Flame Retardants - A Systems Analysis v4

Running head: FLAME RETARDANTS: A SYSTEMS ANALYSIS 1

Flame Retardants: A Systems Analysis

Amanda Thornton

Courtney Hull

Erin Luther-Sheakley

Kelly Bethke

Molly Moore

Bainbridge Graduate Institute

FLAME RETARDANTS: A SYSTEMS ANALYSIS 2

Statement of Purpose

Our team members come from a wide range of backgrounds with stakes in different

sectors of the chemical industry. With shared passion, firsthand experience, and a commitment to

healthier lives, we take a deep look into the current system of Flame Retardants. Flame

retardants are a class of industrial toxic chemicals used to reduce flammability in consumer

products, furniture and mattresses. This report is designed to be used as a tool to better

understand the system of the chemical industry, and discover the most effective ways to

transform it into a healthier and more sustainable one. It is our goal that more companies,

governmental agencies, and working groups will begin to use safer alternatives or no flame

retardants at all, thereby reducing the risk of exposure to toxic chemicals and increasing the

availability of safer, healthier products.


Abstract

This systems analysis seeks to explore the interconnected relationships between prevalent

use of chemical flame retardants in consumer products in the United States, exposure to toxicity,

and human health. When referencing toxic flame retardants, the authors of this report are

referring to a whole group of chemicals that are used on household products for the purposes of

decreasing flammability. We reference flame retardants because the group of chemicals shows

harmful impacts to children, adults, wildlife and ecosystems.

Flame retardants are manufactured at a rapid pace, to keep up with market demand, but

there is no consideration to their impact on our health and the environment. Flame retardants

enter the market without having to prove they are safe for humans or the environment. The

demand for flame retardants is increasing 4.6% a year and is projected to hit 938 million pounds

by 2016, according to market research released in October (Gross, 2012). Toxic flame retardants

are one of the most common sources of toxicity in our homes and our lives, used on everything

from electronics, to furniture, to carpeting, to building insulation, to maternity and children's

products. Flame retardants migrate from products and settle in dust, which humans then ingest

through numerous points of exposure.

Exposure to flame retardants, even in very small doses, has been linked to obesity,

infertility, developmental disorders, neurodegenerative disease, hormonal and endocrine

diseases, and cancer. A growing body of peer-reviewed scientific research, including animal and

human studies, shows that these chemicals can disrupt the development and functioning of the

brain and nervous system.

Given the problematic persistence, bio-accumulative capacity, and long-range transport

of flame retardant, this report seeks to understand the current system in place that is enabling the


market growth of toxic flame retardant chemicals. Although we chose to focus specifically on

toxic flame retardants, the authors understand this case study of flame retardants to be reflective

of the US chemical industry, which as a whole is in need of closer examination, particularly in

relationship to sustainability. 25% of the U.S. Gross Domestic Product is impacted by the

chemical industry and over 96% of manufactured products are touched by the business of

chemistry (American Chemistry Council, 2012) and yet less than 1.2% of these chemicals have

been in tested for human or environmental safety (Eastman, n.d.).

Key findings at play throughout the system:

Media exposure makes a big difference – Given the scope of the problem and the vastness of the

system at play, there has been very little media attention on the topic. The Chicago Tribune’s

investigative journalism series “Playing with Fire” from May 2012 is a game-changer with

regards to consumer advocacy, government response, and demand for supply chain transparency.

Given that manufacturers are not required to list the chemicals in their products, consumer

awareness is potential chemical toxicity is a challenge.

The Toxic Substance and Control Act (TSCA) Protects Industry Ahead of Consumers – Under

the current law, which was passed in 1976, the EPA can only call for safety testing after

evidence surfaces demonstrating a chemical is dangerous. This lack of regulation, coupled with

lack authority to remove hazardous chemicals from the market in a timely manner creates

multiple time delays and inefficient feedback mechanism throughout the system. The large

lobbying power of the chemical industry blocked numerous attempts to reform the outdated

legislation. It is the only major piece of US environmental legislation that was not updated since

its inception. In the absence of federal action, numerous states are attempted to address the issue


through their legislatures, often working together in state based coalitions to increase

transparency and accountability of chemical manufacturers.

Investments in green chemistry are key – As the system functions currently, lawmakers as well

as consumer advocates, often try to ban the use of a single toxic chemical, but this “whack-a-

mole” approach has numerous unintended consequences. If one chemical is banned, "the

industry moves a few molecules and calls it a new product," says Kathy Curtis, the policy

director of Clean New York (Safer States, 2011). The new replacement chemicals can often be

more harmful than the originals, seen with the case of Firemaster® 550, which was original

introduced as an “eco-friendly” replacement to a known toxin. Investment is needed into the

field of green chemistry, to begin to incorporate the precautionary principle and life-cycle design

into American consumer goods and public policy. Additional investment and research is needed

to study the continuous compounding of hundreds of individual chemicals within our bodies, as

American babies are now born pre-polluted and overall chemical content, measured by the

Center for Disease Control’s body burden metrics, only increases with age.

Overall, the effects of flame retardants on human health are only in the initial phases of

being understood. Given the longitude and magnitude of human exposure to this class of

chemicals, including those known to cause disease and those yet to be tested, this topic will be an

area of study for generations to come.


The Story

The morning alarm sounds and Americans everywhere raise their heads from their

pillows; remove their covers; and get out of bed – the comfortable mattress that cradled them as

they slept. They shower, washing their hair and bodies; use deodorant; style their hair; and get

dressed. While eating breakfast or before heading to work, some may sit on their couch to catch

a few minutes of TV news or they may use their computers to check email. Most Americans are

exposed to at least 125 synthetic chemicals before they have their morning coffee according to

Eastman (n.d.). This simple morning routine exposes Americans to a rogues’ gallery of

chemicals and the day is only beginning.

Americans falsely assume the chemicals used to make the products they encounter every

day, such as those in cosmetics, clothing, packaging, electronics, furniture, household products,

etc., are tested for safety. However, there is no requirement to test for health data and only 20

percent of the 40 to 50 new chemicals approved each week are tested, according to Landrigan

(2001). Currently, the only required pre-market toxicology testing of chemicals is conducted on

pharmaceuticals, pesticides and food additives. Myers (2012) states when toxicology tests are

conducted, they only review “the dose that makes the poison” and then extrapolate from those

results the lower, “safe” dosage. Unfortunately, the lower dosage is never tested to determine if

it is actually safe and in fact a March 2012 study, by the Endocrine Society, shows that even in

tiny doses, many chemicals can derail the delicate systems that control our development, health

and reproduction.

