Final Technical Report - Defra, UK - Science Searchrandd.defra.gov.uk/Document.aspx?Document=EV0432_9846...retardancy in order to maintain and even improve fire safety standards. Although

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


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

http://www.gnosysuk.com/


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.


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.


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.


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

http://www.defra.gov.uk/environment/quality/chemicals/achs/documents/achs-decaBDE-opinion-100923.pdf

http://www.defra.gov.uk/environment/quality/chemicals/achs/documents/achs-decaBDE-opinion-100923.pdf


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


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


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.


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.


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.


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.


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.


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.


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.


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.


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.


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.


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.


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.


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


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


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


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


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


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.


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


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


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

http://www.see.ed.ac.uk/FIRESEAT/files08/04-Guillaume.pdf


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.

http://www.kemi.se/templates/News____3803.aspx

http://www.sft.no/english/english/Legislation/

http://www.berr.gov.uk/files/file54041.pdf


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



http://www.irishstatutebook.ie/1979/en/si/0215.html

http://www.ucd.ie/library/about/branch_libraries/jjl_library/index.html


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

http://ec.europa.eu/consumers/safety/prod_legis/index_en.htm#sect

https://fa1.gnosysgroup.com/owa/redir.aspx?C=ad7b4b6e8b044f18afd507a88fe75a2a&URL=http%3a%2f%2fwww.berr.gov.uk%2ffiles%2ffile52889.pdf

http://ec.europa.eu/consumers/safety/prod_legis/docs/report_impl_gpsd_en.pdf


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.

http://guidance.echa.europa.eu/about_reach_en.htm

http://guidance.echa.europa.eu/docs/guidance_document/clp_introductory_en.pdf?vers=24_08_09

http://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html


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 lifecycle

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.

http://www.opsi.gov.uk/si/si2006/uksi_20063289_en.pdf

http://www.opsi.gov.uk/si/si2007/pdf/uksi_20073454_en.pdf?lang=_e

http://www.opsi.gov.uk/SI/si2005/uksi_20052748_en.pdf


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

http://www.cpsc.gov/


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

http://www.sustainableproduction.org/proj.chem.abou.shtml


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.


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:


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)



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

http://www.flameretardants.eu/Content/Default.asp?PageName=openfile&DocRef=2006-02-10-00006

http://www.eeb.org/publication/2008/Dec08-Ecolabel+Chems-FINAL.pdf

http://www.eeb.org/

http://www.beuc.org/Content/Default.asp

http://www.oeko.de/home/dok/546.php

http://www.unece.org/trans/danger/publi/ghs/ghs_rev03/03files_e.html

http://eurlex.europa.eu/LexUriServ/site/en/com/2004/com2004_0038en01.pdf

http://ec.europa.eu/internal_market/publicprocurement/legislation_en.htm

http://ec.europa.eu/environment/gpp/pdf/national_gpp_strategies_en.pdf

http://ec.europa.eu/environment/gpp/pdf/toolkit/office_IT_equipment_GPP_product_sheet.pdf

http://ec.europa.eu/environment/gpp/pdf/toolkit/textiles_GPP_product_sheet.pdf


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

http://www.sriconsulting.com/SCUP/Public/Reports/FLAME000/#xml=http://10.2.0.53/cgi-bin/texis/webinator/search/pdfhi.txt?query=flame+retardants&pr=super&prox=page&rorder=500&rprox=500&rdfreq=500&rwfreq=500&rlead=500&sufs=0&order=r&id=4af5acdc7


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

http://www.flameretardants.eu/Content/Default.asp


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/

http://www.flameretardants.eu/Content/Default.asp?PageName=openfile&DocRef=2008-04-07-00001

http://www.tnsglobal.com/


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


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


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.


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.


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


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:


„{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


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:


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.


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


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.


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.


“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.


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.


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.


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.


• 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.


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,


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.


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”.


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.


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


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.


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.


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


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.


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.


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.


Table 2: FR Technology Hierarchy Matrix for Personal Protective Equipment

PPE Technical feasibility of compliance


Comments

and

Exemptions


Inherently FR materials commonly

used, particularly in more sophisticated

PPE


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




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


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


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


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.


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


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.


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.


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


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.


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.


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.


Table 3: FR Technology Hierarchy Matrix for Interior Furnishings

TEXTILES FOR INTERIOR

FURNISHINGS

Technical feasibility of compliance


Comments

and

Exemptions


Foam containing furniture usually uses

polypropylene, wool, polyester or

cotton/polyester, all of which require

FR treatment. Inherently FR materials are available for polyester.


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.


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




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



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


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


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.


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.


Table 4: FR Technology Hierarchy Matrix for Mattresses

MATTRESSES Technical feasibility of compliance


Comments and

Exemptions


Conventional design of mattresses

requires these or FRs.

Not possible for PU foams, but

possible for other mattress components


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


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




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



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


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


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.


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.


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.


Table 5: FR Technology Hierarchy Matrix for Electronic Products

ELECTRONIC /

ELECTRICAL

(TVs/PC/Laptops)

Technical feasibility of compliance


Comments and

Exemptions


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)


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


low hazard

Likely to be more

expensive

Reduction in

use of FRs

would assist

recycling of

these plastics




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.


compounds only

Several lists of non-halogenated or non-brominated compounds have

been produced by e.g. the Lowell

Centre



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.

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2000:237:0001:0012:EN:PDF

http://ec.europa.eu/environment/eussd/pdf/com_2008_397.pdf


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


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







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


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.


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


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)


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.


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.


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.


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


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


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.


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/

http://www.defra.gov.uk/environment/quality/chemicals/ukrisk.htm



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


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


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


https://www.who.int/ipcs/publications/cicad/cicad_66_web_version.pdf



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



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


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


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


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.


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).


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.


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


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.


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.


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.


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


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.
