusion of
flammability requirements. However, we consider it essential that the fire retardancy performance of the
product be maintained as a primary requirement. This is the starting point for our recommendations.
9 European Risk Phrases
European chemical risk phrases are used in EU Ecolabel criteria for FRs. These were originally and
formally defined in Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws,
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regulations and administrative provisions relating to the classification, packaging and labelling of
dangerous substances. This have been progressively amended - for example, see Commission Directive
2001/59/EC of 6 August 2001 adapting to technical progress for the 28th time Council Directive 67/548/EEC on the approximation of the laws, regulations and administrative provisions relating to the
classification, packaging and labelling of dangerous substances.
The current approach to classification is the new Regulation (EC) 1272/2008 on classification, labelling
and packaging of substances and mixtures (CLP) which entered into force on the 20 January 2009. CLP implements the Globally Harmonised System (GHS). CLP will stepwise replace Directive 67/548/EEC
(substances) and Directive 1999/45/EC (preparations). The most current version is available as Regulation
(EC) No 790/2009 - of 10 August 2009 - amending, for the purposes of its adaptation to technical and scientific progress, Regulation (EC) No 1272/2008 of the European Parliament and of the Council on
classification, labelling and packaging of substances and mixtures
In practice the so called “risk phrases” are actually “hazard phrases”. It is these phrases that are used in Ecolabel criteria related to potentially harmful effects on the environmental and human health arising
from exposure to fire retardants and other chemicals. In this case the Directive contains an exhaustive
listing in Annexe 3 of “hazard statement” codes and Annexe 4 contains the current risk phrase codes.
Appendix 1 in Annex 2 discusses risk phrases further and also contains a listing of the singular and combination risk phrase which relate to those used in Ecolabel criteria. However, it is likely that R-
Phrases will continue to be used in the Ecolabel scheme but it is important that they also harmonise with
the Global Harmonised System of Classification and Labelling of Chemicals (GHS/CLP) which now also use hazard statements.
Annex 2 notes that the application of risk-phrases in the setting of Ecolabel criteria have been criticised as
they were initially developed for manufactured chemical and are not suitable for the purposes of use of
chemicals in consumer products that might contain diluted small quantities or where the chemical is transformed when it is reactive. R-phrases take no account of exposure condition, dose-response and risk
to human health and the environment through the use of the chemical in consumer products.
The report also notes that in December 2008 a discussion paper entitled “The path to sustainable use of chemicals in products: The European Ecolabel as a signpost” was published by The European
Environmental Bureau (EEB) and The European Consumers‟ Organisation (BEUC) with contributions by
The Oeko Institute. This discussion paper recommended that R-Phrases should be continued to be used in the Ecolabel scheme but also harmonise with the Global Harmonised System of Classification and
Labelling of Chemicals (GHS) which now also use hazard statements.
10 Risk and Hazard Assessment Annexe 2 identifies current information on chemical fire retardant chemical safety classification, hazard
identification and risk assessment in Europe and the US.
It also identifies European, UK and US governmental and regulatory sources of information as well as FR
industry trade association and academic sources.
It gives examples of the risk assessment information available from sources such as the European ESIS
and ORATS databases (see Table A1) and also the US Environmental Protection Agency and its IRIS
database.
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This report together with that on “Alternative Fire Retardant Technologies” – Annexe 4 - provides
information on studies that have examined substitution options for brominated fire retardants. These
reports should be read in parallel with related information contained in the “Legislative Landscape” report – Annexe 1 - which describes the changing regulatory and legislative position in the UK, Europe and the
US on chemical safety and fire protection.
Annexe 2 provides risk assessment summaries of a number of leading chemical FRs including their
current chemical safety classification and the risk-phrases and safety statements that are associated with European chemical safety assessment. These risk phrases are hazard statements and they are used in the
setting of Ecolabel criteria and could also be used in the future in green procurement.
Annexe 2 also summarises all of the current information available on European risk assessment and chemical classification for the more common chemical FR technologies in current use, and proposed for
use, with the consumer products of interest here.
A number of the key risk assessment summary tables from Annexe 2 are include in Appendix 1; these include: Table 2 (FRs subject to European risk assessment), Table 12 (DecaBDE alternatives in electrical
and electronic equipment from the Danish EPA 2007 report) and Table 16 (Chemical classification of
some commercial fire retardant chemicals from the FR technology survey) which are reproduced in
Appendix 1 as Tables A1, A2 and A3 respectively. These tables show the current extent of European risk assessment of a number of FR currently, and in some cases historically, used in the products of interest
here. The chemical classification for those FRs referenced in the FR Technology Survey are also included.
For completeness, the available chemical classification information for a number of FRs that have been proposed as substitutes for decaBDE (and some other FRs) is also shown.
This information is however constrained as formal risk assessments and chemical classification of FRs is
incomplete. The Risk Assessment report6 in Annexe 2 notes that;
“Not only have very few FRs undergone a full risk assessment, but also very few have received a harmonised classification for intrinsic hazard in accordance with the CLP
Regulation. Thus only 4 of the 30 alternatives to decaDBE, which were identified by the
Danish EPA in 2006 (see Table 12 in Annexe 2) have received a harmonised EU classification and only 2 of those appear in ESIS. Substances may not be classified
either because a) the substance does not meet the criteria, or b) there are insufficient
data to reach a conclusion. So it could be that some of the alternatives are not in fact intrinsically hazardous. A classification and labelling (C&L) inventory will be compiled
by January 2011 for most substances in the EU. This is expected to highlight any
inconsistencies between suppliers, and data provision under REACH will allow
classifications to be updated”
“Similarly, of the commercially available FRs identified in the FR Technology Survey
carried out as part of this project and reported in Annexe 3, only 7 have received a
harmonised classification out of 31 and only 1 appears in ESIS”.
It was also noted that the absence of a chemical classification does not mean that the chemical is safe, it
may indicate that the chemical has not been assessed or is in the process of being assessed. Annexe 2
further commented that:
“Individual FR manufactures have an obligation to self–classify the safety of their
products. ......The study has shown that some differences can exist between different
manufacturers. This apparent lack of basic harmonised classification could add to the
uncertainty regarding the safety of FR alternatives”.
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The latest EU CLP regulations force the onus for classifying chemicals onto the
suppliers/ manufacturers. Improvements to harmonise the classification of individuals
FRs should gradually improve confidence in European classification”. The regulations place responsibilities on to manufacturers, importers and distributors to ensure that
chemicals are classified and appropriately labelled, with an obligation to apply CLP
from 1 January 2011. Chemicals are classified according to physical hazards
(approximating to current “S” classification), health hazards (approximating to current “R” classification) and environmental hazards”.
Further, it is noted that classification can only occur if there is adequate toxicity data to support it. In
practice it is possible for potential users of a chemical FR technology to confuse the absence of a classification with it being acceptable for use. In ecolabel terms (see Annexe 4) this should not be
acceptable and any FR that has no classification and appears to meet ecolabel requirements should have
adequate toxicity data to support this position.
It is against this background that the report makes recommendations based on the hierarchical approach
described here.
11 Hierarchy for Human and Environmental Safety
We introduce a hierarchical approach to the assessment of best environmentally performing FR
technologies. This is based on the premise that the avoidance of FR chemicals is to be preferred through
either the use of alternative intrinsically fire retardant materials or through product design to achieve the
fire retardancy required. This is consistent with the principles of green chemistry and the use of the
precautionary principle applied to an assessment of potential human and environmental exposure hazards
associated with FR chemicals.
The most general approach would therefore seek to minimise human exposure and environmental impact.
The FR technology hierarchy adopted is assumed in each case to achieve the required product fire
retardancy; in order of priority the hierarchy is:
Use of inherently fire retardant materials
Design of products
Use of chemical fire retardants
In turn, the human and environmental impact of chemical fire retardants can at present be minimised by
adopting the following hierarchy of assessment, which is linked to current Ecolabel practice:
Use of risk phrases
Prohibited and allowable chemical classes
Exemptions = where no alternative approach will enable fire safety to be
maintained
White List - in which all chemical fire retardants are prohibited with the
exception of named chemicals that have been incontrovertibly shown to be of
very low hazard and enable fire safety to be maintained.
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This hierarchical approach is in turn constrained by the following factors:
Meeting legislative requirements
Maintaining a degree of commercial choice
Cost – to the product manufacturer and the consumer
Product groups are described that are subsets of Ecolabel definitions that are impacted by different FR
legislation – this is summarised in the Legislative Landscape report 5 in Annexe 1. For each group, the
ability of the different FR approaches to meet the constraints is described in the next section. It should be
noted that no attempt is made here to include any assessment of life cycle environmental performance;
however such assessments could form part of a more thorough evaluation in the future.
12 Alternative FR Technologies and Recommendations
The assessment of alternative FR technologies for each product group uses the hierarchical approach
described in section 13 along with the assessment of FR hazard and risk taken from Annexe 2 to identify alternative chemical and physical technologies, use of inherent FR materials and design approaches that
can ensure fire safety and offer better environmentally performing solutions.
A summary of alternative technologies for each product group is given in:
Appendix 2 – Textiles
Appendix 3 – Furniture and Furnishings
Appendix 4 - Electronics
There are many potential alternative chemical FR technologies and substitution options available for a
number of the leading chemical FRs which have been or are being considered for ban or voluntary
removal in Europe. While some of these have been well researched and are fit for purpose, there are many
that have not been risk assessed – see Annexe 2 6. There are also a number of emerging technologies that
are at the research stage and cannot currently be offered commercially.
Given the different legislative concerns and material and design options we have divided the consideration
of criteria into two simpler areas: (i) textiles/ garments/, (ii) furniture and furnishings, and (ii)
PCs/laptops/TVs.
12.1 Textiles
This includes the subcategories of sleepwear, foam, mattresses, personal protective equipment (PPE),
wooden furniture and floor coverings. A summary of the current, alternative and emerging technologies is
given in Appendix 2.
12.1.1 Sleepwear
Background
Children‟s nightwear fabrics generally include polyester and polyester/cotton or viscose blend. For adults,
the most commonly used fabrics are polyester/cotton blends, polyester, cotton, viscose, nylon, silk fibres
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and their blends. In UK according to the Nightwear (Safety) Regulations 1985, children nightwear fabrics
are tested to BS 5722:1984, using BS 5438 Test 3. 100 % polyester fabric, without any FR treatment can
pass this test. For adult nightwear there is no requirement to pass this test.
At present, apart from the GPSD, there are no specific fire safety regulations for sleepwear in most EU
member states, however very recently a new European standard: BS EN 14878 has been introduced,
which in addition to a fire spread test also requires testing for flash resistance. The existence of a
European test standard for the product places an obligation on Member States to use it to ensure product safety.
The fabrics currently used for different markets and their FR treatments are discussed in detail in column
1 of the table in Appendix 2, along with possible substitution technologies and emerging technologies in columns 2 and 3. The FR Technology hierarchical matrix for sleepwear is shown in Table 1.
Specific Recommendations
For children‟s sleepwear which is 100% untreated polyester, the material is able to meet current Ecolabel criteria but it cannot be recommended for this application on this basis alone.This
recommendation recognises concerns over the tendency of this material to melt when heated in fire
and which may cause serious burns to the wearer. While Ecolabel accept this material in regard to its environmental performance, it would reject other materials containing additive FR technologies and
which perform more safely in fire. In this regard Oeko-Tex uses a white list approach to identify up
to 14 environmentally acceptable FRs which significantly broadens materials choice.
Many of the FR alternatives contain halogens and these should not be excluded unless they fail to
meet the risk phrase criteria. This requires a reconsideration of halogen exclusion.
Maintain the limits on formaldehyde for skin contact sleepwear.
There are some FR treated cottons incorporating phosphorus or nitrogen-based FRs which are sold for children by some retailers. In this case some concerns exist in regard to skin irritation and loss of FR
performance caused by numerous washes, possibly at high temperatures. However, the main concern
from the primary FR manufacturer active in this area concerns the low levels of formaldehyde required by the Ecolabel. While this was thought to be achievable for sleepwear there may be merit in
considering a relaxed limit in no-skin contact uses – see also the discussion in Section 12.1.2 .
Further work is required on the use of modified acrylic/ cotton mixes and the questions raised on
possible hydrogen cyanide emissions; these should not be recommended as inherent FR materials
until the question has been answered.
Modified acrylic / cotton mixes which produce a partially inherent FR textile have been criticised because of possible hydrogen cyanide emissions. Until this is resolved such fibre mixtures should not
be seen to reduce chemical hazards.
