White Paper Final

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Lauren Ghelardini, Cory Hood, Corey Park, Jill Terner,
July Tran, Lauren Westley, Yunran Zhang
Spring 2015
Department of Environmental Health Sciences
Columbia University Mailman School of Public Health
A CRITIQUE OF COLUMBIA
UNIVERSITY’S FIRE SAFETY
STANDARDS FOR UPHOLSTERED
FURNITURE & FURNISHINGS

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Glossary
BDE Brominated Diphenyl Ether
CAL 117 California Technical Bulletin 117
CAL 117-2013 California Technical Bulletin 117-2013
CAL 133 California Technical Bulletin 133
CPSC Consumer Product Safety Commission
DfE Design for the Environment Program
DPHP Diphenyl phosphate
EPA Environmental Protection Agency
EU European Union
NFPA National Fire Protection Agency
NRDC National Resource Defense Council
OPFRs Organophosphate Flame Retardants
PBBs Polybrominated Biphenyls
PBDEs Polybrominated Diphenyl Ethers
PUF Polyurethane Foam
REACH Registration, Evaluation, Authorization, and Restriction of Chemicals
T3 Triiodothyronine
T4 Thyroxine
TSH Thyroid Stimulating Hormone
TBBA 2,3,4,5-tetrabromobenzoic acid
WHO World Health Organization
Acknowledgements
We thank Dr. Robin Whyatt and Whitney Cowell for assistance in writing section 6 (Health Effects) of
this white paper and Dr. Heather Stapleton for analyzing the indoor air samples.

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Table of Contents
1. Physical and Chemical Properties of Flame Retardants ............................................................. 6
2. History of Fire Safety Standards and Flame Retardant Use ....................................................... 6
3. New York Fire Safety Standards .............................................................................................. 11
4. Columbia University Fire Safety Standards ............................................................................. 11
5. Exposure ................................................................................................................................... 12
5.1 Prior Use Flame Retardants............................................................................................................. 13
5.1.1 Polybrominated diphenyl ethers (PBDEs)................................................................................ 13
5.2 Current Use Flame Retardants ........................................................................................................ 14
5.2.1 Firemaster 550.......................................................................................................................... 14
5.2.2 Non-Halogenated Organophosphate Flame Retardants (OPFRs) ............................................ 14
5.2.3 Chlorinated OPFRs................................................................................................................... 14
6. Health Effects............................................................................................................................ 16
6.1 Prior Use Flame Retardants............................................................................................................. 16
6.1.1 PBDEs ...................................................................................................................................... 16
6.2 Current Use Flame Retardants ........................................................................................................ 17
6.2.1 Firemaster 550.......................................................................................................................... 18
6.2.2 Non-Halogenated OPFRs ......................................................................................................... 18
6.2.3 Chlorinated OPFRs................................................................................................................... 18
7. Indoor Air Sampling For the Current Use Flame Retardants ................................................... 19
8. Efficacy..................................................................................................................................... 20
9. Alternatives............................................................................................................................... 22
9.1 Alternative Chemicals..................................................................................................................... 23
9.2 Alternative Policy & Technologies................................................................................................. 24
9.3 Indirect Alternatives........................................................................................................................ 24
10. Disposal................................................................................................................................... 25
11. Recommendations................................................................................................................... 26
11.1 Recommendations for Columbia University Fire Safety .............................................................. 26
11.2 Disposal Recommendations.......................................................................................................... 26
11.3 Alternative Recommendations...................................................................................................... 27

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Table 1. Flame retardants used in furniture and furnishings

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Executive Summary
An increase of fire safety regulations since the 1970s has led to expanded use of chemical flame
retardants in industrial and home furnishings. Today, as a result, humans in the U.S. are ubiquitously
exposed to such chemicals. The use of chemical flame retardants as a method to meet fire safety
regulations, such as California Technical Bulletins 117 (CAL 117) and 133 (CAL 133), can be partially
attributed to lobbying by the chemical and tobacco industries. The Columbia University Fire Safety
Policy self-subscribes to both CAL 117 and CAL 133 in order to adhere to New York City and New
York State Fire Codes.
Since the 1970s, polybrominated diphenyl ethers (PBDEs) have been the dominant class of flame
retardants used in furniture and furnishings in the U.S. However, owing to evidence of environmental
persistence, ubiquitous human exposure, and health effects, including adverse neurodevelopment and
endocrine disruption, these chemicals have been phased out of production. The major class of
replacement chemicals include halogenated (primarily bromine or chlorine) and non-halogenated
organophosphate flame retardants (OPFRs). Preliminary exposure assessment studies have documented
detectable levels of these replacements in humans and wildlife. Though research on the health effects of
these replacements is extremely limited, there is at least some animal and in vitro studies on all of the
compounds that provide evidence of carcinogenicity, endocrine disruption, atopy, and/or developmental
and reproductive toxicity. Thus it is not possible to recommend any of the replacement flame retardant
as safe substitutes for the PBDEs until further research is conducted and the data gaps are filled.
Research demonstrating that chemical flame retardants are efficacious at slowing fires and reducing fire
deaths are also extremely limited. In spite of extensive data searches, we were not able to find any
reliable studies. Although several studies conducted by flame retardant manufacturers have
demonstrated efficacy, our evaluation indicated significant problems in the study designs. Further, the
use of flame retardants has coincided with a number of other secular trends, including declining smoking
rates, increased use of smoke detectors and sprinkler systems, and improved building, fire, and electric
codes, making the efficacy of flame retardant use difficult to disentangle. Additionally, during a fire
flame retardants can increase the yield of carbon monoxide, irritant gases, and soot.
In 2013, the State of California Consumer Affairs introduced California Technical Bulletin 117-2013
(CAL 117-2013), an amendment to the dated CAL 117 statute of 1975. Importantly, the new standard is
designed to be met using methods and technologies that do not require the use of flame retardants, while
still providing fire safety.
With a growing literature supporting the adverse effects of flame retardants, limited evidence of
efficacy, and recent development of a new flammability standard, we recommend the following changes
are made at Columbia University: 1) Columbia University avoids purchasing furniture treated with
chlorinated organophosphate flame retardants that have been associated with evidence of
carcinogenicity until further research is conducted on exposure and health effects. 2) Columbia
University should continue to evaluate information that becomes available on the remaining flame
retardants currently used in furniture and furnishings as there are currently significant data gaps. 3)
Columbia University should shift away from policies such as CAL 117 that can only be met using flame
retardants, and toward alternative approaches for fire safety such as the installation of sprinklers and
furniture produced with fire barriers.

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1. Physical and Chemical Properties of Flame Retardants
For decades the foam inside sofa recliners, loveseats, and other furniture and furnishings has been
treated with flame retardants, many of which are toxic (1). Flame retardants are chemicals added to
products to delay fire ignition and prevent the spread of fire. Many products in the U.S. contain these
chemicals, including appliances and product cases, baby products, cable jackets, couches, mattresses,
plastic toys, wood, polyurethane insulation, upholstery foam, and upholstery textiles (2). Our report
focuses solely on flame retardants used in furniture and furnishings. For a list of these flame retardants,
including their abbreviation, full name, and chemical structure, please refer to Table 1 above. Table 2
below lists the major classes of flame retardants, details their current use status and summarizes their
production volume in pounds (3).
Table 2. Flame retardants by group including their current status and production volume
Phased out in US Phased out in Europe
PBDEs Yes Yes
Firemaster 550 No (10-60 million lbs produced/year) No
Non-Halogenated OPFRs No (1-540 million lbs produced/year) No
Chlorinated OPFRs No (10-100 million lbs produced/year) No
Flame retardants are classified by their chemical structure and by the presence of a halogenated
functional group (4). The majority of additive flame retardants used in furniture or furnishings are
halogenated and designed with bromine or chlorine. In addition to the presence or absence of halogens,
flame retardants are characterized as organophosphates if they contain a phosphorylated organic
backbone. Furthermore, flame retardants can be classified as either additive or reactive depending on
whether they are added to or bonded with the product. The majority of flame retardants used in
polyurethane foam are additive; as discussed in the exposure assessment below, these chemicals are
readily released from products and adhere to dust particles in the surrounding environment (5).
2. History of Fire Safety Standards and Flame Retardant Use
Flame Retardant Use is Historically Linked to Cigarette Smoking, Resultant Fire Deaths, and The
Tobacco Industry’s Reluctance to Develop Fire-Safe Cigarettes: History from the 1970s
In 1970, 37.4% of adults in the U.S. smoked cigarettes, down from 42.4% in 1965 (6). During this
period, household fires attributable to ignition of upholstered furniture from cigarettes was the leading
cause of fire-related deaths in the U.S. (7, 8). According to a 2002 investigation, approximately 1000
deaths and billions of dollars in property damages, health care, lost productivity, and fire and emergency
services are attributable to cigarette-related fires annually (9). Therefore, in addition to the continued
pressure from governmental bodies to limit advertising and increase labeling of tobacco products in the
1960s and 1970s, the tobacco industry was under intense public pressure and media scrutiny to develop
self-extinguishing or fire-safe cigarettes that would be less likely to start a fire if dropped or left
unattended around upholstered furniture (9).
Despite these findings, the tobacco industry claimed they could not create fire-safe cigarettes due to a
variety of physical and chemical challenges. In addition to research concerns, they maintained that
prototypes of self-extinguishing cigarettes tasted worse, were harder to smoke, and were less desirable to
consumers, making them an unattractive investment (10). Interestingly, several patents issued to private

