NCHR Comments to CPSC on the Organohalogen Flame Retardant Petition

National Center for Health Research: September 14, 2017

Thank you for the opportunity to speak today. The National Center for Health Research is an independent nonprofit organization that conducts research and scrutinizes research conducted by others. We often compare conflicting scientific and medical conclusions to determine which are more scientifically sound. We do not accept funding from chemical companies and pharmaceutical companies, in order to avoid conflicts of interest.

We have been very impressed with the Consumer Product Safety Commission’s careful review of children’s products that contain numerous phthalates and we urge the Commission to play a similarly important role regarding organohalogen flame retardants.

The EPA website clearly states that organohalogens “are highly persistent, bioaccumulative, and cause adverse effects in humans and wildlife. Because of the widespread use of these organohalogens in household items and consumer products, indoor contamination may be a significant source of human exposure, especially for children. One significant concern with regard to health effects associated with exposure to organohalogens is endocrine disruption.”[1]

All organohalogen flame retardants are semi-volatile organic compounds (SVOCs), and when they are in products that are indoors, OFRs migrate into air, dust, and films on surfaces such as walls and fabrics. They will also get on the skin, and although they can be washed off, OFRs in the air and surfaces will once again find their way onto the skin. The bottom line is that once OFRs are indoors, they will stay indoors and that means humans will be exposed day after day.

We were not involved in the petition, but note that it included footnotes of numerous relevant studies that we found persuasive. However, the scientific evidence is even stronger today, indicating that exposure from indoor sources can occur by:

1. Ingestion of dust containing OFRs,
2. Hand-to- mouth transfer of OFR-containing dust on hands or direct hand contact with a OFR-containing product,
3. Skin exposure from air or from clothing exposed to OFRs from indoor air and dust, and
4. Inhalation of OFRs found in indoor air.

Unfortunately, many children’s products contain OFRs and children are also exposed due to common household products such as sofas, mattresses, pillows, and electronics. For example, Dr Julie Herbstman from Columbia has conducted research indicating that pregnant women and children are exposed in their homes to detectable levels of PBDE as well as their halogenated replacements. She points out that children, infants, and fetuses are more vulnerable to health effects resulting from exposure to a variety of environmental chemicals, including halogenated flame retardants.

I hope you will carefully review her footnoted testimony, which clearly documents that OFRs in products are causing OFRs in air and dust: Concentrations of organohalogen flame retardants in dust are higher the closer the dust is to the OFR products;

  • The presence and number of products are statistically significantly associated with contamination levels of OFRs in air or dust; this means the association has at least a 95% probability of being proven, and did NOT occur by chance;
  • When one removes such a product from a room, the level of OFRs in air and dust decreases, and vice versa;
  • Organohalogen flame retardants are directly emitted from products when products are placed in an experimental chamber and the emissions measured. In an actual indoor environment, such emissions would result in flame retardant chemical contamination of the room’s air and dust.

In conclusion, flame retardants used in upholstered furniture, children’s products, mattresses and casings for electronics contribute significantly to the levels of indoor air and dust contamination, and subsequent to human exposures.

We agree with CPSC staff that there are likely to be variations in the impact of specific OFRs on human health. In the ideal world, it would make sense that each specific OFR proposed for use as flame retardants in consumer goods should undergo a risk assessment to determine whether it is safe to use. I understand the desire to be very precise and to determine whether some OFRs are safer than others, but in the meanwhile, we know as scientists that these exposures can be extremely harmful. If we look at all the scientific evidence on the toxicity of organohalogens, the risks are clear. As the Director of the National Institute of Environmental Health Sciences noted, it is not possible to study all OFRs, but so far all of them that have been studied are known to pose risks to human health, and especially prenatally and to children. We also know that the combination of exposures from these various chemicals can be much greater than is demonstrated in the study of just one OFR. In order to keep our children safe, it is essential to regulate OFRs collectively as a class unless and until there is scientific evidence that one or more particular OFRs is proven to be safe, and then treat that specific OFR differently.


  1. Kodavanti, P.S. and Curras-Collazo M. C. (2010). Neuroendocrine Actions of Organohalogens: Thyroid Hormones, Arginine Vasopressin, and Neuroplasticity. Retrieved from