Future Challenges
For nightwear fabrics the current industry challenges are:
To minimise thermoplastic and melt drip effects and enhance char-promotion in synthetics.
Polyester (and other synthetic fibres) rich fabrics, although passing the BS5722:1984 test, allow
molten dripping which can inflict serious burns to a wearer‟s skin.
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To avoid chemical finishes (including non-fire retardant finishes such as easy-care treatments)
that may release formaldehyde, especially for children where skin sensitivity is greatest. It is
noted that Japan have minimum formaldehyde release requirements and in the USA
phosphonopropionamide-based finishes are banned for use on children‟s nightwear because of their formaldehyde-releasing potential
From a fire performance point of view:
While the choice of polyester is recommended for sleepwear from environmental considerations,
its fire safety performance could be improved, probably by means of char forming chemical additives.
It is also possible to consider the use of inherently fire resistant fibres such as Trevira CS polyester,
Kaneka‟s Kanecaron modacrylic (Kaneka, Japan) and Lenzing‟s FR Viscose (Lenzing GmbH,
Austria). Commercial FR polypropylenes are also available.
In relation to maintaining consumer choice:
Other fabrics will require chemical FR treatment if they are to satisfy fire safety requirements.
The balance of environmental performance and durability of the treatments suggest that reactive
FR systems are preferred provided they are able to satisfy low formaldehyde emissions during
use and no other negative environmental impacts are present.
There are a small number of reactive FRs that will meet the EU Ecolabel criteria although some
adjustment in the formaldehyde emission limit may be required to fully satisfy the criteria.
There are also a number of alternative materials technologies:
To reduce thermoplasticity of polyester, layered silicate nanocomposites may be formed in
combination with nominal amounts of phosphorus-based fire retardants.
Alternatively the clays can be added in the surface finish, by nanodispersion in one of the
components of the finish.
It is noted that the emerging technologies cited in Appendix 2 are not currently available commercially
but may become available in the future.
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Table 1: FR Technology Hierarchy Matrix for Sleepwear
SLEEPWEAR Technical feasibility of compliance
with UK /EU Legislation Hazard Assessment Degree of Choice Cost Implications
Comments
and
Exemptions
Low flammability materials
UK legislation can be met using certain
non-FR treated polyesters or specialist
FR viscose, polyester or acrylic. Cannot use cotton for children‟s wear
without FR treatment
Generally assessed as low
hazard
Relatively few
inherently FR
grades in each fibre
type. Wide choice of
non-FR polyester
Inherently FR
perhaps 30% more
expensive material,
but can be blended. Non-FR treated
polyester – no cost
implications
Design to eliminate FRs Plasma finishing to graft FRs onto
surface (lab scale only)
Likely to be considered of
low hazard Not known
Not known but likely
to be more expensive
Use of risk phrases, exclusions
of classes of compounds and
exemptions to control FR
chemical selection
Oeko-Tex standard FRs are available to
meet UK legislation for e.g. polycotton
blends
Phosphorus and nitrogen based FRs are
available, but some reduction in choice
if chlorinated FRs are not permitted.
Current focus is on reducing
formaldehyde release, which
significantly affects use of reactive FRs, and reducing thermoplasticity
Additive compounds
currently excluded, and risk
phrases R40, R45, R46,
R49, R50-53,R60-63, R68
Significant choice
still likely to be
available
Cheapest option is
use of non-FR
polyester, unaffected
by r-phrase changes,
which will meet UK
legislation
White list of allowable FR
compounds only
Oeko-Tex has 14 allowable
compounds
7 manufacturers of
Oeko-Tex allowable products
Oeko-Tex list
relates to
human health and
environment
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12.1.2 Personal Protective Equipment
Background
Inherent FR materials such as Kevlar and Kermel are required for high specification PPE such as
Firemen‟s uniforms. Lower specification PPE can use reactive FR-treated materials based on
phosphonium related FR chemistries. However, currently these are not eligible for EU Ecolabel due to formaldehyde emission issues rather than the risk phrases associated with the FR chemical. The
comparative position is shown in the FR technology hierarchy matrix for PPE - Table 2.
The most effective treatments are based on the use of phosphonium salts, but their use is restricted under
current Ecolabel requirements as a result of formaldehyde release under certain conditions of use. The Risk Assessment report
6 discusses this issue and highlights that phosphonium salts although not classified
or risk assessed in Europe, are no longer used in the US in children‟s nightwear due to formaldehyde
release during processing or after prolonged storage. Acidic residues from the acid catalyst (phosphoric acid) used during curing promote this and may reduce durability during subsequent washing. However,
the same acid catalysis will also release formaldehyde from the phosphonium salt. Pyrovatex was
voluntarily withdrawn from the US by CIBA in 1998 due to such concerns.
It is noted that Oeko-tex, with its white list approach, might be seen as a more attractive label than EU
Ecolabel since a number of the phosphonium based FRs are on the white list with no additional
requirements placed on free formaldehyde content. Environmental performance is not the only factor of
concern. The use of inherently FR materials is not always seen as superior to FR treated, since some high specification materials such as Kevlar have poor UV resistance. These materials should therefore be seen
as complementary approaches for different applications. This provides for some consumer choice that
reflects a wider set of application requirements than those addressed by Ecolabel criteria.
Specific Recommendations
Use inherent FR materials such as the aramids.
The use of inherent FR materials is to be recommended when there are no costs constraints. Where such constraints exist or where market choice is important then chemical FR technologies will be required for use with more flammable materials. In this case, it is recommended to,
Review the formaldehyde limit to enable the use of phosphonium salts to fire protect cheaper
textile materials.
The most commonly used durable commercial finishes are tetrakis hydroxyl methyl phosphonium chloride-urea condensate (eg, Proban, Rhodia Specialities Ltd) and N-methylol dimethyl
phosphonopropionamide (eg Pyrovatex, Huntsman, formerly Ciba). However, in view of the possible
release of formaldehyde, this would be more generally acceptable for non-skin contact applications.
Alternatively, exempt phosphonium salts or add FR technologies containing them to a white list.
Materials treated with these FR technologies might be allowed under the current Ecolabel risk phrases if they were treated as an exemption with restrictions on use or they could be placed on a white list of
approved FRs. In either case a formaldehyde emission limit could be set to achieve this.
Use different formaldehyde limits according to use of the material.
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As the formaldehyde content is a general issue for this type of treatment, an alternative approach would be to introduce a more stringent free formaldehyde content for children‟s sleepwear, and a less
stringent requirement for garments in contact with adult skin, and less so again for garments not in contact with the skin. PPE would fall into the latter two categories, and so could be made permissible
for Ecolabel and green procurement purposes.
Use different technologies according to the specification and intended use of the PPE.
For high performance PPE applications, it is recommended that inherent fire retardant materials such as aramids Kevlar and Kermel should be considered and phosphonium based FR technology treated
fabrics be allowed for lower specification PPE by allowing the formaldehyde limit to be relaxed to a
level that can be achieved for good quality treated FR finishes.
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Table 2: FR Technology Hierarchy Matrix for Personal Protective Equipment
PPE Technical feasibility of compliance
with UK /EU Legislation Hazard Assessment Degree of Choice Cost Implications
Comments
and
Exemptions
Low flammability materials
Inherently FR materials commonly
used, particularly in more sophisticated
PPE
Generally assessed as low
hazard
Usually depends on
technical
performance, but
widely available
Inherently FR
materials more
expensive,
sometimes
substantially so (e.g.
Kevlar)
Some
restrictions on
inherently FR
materials e.g.
UV stability
Design to eliminate FRs Likely to be considered of
low hazard
Use of inherently FR
materials increases
cost
Use of risk phrases, exclusions
of classes of compounds and
exemptions to control FR
chemical selection
Reactive FRs already in use in PPE.
Some organo-chlorinated FR products
used
Additive compounds
currently excluded, and
risk phrases R40, R45,
R46, R49, R50-53,R60-63,
R68
Range of well
known products
available
A major issue
is keeping the
formaldehyde
level below
allowable
Ecolabel limits
for certain FR
chemicals
White list of allowable FR
compounds only
Oeko-Tex has about 14 allowable compounds
7 manufacturers of
Oeko-tex allowable products
Review Oeko-
Tex list in the
light of solely environmental
criteria
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12.2 Furniture and Furnishings
Upholstered furniture and mattresses contain covering materials (most commonly fabrics), foam filling and in some cases an interliners between the filling and the covering, and a frame assembly. In some cases
so-called fire-blocker materials are used between the face fabric and the foam. In the UK, the foam used
for furniture should pass certain flammability criteria depending on domestic or non-domestic use, and all commonly used polyurethane foam needs to be fire retarded.
As the whole assembly needs to pass the BS 7176:1995 (now 2007), different design, physical and
chemical FR technology solutions can be applied.
A detailed summary of the FR Technologies used in each component of furniture is presented in
Appendix 3 along with some comments on substitution options and the position on emerging
technologies. A more general table of the hierarchical FR technology matrix is shown in Table 3 for interior furnishings in general and Table 4 for mattresses.
12.2.1 FR technologies avoiding the use of chemicals
Specific Recommendations
1. Covering fabrics from inherently fire retardant fibres
Use natural fire resistant materials such as wool or leather
Wool fabric of high area density, i.e. ≥ 600 g/m2, can pass the required fire performance tests. If a
lighter wool fabric is used, it might need some fire retardant treatment (e.g. by the ZIRPRO-treatment
using hexafluoro zirconate or titanate by the exhaustion method) at nominal levels.
Leather is inherently fire retardant. However, artificial leather fabrics eg, polyurethane based require
a chemical fire retardant treatment to satisfy fire retardancy requirements. However PVC based
artificial leather will not require flame retardant treatment for domestic furniture, but may require
other flame retardant additives to pass BS5852 Crib 5 or 7 tests, depending upon specific end use.
Use a synthetic fire resistant material such as modacrylics with small amounts of additive FRs.
The other inherent FR fibres are modacrylics but these are expensive and could restrict consumer choice. Modacrylics (defined as copolymers containing between 35 to 85% acrylonitrile usually with
either vinyl chloride or vinylidene chloride as second main comonomer) have typically been used in furnishing fabrics because of their acrylic and hence wool-like handling characteristics. Some
modacrylics contain small amounts of the additive FR antimony trioxide (ATO) to enhance their fire
retardancy. ATO has a risk phrase (R40) related to potential inhalation hazards but if it is incorporated and physically well bound in the material the risks can be significantly reduced.
Use natural and synthetic blends to reduce cost and increase choice.
Blends of different fibres can also be used, e.g. wool/modacylic, wool/nylon blends, wool/FR viscose, etc. Blends of wool with other high performance fibres like Nomex, Kevlar, Basofil, Polybenzimidazole, etc., can also be used, though the latter are very expensive.
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2. Fire-blockers and Interliners
Use natural or synthetic fire resistant material or a mixture of both for fire blockers and
interliners.
Interliners made from inherently fire retardants fibres can further reduce the flammability of the product, both for domestic and non-domestic applications. In general if the covering material is made of > 75% natural fibres such as cotton or wool, it does not need to be fire retarded to pass the Crib 5
test of BS5852: Part 2:1989. These barrier materials can be multi-layered which allows a product to
maintain its fire resistance even if one layer is compromised.
For domestic under S.I. 1324, interliners are tested to Schedule 3 using Crib 5 test of BS5852: Part 2:
1982. A water soak requirement controls the viability of interliner FR treatment .
For non-domestic furniture BS7176: 2007calls up BS5852: 2006 and BS EN 1021-1 & -2: 2006.
There are no constraints on what/how interliners are used but open flame ignition sources up to BS 5852 Crib 7 can be applied (depending on end use scenario). Since this is an actual composite test the
pass/fail outcome will depend on physical/chemical make- up of both textile and filling.
Adopt transport sector fire-blocker designs in the domestic market.
Fire-blockers, made from inherently fire retardant fibres like oxidized acrylics and aramids, can make the product fire retardant. These however, are expensive fibres. Fire-blockers from oxidised acrylics
and aramids are commonly used for aircraft seats; their use is increasing in trains, buses and coaches.
So the adoption of design practice in the transport sector could create benefits in the furniture product sector.
The barrier materials can also be a blend of inexpensive natural fibres and expensive synthetic fibres,
such as Basofil, Polybenzimidazole, Kevlar, Nomex, etc. Cost may be prohibitive for general
consumer markets.
Use fibreglass wrapped in an inherently fire retarded fibre to reduce cost.
A cheaper alternative is to use glass fibre wrapped in fabric of inherently fire retardant fibres (e.g. FR viscose) or plastic film made from neoprene, PVC which produces fire retardant species when
exposed to thermal degradation conditions and to fire.
