09 Apr REVIEW OF 2 ARTICLES
We have received 2 articles/briefings/introductions/prerambles recently and had thought we should write something of an assessment for each to give some insight into just exactly what they are about.
Closer examination though reveals such a great similarity between the 2 that it was decided that one response would do for both: “Two birds with one stone as it were…”
The 2 items are the Breast Cancer UK briefing
BCUK Background briefing – Flame retardants (BCUK)
The Parliamentary Environmental Audit Committee inquiry into chemicals in Consumer Products (EACOM) introduction to the Inquiry.
Both items suffer from identical defects: In their haste to scatter condemnation of toxic substances they fail
- a) to identify what is actually toxic and
- b) confuse legacy (or what happened in the past) with what we will buy in the future
- c) the difference between using a substance in the manufacture of an article and its presence as a micro pollutant in raw materials or products supplied.
It may surprise some to know that there are concerns in the chemical-using industry and a desire to make sure what we do is not only technically advanced (from past situations) but also as safe and suited to the end use and end user as we can make it.
We can only hope that what follows can be seen in a constructive light.
Both documents set out to offer a list of Consumer Articles where Toxic chemicals and/or Flame Retardants may be found. Both are quite precise about Upholstery Textiles and Foam. They do include (and this is not an original mistake) articles that have no recognised level of fire safety in their use that requires a fire retardant performance ergo no flame retardants will be used. This is allied with articles where it has been recognised that e.g. levels of certain substances may be found at low levels. Manufacturers are used to ensuring the purity of raw materials or that final products meet strict limits of certain substances such as Heavy Metals. Manufacturers are well organised to spend a lot of time and money meeting the concerns for Consumer Safety imposed by e.g. Retailers as described in their own Specifications to be met. These include levels of substances where admitted tolerance levels are at the boundary of detectability = effectively Nil/None/Nothing.
The “Legacy” aspect of the description of flame retardants is a bit confused or confusing? PBDE’s are listed but that would include DecaBDE that has been used until it became an SVHC but would include Penta- and Octa-BDE that have not been used in UK Consumer Articles as far as we know. Whatever toxicity you may apply to PentaBDE and OctaBDE and however much you may discuss the amount that “may” have been found in commercial DecaBDE, any presence did not render DecaBDE as being TOXIC i.e. having levels of toxicity agreed by definition that would require DecaBDE to be labelled as TOXIC by any of the 3 ways it may be taken into the human body.
DecaBDE did demonstrate persistence in the Environment and was abandoned by its REACH-led Sunset date. Until that date it was properly used but many in Industry had already made the decision some years before and stopped its use – leading the regulatory requirement but avoiding any issue of Sunset date or Authorisation.
Why is HBCDD relevant then when we consider the future of Consumer Articles or are we only looking at legacy. Are we describing what we bought or what we will make tomorrow? Both documents offer very confusing opinion from that viewpoint.
Without considering so-called “novel” FRs, all of the substances listed except DecaBDE and HBCDD have one overriding physical characteristic. They are mainly OILS.
Does it matter? Well yes, definitely it does.
Coatings for the FFR textiles that are in focus here have certain common characteristics. The Textiles will be in a weight area of 250 – 550 gsm (grammes per square metre). The coatings applied will be in the area (and this is fact rather than ill-informed comment) of 80-125 gsm. That is dry weight of coating after a wet compound has been applied and dried/cured onto the textile so that it is stable, non-dusting and firmly attached.
The fabric must be as flexible as possible, not only for Consumer desirability, but also to allow it to be fitted over a frame during upholstery manufacture. It must not be too much as that is cost and unnecessary chemical usage. If it is stiff it will be difficult to make into upholstery and workers will complain. Oily chemicals that also have FR properties can be useful here but only in small and limited amounts as too much makes the coating sticky (or plasticises the coating).
There is another issue. Due to the dry/cure temperatures employed in textile processing such “semi-volatile characteristics” will result in migration to the textile surface and it is well understood that the presence of oleophilic substances on the surface will seriously affect the soiling behaviour of such textiles. That is another tested characteristic of Textiles in these end uses scenarios.
CHEMICAL SELECTION PROCESS.
Ally this to any Risk phrases attached to the substances and to be declared in the MSDS you can easily describe a strong and definite requirement that such substances are not suitable for the end use. In other words, DO NOT USE.
