Fire Retardant Technologies: safe products with ... - Oakdene Hollins

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The context for the recommendations is the existing Ecolabel scheme criteria within theframework for FR technology environmental performance assessment presented in Annex 4.In brief, a comparison of various Ecolabel schemes in Europe provides criteria for theenvironmental assessment of products containing FRs – these generally contain:A risk phrase approach to chemical safety – this is based on the precautionaryprinciple applied to risk phrases drawn from current chemical hazard basedclassification in Europe, not formal European risk assessment findings.The use of exclusions and exemptions – sometimes of whole classes of compounds,such as organohalogens, often combined with specific exemptions of particularcompounds.In some cases, the exclusion of “additive” FRs and the retention of “reactive” FRs formattresses and textiles.It is noted that no attempt was made in this work to consider environmental performance interms of life cycle environmental impact assessment with a consideration of for exampleenergy and water use, waste production and environmental emissions across the whole lifecycle from component manufacture to end of product life. Formal life cycle assessment(LCA) is possible but is beyond the scope of the current project.The context for the recommendations made here is the existing Ecolabel scheme criteriaand a framework for FR technology environmental performance assessment. A hierarchicalapproach to fire retardancy is used for this assessment which excludes LCA concerns,whose analysis across the range of chemicals and product groups studied is too complex forthis current study to incorporate.This approach is based on the premise that the avoidance of FR chemicals is to be preferredthrough either the use of alternative intrinsically fire retardant materials or through productdesign to achieve the fire retardancy required. This is consistent with the use of greenchemistry principles and the precautionary principle applied to an assessment of potentialhuman and environmental exposure hazards associated with FR chemicals. The mostgeneral approach would therefore seek to minimise human exposure and environmentalimpact.The FR technology hierarchy adopted is assumed in each case to achieve the requiredproduct fire retardancy in order to at least maintain, and potentially to improve fire safetystandards; in order of priority the hierarchy is:o Use of inherently fire retardant materialso Design of productso Use of chemical fire retardantsP a g e 27 |
5 Limitations of the StudyThe study was limited by the extent of the FR Technology Survey and the EcolabelsAwareness consultation. The former involved only 57 individual organisations out of 400 whowere invited. Despite this, there were representative responses across all of the productsectors and FR manufacturers with the exception of the manufacturer of particular textiletreatments in Europe. A larger statistical sample would have enabled greater crosscorrelation of the findings.The EU Ecolabel consultation only involved 12 organisations but these were spread acrossall of the products of relevance. The views recorded are therefore from a small cohort andmay be biased by the particular experience of the individuals consulted. Despite this theviews expressed aligned very well with the findings of the FR Technology survey.Significant effort was put into the collection of information on FR risk assessment and theauthors acknowledge the expert support of the Environment Agency in obtaining keyinformation sources and for their critical review of drafts of each version of the workingdocument report – there were 3 in total. Both the risk assessment study and the review ofthe legislative landscape involved the compilation of complex histories of development andwhile many of the nuances of change over time were obtained it is not certain that all of theimportant ones have been identified and communicated. It is also unlikely that not all of theproduct safety regulation across the EU has been obtained; this is particularly difficult totrace for the newer member states.In common with all chemicals, the paucity of FR risk assessment data globally and the lackof complete and in some cases consistent chemical classification data, has frustrated themore critical assessment of EU Ecolabel criteria setting in regard to alternative FRtechnologies. This however, raises doubts about the ability of Ecolabel bodies to reliably setand apply their criteria. The information flows to support REACH and CLP will assist this inthe future.P a g e 28 |
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Page 12 and 13: availability to escape into the env
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Page 20 and 21: decaBDE to the US who have entered
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Page 24 and 25: Covering fabricsBack-coatings:14. C
Page 26 and 27: cotton, which would require treatme
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Page 38 and 39: 1163-19-5214-604-932536-52-0251-087
Page 40 and 41: 85535-84-8287-476-585535-85-9287-47
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