12.2.2 FR chemical technologies
Specific Recommendations
1. Covering fabrics
We consider the primary treatments in current use and the reader is referred to Table 4 for a summary
of the hierarchy of options:
Back-coatings:
Phase out the use of brominated FRs in backcoatings despite their effective FR performance.
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The environmental performance of a number of brominated fire retardants (Br-FRs) and ATO in traditional back-coatings and the pressure to avoid the use of persistent organic compounds in the
environment would suggest that continued use of small molecule Br-FRs in covering fabrics is not justifiable if alternatives exist that can meet the fire performance requirements. Low hazard
polymeric Br-FRs might be an alternative if suitable formulations can be made and combined with
alternative low hazard synergists.
Investigate phosphorus-based FRs as an alternative to Br-FRs in backcoatings.
The use of volatile and possible vapour phase-active phosphorus-based FRs should be explored and effective substitutes found. The only drawback is that these coatings will be fibre specific and so
cannot be used for all fibre types and blends.
Investigate alternative synergists to, and phase out the use of, ATO.
ATO, the most common synergist for Br-FRs, also has environmental issues, although these can be managed by effective matrix incorporation to reduce inhalation exposure. This compound could be
replaced by other synergists such as the zinc stannates. Stannates show synergism with halogenated
compounds in some chemical finishes and when used as additive fire retardants in polymers. However, zinc hydroxystannate and zinc stannate are more expensive than ATO and so have not
been used in commercial formulations. Consequently, the assessment of material and product fire
performance using these alternative synergists has not yet been done to establish whether they will work in back-coatings as efficiently as ATO.
Investigate the use of halogen-free back-coatings and other emerging technologies.
There are some halogen-free back-coating formulations available, such as MelaphosFR™ Dartex. However, it is not clear to which fibre types these will be applicable.
Thor has also developed alumina trihydrate (ATH) and exfoliating graphite containing coatings,
which work by providing physical fire barrier protection, but these may need to supplemented by
chemical FR technologies that are also effective in the gas phase.
Hot melt technologies have been developed to replace solvent and some aqueous-based textile coating technologies but there has been no exploitation within the textile back-coating area to date.
Additive fire retardants:
Use polymeric additives in synthetic fibre materials.
If additive fire retardants are to be used in synthetic fibres, these should be polymeric in nature – this would satisfy REACH. Examples of some halogenated FRs developed by ICL include brominated
epoxy (FR-2400), brominated polystyrene (FR-803P) and brominated poly (benzyl acrylate) (FR-
1025). Hence a blanket exclusion of Br-FRs without considering their environmental performance would be inappropriate. Polymers are considered hazard-free if a) they do not contain any residual
monomer or b) the monomer(s) have been assessed as hazard-free.
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Chemical finishes:
Investigate water-based finishes with surface modification by plasma technology.
For cotton and cotton/polyester blends, durable chemical finishes such as Pyrovatex (Huntsman, formerly Ciba) or Proban (Rhodia) are usually applied. The conventional water-based finishes could
be replaced by surface modification by plasma technology. The interest in this has increased with the
recent development of atmospheric plasma machines for processing wide widths of fabrics although no current fire retardant successful example exists at the present time.
2. Foam
Investigate the use of graphite impregnated foam in the domestic market.
Physical fire protection of foam seating by the introduction of graphite impregnated foam (GIF) as an inherently fire-resistant foam is recommended.
Investigate replacing halogenated phosphorus FRs with non-halogenated phosphorus FRs.
In regard to chemical FR technologies, the halogenated phosphorus based FR chemicals currently used for fire retarding foams could be replaced by non-halogenated phosphorus based fire retardant,
such as triarylphosphate, organic phosphate ester with triphenyl phosphate. However, it is noted these would be of the additive type and not reactive and while some may be able to satisfy the Ecolabel
risk phrase criteria they would be excluded because of not being reactive.
These constraints may be unacceptable as no conventional polyurethane foams could satisfy the
“additive” requirement. Also, a move to non-chlorinated FRs would increase costs and in some cases substantially so.
Review and continue to develop nanocomposite foams as an alternative to conventional
polyurethane.
There has been a considerable amount of research in developing polymer nanocomposite foams, which still need other fire retardant to adequately pass fire performance tests. However, most of the
effort to date has been at a laboratory scale and the technology is not yet commercially available. So
while this can rightly be seen as an emerging technology it is unlikely to provide the required degree of fire retardancy on its own and would require chemical FRs to ensure adequate retardancy. The
benefit is the potential reduction in the amount of chemical FR used. Review and continue to develop
nanocomposite foams as an alternative to conventional polyurethane.
Most FR foams for interior furnishings rely currently on additive chemical and physical FR
technologies, including those that would satisfy R-phrase criteria. The “additive” FR criteria
should not apply to foams unless viable alternatives are available.
12.2.3 Interior Furnishings Recommendations
Table 3 summarises the FR technology hierarchy matrix for interior furnishings.
Background
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It was noted in the Ecolabel consultation reported in Annexe 6 that there is a drive from customers (i.e.
retailers) to replace chlorinated FRs. R-phrase hazards for some chlorinated phosphorous FRs appears not
to be as great as for brominated FRs. For example, some of the chlorinated phosphorus FRs used in foams do not contain adverse R-phrases - TCCP is an example. Generally the non-chlorinated FRs will be more
expensive, and there is also greater uncertainty about their FR effectiveness across different polymer
types. In many cases these compounds also lack any chemical classification and it is uncertain if they
would offer a better environmental performance. Until this is achieved it would be perverse to exclude a compound like TCCP by an over-restrictive Ecolabel criteria centred on excluding all halogen containing
and additive FRs.
In contrast, the Oeko-tex white list approach was felt by consultees to be a reasonable attempt to meet environmental criteria, although there was a limited preference for the risk phrase approach rather than a
white list approach, due to the greater flexibility that this approach gives.
Specific Recommendations
Use inherent fire retardant materials where possible.
Inherent FR approaches are possible for many textiles, for example the use of modified acrylic/cotton blends (i.e. a partially inherently FR blend) was used in the USA, albeit with different regulatory
requirements. There is also some use of inherently FR polyester in coverings. These provide opportunities to use inherent FR options but they may be seen as limited within the current vast range
of materials and constructions currently available.
Allow use of synthetic, inherently fire retardant interliners.
Technically, interliners may be used as a design alternative to eliminate chemical FR use. Consultation with users revealed a view that they may be of limited use in gaining environmental
improvement since it is believed that most interliners in the UK were of cotton, which would require
treatment with FRs. Inherent FR materials such as aramid would be possible, but would cost
approximately ten times more. So while technical alternatives do exist and can be recommended as are good environmental performers (in risk phrase terms), their costs and market constraints may be
prohibitive at this point in time.
Encourage use of treated top cover and treated foam as a means of phasing out Br-FRs.
A general approach to meet flammability requirements by using a treated top cover (Pyrovatex or equivalent) and by treated foam works well technically and was seen by consultees as workable. One
environmentally friendly approach is the use of ammonium polyphosphate (APP) based product that
can only be a soak durable treatment, but can meet up to a crib 5 standard over flammable foam. Brominated FRs in backcoated textiles have some advantages related to their flexibility in application.
However, the use of poor environmentally performing Br-FRs should not continue. There appears to
be market acceptance that brominated FRs will be excluded.
Encourage a switch from halogenated phosphorus FRs to non-halogenated equivalents.
In regard to foam fillings, it is possible to replace chlorinated phosphorous based FRs with non-chlorinated ones and there was a general consensus from consultees that non-chlorinated FR
compounds were starting to become commercially available for foams. These are for example being
introduced into office furniture by one foam manufacturer, with an eventual ambition of introduction into interior furnishings in households. This switch should be encouraged.
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Modify Ecolabel requirements that specifically excluded additive and/or chlorinated FRs to
enable the use of adequately classified non-chlorinated phosphorus chemical FR technologies.
For those non-chlorinated phosphorus chemical FR technologies which have an adequate classification to satisfy the Ecolabel risk phrase criteria, these should be recommended as best environmental performers, particularly given the potential difficulties of the costs and market
acceptance of GIF-foams. However, these FRs would not currently satisfy the Ecolabel requirement
that excludes additive chemical FRs. This requirement should be reviewed.
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Table 3: FR Technology Hierarchy Matrix for Interior Furnishings
TEXTILES FOR INTERIOR
FURNISHINGS
Technical feasibility of compliance
with UK /EU Legislation Hazard Assessment Degree of Choice Cost Implications
Comments
and
Exemptions
Low flammability materials
Foam containing furniture usually uses
polypropylene, wool, polyester or
cotton/polyester, all of which require
FR treatment. Inherently FR materials are available for polyester.
Generally assessed as low
hazard
Inherently FR
materials up to 2-3x
more expensive.
Ecolabelled
wool products
are currently
supplied without FR
Design to eliminate FRs
Use of inherent FR interliners between
the foam and face fabric can reduce the
need for FRs.
Likely to be considered of
low hazard
Wide variety of
interliners available
Use of interliner
increases costs.
Usual types (cotton)
are cheaper than
inherently FR
materials – but have
FR treatments
themselves
Use of risk phrases, exclusions
of classes of compounds and
exemptions to control FR
chemical selection
Phosphorus and nitrogen based
alternatives available. Some
chlorinated phosphorus compounds
used with polyester.
Alternatives to organobromine
compounds exist, but more specific to
fibre types
Additive compounds
currently excluded, and risk
phrases R40, R45, R46,
R49, R50-53,R60-63, R68
Some chlorinated
phosphates do not have
these risk phrases, so
allowable.
Some halogen-free
FR chemicals are
available suitable
for cotton, polyester
etc
Exclusion of
additive FRs
substantially
decreases choice
Generally more
expensive than
brominated
alternatives
Higher cost of
processing due to
fibre specificity
White list of allowable FR
compounds only
Oeko-Tex has about 14 allowable
compounds but it is not clear if these
could assist products to meet the UK
furniture fire safety regulations
7 manufacturers of
Oeko-Tex
allowable products
Review Oeko-
Tex list in the
light of solely
environmental
criteria
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12.2.4 Mattresses Recommendations
Table 4 summarises the FR technology hierarchy matrix for mattresses.
Background
Much of the discussion relating to textiles and interior furnishings applies to the covering materials used
in mattresses. Also consideration of the fillers and tickings can also be accommodated with the reasoning applied to the best FR technologies for furniture foams, fire blockers, interliners and fabrics.
The Ecolabel Survey consultees for mattresses indicated a preference that Ecolabel criteria be based on
risk phrases rather than on specific chemical exclusions or inclusions.
Specific Recommendations
Encourage better design and use of inherent FR materials to obviate the need for FRs.
In the consultation, one example was found of a mattress manufacturer who has met the UK legislative requirements on fire performance using a combination of materials (wool) and changes in
design (side seaming rather than tape edging) and did not use chemical FRs. Many of the materials in conventional mattresses are polyester and polypropylene, and the flammability requirements can be
met with non-halogenated compounds. (The UK standard is easier to pass for mattresses than for
furnishings due to the fire test methods being horizontal burn tests).
Encourage a switch from halogenated phosphorus FRs to non-halogenated equivalents while
recognising the needs of polyurethane foams.
Polyurethane foam mattresses currently require chlorinated or non-chlorinated phosphorus FRs (see discussion in Section 4.1.3). The chlorinated compounds are regarded as the standard FR chemicals, with non-chlorinated being less characterised with respect to environmental performance and risk.
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Table 4: FR Technology Hierarchy Matrix for Mattresses
MATTRESSES Technical feasibility of compliance
with UK /EU Legislation Hazard Assessment Degree of Choice Cost Implications
Comments and
Exemptions
Low flammability materials
Conventional design of mattresses
requires these or FRs.
Not possible for PU foams, but
possible for other mattress components
Generally assessed as low
hazard
Inherently FR
materials up to 2-3x
more expensive
Only possible to
have non-FR
materials if
combined with
design changes.
Design to eliminate FRs
Side seaming rather than tape edging
combined with high wool content
paddings can meet BS 7177 for
domestic mattresses without use of
FRs. Also can use interliners from inherently FR materials or >70%
natural materials e.g. wool/viscose
will meet more demanding standards
Likely to be considered of
low hazard
Greater use of
wool or other less
flammable materials required
Redesign of some
elements of
production required. More expensive
materials
Not possible to
use PU foams
Use of risk phrases, exclusions
of classes of compounds and
exemptions to control FR
chemical selection
Depends on the risk phrases of
chlorinated phosphorus compounds.