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companies provide evidence that by the early 1970s, research to make a realistic, publically acceptable
cigarette was well under way (9, 11). In 1974, a bill mandating cigarettes be made to “self-extinguish”
passed through the Senate, but was killed in the House of Representatives, presumably as a testament to
the power and influence of the Tobacco Institute, a tobacco industry trade group (11). At this point in
history, the tobacco industry’s agenda shifted from fire-safe cigarettes as a way to reduce household
fires, which they saw as a detriment to their profitability, to that of reducing the flammability of
upholstered furniture and furnishings.
The tobacco industry used funding, media power, and the faces of concerned firefighters to promote the
passage of fire safety standards requiring the use of flame retardants on household materials and items.
However, the degree to which they influenced legislation on the regulation of flammable fabrics is
uncertain. In the early 1970s, concerns about the growing number of fire-related fatalities prompted the
newly formed Consumer Product Safety Commission (CPSC), a government body created to regulate
the safety of consumer products, to begin testing and regulating the flammability of clothing (12). In
November of 1972, the Federal Register stated that it was necessary to regulate the flammability of
upholstered furniture and in 1973, the CPSC took over the issue (12). During this period, methods for
testing whether a product meets flame retardant standards were developed by public and private
partnerships but ultimately the CPSC did not set federal standards (12).
Coincidentally in 1973, Polybrominated Biphenyl (PBB) flame retardants were removed from the U.S.
market after an accident in which 2,000 pounds of PBBs were inadvertently mixed with animal feed in
Michigan, subsequently exposing roughly 10,000 residents via consumption of contaminated meat, milk,
butter, cheese, and eggs. This accident had large health and economic consequences; roughly 30,000
head of livestock and 1.6 million chickens were destroyed and 90% of Michigan residents had detectable
levels of PBBs in their blood for several years following the accident (13).
1975: California Technical Bulletin 117
Following discussions of flammability standards for upholstered furniture at the federal level and the
tobacco industry’s influence on the use of flame retardant chemicals, the state of California passed
legislation in 1975 mandating flammability standards for furniture components (12). The mandatory
legislation, California Technical Bulletin 117 or CAL 117, required an “open flame” test for all
components of upholstered furniture except for the frames and fabric itself (14). There are different test
requirement for different fabrics, but for polyurethane foam, a sample pillow of cushion of at least
13”x13” is required to withstand a 12 second flame without losing more than 5% of its weight (14). This
was intended to prevent home fires caused by small open flame sources such as candles (15). While
CAL 117 does not directly require application of flame retardant chemicals, it is highly unlikely that any
component of upholstered furniture, specifically polyurethane foam would be able to pass this test
without their addition (14, 15). Additionally, CAL 117 does not require testing of external fabric, is
often the primary contributor to the high flammability of upholstered furniture (16).
Since CAL 117 is state level legislation, it only applies to furniture sold within California (14).
However, as it would be cumbersome and expensive for companies to manufacture products specifically
for one state, the majority of companies design all furniture and furnishing to meet the California
standards. This approach was also taken to avoid potential litigation from burn victims who could claim
that a fire was due to untreated foam. Over time, other states began to adopt similar fire safety
legislation that required flame retardant chemical application. A study conducted on 102 samples of

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polyurethane foam from couches purchased between 1985 and 2010 in the U.S. concluded that 85%
contained flame retardant chemicals (15). Thus, CAL 117 has essentially been the flammability standard
for the entire U.S. population for decades.
Big Tobacco Organizes Fire Marshals: History from the 1980s
To improve their credibility regarding the promotion of fire resistant furniture, the tobacco industry
sought to engage with a group that was well-respected regarding fire safety. The Tobacco Institute was
the prime tobacco industry interest group and gave millions of dollars to fire groups, in addition to
paying consultants to woo fire officials. A memo from 1984 outlines a meeting of Philip Morris
executives discussing this strategy. In 1989, the former Vice President of the Tobacco Institute, Peter
Sparber, formed and then steered the National Association of State Fire Marshals, an organization of the
top fire official from each state (16, 17). Sparber had left the Tobacco Institute to form his own lobbying
firm, but kept the Institute as a main client. This enhanced his credibility and allowed him to appear as
though he had the marshals’ and the public’s best interest at heart. The marshals thought Sparber’s work
to protect the community from fires was voluntary. However, he was actually paid $200 an hour by the
Tobacco Institute to work on projects such as a petition to include flame retardants in furniture.
These low profile, taxpayer-funded government appointees were given the star treatment by the tobacco
industry, including gifts of nice wines, hospitality suites, and free mountain bike rentals. The marshals
were also provided with talking points through media-training seminars to improve public speaking
skills. Sparber set the association’s national agenda and passed along internal documents and
information on the marshal’s work to the Tobacco Institute, which in turn relayed it to cigarette
companies. The wooing of the marshals and the influence of Big Tobacco within the association
worked; the fire marshals passionately fought for the tobacco industry’s political agenda, although they
were unaware of it (16).
California Technical Bulletin 133: Continuing into the 1990s
With the Tobacco Institute and the National Association of Fire Marshals firmly behind the increased
use of flame retardants, California developed California Technical Bulletin 133 (CAL 133) in 1992, a
second piece of fire safety legislation that mandated a “full burn” or “composite” test on upholstered
furniture in areas of public buildings and public assembly with ten or more pieces of seating furniture;
however, the standard does not extend to residential furniture (18). This composite test requires that a
square gas burner is placed on the test furniture, ignited, and burned for 80 seconds (18). A variety of
specific measurements are taken including, temperature, mass loss of furniture, concentrations of carbon
dioxide, unburned hydrocarbons, opacity of smoke, and heat release based on oxygen consumption (18).
In order to pass, certain thresholds must be met for each of these measurements. This often requires that
flame retardants are applied to the foam, fabric, and/or barrier cloth components of furniture, but their
application is not explicitly stated as necessary to meet the standard (19). Exceptions to CAL 133 are
made for rooms with automatic sprinkler systems depending on the municipality. For instance, Boston
and Ohio do not allow for any exceptions in the presence of sprinklers, while California, Massachusetts,
and Illinois do (12, 19). Even with these exceptions, CAL 133 increased the use of flame retardants
across the country by both increasing the quantity used in an individual piece of furniture and by
requiring more public and private spaces to comply with the standard.

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The Tobacco Institute Shuts Down, Leading to Fire-Safe Cigarette Legislation: 1999
In 1999, the Tobacco Institute shut down as part of a court settlement. A number of states subsequently
passed laws requiring fire-safe cigarettes, thereby further eliminating Big Tobacco’s interest in
promoting flame retardant policies. This settlement also resulted in the public release of a wealth of
internal documents, many of which have been used as evidence of the tobacco industry’s role in
lobbying for flame retardants. Since the closing of The Tobacco Institute, the chemical industry has
stepped in to sponsor the National Association of State Fire Marshals, which continues to work towards
stopping bills that restrict the use of flame retardants (16).
Chemical Industry Creates a Front Group: Citizens for Fire Safety Institute: Moving into 2007
In 2007, the flame retardant chemical industry created its own group to lobby for its interests, while
trying to maintain an innocuous and credible appearance. To achieve this, they formed the Citizens for
Fire Safety Institute, an organization that described itself as a “coalition of fire professionals, educators,
community activists, burn centers, doctors, fire departments and industry leaders, united to ensure that
our country is protected by the highest standards of fire safety.” Its website claimed that the group
worked with the international firefighter’s association, the American Burn Association, and a federal
agency. However, during a journalistic investigation, the Chicago Tribune uncovered that the group was
actually a trade association whose members solely consisted of the three largest manufacturers of flame
retardants: Albemarle, ICL Industrial Products, and Chemtura. Additionally, all of the organizations that
Citizens for Fire Safety Institute claimed to work with have stated that they, in fact, do not work
together. Moreover, the executive director of the organization previously served as a political advisor to
tobacco executives. Between 2008 and 2010, the group received $17 million in funding solely from
membership dues and that money’s interest. This was spent almost entirely on lobbying efforts in state
legislatures, which were the political battleground for legislation addressing the health effects and
ubiquity of flame retardant exposure.
This industry front group continued to use misrepresentation as their main tactic in blocking state
legislation restricting the use of flame retardants. Citizens for Fire Safety Institute paid people to serve
as witnesses at legislative hearings, either directly or through donating to groups that the witness was a
part of. This sponsorship was not disclosed to the committees. The testimonies framed anti-flame
retardant advocates as overzealous, elitist environmentalists, while the community affected by the
proposed legislation was framed to be poor, minority children who would suffer even more fire deaths
than they already disproportionately bear. A prestigious burn doctor sponsored by Citizens for Fire
Safety Institute promoted burn victims as the ‘face’ of the pro-flame retardant agenda, falsifying a story
about a baby’s death from a fire that could have been prevented with flame retardants (16).
In addition to misrepresenting the issue at legislative hearings, Citizens for Fire Safety Institute ran
media campaigns using strong fear tactics, such as a video titled “Killer Couches!” which showed a
couch on fire, ominous music in the background, and the words “Are you sitting comfortably?” These
fear tactics, fabricated emotional and ethical appeals, and a lack of disclosure of the connection between
the industry front group and the witnesses helped the industry block several proposed bills, such as the
California State Assembly’s 2009 proposal to exclude baby products from the state’s flammability
regulation and California Senate’s 2011 proposal to significantly reduce the use of flame retardants.
Since the release of the Chicago Tribune’s investigative report, chemical companies have claimed that
they have cut ties with the Citizens for Fire Safety Institute and will lobby through the American
Chemistry Council, the main lobbying group for the chemical industry (16).

