NASFM Science Advisory Committee

1. NASFMScience Advisory Committee • Annual Report 2013 • Indianapolis, Indiana 1

2. Science Advisory Committee • Founded in 1997 • Identifies and evaluates scientific and technical issues important to NASFM and State Fire Marshals • Assists NASFM Board in taking positions and making decisions based on science and engineering • Members volunteer time and expertise • Meets in person at NASFM Annual Conference

3. SAC Members • Margaret Simonson McNamee, Research Manager,SP Technical Research Institute of Sweden (Chair, 2001- ) • Gordon Damant, Flammability Expert and Consultant,Damant & Associates • Roy Deppa, Product Safety Management Consultant, Marchica & Deppa, LLC; US Consumer Product Safety Commission (ret.)

4. SAC Members • Shannon Frattaroli, Associate Professor, Johns Hopkins University Bloomberg School of Public Health • Pravin Gandhi,Director, Global Corporate Research,Underwriters Laboratories • David J. Icove, Research Professor, University of Tennessee Dept. of Electrical Engineering and computer science • Nick Marchica, Product Safety Management Consultant,Marchica & Deppa, LLC; US Consumer Product Safety Commission (ret.)

5. SAC Members • David Purser, Professor and consultant, Hartford Environmental Research, Retired from U.K. Building Research Establishment’s Fire and Risk Sciences Division • Steve Spivak, Professor Emeritus, Fire Protection Engineering Department, University of Maryland • Jack Watts, Fire Protection Engineer, Fire Safety Institute

6. NASFM Liaisons to SAC • Butch Browning,Liaison to the NASFM Board • Karen Deppa,NASFM DC Office, Staff Support

7. SAC Working Priorities Include… • Upholstered furniture fire resistance • Building fire safety and security • Effectiveness of smoke alarm technologies • Fire resistance of clothing • Human behavior and emergencies • Health and environmental effects of fire and fire retardants • Identification of emerging hazards … NASFM Board sets the agenda

8. Outreach for NASFM • Research organizations (e.g., SP, NIST, FPRF) • Standards development organizations (e.g., NFPA, UL, ANSI/ISO) • Industry associations (e.g., NCA) • Professional societies (e.g., SFPE) • Regulators/enforcers (e.g., CPSC) • Insurance industry (e.g., FM)

9. Today’s Presentations • Upholstered Furniture Fire Safety Standards • Cigarette Fire Safety Standards • Flame Retardants

10. SAC Focus on… • Upholstered Furniture • Fire Safety Standards • Gordon Damant • Damant and Associates 10

11. Furniture Flammability – Brief History • Consumer Product Safety Commission (CPSC) • California Bureau of Home Furnishings • Upholstered Furniture Action Counsel (UFAC) 11

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13. Reduction in Fire Statistics Reasons include: • Increased use of residential smoke detectors • Increased installation of residential sprinkler systems • Reduction in the number of smokers • Fire standards for some consumer products since the 1970’s • Introduction of Reduced Ignition Propensity (RIP) cigarettes??? 13

14. Upholstered Furniture Fires • Significant decline in cigarette caused furniture fires in recent years – currently about 1/4th of all furniture fires. • Small open-flames and electrical sources are the other main causes. • Furniture often the main fuel source in fires, even when not the first item ignited. • Furniture still accounts for about 400 U.S. fire deaths each year – number-one cause of U.S. fire deaths 14

15. CPSC – Upholstered Furniture • CPSC inherited a “Finding of Need” for a furniture standard in 1972. • Upholstered furniture has been the leading cause of U.S. residential fire deaths, at least since 1973. • 1993 - NASFM petitioned CPSC to adopt national upholstered furniture flammability standards addressing cigarette, small open-flame and large open-flame ignitions. 15

16. CPSC – Upholstered Furniture • 1994 - CPSC issued an Advance Notice of Proposed Rule-making (ANPR) in response to the NASFM petition. • October 2003 – The Commission (CPSC) voted to publish a new flammability standard for upholstered furniture, to include standards for both cigarette and small open-flame ignition. • February 2008 – CPSC Staff proposed an upholstered furniture flammability standard which addressed only cigarette ignition resistance. Stated that fire statistics no longer supported the need for an open-flame requirement. 16

17. CPSC – Upholstered Furniture • CPSC has conducted several laboratory studies, including some at NIST – have concluded the proposed cigarette standard (which is based upon small-scale furniture mock-up tests), is not a scientifically valid standard. Test results from the mock-up tests, are not validated by real-scale testing. 17

18. CPSC – Upholstered Furniture • Recently, CPSC appears willing to entertain a furniture standard that (in addition to a cigarette ignition standard) would require the use of fire blocking systems – similar to the technology used to comply with the standard for residential mattresses and bed sets – 16 CFR 1633. • CPSC held a public informational workshop on the applicability of fire blocking/barrier systems for residential furnishings in April 2013. 18