One category of chemicals, flame retardants, is found in many everyday products. Flame

retardants are in furniture, such as mattresses, couches, and office chairs. They are in electronics

like televisions, computers, cell phones and remote controls. A study by Stapleton et al (2011),


found flame retardants in 80 of 101 baby products tested, from diaper-changing pads to breast

feeding pillows, and car seats. Other products (e.g. clothing, bedding, home insulation, and

carpet padding) contain flame retardants as well. Over time, these products shed the flame

retardants and thus the flame retardants accumulate in house dust. Our contact with this dust,

from our hands to our mouths, provides flame retardants a pathway into our bodies, which allows

accumulation in our blood, fat tissue and breast milk (National Library of Medicine, 2012). So,

how did the find flame retardants find their way into our homes and bodies?

The 1980s found tobacco companies facing a publicity nightmare from house fire deaths,

not just cancer. According to the National Fire Protection Association (2012), smoking was and

is a leading cause of civilian death from house fires. In order to mitigate this issue, there was a

push for tobacco companies to change to “fire-safe” cigarettes so they did not burn when not

actively smoked. However, tobacco companies did not want to change their cigarettes because

their market research indicated the reformulated cigarettes were less appealing to

consumers. Instead, the tobacco industry chose to shift the burden and lobby for flame-retardant

furniture as a means to reduce deaths from house fires.

According to the Chicago Tribune, in order to combat the compelling case for fire-safe

cigarettes, made by burn victims and fire fighters, tobacco companies deceptively used the

National Association of State Fire Marshals (NASFM) to lobby their case for flame

retardants. A “volunteer” named Peter Sparber organized the group, but was a former tobacco

executive and was paid by the tobacco industry, unbeknownst to the fire marshals. Nonetheless,

Sparber set the organization’s agendas, provided it with educational and lobbying materials, and

generally steered the position of NASFM to push for flame retardant furniture rules (Callahan &

Roe, 2012).


The significant financial benefits from the flame retardant market led the chemical

industry to continue the campaign of deception started by the tobacco. According to Callahan

and Roe (2012) A group known as the Citizens for Fire Safety described itself as, “a coalition of

fire professionals, educators, community activists, burn centers, doctors, fire departments and

industry leaders, united to ensure that our country is protected by the highest standards of fire

safety.” However, the Chicago Tribune uncovered that the Citizens for Fire Safety was actually

a trade association for the three largest flame retardant manufacturers: Albemarle, ICL Industrial

Products and Chemtura. While the chemical companies obfuscated the real identity of the

Citizens for Fire Safety, they used the Citizens for Fire Safety to lobby for rules requiring flame

retardants in consumer products or against banning the use of flame retardants. They cited a

1980 government study which indicated flame retardants give people 15 times more time to

escape fire and used frightening videos of burning couches to mislead consumers and lawmakers

about the risks of fire and the effectiveness of flame retardants.

This campaign of fear and deception, utilized to expand the flame retardant market,

required chemical manufacturers to distort the evidence. Vytenis Babrauskas, the lead author of

the 1980 government study cited by the chemical industry, explained the real effectiveness of

flame retardants by stating “the fire just laughs at it.” The amount of flame retardants used in the

study was significantly higher than in real-world conditions. i.e., the amounts found in

furniture. The amount of flame retardants in furniture provides “little to no fire protection,”

according to Babrauskas (Callahan & Roe, 2012) therefore, referencing this study to prove the

effectiveness of flame retardants is misleading.

As studies indicate the limited effectiveness of flame retardants, many other studies are

adding to the dismal picture of flame retardants by identifying the health risks they pose to


humans. Chlorinated Tris, a popular flame retardant, was banned from children’s pajamas in the

1970s because its mutagenic properties were identified to cause cancer, hormone disruption, and

neurological problems (Stapleton et al, 2011), but it is still used in furniture and baby products

today. Even a new flame retardant, Firemaster® 550, originally billed as “eco-friendly”, is now

linked to causing obesity, early puberty, and heart disease in lab animals (Patisaul et al,

2012). Results from various studies indicate the evolving nature of FR exposures and suggest

that manufacturers continue to use hazardous chemicals and when chemicals of concerned are

replaced, they are replaced with chemicals of uncharacterized toxicity. If flame retardants

provide little to no effectiveness in fires and bioaccumulation is creating negative health impacts,

why is the flame retardant market growing?

Key Problem Statement

As studies indicate the limited effectiveness of flame retardants, many other studies are

adding to the dismal picture of flame retardants by identifying the health risks they pose to

humans. Chlorinated Tris, a popular flame retardant, was banned from children’s pajamas in the

1970s because its mutagenic properties were identified to cause cancer, hormone disruption, and

neurological problems (Stapleton et al, 2011), but it is still used in furniture and baby products

today. Even a new flame retardant, Firemaster® 550, originally billed as “eco-friendly”, is now

linked to causing obesity, early puberty, and heart disease in lab animals (Patisaul et al,

2012). Results from various studies indicate the evolving nature of FR exposures and suggest

that manufacturers continue to use hazardous chemicals and when chemicals of concerned are

replaced, they are replaced with chemicals of uncharacterized toxicity. If flame retardants


provide little to no effectiveness in fires and bioaccumulation is creating negative health impacts,

why is the flame retardant market growing?

Set system Boundaries

The average American adult or child has approximately 500 potentially harmful synthetic

chemicals in their bodies (Eastman, 2012). These chemicals are in found in clothing, furniture,

cleaning products, food, and more. There is reason to suggest a linkage between the increase in

chemical production and the increase in diseases, such as cancer, autism, autoimmune disorders,

attention deficit disorders, and obesity. This crisis is as simple as the struggle between profit and

consumer awareness. Currently, the EPA lacks the power to control the process by which they

allow the introduction of new chemicals.

For the purposes of our analysis, our focus is on one chemical group, flame-retardants,

within the United States. We acknowledge the greater complexity of the system, and in our

causal loop diagram we indicate flame retardants are used as a micro lens to the industry;

however, we recognize that this level of information is indicative of the macro lens in the

chemical industry.

A few flame-retardants are regulated chemicals, but this is an abnormality in the chemical

industry. The amount of regulated chemicals is extremely low since the precautionary principle

is not practiced and stakeholder influence dominates the regulatory process.

Behavior Over Time


Flame retardant concentrations are increasing in human blood, breast milk and tissue, as

displayed in Figure 1, because of increased exposure to those chemicals. Since 1970,

concentrations of flame retardants in humans experienced a 100 fold increase (Hites, 2004). This

increase can be partially attributed to increased marketing and lobbying by the tobacco and

chemical industries and the legislation in California requiring the flame retardant capability. As a

result, the levels of flame retardants found in the United States population are the highest

worldwide.

Figure 1: Flame retardant concentrations in humans. This figure illustrates the amount of flame retardants (PBDEs) found in samples from humans in the United States, Japan, and Europe (Hites, 2004).

In addition to the bioaccumulation in humans, flame retardants are accumulating in

wildlife. Figure 3 shows concentrations of flame retardants increasing in United States harbor

seals and Canadian Arctic seals. This increase in accumulation of flame retardants in wildlife


illustrates the downstream impacts flame retardants. As the dust from flame retardants makes its

way into the ecosystems, wildlife, trees, and other life, flame retardants accumulate in life that

does not have a direct exposure to the chemicals.