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CAL 117-2013
The Chicago Tribune exposé, printed in May 2012, started the national conversation regarding the
efficacy and safety of flame retardant chemicals (16). In June 2012, the Governor of California, Edmund
Brown, made a public statement calling for a reassessment of flammability standards by the State’s
agencies (20) He mentioned the growing body of evidence suggesting flame retardants are associated
with several adverse health effects in vulnerable population such as children, women of reproductive
age, and firefighters (20). Activist groups such as the San Francisco Firefighters Cancer Prevention
Foundation were extremely vocal about their concern for health effects and organized around
amendments to CAL 117 and 133 (21). Additionally, later in 2013, HBO aired a documentary entitled,
“Toxic Hot Seat” in which the corruption, efficacy concerns, and adverse health effects associated with
flame retardants are depicted for a mass audience (22).
As a result of grassroots organization and advocacy by firefighters in California, Technical Bulletin 117-
2013 (CAL 117-2013) was passed in January 2013 and came into effect as of January 2014 (23). This
standard requires a “smolder test” for fabrics and is novel in that compliance is feasible without flame
retardant chemicals (19, 24). CAL 117-2013 consists of three tests used to evaluate the cigarette
ignition resistance of upholstery cover fabrics, barrier materials, and resilient filling materials used in the
manufacture of upholstered furniture (24). In each test, the test material is placed directly on a
fiberglass board on which a lit cigarette is then allowed to “smolder”. The material is considered to pass
the “smolder test” if a cigarette burns its full length and the material ceases to smolder (24).
Interestingly, while this test better models a real-life fire than the previous test, which solely tested the
flammability of the polyurethane foam, it still does not necessarily test for the interaction between
various furniture components, including both the foam and the upholstery cover fabrics (23).
The passage of CAL 117-2013 is a clear indication of a shift in the view of fire safety and the role that
flame retardants play. CAL 117-2013 has the potential to improve fire safety without relying on these
chemicals and has encouraged manufacturers to switch to less flammable fabrics (25). Instead of
injecting chemicals into polyurethane foam, manufacturers can now line furniture with a fire shield, or
use non-flammable materials (26). Public building occupancies can also either choose to comply with
CAL 117-2013, rather than CAL 117, if the space is fully protected by an automatic sprinkler system
(19).
While this shift away from flame retardants may result in health benefits while also assuring fire safety,
it is not easy to determine whether or not furniture is treated with flame retardant chemicals as labeling
is not required. Here, we provide a set of guidelines to help a consumer determine whether or not
furniture or furnishings contain flame retardants:
1. Furniture that does not contain polyurethane foam usually does not contain flame retardant
chemicals.
2. Furniture containing polyurethane foam purchased or reupholstered in California after 1975 or
furniture with a specific label stating compliance with TB 117 likely does contain flame retardants.
3. Furniture purchased prior to 2000 outside of California has about a 50% chance of containing flame
retardant chemicals (27). A list of companies that currently produce flame retardant-free furniture
can be found in the Appendix.

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3. New York Fire Safety Standards
New York State and New York City Fire Safety Legislation
The New York State Legislation Uniform Codes contain statewide information regarding fire codes in
both residential and other buildings (28). These codes do not apply to New York City, which has its own
Fire Code. The Columbia University facilities are bound by the 2008 Fire Code, which classifies all
university and college facilities and occupancy spaces as Class B business establishments (29).
Information pertinent to the Columbia University Fire Safety Policy can be found in chapters 8 and 27
of the New York City Fire Code, as well as National Fire Protection Association (NFPA) standards 701
and 267 (29). Stated in the codified rules of the city under Title 3, Chapter 8, Section 805, decorations in
college and university facilities must be flame resistant in accordance with the tests specified in NFPA
701, which has similar requirements to CAL 117 (30). Chapter 27, Section 2706, of the New York City
Fire Code refers to standards for Hazardous Materials in non-production chemical laboratories,
including curtains and laser curtains in Columbia University’s laboratories (30).
In parallel with a voluntary phase-out by the chemical industry, in 2004 New York State passed an
environmental law that codified the prohibition of production and use of two of the three major
commercial PBDE formulations, pentaBDE and octaBDE (31). Twelve other states and the District of
Columbia currently ban both pentaBDE and octaBDE as well (31). Additionally, beginning in December
2013, New York State banned the sale of any products intended for children under 3 years old that
contain the flame retardant Tris (1,3-dichloro-2-propyl) phosphate (TDCPP), also referred to as
Chlorinated Tris (31). Regulations regarding chemicals in children’s clothing date back to the 1970s
when concerns over children’s vulnerability to these chemicals came to light (12). As of 2015, decaBDE
has not been banned in New York State or New York City (28). However, in 2004 New York State
formed a Task Force on Flame Retardant Safety to assess the cost, effectiveness, and adverse health
effects of decaBDE and any viable alternatives (28). Simultaneously, the U.S. Environmental Protection
Agency (EPA) announced in 2009 that all major U.S. based producers and importers of decaBDE must
phase out production, importation, and sale by the end of 2012 as a result of increased evidence for
adverse health effects (28). From the final state report published in March 2013, New York State agreed
with EPA’s recommended voluntary phase-out of decaBDE (28).
4. Columbia University Fire Safety Standards
In 2009, the Columbia University Fire Safety Policy was updated to reflect amendments to the New
York City Fire Code, including sprinkler exemptions consistent with CAL 133 requirements (29).
Currently, the policy must meet the Fire Safety codes of the city and follow CAL 117 and CAL 133 for
certain spaces and situations, which are detailed below.
Rooms and spaces are split into three categories (29):
 Any offices, public areas, and places of public assembly, including classrooms that are protected by
an automatic sprinkler system must meet the flame resistant requirements of CAL 117. However,
any of these spaces that are not protected by a sprinkler system must meet CAL 133.

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 Laboratory space must comply with New York City Fire Codes or be exempted through an affidavit
as described in the New York City Fire Code Chapter 8.
 Regardless of the presence of an automatic sprinkler system, all dormitory and hospital occupancies
must meet the CAL 133 requirements for upholstered furniture, curtains, drapes, and carpets.
Mattresses have specific city code testing requirements based on national guidelines outlined by
NFPA 267.
5. Exposure
In this section we discuss 12 flame retardants that are commonly used in furniture and furnishings. We
refer to each by commonly used abbreviations, however, full names can be found in Table 1 at the
beginning of this document. PentaBDE and decaBDE are brominated flame retardants that were
voluntarily phased out of production in 2004 and 2013, respectively. TCEP, V6, TCPP and TDCPP are
chlorinated organophosphate flame retardants. TBPP and MPP Mix are two non-halogenated
organophosphate flame retardants. Firemaster 550, which has been widely used following the phase out
of PBDEs, is a commercial mixture containing TBB, TBPH and TPP. TPP is a non-halogenated
organophosphate that is also a primary component of MPP Mix and TBPP. All flame retardants included
in this section are additive and commonly used in polyurethane foams. Over time they are released from
the material and enter the indoor environment. Depending on their persistence, some chemicals can exist
for a long period of time and continue to accumulate in the environment. All the flame retardants
described in this section are detected in the indoor environment, primarily in dust, but also occasionally
in air. Air sampling data are limited and not available for many of the newer flame retardants. Since
flame retardants are primarily present in indoor dust, incidental ingestion of dust is a major route of
exposure. Inhalation may be a second exposure route for some flame retardants, while dermal absorption
does not appear to occur in most cases. Table 3 below summarizes the major chemical and exposure
properties for each flame retardant examined here, including: environmental persistence,
bioaccumulation, biological half-life, sources and routes of exposure.
Table 3. Properties of flame retardants used in furniture and furnishings

