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JUDY: Welcome everyone to today’s webinar. We are delighted that you are on the line. Our topic today is the environmental and public heath issues associated with flame retardant chemicals and the opportunities businesses now have to reduce exposure given a groundbreaking regulation change. We have three speakers today: Myself Judy Levin, Roger McFadden, Senior Scientist and VP at Staples Inc. And we have also have Kathryn Rodgers from the Silent Spring Institute who will address some of the unique issues in Boston and Massachusetts since we have many participants from Mass. on this call. We ask that everyone mute their lines but PLEASE do not place us on hold as this can cause us to hear Muzak! If you need to get off for a short while, please do so and then dial back in rather than placing us on hold. We will speak for about 45 minutes and then open up the floor to questions.
JUDY: The Center for Environmental Health is a nonprofit organization dedicated to protecting the public from exposures to toxic chemicals. CEH works on numerous toxic and sustainability issues. I lead CEH’s work on flame retardant chemicals both in electronics as well as in furniture and children’s products We have worked on state and federal policies to reduce the use of toxic frcs in consumer products including work on the change to TB 117. . I also thoroughly enjoy my work with large public and private purchasers to help them identify environmentally preferable products and to help them learn how to use their purchasing power to transform the market towards safer products
JUDY: I would like to acknowledge the 6 members of our purchaser advisory group, our think tank of purchasers who have helped shape this webinar and the tools that we will be discussing. HDR Architecture, Staples, Construction Specialties, Multnomah county, Fairfax County and Harvard University were all members of this wonderful group.
JUDY: Today we will talk about FRCs that are present in many products with which we come into contact every day. We will discuss the public and environmental health issues associated with FRCS, the lack of fire safety benefit and then we will delve into the change in the regulations and the opportunities this can afford your business. Lastly we will talk about how purchasers can leverage their buying power to help expedite and incentivize a market transformation to products without unnecessary and harmful FRs. There are of course other Chemicals of concern and we will address them towards the end of the webinar. Bu we are focusing on FRs today because of the new regulation that just went into effect on 1/1/14
JUDY: FRs are intended to stop fires from starting and to stop the spread of flames. In reality, these chemicals can slow fires but cannot stop them. As a class of chemicals there has been a long legacy of health and environmental concerns Dozens of flame retardants currently in use FRs are used in a number of products. Electronics, Building Insulation, Foam Furniture and Wires and Cabling
JUDY Persistent means that they last in the environment and do not break down into safer chemicals over months or years. Being bioaccumulative means that they accumulate in plants and animals, becoming more concentrated as they move up the food chain. Some flame retardants have been tested and found to be carcinogens or to be mutagens which means they change DNA and others affect our reproductive systemss.
JUDY: Most people assume that if a chemical is on the market that someone has checked to make sure that it is safe. This is unfortunately not the case. There are over 82,000 chemicals in commerce and 62,000 of them were grandfathered in in 1976 so NO health data was received these chemicals. Of the new chemicals that have come to market since TSCA was first passed, 85% have lacked health data to assess the safety of the chemical and 67% have no data on health or environmental impacts. Under the current law ,the burden of proof is on EPA to show that a chemical may be harmful and most often the agency has no data to assess safety. There are ongoing efforts to change the law to give the EPA more authority, and businesses can play a key role in advocating for a stronger, truly health-protective law.
JUDY: Flame retardants have been found all over the globe from the polar bears in the Arctic to the Marine mammals off our coasts. Flame retardants are found in air, wastewater from homes and landfill leachates. The chemicals have been found to contaminate soil, rivers, the ocean, fish, marine mammals and the food supply. Killer Whales and other marine mammals along the CA coast contain the highest reported levels in the world of certain flame retardants (PBDEs) in their body fluids.
JUDY Flame retardants are considered Semi Volatile Organic Compounds and they continually migrate out of the products. These particles become airborne and also settle on the floor and other surfaces, so we have multiple points of exposure. It’s believed that the most significant route of exposure to flame retardants is from inhalation or ingestion of contaminated dust particles. FRS get on our hands and then when we eat or touch our mouths, the se chemicals are ingested.. FRs can cross the placenta and babies are born with FRs in their bodies. Toddlers have three times higher levels of FRs in their bodies than their parents due to their frequent hand to mouth activity . As furniture ages, the foam breaks down and more flame retardant chemicals are released. Children of color and children form low income communities have the highest levels of FRs in their bodies. .
