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Use status and regulatory restrictions for flame retardants in children's products in the US market

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[Abstract]:
On April 15, 2013, under the California 65 proposal, the first case of a settlement of banned flame retardants in children's products (RG-13667688) was reached, which attracted the attention of many children's product manufacturers. In fact, prior to this, the situation of children's products containing triglyceride (TRIS) flame retardants in the US market has received attention. In 2012 and 2013, the US government and civil society organizations repeatedly tested children's products on the market, and the results showed that most children's products contain harmful chemical flame retardants.
On April 15, 2013, under the California 65 proposal, the first case of a settlement of banned flame retardants in children's products (RG-13667688) was reached, which attracted the attention of many children's product manufacturers. In fact, prior to this, the situation of children's products containing triglyceride (TRIS) flame retardants in the US market has received attention. In 2012 and 2013, the US government and civil society organizations repeatedly tested children's products on the market, and the results showed that most children's products contain harmful chemical flame retardants.
 
1 The use of flame retardants in children's products in the US market
 
In December 2012, the famous American media "Chicago Tribune" released a survey report on the content of TRIS flame retardant in baby mattresses. A total of 27 products under inspection, from three different brands, tested, 13 of which found TRIS (TDCPP, TCEP, TCPP) flame retardant, some content up to 6.8%.
 
In February 2013, CEH (California Environmental Health Center) released a report that CEH commissioned Duke University to test purchases from seven markets in California, New York, Washington, Alaska, Massachusetts, Vermont and Connecticut. 24 children's nap mats, 22 of which contain flame retardants. Tests have found that there are 10 flame retardants used in these nap pads, 19 of which contain more than two flame retardants. Among them, triphenyl phosphate TPP was used most, and was found in 18 nap mats. At the same time, TDCPP was found in the nine nap pads.
 
In March 2013, CEH also found that high-concentration TCEP and TDCPP were found in baby walkers, diaper changing mats and furniture sold by large retailers.
 
With the deep understanding of the dangers of flame retardants, combined with the current use of flame retardants, many states in the United States have introduced a bill (proposal) to limit the use of flame retardants in children's products.
 
2 state bills that have passed the ban on flame retardants
 
2.1 California
 
On April 15, 2013, CEH announced that it had reached an agreement with a well-known child sleeping pad manufacturer (RG-13667688) to ban the use of chemical flame retardants in its products. This is the first settlement agreement on flame retardants under the California 65 proposal.
 
Control products: foam pads for children and babies lying down, such as mats for rest
 
Control requirements: Polyurethane foam in control products sold in California is not allowed to be detected with chemical flame retardants (referring to chemicals containing any phosphorus or halogen functional groups that are added to prevent or slow the spread of fire, including However, it is not limited to the compound of Table 1).
 
 
 
Table 1 chemical flame retardant
 
Substance name
 
CAS No.
 
Tris(l,3-dichloro-2-propyl) phosphate (TDCPP)
 
Tris(1,3-dichloro-2-propyl) phosphate
 
13674-87-8
 
Tris(2-chloroethyl) phosphate (TCEP)
 
Tris(2-chloroethyl) phosphate
 
115-96-8
 
Tris(l-chloro-2-propyl) phosphate (TCPP)
 
Tris(2-chloropropyl) phosphate
 
13674-84-5
 
2-ethylhexyl tetrabromobenzoate (TBB)
 
2-ethylhexyl-tetrabromobenzoic acid
 
183658-27-7
 
Bis(2- ethylhexyl)-2,3,4,5-tetrabromophthalate (TBPH)
 
2,3,4,5-tetrabromo-benzenedicarboxylic acid bis(2-ethylhexyl) ester
 
26040-51-7
 
Triphenylphosphate (TPP)
 
Triphenyl phosphate
 
115-86-6
 
2,2-bis(chloromethyl) trimethylenebis(bis(2-chloroethyl) phosphate) (V 6)
 
2,2-dichloromethyl-trimethylene-bis[bis(2-chloroethyl)phosphate (V 6)
 
38051-10-4
 
4-(tert-butyl)phenyl diphenyl phosphate (MDPP)
 
Tert-butyl phenyl diphenyl phosphate
 
56803-37-3
 
Bis(tert-butylphenyl) phenyl phosphate (DBPP)
 
Phenyl (di-tert-butylphenyl) phosphate
 
65652-41-7
 
Tris(4-tert-butylphenyl) phosphate (TBPP)
 
Tris(p-tert-butylphenyl) phosphate
 
78-33-1
 
28777-70-0
 
Pentabromodiphenyl ethers
 
Pentabromodiphenyl ether
 
32534-81-9
 
Octabromodiphenyl ethers
 
OctaBDE
 
32536-52-0
 
Decabromodiphenyl ethers
 
Decabromodiphenyl ether
 
1163-19-5
 
 
 
 
 
 
      On October 28, 2011, TDCPP was added to the California Proposed toxic and hazardous chemical list for its carcinogenicity, with no significant risk level (NSRL) of 5.4 micrograms per day. In addition to TDCPP, TCEP is also on this list.
 
