NAFRA Comments on Draft Regulatory Determinations Report Under Safer Products for Washington
WASHINGTON (January 31, 2022) – The American Chemistry Council’s (ACC) North American Flame Retardant Alliance (NAFRA) issued the following statement in response to the Draft Regulatory Determinations Report to the Legislature from the Washington State Department of Ecology (the Department) regarding its implementation of Safer Products for Washington.
“Flame retardants are used by product manufacturers to meet or exceed flammability standards as part of an overall approach to product safety. One of the most important benefits of flame retardants in product design is they can stop small ignition events from turning into larger fires.1,2,3 Therefore, flame retardants are an essential tool for overall electronics safety and performance.
“NAFRA has deep concerns with the draft proposal, and there are key issues that the Department should consider in developing regulations for a diverse set of flame retardant chemicals used in a wide range of electrical and electronic products.
“Electrical and electronic equipment with enclosures utilizing flame retardants is not a significant source of chemical exposure and should not be designated a priority product based on the Safer Products for Washington criteria. Specific flame retardants used in electronic casings are either not found in the Washington environment or any actual measured levels are extremely low and therefore unlikely to present a risk to human health or the environment. 4
"The identified product category of electronic casings is overly broad. The Department identified a long list of products (televisions, laptops, mobile phones, kitchen appliances, washing machines, irons, coffee makers, vacuum cleaners, hair dryers, and power tools) as part of its draft recommendations, which fail to consider the vastly different product design and performance factors for a wide range of products.
“It is not scientifically accurate or appropriate to make broad conclusions or impose a one-size-fits-all approach for flame retardants. Not all flame retardants are the same, and they are often uniquely designed to work with specific resin systems. Specifications, standards, and regulations therefore need to address specific flame retardants in specific product applications.
“Electrical and electronic equipment present unique fire safety risks because they have an always 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.5
“Simple substitution is not possible in many cases. Electronic device manufacturers balance consumer demand for smaller, lighter, and more powerful products with the need to ensure that those devices meet performance and safety standards. 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.
“Product safety should be a shared objective of all stakeholders. We look forward to working with Washington State to enhance its implementation of this new program to ensure that chemicals and the products that they enable are safe and available.”
For more information:
A full copy of the comments NAFRA submitted to the Department of Ecology can be found here.
1 Knapp, 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
2 Blais, 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
3 Blais, 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
4 Washington Department of Ecology, Flame Retardants in Ten Washington Lakes, 2017-2018, December 2019. https://apps.ecology.wa.gov/publications/documents/1903021.pdf
5 Based on U.S. Consumer Product Safety Commission (CPSC) recall data. https://www.cpsc.gov/Recalls
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