We are exposed tp FRCs both at home and at work. Some of the exposure sources in offices include office furniture, foam carpet padding, building insulation, electronic products. In our homes many of these same sources exist such as household furniture, dust, electronics. We are also exposed to FRcs in our cars and through our diet. Foods that are high in fats like meat and dairy are also sources of exposure.
Most Americans spend up to 90% of their time indoors and many of us spend most of our working hours in an office environment. indoor air quality is a major concern to businesses, building managers, tenants, and employees because it has been found to impact the health, comfort, well being, and productivity of building occupants. Studies conducted by the U.S. Environmental Protection Agency (EPA) and others show that indoor environments sometimes can have levels of pollutants that are actually higher than levels outside
This Michigan study looked at a particular type of FRs called BFRS. They noted that offices are large reservoirs of BFRs meaning that there many sources that are stationary in the offices leading to high concentrations. They concluded it was important to try to minimize human exposure, and look at ways to reduce migration of these chemicals within the building and prevent these chemicals from being released into the environment.
This Boston study looked at the presence of a particular FR called Chlorinated Tris which is a chemical listed by the State of Ca as a carcinogen. You can see it was present in virtually every dust sample tested both at home, in vehicles an at work. This study could probably be replicated in any office building.
The data we have on some of the most commonly used FRs shows the potential for a wide range of health effects. And it is not just the old legacy chemicals that have been banned or restricted that have shown to be problematic. Studies have also found that some of the newer flame retardant chemicals have been linked to serious health concerns. Neurodevelopment: decreased memory, learning, altered motor, hyperactivity and decreased IQ. Endocrine disruption: Interferes with thyroid hormone in fetuses and young children-can affect brain development, decreased thyroid hormone levels Reproductive system effects: Increased time to pregnancy, decreased birth weight, decreases sperm quality, cryptorchidism Carcinogenicity, Immune suppression, Diabetes Three flame retardant chemicals have already been listed on the Prop 65 list as human carcinogens.
Workers who come into contact with flame retardants regularly are highly exposed. Workers who manufacture the flame retardant chemicals, incorporate them into products Fire Fighters have been found to have significantly elevated levels of 4 different types of cancer: multiple myeloma, non-Hodgkins lymphoma, prostate and testicular cancer. A recent study of San Francisco Bay Area Fire fighters found that these women had a 6 x higher rate of breast cancer. Workers who install or recycle products containing foam are also highly exposed.
If flame retardants in furniture worked, then we would have to weigh the health effects vs. lives saved. But numerous governmental studies have shown that FRs as used In furniture do not provide a significant difference. The US Dept. of Commerce and the CPSC found that the Severity of fire- Not reduced with TB 117 foam TB 117 does Not prevent ignitions from small flame sources No measurable difference in fire deaths
Overall fire deaths have gone done due to the decline in smoking, smoke detectors, etc. In office buildings there are additional considerations.
This study found that FRs greatly increased smoke, carbon monoxide, and soot. Inhalation of toxic gasses is the leading cause of fire deaths.
3,810 structure fires occurred in dorms, fraternities and sororities Fires in such circumstances caused 2 civilian deaths, 30 civilian injuries nationwide. The study does not state what the ignition source was for the deaths and injuries. Cooking equipment was the largest cause of fires and represents 84% of reported structure fires. Furniture did not make it on to the list of causes because it represented such a small fraction of the fires (cut off of items to be reported was 2%). More than two-thirds (70%) of fires in these properties began in the kitchen or cooking area. 7% of fires started in the bedroom, but these fires were responsible for 27% of injuries. Three percent of fires began in a lavatory, bathroom, or locker room. 57% of structure fires in these properties occurred in structures with automatic suppression equipment present.
NFPA reported that, between 2006-10, there were roughly 1,400 fires per year in hospitals and hospices. Cooking equipment was the leading cause of the fires, with other notable sources including dryers, arson, smoking materials, etc. Furniture was not listed in the report as a cause of structural fires because the numbers were too low to be considered a meaningful risk. NFPA reported most fires were small and contained to object of origin. NFPA ran statistics for this period isolating hospitals from hospices and found no reported fire deaths or injuries from furniture.
