“Look before you leap” has long been considered sage advice. But environmental activist today called on regulators at the Consumer Product Safety Commission (CPSC) to take a leap of faith and ban an entire class of flame retardant chemicals because they believe the chemicals are dangerous. These groups lack data to prove their claims, so they want the commission to rely on junk science to fill “data gaps.”
Today’s hearings addressed a petition filed by the group Earth Justice and other anti-chemical activists. It called on CPSC to ban the use of all “organohalogen” flame retardants in upholstered furniture sold for home use in mattresses, mattress pads, and in the plastic casing of all electronic devices. The agency held a hearing at the end of 2015 and commission staff completed a report last spring that recommended that the five commissioners deny the petition in good measure because they don’t have data to support a ban.
In the absence of conclusive science, activist have made unsupportable claims in their petition and at hearings to support their case. These allegations can be lumped into three main arguments: 1) All organohalogen chemicals are basically the same; 2) these chemicals don’t work well to slow or prevent fires; and 3) the chemicals pose unacceptable health risks because trace amounts appear in human blood and tissue. Alleged health effects from such trace exposures include cancer, disruption of human endocrine systems, and neurodevelopmental problems such as autism.
Let’s look at each of these claims individually.
First, it’s nonsense to suggest that all organohalogens are basically the same. This class of compounds includes both naturally occurring and synthetic chemicals containing at least one halogen (fluorine, chlorine, bromine, or iodine) bonded to carbon. Each organohalogen has unique properties. While some may pose some health risks, some even have beneficial health effects. For example, in a 2004 American Scientist article, Dartmouth University chemist Gordon Gribble points out that organohalogens are useful as antibiotics, other medicines, and as natural pesticides.
Hence, the risks and benefits of each are distinct and depend on a wide range of factors, such as exposure levels. Accordingly, any regulation should consider each specific chemical separately, which is what CPSC staff have noted along with a recommendation that the commissioners reject the petition.
Second, while there is a debate among fire safety experts about how effective certain flame retardants are within various applications, data exists to show that these products have life-saving value in many applications. The American Council on Science and Health documents numerous life-saving applications in a report on the topic.
Similarly, fire scientist Matthew Blais, Ph.D., details his research on how flame retardants slow the progression of fires, allowing people more time to escape or to extinguish the fire. One recent study, he notes, “found that when flame retardants are used in couches, the fire was delayed by six to seven minutes. When foam in the couch contained both a flame retardant and a flame-resistant cover, the fire quickly self-extinguished. And when flame retardants weren’t used in couches, the whole room was consumed by fire within three minutes.”
Finally, mere exposure to a substance does not necessarily pose risks, even when traces of chemicals appear in the human body. The Centers for Disease Control and Prevention (CDC) has explained: “The presence of an environmental chemical in people’s blood or urine does not mean that it will cause effects or disease. … Small amounts may be of no health consequence, whereas larger amounts may cause adverse health effects.” Indeed, there isn’t much data to support the existence of any actual health impacts from these trace exposures.
Consider the alleged cancer risks. Supposedly, some of the most dangerous organohalogens are the Polybrominated Diphenyl Ethers (PBDEs) flame retardants. Yet the Agency for Toxic Substances Disease Registry’s public health statement on PBDEs notes: “Nothing definite is known about the health effects of PBDEs in people. The majority of information regarding toxicity of PBDEs and their breakdown products (metabolites) is from animal studies.”
That means rodent tests are the primary “evidence” that these chemicals pose cancer risks to humans. But rodent tests, which administer very high levels of chemicals to the animals, are not particularly relevant to humans exposed to trace levels. After all, it is the dose that makes the poison. In fact, rodents also get tumors from very high doses of chemicals found naturally in healthy foods, like broccoli, carrots, and plums.
Nor are activists able to demonstrate health impacts as so-called “endocrine disrupters,” i.e., hormonally active chemicals that can disrupt normal biological processes in the human body and result in adverse health effects. A 2000 National Research Council report on such “hormonally active agents” shows that synthetic chemicals used in consumer products are both too weak and exposures too low to pose any significant risks.
If such weak trace chemicals could impact our endocrine systems, then the real focus of concern should be on Mother Nature. Consider the fact that plants naturally produce hormonally active agents called phytoestrogens, and they are common in foods such as corn, soy and nuts. Human exposure to these naturally occurring chemicals is tens of thousands of times higher than that of synthetic chemicals, and the phytoestrogens are thousands of times more potent as well. Yet humans consume these chemicals every day without adverse effects.
Activist allegations that organohalogens can affect neurodevelopment and contribute to increased rates of autism also falls apart under scrutiny. For example, during December 2015 CPSC hearings, Maureen Swanson of the Healthy Children Project for the Learning Disabilities Association of America exclaimed: “We are witnessing an alarming increase in neurodevelopmental disorders that cannot be fully explained by changes in awareness or diagnosis.” She suggested that organohalogens are partly to blame for these trends, and therefore deserve to be banned.
While the number of autism cases reported may have increased in recent years, there are some not-so-alarming explanations. In a review of the research on this topic, Eric Fombonne, M.D., of McGill University’s Department of Psychiatry finds: “Although it is clear that prevalence estimates have gone up over time, this increase most likely represents changes in the concepts, definitions, service availability, and awareness of autistic-spectrum disorders in both the lay and professional public.” So the “alarming” autism trends that Swanson pins to flame retardants don’t even exist.
Meanwhile, there are documented cases of people dying in fires every year. According to the U.S. Fire Administration, 3,362 people died in fires in 2015, but there are no documented cases of people getting sick or dying from trace exposures to flame retardants. And that’s hard data that the Commissioners should consider.
After all, flame retardant chemicals are used to reduce real risks, and blindly banning them could prove more to be the more dangerous choice.