Product Stewardship: Overview
PFA and its member companies are committed to responsible and commendable products and production processes. As a starting point, this entails meeting governmental requirements for occupational safety, environmental protection, and the safety of products. In this section, you well learn more about regulations established by federal agencies such as OSHA, EPA, CPSC and their state and provincial counterparts.
The flexible polyurethane foam industry frequently goes beyond mandatory governmental requirements. PFA sponsors research to identify best practices in occupational safety, facility emissions, flammability, and chemical content of foam products. PFA companies participate in standards organizations such as ASTM, UFAC, and CertiPUR-US®.
An organic material, like wool, cotton, nylon and polyester, FPF is flammable. It should be kept away from open flames and heat sources such as burning cigarettes, lighters, matches, space heaters or any other potential ignition source, because if ignited, FPF can burn rapidly. Since the 1960s, PFA members have been researching and improving the combustion characteristics of FPF cushion components to help reduce the ignition and combustion properties of furniture and mattresses. PFA has worked closely with federal and state authorities, and with standards bodies such as ASTM and NFPA to inform regulations and standards on flammability.
For example, PFA worked with the CPSC, the International Sleep Products Association (ISPA), the Sleep Products Safety Council (SPSC) and other industry groups in its development of a 2006 federal standard that set mandatory national fire performance criteria for all mattresses. This law (16 CFR Part 1633) took effect in 2007, and compliance is largely accomplished using fire barrier materials that limit the involvement of internal cushioning materials in mattress fires.
Similarly, PFA worked with California authorities to revise that state’s law governing ignition of upholstered furniture. The 2013 rewrite of California Technical Bulletin 117 responds to concerns that an earlier version of the standard drove increased use of flame retardants (FRs) chemicals in foam and furniture. California TB 117-2013 focuses on ignition of furniture by smoldering sources such as cigarettes, which account for approximately 90% of furniture fires.
Separate flammability requirements exist in the U.S. for motor vehicles and aircraft interiors.
For more information on flammability, see our Flammability page.
Occupational Health And Safety
The manufacture of FPF involves the use of various chemical raw materials. Substances called isocyanates fully react during manufacturing and aren’t present in the finished product. However, in their raw reactive state, isocyanates must be carefully handled to prevent risk of exposure.
The flexible polyurethane foam industry has numerous safety practices in place to protect worker health. Typical examples of safety practices include:
- Engineered ventilation systems
- Production and off-loading emergency shutoff controls
- Stack engineering and scrubber technologies
- Spill and emergency management procedures
- Personal Protective Equipment (PPE) for use in high-concentration areas
- Personal and area monitoring
- Risk management and training
For more information, see our Occupational Health and Safety page.
Through ongoing efforts, the FPF industry is elevating the sustainability of its products and manufacturing processes. Today, FPF is one of the most environmentally benign and versatile materials in widespread use. FPF industry achievements in environmental protection and sustainabilty include:
- Compliance with all federal and state emissions standards and the Clean Air Act.
- Blowing agents: in recent decades, the FPF industry has been able to eliminate some regulated chemicals previously used as auxiliary blowing agents. For example, the industry voluntarily eliminated the use of chloroflurocarbons (CFCs) from FPF manufacturing processes well in advance of the requirements of the Montreal Protocol. The blowing agent function is now primariliy accomplished by process changes that produce carbon dioxide.
- Voluntary phase out of PBDEs: In January 2006, PFA manufacturer members voluntarily phased out the use of pentaBDE flame retardants in the manufacture of FPF for use in home furnishings cushioning applications (The process required nearly two years of conversion work).
- Recycling: The FPF industry has one of the most successful recycling records in the world. FPF scrap and recovered materials are recycled into useful consumer products such as bonded carpet cushion (sometimes called “rebond”) , which accounts for approximately 80% of all carpet cushion products sold in the U.S.
For more information on environmental practices, see our Environment page.
A number of government and private sector initiatives address the levels of various chemicals allowed in materials and consumer products. These include federal bans of chemicals such as lead and cadmium in children’s products, and state bans of flame retardants and related chemicals in children’s products, furniture, and mattresses. Such bans typically allow a de minimis level of such chemicals (e.g. 1000 parts per million) to account for impurities and residual chemicals from the manufacturing process.
Other programs require the disclosure of chemical content in materials and products sold in commerce. A handful of states require reporting to state authorities of about 75 “chemicals of concern” in products intended for consumers under 12 years of age. California’s Prop 65 law requires manufacturers and sellers of products to post compliant warning labels if any of the over 800 Prop 65–listed chemicals are present in their products. In some cases, the state has published “safe harbors,” de minimis thresholds beneath which reporting is not required. Listed chemicals of potential relevance to the FPF industry include TDI and styrene.