19. CPSC – Upholstered Furniture • NASFM has filed numerous comments with CPSC urging the Commission to address both cigarette and small open-flame ignition tests in the flammability standard for upholstered furniture. • NASFM has also met with Commission staff and has participated in CPSC furniture flammability workshops. • NASFM’s message to CPSC has consistently been that true fire safety can only be achieved by a comprehensive approach to furniture fire safety that addresses problems of smoldering and open-flame ignition. 19

20. UFAC (Upholstered Furniture Action Council) • Furniture industry voluntary standard • First published in 1980 • Addresses only cigarette ignition • Does not test pieces of furniture for cigarette resistance – only furniture components • Complying manufacturers often attach a UFAC label. • Has been adopted as ASTM E 1353 20

21. California Furniture Standards • 1972 California law passed requiring all upholstered furniture sold in California to be Flame Retardant. • Responsibility for establishing flammability standards delegated to the California Bureau of Home Furnishings. • California regulations and test methods became effective in October 1975. 21

22. California Furniture Standards • California TB 117 eventually became a quasi-national standard for residential upholstered furniture. • Many furniture manufacturers, including all of the majors, chose to voluntarily comply with TB 117 nationwide – primarily for business and liability reasons. • Although California TB 117 did not specify the use of flame retardant chemicals, compliance with the test requirements for some furniture components, such as polyurethane foam, could only be achieved by use of FR chemicals. 22

23. California Furniture Standards and FR Chemicals • In recent years environmental advocates, as well as some so-called health professionals and academics, have expressed concern about the use of FR chemicals (as well as other ‘dangerous’ chemicals) in consumer products. • Most of the ‘chemo phobia’ has emanated from UC Berkeley. • California’s upholstered furniture flammability standards have become a key target. 23

24. California Furniture Standards and FR Chemicals • After numerous failed attempts at convincing California Legislators to modify furniture flammability laws, last year the anti-FR chemical consortium was successful in getting Governor Jerry Brown to issue an executive order. • The governor’s executive order instructed the California Bureau of Home Furnishings to revise California TB 117, with a view to eliminating the need for FR chemicals in furniture sold in California, while at the same time not reducing the level of safety to the public. 24

25. California Furniture Standards and FR Chemicals • In response to the Governor’s directive CBHFTI has held workshops and public hearings, and has formally proposed a major revision to TB 117 (TB 117-2013) that totally eliminates open-flame testing requirements from the California furniture standards, and addresses only ignition of furniture by cigarettes. • Many public comments (including those from members of the NASFM SAC) to CBHTI strongly oppose the direction proposed in the new California TB 117-2013 proposal. 25

26. SAC Focus on… Cigarette Fire Safety Standards Gordon Damant Damant and Associates 26

27. Cigarettes • The ignition propensity of smoldering cigarettes, when in contact with upholstered furniture, mattresses, mattress pads, cellulose insulation, trash and a variety of miscellaneous consumer products, is well recognized. • Some standard cigarette tests have been around since the early 1970’s. • In recent years all U.S. states have enacted laws that prohibit the sale of “Conventional” cigarettes, and which mandate the sale of cigarettes that are referenced as “Fire-Safe” cigarettes, or cigarettes of “Reduced Ignition Propensity” (RIP). 27

28. Cigarettes • The definition of RIP cigarettes is tied to a test method, developed by the National Institute for Standards and Technology (NIST). The test method has been adopted by ASTM as ASTM E2187 - Standard Test Method for Measuring the Ignition Strength of Cigarettes. • ASTM E2187 tests candidate cigarettes over multiple layers of laboratory filter paper. Cigarette must achieve a certain performance threshold in the test to meet the criteria as being RIP cigarettes. 28

29. RIP Cigarettes – Do They Work? • Assumption. Cigarettes in compliance with ASTM E2187 will result in fewer cigarette ignitions of products with a smoldering potential. • Assumption. ASTM E2187 test, using filter paper, predicts the performance of cigarettes in contact with more common substrates, e.g. furniture, mattresses, etc. • Assumption. Fewer lives will be lost and injuries will be reduced, since RIP cigarettes will cause few ignitions. 29

30. RIP Cigarettes – Do They Work? • Two recent studies have raised doubts about the effectiveness of RIP cigarettes, with respect to their ability to prevent ignition when in contact with typical combustibles. • A paper presented at the International Fire and Materials Conference in February 2013 entitled, “Fire Safe Cigarettes, Aren’t”, by Dr. John DeHaan and James C. Albers indicated that cigarettes manufactured to comply with the RIP conditions of ASTM E2187, do not prevent ignition under real-life conditions. 30