In the mid-1970s, California became first to adopt specific flammability standards. Technical Bulletin 117, or TB117, established in 1975 required the filling inside upholstered furniture, typically polyurethane foam to meet. TB117 also applies to some baby products that are considered juvenile furniture. It is a de facto standard across the US and Canada, since product manufacturers don’t want to make special products just for one state. Most furniture sold throughout the country meets the TB117 standard. Flame retardants are the cheapest way to meet the standard. Technical Bulletin 133, or TB133, applies to seating furniture in public occupancies such as hospitals, schools, dormitories, and day cares. TB 133 is typically met with flame retardant chemicals in the foam as well as in the fabric and or barrier materials. FRs are usually used in very high quantities, sometimes making up 5% of the foam by volume.
After 38 years, a new standard has finally been developed. The new standard came about as a result of a confluence of events – years of advocacy work, mounting scientific evidence on the harm of FRs, a series in the Chicago Tribune, and having a receptive governor in office who was committed to environmental health issues. As of January 1, a new flammability standard took effect in California.
Manufacturers are allowed to make products that meet the new standard (effective as of January 1), but they have until January 2015 before they’re required to meet the new standard. The new standard changes the test standard and makes it possible for manufacturers to meet the new standard without the use of flame retardant chemicals but it does not prohibit their use.
Let’s quickly take a look at the old and new standard. As we discussed, the old standard TB117 required the inside foam of upholstered furniture to withstand small open flame (like a candle) for more than 12 seconds. This did not add fire safety and did not address the major cause of fires. The new standard TB 117-2013 is a smolder test which uses a smoldering cigarette on the fabric (this is the largest cause of fires and fire deaths). So unlike TB 117’s unrealistic test of the inside foam, the new standard TB 117-2013 addresses where fires actually start in the cover fabric. . The new standard can be met with fabrics that are smolder proof. Fabrics like wool, leather, thermplastics, densely woven fabrics tend to be very smolder resistant.. The federal Consumer Product Safety Commission and the furniture industry estimate that 85% of fabrics can already meet TB 117-2013. 10% of fabrics are likely to require a polyester batting to pass the test and approximately 5% of fabrics are likely to be replaced Manufacturers have indicated that they can meet TB117-2013 without the use of FRs, but it’s important to note that TB 117-2013 does not ban the use of FRs and there is no requirement to label product’s flame retardant content. Exempts kids products
Definition of pubic building may vary state to state. You will see in California, it covers hospitals, healthcare facilities, nursing homes, board and care homes, convalescent homes, jails, prisons, stadiums auditoriums and the public assembly areas of hotels/motels. In MA it is defined differently. Massachusetts includes: assembly, educational, institutional, and specific residential settings. Including boarding houses and hotels and motels a well as apartment houses, and dormitories Check local regulations for specific types of buildings that are considered public buildings.
The new standard and implementing regulations clarified that a public occupancy building does not need to meet the TB 133 standard if the building is fully equipped with an automatic sprinkler system that meets the NFPA code for sprinkler systems.. Instead, these building occupants can purchase TB117-2013 compliant furniture. . TB 133 is most often met with a fire barrier between the foam core and exterior fabric. Flame retardants may be used in the fabric, fire barrier and/or foam. The test method is more expensive because it requires the entire piece of furniture to be burned. The increased cost to meet TB 133 is anywhere from $100-several hundred dollars per furniture piece.. A consideration that any public occupancy building would need to keep in mind is if furniture that meets TB 117-2013 is moved into a part of a facility or into a different building that does not have an automatic sprinkler system.
Kathryn: We did some research on sates and entities that reference the CA regulations and we were able to identify the following entities that reference TB117 and or TB 133. This may not be a complete list. It is very hard to get this information. Ohio requires all public buildings to comply with TB 133 and provides not exceptions for sprinklers Illinois does provide an exemption to TB 133 for public buildings that are fully sprinklered. These buildings were allowed to comply with TB 116 and TB 117. We have been told that this will be changed to reflect the updated TB 117-2013 but have not had this confirmed yet. One step you can do if you are outside of CA is to check with your legal counsel to determine whether there are local or state standards that would apply in your jurisdiction. .
