Costs of PBDE Flame Retardant Replacement for Furniture Manufacturers
RAPID RESPONSE: Review of Literature on Costs of PBDE Flame Retardant Replacement for Furniture Manufacturers
Requested by: Eric Downey, Alaska Manufacturing Extension Partnership, Inc.
The state of Alaska is considering legislation that would eliminate the use of polybrominated diphenyl ether (PBDE) flame-retardants in furniture manufacture, among other uses. Are there data from previous studies that will help estimate the costs of PBDE elimination to manufacturers?
- Furniture manufacturers most likely no longer use pentaBDE for residential or office/institutional applications, as furniture component suppliers have moved to non-PBDE replacements. No reference could be found to demonstrate current use of octaBDE to meet foam or textile furniture fabric flammability standards. Several state and federal government sources report that decaBDE is also not used in residential or office furniture applications or in mattresses. While these results should be verified by direct consultation with Alaska manufacturers, if true, a ban on PBDEs would not require any change to current furniture manufacturing practices.
- Federal upholstered furniture flammability standards are slated for completion in 2011. These may require re-design of current furniture products to incorporate new flame-retardants or barrier technologies. While these requirements could possibly be met using PBDEs, reports suggest that non-PBDE chemicals and/or other product design choices can successfully meet all current and pending federal fire safety standards.
- The Consumer Product Safety Commission (CPSC) has completed economic impact analyses addressing fire safety standards for mattresses and upholstered furniture. CPSC reports and industry rebuttals provide sufficient detail to estimate economic impact from the pending Alaska PBDE legislation.
- A wide range of technologies and designs can be used to provide the same level of fire safety. In actual practice, designs will change to accommodate a new cost structure. Any further cost analysis should be narrowly focused on a very few specific designs and clearly specified cost categories (what is included/excluded) to permit clear outcomes within a manageable work load.
The state of Alaska is considering legislation (2011 House Bill 63 and Senate Bill 27) that would ban the use of polybrominated diphenyl ether (PBDE) flame-retardants in furniture manufacture. PBDEs are used in plastics and other petroleum-based products to slow the development and spread of fire. The proposed legislation references three general PBDE product types: pentaBDE, octaBDE and decaBDE. Since the legislation exempts transportation-related products, only home and commercial furniture uses (including mattresses) were considered for this Rapid Response.
Are Penta- or OctaBDE in Use in Alaska?
Following concerns about the safety of exposure to PBDEs, the only US manufacturer of penta- and octaBDE ended production in 2004 (as part of a voluntary agreement with the US EPA http://www.epa.gov/oppt/dfe/pubs/projects/flameret/milestones.htm). In a similar set of negotiations, the only US manufacturers of decaBDE have agreed to end production and sales for all uses by the end of 2013 (http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/deccadbe.html). PentaBDE and octaBDE are banned for sale and use in the European Union, Canada, and the states of Washington, Oregon, California, and Hawaii among others and a recent Canadian risk assessment reports that pentaBDE and octaBDE are no longer manufactured anywhere in the world (http://www.ec.gc.ca/Publications/default.asp?lang=En&xml=34DCDBA9-9C86-4EB2-AA93-81B6755321F9). National and state bans or limits on PBDEs have created a driving force for change in the commercial use of flame-retardant chemicals.
While pentaBDE was at one time widely used in flexible polyurethane foam for furniture, the Polyurethane Foam Association, whose members represent 70% of US flexible polyurethane foam production, announced in 2005 that the industry had converted away from use of pentaBDE in foam for home furnishings cushioning applications for all but a small number of specialty applications. The same release states “[o]ctaBDE and decaBDE additives are not used in the manufacturing of flexible polyurethane foam” (http://www.pfa.org/forms/penta_release.html ). A Frequently Asked Questions page at the website of the Sleep Products Safety Council (a safety division of the International Sleep Products Association, http://www.sleepproducts.org/) reports that mattress foams do not use PBDEs to meet current fire safety standards (http://www.mattressregulation.org/faq.aspx#4 ). Lastly, a recent scientific study looked for pentaBDE in furniture foam samples 26 pieces of furniture manufactured between 2003 and 2009. Only one futon, purchased prior to 2004, contained pentaBDE (http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2782704/).These reports suggest that, at least for furniture manufacture, only textile and fabric applications of PBDEs could possibly be affected by the proposed Alaska legislation.
Is DecaBDE in Use in Alaska?
