Considerations for Development of Effective Flammability Standards

Transcription

1 Considerations for Development of Effective Flammability Standards Polyurethane Foam Association Bob Luedeka February 12, 2015 Thank you for inviting me to speak this morning. It is a pleasure to return to Berkeley and to be able to address issues that now relate to the implementation of TB and SB Instead of discussing about how to make it happen, we can now focus on how to make it work. 1

2 Topics Fast facts about flexible polyurethane foam What is the real risk of furniture ignition? What builds better fire safety? What are the requirements for an effective flammability standard? How can existing flammability testing and labeling requirements be improved? In the next 11 and one half minutes I would like to share some fast facts about flexible polyurethane foam and our industry. I will discuss real fires and real ignition scenarios and how they relate to today's and possibly tomorrow s fire standards. And I will suggest ways to improve fire safety that go along with regulatory flammability requirements. In the remaining time I will pose some questions that may help to improve existing standards and provide considerations for possible future requirements.

3 Foam Must be Comfortable Physical characteristic State of mind Foam manufacturers focus on satisfaction Controversy and concerns do not sell products. As background flexible polyurethane foam that I will refer to as FPF is a comfort product. It is the comfort component in home furnishings. And, as the slightly hokey photo shows, comfort is more than a physical characteristic, comfort is also a perception and a state of mind. Foam producers are aware of the important value of comfort and are very proactive in finding ways to reinforce the security and well being associated with our industry's products. All controversies and concerns are taken very seriously and finding solutions become priorities. This is why PFA became proactively involved in learning about the fire retardant dilemma and working with all stakeholders to find solutions to satisfy everyone.

4 Background: Fire Safety is a Priority Founded in 1980, PFA encourages research and addresses questions about foam ignition and combustion Like other organic materials, FPF is combustible and can burn vigorously FPF has the ability to retreat from moderate radiant heat without need for FR additives FPF can be combustion modified to improve open flame ignition and burning behavior With that goal, PFA was founded in 1980 to provide a forum for sharing research that was originally focused on the flammability issue. There was an interest in improving the safety of foam products in light of decades long attention to household fires. The flammability issue predates polyurethane foam, as all carbon based cushioning materials like cotton, foam rubber, synthetic fiber and polyurethane foam burn vigorously once ignited. But unlike previous cushioning materials, with out the need for FR additives, FPF has the desirable ability to retreat from moderate radiant heat, such as smoldering cigarettes. This is one of the key reasons that FPF pretty much replaced cotton batting and latex rubber in mattresses back in the early sixties. And for larger ignition sources such as small open flame, FPF has the ability to easily combustion modified using chemical flame retardants and we all know how prolific that became due to regulatory requirements that put an emphasis on filling components resistance to small open flame ignition.

5 What is the Real Risk of Ignition? Through the adoption of TB we now have an opportunity to take a deep breath and pause to look at the real risk of household fires, and we find that an open flame requirement wasn't as critically needed as originally believed. The statistics related to cases of fire begin with the National Fire Incident Reporting System known as NFIRS that records what essentially are case reports of fire calls submitted by many fire departments. The NFIRS database is analyzed by NFPA and then the NFPA summary data are interpreted by the Consumer Product Safety Commission in the form of a biannual residential fire loss report.

6 What is the Real Risk of Ignition? CPSC Estimate : 410 Deaths (avg) 190 Smoking materials 50 Open flame 170 Other NFPA Estimate : 610 Deaths (avg) 270 Smoking materials 60 Open flame 130 Open flame from other 70 Operating equipment 60 Ember / ash / other smolder 20 Unclassified Based on years of CPSC Fire Loss reports, smoldering ignition has clearly been identified as the leading cause of ignition with fires involving upholstered furniture. On a smaller scale, losses related to small open flame are also noted, however the frequency of this type of ignition is far less than smolder. Recently, a publicized NFPA analysis went beyond the scope of the CPSC interpretation and proposed that there is a significant risk presented by upholstered furniture as a possible second item of ignition or afuel load ignited by a much larger heat source such as a large trash fire, burning appliance or flame spread from a burning wall or from another room.

7 What is the Real Risk of Ignition? CPSC Data show consistent multi-year trending NFPA snap shot may not provide consistent trending Preliminary statistical analysis indicates low confidence in NFPA data interpretation due to: Frequency of missing data and unknowns Regional bias among reporting departments Unpredictable unique real fire conditions Difficulty identifying secondary ignitions The two sets of loss numbers differ in that the CPSC interpretation and resulting fire lost estimates have been published over many years and provide a fairly consistent trend indicating a continual reduction in fires and related losses; while the recent NFPA analysis regarding secondary ignition sources represents a snapshot based on a short time span. We don't know if the NFPA analysis information has or will trend over the years. A preliminary analysis of the NFPA report shows a low confidence interval and possible limited accuracy because when it comes to identifying secondary ignitions and fuel load sources, the NFIRS database based on submitted fire departments call reports contains many blank responses and unknown checked boxes that are difficult to interpret as anything other than no data. Not all fire departments participate and submit call reports. And among reporting departments there may be regional and local differences in the types of fires they respond to. The response time in the city may be very different than it is in a vast rule area and so fire losses may be very different for one department vs another. But, NFPA takes blank data and gives it a value based on extrapolated national data that may be very inaccurate. This raking and assigned value approach does not take into account that all fires are unique and cause of fire or the extent of loss may not be predictable. Real fires don t stick to a plan. Another consideration is that it often requires a professional fire engineer to identify a secondary ignition source and many call reports do not have the benefit of that level of expertise. So recent interest in developing fire standards to address the role of large fuel load and fires caused by large heat sources may be premature. The data simply aren t refined enough to be very useful.

