We have seen in the March 24 Newsletter that The Department for Business, Innovation and Skills is now making public its intention to revisit the UK furniture flammability regulations. Our organization has been in dialogue for some time with the authors of the new proposals and we would like to share our views with your readership by way of the following letter to the editor.
Flexible Foam Research Ltd is affiliated to the British Plastics Federation and represents the UK manufacturers of flexible polyurethane foam block in areas such as technical standards and regulatory matters. Over the last 30 years we have accrued substantial experience in the burning behaviour of full items of furniture.
We are writing to you to express our concern on proposed changes by the Department for Business Innovation and Skills (BIS) to the Furniture and Furnishings (Fire) (Safety) Regulations 1988 (FFRs) which, as we understand, will be presented to Parliament as an amendment to the current Regulations. We consider that, at the present time, the proposed changes are neither based on good science or in the public interest.
It is well-known from Government statistics that the introduction of the Regulations in 1988 led to substantially improved fire safety in the home. An independent report by Greenstreet Berman in 2009, carried out on behalf of BIS, on the effectiveness of the FFRs concluded 54 fewer deaths per year
and 780 fewer casualties.
Despite reassurances by BIS and the Parliamentary Under-Secretary of State - Employment Relations and Consumer Affairs that the new proposals will not reduce fire safety in the home, we believe there are conflicting arguments and significant concerns.
It is proposed to make the "match test" for upholstery fabrics easier to pass (by changing the test foam). In our view a test that is easier to pass is synonymous with a relaxation of fire safety.
1. BIS projects that this new test will allow reductions of 30-50% in the concentration of applied flame retardant (FR) treatments. All common sense and science says that this is also a relaxation of fire safety.
2. As justification for the changes, BIS estimates savings to industry of £50m/year but at the present time no supporting evidence has been presented to justify this figure.
3. It is claimed that FR reductions will bring benefits in abstract terms but no risk-benefit study has been presented.
4. The development of a match ignition test based on combustion modified reference foam is fraught with new technical and legal enforcement difficulties. There are good reasons for anticipating fabric test result variability caused by differences in content and type of FR additives in the foam and indeed the foaming technology itself. On the back of such variables we would expect to see the failure of many more non-compliance prosecutions together with an increase in misleadingly contrived "pass" certificates.
5. It is assumed that on the back of 30-50% FR reductions, fabrics will automatically resist smouldering ignition and therefore that the cigarette test can be deleted. There is as yet no scientific evidence to support this intention; it could actually constitute a further fire safety reduction and it needs to be clearly understood that open flame and smouldering ignition are fundamentally different in mechanism rather than severity.
6. Small-scale tests for ignitability can show (on an individual basis) the new level of FR additive needed for a fabric to pass the new test but much additional research is required. The tests within the Furniture and Furnishings Fire Safety Regulations do not implicitly measure fire safety, only ignitability. The true impact of revised legislation on overall fire behaviour (rate of fire growth, escape time, time to flashover) can only be understood by post-ignition monitoring of full furniture items.
7. The FFRs deliberately set out to require that furniture fabrics be both match resistant and match protective. The proposed new test deletes the match protection requirement which means that it would underwrite a return to fully melting fabrics. It is well-known that melting fabrics can create liquid pools that intensify flames, and potentially spread fire to other room contents. This is a very clear fire safety reduction, which in our opinion will inevitably increase casualty rates.
8. It is apparent from Trading Standards activity and media attention (e.g. BBC "Fake Britain" and Watchdog "Test House") that there have been worrying enforcement gaps and too many infringements of the FFRs in recent years. To relax the existing requirements in this climate is a clear disconnect and a totally wrong message. Since FR treatments have been inconsistent and variable on some fabrics for some time, legitimising further reduction via an easier test will increase the impact of new non-compliances, creating an even greater life threat than exists today.
9. In addition, since match ignition of cover fabrics will inevitably result in full-scale furniture and room contents fires, we stress that non-conformance of a non-protective cover would be a more dangerous situation than non-conformance of a protective cover.
10. BIS is proposing new control measures for previously unregulated items. We support this strongly because modern furniture is known to contain items with little or no ignition resistance that can become significant sources of secondary ignition. However, the detailed test methodology has yet to emerge and we fear that ultimately stakeholders will consider it to be unfeasible. Ongoing use of such items under melting as opposed to protective covers would be a very clear fire safety reduction.
UK furniture is intended to be both cigarette and match resistant, but we still have 200+ fire fatalities per year in the UK. Instead of relaxing FFR requirements we would much prefer to see Government understanding and remedying this situation.
Please note that any negative effects of FFR changes would be slow to emerge in fire statistics and could be undetected for several years. Any implementations necessary to reverse such trends would be equally slow to take effect. Does the UK Parliament really wish to put more lives at risk when compliance with existing provisions has such a good track record?
On behalf of Flexible Foam Research Ltd
Dr David King
Director- Technical Services
Dr David Waite
Director and Company Secretary