With the ban of penta- and octaBDE in many locales, many manufacturers shifted to the use of decaBDE in furniture applications. Some products were redesigned to satisfy fire resistance standards without the addition of chemicals to the cushioning foam. Three main approaches are suitable: 1) use of cover fabrics made from materials that are inherently fire resistant, 2) treatment of cover fabrics (or fibers) with flame retardants (e.g., decaBDE), or 3) use of fire-resistant barriers between the cover fabric and the flammable cushioning foam. Any Alaska manufacturers currently using fabrics treated with decaBDE would need to modify their existing processes or materials to comply with the pending Alaska legislation.
Following negotiations with the US EPA, the only US manufacturers of decaBDE agreed to phase end production and sales for all uses by the end of 2013 (http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/deccadbe.html). As decaBDE is suspected of presenting hazards similar to other PBDEs, some US states have also enacted bans on its manufacture or use in products, including Maine, Illinois, and Washington State, among others. Environmental staff from these three states and studies addressing decaBDE replacement were consulted to locate information on cost impacts of decaBDE replacement for furniture applications. Several of these sources report that decaBDE is not currently used in home or office furniture manufactured in the US (see below).
Review of Selected decaBDE Studies
2005 Lowell Study
In 2005, the Lowell Center for Sustainable Production published an excellent study on the uses and potential alternatives to decaBDE (http://www.sustainableproduction.org/downloads/DecaBDESubstitutesFinal4-15-05.pdf). The study provides little information on cost, however, it does illustrate the challenge to quantifying costs given the wide range of possible approaches used to achieve fire resistance.
Data gathered from one manufacturer showed that phosphate-based replacement chemicals would be roughly two- to two-and-one-half times the cost of decaBDE. As chemicals achieve equivalent fire resistance at different additive levels, the final chemical loading for any product would be required to determine the true cost impact.
2007 Maine Department of Environmental Protection Study
The state of Maine banned decaBDE for use in furniture and mattresses beginning January 1, 2008. A report by the Maine Department of Environmental Protection to the legislature largely references the 2005 Lowell study and provides little information on cost (“Brominated Flame Retardants -Third annual report to the Maine Legislature” available at:
http://www.maine.gov/dep/rwm/publications/legislativereports/pdf/finalrptjan07.pdf). Citing US Consumer Products Safety Commission (CSPC) and other research, the report concludes that low-cost chemical alternatives to decaBDE were available to meet pending fire safety standards:
In the case of textiles, alternatives that do not require the use of chemical flame retardants already are widely employed in the marketplace. There are many ways to modify mattresses, upholstered furniture and drapes to meet flammability standards without using decaBDE or other BFRs. Mattress manufacturers uniformly have eschewed the use of decaBDE to meet a national flammability that takes effect on July 1, 2007. And furniture industry sources suggest that, in 99% of cases, chemical flame retardants will not be needed to meet pending national standards for residential upholstered furniture.
One of the study’s authors, John James, was contacted, but could not provide any further information on cost (contact information: John James at Maine Department of Environmental Protection, John.James@maine.gov).The study recommended that decaBDE be banned in part to prevent its introduction to meet pending federal flammability standards for furniture.
2007 Illinois Environmental Protection Agency Study
In preparation for a decaBDE ban, the State of Illinois published a study on decaBDE: “Report on Alternatives to the Flame Retardant DecaBDE: Evaluation of Toxicity, Availability, Affordability, and Fire Safety Issues” (March 2007), available at: http://www.epa.state.il.us/reports/decabde-study/decabde-alternatives.pdf (Contact: Gary Styzens at the Illinois Environmental Protection Agency, Gary.Styzens@Illinois.gov ). Appendix IV of the report contains a detailed qualitative discussion of affordability. The study reports that no PBDEs, including decaBDE, are currently used for either residential furniture or commercial furniture/office applications.
The report suggests that the transition away from all uses of decaBDE occurred as a result of market pressures, negative publicity, etc., and that affordability would likely be more of a concern for manufacturers that were slow to respond to the move away from PBDEs (due to loss of market share and other factors):
In light of the substantial transition away from DecaBDE that is already occurring, it appears that many alternatives to DecaBDE’s uses have been found to be available and affordable by manufacturers. Whether these transitions have resulted from regulations and proposed regulations, market pressures, liability concerns, or other forces, it appears to us now that many users of DecaBDE are in the process of phasing it out or intend to phase it out as soon as reasonably possible.