31. RIP Cigarettes – Do They Work? • The conclusion of the study by DeHaan and Albers was: “The laboratory test (ASTM E2187) which may have some comparative validity, has little real world value. The test does little to ensure the fire safety of those exposed to ‘Fire Safe’ cigarettes in the real world. Cigarettes that pass the ASTM E2187 test can, and do, start real world fires.” 31

32. RIP Cigarettes – Do They Work? • Perhaps of even more significance was a summary paper presented at the same Conference by staff of the CPSC, entitled: “Cigarette Ignition Risk Project”. • The CPSC paper was a summary of a 200-page research project conducted by CPSC. The purpose of the study was to look at the efficacy of RIP cigarettes under real-life conditions, and to estimate the potential impact of RIP cigarettes on fire statistics. 32

33. RIP Cigarettes – Do They Work? • The CPSC study compared 13 of the most popular brands of RIP cigarettes, with the same brands of cigarettes that were NOT RIP compliant. • CPSC administers a cigarette standard for mattresses and mattress pads (16 CFR 1632). Therefore, CPSC chose to evaluate the cigarette ignition propensity of mattress and mattress components in the comparative study of RIP and non-RIP cigarettes. 33

34. RIP Cigarettes – Do They Work? The conclusions of the CPSC study included: • Compliance with ASTM E2187 did not predict differences in the ignition propensity between RIP and non-RIP Cigarettes. • Cigarette performance on a filter paper substrate was not predictive of smoldering behavior on mattress substrates. 34

35. RIP Cigarettes – Do They Work? • Different brands of RIP cigarettes gave dissimilar test results. • It is premature to conclude that the use of RIP cigarettes will greatly reduce the threat of unintentional fires ignited by cigarettes. 35

36. NASFM and RIP Cigarettes With respect to RIP cigarettes, the Science Advisory Committee recommends: • That State Fire Marshals caution the public that RIP cigarettes are not a cure-all for cigarette ignited fires, and that people still need to be careful when smoking around products such as upholstered furniture. 36

37. SAC Focus On…. • Flame Retardants • Margaret Simonson McNamee • SP Technical Research Institute of Sweden

38. FR function • Impact on fire performance (FRs don’t make plastics non-flammable) • Can be achieved by judicious choice of material in some cases (fire resistance can be achieved without FRs) • Defined by performance test, not by FR vs non-FR (e.g. UL94, glow wire test) • Different FRs impact in different ways • FRs are not strictly interchangeable

39. Groups of FR Chemicals • Chlorinated and Brominated (“Halogenated”) • e.g., E&E, upholstered furniture, high end applications, PVC • Phosphorous based • e.g., furniture, E&E • Intumescent systems • e.g., wire and cable, paints • Aluminum/Magnesium based systems • e.g., wire and cable • Variety of other inorganic additives (e.g. nano-clays)

40. Combustion of Plastics Halogens Phosphorous based Intumescents gas phase thermal feedback oxygen Al/Mg-hydrates heat combustion products smoke combustible gases heat Pyrolyse charred layer area of decomposition char formation condensed phase 08/05/13

41. Why are FRs questioned? • Environmental impact and toxicity • PBT, vPvB, POPs • Occupants and first responders • Environmental presence • Precautionary Principle • Those FRs that have come under closest scrutiny to date are halogenated • ”Alternative FRs” refer to alternatives to halogenated FRs

42. Regulatory status – USA • Penta-BDE, octa-BDE voluntary industry removal 2004, deca-BDE 2012 • 10 states have adopted legislation banning Penta and Octa (California, Hawaii, Illinois, Maine, Maryland, Michigan, New York, Oregon, Rhode Island and Washington) • Three of those 10 have also enacted limited bans on Deca-BDE (Maine, Oregon, and Washington) • One state has banned only Deca-BDE (Vermont) • California Proposition 65: labeling standard for certain chemicals • Currently, no bans on non-halogenated FRs • Flame retardants evaluated through an agency-specific regulatory process lead by EPA

43. Regulatory status – Europe • Three relevant regulations : REACH, RoHS and WEEE • PBBs voluntarily ceased production 2000 • Penta- and Octa-BDE voluntarily removed 2004, Deca-BDE voluntarily removed 2014, mandatory removal of DBDE under review in EU (2017 at earliest) • Deca-BDE banned from use in E&E equipment 2008 (RoHS) • TBBP-A has undergone EU risk assessment and is not restricted • HBCD has undergone EU RA and is presently restricted, use expected to cease 2015 • Currently, no bans on non-halogenated FRs • Numerous Risk Assessments have been conducted or are under way 43

44. How Can the SAC HelpNASFM Members? • “Ask the SAC” -- NASFM members’ opportunity to use the expertise of the SAC to answer questions, obtain leads to information, etc. • White papers • Workshops • Research • Grant applications • Talk to us while we are here! • Contact Karen Deppa of NASFM 44