Figure 2: Flame Retardants in Humans and Seals. This figure illustrates the amount of flame retardants (PBDEs) found in samples from humans and seals in the United States, Japan, Europe, and Canadian Artic (Hites, 2004).

Variables

The following is a list of variables representing different aspects to the systems analysis of

Flame Retardants. Definitions to each point are offered to further understanding and clarify

intended meaning.

• Amount of toxic flame retardants – The amount of toxic flame retardants in -relation to

Humans.


• Amount of disease – Amount of disease linked to toxic chemicals marketed as flame

retardants.

• Amount of profit – The amount of revenue gained by the chemical industry.

• Amount of political expenditures of the chemical industry – Money paid through

campaign contributions, lobbying expenditures, and political advertising on part of the

chemical industry.

• Amount of regulation favoring chemical industry – The amount of federal, state and

local regulation in favor of the chemical industry.

• Public Relations (PR) / Marketing expenditures by chemical industry – The amount

of money spent by chemical manufacturers, chemical trade associations, and other

lobbying groups to maintain and expand the market for chemicals.

• Level of consumer awareness – The amount of understanding about products from

ingredients to safety by those who could potentially purchase them.

• Consumer advocacy – The amount of citizen action groups and advocacy organizations

arising in response to the chemical industry.

• Scientific data of flame retardants / studies on human health – The amount of

publications and research studies focused on flame retardants and their impacts on human

health for a defined period or over time.

• Number of media articles about flame retardants and toxicity – The amount of

consumer awareness through media coverage specifically addressing flame retardants and

health concerns.

• Consumer legislative safeguards – The number of legislations defining the policy for

managing chemicals and requiring testing of new or known chemicals.


• Innovation: Green chemistry – The amount of alternative chemistry solutions discovered or

under study to reduce, provide safe alternatives, or eliminate hazardous chemicals.

Causal Loop Diagram

Figure 3: Flame retardant casual loop diagram. This figure diagrams the relationships between the variables in the flame retardant and health system, as well as the mental models.

Causal Loop Diagram Summary


Our three mental models (trust in producers/manufacturers, faith in government, and

belief in moderation) are highlighted with an asterisk at PR/Marketing Expenditures, Legislative

Safeguards and Amount of Toxic Flame Retardants respectively. Expanded explanations of

these are in the Mental Models section.

In order to enhance the ability to follow the diagram’s loops, they were color coded. This

resulted in some repeating line directions, but it is used to illustrate the differing roles of the

variables.

Blue Loop – With a lead-in from profit, Amount of Toxic Flame Retardants increases the

Amount of Disease, though this increase occurs through a delay. The increase in Amount of

Disease results in a rise of Consumer Advocacy because people begin to search for answers and

contributive factors for an upswing in frequency of a particular disease or health concern. Public

voice in the form of Consumer Advocacy results in more human interest pieces in the media on

the topic. This rise in Number (#) of Media Articles about Flame Retardants (FR) & Toxicity

results in a higher level of Consumer Awareness. When consumer awareness is high, the Amount

of Toxic Flame Retardants will decrease. This decrease is not due to legislative mandate or

change to the market, rather, it is representative of the purchase power consumers hold.

Decreased exposure to Toxic Flame Retardants will result in a decrease of the relative Amount

of Disease.

Orange Loop – An increase in the Amount of Profit derived from flame retardants

allows for an increase in Political Expenditures made by the Chemical Industry. This leads to

Regulation Favoring the Chemical Industry. At present, this really just means keeping business

as usual. The EPA has little governing power over any chemicals already on the market and has

bandwidth to test only 1.2% of the total market historically (Eastman, 2012). As the floodgate of


opportunity to saturate the market of chemicals remains high, we see an increase in the Amount

of Toxic Flame Retardants. This leads to an increase in both the Amount of Disease and Amount

of Profit. One off-shoot to this loop is that as Regulation Favoring the Chemical Industry

increases, Innovation in Green Chemistry is stifled. With so many mainstream options abiding

by laws requiring flame retardants, it's hard to introduce a potentially higher-priced alternative

that may be deemed unsafe (by regulation standards and our current mental models). The core of

this loop is reinforcing.

Gray Loop – Consumer Advocacy leads to a rise in Consumer Legislative Safeguards,

but there is a delay because of the time required to pass legislation. A recent article from Forbes

(2012) highlights a current and unprecedented lawsuit being brought against several large

companies as a result of consumer advocacy organizations. This rise in safeguards, primarily at

the State level, the anticipated response from the opposition based on their history is: an increase

in Political Expenditures by the Chemical Industry. This maintains the high level of Regulation

Favoring the Chemical Industry and cycles right through to increase in Amount of Toxic Flame

Retardants and Amount of Disease, with the previously mentioned delay.

Yellow Loop – An increase in Scientific Data of FR/ Studies on Human Health leads to

an influx of Innovation in Green Chemistry, though there is a delay in this increase. Assuming

that this sector is profitable as a result, they too will have buying power relative to Consumer

Legislative Safeguards. This increase and shift in Safeguards will result in the funding for

additional Scientific Data and Studies on Human Health and become a reinforcing loop.

Red Loop – An increase in Consumer Advocacy leads to more Scientific Data of

FR/Studies on Human Health. Aside from the aforementioned increase in human interest pieces,

there is now more data-driven news in the # of Media Articles About FR & Toxicity. This is


important because some people relate to emotions or general trends evidenced in publications

and others want hard facts before accepting a new truth. This leads to an increase in the Level of

Consumer Awareness and spurs on additional Consumer Advocacy. An increase in # of Media

Articles About FR & Toxicity also leads to a rise in Marketing Expenditures by the Chemical

Industry because there is a need to earn back or buy back our trust. Advertisements downplaying

the media, disagreeing, or going for feel-good associations, work hard to ensure that whatever

consumers read is not acted upon. A great example of this outside our specific chemical group is

the Corn industry’s advertising campaign in response to the exposed health risks of high fructose

corn syrup. When these Marketing Expenditures by the Chemical Industry occur, there is a

decrease in Level of Consumer Awareness. Only the core loop is reinforcing.

Mental Models

The confirmed science that our bodies are burdened by exposure to toxic matter on a

daily basis from the time of conception is overwhelming. This statement disrupts the current

mental models of U.S. citizens in several ways. Faith in producers, trust in government

protection, and the idea that moderation is good are all challenged by the current evidence of our

exposure to toxics.

As consumers in a first-world capitalist culture, we have the luxury of choice. Choose

any item on the market and, inevitably, there are many options. While producers compete for our

dollar, we understand that company reputation, quality, and price are variables. We do not,

however, typically consider whether a product is toxic. Instead, we trust in the messages they

send to us through advertising and packaging. The companies we buy products from invest a

large amount in marketing to consumers, often 7-8% of total revenue (Beesley, 2012). Image is

important and consumer trust is what they seek. It works. In fact, it works so well that we do not


believe anyone will put something on the shelves if it knowingly contains the potential for harm.