Chlorophosphates are widely used in
combustion modified PU foam.
Therefore this would exclude most PU
foam mattresses. However FR of
polyester and polypropylene could be
achieved with non-halogenated
products
Bromine-based materials less specific
to fibre types
Additive compounds
currently excluded, and risk
phrases R40, R45, R46,
R49, R50-53,R60-63, R68
Some halogen-free
FR chemicals are
available suitable
for cotton,
polyester etc
Exclusion of
additive FRs
substantially decreases choice
Non-brominated FR
chemicals generally
more expensive than
brominated
alternatives
Additive nature
of most FR
chemicals
exclude PU-
foam mattresses
from ecolabel
consideration
White list of allowable FR
compounds only
Oeko-Tex has about 14 allowable
compounds but it is not clear if these
could assist products to meet the UK
furniture fire safety regulations
7 manufacturers of
Oeko-Tex
allowable products
Review Oeko-
Tex list in the
light of solely
environmental
criteria
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12.3 Electronic Products Recommendations
Background
Appendix 4 summarises the current, potential substitute and emerging FR technology options and Table 5
summarises the FR technology hierarchy matrix for electronic products. Annexe 3 and 4 discuss
alternative FR technologies in more detail and the acceptability of existing chemical FR technologies in
regard to Ecolabel criteria. Comments received from respondents to the Ecolabel Awareness survey
(Annexe 4) and the FR Technology Survey (Annexe 3) were sufficiently similar to enable these to be
generally used in the recommendations for all categories of PCs, laptops and televisions.
In regard to designing out FRs, the larger size and fire load of the products now produced are critical
factors in the use of inherent FR materials of chemical FRs in conventional materials rather than simply
using design. Also approaches, such as the greater use of metals, may introduce different risks such as
electrocution and short circuits. There are likely to be other issues that might give problems at other
points in the lifecycle e.g. greater weight and process energy. There are also be other requirements for
components such as US Underwriters Laboratory requirements on hot parts and live voltage parts to be
fire retarded in case of a fault condition.
Specific Recommendations
Use inherently FR materials for casings and enclosures.
While this is recommended, the use of inherent FR materials in casings and enclosures is possible but
the costs may be prohibitive particularly for more exotic polymers and composites. Other life cycle
factors such as weight and total energy use in manufacture may also limit the use of metals.
Phase out decaBDE/ ATO FRs in favour of phosphorus-based FRs for casings and enclosures.
The unacceptability of decaBDE and its failure to satisfy the risk phrase requirements, the exclusion
of all PBDEs in Ecolabels, and the concerns expressed about ATO, indicate that while this is one of
the best fire performing FR technologies it is one of poorest environmental performers. Other additive
chemical FR technologies based on phosphorus based FRs which satisfy current risk phrase criteria
are the best performing but care is required to ensure that only those FRs that are chemically classified
and shown to be satisfactory should be included. This may be achieved with an appropriate phase out
strategy.
Allow brominated FRs in applications where they are chemically bound to the substrate, for
instance reactive TBBPA in printed circuit boards.
For printed circuit boards the reactive and brominated FR TBBPA is acceptable for current Ecolabel
purposes and should not be excluded on the basis of its bromine content unless the residual monomer
concentration exceeds defined limts that are considered to present an unacceptable hazard. The
existence of inherent FR materials in high specification PCBs offers the best environmental
performance but the cost of adopting this technology in consumer electronic products would be
prohibitive.
Review and restrict the use of exclusions to avoid exclusion of potentially useful chemical FRs in
low hazard situations.
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It was felt by one FR manufacturer that the current Ecolabel criteria had about the maximum number
of risk phrases that would be practicable with electronic products. While the exclusion of some
brominated FRs is justified on environmental grounds, such exclusions should not be applied to all
halogenated FRs that could be used in electronic product applications.
A number of chlorophosphorus based FRs with good risk phrase based environmental performance
are available which could replace brominated FRs and these should not be arbitrarily excluded. In
principle the same position could exclude many of the new polymeric brominated FRs in spite of their
potential low hazard status within REACH.
As regards cost, the brominated FRs are generally cheaper than alternatives and require lower
loadings to achieve the same fire retardancy performance while not compromising key physical
properties and processability. While this might present some barriers to the adoption of new FR
technologies it is not a fundamental limitation.
Ensure that more of the alternatives to halogenated FRs are appropriately hazard and risk assessed
and only used if less hazardous than the chemicals they replace.
One end user had removed brominated and chlorinated FRs from their products. However some of the
phosphate esters used as replacements had the same risk phrases as the products that they were
replacing. Another end user had problems of replacing brominated compounds with less known
products which had later presented problems when the risk assessments had been carried out.
However another end user stated that the choice of non-brominated FRs for the plastics in their
products was sometimes very limited.
Consider the use of a white list of acceptable FR chemicals.
Technically, a white list approach is attractive as it presents manufacturers with a definite albeit
limited choice of acceptable FR technologies. This would also simplify the recycling of these
materials in the future. Some consultees were in favour of a white list approach, which contrasted
with the views expressed from the textiles sector. One of the problems foreseen was the criteria for
inclusion and the large amount of activity that would be generated from various plastics and FR
manufacturers that might make this process difficult to manage.
Overall, in the survey there was greater dissatisfaction with the risk phrase approach in the electronics
sector, and a greater preference for a white list or one based around systematic risk assessment and
REACH requirements. This was not however constraining current applications for Ecolabel licences.
Removal of halogenated compounds appears technically possible, at the expense of greater cost, a
reduction in choice and moving away from the principle of purely a risk phrase based approach.
Certain of the respondents in the electronics sector were critical of the use of risk phrases. However this
was felt by them to be an issue across all of the Ecolabel product groups and criteria and it would best
dealt with by a general consideration of the risk phrase approach, rather than by one that simply related to
FRs. Most proposals by respondees included the need to align Ecolabel criteria with the REACH process.
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Table 5: FR Technology Hierarchy Matrix for Electronic Products
ELECTRONIC /
ELECTRICAL
(TVs/PC/Laptops)
Technical feasibility of compliance
with UK /EU Legislation Hazard Assessment Degree of Choice Cost Implications
Comments and
Exemptions
Low flammability materials
Use of inherently FR materials in
casings, although performance may
not be comparable. Some use of
metals as alternatives
New laminate materials for PCBs
(developed for lead-free soldering)
Generally assessed as low
hazard
3 plastics identified
to be inherently FR
– polysulphone,
polyether sulphone
and polyarylether
ketone
Likely to be more
expensive than usual
high volume plastics
Specific
requirements for
PCBs.
Requirement for
RoHS
compliance
Design to eliminate FRs Use of internal metal
partitions/casings
Likely to be considered of
low hazard
Likely to be more
expensive
Reduction in
use of FRs
would assist
recycling of
these plastics
Use of risk phrases, exclusions
of classes of compounds and
exemptions to control FR
chemical selection
Alternatives exist to brominated FRs
in PCBs based on phosphorus.
Reactive FRs would likely meet
tighter risk phrase requirements.
A number of non-halogenated FR
chemicals exist, but impact on
performance of plastic and cost.
Certain manufacturers already
eliminating halogenated FR
chemicals.
PBBs and PBDEs excluded.
Risk phrases R40, R45, R46, R50, R51, R52, R53, R60,
R61, R62, R63 all excluded
unless reactive and hence
lose Rphrase. The R40,
R52, R62 exclusions do not
apply to PCs
Chlorparaffins excluded (for
PCs).
Not included in Annex 1 to
Directive 67/548/EEC (for
PCs)
A wide range of FR
chemicals available,
but with cost
penalties
More expensive that
BFR alternatives
Exemptions in
other ecolabels
for fluorinated
compounds.
White list of allowable FR
compounds only
Several lists of non-halogenated or non-brominated compounds have
been produced by e.g. the Lowell
Centre
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13 Fire Retardants and the EU Ecolabel
13.1 Overview
The Ecolabel review and awareness survey is reported in detail in Annexe 4 8; the first part reviews the
current ecolabels operating in Europe and their specifications relating to FR use. The EU Ecolabel is then reviewed in greater detail and its FR criteria compared with that of other schemes.
All of the consumer products being considered in this review are eligible to apply to obtain the European
Ecolabel49
. The Ecolabel scheme is voluntary and was established in 1992 to encourage businesses to
market products that used sustainable and environmentally friendly technologies throughout the supply chain. Take-up has grown more rapidly in recent years.
The scheme forms part of a broader environmental plan on sustainable consumption and production and
sustainable industrial policy that was adopted by the EU Commission on the 16th July 2008
50. At the
beginning of 2009 there were more than 750 companies that had obtained the stringent EU Ecolabel
requirements for their products. Italy, France, Denmark and Germany hold the greatest number of licenses
(~480) for products.
13.2 Introduction
The EU Ecolabel is a so-called “Type One” ecolabel in that it requires verification by a third party and may not be self-certified by the applicant. It is therefore one of the most stringent ecolabels in terms of the
verification requirements. In the context of fire retardant chemicals the most important other ecolabel schemes for comparison are the German Blue Angel and the Scandanavian Nordic Swan, since these are:
Also “Type One” Ecolabels
Typically have specific and demanding FR chemical requirements
The EPEAT scheme is also included since this is important as a leading US scheme that includes
materials and not just energy consumption. Other national ecolabel schemes were reviewed from:
Sweden (the TCO label for IT equipment)
Spain and Cataloni (AENOR and El Distintiu)
Hungary (which is generally identical to the EU Ecolabel)
Czech Republic
49 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2000:237:0001:0012:EN:PDF Regulation (EC) No 1980/2000 of the European Parliament and of the Council of 17 July 2000 on a Revised Community Eco-label
Award Scheme. 50 http://ec.europa.eu/environment/eussd/pdf/com_2008_397.pdf Communication from the Commission to the
European Parliament, the Council, the European Economic and Social Committee and the Committee of the regions
on the Sustainable Consumption and Production and Sustainable Industrial Policy Action, Com (2008) 397 Final,
16-07-2008.
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The Netherlands
France (NF Mark)
But these were did not have the same relevance to FRs. A comparison of the FR requirements of these
different ecolablels is given in Annex 4.
Table 4.3 in this Annex indicates the detailed differences and similarities between the EU Ecolabel and the Nordic Swan, Blue Angel and EPEAT schemes. The product groups selected for comparison are those
in the EU Ecolabel which contain FR criteria. These are:
Textiles
Mattresses
Personal Computers (PCs)
Portable Computers (“laptops”)
Televisions (TVs)
The main similarities across the chosen ecolabels are:
Ecolabels use hazard statements of ingredients as a proxy for risk assessment
Restrictions are usually based around general restrictions on classes of compound (sometimes
supplemented by exemptions) and the use of risk phrases.
The main general restrictions are on the use of PBB, PBDE, chlorinated paraffins and organic
halogenated FRs. These are applied to different extents across the ecolabels.
The main exemptions refer to fluorinated organic compounds, or plastic parts <25g
Typical risk phrase restrictions are R45, R46, R50-R53, R60, R61
There is one attempt only to harmonise with REACH (German Blue Angel RAL-UZ 135 on
netbooks)
Discussions with business stakeholders indicated that the specialist textile label Oekotex, which
combines concerns for human and environmental exposure to chemicals, was of particular relevance. This has been included in the summary. It prohibits all FRs except for those on a
“white list” of approved chemicals.
The purpose of this section is to examine the current EU Ecolabel criteria in the light of the latest evidence on risk assessment and on possible alternative approaches, including comment from
stakeholders, and to determine what changes in the criteria, if any, should be proposed. Life cycle
comments have been made where these are likely to be relevant, although the scope of the project does not include an analysis of product or FR LCAs.
13.3 Criteria for Improved Environmental Performance in Ecolabel
GR241/Defra/2010 87 of 115 November 2010
The current EU Ecolabel criteria are summarised in Table 6 below:
Table 6 Summary of EU Ecolabel Product Criteria and Restrictions
EU Ecolabel
Product
Group
Sub-Group Valid
Until
Restrictions on Fire Retardants
Textiles51
Textile clothing
& Accessories.
Interior Textiles,
Fibres Yarn & Fabric
10th July
2013
Only reactive fire retardants are allowed plus restriction
on certain R-Phrases
Electronic
Equipment
Personal
Computers52
Portable
Computers53
31st May
2010 Plastic parts shall not contain poly-brominated biphenyl
(PBB) or poly-brominated diphenyl ether (PBDE) fire
retardants as listed in Article 4 to Directive 2002/95/EC of the European Parliament and of the Council. Also
Plastic parts shall not contain chloroparaffin fire
retardants with chain length 10-17 carbon atom Also
restriction of FRs in plastic parts >25g that contain certain R-Phrases.