8 What is the Real Risk of Ignition? Appropriate to focus on smolder ignition Risk of addressable small open flame is comparably low Risk of larger open flame and other large ignitions remains unknown and may not be addressable with practical, safe technologies What we do know and what is suggested by many years of consistent data is that smoldering ignition remains the major hazard and the most frequent cause of fires involving furniture and that should be the regulatory focus for now. And while small open flame such as a candle or lighter is also a threat, it is much smaller as compared to mishandled cigarettes. Yes, larger ignition sources are of interest and worth studying, but, for now, the actual risk is not supported by reliable data. In addition, addressing large ignitions that may include vigorous heat sources is not something that can be easily done without significant added product expensive and possibly combinations of barriers and FR chemistry in the components.

9 What Builds Better Fire Safety? Fire prevention behavior (education, fewer smokers) Detection and suppression (smoke detectors, alarms, sprinklers/extinguishers) Construction modification (smolder resistance, barriers) Combustion modification (improved raw materials/formulations) There are a number of ways that furniture fire safety can be improved. It can be addressed through behavioral changes brought about by education and fewer smokers. Smoke detectors, fire alarms and sprinklers can be extremely effective and there are great opportunities in this area. As we've seen through TB there are ways to change furniture construction so that items are made to be more resistant to the most common cause of fire. There are new opportunities to develop new ways to make products using new science such as modifying the basic polymers used to produce synthetic materials without use of traditional flame retardant chemicals. Work in the area of polymer modification and development of so called reactive combustion modified products may be compatible with California s Green Chemistry initiative.

10 Effective Flammability Standard Requirements PFA supports a national standard that is: Appropriate to the real risk of ignition Based on a performance-based test method Without bias toward any component or material Providing reproducible and repeatable results Resulting in compliant products that are salable and safe for workers, consumers and the environment Now let's take a minute or two and look at what goes into making a good flammability requirement that could help improve fire safety on a national scale. TB is a good starting point and PFA could supports a national effort to make such a smolder standard a national requirement. The Bureau s new standard meets what we believe to be the basic requirements.

11 TB / SB 1019 Questions and Challenges How to educate the entire distribution channel? But work on TB is not complete. There is still an education challenge. Here s a look at the distribution channel for foam cushions used in furniture. Other components may have similarly complex challenges. To make TB and SB 1019 reality, each sector of the channel must understand the requirements. Based on the many calls I still receive, I am convinced many sectors remain uninformed or worse yet, are misinformed. As an example the small businesses that buy bulk foam for the manufacturer of cushions typically are outside the communications loop. The companies are hard to identify. Many companies remain uninformed about the new requirements. How can we better inform small companies that are hard to reach?

12 TB / SB 1019 Questions and Challenges How do we overcome barrier issues? Are the risks of ignition valid? Can a single barrier effectively address all ignitions? Material economics? Assembly labor costs? International competition and possible jobs loss? Aesthetics and durability? SB 1019 label requirement? And there is the question of use of possible barrier technologies with the intent of addressing a number of possible ignition sources that might include cigarettes, lighters, burning trash and even flames spread from another room. Without accurate statistics it is impossible to develop solutions to address unknown and widely varying risks. We do not believe there is any single barrier that can mitigate all of the possible ignition hazards. And the idea of applying a physical barrier that must be cut to a unique pattern and fitted to many different furniture shapes is an expensive proposition. Add material costs, labor and we are playing into the hands of eager offshore furniture manufacturing competition. There are also aesthetic and performnace considerations. And now there is a new consideration. The way SB 1019 was written, we believe if a barrier product is marketed to reduce ignition and flame spread, then use of this product would require a YES on the SB1019 label even though chemical flame retardants may not have been added.

13 TB / SB 1019 Questions and Challenges How can we improve FR content identification? Label requirement applies to all FR products chemical additives, reactive FRs, polymer improvements, barriers, articles and devices Complexity of the distribution chain makes product identification (chain of custody) almost impossible Over labeling may become common Regarding SB1019 there are a number of questions. The language is unclear as to how flame retardants are defined and the bill seems to include flame retardant products that may be articles, and not chemical substances. The law also requires companies to determine if FR content above the allowed threshold exists. This is hard to know for sure with so many hands touching the components and possible comingling of component parts as they travel through the distribution network. Without a sophisticated chain of custody program, content identification hits a brick wall, particularly when very small labor focused businesses are involved. Over labeling out of precaution likely will occur and this flies in the face of efforts to help consumers know for sure what s inside their furniture. It may show there is FR content when in fact there is not.

14 Let s Move Forward Together Take advantage of smolder-safety opportunity and advocate for national adoption Don t abandon sound science Use fact-based decision making Work together to achieve realistic furniture flammability performance appropriate to the real risk of fire Encourage innovative green fire safety solutions I will leave you with these thoughts and a challenge. We have an opportunity to help improve fire safety on a national basis and we can do that by supporting adoption of a standard like TB as a federal regulation through the CPSC. And I challenge everyone to look carefully at the science and statistical reliability of fire solution proposals that may try to address large open flame ignitions. Let s encourage fact based decisionmaking at all levels particularly when there are emotional undercurrents. Let s work together to achieve realistic and appropriate flammability requirements like TB And, please keep in mind the objectives of the Green Chemistry initiative. Help encourage innovative and safe fire safety solutions and try to avoid regulations that impede or restrict that development process. Thank you so much for your attention and support of the foam industry.