Terms such as “child-proof”, “natural”, ”made for babies”, “organic”, so and so...”a family

company” all lend an association with safety. Our mental model is that the companies producing

chemicals (and the manufacturers including them in the products we buy) would not knowingly

put something harmful to our health on the shelf. For the most part, we believe them to be

valuable partners in our efforts to want the best for ourselves and our families.

We trust our government in a similar fashion. Policy and regulation are there to protect

us. State and federal government follow through on this intent with legislation and organizations

that will ensure our health and safety. The EPA, Environmental Protection Agency, is a large

governing body that we presume to be quite diligent and powerful. Through fault in placement of

power, the EPA has little to no capability to manage or control the chemicals brought to market.

In fact, very few chemicals introduced and approved for use are even tested. This is an outright

violation of what we understand to be the function of this agency. But still, the trust remains.

Following our mental model, the government would not really let something like this happen,

right? If something is falling through the cracks, surely a fix is close at hand. In the case of the

EPA, they have had virtually no controlling power over the influx of new chemicals for the past

4 decades. They are the gate to deny any potential harm and it is wide open.

A third mental model is that moderation is good. We tend to think that just a little bit of

chemical exposure will not hurt us. Most Americans realize that not everything we come in

contact with is healthy. We balance our risks with safety and trade our bad choices in with good

ones in an effort to maintain a reasonable level of health. This is up to us as individuals. We

imagine that any harm we are doing to our bodies is a choice we make rather than a hidden harm.


One hidden example is exposure at work. Nurses and other healthcare providers were

found to have especially high levels of toxicity when tested. The concentration of industry-

related chemicals paired with flame retardants in nearly every bit of furniture, equipment and

clothing leaves health care professionals unintentionally exposed to many health risks. In 2009,

Physicians for Social Responsibility (PSR) in partnership with American Nurses Association

(ANA), and Health Care Without Harm (HCWH) released the “Hazardous Chemicals in Health

Care” report, which concluded that every participant had toxic chemicals associated with health

care in their bodies (Wilder, Curtis & Welker-Hood). Each had at least 24 individual chemicals

present, four of which are on the recently released EPA list of priority chemicals for regulation.

These chemicals are all officially associated with chronic illness and physical disorders. In the

Wilder, Curtis & Welker-Hood report, ANA President Rebecca M. Patton, MSN, RN, CNOR

stated:

Simply put, we are being ‘polluted’ by exposure to chemicals used in health care. This study demonstrates the urgent need to find safer alternatives to toxic chemicals whenever possible; to demand adequate information on the health effects of chemicals; and to require manufacturers to fully disclose the potential risks of their products and their components, for the safety of both healthcare professionals and the communities we serve.

In summation, our current mental models do not hold true to the reality of our exposure

to toxic substances. Our health and safety are not necessarily the primary concern of chemical

producers and products manufacturers. The government does little to require testing for

incoming chemicals and is slow to ban any pre-existing formulas known to have significant

harmful effects. Small amounts of exposure over time as well as small but repetitive absorption

while at work are resulting in studied and measurable amounts of toxicity in our bodies. With

this knowledge, our current thinking calls for a change.


Stakeholders and Players Analysis Stakeholders Chart

Power Rank

Entity Example if Applicable Goal/Interest

2 NGOs in general

Safer States, Safer Chemicals, Healthy Families, Center for Environmental Health

Working to inform public and ban use of FR (CEH bringing first lawsuit in years with major stores such as Walmart, Target, etc. for sales of toxic products)

1 American Chemical Council

N. American Flame Retardant Alliance (NAFRA)

Supporting FR as essential for safety *sole members are Albemarle, Chemtura and ICL

3 Healthcare Without Harm

Providing data regarding studies that conclude FR as harmful

TBD Public All consumers Interest in keeping our bodies and environment free from toxics

4 Consumer Product Safety Commission

Linked to EPA, seeks to expand their visibility to toxics

1 down to a 4

FR General Public Supporters

Citizens for Fire Safety (CFS)

False group founded and funded by the top 3 FR producers (phony non-profit)

2 Healthcare Organizations

World Health Organization, Nat'l Cancer Institute, Nat'l Research Council

Each of these major health orgs have concluded that Tris is a cancer risk

3 Science-Based Research Groups

U.S. Consumer Product Safety Commission and Underwriters Laboratories

Concludes that flame retardants in furniture cushions provide no meaningful protection from fire.

1 Tobacco Industry

Millions in funding to support FR industry

2.5 Firefighters International Firefighters Association

Formal letter requesting the ban of harmful flame retardants: http://www.pffmd.org/MarylandDecaBDEs.pdf

Figure 4: Stakeholders chart. This figure defines the various organizations, companies, governments, and groups who have a stake in the flame retardant market.


Players Chart

Power Rank

Entity Example if Applicable

Goal/Interest

1 FR Manufacturers

Albemarle Corp, ICL Industrial, Chemtura= 40% total

Producers of FR found in a vastly broad array of products

2 Products Made with FR

Everything from couches to stroller to building materials

Exaggerated role of "protecting" the public from fire

1 Electronics Companies NOT using FR

Sony, Panasonic, Apple, Dell

Discontinued bromiated PBDEs to maintain reputation/safety

1.5 Furniture Companies NOT using FR

Herman Miller, Soaring Heart, Furniture, Bean Products, A Natural Home

Furniture and products free from FR/PBDEs for consumer safety

1 Companies using alternative FRs

IKEA Banning current harmful FRs in their broad spectrum of products

2 Products Made with "safe" FR

Naturpedic Using cotton treated with baking soda, hydrated silica

2 Polyurethane Foam Association

FR users who work to set themselves apart from PBDE group

Figure 5: Players Chart. This figure describes the various companies that work in, use or influence the flame retardant market.


Regarding all entities who received a power ranking of 1:

• The American Chemical Council (ACC) supports the chemical industry. They

contribute testimony and influence in an effort to keep flame retardants on the

market. Albemarle, ICC and Chemtura each have a member on their board of

directors. In a recent effort to ban flame retardants, several reputable contributors

voiced their concern for the harmful chemical class. The ACC was the single force of

opposition to the restrictive measures proposed. Why are they so powerful? They

have a large pocketbook and a longstanding history of producing scientific evidence

presented to promote the use of flame retardants (Curtis, 2012).

• Citizens for Fire Safety (CFFS) wins an honorable mention in this category. While

their power has diminished significantly since being discovered as a sham, a

significant amount of damage has been done during their history. CFFS was formed,

funded and run by the chemical industry. They are, for lack of a better term, a fake

organization. The top three (Albemarle, ICC, and Chemtura) were able to use this

false front citizens group to create and manage the public’s perceived need for flame

retardants. In doing so, they gained the support of local votes when needed and the

buying power of many people. Images of burning homes and innocent children

running for safety fabricated the need for flame retardants and perpetuate their use

(Callahan & Roe, 2012a). For this reason alone they are absolutely worth

mentioning.