TV54
31st
October
2013
Plastic parts shall not contain poly-brominated biphenyl
(PBB) or poly-brominated diphenyl ether (PBDE) fire
retardants as listed in Article 4 to Directive 2002/95/EC of the European Parliament and of the Council. Also
restriction of FRs in plastic parts >25g that contain
certain R-Phrases.
Mattresses55
Bed mattresses,
fillings for bed mattresses
10th July
2013
Only reactive fire retardants are allowed plus restriction
on certain R-Phrases. Alternative hazard statements are used.
It is assumed that the efficacy of the fire retardant in use is dealt with via national legislation or by EU
legislation. Therefore this study does not consider for example arguments around the different modes of
action of FRs, or the toxicity of products generated during a fire. The eligibility of FR chemicals that
have been reviewed as part of this project to be used in the different Ecolabel product groups is
summarised in Tables 4-9 and 4-10 in Annex IV.
The basis for selecting or preferring Ecolabel criteria for FRs is based upon:
Assessment of risk, which is made operational in ecolabels through the hazard statements of
ingredients
51 EU Ecolabel criteria for textile products 52 EU Ecolabel for personal computer products 53 EU Ecolabel criteria for portable computer products 54 EU Ecolabel criteria for TV products 55
EU Ecolabel criteria for bed mattresses
GR241/Defra/2010 88 of 115 November 2010
Environmental impacts over the life cycle of the product
Technical ability to meet the required legislative standards
Information on risk (more precisely, hazard) assessments is presented in Annex 2, and technical ability of
alternative technologies is presented in Annex 3. Analysis and comparison of whole life cycle impacts of
FRs lie outside of the scope of the project. However, we may use certain principles to guide the
comparison, such as the Principles of Green Chemistry. These include waste prevention, use of substances
that possess little or no toxicity to human health and the environment and minimisation of toxicity of
chemicals 56.
From this we can derive the following preferences, which may be subject to individual life
cycle amendments, but do give a hierarchy of approaches to evaluate the suitability of the varying
specifications across the different product groups. This approach is based on the premise that the
avoidance of FR chemicals is to be preferred through either use of alternative materials or through design.
If FR chemicals are used, then a number of approaches are used to minimise their environmental impact.
The hierarchy used is discussed in section 11
The choice of options was determined by the review of the ecolabel schemes, the review of the risk
assessment data available, and the technical options for substitution.
There is a final option of using a “White List” i.e. prohibiting all fire retardants except for specified
chemicals that have been incontrovertibly shown to be of very low hazard. This approach has been used in
the Oekotex textile label. All of these approaches can be used in isolation or in combination.
Using information on the technical alternatives to existing FR chemicals (Annex 3), the analysis of FR
risk assessments (Annex 2), and information from the stakeholder survey that is believed to be sufficiently
validated, a series of matrices have been created for each relevant product group. These are shown in full
in Tables 4-4 to 4-8 in Annex IV. Included in these matrices are information about the cost and choice
implications of using the different approaches, which is relevant for GPP. Business stakeholder
comments on these approaches are given in Sections 1.3 and 1.4 below.
The general conclusions of the analysis are:
Alternative non-FR approaches: there are successful low flammability or FR by design
approaches in almost all of the product categories. These do lead to restriction of choice of material, most noticeably the restriction in cellulosic textiles and in the use of certain common
plastics in electronics. Costs would increase and the degree of choice decrease in many cases. No
firm estimates have been made of the impact on final pricing of the FR-containing product, but it is believed that these would be modest, therefore within the scope of Ecolabel but possibly more
problematic with GPP. Elimination of FRs would also bring other advantages such as greater ease
of recycling of plastics in the electronics sector.
Although there is probably insufficient evidence that FR chemicals can be excluded from EU Ecolabelled products, sufficient evidence exists to insist upon continued high levels of
environmental performance from FR chemicals, since substitution by non-FR approaches is
possible in many cases.
56 “Principles of Green Chemistry” Anastas P. T., Warner J.C. Oxford University Press, 1998, p30
GR241/Defra/2010 89 of 115 November 2010
Restriction of choice of additive FRs: Tables 4-9 and 4-10 in Annex 4 illustrate the impact of
the exclusion of additive FR chemicals from the textile EU Ecolabel, with several chemicals with
acceptable R-phrases excluded and just a small number of reactive FR chemicals acceptable. Subject to consideration of impacts elsewhere in the product lifecycle, the exclusion of additive
FRs appears to create substantial restrictions not justified on hazard assessment grounds.
Exclusion of classes of compounds: brominated compounds can be excluded from all product
categories, since alternatives do exist. Similarly, chlorinated compounds with the current exception of polyurethane foams. However brominated and chlorinated FRs do exist with
acceptable risk phrases for the current Ecolabel criteria.
13.4 Stakeholder Comments on Criteria Options for Textiles and Mattresses
13.4.1 Design and Low Flammability Options
Certain design- and inherently FR-led approaches are possible for textile products, and there are
successful examples in each product category. However they do lead to the restriction of choice for the
consumer in some way, usually limiting the choice of covering or filling materials. For example,
children‟s sleepwear would likely be restricted to polyester; polyurethane foam would be likely to be
excluded from mattresses. Costs would increase in almost all cases.
Children‟s sleepwear is generally untreated polyester, which would therefore be able to meet Ecolabel
criteria. There are FR treated cottons (phosphorus or nitrogen-based) available, but there were some
concerns over skin irritation or reaction that might be caused in children.
Inherent FR materials such as Kevlar and Kermel are required in high specification PPE such as
Firemen‟s uniforms. Lower specification PPE can use FR treated materials that meet the current EU
Ecolabel criteria. The main concern here is formaldehyde limits arising from the use of certain FR types
rather than the risk phrases of the FR chemical.
Two examples were found of mattress manufacturers who met the UK legislative requirements with low
flammability materials (or combinations of materials, namely wool, natural latex and coir). Coir was
often used as a stabilising centre, wrapped in wool or latex, giving a greater range of firmness/softness to
the mattress, whilst still maintaining an FR free body. One of these manufacturers additionally used side
seaming to make passing the appropriate British Standard test on the mattress easier. Non-halogenated
FRs could be used with mattresses higher in synthetic fibres to meet this standard.
Inherent FR approaches were possible for interior furnishings, for example the use of modified
acrylic/cotton blends (i.e. a partially inherently FR blend). There is also some use of inherently FR
polyester in the top cover. The general approach was to meet flammability requirements by either a
treated top cover (Pyrovatex or equivalent) or by treated foam.
13.4.2 FR Chemical Options
Polyurethane foam mattresses currently require chlorinated or non-chlorinated phosphorus FRs. The
chlorinated compounds are regarded as the standard FR chemicals, with non-chlorinated being less
characterised with respect to performance and risk.
GR241/Defra/2010 90 of 115 November 2010
The exclusion of specific product categories such as brominated or halogenated compounds was not
favoured by most of the manufacturers, nor by some of the users. However there was a widespread
acceptance by a number of consultees that brominated compounds would likely not be acceptable to
consumers in high-end environmentally-conscious products. There was also some movement to remove
halogenated FRs, largely from foam. Hence an exclusion of all halogenated compounds from Ecolabel
textile products appears technically feasible, but not supported by the bulk of the organisations consulted
because of:
Cost
Principle (use of risk phrases was believed to be more scientifically defensible than using
chemical type)
Risk (alternatives may not have been as rigorously hazard assessed)
Adoption of a white list similar to Oeko-tex was generally not favoured – the use of risk phrases was felt
to be more flexible. However restriction to the list of Oeko-tex allowable FRs was not believed to cause
any particular cost issues, since many of the widely used FRs were on their white list.
13.5 Stakeholder Comments on Criteria Options for Electronic Equipment
13.5.1 Design and Low Flammability Options
As regards designing out FRs, the larger size of the products now produced (and hence greater fire load)
was felt by one end user to be an important factor in the use of FRs rather than simply using design. Also
that approaches such as the greater use of metals brought different risks such as short circuits. There
would also be other issues that might give problems at other points of the lifecycle e.g. greater weight.
There were also other requirements for components such as US Underwriters Laboratory requirements on
hot parts and live voltage parts to be fire retarded in case of a fault condition. Hence business stakeholders
perceived use of inherently FR or use of design as an incomplete solution to FR requirements.
13.5.2 FR Chemical Options
There was a general acknowledgement by users of FRs of a move towards non-halogenated FR chemical
systems.
The issue of less information on the newer FR chemicals compared to the greater knowledge on
incumbent FRs was acknowledged. Solutions suggested include:
An inferring of likely problems when looking at new candidates before they had been rigorously
risk assessed – for example those based on readily available inorganic materials such as
magnesium hydroxide were likely to be less hazardous than those based on complex organo-
phosphorus chemistry
GR241/Defra/2010 91 of 115 November 2010
A period of grace, such that if newer FRs are recategorised with risk phrases following more
extensive testing, then companies who have adopted them as substitutes should have a number of
months to reformulate without losing the Ecolabel
The requirement comparable datasets on FR chemicals. This could be made operational by
requiring any FR chemical to have been tested for the risk phrases excluded by Ecolabel before it
can be used in an Ecolabelled product
Projects such as the EU ENVIROFER project will help to fill in the gaps, not just with the newer FRs, but
also with some of the organobromine and inorganic FRs, where there are still some data gaps.
There was no mention of the new “candle” test that may be required for all TVs across Europe in the
future, but this may affect the choice of FR system.
13.6 General Comments
13.6.1 Flammability criterion within Ecolabel
There was general support for inclusion of flammability criteria in the Ecolabel from those who expressed
an opinion, apart from a supplier of natural materials.
13.6.2 Use of risk phrases
Certain of the consultees, particularly in the electronics sector, were critical of the use of risk phrases. However this was felt by them to be an issue across all of the Ecolabel product groups and criteria and it
would best dealt with by a general consideration of the risk phrase approach, rather by one that simply
related to FRs. Proposals by consultees included aligning consideration with the REACH and CLP process.
13.6.3 Stakeholder survey general conclusions
The conclusions from the survey were:
i. Only about 60% of the respondents used FR chemicals in the products that they either
manufactured or represented (see Figure 8 below). The results are consistent with the matrices of
criteria options generated for each product group (Tables 4-4 to 4-8 in Annex IV). FR chemicals
were used by all electronic and foam respondents; by none of the nightwear respondents; and by a
minority of the textile respondents; by most of the PPE respondents. Although the low sample size
per product group should encourage caution in interpretation, the results are consistent with the
technical ability to use alternative approaches such as low flammability materials or design
approaches to meet FR requirements.
ii. Slightly more than 50% of the FR chemicals used were additive FRs, although over 30% of
respondents were unsure of how to categorise the FRs.
iii. There was a good awareness of the EU Ecolabel, with 58% of respondents being aware (100%
awareness in the electronics product group)
GR241/Defra/2010 92 of 115 November 2010
iv. A great deal of uncertainty was expressed over whether business stakeholders would consider
applying for Ecolabel (this could have been in the way the question was expressed). Notably in
the textiles area the Oekotex standard was felt to be better recognised by customers whilst being
considered of an acceptable environmental standard.
v. There was concern from foam and furniture sectors about the exclusion of additive FRs
vi. Costs were estimated to increase in the textile and mattress product groups if the increased use of
inherently FR or low flammability materials was to necessary for the EU Ecolabel. Costs would
be unchanged in sleepwear, since no changes are required. It was believed that costs in electronics
would not necessarily rise for the end consumer.
14 General Comments and Recommendations
The general findings of this work make it clear that (1) there is significant scope to move towards design-
based and intrinsic fire retardancy approaches which can avoid the use of chemical FR technologies.
However, adoption of these better environmentally performing technologies, as measured by risk phrases
and the use of exclusion criteria in EU Ecolabels may not in all cases offer the best whole life
environmental performance. These may also exclude chemical FR technologies that are good
environmental performers.
So, (2) while adoption of non-chemical FR technologies is to be encouraged, it may take some time for
this to occur and it may be constrained by costs and other technical, environmental and market factors. It
is therefore prudent to maintain Ecolabel approval of safe and low hazard chemical FR technologies that
can play a role in maintaining product fire performance standards. This may require that existing Ecolabel
criteria be reviewed and modified to enable a balanced position to be achieved which does not
compromise human or environmental safety or compromise advances in fire safety that have been
achieved with existing FR technologies.