A number of Illinois manufacturers and trade groups were contacted for the report and confirmed the move away from PBDE products. Links and contact names were documented for some sources and may be useful in developing additional detail on cost. Affordability issues were considered important for transportation uses (RVs, airline seats, etc.), but these are specifically excluded from the Alaska legislation.
2008 Washington State Department of Ecology Study
Washington State banned decaBDE effective 2011, following an analysis that demonstrated the commercial availability of alternatives (“Alternatives to Deca-BDE in Televisions and Computers and Residential Upholstered Furniture” available at: http://www.ecy.wa.gov/pubs/0907041.pdf). This report mentions that decaBDE is not and could not be used in foam materials to meet furniture flammability standards (as described earlier). They further concluded, based on CPSC work, that manufacturers could meet existing and proposed fire safety standards without decaBDE through appropriate choices of cover fabrics and/or internal barriers. The study did not address affordability or cost of alternatives for textile applications (confirmed by Alex Stone, Washington State Department of Ecology, email@example.com).
Flame-Retardant Alternatives for DecaBDE Partnership
The US EPA initiated a Design for Environment study of alternatives to decaBDE in October 2010. The study will generate environmental health and safety data for a number of chemicals or systems that could replace decaBDE in common applications. Final results are expected in late 2011. Staff members at US EPA were not able to provide any information on chemical costs (contact: Emma Lavoie, Lavoie.Emma@epamail.epa.gov).
Consumer Product Safety Commission Studies (not focused on decaBDE replacement)
A 2004 analysis by the CPSC for a proposed federal open-flame ignition resistance standard for mattresses includes estimates of new costs to manufacturers for various mattress configurations (found at: http://www.cpsc.gov/cpscpub/prerel/prhtml05/05032.html; costs are described in part 4 at: http://www.cpsc.gov/library/foia/foia05/brief/mattressespt4.pdf). These costs are not for replacement of decaBDE, but rather for the costs of complying with new standards requiring changes in mattress design. The new standard took effect in 2007.
The CPSC study estimated costs for several categories of expense: material and labor costs, costs of prototype and confirmation testing, costs of information collection and record keeping, costs of quality control/quality assurance programs, costs to wholesalers, distributors and retailers, and costs of compliance and enforcement. Considerable effort went into the analysis and details are well documented in the accompanying reports. These results would provide a good basis for an analysis of decaBDE replacement costs or a sensitivity analysis for alternative flame retardant chemical costs in mattress applications.
A similar analysis addressed economics of a proposed upholstered furniture flammability standard (http://www.cpsc.gov/LIBRARY/FOIA/foia08/brief/ufflamm.pdf). The economic analysis is included in Tab F – “Preliminary Regulatory Analysis of a Draft Proposed Flammability Rule to Address Ignitions of Upholstered Furniture” (beginning at page 103). Once again, a wide variety of possible types and placements of material can be used to meet the standard, and costs depend on the constraints and choices of any particular design. Although rulemaking for upholstered furniture is not complete (final work expected in fiscal year 2011), the process has been underway for some years and businesses should be perparing a response to these changing safety standards (http://www.cpsc.gov/LIBRARY/FOIA/ballot/ballot10/regagenda.pdf).
Considerable additional information is included in public comments associated with these studies. Relevant documents can be found using a convenient search tool for documents at CPSC: http://www.cpsc.gov/cgi-bin/foia.aspx (select “mattresses” or “upholstered furniture” topics in the pull down menu). These include some industry rebuttals suggesting that CPSC underestimated costs. A similar analysis was published by a small group of furniture manufacturing associations, available at: http://www.ahfa.us/uploads/documents/flammreportmarch06.pdf. These reports offer additional information on cost estimates for furniture manufacture and impacts of design changes. A full review and analysis of this data is well beyond the scope of a Rapid Response, but it is hoped the data may prove useful for any follow-up work on this issue in Alaska.
Cost of Flame Retardant Chemicals
In order to use the CPSC data on costs, some comparative data on prices for flame retardants would be helpful. Recent press releases suggest that current decaBDE prices are approximately $5 per pound in the US (http://abcnews.go.com/Business/wireStory?id=11464150). A European association of flame retardant manufacturers published some rough cost data on various classes of flame retardants from 2007-2008 (found in a presentation available at http://www.pinfa.eu/uploads/Mediaroom/PINFA_Media-Info_on_PIN-FRs_Global_FRMarket-2.ppt. A variety of flame retardants were listed in a “< 4 USD” commodity category. As any application has specific requirements from the chemicals used, the best chemical alternatives cannot be identified without specifying the means by which fire safety standards would be met (chemical options depend on materials used, whether treatment would be to cover, barrier or foam, etc.).