• The Tobacco Industry was an early contributor to Flame Retardants. Decades ago

when studies called out cigarettes as the top contributor to household fire deaths, Big


Tobacco launched an effort to buy influence of the firefighting organizations.

According to the Chicago Tribune (2012b):

The industry poured millions of dollars into the effort; doling out grants to fire groups and these strategic investments endeared cigarette executives to groups they called their "fire service friends."

To give us clout, to give us power, to give us credibility, to give us leverage, to give us access where we don't ordinarily have access ourselves — those are the kinds of things that we're looking for, a Philip Morris executive told his peers in a 1984 training session on this strategy.

• Flame retardant manufacturers are the source of these chemicals. As the top

manufacturing entity, chemical production accounts for billions of dollars in revenue

each year. With California as the 8th largest economy in the world requiring that

many products contain FR’s, the industry has become quite lucrative (Associated

Press, 2007). With purchasing power to influence governing forces, they have

maintained open production in the last few decades with the exception of voluntarily

phasing out PBDE’s.

• The manufacturing sector that includes flame retardants in production is quite large.

Everything from mattresses, carpets, couches; home insulation, electronics and more

are made with flame retardants. With laws in place to require the use of them in

specific product sets, most manufacturers are complying in order to sell their goods.

Companies such as IKEA, Hewlett Packard, Apple and Herman Miller are all

working to be more progressive by selecting less harmful versions of flame

retardants. Natupedic is one example of a manufacturer for the Green Chemistry

side. They use baking soda and hydrated silica as a natural alternative that is just as


effective as any amount of time gained from traditional flame retardants and results in

no known health effects (Natupedic, n.d.).

Leverage Points

There are multiple leverage points within the flame retardants and human health system. The

primary six include: 1) media exposure; 2) federal regulation reform; 3) state legislative

initiatives; 4) research to fill data gaps; 5) supply chain transparency; and 6) innovations in green

chemistry.

1) Media Exposure – Build awareness of chemical hazards and new science to create

momentum for change.

Consumer awareness is an essential leverage point for change within this system. The

primary reason this paper focuses on flame retardants as a particular case study within the

chemical manufacturing industry, is due to the exponential increase in media exposure flame

retardants have received within the last year. Multiple sources have noted that prior to the

Chicago Tribune’s investigative journalism series Playing with Fire, first released in May, many

Americans were unaware that flame retardants even existed. Reflecting on the powerful impact

and chain of events the Tribune series generated the Columbia Journalism Review (2012) states:

This is how newspaper journalism ought to be done. The Tribune calls the chemical industry’s push “a decades-long campaign of deception” that “manipulated scientific findings” with “flaws so basic they violate central tenets of science,” and created a “phony consumer watchdog,” a “front” that has “misrepresented itself”…This is one of those series that is so damn good and so infuriating, you’d like to think we’d wake up tomorrow and everything has changed…But if there’s a piece of journalism that could force it to happen, it’s this one.

Since the series debuted in May, media outlets throughout the country have picked up the

topic, with continued coverage. Consumer awareness and advocacy is increasing dramatically.


California Sen. Mark Leno, perennial sponsor of measures to reduce the use of flame retardants,

said the Chicago Tribune's investigation "completely altered the debate…I've been fighting this

for five years and losing at every step, and then a lot of change is happening suddenly” (Callahan

& Hawthorne, 2012).

Special government hearings were called and the EPA is maximizing its limited authority

to address the issues. Additional scientific research data was released, highlighting the need for

more research and the lack of funds currently available for research outside of the chemical

industry. Due to the increase in media exposure, the phony watchdog group Citizens for Fire

Safety has disbanded. As the number of media articles connecting flame retardants and toxicity

goes up, consumer awareness goes up, which in the absence of government regulation is the best

route to effect manufacturers’ behavior in relation to its supply chain.

2) Federal Regulation – Reform policy to incorporate precautionary principle; Prioritize

children’s vulnerability to chemical exposure. Shift evidence of proof burden from the

public to the producer.

The majority of stakeholders within the system are calling for Toxic Substances Control

Act (TSCA) reform, based on the inability of the law to protect the health of the American public

from exposure to harmful chemicals (Eastabrook & Tickner, 2000) & East. TSCA allows new

chemicals to come to market with little to no required testing (Landrigan, 2001). Passed in 1976

under President Gerald Ford, it is the nation’s main law aimed at regulating chemicals used in

everyday products. According to Safer Chemicals, Healthy Families (2012), a broad-based

coalition representing 300 organizations and 11 million Americans who are concerned about

toxic chemicals, TSCA is flawed because:


• Americans assume that chemicals used to make products like toys and food containers

sold in the U.S. are regulated and tested for safety — but they are not.

• When passed into law, TSCA grandfathered in more than 60,000 chemicals, presuming

them safe; only 200 of the original 60,000 chemicals have been tested for safety; and it is

a testament to the limitations of TSCA that, since 1976, the EPA has been apply to apply

the statue in regulating just only 5 chemicals.

• Today there are more than 80,000 chemicals on the market, which have never been fully

assessed for toxic impacts on human health and the environment.

• TSCA allows chemical manufacturers to keep the ingredients in chemicals secret: nearly

20 percent of the 80,000 chemicals are secret, according to EPA.

• TSCA makes it nearly impossible for consumers and businesses to find the information

they need to identify which chemicals are safe and unsafe, meanwhile TSCA leaves large

loopholes for continued toxicity exposure through chemicals entering the U.S. in

imported products.

• The EPA does not have the authority or budget they need to address the problem.

• Instead of requiring chemical manufacturers to demonstrate that their products are safe

before they go into use, the law says the government has to prove actual harm in order to

control or replace a dangerous chemical.

• TSCA perpetuates the chemical industry’s failure to innovate toward safer chemical and

product design.

In addition to the non-profit organizations pushing for TSCA overhaul, federal chemical

reform is supported throughout the business community. Numerous large companies across

industries, from Kaiser Permanente to Howard Williams, lobbied Congress on behalf of


increased chemical regulation, to protect worker health and increase consumer confidence (H.R.

5820, The Toxic Chemicals Safety Act, 2010). For example BIZ-NGO, a working group of

leaders of the electronics, health care, building, apparel, outdoor industry, cleaning product, and

retail sectors, as well as environmental organizations, put forth a widely distributed Business

Case for Comprehensive TSCA Reform (n.d.) stating, “American business leaders are hampered

by a failed national program for managing chemicals. Stronger chemical laws will not only

make our families safer and healthier, but also help businesses restore faith in the American

market. According to the Business Case for Comprehensive TSCA Reform (n.d.):

Product formulators, manufacturers, retailers, state and local governments, health care organizations and consumers are searching for products made with chemicals that have low toxicity and degrade into innocuous substances in the environment. But due to the lack of government action, they are often unable to determine what chemicals are in their products, what hazards they may pose, and whether safer alternatives are on the market. Companies downstream of chemical makers in the supply chain—who are the major users of chemicals—are now demanding federal change.

