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Duke University Student Community in Support of Restricting the use of Added Flame Retardants and Reviewing Flammable Fabrics Act of 1967

Dear Speaker Pelosi, and Leaders Schumer, McConnell, and McCarthy:

We, as students of Environmental Science and Health at Duke University, write to urge Congress to nationally restrict the use of added chemical flame retardants in household items and review the effectiveness of fire standards established in the Flammable Fabrics Act of 1967. Mounting scientific research suggests that human exposure to chemical flame retardants can be quite harmful. Additive chemical flame retardants are found in couches, pillows, mattresses, curtains, and even some electronics, and thus affect millions of Americans daily. While some state legislators have restricted these chemicals, a uniform federal movement is needed. The potential societal harm imposed by these chemicals is large, and a review of this issue is needed to protect all Americans, regardless of their state of residence.
Since the 1970s, manufacturers have added chemical flame retardants to a plethora of consumer goods. The rise of petroleum-based products in the late 1900’s increased the flammability of many household materials, and these chemicals were seen as a way to effectively mitigate any fire risk that these products may introduce. Furthermore, these chemicals allowed more naturally flammable materials to become compliant with the standards created by the Flammable Fabrics Act of 1967 (Consumer Product Safety Commission). While reducing and lawfully restricting the flammability of consumer materials may appear to benefit the public good, research has found that additive chemical flame retardants may be causing significant harm.
Added flame retardants are commonly formulated from brominated and/or organophosphate-based chemicals. In the early days of their application, PBDEs were frequently used. However, because of significant evidence demonstrating this compound was bioaccumulative and potentially toxic, it was phased out in the mid 2000s by manufacturers of household products (Tullo, 2003). While this certainly was a step in the right direction, PBDEs were shortly replaced by equally, if not more, detrimental alternatives. Now, organophosphate-based chemicals such as TDCIPP, TCIPP, and a chemical known as Firemaster 550 are being used as replacements and research has proven all of these chemicals to be quite harmful (Stapleton et al, 2012). These chemicals end up in household dust and can subsequently be inhaled or ingested by humans. They also can be absorbed through physical contact with household items (Stapleton et al., 2009 & Hammel et al., 2017). Once in the human body, these chemicals can have sweeping health effects. Seven different academic studies found exposure to these chemicals to be linked with detrimental health effects including cancer, improper bone development, lowered fecundity, nervous system damage, and heart developmental issues. Due to the commonality of flame retardants in household items, workplaces, and schools, these potential effects are quite concerning as we all likely interact with these chemicals daily.
With mounting academic evidence demonstrating the potential harm that these chemicals induce, it is necessary to evaluate the benefit they provide. Historically, these chemicals have been added to furniture, mattresses, and carpets in order to adhere to Class I flammability requirements under the Flammable Fabrics Act. To qualify for this standard, flame retardants have to slow the rate at which products burn by just a few seconds (Consumer Products Safety Commission). It isn’t necessarily clear whether these few seconds actually change individuals’ outcome when escaping fires, and the added chemicals are by no means a way of extinguishing or otherwise stopping an existing fire.
We can also look at home fire data to evaluate the potential benefit of these products. The National Fire Protection Association (NFPA) reports that from 2015-2019, there was an annual average of approximately 2,620 civilian deaths and 11,070 civilian injuries caused by housefires, with smoking being the leading cause of home fire deaths over the entire period. While the impact of housefires is significant, many households are being exposed to flame retardants on a daily basis. Stapleton et al (2012) tested foam furniture samples from 101 couches purchased between 1984-2010 and found that 85% of the samples contained harmful or largely untested flame retardant chemicals. Assuming this is a representative sample of United States households, it suggests that most Americans probably own furniture with added flame retardants. Thus, hundreds of millions of Americans are likely exposed to these chemicals every year. The societal health benefit of protecting millions of individuals from these chemicals is likely much greater than the benefit received from delaying fires by a few seconds for the several thousand Americans who experience harmful house fires each year.
Legislation on these dangerous chemicals varies state-by-state. Currently, there are sixteen states that have adopted policies restricting flame retardants. New York was the most recent state to do so in a sweeping reform that restricts the use of flame retardants in furniture, electronic displays, and mattresses (SCHF). This is promising progress, but unfortunately, Americans in states that have yet to adopt legislation on this issue will continue to be exposed to these hazardous substances. With the mounting evidence of their harm, it is time to tackle this issue at a federal level.
At the moment, additive flame retardants are silently harming, and in some instances, killing, many Americans. The benefits of these chemicals are unclear, while experts in environmental health seem to have abundant proof of the harm they cause. Congress should use its power to restrict chemical flame retardants and review the societal benefit of current flammability regulations under the Flammable Fabrics Act of 1967. We need to eradicate this invisible harm to preserve and protect the American people.

Best Regards,

Davis Jones, Student at Duke University