Kathryn: CMR = code of Massachuse Massachusetts currently has a regulation requiring public buildings to comply with TB 133 but there is an exception for fully sprinklered buildings to be able to comply with TB 117. Mass. will be updating their state fire codes and we have heard that they plan to update the reference from TB 117 to TB 117-2013. The new fire code in Massachusetts will go through public comment period in October, then is finalized by the MA Board of Fire Prevention, then would be in writing by Jan 2015
Kathryn: No exception for sprinkled buildings CMR = code of Massachusetts Regulations Boston is unique. All regulated spaces must meet TB 133 regardless of sprinklers in the following settings: Assembly spaces Educational Spaces Institutional spaces including healthcare facilities Certain residential spaces (does not include 1 and 2 family homes) However, there is some recent news: Boston has recently provided some exceptions for buildings that are fully sprinklered that previously were required to comply with TB 133
Kathryn: As of 4/1/14 the Boston fire department changed the requirements for which occupancy settings must comply with TB 133. Most businesses and mercantile spaces that are fully sprinkled are now exempted from having to meet TB 133. These were settings that previously had to comply with TB 133 even if they were fully sprinklered. One and two family residential homes continue to be exempted from TB 133. There are some exceptions to this exemption: -If a business or mercantile space has a residential space above and is not fully sprinkled, they must comply with TB 133. -If a building or mercantile space has “assembly spaces” that have an occupancy load of greater than 49 persons they must continue to comply with TB 133 even if fully sprinkled. -Seating in temporary structures that have open flames, ie from candles or cooking
The elimination of harmful flame retardants from products like office furniture meets our commitment to offer consumers and organizations of all sizes products that are inherently safer for human and environmental health. We view this as an opportunity to create shared value and help transform the market. Eliminating toxic chemicals and/or replacing them with safer alternatives will make the toxic material obsolete. While in the case of furniture, alternative chemicals are not need to meet the new standard for products. For products where safer alternatives are needed, we need to make certain that the replacement materials are in fact safer. Regrettable substitution must be avoided. We need to clearly articulate to product makers, assemblers and suppliers that we do not want to trade one toxic material for another. We want to eliminate the toxic material or we want to substitute an alternative that is known or proven to be safer than the toxic material that it is replacing. This is why we endorse the 12 Principles of Green Chemistry and encourage our suppliers to apply these principles in product design and re-design.
Today’s focus is on flame retardants due to regulation changes. But we are beginning to think much more holistically at chemicals in products. All chemicals are not created equal when it comes to their hazard traits or endpoints. Some chemicals can help treat cancer and other chemicals can cause cancer. We must be careful to understand the differences. We already know that some chemicals are harmful and understand their hazard traits and risks they pose to human health and the environment. But for many chemicals we know very little and in many cases we do not even know what chemicals are in products. This needs to change. HERE ARE SOME USES OF CHEMICALS OF CONCERN IN FURNITURE PRODUCTS. HEXAVALENT CHROMIUM MAY BE USED IN SOME FURNITURE LEGS OR BASES OF SOME TABLES AND CHAIRS . THERE ARE SAFER ALTERNATIVES THAT CAN BE SPECIFIED SUCH AS POLISHED OR BRUSHED ALUMINUM. PERFLUORINATED COMPOUNDS ARE OFTEN USED AS STAIN REPELLANTS IN FURNITURE FABRIC AND SOMETIMES IN CARPET AS WELL. HEAVY METALS MAY BE PRESENT IN SOME DYES OR MAY BE USED AS A STABILIZER IN VINYL PRODUCTS. FORMALDEHYDE MAY BE USED AS A TREATMENT ON SOME FABRICS. ADDED UREA FORMALDEHYDE MAY ALSO BE PRESENT IN ADHESIVES FOR COMPOSITE WOOD PRODUCTS (OUTSIDE OF THE STATE OF CALIFORNIA)
The market is moving. Consumer awareness is growing. The Chicago Tribune article “Playing with Fire” exposed the worst side of the chemical industry and chemical in product information is being shared 24/7 across social media and crowd sourcing is becoming more common. The market leaders are already taking action. Architectural design firms are already requesting Health Product Declarations be provided by materials makers and suppliers. BIFMA and BIFMA members are supportive. Some makers of foam for furniture are identifying flame retardant free foam for their customers. Some furniture makers are identifying flame retardant free furniture for their customers. Living Building Challenge goes farther than USGBC LEED rating system related to flame retardants. LBC gives clients guidance and points for removing flame retardants. We can move the market faster together than we can one organization at a time.