This month, December 2012, hundreds of leaders from the American Sustainable

Business Council (ASBC) traveled to Washington D.C. to lobby Congress that “strong laws on

toxic chemicals are good for business, and foster innovation” (Dahl, 2012). Amongst the data

presented by ASBC (2012), is recent polling data showing:

• 75% of small business owners support stricter regulation of chemicals used in everyday

products.

• Nearly all small business owners believe there should be publicly accessible database

identifying toxic chemicals, and nearly all believe manufacturers should be held

responsible for chemical safety.


• Most business owners explicitly support government regulation of the products

companies buy and sell, and nearly three out of four support a proposed reform to

federal law requiring manufacturers to show their chemicals are safe.

Multiple pieces of legislation were put forth to reform TSCA over the years, yet due to the

immense power of the chemical industry lobby (2nd largest lobbying force within the US), these

efforts have failed so far (Common Cause, 2012). The proposed policy initiatives, such as the

current Safe Chemicals Act, include revisions that adopt the precautionary principle, making

companies prove the safety of their product before it reaches consumers. These revisions shift

the burden from the consumer and government to the producer. Without sufficient data, a

product is denied market access. Additional policy upgrades require biomonitoring, studies to be

made public, and empower the EPA to remove toxic chemicals from the market in a timely

manner. Although they continually lobby against it, the American Chemical Council (2012) is

recognizing that it may be within the best interest of the chemical industry to update TSCA,

“After decades of implementation, it has become apparent that TSCA needs updating to reflect

advances in science and technology, as well as today’s public expectations of vigorous

government oversight.”

The area where there is the most agreement and potential political will amongst the

system’s stakeholders (as demonstrated at an Environmental Working Group convening of 150

stakeholders across sectors, including ACC), is the need to create risk-based standards for

evaluating chemical risks that specifically take into account the greater vulnerability of children.

In 2008, tens of millions of dollars were spent on studying levels of chemicals in human adults,

fish and dirt, but “no dollars” were spent on testing children under age six. “When you talk about


children’s health, when you talk about pollution in people, this issue has entered the mainstream.

People are concerned. This issue is a winner politically,” said Heather White, EWG’s chief of

staff and general counsel. “In principle we’re very much aligned. The policy differences we can

hammer out” (Bruzelius, 2009).

3) State Legislative Initiatives – In the absence of political will for federal chemicals

policy reform, smaller governmental bodies are acting independently.

When it comes to the amount of toxic flame retardants in American homes and buildings,

state policy is a key determinant. The demand for flame retardants over the last four decades

was state policy driven. Now, it is state legislatures who may be best positioned to increase

industry regulation, with state governmental bodies working through numerous legislative

strategies to do so. The potential impact on the chemical industry through state policy is visible

in the increase in political expenditures by the chemical industry lobby to deflect the increase in

state-based chemical safety policies and protect its financial interests. “Why is this industry so

engaged in defeating every one of our efforts?” asks CA State Senator Mark Leno (Gross, 2012).

“They’re making billions and billions of dollars.” The demand for flame retardants is increasing

4.6% a year and is projected to hit 938 million pounds by 2016, according to market research

released in October (Gross, 2012).

Flame retardant use in furniture increased rapidly after California implemented Technical

Bulletin 117 (TB117) because it required the ability of foams to resist exposure to a “candle-

like” flame for 12 seconds. Many furniture manufacturers decided it was easier to make one

product line to serve all of the U.S. rather than a separate line for California (Brown, 2012). 37

years later, California is now seeking to reform TB117 and its massive impact on flame retardant

production. In June, Gov. Jerry Brown (2012) directed state agencies to revise flammability


standards for upholstered furniture sold throughout the state: “We must find better ways to meet

fire safety standards by reducing and eliminating – wherever possible – dangerous chemicals.”

According to the Chicago Tribune (Callahan & Hawthorne, 2012), “Changing the obscure rule

Technical Bulletin 117, would be the most significant step any state has taken to reduce the use

of flame retardants that scientists say are building up in people's bodies and in the environment

around the globe.”

However, it not only upholstered furniture that is driving the problematic demand for

flame retardants. Construction is creating a high demand for flame retardants, due to the

recovery of the housing market, and fueling the growth of the flame retardant market. The

Uniform Building Code mandates protection from the heat of a fire by requiring 15-minute

thermal barrier. To make matters worse, green builders are using flame-retardant-treated plastic

insulation to boost energy efficiency. Household dust, different elements of the environment,

and humans are showing increases in their level of contamination from these flame retardants

(Gross, 2012).

Over the past few years, five bills have been introduced to update California’s flame

retardant requirements, and all attempts failed to pass the Legislature. From 2006 to 2011, the

chemical industry spent at least $23.2 million to lobby California officials in order to defeat

legislation that would regulate flame retardants. Despite the powerful influence of the chemical

industry lobby to block various pieces of legislation, states are coming together to formulate

creative solutions, such as public lists of known toxics, as a successful means to increase

transparency and push industry to manufacture safer alternatives.

One example of this is the January 2011 formulation of the Interstate Chemicals

Clearinghouse, which is designed to collect and share information from agencies in nine states


about reducing toxic chemicals. Their proposed tools include a “Safer Alternatives Assessment

Wiki” and a searchable state-level chemicals policy database (Brown, 2012). Additionally,

California is embarking on what is probably the most comprehensive chemicals regulation in the

US, through the California Department of Toxic Substances Control. This comprehensive set of

rules, titled the Green Chemistry Initiative, has the potential to impact up to 3,000 chemicals, if

they are labeled harmful (Sims, 2012). Manufacturers would need to substitute any harmful

chemical in order to keep selling their products in California. In turn, companies would be forced

to innovate.

According to the coalition Safer States (2012), in the past ten years, states have passed 93

laws, rules and policies, which will help protect the residents in those states from harmful

chemicals. The rate of change is increasing too, as 14 state policies were adapted in 2010.

When asked about leverage points within the system, chemical toxicity and health expert A.

Carlson (personal communication, October 30, 2012) replied, “State by state chemical related

actions – These drive industry nuts! They hate the patchwork of state by state restrictions.”

4) Research to Fill Data Gaps – Invest resources to fill critical data gaps to strengthen

public policy and medical practice.

“Data gaps” refers to lack of information on the health and environmental impacts of

chemicals, as well as the lack of information on the chemical ingredients of many products, and

the lack of monitoring for the presence of these chemicals in the environment and in people

(Rossi, Peele & Thorpe, 2012). These data gaps, which include a lack of empirical data on

health effects, as well as a lack of tools and algorithms to integrate data from multiple sources,

are immensely problematic. Brown (2012) discusses the Firemaster® 550 example:


A 2005 EPA report on flame retardant alternatives indicated that the unidentified

proprietary components of Firemaster® 550 have “low” or “moderate” hazard for human health

effects and low hazard for persistence and bioaccumulation. However, the supporting

documentation behind these determinations reveals a dearth of hard data, as the only data

provided in the report is based on “expert judgment” provided by the company producing

Firemaster®.

