Restricting the Use of Organohalogen Flame Retardants in Televisions and Other Electronics Could Reduce Overall Product Safety and Performance
Unsupported Claims and Policies Should Not Drive Product Decision Making
Electronics present unique fire safety risks because they have a continuously present ignition source and combustible components that can be ignited by product failures. Despite fire safety standards for products, including electrical and electronic equipment, last year in the US over 6.2 million units were recalled due to fire and shock hazards.1
Flame retardants are used by product manufacturers to meet or exceed flammability standards as part of an overall approach to product safety.2 They can offer valuable mitigation against ignition failures in electrical and electronic equipment.3
Published research illustrates that specific flame retardants used in electronic casings do not present a risk to human health or the environment. However, claims by some individuals and organizations, along with newly proposed and enacted policies, might lead you to believe otherwise.
For example, the European Commission Ecodesign Directive, which took effect on March 1, 2021, restricts the use of organohalogen flame retardants (OFRs) in the casings and stands of electronic displays. This regulatory policy is not based on any substantive scientific risk assessment and targets an entire class of chemicals, nearly none of which are subject to other regulatory restrictions.
The rationale for the EU directive was not related to chemical safety. Instead, the basis for the ban centered on the misconception that OFRs hinder recycling. Yet, plastics containing OFRs can be reclaimed by recyclers in Europe.4 A legal challenge to the directive is currently before the European Court of Justice, where a ruling is expected later this year.5
OFRs are used in electronics to provide critical fire safety protection. Misguided pressure to remove OFRs could potentially put consumers at risk. These substances are commonly found in televisions, mobile phones, and a variety of electrical appliances to help stop small ignition events from turning into larger fires — no ignition, no fire.
Rather than attacking the use of flame retardants, the focus should be on utilizing the appropriate safe chemistry — the right chemical for the right use. Electronic manufacturers should balance the need to meet consumer demand for smaller, lighter, and more powerful electronics with the need to ensure that those devices meet safety standards.
What about alternatives to OFRs? Simple substitution is not possible in many cases. Electronic enclosures can not only improve the appearance and portability of a product but can also protect from fire and shock risk. Product manufacturers need a broad array of material choices for electrical and electronic equipment that can work indoors, outdoors, and places in between.
Lately, there has been a trend in one-size-fits-all policies by federal and state policymakers to ban, restrict, or regulate entire chemical families. It is not scientifically accurate or appropriate to make broad conclusions or impose a one-size-fits all approach for all flame retardants or even subclasses of flame retardants. Not all flame retardants are the same. They are a diverse set of chemicals that vary in property and molecular structure. Chemical and toxicological properties vary widely between various flame retardants and even substances of the same family. Specifications, standards, and regulations therefore ought to address specific flame retardants and specific applications.
Reviews and regulations should take into account the significant differences among the many compounds that are part of a chemical family. Rather than using a one-size-fits-all approach, we need a fact-based discussion about the nature of these substances, how they differ from each other and what they do affect — and what they don’t — in terms of human health and the environment.
Product safety should be a shared objective of all stakeholders. Listening to the science is the way to help ensure that chemicals and the products that they enable are safe and available.
1Knapp, G., The Analysis of the Transition from Smoldering to Flaming in Polyurethane Containing Assemblies Representative of Upholstered Furniture, 2019. https://drum.lib.umd.edu/bitstream/handle/1903/25190/Knapp_umd_0117N_20336.pdf
2Blais, M.S., Carpenter, K. & Fernandez, K. Comparative Room Burn Study of Furnished Rooms from the United Kingdom, France and the United States. Fire Technol 56, 489–514 (2020). https://doi.org/10.1007/s10694-019-00888-8
3Blais, M., Carpenter, K. Combustion Characteristics of Flat Panel Televisions with and Without Fire Retardants in the Casing. Fire Technol 51, 19–40 (2015). https://doi.org/10.1007/s10694-014-0420-7
4Sofies, “Study on the Impacts of Brominated Flame Retardants on the Recycling of WEEE plastics in Europe,” https://www.bsef.com/wp-content/uploads/2020/11/Study-on-the-impact-of-Brominated-Flame-Retardants-BFRs-on-WEEE-plastics-recycling-by-Sofies-Nov-2020.pdf.
5BSEF v. European Commission (Case T-113/20)
NAFRA Comments on New York Legislation Restricting Flame Retardants in Electronic Displays
Removing This Critical Layer of Fire Safety Could Negatively Impact New York Residents and Businesses