Such a balanced position may encourage more product manufacturers to improve their products to qualify
them for Ecolabels. This may also encourage a balanced position to be adopted within green procurement
which is likely to follow the lead set by Ecolabels.
(3) Exclusion of brominated FRs is technically possible for all product groups but is not considered
essential for either reactive FRs such as TBBPA as used and chemically transformed in printed circuit
boards, or polymeric brominated FRs unless these are known to pose serious chemical hazards and risks
to humans and the environment.
(4) Exclusion of chlorinated FRs is also possible for almost all product groups, although their possible
substitutes in polyurethane based foam are not as well characterised with respect to risk and fire
performance. Exclusion based purely on possession of a certain chemical moiety cannot be scientifically
justified unless there is sufficient evidence across a range of compounds to apply the precautionary
principle. While this is the case for some brominated compounds such as the PBDEs, this is not
necessarily the case for all brominated compounds and certainly not for all chlorinated compounds.
(5) The descriptions of terms such as “reactive”, “inherent FR” or “additive” was criticised by certain
respondents as sometimes misleading, and unable to describe accurately the way in which some FR
chemicals are incorporated or act. Similarly, exclusion based on such terms is artificial and non scientific
in risk assessment terms and the elimination or modification of such vocabulary would be helpful.
GR241/Defra/2010 93 of 115 November 2010
Flammability criterion within Ecolabel
(6) There is general support for inclusion of a flammability criterion in the EU Ecolabel. Consideration
should be given to whether flammability is a key performance criterion of the Ecolabel product groups
considered here.
Information on newer FRs
It is acknowledged that there is less human and environmental exposure risk information on the newer FR
chemicals compared to greater knowledge on incumbent FRs. Some comments from survey respondents
that are relevant to practical implementation of newer FRs include:
- There might have to be an inferring of likely problems when looking at new candidates before
they have been rigorously hazard and risk assessed – for example those based on readily available
inorganic materials such as magnesium hydroxide or those based on simple organics are likely to
be less hazardous than those based on complex organo-phosphorous chemistry
- A period of grace should be included such that if newer FRs are re-categorised with risk phrases
following more extensive testing, then companies who have adopted them as substitutes should
have a period time to reformulate without losing the Ecolabel
- Projects should be encouraged which help to fill data gaps not just for the newer chemical FRs,
but also for some of the organohalogen and inorganic FRs, where there are still significant data
gaps.
(7) The setting of Ecolabel criteria should be closely allied to the process of REACH and CLP in Europe
and benefit from the hazard and risk data gathering exercises that form part of REACH for all chemical
FR technologies.
(8) Harmonisation of the risk-phrase approach within Ecolabels with REACH and CLP should be
addressed, probably as a cross-cutting theme across all the Ecolabel criteria that use risk phrases.
15 Are the Current EU Ecolabel Criteria Fit For Purpose?
The existing EU Ecolabel criteria for the products considered here are too restrictive and are not consistently based on the risk phrase approach to environmental performance. Meaningful and balanced
Ecolabel criteria are likely to be based on:
1. Encouragement to use non-chemical FR technologies such as product design and inherent FR
materials. For GPP this would also require it being achieved at reasonable cost.
2. Exclusion of any chemical FRs that are known to be hazardous through appropriate risk-phrase
hazard assessment and, where appropriate, risk assessment. It is not appropriate to exclude all classes of brominated FRs due to the poor environmental performance of some classes.
3. Inclusion of chlorinated FRs that meet ecolabel hazard criteria.
GR241/Defra/2010 94 of 115 November 2010
4. Inclusion of both additive and reactive chemical FR types, as currently defined, but subject to
ecolabel criteria. Cease to use exclusion criteria based on “reactive” and “additive” terminology
and avoid the use of such terminology in the setting of criteria.
5. Alignment of criteria setting with REACH and CLP in Europe; this should include consideration
of the effect of FRs being chemically and physically bound into materials rather than based on
free molecule hazard assessments.
6. Regular review of the criteria to keep pace with hazard and risk information developments under REACH and CLP. FR chemicals should not be used in ecolabel products unless they have
adequate toxicity data to ensure that no classification is required in respect of the specific risk
phrases listed in the ecolabel. Absence of data and absence of classification should not mean that an FR is acceptable.
7. A fire retardancy criterion to ensure the fire performance of products is not compromised.
GR241/Defra/2010 95 of 115 November 2010
Appendix 1: Summary Tables of FR Chemical Risk Assessment and Classification
From Annexe 2 on hazard and risk assessment 6.
Table A1: FRs subject to European Risk Assessment
Name C
AS
nu
mb
er
EU
Nu
mb
er
Ab
bre
via
tion
Late
st A
sses
smen
t
Ris
k P
hra
ses#
Haza
rd
Cla
ss
an
d
Cate
gory
Cod
e(s)
##
Haza
rd
Sta
tem
ent
Cod
e(s)
##
Work
ers
Con
sum
ers
Man
via
En
vir
on
men
t
Aq
uati
c
Ter
rest
rial
Atm
osp
her
e
Sec
on
dary
pois
on
ing
ST
P
Comments
PENTABROMODIPHENYL
ETHER
32534-81-9 251-084-2 Penta
BDE
2000 Xn; R48/21/22
R64
N; R50-53
Acute Tox. 4
Acute Tox. 4
Aquatic Acute 1
Aquatic Chronic 1
H312
H302
H400
H410"
(i)
(iii)
(i)
(iii)
(i)
(iii)
(iii) (iii) (ii) (iii) (i) Banned.
Possible risk to
babies through
human breast milk.
Possible secondary
poisoning.
OCTABROMODIPHENYL
ETHER
32536-52-0 251-087-9 Octa
BDE
2003 Repr. Cat. 2;
R61 Repr. Cat. 3;
R62
Acute Tox. 4
Aquatic Acute 1 Aquatic Chronic 1
H302
H400 H410"
(i)
(iii)
(ii) (i) (ii) (i) (ii) (i) (i) Banned.
Respiratory and female fertility
effects. Possible risk
of secondary
poisoning and more
toxic degradation
products
BIS(PENTABROMODI
PHENYL) ETHER
1163-19-5 214-604-9 Deca
BDE
2003
2004
2007
N; R50-53 N/C (i) (i) (i) (ii) (ii) (ii) (i) (ii) Possible risk of
secondary poisoning
and more toxic
degradation products
TETRABROMOBIS
PHENOL-A
79-94-7 201-236-9 TBBP-A
or
TBBPA
2006 N; R50-53 N/C (ii) (ii) (ii) (i)
(iii)
(i)
(iii)
(i) (ii) (ii) Very toxic to aquatic
organism
HEXABROMOCYCLO DODECANE
25637-99-4 247-148-4 HBCDD or HBCD
2008 N; R50-53 R62/63, R64
N/C (i) (iii)
(ii) (ii) (iii) (iii) (ii) (iii) (iii) Possible neuro-toxicity
GR241/Defra/2010 96 of 115 November 2010
Name
CA
S n
um
ber
EU
Nu
mb
er
Ab
bre
via
tion
Late
st A
sses
smen
t
Ris
k P
hra
ses#
Haza
rd
Cla
ss
an
d
Cate
gory
Cod
e(s)
##
Haza
rd
Sta
tem
ent
Cod
e(s)
##
Work
ers
Con
sum
ers
Man
via
En
vir
on
men
t
Aq
uati
c
Ter
rest
rial
Atm
osp
her
e
Sec
on
dary
pois
on
ing
ST
P
Comments
proposed
DIANTIMONY TRIOXIDE 1309-64-4 215-175-0 ATO 2008 R40
R38 proposed
by rejected
Carc.2 H351 (iii) (ii) (ii) (iii) (ii) (ii) (ii) (ii) Possible skin
irritation
TRIS(2-CHLORO-1-METHYLETHYL)
PHOSPHATE
13674-84-5 237-158-7 TCPP 2008 R22 proposed N/C (iii) (ii) (ii) (ii) (ii) (ii) (ii) (ii) Possible fertility and developmental
toxicity
TRIS[2-CHLORO-1-
(CHLOROMETHYL)ETHYL
] PHOSPHATE
13674-87-8 237-159-2 TDCP 2008 N; R51-53 R22 proposed
N/C (i)
(ii)
(i)
(ii)
(iii) (iii) (iii) (iii) (iii) (iii) Possible female
fertility effects
2,2-BIS(CHLOROMETHYL)
TRIMETHYLENE
BIS[BIS(2-CHLOROETHYL)
PHOSPHATE]
38051-10-4 253-760-2 V6 2008 Possible R60
due to
impurity
N/C (ii) (ii) (ii) (ii) (ii) (ii) (ii) (ii) No risks identified
TRIS(2-CHLOROETHYL)
PHOSPHATE
115-96-8 204-118-5 TCEP 2009 Carc. Cat. 3;
R40
Repr. Cat. 2;
R60
Xn; R22
N; R51-53
Carc. 2
Repr. 1B
Acute Tox. 4
Aquatic Chronic 2
H351
H360F
H302
H411
(iii) (iii) (ii) (ii) (ii) (ii) (ii) (ii) Possible
carcinogenicity
unless contaminated
Medium chain chlorinated
paraffins
85535-85-9 287-477-0 MCCP 2007 R64
R66
N; R50-53
Lact.
Aquatic Acute 1
Aquatic Chronic 1
H362
H400
H410
(iii) (ii) (ii) (iii) (iii) (ii) (iii) (ii)
Short chain chlorinated
paraffins
85535-84-8 287-476-5 SCCP 2008 Carc. Cat. 3;
R40, R66
N; R50-53
Carc. 2
Aquatic Acute 1
Aquatic Chronic 1
H351
H400
H410
(ii) (ii) (ii) (i),
(iii)
(i0 (ii) (iii) (ii)
# Risk phrases from Table 3.2 of CLP Annex VI ## Hazard phrases from Table 3.1 of CLP Annex VI N/C Not classified on Annex VI of CLP
GR241/Defra/2010 97 of 115 November 2010
EU Risk Assessment standard “conclusions” statements:
(i) There is a need for further information and/or testing
(ii) There is at present no need for further information and/or testing and no need for risk reduction measures beyond those which are being applied
already.
(iii) There is a need for limiting the risks; risk reduction measures which are already being applied shall be taken into account
It should be noted that the risk assessments strictly only apply to a particular physical form of a chemical and in a particular application or use for which it was assessed. It cannot therefore be automatically assumed that a chemical assigned conclusion (ii) is necessarily safe in all its forms or uses.
It should also be noted that, we believe that, the ESIS data are not longer kept up-to-date although there is no statement to that effect on their website. Annexe
VI CLP contains more up-to-data for some chemicals, but is, currently, far from complete for others.