The customer is our boss and suppliers should be our partners in helping to meet our customer’s expectations. We have retail and business customers asking us to help them eliminate and transition away from flame retardants. Suppliers are important in helping meet the goals of our organization while offering new innovative products that are compliant with our customer’s toxic reduction goals.
Customers are asking businesses to be more transparent. We are working with our suppliers to understand what they know and don’t know about the chemicals in the products they offer us. It has become clear that all suppliers are not created equal when it comes to what they know about chemicals in the products they make or sell. Many furniture manufacturers are actually assemblers of the parts and do not make the furniture itself. We have found it useful to inform suppliers about the Health Product Declaration Collaborative. This ingredient disclosure system can help product makers and suppliers collect ingredient information from their suppliers. The HPD provides a standardized way to collect information THAT WILL HELP PURCHASERS UNDERSTAND what is in the materials or products THEY ARE CONSIDERING. It will help PURCHASERS AND SUPPLIERS identify and assess the hazards and related health implications. Open and inclusive process used to create the Standard – Input from a wide range of stakeholders including downstream users and businesses. The HPD proactively responds to the growing supply chain demand for more ingredient disclosure and transparency. Creates common language and communication across the supply chain –merchant-to-suppler, business-to-business, business-to-customer, business to government etc. Pragmatic tool to help make an orderly transition. PURCHASERS CAN ASK THEIR SUPPLIERS TO PROVIDE AN HPD FOR THEIR PRODUCTS
Satisfied customers and responsive strategic suppliers are essential to any successful business. Changing supplier behavior is key to making an orderly transition to safer alternatives. Where we choose to spend our money says a lot to our suppliers about our commitment. Be clear with suppliers about what you expect and walk the talk. And be fair with suppliers and when necessary provide them reasonable time to meet your expectations. But don’t allow them to use this to stall or delay taking action. And don’t be deterred or obstructed by “status quo” laggard thinking. Think forward, not backwards and be willing to look at new options.
Safer chemicals, materials and products provide benefits for all of us. Workers, firefighters, suppliers, shippers, consumers and those that are most vulnerable, most likely and most frequently exposed these harmful chemicals.
The reason for the tools is to incentivize manufacturers We have been told that this is really important for manufacturers to hear Pressure to remove the FRs Chemical companies will be pushing manufacturers to keep FRs in foam due to liability They want to meet the needs of the consumers Helps them make the transition because they want to meet their customer’s demands BIFMA and their members is very much in support of the standard Some are making the transition quickly or already have due to requests to meet the LBC Red List, etc. Have begun creating a list of products that are FR free Teknion chair (task chairs without foam seats) MDI slab foam does not have to have FRs added to it.
Roger: Tell Other like minded purchasers. Tell others within your organization. When people understand the problem and the available solutions, there is a desire to make a change Build awareness about the value of transitioning to safer (less toxic) products with your procurement team and downstream users. Screen your current product inventory to identify non-compliant (containing chemicals of concern) products with the goal of replacing them with compliant products. Sign on to the Purchaser letter to Suppliers or meet with manufacturers/suppliers: Collaborate with your suppliers to identify alternatives to help you meet your toxic reduction objectives. Incorporate FR free specifications into your epp policies if they are not there already. If your organization has a contract for furniture, find out what the timeframe is so you can build in FR free criteria. Sign the pledge
Flame Retardants: Environmental and Public Health Impacts and Opportunities for Business to Reduce their Use
Environmental and Public Health Impacts
Opportunities for Businesses
to ReduceTheir Use
Roger McFadden, Staples, Inc ,
Judy Levin, Center for Environmental Health
Kathryn Rodgers, Silent Spring Institute
Advisory Group Members
Jean Hansen: HDR Architects, Senior Professional Associate, Sustainable
Roger McFadden: Staples, Senior Scientist,Vice President
HowardWilliams: Construction Specialties, Vice President-General
Brian Smith: Multnomah County Oregon, Purchasing Manager
Chris McGough: Fairfax County (Virginia), Green Purchasing Program
Susan ChemerynskiWason: Harvard University, Research Fellow:
Department of Environmental Health at Harvard School of Public Health
1. Flame Retardant Chemical Concerns
Human and Environmental Health
Lack of Fire Safety Benefit
1. Changing Regulations-Opportunity for
2. LeveragingYour Purchasing Power
3. Questions and Answers
What are flame retardants?