The report contains no data at all regarding chronic or subchronic toxicity,

carcinogenicity, neuro-toxicity, immuno-toxicity, genotoxicity, or effects on reproduction or

development.

Seven years later, researchers conducted the first pilot study on Firemaster® 550, which

is now the primary flame retardant used in the US. The results, mentioned previously, were just

released this fall. As it turns out, Firemaster® 550 is now linked to causing obesity, early

puberty, and heart disease in lab animals according to the recent study from researchers from

North Carolina State University and Duke University (Patisaul et al, 2012). Importantly, the

study also proved the flame retardant is capable of crossing the placenta during pregnancy,

reaching infants via breast milk or both. Researchers cite a lack of funding as a primary barrier

to further research.

According to Alison Carlson, Director of the Forsythia Foundation, the leading U.S.

foundation investing in chemical toxicity and health (personal communication, October 30,

2012), “There is a dearth of early stage, preliminary data research money that enables researchers

with envelop pushing hypotheses to get on federal funding radar screens.” There is an

opportunity to address the data gaps through computer modeling and methods that predict

chemical behavior based on structure; however, there is less confidence in this data. Given the


alternative, where chemical and product manufacturers choose alternatives with little to no

guidance, it is at least a step in the right direction.

Joel Tickner, a professor of environmental health at the University of Massachusetts

Lowell says that “in fact, new compounds are frequently selected because they are chemically

similar to their predecessors and thus will likely preserve their desirable qualities—and, as an

unintended consequence, their undesirable ones" (Brown, 2012). The testing of chemicals to

date has largely ignored the risk assessment gaps of low dose effects over time, and the issue of

mixtures of chemicals with cumulative and synergistic effects. These research opportunities and

gaps in scientific data, position themselves as leverage points within our system; however,

increased funding is necessary.

5) Increase Supply Chain Transparency – Reduce toxic chemical exposure with

“Lifecycle Approach” design.

Figure 6: Flame retardant supply chain. This figure explains the path flame retardants, and all chemicals, take to get to market.

According to Health Care Without Harm (2008), “the supply chain is the entire set of

manufacturers and distributors that are responsible for bringing a product to the market from raw

material to final product.” The supply chain typically has not included the design of a product,

nor does it include the disposal or end-of-life of a product, both of which must be considered

when examining product toxicity. For example, studies show that most Americans hold onto


their couches for twenty plus years, during which the toxic flame retardants from the foam of its

cushions are broken down into household dust, which then enters both humans and the

environment. When couches are added to the waste stream, they are disposed of in ways that do

not account for their toxic components. "The problem is, they don't stay put," says Rebecca

Williams, a reporter for The Environment Report. "They leach out of products and they get into

us" (Safer States, 2011). There is a massive opportunity with regard to designing consumer

goods: not only for new products manufactured without toxic flame retardants, but also design

adaptations that incorporate the lifecycle approach into products currently in circulation

throughout the supply chain, that already contain flame retardants.

As it currently stands, consumers do not know if products they purchase contain toxic

chemicals. Downstream companies are left in the dark about which chemicals are in their supply

chain, thereby limiting their efforts to make wise decisions about which chemicals to use or

avoid. Neither chemical manufacturers, no the EPA can determine the safety of a chemical

without knowing all of its uses. Without specific chemical use information down the supply

chain, no one will be able to restore public confidence by ensuring the safety of chemicals in

everyday products – not the product manufactured, not the chemical producer, and not the

federal government. At a minimum, consumers should know if the products they purchase

contain chemicals that are of high concern to human health and the environment (Rossi, Peele &

Thorpe, 2012). According to Schwarzman and Wilson (2009) there is proof in Europe, through

the implementation of the EU’s chemical policy REACH, improving overall transparency and

accountability in the chemical market supply chain leads to advances in green chemistry

innovation.


6.) Innovation and Green Chemistry – Invest to accelerate a new generation of

chemicals and materials that are benign by design.

Currently TSCA does not require producers to generate basic information on chemical

uses, health effects or exposures. This lack of transparency in the chemical market has hidden

the human and environmental costs of chemical exposure. As a result, the market essentially

undervalues the safety of chemicals relative to their function, price and performance. Producers

have had little incentive to develop safer substances according to the principles of green

chemistry (Schwarzman & Wilson, 2009).

Green chemistry is an approach to the design, manufacture and use of chemical products

to intentionally reduce or eliminate chemical hazards. The goal of green chemistry is to create

better, safer chemicals while choosing the safest, most efficient ways to synthesize them and to

reduce wastes. Chemicals are typically created with the expectation that any chemical hazards

can somehow be controlled or managed by establishing “safe” concentrations and exposure

limits. Green chemistry aims to eliminate hazards right at the design stage.

Consumers and business purchasing departments can promote green chemistry by

demanding safer, non-toxic products from manufacturers, and implement a supply chain strategy.

One example of this is the demand created by Healthcare Without Harm, to leverage the massive

purchasing power of hospitals. This strategy helps shift the competitive advantage toward those

companies who screen the chemicals used in their products and demand safer substitutes from

their suppliers. To what degree the chemical industry is actually adopting green chemistry

principles is unknown because some of the most innovative examples are proprietary.

However, the U.S. investment in green chemistry training and research lags far behind its

international competitors. China and India are taking an active role in leading green chemistry


by expanding their expertise. Furthermore, there is a requirement for chemistry students to study

green chemistry and China has several green chemistry centers. Contrast that with the U.S.,

where there are no requirements for students even to learn basic toxicology. Furthermore, the

focus on green chemistry needs to increase in the U.S. because the National Research Council

only advertised five green chemistry positions out of an available 3,020 post- doctoral research

positions (Clean Production Action, n.d.).

There are multiple companies publicly addressing the need for increased green chemistry

as a means to innovate safer products. Hewlett Packard in a great example of an industry leader,

who is using the ‘Green Screen public benchmarking tool,’ as a means to track their progress

toward eliminating the use of flame retardants and other toxic chemicals in their products.

However, to seriously transition the U.S. economy away from its reliance on untested, often

toxic industrial chemicals toward a baseline of green chemistry grounded in the precautionary

principle, serious investment in the field is needed. The opportunities to change the system

through this leverage point of innovation are tremendous.

Unintended Consequences from Leverage Points

Increase in green chemistry and safer products could lead to environmental

injustice – One opportunity in the flame retardant industry is innovation in safer flame

retardants. However, having safer flame retardants on the market may lead to unintended

consequences, one of which is an increase in inequality amongst consumers who have the

purchasing capacity to buy safer chemical products, and those who do not due to financial

barriers. In the current system, low income and communities of color are disproportionately

affected by flame retardant toxicity during the manufacturing, use, and disposal of

chemicals. As less toxic consumer products become available, they are likely to cost more than


those currently on the market, making it harder for lower income people to afford a more

expensive, healthier product. Unfortunately, this would mean that a low-income family would

be exposed to higher levels of toxic flame retardants than a family in a higher income bracket. A

person’s level of toxic exposure and body burden should not be dependent upon one’s capacity

to purchase safer chemical alternatives.

