Fire safety and environmental risk: what next?

April 29, 2014 at 10:39 am | Posted in Feature Articles | 2 Comments
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Sources of ignition risk in televisions and how they have changed between previous- and next-generation technologies. Click to enlarge.

The use of flame retardants in consumer goods is a very good example of how difficult it can be to ensure that as few people as possible are harmed by a given risk (in this case, house fires), while also being sure that as few people as possible are harmed by the steps being taken to reduce that risk (which here would be the use of flame retardant chemicals to meet fire safety standards).

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Two contemporary examples which illustrate the challenges in fire safety risk/benefit trade-offs are the ignition requirements in international safety standards for televisions and other consumer audio-visual equipment, and a forthcoming UK consultation about changing ignition test methods in safety regulations for furnishings.

Ignition tests are an environmental health issue because meeting them often requires the addition of flame retardants to products. This has particularly become the case since the widespread adoption of polyurethane foams in furniture cushions and use of plastics for TV enclosures; plastics burn readily and are a major fuel source in fires, greatly increasing fire risk, and consequently the number of UK house fires has increased rapidly since the introduction of polyurethane foams in the 1970s.

The problem with flame retardants is they do not have a particularly good history when it comes to environmental health performance. They are added to consumer goods in large quantities (up to as much as 15-20% by weight) and tend to persist in the environment; if they are toxic or bioaccumulative, as many flame retardants have been found to be, they then present a substantial environmental health risk.

This came to a head in the revision of international safety standards for consumer audio-visual goods, where it was proposed that in order to be considered safe enough for use, TV housings should resist ignition from an open candle flame. In response, some stakeholders argued that the use of flame retardants to meet such a standard would present an environmental health risk outweighing the fire safety benefits yielded by conformity with the standard.

The risk/benefit issue, of whether the benefits to health of fire prevention was outweighed by the risks to health posed by the likely use of flame retardants in order to secure them, received a great deal of consideration in the various national committees responsible for developing and agreeing on the proposed standard. Eventually, however, these particular discussions ended in stalemate.

Why? To cut a long story short, it is because standardisation works on a consensus process: only very black-and-white issues secure the unanimity necessary for a proposal to go forward. In this case, because flame retardants were too loosely-defined a class of compounds to allow generalisations about their environmental health risks to be made, and because this uncertain generalisation was weighed against uncertain data about fire risks, there was no data which overall was conclusive enough to force consensus on the committees.

The concerns about the environmental safety of flame retardants persisted. In the face of a lack of compelling data about risks and benefits of flame retardant use, some standards committees shifted attention to whether or not the ignition standard as proposed could be reasonably expected to prevent fires. Here, a number of committees concluded that external ignition was unlikely to be anything more than a relatively minor fire risk. In the UK, internal component failure seemed to be overwhelmingly the most likely cause of a TV fire (DTI 2001), with the number of fires caused by external ignition being comparatively negligible. Designing TVs so they resist an external flame therefore seemed unnecessary; any environmental risks incurred by so doing would necessarily outweigh such non-existent gains.

There is an argument that the addition of flame retardants presents a de facto improvement in fire safety. However, given that the flame retardants are being added on the basis of a test which does not measure increased protection from internal ignition, such a safety benefit can only be conjectural. In order to be sure that a standard is doing its job, the provisions of the standard should be aimed directly at performance and not included in the hope that they have sufficient benefit; the solution is to drop the current ignition test and develop a new one which is fit for purpose.

It is this issue of fitness-for-purpose of safety tests which is fundamental to our second illustrative example, where the UK Government’s Department for Business, Innovation and Skills (BIS) has opened a consultation on their proposals to amend ignition requirements for furnishings (FIRA 2014). Historically these have been much more stringent than for mainland Europe and, according to BIS, are preventing about 1000 fires per year, but also resulting in higher use of flame retardants.

Speaking in April at a workshop at the FRT14 fire retardant technologies conference (UCLAN 2014) Terry Edge, who is leading development of the proposals, explained that potential damage to the environment (whether perceived or real) resulting from use of flame retardants is behind the new proposals, which he says will reduce flame retardant use by 30-50%.

Other benefits cited by BIS are cost savings of the changes (up to £50 million per year for business) and anticipation of the introduction in Europe of WEEE-style regulations for furniture. As for electronics, it is expected that furniture manufacturers will be expected to take responsibility for end-of-life disposal of furniture. The UK currently has a small mountain of waste furniture which, containing as it does high levels of flame retardants, presents a substantial disposal problem.

What is common to both the TV and furniture case is that there is no intention to relax the fire safety standard in order to reduce environmental impact of meeting the standard. For TVs, the ignition standard is being dropped because it makes no difference to fire safety; for the BIS proposals, the standard is changed because it is believed there is an alternative way of administering a robust fire safety test which incurs less use of flame retardants.

The common theme is that while both examples are the product of environmental concerns, neither measure to reduce environmental harm squarely addresses the environmental concerns associated with fire safety; environmental gains are a halo benefit rather than the objective of the changes in question. As such it is difficult to see how from an environmental perspective either offers a long-term solution. This would become particularly clear if ignition proposals were developed which indisputably and substantially improved fire safety, and brought with them the potential for increased use of flame retardants. What should happen then?

This is where the strategy of securing the prevention of environmental harm from fire safety standards by opposing bad tests bump ups against its limits: if a good test arrives, it is only regulation which determines the environmental health performance of the technological solutions employed for passing the test.

The problem with regulation is that it only sets a minimum legal standard for performance. Although this prevents bad actor chemicals from being used, not all chemicals on the market present negligible environmental risk, and regulation does nothing to encourage the use of the most environmentally benign technological solution to a problem.

It is difficult to pinpoint at this stage exactly what should be done to set limits on the environmental impact of strategies for meeting fire safety standards, except to say that there are several boxes which need to be ticked by a proposed solution and at the moment not all are being ticked. We know that smoke toxicity is a major hazard in domestic fires and that a number of fire retardant technologies increase smoke toxicity, yet there are as yet no measures to address this.

Adding environmental impact to the concerns which need to be explicitly addressed may not be easy or a particularly welcome complication, but there is no principle as to why this should not be done. The standards process would seem to be one forum in which this could be addressed, concerned as it is with product performance. Furthermore, there are moves within the standards community to explicitly address environmental aspects of the standardisation process (DG Enterprise 2013); measures for doing this directly would bear more scrutiny.

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  1. Fire retardants , use for furniture must be a consequential response to smokers behaviour in falling asleep in their chairs or beds. , lighted cigarette in hand.

    is it justifiable that all of us must bear environmental insult , for such a weak reason. Surely the smoker is the person to consider the risks of smoking and dozing off while doing so and must bear the consequence.

    • I think part of the problem is the consequences don’t just affect the smoker but their family and (if they live in a block of flats, for example) the safety of those around them. I think we can assume that preventing fires from cigarettes is very important, which makes the question of how we can ensure efficacy of measures while minimising their environmental consequences essential, I think.


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