08 Aug EACOM REPORT – SOME THOUGHTS……
The EACOM report titled “Toxic Chemicals in Everyday Life” has been published.
FRETWORK has taken its usual approach to the report and “asked STUART” or in other words subjected it to a (more) critical evaluation. Our objective remains to be (somewhat) provocative and to stimulate a questioning approach).
FRETWORK has directly submitted some thoughts and opinion and various members of our Group have also taken part. Many have been intrigued by the spectacle of this aspect of the Parliamentary process. We were invited to give evidence but that was subsequently withdrawn.
The Group of Companies represented by FRETWORK are those who carry the responsibility in the UK upholstery manufacturing supply chain where daily decisions are made in dealing with the textile cover fabrics, any treatments made, subsequent testing and ensuring legal compliance with the FFR. They are the only sector that holds the competence over all these aspects of manufacture.
DOES THE REPORT ACHIEVE ITS OBJECTIVES?
The report could impress by covering (well) all the relevant areas but a pervasive feeling exists that many of the points selected are limited so that they do not impinge on the main objectives of the report. The report looks pretty much the same as the views outlined in the opening statement published before the public evidence sessions began.
In an 85 page document the first three words of the Summary and the text read: “Chemicals are pervasive……”
With this beginning we may immediately see the tone adopted throughout the document. Whilst this may not be surprising to many who will read the report, it does set out clearly its approach to the subject. Not for EACOM would the simple “present” do, rather the damnation of “pervasive”.
PRESENCE VERSUS DISCOVERY.
The relevance of “present” is the key to what may be termed “discovery”. Everyone, without exception, should be alarmed at the discovery of substances or chemicals where they should not be found whether that is household dust or human placenta. The problem is that with modern analytical techniques we can “discover” a lot more chemicals where we have every right to expect that they should not be found. The Inquiry did not exactly address this question and here we come to a very fine point of the debate: “What was found?”.
Every time we get the full picture, we find that lots of chemicals are found where they shouldn’t be found – not just biocides or flame retardants or fluorocarbons or surfactants. Was the Inquiry being selective in targeting flame retardants?
Throughout the document there seems to be a failure to recognise that chemicals have an important role to play in the Modern World and that they are indeed “present” and nowhere do they ask the question: “Is safe use of chemicals possible at all?”. There are problems associated with our use of chemicals but we should ask if this report truly identifies those and then offers a way forwards?
OR: Is this just a case of set out your objective and write the report to achieve that – whatever is said during the inquiry?
TOXICITY AND DOSE.
The question of “present” is actually very important and the question “what is safe?” may be found running through the document. Chemicals are “toxic”. Of course, toxicity is dependent on dose and whilst, again, this is defined quite clearly, the report generally seems always prepared to use the adjective “toxic” without defining the dose and this was also seen and heard during the televised proceedings in spite of learned evidence on the subject.
When making or using chemicals, Industry is highly regulated. The members of the FRETWORK Group are very aware of their responsibilities in this matter. They have 2 very intrinsic regulatory frameworks to be used on a daily basis:
- The FFR
- The Use of Chemicals.
The Inquiry is therefore very important to both them and their businesses.
REACH OR ‘OUT OF REACH?’
Chemicals are regulated in the EU by REACH – and we will be regulated by BREACH if and/or when BREXIT takes place. REACH provides a system requiring data to be made public and it covers all aspects of substances as chemicals are called in REACH. If you want to check for yourself then with a little bit of basic information you can find all there is written about (most) substances on the ECHA web site.
Unfortunately REACH will not tell us what is “safe” but it does guide us through a set of data which includes Exposure Scenarios. This SHOULD allow us to be able to assess if there are particular risks to the supply chain and the end user (better known as the Consumer).
In fact this was one of the guiding principles of REACH: what is used and where and does that use bring Risk? This again seemed to be of no interest or not within the objectives of the report so seems to be ignored.
ARE WE TAKING A RISK?
