VII. Recommendations. For the Federal Government. Flame-retardants should only be used in high fire-risk situations.

Transcription

1 F L A M E R E T A R D A N T S VII. Recommedatios f For the Federal Govermet Flame-retardats should oly be used i high fire-risk situatios. Because exposures to flame-retardats carry their ow set of health risks, flame-retardats should oly be used i situatios where the risk of ijury from fire outweighs the risk from flame-retardat exposures. Examples of such high-risk situatios iclude aircraft, marie vessels, cars, exterior buildig materials for use i fire-proe regios, ad specialized clothig desiged for those who face special fire risks. Restrict the use of flame-retardats i ifat ad toddler products. Recet toxicological studies show that flame-retardats pose the greatest risk to the ormal growth ad developmet of fetuses, ifats ad childre. Ifats ad small childre s body weight is so low that their exposures to flame retardats, i relatio to their body weight, is simply too great. The health risks that all ifats ad childre are experiecig, due to the federal law madatig that flameretardats be i may of their products, far outweigh the risk of fire. Restrict flame-retardat use i low fire-risk situatios. Most people live their daily lives i circumstaces with low risk of fire. Curret law allows ad i some circumstaces requires that utested fire-retardat chemicals be used to fireproof most compoets of our built eviromets ad may cosumer goods. For example, there is o eed to add flame-retardats to thousads of cosumer products, such as plastics used to package foods ad 84

2 T H E C A S E F O R P O L I C Y C H A N G E beverages. The distictio betwee high ad low fire risk situatios should be carefully defied, ad flame-retardats should be baed from all low-risk products. The govermet should require that flameretardats be tested for their health effects. Most of the 200 flame-retardats i iteratioal commerce have ot bee adequately tested to reach the judgmet that they are reasoably certai to be safe. Cogress should require that flameretardats be tested so their health ad evirometal effects are kow. Testig requiremets should apply to all flame-retardat chemicals, regardless of whether or ot Cogress exempted them from regulatio uder the Toxic Substace Cotrol Act of Flame-retardat risks should take ito accout susceptible populatios. EPA should prepare huma exposure risk assessmets for flameretardats. EPA should take ito accout the vulerability of susceptible populatios, icludig childre, ifats, ad fetuses; the elderly; ad those with illesses that might be exacerbated by exposures. Testig should iclude chemical mixtures of flame-retardats. Flame-retardats are commoly preset as mixtures i our cosumer products, ad huma tissues. Firemaster 550, a commoly used brad of flame-retardat i the Uited States, is a mixture of four distict chemicals. Pesticides provide a model for this proposal, sice EPA has completed mixtures risk assessmets for orgaophosphate ad triazie pesticides. Cogress should demad toxicity testig of mixtures of compouds, such as the flameretardat Firemaster

3 F L A M E R E T A R D A N T S Govermet should require idustry to pay for testig. The chemical idustry, or product maufacturers who use ad beefit from flame-retardats, should provide fudig for the chemical testig iitiative. Pesticide maufacturers, divisios of the same firms that maufacture flame-retardats, already are required to fud the testig of chemicals proposed for EPA approval, alog with the costs imposed o EPA to review these data. Products cotaiig flame-retardats should be labeled as such. Ay product cotaiig a flame-retardat should be labeled as such. Labels should state which flame retardat has bee used. Product certificatio programs should be established that verify the absece of flameretardats just as the Orgaic Food Program shows the absece of pesticides. EPA should create a program that certifies the absece of flameretardats from cosumer products. This program could be similar to the orgaic food program that certifies that orgaic foods do ot cotai pesticides. This flame-retardat certificatio program could provide cosumers with the opportuity to kowigly buy products that do ot cotai flame-retardats. The federal govermet should require that corporatios disclose their kowledge of sigificat hazards i their products. Producers of flame-retardats should be required to disclose their kowledge of ay hazard. May corporatios coduct their ow hazard ad risk assessmets to uderstad ad limit their liability, yet these data are ot ormally disclosed to the govermet. 86