It could be that such chemicals were used and as data became available establishing a different basis for evaluation the use changed. HBCDD as we have seen was phased out when its SVHC status arrived and had stopped from being used for textiles by its Sunset Date. DecaBDE suffered a similar fate. That was
some years ago and they have not been used since.
But why do they both include PCBs?
Here we are talking of a 20thcentury chemical in 21stcentury chemistry and we have moved on somewhat since the disaster that was PCBs happened. The process to ban them started in the 1980’s, well before the FFR. So why are they included in a modern day assessment of chemical risk and consumer articles that includes Textiles and Flexible foam? They are often analysed for in consumer articles but the detection limits are set very low and the permitted levels set below that – in other words by most analytical methods they should not be there. It certainly falls into an area where LEGACY could be applied but they are not used by Industry. From an extensive experience in textiles, they have never been used as Textile Finishes.
Or are they simply there to just show how bad chemistry can be?
Out of the other oils we may see that some (PCBs) were never suitable for use as the presence of Dioxins rendered them highly toxic. The other oils have been through the years subject to increasing scrutiny and Industry responds and much more quickly than the Regulators. Are they used to treat Textiles today? NO. Will they be used in the future? NO.
Will it serve any useful purpose in the case of BC UK to say we do not use any of the substances they list in our treatment of textiles for the FFR?
In the UK only DecaBDE was widely used and this again highlights an aspect of the Legacy concept. It is possible that in the very early years lower quality grades of DecaBDE were used but this was in the start of the Risk Assessment Process (early 1980’s) and it was quickly realised that a new standard for DecaBDE was necessary and that was established as the product used in the UK. From there it can be said with some confidence that none of the lower congeners were (commonly) used. DecaBDE use stopped within one year of it being sent for consideration by the UK Competent Authority as an SVHC.
At the time the SVHC listing was confirmed in the MSDS for DecaBDE there remained a total lack of any recorded TOXICITY data that could be used to consider avoiding its use. HBCDD had a similar toxicity profile.
Perhaps we need a new definition of TOXICITY? Using the scientifically agreed methods upon which REACH is based any evidence of Toxicity is clearly shown and including the CLP iconography relevant. The selection of which chemicals to use is a very careful process and heavily influenced through all aspects of using chemicals in Consumer articles due to the very clear requirements of major Customers such as the major Retailers.
Industry can only use the data we are supplied through a process that is now governed by REACH. The transfer of data is rapid and efficient and those involved in the supply chain respond quickly.
ENDOCRINE DISRUPTORS ETC?
It is also important to recognise that the REACH system only informs us of scientifically tested data and Industry responds to that. What is missing is the scientific recognition of many of the claims made in both items. We would not dismiss such concerns and they have a recognised relevance but the scientific proof falls far short of tested and proven data and often has little more scientific proof in the circumstances than e.g. the PLACEBO EFFECT.
Discovery of presence by Modern Analytic techniques does raise concern that has not so far been supported but levels of discovery fall into the HOMEOPATHY area of dilution. In one case the low level toxins are considered for their beneficial effects and in the other for their toxicity even though they are far from the levels of effect considered in human toxicity assessment.
SOMETHING ABOVE REACH?
The question must be asked by those who carefully follow all the evidence presented through careful evaluation and strong dissemination of data if both items are looking for something better or at least knowing more than REACH.
Is it good enough to just say we are only following what REACH tells us?
Are we being challenged with ideas that go beyond REACH?
Is this simply a case of ‘those for whom REACH is just not good enough’?
The 2 items have a strong degree of commonality that is disturbing and whilst some may question why a Political Inquiry is looking into an already strongly regulated area we can also see that a charity is apparently entering a political debate on the basis of the risk of being a cause of cancer.
Much of the “chatter” of the evidence set out is ill-informed and seemingly willfully so. The range of chemical substances referenced and the Consumer Articles highlighted do not match up very well with the reality of manufacture and it gives the impression of trying to overwhelm what may well prove to be reasonable concerns with a surfeit of concerns – or scares we may call them.
However, whatever the concerns, it is regrettable that Industry can be displayed as a whipping boy with little defence than we are following the system set out for us.
The intention to add things that REACH will not tell us looks like an attempt to create a chemophobic atmosphere that betrays any reasonable concerns.