The consequences of this are compounded by returning to the question of “dose”.
Discovery is often about levels that bear no relationship to the data concerning the use of chemicals as described by REACH. The problem is that the data supplied by REACH does not inform its users of the sort of Risks identified by the Report. Do they have a higher level of knowledge to allow them to do this? In spite of concerns by Inquiry panel members, does anyone actually know the acute oral toxicity of DecaBDE?
DOES ALL THIS HAPPEN WITHOUT ANYONE CARING?
There is a further level of control applied to the supply chain. Downstream Users, such as the big Retail Chains set their own requirements for what they will accept and these effectively dictate much of what we do. We actually spend a lot of time and resource providing reassurance to such organisations through their own systems or third party systems they have adopted.
Were there areas that the Inquiry did not cover or gave less attention than deserved?
DO WE LOOK GREEN IN THIS?
When inquiring into the presence of chemicals in consumer articles there are issues relating to the production of both cotton and wool where there can be extensive use of pesticides and herbicides and there is an important question of supply in volume and quality when organic or green products are mentioned.
STUART, having been through the problems with LPCP (a biocide used as both pesticide and herbicide) in the second half of the last century, knows a bit about this and more needs to be said about where these problems reside in the World as UK processing of textiles has declined – “has the problem gone away or just been shifted elsewhere?”.
This should also have been covered in more depth as part of the burning behaviour achieved without resorting to the use of chemical flame retardant treatments – or are we only concerned about certain “toxic chemicals” over others?
PUT TO THE TEST?
It would have been good to have an informed opinion of the merits of the Cigarette (smoulder) and Match (open flame ) tests as used for the FFR. We are aware that one recent FFR Review proposed the dropping of the cigarette test and we now hear siren calls to drop the match test.
Apart from the textile testing issues, this approach lacks any dimension of consideration for textile fibre types and in particular in the way certain materials are represented.
There are materials on the market that do meet the requirements of the FFR without the use of flame retardants in the bedding market but extreme care must be shown when discussing such products in the context of the FFR.
For those who do not understand this point we can say the way the testing is made is all important and understanding the differences between the FFR for upholstery and the Regulations as applied to mattresses is very important. A good understanding of testing is needed in these considerations.
2 Points follow from this:
1 Mattresses do not have the same design and style demands that are necessary for the upholstery market, nor do they use such a wide range of different materials in their manufacture.
2 Presuming that because a combination of filling and cover material is OK for mattresses does not mean they will meet the requirements of the FFR.
This aspect reflects also on what may be seen as a certain lack of expertise in some of the opinions offered during the evidence sessions.
STUART wonders what forensic analysis of such articles would “discover”?
SUBJECT TO REVIEW.
The Inquiry should also have been much more wide ranging on the subject of Review of the FFR. They asked about Review after the second decade of the FFR but said nothing about the first 2 decades.
The original concept of the FFR was to address the ignition risk found in large items of foam filled furniture (sofas and etc) in every home in the Land.
It is an important issue that many other items were included and these went from the mundane, bed headboards and dining chairs, to eventually include more critical items such as children’s articles including pushchairs and baby nests. Their inclusion was not based upon clear evidence of risk but a similarity in the materials used. Was this a wise thing to do? The inquiry had little apparent interest as to how they became part of the FFR. This would seem to be the area where the components and how they could be used became more important than actually addressing an identified ignition risk. There is a point where we should be inquiring into how this happened, why wasn’t it reviewed?
DOES THE REPORT ACHIEVE ITS OBJECTIVES?
It is clear that there are a wide range of complex issues involved in the upholstery supply chain and we must hope that Inquiry’s use of their power to put pressure on the regulators will not lead to hasty or ill-considered attempts at reform. Of course, by the time you read this it may already be too late…………
Concentrating on certain aspects and not focussing nearly enough on what is done already by REACH will not achieve a positive outcome. In discussion with Regulators responsible for chemicals there is a feeling that they feel we are making progress and that seems to be missing in the report.