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5.1 Prior Use Flame Retardants
5.1.1 Polybrominated diphenyl ethers (PBDEs)
There are three types of commercial PBDE products, pentaBDE, octaBDE, and decaBDE each of which
contains a mixture of PBDE congeners (32). Here, we focus on penta and decaBDEs as these are the
primary brominated flame retardants found in furniture and furnishings. The relative proportions by
weight of various PBDE congeners in the commercial pentaBDE mix are as follows: BDE 99 (43%),
BDE 47 (28%), BDE 100 (8%), BDE 153 (6%), and BDE 154 (4%) (32). PentaBDE is typically used at
levels approximately 3% to 6% of the weight of the polyurethane foam. DecaBDE is comprised solely
of BDE 209, however, it is known to degrade to lower congeners in the environment (33).
PBDEs persist in human tissue from months to years, depending on the congener, with higher
brominated molecules typically having shorter half-lives (34). Nationwide studies of PBDEs
demonstrate nearly ubiquitous exposure in the U.S., with levels detected in human serum, breast milk
and adipose tissue (See Figure 1). Although it was voluntarily phased out in 2004, due to its high
persistence, pentaBDE remains a ubiquitous environmental pollutant and studies suggest its component,
BDE 47, contributes the most to human exposure. In a 2011 study based in California that measured
pentaBDE and decaBDE concentrations in furniture found that 50% and 100% of house dust samples
contained pentaBDE and decaBDE, respectively (35). The main routes of exposure to pentaBDE for
adults are incidental ingestion of dust (66%), inhalation (17%) and consumption of food, specifically
fatty fish or other animal products with high fat contents (17%). Estimates suggest children engage in
approximately 18 hand-to-mouth behaviors every day, providing a direct route of exposure to indoor
dust, which helps to explain their intake of approximately 100-200 mg of dust per day, compared to the
20-50 mg estimated to be ingested by adults (36). Accordingly, children and adults are estimated to
ingest approximately 16 mg and 3.25 mg of pentaBDE per day, respectively (37). Historically, decaBDE
has been produced at a higher level than pentaBDE, however, pentaBDE is more persistent and
bioaccumulative in the environment and therefore is typically detected at higher concentrations.
Figure 1. Total PBDE concentrations in biologic samples (ng/g lipid) as a function of the year and
sampling location (adapted from: (38)).

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5.2 Current Use Flame Retardants
5.2.1 Firemaster 550
Firemaster 550 is comprised of at least 14 phosphate compounds of various concentrations (39)
including the brominated flame retardants TBB and TBPH, which are found at an approximate
proportion of 4:1 by weight (15). Firemaster 550 is commonly used in polyurethane foam as a substitute
for pentaBDE. In previous studies, both TBB and TBPH were detectable in air samples, marine mammal
tissue, and wastewater sewage sludge, which demonstrates that Firemaster is released into the
environment. In a study conducted by Stapleton et al (15), Firemaster 550 was the second most detected
flame retardant in polyurethane foam samples following the phase-out of pentaBDE in 2005. Likewise,
among indoor dust samples collected from 20 houses in Boston, Massachusetts, TBB and TBPH were
detected in 94% (median=322 ng/g) and 100% of samples (median=234 ng/g), respectively (40).
Once absorbed, TBB is biotransformed in the liver to 2,3,4,5-tetrabromobenzoic acid (TBBA), which is
eliminated in urine and has been proposed as a potential biomarker of Firemaster 550 exposure (41). A
study examining concentrations of TBBA in urine samples and concentrations of TBB and TBPH in
dust samples and hand wipes demonstrated a high correlation, providing evidence that TBBA reflects
exposure to TBB and TBPH in house dust (41). A study performed in paired mothers (n=22) and
children (n=26) residing in the U.S. detected TBBA in 27% of mother and 70% of child urine samples,
indicating children have high exposure to TBB and likely Firemaster 550 (42).
5.2.2 Non-Halogenated Organophosphate Flame Retardants (OPFRs)
A study examining TPP, a component of Firemaster 550, TBPP and MPP Mix, in 53 houses in North
Carolina detected TPP in 100% of dust samples. (43). Humans are exposed to TPP via inhalation and
ingestion of contaminated dust and food. Diphenyl phosphate (DPHP), a metabolite of TPP, is a useful
biomarker when measured in urine and was detected in 90.6% of urine samples collected from
participants in the North Carolina cohort. Interestingly, the researchers also found that the levels of
DPHP in urine samples among women were almost two times higher than among men (43), suggesting
this population might be particularly susceptible to heightened exposure. In a second study examining
urine samples collected from paired mothers (n=22) and children (n=26), DPHP was detected in 100%
of maternal urine samples and 92% of child urine samples (42).
TBPP consists of mixture of non-halogenated organophosphate flame retardants. About 40% of the
TBPP mixture consists of TPP. TBPP has low volatility based on its chemical features and preliminary
studies estimate an average half-life of one day depending on the mixture (44).
MPP Mix is a mixture of organophosphate flame retardants that do not contain halogens. Like
Firemaster 550, TPP is a primary component of MPP Mix (see above for more information on TPP).
Exposure data on MPP Mix are limited, however, a Japanese study found detectable levels in 100% of
dust samples collected from elementary schools (n=18) and households (n=10) with a median level of
6800 ng/g (45).
5.2.3 Chlorinated OPFRs
TDCPP is a chlorinated phosphate ester. It is currently used as a flame retardant in many products
including polyurethane foam. While PBDE was the most prevalent flame retardant before its voluntary

15
phase-out in 2004, TDCPP is currently the dominant flame retardant used in products and has been
documented in office furniture at levels up to 5% by weight (37). In a study examining flame retardants
in residential couches purchased from 1985 to 2010, Stapleton et al. (40) found that among couches
purchased before 2005, PBDEs were detected in 39% and TDCPP was detected in 24%. For couches
purchased after 2005, TDCPP was detected in 52%, while Firemaster 550 was detected in 18%. These
results suggests that TDCPP is one of the most prevalent flame retardants and was in use prior to the
phase out of the PBDEs.
In a study examining TDCPP in house dust (n=50), researchers found detectable levels in 96% of
samples, with a geometric mean concentration of 1890 ng/g. Likewise, TDCPP has been detected in air
samples collected from residences (46). Ingestion and inhalation are two common routes of exposure to
TDCPP and animal studies indicate it is also rapidly absorbed dermally (47). Once absorbed TDCPP is
metabolized to BDCPP and excreted in urine (47). A study (48) examining the association between
urinary BDCPP and TDCPP levels in office dust found TDCPP was detected in 99% of the dust samples
(median = 4.43 μg/g) and BDCPP was detected in 100% of urine samples (median = 408 pg/g)
collected from adult office workers (n=29).
TCEP is commonly used in furniture foam, polyvinyl chloride, electronics and various building
materials and it has been detected in indoor air with concentrations ranging from 1.4 - 15 ng/m3
(49). A
Japanese study that measured TCEP in dust detected TCEP in 96% of samples with median levels of
500 ng/g and 2700 ng/g for samples from elementary schools and households, respectively (50).
TCPP is a non-volatile flame retardant often used in flexible polyurethane foam and some building
materials. TCPP shares a similar structure with TCEP and it is often used as a replacement for TCEP
(37). In a study of indoor dust, concentrations of TCPP were found to be much higher than
concentrations of TCEP suggesting an increase in the use of TCPP (49). A Swedish study examining
indoor air concentrations found TCPP levels ranged from 91-850 ng/m3
in 3 samples (49). Similarly, a
study completed in ten work environments in Stockholm, Sweden, found TCPP, TCEP and TDCPP in
all air and dust samples and concluded these chemicals accounted for 75% of the total mean
concentration of phosphate ester flame retardants. Among these, TCPP was found to have the highest
concentration in office settings whereas TCEP was found at high levels in homes, daycares and offices
(50).
V6 is mainly used in polyurethane foam for products in the automotive (50-70%) and furniture (25-
50%) industries (51). The chemical structure of V6 is very similar to TCEP and it often contains TCEP
as an impurity. According to a European Union (EU) Risk Assessment report, TCEP is found at levels
of 4.5-7.5% in V6 products on average (52). Baby products produced using V6 may contain
considerable amount of TCEP as a component (51). In a study conducted in 2009, researchers detected
V6 in 70% of dust samples collected from 29 houses in Boston, Massachusetts. In these samples, the
concentration of V6 ranged from <5 to 1110 ng/g with a median value of 12.5 ng/g. TCEP and V6 were
found to be significantly correlated in dust samples, suggesting V6 is a major source of TCEP. The
median concentration for TCEP was 50.2 ng/g, which was higher than that of V6 (51). One plausible
reason to explain this result is that TCEP may have greater migration away from polyurethane foam due
to its higher vapor pressure compared to V6 (51).