4 T H E C A S E F O R P O L I C Y C H A N G E As well, chemical compaies should have the legal obligatio to iform potetial purchasers of flame-retardats that the federal govermet has foud a sigificat hazard. Similarly, maufacturers should have a legal obligatio to iform distributors ad retailers about which flame-retardats are i their products. EPA should require maufacturers to demostrate safety usig the reasoable certaity of o harm stadard. To meet this burde, maufacturers should submit testig data that demostrate a reasoable certaity of o harm associated with their products. The federal govermet should establish a Registry of Flame-Retardats. EPA should be required to create ad maitai a registry of flameretardats. The purpose of the Registry would be to provide the public with kowledge about what flame-retardats are ow i 87

5 F L A M E R E T A R D A N T S productio ad what hazards they may pose to huma health ad the eviromet. It should also list what flame-retardats have bee discotiued but are still i use, ad their health effects. The govermet should explicitly permit EPA to restrict productio, use, export, ad import of flame-retardat chemicals. Govermet should explicitly permit EPA to restrict productio, use, export, ad import of flame-retardat chemicals ad products that cotai them. For example, use of a flame-retardat should be allowed i aircraft iteriors, while its use i childre s sleepwear should be restricted. If a chemical is baed from productio ad use, the maufacturer should ot be allowed to cotiue the sale of existig stocks. Products cotaiig flame-retardats should display a scaable barcode. Products that do cotai flame-retardats should have a scaable barcode clearly visible that ca be scaed usig covetioal cell phoe techology. Scaig the code via cell phoe would provide the cosumer with additioal iformatio about the specific flameretardats that were used, their potetial health ad evirometal effects, ad the proper disposal methods. Cradle-to-grave producer resposibility. Nearly 10,000 muicipal ladfills cotai a mixture of hazardous chemicals, icludig flame-retardats that have cotamiated uderlyig soils ad water. The chemical maufacturers have simply passed resposibility for these hazards alog to local commuities. Chemical maufacturers should be required to take fiacial resposibility for the evirometal cotamiatio caused by practices relatig to disposal of their products. 88

6 T H E C A S E F O R P O L I C Y C H A N G E Recommedatios for States States should pass laws that protect their citizes from flame-retardat exposures. Idustry will always work to pre-empt states legal authority to set safe ty stadards that are more striget tha those adopted by the federal govermet. States should have the right to protect their citizes whe the federal govermet fails to do so. States should restrict flame-retardats i ifat ad toddler products. Recet toxicological studies show that flame-retardats pose the greatest risk to the ormal growth ad developmet of fetuses, ifats ad childre. Ifats ad small childre s body weight is so low that their exposures to flame retardats, i relatio to their body weight, is simply too great. The health risks that all ifats ad childre are experiecig, due to the federal law madatig that flame retardats be i may of their products, far outweigh the risk of fire. States should require that products cotaiig flame-retardats be labeled. Ay product cotaiig a flame-retardat should be labeled as such. Labels should iclude which flame-retardat has bee used. States should promote fire-prevetio programs. States should ivigorate their fire prevetio programs. Promotio of fire prevetio is the most effective, least expesive, least evirometally damagig priority our atio could pursue to reduce loss of health, life ad property from fires. States should promote low-cost ad highly effective early warig techologies. Smoke alarms save lives. They should be available to all, regardless of icome status. 89

7 F L A M E R E T A R D A N T S States should offer opportuities to recycle electroic products. Foam that cotais flame-retardats remais a problem for ladfills. State ad local govermets have primary resposibility for maagig the disposal of solid ad hazardous wastes. Most solid wastes i Coecticut are disposed of via icieratio, but some are still placed i ladfills. The broad failure to effectively recycle electroics, buildig materials, auto plastics ad foam meas that most products cotaiig flame-retardats are released to the eviromet at the ed of their life-cycle. Recommedatios for Idividuals Choose furishigs carefully. New furiture filled with polyurethae foam cotais flame retardats, while furiture with polyester, dow, wool or cotto filligs is ulikely to cotai them. Avoid buyig furiture labeled, Complies with Califoria TB 117 or similar laguage. Ask the maufacturer if its foam is flame-retardat-free, thereby creatig a icreased demad for utreated foam furiture. Choose mattresses carefully. Major U.S. mattresses maufacturers do ot disclose their use of flame-retardats, ad a mattress labeled Orgaic, Eco-friedly, Gree, Natural, or Healthy does ot mea it is free of flameretardats. There are some compaies that will maufacture mattresses for you that do ot cotai flame-retardats; however, they may require a physicia's letter. Wash your hads ofte. You touch products with flame-retardat igrediets every day, perhaps dozes of times. The most commo cosumer products cotaiig them iclude televisios, cell phoes, computers, 90

