These remarks address the position of Cellular Technology International, Inc., an international supplier of flame retardants to the polyurethane industry, regarding the California Bureau of Electronic & Appliance Repair (BEAR) Bureau of Home Furnishings & Thermal Insulation (BHFTI) proposed revision of the TB 117 standard for upholstered furniture and filling materials.
While we applaud the State of California for addressing the problem of toxic, carcinogenic, bioaccumulative and biopersistent additives to flexible polyurethane foam, we feel that part of the revisions proposed for TB 117 represent a step backward in the protection of the public from fire hazards in upholstered furniture.
We endorse the modification of the smolder test to incorporate a composite foam-and-fabric approach which more closely approximates real world conditions with respect to smolder initiated fires. However, the elimination of an open flame ignition test is a large step backward. Given that the statistics may demonstrate that the majority of upholstered furniture fires are smoulder initiated, the instances of open flame ignition are not to be ignored. In a fully developed fire scenario, a room containing upholstered furniture constructed of PU foam with no ignition resistance significantly reduces escape time for occupants and increases the risk to first responders as the fire can develop much more quickly. The removal of the open flame ignition test just to eliminate the need for chemical flame retardants is in fact unnecessary, and does not recognize that the technology exists to produce flame-retarded, ignition resistant foam without the need for dangerous and accumulative chemicals used in the past. As an additives supplier, we endorse and advocate the use of chemically reactive flame retardant additives that react into the foam matrix and cannot migrate or leach out to cause health problems. Such reactive FR additives exist at present, and can be used in PU foam with only some modifications of the foam formulation required.
In sum, the recommendations of Cellular Technology International, Inc. to the State of California are to (a) implement the new smoulder regulation as proposed, with testing performed on the foam-fabric composite; (b) retain the open flame ignition test which can be achieved by using reactive flame retardant additives which represent no health or environment hazards.