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6. Health Effects
6.1 Prior Use Flame Retardants
6.1.1 PBDEs
Research on the health effects of PBDEs has increased exponentially in the past decade (53). Mounting
evidence indicates the greatest concerns relate to developmental neurotoxicity. As such, we provide an
overview of major neurodevelopmental findings and briefly review effects observed for other health
endpoints. When sufficient data were not available for human subjects, we present results from studies
conducted in laboratory animals.
Recently, the neurodevelopmental and neurobehavioral effects of PBDE exposure were systematically
reviewed by Roth et al. (54). Of the studies conducted to date, Roth et al. classified two as high quality
(55, 56) and four as moderate quality (57-60). In conjunction with a recent study by Chen et al. (61) not
included in the review, these studies collectively provide evidence that prenatal (maternal blood, cord
blood) or early childhood (breast milk, child blood) PBDE exposure is associated with reduced fine
motor skills, impaired cognition (verbal skills, perceptual reasoning, IQ) and disrupted behavior
(attention, anxiety, hyperactivity and impulsivity) among children. The results from numerous animal
models support these findings and are summarized in a review article by Costa et al. (62). For example,
exposure to PBDEs in mice and rats has been associated with reduced habituation to environmental
surroundings, which is considered to be a correlate of hyperactive behavior in humans. Similarly, studies
examining prenatal exposure in mice have observed hyperactivity in the offspring of exposed, but not
control, mice. In addition to behavioral alterations, postnatal exposure to PBDEs has been associated
with cognitive impairments related to learning, memory and visual discrimination in multiple murine
models.
Alteration of thyroid hormone homeostasis has been investigated as the mechanism underlying the
observed associations between PBDE exposure and disrupted neurodevelopment. Thyroid hormones
play a critical role in brain development during gestation and early life (63). Conversely, results from
research conducted in laboratory animals have consistently demonstrated a relationship between prenatal
exposure to PBDEs with decreased serum thyroxine (T4) and increased thyroid stimulating hormone
(TSH) levels (64). Several prospective birth cohort studies have examined associations between prenatal
PBDE exposure and disrupted thyroid hormone homeostasis, however results are limited and have been
inconsistent. In the largest study conducted to date (n=380), cord blood PBDE levels were associated
with decreased levels of total triiodothyronine (T3) and T4, but increased free T3 and T4. Smaller
studies have detected a mix of results including decreased T4 (65), increased T4 (66), decreased TSH
(67), and increased TSH with no change in T4 (68).
Likewise, results from studies examining thyroid hormone disruption in adults have been inconsistent.
In an occupational study of male workers, exposure to decaBDE via inhalation was associated with an
increased prevalence of hypothyroidism (69) and in an observational study conducted among 110 men
consuming fatty fish caught from the Baltic Sea, researchers detected a weak negative correlation
between BDE 47 (a component of pentaBDE) and plasma TSH levels (70). Similarly, among a cohort of
healthy adult male sport fish consumers (n=308) in the U.S., higher PBDE serum concentrations were

17
associated with altered free and bound T4, T3 and TSH levels. These researchers also detected a positive
association between BDE 47 with altered testosterone levels (71).
Few other studies have examined the relationship between PBDEs and altered sex hormone levels in
humans. One existing study conducted cross sectional analyses among a cohort of adult men (n=24)
recruited from a fertility clinic in the U.S., and found PBDE (BDEs 47, 99, 100) levels measured in
house dust were associated with a number of hormonal endpoints, including lower free androgen index
(significant at the 0.05 level), luteinizing hormone, follicle stimulating hormone, and higher inhibin B,
sex hormone binding globulin, and free T4 (72).
Limited studies have demonstrated effects between PBDEs and adverse reproductive, and
developmental outcomes. This literature includes findings from one epidemiologic study examining
PBDE exposure and fecundability. Among a cohort of 202 women in California, Harley, et al. found
blood PBDE (BDEs 47, 99, 100, 153) concentrations were positively associated with self-reported
duration to pregnancy. In a separate study examining adult men, serum PBDE levels have been
associated with decreased sperm motility and concentration (73, 74).
Several studies have examined the relationship between PBDE exposure and adverse birth outcomes,
including preterm birth, low birth weight, and still birth, however existing studies suffer from several
methodological limitations (i.e. small sample size, poor confounder control) and have conflicting and
inconclusive results (75-78). One prospective study found breast milk PBDE levels were significantly
higher among infants with cryptorchidism (n=95), a male reproductive tract abnormality, compared to
healthy boys (n=185) (79).
As a result of these findings, pentaBDE and decaBDE were voluntarily phased out of production in the
U.S. in 2004 and 2013, respectively. In addition, some states have legally banned their use and they have
been listed as persistent organic pollutants by the Stockholm convention, which aims to identify and
reduce the release of pollutants that are resistant to environmental breakdown and have known human
health and ecotoxic effects (80).
6.2 Current Use Flame Retardants
As discussed previously, three main classes of flame retardants are currently being used on furniture and
furnishings in the U.S. These include Firemaster 550, the non-halogenated organophosphates and the
chlorinated organophosphates. In spite of widespread human exposures to these compounds, evaluation
of their health effects is extremely limited. In sharp contrast to the extensive epidemiologic research on
the health effects of PBDEs, there have only been two, small epidemiologic studies conducted in men
that have evaluated the endocrine disrupting effects associated with exposures to chlorinated
organophosphates. In vitro analyses have also been conducted to evaluate risk of endocrine disrupting
potential and a number of the compounds have been tested in zebrafish as well as other fish models. The
zebrafish model is an established relatively high-throughput model for evaluating developmental and
neurotoxic effects (81) but its relevance to human health has not been fully characterized. Risk of
carcinogenicity and mutagenicity has been assessed in experimental bioassays for some of the
chlorinated flame retardants. Based on results of this body of literature, a recent review concluded that
due to adverse health effects, none of the flame retardants currently used on furniture and furnishings in
the U.S. are recommended as suitable replacements for the PBDEs (82). The only compound that was
recommended was MMP Mix but it is generally contaminated by TPP, which has been shown to be an
endocrine disruptor, teratogen and developmental and reproductive toxicant (81, 83). However, caution

18
should be used when interpreting this recommendation given that data on the health effects of the
current use flame retardants are limited as described below.
6.2.1 Firemaster 550
Firemaster 550 has been marketed as a replacement for PBDEs and is currently the second most
commonly detected flame retardant in polyurethane foam in the U.S. (84, 85). Relatively little is known
about its potential for toxicity (81) and to date, no epidemiological studies have been conducted on the
health effects of Firemaster 550. A recent analysis found the mixture contains TPP, TPP isomers and
two brominated compounds, TBB and TBPH (86). The latter are high production chemicals and have
been shown to be genotoxic in fish models (reviewed in (87)). In vitro studies suggest TBB and TBPH
are endocrine disruptors that interact with estrogen and androgen receptors and alter hormone synthesis
(88). A recent exploratory study in rats found that exposure to Firemaster 550 during gestation and
lactation increased serum T4 levels in the dams and resulted in advanced female puberty, weight gain in
both sexes, changes consistent with metabolic syndrome and altered exploratory behaviors among the
offspring (86). Results from a medaka fish model also suggest TBB and TBPH impair fecundity (84).
TPP may be a teratogen based on preliminary data using a zebrafish model and is also a potential
endocrine disruptor and developmental toxicant (81, 82, 89).
6.2.2 Non-Halogenated OPFRs
Little information is available on the toxicity of MPP Mix. TPP is a primary component of MPP Mix
and as discussed below is associated with potential toxicities.
6.2.3 Chlorinated OPFRs
Four chlorinated organophosphates are used as flame retardants in furniture and furnishing of which
TDCPP is the most studied. To date, only two epidemiological studies have examined the relationship
between chlorinated organophosphate flame retardants and health endpoints in humans. Meeker et al.
(83) conducted a cross-sectional analysis to examine the association between TDCPP and TPP analyzed
in household dust with thyroid hormone levels and semen quality parameters. Men between the ages of
18 and 54 years were recruited from a U.S. infertility clinic either because they or their partner were
infertile. Of those enrolled, dust from 50 households was analyzed for TDCPP and TPP. Blood and
semen were analyzed for hormones (serum luteinizing hormone, follicle-stimulating hormones,
estradiol, prolactin, and thyroid hormones) and semen quality (concentration, mobility, morphology),
respectively. The authors detected the following significant associations: 1) TDCPP was associated with
decreased free T4 and increased prolactin and, 2) TPP was associated with decrease in sperm
concentration. Based on these findings, the authors conclude chlorinated organophosphate flame
retardants measured in house dust may be associated with altered hormone levels and sperm
concentrations.
An observational study based in Japan examined associations between 11 organophosphate flame
retardants measured in house dust (n=182) with asthma and allergies among the residents. In adjusted
analyses, the researchers found significant associations between TCPP and TDCPP with an increased
odds of atopic dermatitis (90).
In animal studies, researchers have shown TDCPP to be carcinogenic and mutagenic in rats, leading to
its classification as a carcinogen by the CPSC and the World Health Organization (WHO) (82, 87).
Based on dermal exposure, the CPSC estimated a lifetime cancer risk from use of TDCPP in furniture