8 T H E C A S E F O R P O L I C Y C H A N G E remote cotrols, kitche appliaces, home furishigs, vehicle iteriors, paper, ad other electroic equipmet. Washig hads ofte, especially before eatig, will reduce the amout igested. Prevet ifats from mouthig products that may cotai flame-retardats. Prevet ifats from mouthig plastic items that ormally cotai flame-retardats, TV remote cotrols, cell phoes, ad other plastic items. Vacuum floors ad carpetig ofte. Idoor dust is ofte a source of exposure to flame retardats, ad dust is commoly ihaled as fie particles. Ifats may easily igest dust as they crawl o the floor, placig hads ad figers i their mouths. PBDEs ad other flame-retardats i carpet paddig ad furiture are released ad bid to household dust. Vacuumig ca help prevet this. Prevet fire hazards. Prevetio is the most effective, least costly, ad least cotamiatig strategy you ca follow to avoid loss from fires. Fire-proofig your eviromet with toxic flame-retardat chemicals might add oly 20 secods to the time you eed to escape your home i the evet of a fire. Remember that the retardats cause products to smolder, which causes them to release potet toxic gases before burstig ito flames. Be certai you have workig fire alarms i each of your rooms, hallways, basemet ad attics. Chage your alarm batteries each year ad test the alarms oce a moth. Keep a workig fire extiguisher ear the kitche, basemet, ad i the master bedroom. Do ot smoke idoors. Cigarettes cotiue to be the leadig cause of furiture fires. 91

9 F L A M E R E T A R D A N T S If you have childre, be exceptioally careful to store lighters ad matches i a place iaccessible to them. Have a separate escape pla for every member of your family. Practice the escape pla to make childre comfortable. Have your furace, water heater, chimeys, ad wood stoves ispected aually by professioals to determie proper combustio ad vetilatio. Do ot store highly flammable liquids or gases idoors. These iclude propae taks ad gasolie cas. Recommedatios for Corporatios Corporatios should disclose to the govermet ay sigificat hazards from their products. May corporatios coduct their ow hazard ad risk assessmets to uderstad ad limit their liability, yet these data are ot ormally disclosed to the govermet. Producers of flameretardats should be required to disclose their kowledge of ay hazard. Corporatios should demad that their suppliers iform them about which flameretardats are i their supply chais. Maufacturers should require their distributors ad retailers to disclose ay flame-retardats i their products. Corporatios should actively maage what chemicals are i their products. Corporatios should adopt ad publish criteria for acceptable chemical igrediets i their products, ad work with their 92

10 T H E C A S E F O R P O L I C Y C H A N G E suppliers to restrict or phase out the use of chemicals that are persistet, that bioaccumulate, or are toxic. Corporatios should cosider havig product lies that are flame-retardat-free just as orgaic food lies are pesticide-free. May of the atio s orgaic food compaies are owed by the largest o-orgaic paret compaies. Major producers of buildig materials, electroics, plastics, textiles ad paper products should lauch flame-retardat-free lies of their ow brads. The buildig sector is movig rapidly to develop product lies that cotai less-persistet ad less-toxic chemicals. The pait idustry carries both low-voc emittig paits ad traditioal solvet-based paits. Corporatios should adopt the priciples of Gree Chemistry to drive choices about chemical acceptability ad substitutio. It is especially importat to avoid replacig oe hazardous chemical with aother that is poorly tested. Corporatios, where appropriate, should be resposible for product disposal. Corporatios should adopt stadards of resposibility for proper disposal of products cotaiig flame-retardats oce they reach the ed of their useful life-cycle. This may mea workig collaboratively with other firms i a product sector to establish recyclig ceters, or requestig that some especially hazardous products be retured directly to a store. For example, HP pays for the retur of priter cartridges to dispose of ay remaiig iks ad recycle plastic materials. 93