2.2 Washington
 
The Children's Safe Product Act (CSPA-Chapter 70.240 RCW) in Washington, DC lists 66 highly regarded chemicals, including the flame retardant TCEP. This means that if a child's product contains TCEP, the manufacturer must notify the Washington Department of Ecology according to the following conditions.
 
Contaminants: Unintentionally added, not intended to add some functionality. These include, but are not limited to, by-products in chemical reactions, incompletely reacted reactants, decomposition products, and the like. As a pollutant, when the concentration reaches 100ppm, it needs to be notified. However, if the manufacturer already has a control program and can indeed reduce the amount of contaminants in actual production, no notification is required.
 
Intentionally added substance: A substance that is present in a product to achieve a predetermined property. If the concentration of the intentionally added substance is greater than the actual limit of quantitation PQL (the PQL of TCEP is 50 ppm), notification is required.
 
The effective date of notification is based on the manufacturer's annual turnover and product category.
 
Children's product definition: Children refer to people under the age of 12. Children's products include toys, children's cosmetics, children's jewelry, designs or products intended to help children suck, teeth, sleep, relax, or feed children, clothing (including shoes), and car seats.
 
2.3 New York
 
According to A 6195, products designed for use by children under 3 years of age (including baby items, toys, pillows, mattresses, strollers, etc.) must not contain TCEP as of December 1, 2013.
 
2.4 Maryland (HB 99)
 
As of October 1, 2013, the concentration of TCEP in products designed for use by children under 3 years of age must not exceed 0.1%.
 
3 State bills being reviewed or voted
 
In addition to the state regulations passed above, the state bills that are being reviewed or voted are shown in Table 2.
 
Table 2 State bills being reviewed or voted
 
Regional bill
 
  main content
 
Connecticut (HB 6332)
 
As of October 1, 2014, TDCPP, TCEP and TCPP are prohibited in products designed for use by children under 3 years of age.
 
Massachusetts (SD 1618)
 
From January 1, 2014, TRIS (TDCPP, TCEP, TCPP) should not exceed 50ppm in upholstered furniture and products for children under 12 years of age. The concentration of polybrominated diphenyl ethers (pentabromodiphenyl ether, octabromodiphenyl ether, decabromodiphenyl ether) in any product must not exceed 1%.
 
Vermont (S 81/H 241)
 
From July 1, 2013 (sellers starting July 1, 2014), no one can manufacture or sell TRIS (TDCPP, TCEP, TCPP) products over 50ppm of furniture and children under 12 years old and PBDEs. Brominated diphenyl ethers, octabromodiphenyl ethers, decabromodiphenyl ethers, more than 0.1% of specific consumer products.
 
New Jersey (A 760/S 1554)
 
From January 1, 2014, the concentration of decabromodiphenyl ether in consumer products should not exceed 0.1%.
 
Washington (HB 1294/SB 5181)
 
As of July 1, 2015, the concentration of TDCPP and TCEP in upholstered furniture and children under the age of 12 shall not exceed 100 ppm.
 
New York (A4741)
 
Starting from December 1, 2015, products designed for use by children under 3 years of age (including baby items, toys, pillows, mattresses, strollers, etc.) must not contain TDCPP.
 
As can be seen from the above information, the abuse of flame retardants in children's products has gradually gained attention in the United States, and more and more states have begun to limit the use of flame retardants. Relevant brands and manufacturers should eliminate toxic flame retardants as soon as possible, take the initiative to respond to the requirements of hazardous substances control, reduce the loss of products due to flame retardant problems, and seize market opportunities.
 
Tips: About TRIS
 
TRIS: Phosphate triesters, usually referred to as the following
 
Tris(l,3-dichloro-2-propyl) phosphate (TDCPP) Cas no. 13674-87-8
 
Tris(2-chloroethyl) phosphate (TCEP) Cas no. 115-96-8
 
Tris(l-chloro-2-propyl) phosphate (TCPP) Cas no. 13674-84-5
 
The harm of TRIS:
 
TDCPP: It is recognized as a carcinogen, which has a genetic damage to human cells and damages the nervous system, which may change the level of human hormones. Animal experiments have shown that TDCPP is toxic to developing embryos.
 
TCEP: Animal studies have shown that TCEP can cause leukemia, as well as kidney, lung, and stomach tumors. It also has reproductive toxicity and neurotoxicity.
 
 
TCPP: Genetically detrimental to human cells. Animal experiments have shown that TCPP changes the physiological cycle.