19
foam of three cancers per 10,000 individuals (3 X 10-4
) (87). TDCPP has also been shown to be a
teratogen, endocrine disruptor and neurotoxicant in zebrafish models and in in vitro models (81, 82, 91).
TCPP and TCEP are carcinogens in experimental bioassays. TCPP alters neurodifferentiation in
zebrafish models and TCEP has been shown to be neurotoxic to rats and mice and to induce adverse
reproductive effects in rats (reviewed in (82). Fewer data are available on V6 and may be less toxic,
however there are some indications that it may act as an endocrine disruptor. Additionally the V6 mix
contains TPP which has evidence of toxicity as described above.
In conclusion, the extensive data gaps that exist for most of the current-use flame retardants make
assessment of their potential health effects extremely challenging. Given the evidence of carcinogenicity
for a number of the chlorinated flame retardants (TDCPP, TCPP and TCEP) it is prudent to avoidance
use of these compounds pending additional research to more fully characterize the dose-response
relationships. All of the remaining current-use flame retardants have at least some evidence of toxicity.
Thus is it not possible at this time to identify any that can currently be considered safe until additional
research is undertaken to fill the substantial data gaps.
7. Indoor Air Sampling For the Current Use Flame Retardants
As there has been extremely limited prior air sampling for the current-use flame retardants, we
conducted indoor air samples over two weeks in the conference room at the Department of
Environmental Health Sciences (EHS) at Columbia University Mailman School of Public Health. The
EHS Department was recently renovated and the furniture was
purchased after the phase out of PBDEs. The current furniture
meets the CAL 117 standard given that the room contains a
sprinkler system. The air sampling was conducted at 1.5 liters
per minute over two weeks (336 hours with a total of 30.2
cubic meters of air drawn through the samplers). We collected
fine particulates <2.5 µm on a quartz microfiber filter and semi-
volatile vapors and aerosols on polyurethane foam (PUF) plug
backup. The samplers were prepared at Southwest Research
Institute and were precleaned prior to use in Soxhlet extractors,
first for 24 hours with high-purity acetone, next for 48 hours
with high-purity hexane, again for 24 hours with acetone, and
then dried with purified nitrogen. At the conclusion of the two
weeks, the samplers were frozen and shipped, along with a field
blank, on dry ice to the laboratory of Dr. Heather Stapleton at
Duke University for analysis. We included a field blank as the
flame retardants are ubiquitous and we anticipated the
possibility of contamination within the sampling train. The
filters and PUF plug were Soxhlet extracted using 50-50 hexane:acetone for 16 hours. Isotopically
labeled standards were spiked in the samples prior to extraction. Extracts were concentrated to about 1.0
ml and analyzed directly by gas chromatography-mass spectrometry (GS/MS). Compounds measured
included three chlorinated organophosphates (TDCPP, TCEP, TCPP) and TPP since it is a constituent of
the other types of current-use flame retardants. We extracted the ng/extract of each compound detected
in the field blanks from the ng/extract of each compound detected from the two air samples prior to
calculating final concentrations. Results are presented in Table 4 below.
Figure 2. Air sampling set up

20
As can be seen, the chlorinated organophosphate flame retardants were detected in the field blank
indicating that there was contamination at some point along the sampling train. However, concentration
were lower than it the two air samples. Results from the two air samples indicate that the chlorinated
organophosphate flame retardants were used on the furniture in this room and are able to volatilize into
the surrounding air. We did not detect PBDEs or Firemaster 550 in our samples, however, we cannot
conclude the absence of these chemicals based on our findings, only that they were not present in the air.
TCPP was detected at much higher concentrations that the other two chlorinated organophosphates
indicating that it was the main flame retardant used as volatilities are reasonably comparable: all are
semi-volatile; vapor pressure of TCEP > TCPP > TDCPP. As discussed above, both TDCPP and TCEP
are carcinogens in experimental bioassays and are associated with other potential adverse health effects.
No studies have assessed the carcinogenicity of TCPP but the EU has concluded that it should be
considered a potential carcinogen given that its structure is similar to TDCPP and TCEP. TCPP also has
other potential adverse health effects. Data do not exist to conduct any risk assessments for these
compounds via inhalation exposure.
8. Efficacy
Fires are complex and vary enormously depending on a number of factors that either increase or
decrease the intensity of the fire. Flame retardants are designed to delay or inhibit combustion, a four
step process that includes: preheating, volatilization/decomposition, combustion, and propagation or
spread of the fire (92). Flame retardants, depending on the specific mode of action, can act at any step
in the process. For example, halogenated flame retardants capture free radicals, which are produced
during the combustion phase and necessary for fire propagation (93) and organophosphate flame
retardants increase char formation during burning, thus creating a physical barrier between the ignition
source and the material, which slows the burning process (13). Flammability standards vary in design
and by the method for testing a material. A material may perform differently given variable conditions,
such as the source, duration, or location of a flame or heat source (94). As previously reviewed, some
standards, such as CAL 117, require that individual components, such as flexible polyurethane foam and
other filling materials in furniture withstand a small open flame (95). Other standards require testing of
the entire manufactured article. Given the variability and complexity of fires, a single standard that
mandates testing the performance of an uncovered material when exposed to a small, open flame may
not reflect the overall flammability of the product (96).
The implementation of different flammability standards has led to the increased use of flame retardants
over the last 30 years. However, it is uncertain whether these standards, such as CAL 117, are effective
at preventing fires (94). Flame retardant manufacturers continually point to a large, government funded
study to back their claim that flame retardants increase the duration of time to escape fires by 15-fold,
thereby serving as an effective method for reducing residential fires and saving lives. Yet, the lead
Table 4. Flame retardants detected in the EHS conference room (ng/m
3
)
Sample 1 Sample 2
TDCPP 0.60 1.10
TCEP 4.06 2.13
TCPP 348.5 490.4
TPP <MDL <MDL

21
author of the study, Vytenis Babrauskas, states that industry officials grossly distort the research
findings (16). In fact, the often cited study did not examine CAL 117, which industry was defending.
Rather, the study surveyed materials containing flame retardant formulations at significantly higher
concentrations than would be required to meet CAL 117 (94). Moreover, the study tested fully
furnished rooms in which numerous combustibles were incinerated (97), conditions that are drastically
different than those used to test the CAL 117 standard (94).
Earlier work by Babrauskas (1983) at the National Bureau of Standards showed that subsequent to
ignition, there was no significant difference in important fire hazard indicators between untreated
furniture and CAL 117-compliant furniture treated with flame retardants (98). A small flame source was
able to ignite both CAL 117-compliant furniture and non-compliant furniture, and, once ignited, there
was no difference in fire hazards for either type (99). Taken together, this research suggests that CAL
117 is an ineffective standard to reduce small scale furniture ignitions, and thus is not an effective
approach for increasing fire safety (94, 100). Furthermore, the use of flame retardants has been shown to
increase toxic fire effluents during combustion. During a fire, carbon monoxide is converted to carbon
dioxide through a reaction with hydroxyl radicals. Halogenated flame retardants prevent this reaction,
increasing the yield of carbon monoxide (101). Flame retardants also inhibit the conversion of other
hydrocarbons to carbon dioxide and water, significantly increasing smoke yield. Thus, in addition to the
health effects of chronic exposure to these flame retardants reviewed in Section 6, flame retardants
increase fire effluents, such as carbon monoxide, soot, and irritant gases, which collectively contribute to
fire deaths and fire-related injuries by hindering the ability to escape (94, 102).
A primary piece of evidence cited by the flame retardant industry consists of data from a Swedish
document that have been incorrectly extrapolated (16). The 50 page report, written by a Swedish federal
board, examined the number of total electrical fires in Sweden by analyzing the cause of fires in Western
Stockholm in 1995 and 1996. Despite study conclusions that electrical fires were less common than
previously thought, the chemical industry focused on the fact that one-fourth of the fires were caused by
televisions (16). Industry researchers extrapolated these results to calculate Europe’s total number of
television fires per million sets annually. They concluded the results were much higher than rates found
in the U.S. (16). The logical explanation, in their opinion, was that this was due to the application of
flame retardants to U.S. televisions.
The industry’s process of calculating and comparing television fires per million sets was fundamentally
flawed and disregarded the basic principle that broad conclusions should not be drawn from small or
unrepresentative samples (94). Furthermore, this model—known as the Simonson model—only
considered television fires due to internal ignition (94). By only accounting for a single type of ignition,
the number of fires was reduced from 13 per million sets to 5 per million sets. In contrast, the model did
not restrict television fires that occurred in Europe to internal ignition fires. Ultimately, the model used
dissimilar data sources, which skewed the results unreasonably low and high for the U.S. and Europe,
respectively.
Alternative fire prevention methods, such as smoldering “fire-safe” cigarettes, can prevent fires and
reduce the unnecessary addition of hazardous chemicals to residential products. Although the use of
flame retardants has increased over the years, rates of smoking have decreased. There has been a 60%
decrease in fire deaths in the U.S. since 1980, which parallels the decrease in cigarette smoking (94).
The importance of this secular trend is highlighted by Shaw et al. (2010), who state, “the reduction of

22
smoking, through a combination of education, taxation, and location restriction policies has proven the
single most effective fire safety strategy” (87). Furthermore, other fire safety mechanisms, such as
improved building, fire and electrical codes, smoke detectors, and sprinkler systems have contributed to
the decrease in U.S. fire deaths. Collectively, these trends suggest that the decrease in fire deaths and
office fires, as noted in the graph below, can be largely attributed to the decrease in smoking and
improved fire safety mechanisms--rather than the increased use of flame retardants.
Figure 3. Office property fires by year, 1980-2011 (Adapted from: (103))
9. Alternatives
Mounting concerns regarding the widespread use and associated health effects of flame retardants have
fueled the creation and implementation of flame retardant alternatives. The U.S. government and the
European Commission have each invested in initiatives to create and identify flame retardant
alternatives. Under the jurisdiction of the EPA, the Design for the Environment (DfE) program helps
identify alternatives for multiple chemicals that perform as well or better than current chemicals, and are
safer for human health and the environment. Owing to the reduced stringency of CAL 117-2013, many
of these alternatives enable companies to pass flammability tests without the use of chemicals. As part
of this program, assessments of alternatives have been conducted. Results provide evidence that
encourage chemical companies to switch to safer methods for meeting current flammability standards
(104). The DfE has performed assessments analyzing alternatives for decaBDE as well as flame
retardants used in flexible polyurethane foam (105, 106).
The European Commission has also invested in a similar program that focuses on identifying and
analyzing substitution options for specific brominated flame retardants. ENFIRO assesses the production
and application, environmental safety, and the life cycle of potential alternative options (107). This
project uses an approach that provides an environment-compatible substitution that is viable for use by
the industry, and can be used for other substitution studies performed under Registration, Evaluation,
Authorization, and Restriction of Chemicals (REACH), the EU’s regulation focused on chemical
identification and safety (107). Using a top-down approach, the U.S. and Europe look to begin the
process of identification and implementation of alternatives to substitute harmful flame retardant
products that are currently in extensive distribution and production.

