Revision of furniture flammability regulations
Richard Hull, RSC representative on the BSI FW/6 technical committee on flammability performance and fire tests for furniture
Professor of Chemistry and Fire Science, University of Central Lancashire
trhull@uclan.ac.uk
ECG Bulletin January 2023
Professor of Chemistry and Fire Science, University of Central Lancashire
trhull@uclan.ac.uk
ECG Bulletin January 2023
Although the government’s Office for Product Safety and Standards (OPSS) have not circulated their consultation on the review of the 1988 Furniture Flammability Regulations (FFRs), FW/6 has been meeting to discuss the development of new standards to demonstrate compliance with the revised regulations. The deliberations of standards committees are deemed confidential, and therefore this report outlines my thoughts on the current state of FFRs revision, an issue affecting the lives and health of UK residents.
The main task of this committee is to draft a new British Standard to support businesses to comply with the revised furniture flammability regulations (FFRs) - changes to the FFRs themselves are the remit of the government and OPSS. The proposed format of these revised regulations are generalised, outcome and performance-based Essential Safety Requirements (ESRs). A public consultation on the proposed ESRs is expected in 2023. BSI’s standard will then define these performance requirements of new furniture in terms of flammability.
The composition of the committee includes a wide range of stakeholders, which has progressively changed to include those who are concerned about the unnecessary use of flame retardants, and their potential harm to people and the environment. Recently, I’ve perceived a shift in opinion away from the current, very stringent regulations. It appears that the manufacturers represented are mostly concerned with their obligations under the circular economy, because flame retardant additives add cost, and prevent effective recycling, whilst the test laboratories are dependent on income from furniture flammability testing. It remains to be seen whether the UK will modify its FFRs to align with less stringent Irish and European regulations.
The composition of the committee includes a wide range of stakeholders, which has progressively changed to include those who are concerned about the unnecessary use of flame retardants, and their potential harm to people and the environment. Recently, I’ve perceived a shift in opinion away from the current, very stringent regulations. It appears that the manufacturers represented are mostly concerned with their obligations under the circular economy, because flame retardant additives add cost, and prevent effective recycling, whilst the test laboratories are dependent on income from furniture flammability testing. It remains to be seen whether the UK will modify its FFRs to align with less stringent Irish and European regulations.
The proposed changes seem likely to include:
1. Composite testing. Instead of testing fabric and filling separately, whole items of furniture are expected to meet the new ESRs. It seems likely that mock-ups made from the same materials will actually be tested for
flammability. This should mean that fabric and filling manufacturers will minimise their flame retardant usage for each filling-fabric combination. However, they also want to minimise their product range while maximising market share, so if 20% of the market for a particular product requires flame retardant treatment, it may be cheaper to add a flame retardant to all of that product than to manufacture a separate one for the 20% who actually need it.
2. Foam component testing. Another ESR requires separate tests for foam fillings. If the new test is less severe than the current regulations require, it could allow a large reduction in flame retardant usage. Currently tris(chloropropyl) phosphate (TCPP) is the most widely used flame retardant in flexible polyurethane foams, although it is often used alongside melamine. Both TCPP and melamine are under investigation for potential toxicity by the European Chemical’s Agency (ECHA). In mainland Europe, flexible polyurethane foam from used domestic furniture does not contain flame retardants, and is routinely recycled, yielding polyols (and potentially also isocyanates) for re-manufacture. In the UK, the presence flame retardants in foam prevents recycling.
3. Reduction in flame retardant use. The revised regulations also aim to bring about a reduction in reliance on chemical flame retardant (CFR) use to meet flammability standards. Current CFRs could be found to jeopardise the safety of the user or a third party. However, OPSS have said in discussion that until restricted under UK REACH, they can be legally used.
4. Technical File and Labelling. In addition, the proposed ESRs specify a technical file and labelling proposals, which provide information to consumers, trading standards and waste operatives on the use of flame retardants, traceability, and a technical file for enforcement of the regulations.
5. Justification for CFR use to follow a Flame Retardant Technology Hierarchy - in preferred order from: no need for CFR use; use of inherently fire-retardant materials; use of CFRs.
It remains to be seen what is, and what is not, included in the new FFRs once the review process has been completed, and where FW/6 propose the line should be drawn for achieving compliance in their new standard.
1. Composite testing. Instead of testing fabric and filling separately, whole items of furniture are expected to meet the new ESRs. It seems likely that mock-ups made from the same materials will actually be tested for
flammability. This should mean that fabric and filling manufacturers will minimise their flame retardant usage for each filling-fabric combination. However, they also want to minimise their product range while maximising market share, so if 20% of the market for a particular product requires flame retardant treatment, it may be cheaper to add a flame retardant to all of that product than to manufacture a separate one for the 20% who actually need it.
2. Foam component testing. Another ESR requires separate tests for foam fillings. If the new test is less severe than the current regulations require, it could allow a large reduction in flame retardant usage. Currently tris(chloropropyl) phosphate (TCPP) is the most widely used flame retardant in flexible polyurethane foams, although it is often used alongside melamine. Both TCPP and melamine are under investigation for potential toxicity by the European Chemical’s Agency (ECHA). In mainland Europe, flexible polyurethane foam from used domestic furniture does not contain flame retardants, and is routinely recycled, yielding polyols (and potentially also isocyanates) for re-manufacture. In the UK, the presence flame retardants in foam prevents recycling.
3. Reduction in flame retardant use. The revised regulations also aim to bring about a reduction in reliance on chemical flame retardant (CFR) use to meet flammability standards. Current CFRs could be found to jeopardise the safety of the user or a third party. However, OPSS have said in discussion that until restricted under UK REACH, they can be legally used.
4. Technical File and Labelling. In addition, the proposed ESRs specify a technical file and labelling proposals, which provide information to consumers, trading standards and waste operatives on the use of flame retardants, traceability, and a technical file for enforcement of the regulations.
5. Justification for CFR use to follow a Flame Retardant Technology Hierarchy - in preferred order from: no need for CFR use; use of inherently fire-retardant materials; use of CFRs.
It remains to be seen what is, and what is not, included in the new FFRs once the review process has been completed, and where FW/6 propose the line should be drawn for achieving compliance in their new standard.