Disposal of flame retardant products could lead to an increase in bioaccumulation

in the environment and consequently humans – As consumers become aware of the negative

impacts of flame retardants, there will be an increase of their replacement and disposal. An

increased numbers of flame retardant products in landfills will increase the amount of flame

retardants shed in the environment. This will increase the levels of flame retardants found in our

soil, water, air, etc, which will accumulate in our environment and wildlife. This increase in our

environment will increase our (and nature’s) exposure to higher toxic levels, while we think we

are decreasing them by removing the products from our homes.

Increase in legislation could lead to job loss – If we exercise the leverage point of

legislation requiring proof of safety for the flame retardants currently on the market or coming to

market, it is likely a number of flame retardants will be pulled from the market or not allowed to

go to market. As a result, the chemical manufacturers will have less ability to produce and

therefore fewer jobs.

Pressure on supply chain could impact small businesses – As retailers and others put

pressure on the supply chain to “clean-up” their products, the financial burden of these changes

disproportionately impacts small businesses. Small businesses often do not have the capital or

flexibility in their systems to make dramatic changes such as ensuring their products are flame


retardant free or the ability to easily switch to using safe flame retardants. As a result, it could be

hard for small businesses to stay competitive if they were required to “clean-up” their products.

Differing state legislation initiatives – Similar to the California standard driving the

requirement for flame retardants, state legislation could have unintended consequences. Without

a cohesive United States national strategy, states could create legislation with differing

requirements, which would not represent a holistic view. For instance, having different chemical

controls in different states could allow certain chemicals to continue in production. This could

also lead to varying control of chemicals between products, meaning they could be in some

products but not others, like chlorinated tris. Even though the intent is to regulate these

chemicals, the differing standards could allow those chemicals to still end up in our water, food,

air, and environment. It is important for states to approach chemical regulatory reform with a

comprehensive strategy in order to avoid the unintended consequence of replacing one toxic

chemical with another, as has happened with previous toxic flame retardants.

Figure 7. Explains the new risks of new Chemicals. (Hawthorne, Nieland, Eads. 2012)

Threats and Opportunities

A major threat to the flame retardant chemical industry is consumer awareness. As consumers

learn more about the harmful effects of flame retardants, they will choose products with safer


flame retardants or none at all. This means the flame retardant chemical industry will be facing a

demand issue. This lack of demand will force the chemical industry to adapt to what the

consumer wants. Here is where they have a large opportunity. Consumers with more awareness

will want products that use healthier flame retardants. If players in the chemical industry can

recognize the demand for healthier flame retardants, they will have a competitive advantage in

the market.

An increase in consumer awareness is also a huge opportunity for companies like Apple,

Ikea, and Herman Miller, who are already working on transitioning to products without flame

retardants. As consumers become more aware about the harmful effects they will seek

companies who understand their concerns. These example companies are ahead of the curve and

may see an increase in demand of their products made without flame retardants.

Also, companies can redesign their products to exclude flame retardants. By examining

the entire lifecycle of their products, companies can design their products without or use natural

materials, such as wool, that are naturally flame resistant. For example, mattresses could be

redesigned to be made out of wool instead of flame retardant soaked fabrics.

Also, as consumer awareness increases, regulation will increase as well. Regulation is

another major threat to the flame retardant chemical industry. An increase in regulation creates

an opportunity of creating a flame retardant industry focused on safer chemical alternatives. The

demand from consumers for safer chemicals in products is becoming greater and greater. If a

flame retardant chemical company can realize this gap in the market, they will be able to sidestep

the regulation of the unsafe flame-retardants and make a significant profit.


Conclusion

The dominant mental model amongst Americans is that consumer products in this

country are generally safe; surely someone is watching to ensure that they are not harmful to

human health or to the environment. However, for the vast majority of products introduced to

the public each year, there is no requirement that manufacturers prove that what they’re selling is

not harmful, even if it contains substances that have known track records in animal studies or

other equivalent evidence of toxicity. This industry-prioritization approach of the United States

is in sharp contrast to the EU’s REACH legislation, which operates through the lens of the

precautionary principle, placing the burden of proof upon manufacturers to demonstrate a

product is not harmful before distributing it for sale. REACH is the first comprehensive

chemicals policy to codify the precautionary approach to some chemicals whose risks are not yet

fully understood. In addition to the anticipated (but not-yet-quantified) ecological benefits of

reduced environmental contamination, REACH is expected to garner significant public health

gains. By improving overall transparency and accountability in the chemicals market, REACH

is already advancing green chemical innovation. Given the high stakes, and bio accumulative

effects of flame retardants, it is reckless for U.S. chemical manufacturers to pump them into

consumer products, particularly since flame retardants have been proven ineffective in fire

reduction (Monoyios, 2012). According to Arlene Blum, a U.C. Berkeley Chemist and

Executive Director of the Green Science Policy Institute, "There are literally thousands of peer-

reviewed scientific studies on the harm of these chemicals” (Slater, 2012). And yet the flame

retardant market continues to grow.

The industry that wants to keep flame retardants in American products is motivated by

big dollars. Flame retardants are a large chunk of the $760 billion chemical industry in the U.S.


(Safer States, 2011). To maintain profits, the chemical industry is motivated to prevent the EPA

from updating assessments of a chemical’s hazard, especially if the assessment is likely to

provide first-time evaluation that a chemical is hazardous, or to show that the chemical is more

dangerous than previously thought. The industry has gone to great lengths to prevent any

increases in chemical safety assessment. Although the chemical industry has claimed to be in

support of reforming TSCA and achieving better regulation of chemicals to protect the public, it

has challenged virtually every EPA action, assessment or finding that might lead to increased

environmental and consumer protection, spending hundreds of millions of dollars on political

lobbying.

Lack of government regulation, coupled with lack of transparency and accountability

within the chemical industry, has left Americans and a global ecosystem at risk, as seen through

the case study of flame retardants. Although consumer advocacy is a key leverage point for

change within the system, Americans cannot solely purchase their way out of the problem.

Ideally, government needs to play a role to help prevent toxic exposures. Updates to U.S.

chemical regulation, alongside investments in green chemistry research and innovation, are

necessary components for the U.S. economy to remain competitive in the global market. As is,

toxic flame retardants do more harm than good. While their prevalence in consumer products

continues to increase, so do the health risks and diseases associated them.

As President Obama declared, “The true burden of environmentally induced diseases has

been dramatically underestimated” (Cone, 2010). Chemical regulatory reform and increased

market-based incentives are necessary actions to safeguard human health, ecosystem integrity,

and economic sustainability.


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Documents

Flame Retardants - A Systems Analysis v4