23
9.1 Alternative Chemicals
While health and environmental considerations are important when selecting an alternative chemical
flame retardant, foam quality should also be considered. For this reason, the most environmentally
sound options may not be the most practical. Balancing the most practical with the healthiest option is
part of this complex decision making process.
In addition to balancing the practical aspects with the environmental aspects of alternative flame
retardants, the mode of exposure for the general population is also important. Gaseous flame retardants
generally do not exist outside of the manufacturing arena, therefore, exposures to liquid and solid forms
of flame retardants are of primary concern to the general public (108). Inhalation is the greatest concern,
because liquid chemicals can be inhaled if vaporized, and solids may break down into small particulate
that can be inspired. Inhalation of the dust that contains this small particulate is one of the main routes of
exposure, as simply sitting on a piece of furniture can release it into the air. Additionally, dermal
exposure can result from handling materials treated with flame retardant chemicals. Ingestion can occur
if the chemical, or its byproducts, makes its way into the water supply or bioaccumulates in consumable
aquatic organisms. Additionally, children can ingest the dust containing flame retardant particulate, as
they have high hand to mouth contact.
The EPA has identified two positive flame retardant attributes, high biodegradability and low
bioaccumulation/bioavailability potential, that inform the chemical’s life cycle (108). Emphasizing
products treated with chemicals that adhere to these attributes will lead to potentially safer and greener
choices. The use of readily biodegradable chemicals in flame retardants increases their environmental
friendliness as these chemicals dissolve more quickly in treatment plants and are thus less pervasive in
the environment. However, it is also important to consider potential breakdown products as these may
be more harmful than the parent compounds.
Similar to biodegradation byproducts, effluent caused by combustion of flame retardant chemicals is a
concern. If furniture burns in a fire, or if products using chemical flame retardants are destroyed in an
incinerator, potentially harmful byproducts can be released into the environment. Consequently, when
selecting furnishings for residential or commercial use, consideration of not just the primary flame
retardant chemicals used, but the potential for these compounds to release noxious compounds into the
environment when they are burned is prudent.
The second positive attribute for flame retardants is low bioaccumulation potential and low
bioavailability. This dual attribute can be met by using chemicals that both have large molecular size
and high molecular weight. Large molecules are less likely to be passively absorbed by aquatic animals,
and heavy molecules tend to be less volatile. When possible, it is preferable to select chemicals that have
a low bioconcentration factor. However, these data are not always available, therefore environmentally
conscious companies typically rely on an octanol-water partition coefficient. Chemicals with a
coefficient of greater than eight have a lower, and more desirable, bioaccumulation potential (96).
Additionally, flame retardants that are incorporated into the product at the beginning of the
manufacturing process are generally more tightly bound to the foam substrate and consequently are less
likely to leach into the environment where they can bioaccumulate in animals and be inhaled or ingested
by humans. Further, additives that are mixed in the manufacturing of a product have greater potential to

24
bioaccumulate, as they are not as tightly bound to the foam. Therefore, selecting products that do not use
additives, or use fewer of them is another way to mitigate hazards to environmental and human health
(96).
9.2 Alternative Policy & Technologies
Cover fabrics and barrier technologies can reduce fire propagation by preventing the ignition source
from reaching the inner foam of a piece of furniture (108). Consequently, the risk of releasing harmful
combustion byproducts is reduced. As discussed previously, the intent of CAL 117-2013 is to “produce
upholstered furniture which is safer from the hazards associated with smoldering ignition”. Importantly,
the standard is intended to be met using cover fabrics and barrier methods that do not include flame
retardants (109). Three types of barrier materials that could be used to meet CAL117-2013 are outlined
below.
One current approach to creating flame retardant barrier materials makes use of nanomaterials (110).
Nanomaterials are inherently non-flammable fabrics that have flame retardants directly incorporated into
the textiles themselves, as opposed to being sprayed on to the surface. Nanoclays are another burgeoning
approach to flame retardants. By incorporating naturally-occurring montmorillonite clay into fabrics,
manufacturers can significantly slow the breakdown of material and the release of combustible
molecules.
Graphite impregnated foam is another alternative technology (96). It is self-extinguishing and highly
resistant to combustion. Although it is a newer technology and caters primarily to niche markets, such as
airplane seating, it can be used to design comfortable and attractive seating arrangements. This is in
comparison to furniture designs that simply exclude the use of filling or fabric altogether, which would
be uncomfortable.
Surface treatments of furniture are a third alternative, however they may not be cost effective as
treatments may wash off or degrade over time, giving rise to concerns regarding environmental
contamination and dermal exposure (110). Additionally, the process of achieving uniform distribution of
the treatment and then allowing it to dry is time consuming and expensive.
Finally, the Natural Resources Defense Council (NRDC) has compiled a fact sheet identifying major
furniture purveyors that meet the CAL117-2013 standard without using flame retardant chemicals (1). In
a survey of major furniture stores, the NRDC asked whether each store had plans to manufacture
furniture that was CAL117-2013 compliant without using chemicals, as well as how the store planned
on making these furniture items identifiable to customers. While not all of the companies responded to
the survey request, the results indicate that at least six of the major retailers contacted are moving
towards removing flame retardants from their products while maintaining crucial fire safety standards.
9.3 Indirect Alternatives
Finally, architectural changes such as increased sprinkler coverage can serve to reduce the need for
flame retardants in furniture. Enforcing policies that prevent the use of dangerous products, such as
halogen desk lamps, in offices can also mitigate the need to use flame retardant chemicals. Though
inherently flame-resistant alternatives are available, they are typically prohibitively expensive. Research

25
continues to move forward to develop safe flame retardants for use in furniture and furnishings that are
also economically feasible for consumer products.
10. Disposal
As discussed, flame retardants enter the environment as a result of their additive nature, are resistant to
breakdown and are easily transported throughout the environment. For example, research has
documented increasing levels in the Arctic environment, despite the limited production of these
chemicals in close proximity to Arctic regions. Flame retardants can also be released into the
environment when the manufactured products are burned or discarded in areas of sunlight exposure
(111). When these materials are burned or discarded in dumps and exposed to sunlight, the plastics melt
and release the residue they were manufactured with (111). Due to the long lifespan of these products, it
is likely that these chemicals will continue to pervade food chains and the global environment. As tons
of flame retardant containing materials have been dumped in landfills, and continue to be dumped to this
day, the need for safer disposal of such materials is a priority.
Currently, there are three conventional methods for disposing of flame retardant-containing furniture:
(1) landfilling, (2) reuse & recycling, and (3) incineration (87). Landfilling is the most common form of
disposal, as it is the cheapest and easiest option of the three. Even though complex landfill linings exist
to prevent leaching of material from landfills, the lifespan of these linings is limited. Furthermore, as
flame retardants are not categorized as ‘hazardous waste’, they are not prioritized for safety by landfill
regulations (112). This also means that air monitoring for detection of flame retardant chemicals is not
required for landfills. Owing to this dearth of regulation, little effort has been put into the development
of safe disposal technologies for materials with flame retardants. Until flame retardants are federally
classified as hazardous waste, emphasis on reducing production is the best option for reducing
environmental contamination and human exposure.
With the increased option of buying furniture without flame retardants, reuse and recycling has become
the second most common form of conventional disposal methods. However, as many families who can
afford to replace their furniture donate their old items for second-hand use, the burden of this harmful
exposure falls disproportionately on economically disadvantaged populations, which is an
environmental justice concern (112). These patterns likely contribute to higher body burns for these
populations, whom are predisposed to living near landfills and thus obtaining higher exposures from
landfill leaching. As mentioned by Jason Schneider (112), reuse and recycling is not the proper method
to reduce exposure to and circulation of flame retardants, especially as furniture and industry
manufacturers claim that each owner of a piece of furniture will likely hold onto that piece for about ten
to fifteen years.
Although proper disposal options are limited, the most promising technology for responsible disposal of
furniture with flame retardant chemicals is incineration and combustion. However, it is important that
these incineration methods be carefully controlled to prevent the release of any associated and harmful
by-products, including dioxins and dibenzofurans (112). Further development of these emerging
methods is critical to the process of reducing worldwide exposure to flame retardants.