Human and environmental health
hazards of flame retardants
Lack of fire safety benefit
What are the Concerns?
What are flame retardants?
Inhibit ignition or spread of flames
Where are flame retardants
Wires and Cabling
Toxic Substances Control Act
Most Chemicals in the U.S. are Not Regulated
62,000 chemicals in commerce “grandfathered”
• EPA has regulated only five chemicals
2,000 new chemicals enter market each year
• No environmental or health data required
• 85% lack data on chemical health effects
Burden of proof on EPA to prove chemical is
Flame Retardants Are Ubiquitous
Slide courtesy of Green Science Policy Institute
How are We Exposed?
Inhalation or ingestion of contaminated dust
Ingestion from food, especially meat and dairy
Unique to Children
Absorption across the placenta
Frequent hand-to-mouth activity
Indoor Air Quality
Most Americans spend up to
90% of their time indoors.
Indoor air can have higher levels
of pollutants than outside levels.
Impacts health, comfort, well
being, and productivity
Brominated Flame Retardants in
Offices in MI (2010)
“BFRs are now ubiquitous contaminants with large
reservoirs and high concentrations in buildings.”
“The widespread distribution of BFRs found in offices in
both new and old buildings suggests the significance of
workplace exposures, the need for controls to
minimize human exposure, intra-building migration, and
environmental releases of these chemicals…”
Environ Int. 2010 Aug;36(6):548-56. doi: 10.1016/j.envint.2010.04.008. Epub 2010 May 18.
Batterman S, Godwin C, Chernyak S, Jia C, Charles S.
Flame Retardants in MA Offices (2013)
Chlorinated Tris was present in 99% of dust samples
taken from participants’ homes, vehicles and offices.
Widespread presence of this flame retardant in the
Environment International, Volume 55,May 2013, Pages 56-61
Health Effects of Flame Retardants
Decreased memory and learning
Endocrine System Disruption
Chemicals that mimic estrogen
Alters thyroid hormone
Decreased birth weight
Decreased sperm quality
installers and recyclers)
Lack of Fire Safety Benefit
No significant difference in fire growth between
foam with flame retardants formulated to pass TB
117 and untreated foam. Source: U.S. Dept. of Commerce,
National Bureau of Standards.
Chairs with flame retardant foam offered no
practically significant difference than those
without FR-treated foam. Source: CPSC, 2012.
Presence of automatic fire
sprinklers in buildings
People not allowed to smoke
No fire data supports need for
flame retardant chemicals in
Flame Retardants May Make
Fires Less Survivable
Data Source: Chandra Jayakody, et al. J. Fire Sciences, Vol. 18, pp 430-455, 2000
/kg) (kg/kg) (kg/kg)
FIRES IN DORMITORIES, FRATERNITIES,
SORORITIES AND BARRACKS
Approximately 3,810 fires in dorms, fraternities,
Leading causes of these fires:
Cooking equipment (84%)
Playing with a heat source
Electrical distribution and lighting equipment
2 deaths and 30 injuries nationally (causes not
Source: NFPA Study 2013
Fires in Health Care Facilities
Roughly 1,430/year in hospitals/hospices
Leading causes include:
• Cooking equipment (largest %)
• Smoking materials
• Heating equipment
• Electrical distribution/lighting equipment
• Playing with heat sources
** NO reported fire deaths or injuries from
Source: National Fire Protection Agency 2012
Technical Bulletin 117
• Small open flame test for filling
inside upholstered furniture
Technical Bulletin 133
• Severe, large open flame test for
seating in “public occupancies”
• Voluntary if building is fully
New California Furniture Standard:
cause of fires
Reflects real life fire
Can meet with
smolder proof fabrics
and barrier if needed
Governor Brown Announces New Standards
to Reduce Toxic Chemicals in Furniture
November 21, 2013
Beginning January 1, 2014, manufacturers
may begin manufacturing to the new standards.
They will have a year to complete the transition
and must come into full mandatory
compliance on January 1, 2015”
TB 117 vs. 117-2013
TB 117 TB 117-2013
Small Open Flame
Smolder Standard (largest
cause of fires and deaths)
Does Not Reflect Real
Life Fire Scenarios
Reflects Real Life Fire
Typically met with flame
Can be met without use of
flame retardant chemicals
Exempts 3 baby products Exempts 15 baby products
Technical Bulletin 133
Seating Furniture for Public Buildings
or Assembly Areas
Hospitals, health care facilities, nursing
homes, board and care homes,
Jails, prisons, penal institutions
Public assembly areas of hotels/motels.
