17 Nov FRETWORK letter to ECHA
This is the text of a letter sent to ECHA this weekend:
EUROPEAN CHEMICALS AGENCY
Saturday, 16 November 2019
Attention of Mr Bjorn Hansen, Executive Director
Dear Mr Hansen,
Ref: Web site Guest Corner article “Furniture without toxic flame retardants: ensuring safety for all” Gabriella Kemendi, Secretary General, EFIC.
The Group of Companies represented by FRETWORK carry the responsibility in the UK upholstery manufacturing supply chain for daily decisions made in dealing with the textile cover fabrics, any treatments made, subsequent testing and ensuring legal compliance with the UK Furniture Fire Safety Regulations (FFR). We use flame retardants. We are well equipped to deal with this sort of article and that includes all aspects, when we believe it deserves a response.
The article referred to above is published on your web site. The content and intent of the article are quite familiar – we could say we have read it all before in various places and under various authorship. It addresses Consumer Safety both as a Fire Safety and Chemical Safety issues. Our Group recognises the role that ECHA plays in chemical safety but we believe we may hold superior experience and knowledge to ECHA where the other issues are concerned.
The way chemical safety is addressed in this article is a matter of grave concern and our concern is based upon its appearance on the ECHA web site.
It would seem to us that there are members of your staff that do not understand the principles and objectives of ECHA (or at least, as we understand them).
The article singularly fails to match the objectives of ECHA and no amount of written disclaimers can excuse its lack of objectivity. In (its) simple terms there are no flame retardants – only ‘TOXIC Flame Retardants’.
ECHA deals with toxicity through data. The rhetoric in the article should not find a platform on the ECHA web site.
ECHA has a role of which we are not only aware but use in our daily work activity. The Substances we use are assessed using the data provided under the oversight of ECHA. As a Group we are working to establish Codes of Practice that reflect not only the concerns expressed (even) in this article but also the methods and practices of ECHA.
We are well aware that it is difficult for ECHA to describe the safe use of chemicals – being directed solely towards describing the risks when using chemicals.
We follow your methods and systems and require our members to refer to the data you provide in making assessment of the substances chosen to be applied. () We are in the process of developing audit schemes that will allow responsible officials to audit the management of substances and in particular hazardous substances under REACH. We have tried to set out the importance of a proper understanding in articles published in the UK by Cabinet Maker Journal (). (copies accompany this letter.).
We would also make very clear that the recent action:
is already well within the compass of our planned auditing systems.
We believe that the objectives and presentational style of the article are easily described as a denial of ECHA and its objectives. ECHA deals in terms of toxicity as a measurable factor. The article deliberately chooses to deny this and that leads to the question: ‘WHY was it published by ECHA?’
The same point arises when we consider substitution. ECHA have issued opinion that decisions by users should not be based on the process, instead we must wait for the outcome. The terms “unfortunate substitution” or “regrettable substitution” have always seemed to preempt the ECHA processes or declare a superior knowledge. This surely contradicts the way ECHA works.
Part of our role in the Supply Chain is to respond to the requirements of our Customers. When they issue instructions e.g. that SVHC substances should not be used we must immediately ensure that they are not used. In fact we spend a great deal of time giving written assurance of ‘non use’. Our audit system is intended to help us produce transparency in what we do in this matter.
The question is not therefore why has ECHA published this article but why are we bothering to seek an audited application of the ECHA principles as a reassurance to the Consumer?
We as a Group can recognise the concerns of Consumers, we are very much involved in a real World of commercial manufacture of consumer articles that are likely to be found in every home in the UK and Ireland.
We are striving to demonstrate assurance and refer to ECHA always.
The publication of this article by ECHA surely undermines your role of seeking to protect the Consumer. That in turn undermines our efforts.
We are therefore forced to question ECHA’s position in these matters.
A firm commitment to your core principles that are easily described as contradictory to the ideas promoted in this article would seem necessary.
Director, FRETWORK – The Flame Retardant Textiles Network Ltd.
Attached: transcripts of articles published on the Cabinet Maker web site.