26
11. Recommendations
11.1 Recommendations for Columbia University Fire Safety
First and foremost we recommend that Columbia University avoids purchasing furniture treated with
chlorinated organophosphate flame retardants that have been associated with evidence of
carcinogenicity until further research is conducted to assess the dose-response relationships. Second,
Columbia should continue to evaluate information that becomes available on the remaining flame
retardants currently used in furniture and furnishings as there are currently significant data gaps and we
are unable to determine whether any can be considered safe, given the limited data available and
preliminary evidence of toxicity on all of the compounds. As more adverse health effects of flame
retardants become apparent and alternative methods such as sprinklers and barriers are considered more
efficacious, Columbia University should continue to shift policies away from requiring flame retardant
applications on upholstered furniture. Below are plausible options to decrease flame retardant exposures
for Columbia University staff, faculty, and students:
1. If New York City adjusts the Fire Code to meet CAL 117-2013 for assembly and dormitory
occupancies, Columbia University can adjust the Fire Safety Policy to mirror these changes and
allow for less-stringent flame retardant application. Additionally, any space that is protected by an
automatic sprinkler system can then be required to meet the CAL 117-2013 standards rather than
CAL 117 or CAL 133.
2. There is a current exemption in the New York City Fire Code and Columbia University Fire Safety
Code for offices, public areas, and areas of public assembly to comply with CAL 117 requirements
instead of CAL 133 requirements if protected by an automatic sprinkler system (29). Therefore, we
recommend increasing sprinkler system installation in these spaces wherever feasible. While
expensive, increasing the amount of public areas with automatic sprinkler systems will allow for
legal exemption within the current policy framework and does not rely on larger New York City Fire
Code amendments (29). Furthermore, retrofitting older buildings to include automatic sprinkler
systems would make Columbia University eligible to receive insurance premium credits, thus
making retrofitting financially appealing.
3. Likewise, we recommend conducting a cost-benefit analysis to determine the true cost of university
fires, the true cost of retrofitting university buildings, and the true cost of alternative barrier methods.
This information will help determine the most cost-effective method for reducing fires and flame
retardant exposure.
4. Lastly, we recommend that the University advocate for financial support from both the local and
state governments to assist in updating the furniture and furnishings used across the Columbia
University campuses.
11.2 Disposal Recommendations
It is important to recognize that any furniture Columbia University believes should be replaced with
flame retardant free furniture must be disposed of safely and responsibly. However, as flame retardants

27
are not classified as hazardous material by the government, there are no existing protocols for disposal
of these chemicals. The majority of flame retardant-containing furniture is discarded into landfills,
where the chemicals can leach out into the environment, contaminate food chains, and further expose
human populations.
The safest method for disposal of halogenated flame retardants is likely through use of polychlorinated
biphenyl (PCB) incinerators. PCBs were widely used in applications requiring flame retardant materials
until the 1970s. These compounds were banned in 1978 under the Toxic Substances Control Act due to
their toxicity, persistence, and accumulation in the environment (113). As a result of this regulation,
specific disposal methods, such as high-heat incinerators, are required for disposal of materials made
with PCBs (113). These incinerators must reach very high temperatures and have complex filters to
ensure that toxic effluents are not released from this process. As flame retardants, such as PBDEs, have
similar chemical structures to PCBs, it is reasonable to assume that these incinerators are the safest
method for disposal of other halogenated flame retardants. As of October 2011, there are seven PCB
incinerators in the country, although none are located in New York or the surrounding states (114).
11.3 Alternative Recommendations
Under CAL117-2013, furniture companies can use alternative technologies to meet flame resistance
requirements. These technologies have been implemented, or are going to be implemented, by multiple
furniture companies. The NRDC performed a survey in 2014 to determine the extent of flame retardant-
free furniture distribution by major furniture companies (1). This survey found there are eight major
furniture companies that sell furniture without flame retardant additives, although the number of
companies continues to grow. The companies identified by the NRDC include: The Futon Shop, Crate &
Barrel, La-Z-Boy, Williams-Sonoma, IKEA, and Interline. These companies and an additional two
companies, Ethan Allen and Wal-Mart, have also made a commitment to remove added flame retardants
from their furniture. However, this survey did not mention which alternatives these companies have
decided to implement.
Table 5. Furniture manufacturers that currently produce flame retardant free furniture
California Other states
§ Cisco Home (www.Ciscohome.net)
§ Eco-Terric (www.ecoterric.com)
§ EcoBalanza (www.greenerlifestyles.com
§ Ekla Home (www.eklahome.com)
§ Furnature (www.furnature.com)
§ Green Sofas (www.greensodas.com)
§ Viesso (www.viesso.com)
§ The Futon Shop (www.thefutonshop.com)
§ LEE Industries (www.leeindustries.com)
§ Corinthian (www.corinthianfurn.com)
§ Drexel Heritage (www.drexelheritage.com)
§ EcoSelect (www.ecoselectfurniture.com)
§ Endicott Home (www.condosofa.com)
§ LEE Industries (www.leeindustries.com)
As previously discussed there are currently three general types of alternatives that can be used to meet
fire safety standards under CAL117-2013, including barrier methods, graphite impregnated foam, and
surface treatments (115). Although regulation has allowed for the use of these alternatives, health and
environmental hazards associated with these alternatives have yet to be fully addressed and identified.

28
For example, one type of barrier method includes use of nanoclays, such as montmorillonite clay (110).
Although it has been shown to be an effective flame retardant, there are concerns that the small size of
these nanoclays could result in adverse health effects. One study concluded that the toxicity from
nanoclays appears to be minimal, however, more research is needed to fully understand their impact on
human and environmental health (110). Additionally, this study mentions nanoclays are less toxic than
surface treatments, which are costly, ineffective, and can leach into the environment (110, 115).
Furthermore, although graphite impregnated foam has been described as a good alternative to the use of
flame retardant chemicals, it has only been used in niche markets, such as airplane seating (115). As a
result, it may be difficult to apply this technology to the much more expansive residential and
commercial furniture industries.
Although increased use of alternative technologies are an important step away from the use of flame
retardant additives, data gaps regarding the efficacy and hazards of these alternatives is critical.
Furthermore, we recommend Columbia University makes an effort to further understand which
alternative technologies furniture companies are using to avoid chemical flame retardants. This
information is critical to informing which companies are the safest to purchase from.
Although flame retardants have been proven ineffective in preventing furniture fires and have been
linked to serious adverse health effects, they have been used in furniture for decades and continue to be
used. Therefore the U.S. population is ubiquitously exposed to measurable amounts of flame retardant
chemicals in their daily lives. California Technical Bulletin 117, and later California Technical Bulletin
133, encourage the use of a large volume of flame retardants in furniture and have become a precedent
for other states. New York City and New York State have fire resistant standards in line with the
National Fire Protection Association guidelines yet Columbia University has adopted the stricter
California Technical Bulletins. Columbia University’s strict adherence to these bulletins is endangering
the health of the students, faculty, and staff who work and live in these locations, while not providing
adequate fire protection as compensation. The above recommendations aim to mitigate some of the
potential adverse health effects associated with flame retardant exposure and should be seriously
considered by Columbia University.

29
CAL117
(A-PartII)
A13”x13”pilloworcushionexposedtoa1.5”flamefromaBunsenburnerfor12seconds.Topassthesamplemustnot
losemorethan5%inweight.Notethatshreddedpolyurethanefoams(pillowsorcushions)canbeflameretardantfoam.
CAL133Asquaregasburnerisplacedonthetestfurniture,ignited,andburnedfor80seconds.Consideredafullburntest
(compositetest).Temperature,masslossofthefurniture,concentrationsofcarbondioxide,unburnedhydrocarbons,
opacityofsmoke,andheatreleasebasedonoxygenconsumptionaretaken.Standardisintendedtocoverpublic
assemblyspaceswithmorethan10piecesofupholsteredfurnitureforseating.
CAL117-
2013
Smoldertest:eachmaterialismountedonaplywoodmock-upresemblingasmallchairandexposedtoalighted
cigarette.Threetests:1)CoverFabricTest,2)BarrierMaterialsTest,3)ResilientFillingMaterialsTest.Criteriatopass:
1)Continuestosmolderafter45minutesorcharofmorethan1.8”ortransitiontoanopenflame,2)Continuesto
smolderafter45minutesorcharofmorethan2”ortransitiontoanopenflame,3)Continuestosmolderortransitionsto
openflameorsubstratehasmorethan20%massloss.Note:standardisintendedtobeanalternativetoCAL117.
NYCSec805-
01&805-03
Test1orTest2,illustratedinNFPA701.AppliestodecorationsinanyGroupA,E,I,Moccupancy;commonareain
GroupR-1,R-2andBoccupancies;anybuildingorindoorspaceusedasapublicgatheringplace.
NFPA2671)Peakheatreleasemustnotexceed250kW,exceptifroomisfullysprinklered,2)Totalenergyreleasedinthefirst5
minutesofthetestshallnotexceed40mJ,exceptifroomisfullysprinklered.Appliedtomattressesandbedding
assemblies
NFPA70110samples3.5”x10”(5”x7”largescale)areconditionedinanovenbetween140-145degreesfor1hourandthen
exposedtoa0.5”flamefor12seconds(11”longflamefor2minutesforthelargescale).Smallscale:afterflamemaxis
2seconds,charlengthlessthan3”,nodripburnallowed.Largescale:afterflamemaxis2seconds,charlengthlessthan
10”,nodripburnallowed.Smallscaleandlargescalederivations.

30
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