GR241/Defra/2010 98 of 115 November 2010
Table A2: DecaBDE and Alternatives in Electrical and Electronic Equipment from the Danish EPA 200757
CAS NO EU Risk
Assessed
UKCCRMP58
Risk
Assessed
ESIS
Classification
chemBlink59
Classification
Ethane-1,2-bis(pentabromophenyl) 84852-53-9 N Y N/C N/A
Ethylene bis(tetrabromophthalimide)
32588-76-4 N N/C N/A
Bis(tribromophenoxy)ethane 37853-59-1 N N/C N/A
Tetradecabromodiphenoxybenzene 58965-66-5 N N/C N/A
Tetrabromobisphenol A (TBBPA) 79-94-7 Y R50/53, S60, S61
R36/37/38
S26;S37/39
Tetrabromobisphenol A bis (2,3-
dibromopropyl ether)
21850-44-2 N N/C N/A
Brominated polystyrene 88497-56-7 N/A* N/A N/A
Poly(dibromostyrene) 148993-99-1 N/A N/A N/A
Brominated epoxy polymer 68928-70-1 N/A N/A N/A
Poly pentabromobenzyl acrylate 59447-57-3 N/A N/A N/A
Phenoxy-terminated carbonate
oligomer of Tetrabromobisphenol A
94334-64-2
71342-77-3
N/A
N/A
N/A N/A
Tris(tribromophenoxy) triazine 25713-60-4 N N/C N/A
Dodecachloro dodecahydro
dimethano dibenzocyclooctene
13560-89-9 N N/C N/A
57 http://www2.mst.dk/Udgiv/publications/2007/978-87-7052-349-3/pdf/978-87-7052-350-9.pdf 58 http://www.defra.gov.uk/environment/quality/chemicals/ukrisk.htm 59
http://www.chemblink.com/
GR241/Defra/2010 99 of 115 November 2010
CAS NO EU Risk
Assessed
UKCCRMP58
Risk
Assessed
ESIS
Classification
chemBlink59
Classification
Resorcinol bis(diphenylphosphate)
(RDP)
57583-54-7 N Y N/C N/A
Bisphenol A bis(diphenyl
phosphate) (BAPP)
181028-79-5 N/A N/A N/A
Bisphenol A bis(diphenyl
phosphate) (BDP)
5945-33-5 N N/C N/A
Cresyl diphenyl phosphate (CDP) 26444-49-5 N Y N/C N/A
Triphenyl phosphate (TPP) 115-86-6 N Y N/C R50/53
S60;S61
Triaryl phosphates butylated 68937-40-6 N N/C N/A
Magnesium hydroxide 1309-42-8 N N/C R36/37/38
R36/37/38
Red phosphorous 7723-14-0 N R17, R26/28,
R35, R50; S1/2, S5, S26,
S38, S45, S61
R11; R16;
R52/53
S43C; S61; S7
Ammonium polyphosphate 14728-39-9
68333-79-9
N/A
N
N/A
N/C
N/A
Melamine polyphosphate 218768-84-4 N/A N/A N/A
Melamine Cyanurate 37640-57-6 N N/C N/A
Organic phosphinates 225789-38-8 N/A N/A N/A
Reogard 1000 Pentaerythritol Phosphate
Alcohol, Melamine Phosphate,
5301-78-0
41583-09-9,
N
N,
N/C
N/C
N/A
GR241/Defra/2010 100 of 115 November 2010
CAS NO EU Risk
Assessed
UKCCRMP58
Risk
Assessed
ESIS
Classification
chemBlink59
Classification
Cryst Silica Quartz 14808-60-7 N N/C
N/A = not listed in the ESIS database
N/C – Not Classified in the Annex I of Directive 67/548/EEC
GR241/Defra/2010 101 of 115 November 2010
Table A3: Chemical Classification of Some Commercial Fire Retardants Chemicals from the FR Survey
Chemical Name from Survey Formal Name CAS NO ESIS Risk
Assessment
Hazard
Classification
from EA
ACCESS
Database
ESIS
Classification
chemBlink60
R phrases
chemBlink
S Phrases
2,2-bis(chloromethyl)trimethylene
bis(bis(2-chloroethyl)phosphate)
(V6)
38051-10-4 Y N/C N/A
2,4,6 Tribromophenol61
118-79-6 N N/C R20/22,
R36/37/38,
R51/53
S26, S36/37,
S61
ammonium polyphosphate 68333-79-9 N/A N/A N/A
Bisphenol A Bis-(Diphenyl
Phosphate)
181028-79-5 N/A N/A N/A
bis(Tribromophenoxy)ethane 1,1'-[ethane-1,2-
diylbisoxy]bis[2,4,6-tribromobenzene]
37853-59-1 N N/C R20/22;
R36/37/38; R51/53
S26; S37/39;
S61
cresyl Diphenyl Phosphate diphenyl tolyl phosphate 26444-49-5 N N/C N/A
Decabromodiphenyl-oxide??
(DecaBDE)
CAS NO refers to
bis(pentabromophenyl) ether 1163-19-5 Y N/C R20/21/22 S36/37
60 http://www.chemblink.com/ 61
https://www.who.int/ipcs/publications/cicad/cicad_66_web_version.pdf
GR241/Defra/2010 102 of 115 November 2010
Chemical Name from Survey Formal Name CAS NO ESIS Risk
Assessment
Hazard
Classification
from EA
ACCESS
Database
ESIS
Classification
chemBlink60
R phrases
chemBlink
S Phrases
decabromodiphenyl ether
Decabromodiphenylethane 1,1'-(ethane-1,2-
diyl)bis[pentabromobenzene]
84852-53-9 N N/C N/A
diethylphosphinic acid, aluminium salt
N/A N/A N/A N/A
Ethane-1,2-
bis(pentabromophenyl)
1,1'-(ethane-1,2-
diyl)bis[pentabromobenzene
84852-53-9 N N/C N/A
Hexabromo-cyclododecane 25637-99-4 Y N/C N/A
Melamine 1,3,5-Triazine-2,4,6-triamine 108-78-1 N N/C R20/21; R44 S36/37
Melamine Cyanurates 1,3,5-triazinane-2,4,6-trione 504-19-8 N/A N/A N/A
Melamine polyphosphate 20208-95-1 N/A N/A N/A
phosphorus polyols N/A N/A N/A N/A
Poly(dibromostyrene) 148993-99-1 N/A N/A N/A
Resorcinol Bis-(diphenyl
Phosphate)
tetraphenyl m-phenylene
bis(phosphate)
57583-54-7 N N/C N/A
Tetrabromobenzoate ester N/A N/A N/A N/A
Tetrabromo-bisphenol-A 2,2',6,6'-tetrabromo-4,4'-isopropylidenediphenol
79-94-7 Y ? R 50/53 N; R50-53
S60, S61
R36/37/38 S26;S37/39
Tetrabromophthalic anhydride 4,5,6,7-tetrabromo-2-
benzofuran-1,3-dione
72625-95-7 N/A N/A N/A
Tetrabromobenzoate ester N/A N/A N/A N/A
GR241/Defra/2010 103 of 115 November 2010
Chemical Name from Survey Formal Name CAS NO ESIS Risk
Assessment
Hazard
Classification
from EA
ACCESS
Database
ESIS
Classification
chemBlink60
R phrases
chemBlink
S Phrases
Tetrabromophthalate ester bis(2-ethylhexyl)
tetrabromophthalate
26040-51-7 N N/C N/A
Triarylphosphates isopropylated Phenol, isopropylated,
phosphate (3:1)
68937-41-7 N N: R51/53 N/C N/A
Triarylphosphates isopropylated
7% phosphorus
tris(isopropylphenyl)
phosphate
26967-76-0 N N/C N/A
Tribromophenyl allyl ether 2-(allyloxy)-1,3,5-tribromobenzene
3278-89-5 N N/C N/A
Tricresyl Phosphate tris(methylphenyl) phosphate 1330-78-5 N N/C R39/23/24/25;
R51/53
S20/21;
S28A; S45;
S61
Tris (2,3-dichloroisopropyl)
phosphate
tris[2-chloro-1-
(chloromethyl)ethyl]
phosphate
13674-87-8 Y N/C N/A
Tris (2-monochloropropyl) phosphate
tris(2-chloro-1-methylethyl) phosphate
13674-84-5 Y N/C N/A
Trxylyl phosphate 68952-33-0 N N/C N/A
N/A – Not available N/C – Not Classified in the Annex I of Directive 67/548/EEC
GR241/Defra/2010 104 of 115 November 2010
Appendix 2: Existing, Substitution and Emerging Technologies for Fire Retardant Nightwear
Existing FR Technologies Substitution Technologies Emerging Technologies
Children’s Nightwear
In UK usually 100% polyester fabric (free of all impurities) is used, which can pass the BS 5722:1984 test. No further FR treatment required.
In EU due to no regulations, it is likely that pure polyester, cotton, polyester/cotton or acrylics are used
To pass US regulations FR treatment is required:
- polyester/polyester Trevira CS blend (some
percentage of Trevira) used. Trevira CS is produced by incorporating a comonomeric phosphinic acid
unit into the PET polymeric chain, hence is an
inherently fire retardant fibre.
- 100% polyester may be FR treated with a phosphorus-based durable chemical finishes of the
cyclic oligomeric phosphonate type (eg, Antiblaze
CU, Rhodia Specialities Ltd; Aflammit PE, Thor) is applied by the pad-dry-cure method.
- For cotton-rich, polyester/cotton blends phosphorus
and nitrogen based durable finishes are applied. The most commonly used durable commercial finishes is
tetrakis hydroxyl methyl phosphonium chloride-urea
To reduce thermoplasticity of polyester, use
polymer layered silicate nanocomposites in combination with nominal amounts of
phosphorus-based fire retardants. The
phosphorus- based fire retardant could be a combination of comonomer/copolymer and
layered silicates added by melt blending or in-
situ polymerisation. Alternatively the clays can
be added in the surface finish, by nanodispersing in one of the component of the
finish.
Use inherently fire resistant fibres such as
Trevira CS polyester, Kaneka‟s Kanecaron
modacrylic (Kaneka, Japan) and Lenzing‟s FR Viscose (Lenzing GmbH, Austria). Commercial
FR polypropylenes are also available.
Industry is very keen to replace the
conventional water-based finishing processes with “dry processes” such as the
recently developed atmospheric plasma
processes to add reactive fire retardant groups to the textile surface. Although
much research is being done in this area,
most of the efforts to date are on laboratory
scale and not yet commercially exploited.
With the plasma technology novel
nanocoatings having the desired thermal
shielding effects can also be achieved. Nanoparticles with homogeneous size can
be embedded on textile substrates by
plasma polymerization / etching process or
by plasma polymerization / co-sputtering process. However, while such processes
are low in use of water or solvents they do
GR241/Defra/2010 105 of 115 November 2010
condensate (eg, Proban, Rhodia Specialities Ltd).
N-methylol dimethyl phosphonopropionamide (eg
Pyrovatex, Huntsman, formerly Ciba ) finish has been
banned in US for children nightwear due to formaldehyde release during processing.
consume electrical energy. Whether this input is less than that saved by eliminating
current drying process used in aqueous-
based fire retarding processes remains to be
seen should commercialisation occur.
Adult nightwear
In the UK most of the adult nightwear fabrics are made of
polyester/cotton, especially at the lower price end of the market. According to the Nightwear (Safety) Regulation
1985, the adult nightwear do not need to pass the BS
5722:1984 test and must carry the safety label, „KEEP
AWAY FROM FIRE‟, no further treatment to the fabrics is done.
Where required, e.g. hospitals, etc, for cotton and cotton-
rich polyester blend fabrics for nightwear, phosphorus and nitrogen-based durable finishes are applied. The most
commonly used durable commercial finishes are: tetrakis
hydroxyl methyl phosphonium chloride-urea condensate
(eg, Proban, Rhodia Specialities Ltd) and N-methylol dimethyl phosphonopropionamide (eg Pyrovatex,
Huntsman, formerly Ciba ).
As above
As above
GR241/Defra/2010 106 of 115 November 2010
Appendix 3: Existing, Substitution and Emerging Technologies for Fire Retardant Interior
Furnishings
Existing FR Technologies Substitution Technologies Emerging Technologies
Covering Fabrics
For foam-containing upholstered furniture (domestic and
office) covering textile material is usually made of
polypropylene, wool, polyester and cotton/polyester blends. All of these fibres being flammable need fire retardant
treatment and 100% thermoplastic, fusible fibres (eg
polyester, polypropylene, polyamide) are avoided unless a
char-forming supporting structure (eg backing fabric or back-coating) is present. Wool although considered inherently fire
retardant, is only relatively less flammable than cotton and
usually needs FR treatment
1. Back-coatings
The most common method of fire retarding covering fabric for foam-containing upholstered furniture (domestic and office) is by the technique of back-coating. This method
enables the reverse side of any fabric to be treated in a
manner that has minimal effect on the front face where aesthetic properties are the prime factors. Chemicals used for
back-coatings are antimony-halogen (mostly bromine)-based,
eg decabromodiphenylether (decaBDE) and antimony
To replace both bromine-containing fire retardants
(Br-FRs) and antimony trioxide in back-coatings, the
use of volatile and possible vapour phase-active,
phosphorus-based fire retardant could be made. However, at present, research has shown this to be a
viable solution but currently no widely available
commercial example is on the market. The only
There are some halogen-free back-coating
formulations available, eg, MelaphosFR™
Dartex. However, it needs to be checked as to
which fibre types will be applicable.
Thor has developed alumina trihydrate and
exfoliating graphite containing coatings, which work by providing physical barrier.
GR241/Defra/2010 107 of 115 November 2010
trioxide as synergist, and hexabromocyclododecane (HBCD)
and antimony trioxide.
These can be applied to any fibre/fabric types, including
blends and because they are not chemically bonded to the
fibre, they must be bonded physically using typically an acrylic, ethylene-vinyl acetate (EVA) or PVC based resin,
this last having an inherent fire resistant property. The
advantage of the bromine-containing back-coating formulations is that they function on any fabric composition.
The back-coating functions as a barrier layer, resisting
ignition to sources impinging upon the front face of the
fabric. Levels of application are typically in the range 25-30 wt% (dry weight) on fabric of which the fire retardants
comprise about 60-70 wt%. Typically the brominated fire
retardant: antimony oxide mass ratio is about 2:1 suggesting that total bromine fire retardant content is about 12-15 wt%.
