08 Nov STUART and some thoughts on labelling
This article has been published on
the Cabinet Maker web site:
LABELLING OF UPHOLSTERY
Over the last 12 months, and more, we have heard a lot about the issue of changing the fixed labels on upholstery (as required by the FFR) to include more information to help the Consumer. Much has been said and some things have been written about adding the name of the flame retardant used but in the main it is as yet all rather vague and we must expect something to emerge from the next stage of consultation on the future of the FFR. We have also of course had the Select Committee inquiry into Toxic Chemicals in Consumer articles (aka the EACOM report) and that, of course, provided a great insight into the problems.
In the meantime we thought it might be helpful if STUART had a look at this topic and gave it the benefit of his insight.
STUART’s first reaction is that perhaps it’s all a bit BONKERS – that’s a technical term used to describe what, from the outside, looks like a distinct lack of understanding, a lack of definition in what is intended and a failure to understand the problems.
STUART has also a very strong distrust of a process that starts out without any apparent understanding of the existing systems in place or an opinion of exactly where they are deficient or inefficient.
STUART also has a problem when the sort ideas we see and hear all seem to confuse or be confused by 4 particular factors:
CHOICE OF CHEMICALS
SVHC and other restriction processes
There exists a good understanding of exactly what can be used and that is most obvious in the sector of the supply Chain represented by the members of the FRETWORK Group. They spend a lot of time developing written evidence that some substances are NOT WANTED according to End customer requirements or particular schemes that they are following. Choice is dictated by what is likely to be acceptable as much as understanding what will not.
The REACH process – for it is a process and not a fixed state – will lead to assessments being made, through well founded scientific processes, and it may well be that certain substances will be “upgraded” to higher levels of concern requiring control and eventually become substances of very high concern or SVHC. This is seen by the process as a demand to RESTRICT use. Industry and commerce, on the other hand, take those concerns as an indication that the substance should not be used. It’s not normally a case of choice but of diktat or NOT WANTED.
But….what if we use something and it becomes an SVHC later on? Our part of the supply chain can adapt and changes can be made quickly. We are not so sure about the rest of the supply chain.
It also begs the question: are we labelling for something that may change or based upon present knowledge. That is a very complicated scenario and members of our FRETWORK Group will always be ready and fully able to discuss such issues.
RISK is important because we may choose which chemicals we use based upon what we are allowed to use as much could also present a risk to us. If we are going to have problems then the decision to AVOID is made. This is part of our FRETWORK Code of Good Practice (FCOGP) and we shall be pleased to explain that too.
The Fire Safety RISK for upholstery was identified in the last decades of the 20th Century and evidence suggest the situation has not changed a great deal. The Risk is of course greater because everyone has the right to sit on a comfy seat while they watch TV in their own home. It’s the fact that we all have these articles in our homes makes them so important.
TOXICITY is a very strange subject. If you discuss this with toxicologists then you will be sure they would also say the same. But if we take a very common substance (that is no longer used) like DecaBDE it bothers STUART that it is so readily called TOXIC. If it was so toxic its use would have been stopped a long time ago but even MPs are happy to label it as toxic. It does matter because the problem is that due to its very extreme inert nature (which makes it difficult to be toxic) it will persist in the environment – IF it is allowed to be used without understanding the need to control its use and application to prevent it becoming widely dispersed in the environment it will be a problem. Substances used that are in debate have very clearly defined acute aquatic toxicity and they must be prevented from getting into water streams and that includes the sewer system – don’t throw it down the drain in other words.
REACH requires substance use and application and the articles it may be found in to be assessed to ensure Consumer Safety. Restriction is the next stage when use is only allowed under specific conditions. The FCOGP requires these processes to be understood and followed.
Will the labelling require established RISK data such as Toxicity to be used to determine what is on the label?
The EACOM report did not seem to be particularly engaged in looking at the way industry works at present but did seem to think that “Big Business” needed to be brought to account for imposing the use of “nasty” chemicals on the Consumer.
STUART believes that a better understanding of what happens in industry now should be the starting point for what appears on the label. Meanwhile industry is resigned to their fate in this matter and will as usual make the best of what they are given.
STUART is, of course, a fictional character based on the acronym Science, Technology,Understanding And Reasoned Thinking. Members of the FRETWORK Group will be happy to discuss this and any other topics with you.