HFPA Bucks Flammability Proposal
April 4, 2005,
New York — The Home Fashion Products Association (HFPA) has urged the Consumer Product Safety Commission (CPSC) to slow its move toward creating flammability regulations for bedding products until all needed analyses are completed.
In a report sent to CPSC prior to the March 14 cutoff date for responses to phase one of the three-part regulation process, Frank Foley, HFPA president, and president and CEO of CHF Industries, urged the commission to more thoroughly analyze current home fire data, as well as testing procedures and health challenges from flammability solutions before it decides to regulate.
"There is a rush to judgment under way that completely ignores the due diligence that should be conducted on this very important issue," Foley stated in an HFPA press release. "The CPSC has not thoroughly analyzed current home fire data and has not conducted comprehensive testing on the various combinations of products in question."
The HFPA emphasized that the current trend showing a decline in home fires and bedroom fires will be improved by regulatory action on the sources of fire, not bedding.
"Regulation of ignition sources and public education have already proven to significantly impact the issues in question, but this data has not been included in the CPSC analysis. We believe it must be," Foley said.
In addition, HFPA contends that a national mandatory standard would not accomplish its intended result, and the cost and economic impact — both factors that must be considered before a regulation can go into effect would outweigh any perceived benefit.
In making additional points to the commission, the HFPA first urged that any regulation "should be postponed indefinitely until meaningful testing is complete; the toxicity issue is fully addressed; and home fire data is brought up to date and fully analyzed."
A key point in the HFPA comments is the issue of toxicity of flame retardant chemicals, both on the consumer and the release of such chemicals into the environment. HFPA noted, "A number of chemicals used to protect against flammability have already been banned at the state level because they have proven to be toxic."
The issue of the many different combinations of textiles products used on beds also was addressed vis-a-vis a stand-alone testing standard or combinations of the different textiles used on a bed which require a multiple testing process.
"For example, it is very unlikely that sheets or other unfilled products by themselves would cause flashover," the HFPA's letter to the commission stated. "Likewise, down and feather bedding products disintegrate when exposed to open flame and do not burn long enough or hot enough to be an ignition source."
In line with these considerations, there are other products typically part of usual bed "clutter" such as plush toys, regular toys, newspapers, books, tissues and clothes, among others, that could serve as the igniting material — and thus render any bedding regulation meaningless, the HFPA argued.
The home textiles association also challenged the cost/benefit relationship. There have been no proposed "solutions" for industry members to analyze from a cost basis that would include the costs of testing, higher costs of shipping or inventory as well as the costs of application, the association wrote.
The testing expense, HFPA contends, would add "millions to the industry's costs, which will be passed on to the consumer." These include "the extraordinary number of possible combinations of fiber constructions and thread counts" of top-of-bed products, as well as the different fabrics and combinations of fabrics and fibers involved in testing each bedding ensemble.
The association also pointed to the outcome of the CPSC's regulation of children's sleepwear, concluding: " … consumers will not buy product that physically irritates their children or them, regardless of the benefit … . As with the sleepwear, consumers will find non-compliant (but more attractive) alternatives that will render any regulation ineffective and useless."
The loss of jobs both within the home textiles industry and in the supplier companies — such as fiber companies — would impact domestic product versus moving offshore to seek lower prices, the commentary pointed out.
In conclusion, HFPA believes that bedding/bedclothes "have not been proven an unreasonable risk of the occurrence of a fire leading to death, personal injury or significant property damage" and urged CPSC to do significantly more testing, including long term testing.
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