I’ve been looking at some of the history of the regulation requiring fire retardants in bedding material/mattresses.

During rulemaking, people submitted comments for which the Consumer Products Safety Commission developed responses.

Below is an interesting comment and response (from the Federal Register, January 13, 2005, Volume 70, No. 9, Pages 2469 – 2514). I need to study the risk assessment (apparently done as a part of this rulemaking), but the comment response does not refer to a risk assessment, and indicates that the regulators will rely on finding any problems after the fact, rather than examining carefully all possible fire retardation methods, including chemicals and their potential health effects. And they conclude there’s no need to bother telling people what their beds are made of, either. Strange behavior for an open society.

6. Comment. A commenter expressed concerns about environmental
impact and consumer sensitivity to flame retardants that may be used in
mattresses, whether topically applied or integrated into fibers. The
commenter recommends requiring a label that discloses the use of flame
retardants in the mattress and provides a source of more specific
information.

Response. Mattress fire performance can be improved by
incorporating fire retardant chemicals into component materials or by
using materials that are inherently fire resistant. Flame retardant
chemicals are already widely used in other applications. More than one
billion pounds of different flame retardant chemicals are currently
used annually in the United States, including applications in many
consumer products. There are also flame resistant (FR) materials that
may be used for mattress barriers that have other consumer product
applications. For example, melamine resins, which can be used in FR
barriers, are also used in many laminated counter tops.
Based on available data, the Commission believes that there are
available options for meeting the standard without posing an
unacceptable health risk to consumers or significantly affecting the
environment. Moreover, as described in section N of this preamble, even
if a method used by some manufacturers to meet the standard were
suspected of posing an unacceptable risk, there would be regulatory and
other mechanisms that can be used to control that particular method.
The staff is planning to conduct migration and exposure studies on
various FR chemicals that could be used to meet the standard.
The commenter suggested labeling of chemically treated components
as a possible requirement of the standard, to inform consumers of the
materials used. The Commission questions whether such information would
be of practical value to consumers. Simply stating that a mattress
component has been chemically treated does not indicate to the consumer
whether the mattress poses any health risk or not. The proposed
standard requires manufacturers to maintain records specifying details
of all materials, including flame retardant treatments applied and
inherently flame resistant materials, used in each mattress design
(prototype). This will allow identification of relevant mattresses and
mattress/sets if an unacceptable risk is identified.


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