Since decaBDE and HBCD comprise high concentrations of
brome (~80%) then this means that back-coated fabrics may comprise about 8-10wt% bromine itself.
drawback is that these coatings will be fibre specific
and so cannot be used for all fibre types and blends.
Antimony trioxide (ATO), which also has
environmental issues, could be replaced by other
synergists such as zinc stannates. Stannates show synergism with halogenated compounds in some
chemical finishes and when used as additive fire
retardants in polymers. However, most of the work at present is at the experimental stage and not used
commercially. The greater cost of zinc
hydroxystannate and zinc stannate relative to ATO
has prevented potential commercial development at the present time. Consequently, it is not known
whether they will work in back-coatings as
efficiently as ATO.
Hot melt technologies have been developed
to replace solvent and some aqueous-based
textile coating technologies but there has
been no exploitation within the textile back-
coating area to date.
2. Additive fire retardants in thermoplastic fibres
For polypropylene usually halogenated fire retardants (eg,
tris(tribomoneopentyl) phosphate (FR 372, ICL) are used, introduced in the polymer by melt blending, prior to
extrusion into fibres. These too have been traditionally used
in the presence of antimony oxide as a synergist although more recently this has been replaced by the novel hindered
Use polymeric halogenated products, which are also
acceptable through REACH. Examples of such FRs developed by ICL (Israel)) include brominated epoxy
(FR-2400), brominated polystyrene (FR-803P) and
brominated poly (benzyl acrylate) (FR-1025).
GR241/Defra/2010 108 of 115 November 2010
amine stabiliser such as NOR116 (Ciba).
3. Chemical finishes
For polyester fabrics cyclic oligomeric phosphonate (eg,
Antiblaze CU, Rhodia Specialities Ltd; Aflammit PE, Thor)
is applied as a chemical finish by pad- dry-cure method. It is believed that some chloropropyl phosphates (as used in PU
foams) have affinity for polyester and may be used as
effective fire retardants in 100% polyester fabrics.
For cotton and cotton/polyester fabrics, durable chemical
finishes such as Pyrovatex ( Huntsman, formerly Ciba) or
Proban (Rhodia) are applied. These finishes are phosphorus
and nitrogen based. While Pyrovatex is covalently bonded to cellulose structure, the Proban-type finish is a highly cross-
linked three-dimensional polymer network, enclosing the
fibrillar structures.
Use inherently fire retardant polyester, eg Trevira
CS. To reduce thermoplasticity of polyester, polymer
layered silicate nanocomposites can be added by melt blending or in-situ polymerisation.
The conventional water-based finishes could
be replaced by surface modification by
plasma technology. The interest in this has increased with the recent development of
atmospheric plasma machines for processing
wide widths of fabrics although no current
fire retardant successful example exists at the present time.
4. Inherently fire retardant fibres
Wool will pass the test only if very heavy fabric is used, ie
area density ≥ 600 g/m2. Otherwise, to pass the test the wool
is Zirpro-treated by an exhaustion method often simultaneous with the application of dye in the dyebath, where negatively
charged complexes of zirconium or titanium are ionically
bonded to positively charged wool fibres.
Modacrylics (defined as copolymers containing between 35
to 85% acrylonitrile usually with either vinyl chloride or
Use wool fabric of high area density, ie ≥ 600 g/m2.
The other inherently FR fibres include modacrylic,
which though are expensive. Blends of different fibres can also be used, eg, wool/modacylic,
wool/nylon blends, wool/FR viscose, etc.
Sometimes, fire-blockers (discussed in a later section) maybe included if required and allow the
cover fabric to be less fire resistant.
GR241/Defra/2010 109 of 115 November 2010
vinylidene chloride as second main comonomer) have typically been used in furnishing fabrics because of their
acrylic and hence wool-like handle. They are more expensive
than normal acrylics and so have found less exploitation here
as back-coated acrylics have proved to be cheaper.
Some modacrylics contain small amounts of ATO to enhance
their fire retardancy
5. Leather
Leather is inherently fire retardant and mostly used in aircraft
seats. For artificial leather inorganic fire retardants such as
borates and PVC are used as additives
Use natural leather.
Foam
Most of the fire retarded foams contain melamine and
halogenated fire retardant, added during foam preparation.
The halogenated fire retardant include tris(1-chloro-2-propyl) phosphate (TCPP) and tris (1,3-dichloropropyl 1-2)
phosphate (TDCP).
There are a number of phosphorus based fire
retardant, such as triarylphosphate, organic phosphate
ester with triphenyl phosphate, etc, but most often they are effective in combination with halogenated
fire retardants.
Use of expandable graphite, which on heating expands and provides a physical barrier.
Graphite impregnated foam (GIF), considered inherently fire-resistant, is largely
used in for aircraft seating.
There has been a considerable amount of
research in developing polymer
nanocomposite foams, which still need other
fire retardant to pass the test. However, most
of the efforts to date are on laboratory scale
and not yet commercially exploited.
Fire-blockers and Interliners
Interliners and fire-blocker materials are used between the
Fire-blockers, made from inherently fire
GR241/Defra/2010 110 of 115 November 2010
face fabric and the foam.
Interliners are usually made of cotton because of their non-
thermoplasticity, low cost and they are easily fire retarded.
Like the covering fabrics they must withstand a water soak
durability test and hence a degree of fire retardant durability is required. Polyesters may be used but because of their
thermoplasticity and inability to protect an underlying
unmodified foam, they are only used in contract furnishings where simulated match (Source 1) resistance over
unmodified PU foam is not required. In the US, the use of
inherently fire retardant fibre-containing fabrics is made although can be expensive.
For cotton Pyrovatex- or Proban-type durable finishes are applied. While these finishes are fully durable in home
laundering terms, some semi-durable finishes such as
modified ammonium polyphosphates (eg with urea) can be rendered sufficiently durable to water soaking at 40
oC if heat
cured following padding application. Examples of these and
others are marketed by Rhodia, Thor, Clariant and
Huntsman.
For polyester, phosphorus-based cyclic oligomeric
phosphonate (eg, Antiblaze CU, Rhodia Specialities Ltd; Aflammit PE, Thor) or chlorine based, TCPP chemical
finish could be applied.
The loose fillings are usually enclosed with polyester fabric.
The polyester is either Trevira CS or treated with above
Interliners from inherently fire retardants fibres can further reduce the flammability of the product. In
general if the covering material is made of > 75%
natural fibres (eg, cotton, wool and other non-
thermoplastic fibres) it does not need to be fire retarded if the interliner made of inherently fire
retardant fibres, which can pass Crib 5 test of
BS5852:Part 2:1989, is used.
retardant fibres like oxidized acrylics and aramids, were first used for aircraft seats and
now being increasingly used on trains, buses
and coaches. In the US such fire-blockers
may also comprise glass-cored yarns about which are wrapped with inherently fire
resistant fibres. This reduces the overall costs
of fabrics because of the relatively low costs of glass filament yarn components.
GR241/Defra/2010 111 of 115 November 2010
mentioned finishes.
Mattresses
Bed mattresses are composed of covering materials or tickings and a filling foam. For tickings similar fabrics and
fire retardants to those for fire-blockers and interliners are
used (see above). FR technologies for foam are similar to those for foam in upholstered furniture.
Design for upholstered furniture / mattresses By correct choice of materials the use of chemical
fire retardants can be eliminated but at increased cost.
This includes: The cover fabric can be of inherently fire retardant fibre, such as wool (high area density
fabric), modacrylic, blends of wool/modacrylic,
wool/Basofil (a melamine-formaldehyde-based fibre), etc.
Use of interliners, which can pass crib 5 BS 5852 test
or fire-blockers can improve the fire retardancy of the
furniture / mattress. Theses barrier materials can be layered. Multi-layering allows a product to maintain
its fire resistance even if one layer is compromised.
The barrier materials can be blend of inexpensive natural fibers and expensive synthetic fibers, such as
Basofil, Polybenzimidazole, Kevlar, Nomex, etc.
Alternatively glass fibre wrapped in inherently fire
retardant fibres (eg FR viscose) or plastic (eg neoprene, PVC) can be used.
GR241/Defra/2010 112 of 115 November 2010
Appendix 4: Existing, Substitution and Emerging Technologies for Fire Retardant Electronic Products
Existing FR Technologies
Casings and Enclosures
The most common technology is additive chemical FRs
based on Br-FRs and ATO containing engineering thermoplastics such as PC, ABS, HIPS and arrange of
PC-ABS blends with a wide variety of surface finishes.
In some constructions only heat exposed casings close to power supplies may be treated. However, with increasing
fire load of large flat screen TVs and multi-media panels
there is a fire protection need to have all of the casing
made from FR materials.
Traditional FR treated engineering thermoplastics
incorporate Br-FRs as primary FR containing ATO as the
synergist. This provides a very effective combination which allows an FR concentration range that does not
compromise processing and physical properties.
Concerns regarding Br-FRs have produced an increase in
the use of chlorinated and non-chlorinated phosphorous based FRs, usually without synergists and some attempts
at using inorganic FRs such as ATH. However, these may
be problematic in compromising materials processing and physical properties.
Substitution Technologies
Use of inherently FR materials for casings such as
metals, composites and high performance
thermoplastics are technically feasible. This would require redesign of the product and be more
costly to produce.
Replace low molecular weight Br-FRs and replace with polymeric Br-FRs that will be more strongly
bound and satisfy REACH criteria. These
technologies may work with or without ATO and there is the possibility that alternative synergists
based on stannates may be usable although more
expensive.
Replace both bromine-containing fire retardants (Br-FRs) and antimony trioxide in casings. The
use of volatile and possible vapour phase-active,
phosphorus-based fire retardant could be made.
Antimony trioxide (ATO), which also has
environmental issues, could be replaced by other
synergists such as zinc stannates.
Emerging Technologies
Nanocomposites and nano_FR additives to
existing engineering thermoplastics and
potentially in novel nanocoating FR barriers technologies. Findings suggest that
conventional chemical FR technologies will
be required to supplement the nanomaterials systems.
Trials have been made with virgin and
recycled PET based materials which can be chemically FR treated non-halogenated
phosphorus and inorganic FRs. No materials
are commercially available for casing
applications. PET and its close relative polybutylene terephthale (PBT) may be fire
retarded with diarylphosphonate melamine
cyanurate or red phosphorus. This work was conducted on materials for electrical
connectors but is relevant to enclosures too.
The halogen-free grades have some technical
drawbacks, e.g. insufficient thermal stability.
GR241/Defra/2010 113 of 115 November 2010
These non-halogenated FRs are less effective than Br-FRs
both alone and in combination with ATO and it is
necessary to use them at higher concentrations which can
compromise materials processing and properties. In many cases they are also more expensive.
The potential use of stannates providing
synergism with halogenated compounds when
used as additive fire retardants in polymers comes
from experience in the textile field but may have application to the engineering thermoplastics if
compatibility and processability issues can be
overcome. So while these technologies appear feasible they have not been reduced to practice.
Nevertheless they could be assessment could be
fast tracked if the market drivers exist.
The greater cost of the more common zinc
hydroxystannate and zinc stannate relative to
ATO have prevented potential commercial
development at the present time.
The possibility exists to graft FR functional groups onto engineering thermoplastics or
form blends of FR polymers with
conventional polymers to form inherently FR
materials. No materials are commercially available for casing applications.
Printed Circuit Boards (PCBs)
In order to meet international standards (UL 94 V-0)
printed circuit board base materials have to be fire
retarded. At present this is predominantly achieved by using reactive TBBPA retarded epoxy-laminates or
paper/phenolic laminates with TBBPA or PBDEs.
The FR4 PCB is a low cost volume technology that accounts for the majority of PCBs used in consumer
products.
Other technologies exists for more demanding applications. Halogen-free FR2 laminates are according
The higher specification and halogen free FR2
PCBs could be considered as possible alternative
technologies to current FR4 PCBs.
Alternative materials include resins or composites
based on polyarylketone, polyetheretherketone
and high resins such as the bismaleamides. However, the cost would be much higher than
conventional epoxy based resin laminates used for
FR4 PCBs.
As above
GR241/Defra/2010 114 of 115 November 2010
to the producers of the same price as European produced
bromine based FR2 laminates.
TV-sets and other home-electronics with halogen-free
FR2 laminates are available on the market.
Ceramic laminates are available today for specific
applications, but they are expensive compared to the
epoxy based laminates. According to experts within the line of business, the application of ceramic laminates is
not expected to be widespread within the years to come.
The use of phosphorus based chemical fire
retardants which are also reactive is possible but
may be less effective than Br-FRs.