Key ComparisonsTB 133
TECHNICAL BULLETIN 117-
Addresses public buildings or
public assembly areas
Non- public occupancy or
assembly buildings OR those public
occupancy buildings that are fully
Large Open Flame Test Smolder Test
Typically met with FRs in
fabric, foam and/or barrier
Can be met without FRs
More expensive to meet
than TB 117-2013
Less expensive to meet than TB
Entities Known to Reference
Ohio- Public Buildings must comply
with TB 133 (no exceptions for
Illinois-Public Buildings must
comply with TB 133 unless fully
sprinklered, then may comply with
TB117 and TB 116
Massachusetts Rules (527 CMR 29)
In fully sprinkled building, spaces may meet TB-
117 OR TB-133
In building not fully sprinkled,
spaces must meet TB-133
Assembly (A), Educational (E), Institutional (I), and Residential (R):
R1 – public/enclosed spaces in space of transient nature, e.g. hotel
R2 – public spaces in apartment houses, dormitories (more than 2 units)
R5 – enclosed spaces in group residence (12 people max) for impaired people
(all defined in 780 CMR 3)
Boston Rules (BFD IX-10)
All regulated spaces must
meet TB-133, regardless of
Assembly (A), Educational (E), Institutional (I), and Residential (R):
R1 – public/enclosed spaces of transient nature, e.g. hotel
R2 – public spaces in apartment houses, dormitories (more than 2 units)
R5 – enclosed spaces in group residence (12 people max) for impaired people
(all defined in 780 CMR 3)
Boston Rules - Update
As of 4/1/14 seating in “Business” and
“Mercantile” spaces no longer regulated
B and M spaces with no
sprinklers, and R above
B and M spaces with A
occupancy load > 49
with open flame
Staples Leadership & Engagement
Staples seeks to offer
organizations of all sizes
products that are inherently
safer for human and
environmental health and
that address environmental
impacts throughout their
Chemicals of Concern
Perfluorinated Compounds (PFCs)
Nonyl phenol ethoxylates
Today’s focus is Flame Retardants due to regulation change
Other chemicals of concern in the market
Market is Moving
Consumer awareness is growing – ChicagoTribune “Playing with
Fire”, social media and crowd sourcing.
Business customers are beginning to ask for flame retardant free
furniture in their RFPs.
Architectural / Design Firms are requesting HPDs
Living Building Challenge raises the bar
BIFMA and BIFMA members are supportive
Flame Retardant free foam furniture already exists
Suppliers Are Important In Helping Meet Our Goals
We challenge and ask our suppliers to:
• Consider chemicals of high concern like flame
retardants to be pollutants or contaminants;
• Consider direct and indirect chemical exposure to
vulnerable sub-populations including children,
women of child-bearing age and workers;
• Consider life cycle impacts of chemicals
including harmful degradation and combustion by-
• Consider full life-cycle costing including
externalities when making a product;
• Apply green chemistry/green engineering
principles into their product design or product
re-design whenever possible.
Health Product Declaration (HPD)
Changing Supplier Behavior
• Be clear with suppliers about what you
want. Suppliers are looking for ways to
differentiate themselves and bring you
value.The best in class will cooperate
• Be fair with suppliers and provide
them reasonable time to meet your
expectations, but don’t allow them to
use this to stall or delay taking action.
• Don’t be deterred or obstructed by
“status quo”. Be willing to look at new
Safer Chemicals, Materials and Products
Benefits For Everyone
• Workers that make and/or use them;
• Firefighters that are exposed to them;
• Suppliers that sell them;
• Logistics that transport them;
• Consumers that buy and use them;
• Our children that inherit them.
ADVISORY GROUP TOOLS
FR Free Products
Letter to Suppliers
Talking Points for
RFI / RFP / Contract
Build awareness re: value of transitioning to less
toxic products (CEH can help)
Screen current product inventory for chemicals
Send letter or meet with suppliers: Express
preference & ask for their help in meeting your
toxic reduction objectives
Explore / develop environmentally preferable
Find out your org’s. furniture contract
Sign the pledge