The industry also promotes voluntary product stewardship advances. Through industry funded research and certification programs such as CertiPUR-US, consumers benefit from the latest scientific findings and chemical management practices.
The U.S. Consumer Product Safety Commission restricts the presence of various chemicals in products, particularly children’s products. Chemicals such as lead, cadmium and phthalates are banned above certain de minimis thresholds. CPSC also requires compliance testing, record retention and hazard labeling for some chemicals in products.
In 2017, CPSC voted to launch a project that could ban non-polymeric organohalogen FR (OFR) additives in upholstered furniture, mattresses, children’s products and electronic housings. CPSC also published guidance urging businesses and consumers to avoid OFR’s in these products. CPSC’s rulemaking will likely play out over several years.
Dozens of states and localities have enacted bans of chemicals receiving negative media attention, including flame retardants. Initially targeted were halogen FR’s based on bromine or chlorine chemistry, such as pentabromo diphenyl ether (penta-BDE) and tris (chloropropyl) phosphate (TCPP).
In recent years, some states have moved beyond these classes of chemicals to target other chemicals with flame retardant or synergist properties. Some legislation fails to provide adequate de minimis thresholds to account for impurities and residual chemicals, which could threaten the viability of recycled product such as carpet cushion. PFA has met with lawmakers and interest groups to promote harmonized state-to-state regulation, with reasonable FR restrictions, exclusions for recycled items and de minimis thresholds of 1000 ppm.
California’s Proposition 65 is a “right to know” law established by popular referendum in 1986. The law requires manufacturers and sellers of products to notify California workers, communities, and consumers if any of the over 800 Prop 65–listed chemicals are present in their products or workplace environment. Listed chemicals of potential relevance to the FPF industry include TDI and styrene.
2018 amendments to Prop 65 require most labels to specify a least one listed chemical present in the product. However, some warnings on a product itself or on immediate packaging can omit the naming of a specific chemical. Special rules apply to furniture.
Dermal Exposure to TDI
It is a widely understood principle of foam chemistry that isocyanates are completely consumed in reaction with polyols to produce FPF. Some academic studies and blogs claim a residual presence of isocyanates in cured foam. However, there is evidence that the detected TDI is, at least in part, an artifact of the solvent extraction methods which partially decompose the foam into constituent chemicals. The International Isocyanate Institute (III) initiated research by an independent laboratory to evaluate five grades of recently-cured FPF collected by PFA for the possible surface presence of TDI and MDI. The findings should be peer-reviewed and published in 2019. At the May 2019 PFA Technical Session, Tim Feeley of Covestro described the development of the migration testing method used in this research, and reported some test results.
VOC Emissions from Automotive Foam
Trace levels of chemical used to make foam can volatilize in the hot conditions sometimes encountered in parked cars. Substances involved include amines, phenols and aldehydes. These are not believed to present health risks. Rather, automakers are concerned that fogging and VOC odors generate consumer complaints, particular in Asia. OEMs now require Tier companies to disclose the level of dozens of chemicals in parts and materials, using the Global Automotive Declarable Substance List (GADSL) and the International Material Data System (IMDS). PFA Members are exploring material and process changes that can reduce emissions from foam, including less-emissive amine catalysts and surfactants, reduction of VOC precursors, and the use of “scavengers” to react and bind with VOC pre-cursors. Members participate in the Molded Foam Industry Panel, which is working with OEMs and Tiers to harmonize over 150 different test methods relevant to foam. The panel is developing a “roadmap” for best practices in foam testing, including sample collection, and choice of analytical methods and data interpretation. Papers discussing VOC emissions in automotive applications were presented at the November 2018 and May 2019 Technical Sessions.
CertiPUR-US®is a certification program for flexible polyurethane foam, with standards for content, emissions, and durability. Prohibited chemicals include certain flame retardants, phthalates, and formaldehyde. The program requires analysis of foam samples by independent, accredited laboratories, as well as random on-site foam product plant checks of participating foam producers.
CertiPUR-US® was established with guidance from the global foam industry and in conjunction with the leadership of the mattress and upholstered furniture industries. In addition, an advisory panel of scientists, academics, environmentalists and representatives of consumer groups provided input in the development of standards.
To learn more, visit www.certipur.us.
InTouch: Flexible Foam And Worker Safety