Penta-, octa- and decaBDE are either out of production, or soon will be in the US. While there may still be uses of PBDEs in some challenging applications, such as transportation, industries of all types have largely moved away from PBDEs. Following a review of recent documents and discussions with environmental agencies across the US, it appears that PBDEs are not currently used in furniture applications or mattresses for the US market. If this can be verified for Alaska, then there is no immediate impact on furniture manufacturers from the coming ban.
Pending federal legislation on upholstered furniture flammability may require design changes in the coming years. While PBDEs could be used to meet these new fire safety requirements, alternatives are available utilizing either non-PBDE flame retardants or additive-free design choices such as inherently fire resistant fabrics and materials.
Data discussed in recent CPCS reports and industry rebuttals contain good detail on the estimated costs of meeting fire safety standards. These data, along with estimates of flame retardant prices can be used for a more detailed analysis once design requirements are specified.
- Are there any existing uses for penta- or octa- or decaBDE in furniture manufacturing in Alaska (possible commercial or institutional uses)? A survey of a small number of manufacturers or industry contacts should be done to confirm whether the proposed legislation would have any impact on current practices.
- Are Alaska manufacturers considering a response to pending changes in upholstered furniture standards? Given changes in industry practices, are PBDEs likely to be among the realistic chemical options?
- Other states, such as Maryland, Vermont and Oregon have similar decaBDE bans in place. They may have analyses that would address costs of decaBDE replacement. Several other states studying bans on decaBDE might also be consulted, including Hawaii, Minnesota, New York and Rhode Island (www.chemicalspolicy.org)
- The suggestion from most of the state sources reviewed here is that costs might increase with a ban of PBDEs, but that any increases would be modest. Some states have had PBDE and even decaBDE bans in place for years. It would be interesting to investigate the fate of the furniture industry in these states to see how they fared compared with industries in states without bans.
- Manufacturers associations or industry groups likely have good information on flame retardant trends and costs. Efforts should be made to contact these industry sources (suggestions below under “Resources”).
Participants with US EPA in the Furniture Flame Retardancy Partnership
- Business and Institutional Furniture Manufacturer’s Association: www.bifma.org
- American Home Furnishings Alliance: www.ahfa.us
Textile industry participants with US EPA in the decaBDE Partnership
- Janan Rabiah, Association of Contract Textiles
- Dave Panning, Business and Institutional Furniture Manufacturer’s Association
- Hardy Poole, National Textile Association (http://www.nationaltextile.org/nta/inex.htm)
- Lowell Center for Sustainable Production 2005. Decabromodiphenylether: An Investigation of Non-Halogen Substitutes in Electronic Enclosure and Textile Applications. University of Massachusetts, Lowell, Massachusetts. Available at http://www.sustainableproduction.org/downloads/DecaBDESubstitutesFinal4-15-05.pdf
- Washington State Department of Ecology has a document describing alternatives to decaBDE in common applications: http://www.ecy.wa.gov/pubs/0507048.pdf.
- The US EPA’s Design for Environment Furniture Flame Retardancy Partnership completed an analysis of pentaBDE alternatives in 2005: http://www.epa.gov/oppt/dfe/pubs/projects/flameret/index.htm
- US EPA has a chemical action plan for PBDEs at: http://www.epa.gov/opptintr/existingchemicals/pubs/actionplans/pbde.html
- US EPA 2010 information on the DecaBDE Phase-out Initiative available at http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/deccadbe.html.
- US EPA 2009 information on the Polybrominated Diphenyl Ethers (PBDEs) Action Plan available at: http://www.epa.gov/opptintr/existingchemicals/pubs/pbdes_ap_2009_1230_final.pdf
- Washington State Department of Ecology 2006 information on their Polybrominated Diphenyl Ether (PBDE) Chemical Action Plan available at: http://www.ecy.wa.gov/pubs/0507048.pdf.
- A document prepared for the Persistent Organic Pollutants Committee of the Stockholm Convention contains information on pentaBDE replacements and cost for one alternative (suggesting that less expensive alternatives are available for some applications): http://chm.pops.int/Portals/0/docs/POPRC4/intersession/Substitution/pentaBDE_revised_Stefan_Posner_final%20version.pdf
- Results of a 2009 NIST workshop on barrier fabrics to address flammability can be found at: http://www.bfrl.nist.gov/866/barrierfabric/