Please sign on to stop TB 604 and toxics in our beds

Dear Governor Arnold Schwarzenegger,

As a coalition of consumer groups and health and environmental NGOs representing millions of Americans, we are writing to ask you to stop the implementation of Technical Bulletin 604 (TB604) until its health and environmental impacts, as well as its potential fire safety benefits, are evaluated.
TB 604, being promulgated by the California Bureau of Electronic and Appliance Repair, Home Furnishings and Thermal Insulation (the Bureau), would mandate that filled bedding products such as comforters, mattress pads, and pillows resist ignition by a small open flame for twenty to thirty seconds. While TB 604 does not specify a methodology, the realities of current technology and cost structures indicate that untested and potentially toxic flame retardant materials and chemicals are most likely to be used to meet the standard.

Hundreds of peer-reviewed scientific papers have reported on the toxic health and environmental properties of flame retardants.  They are linked to numerous health problems, including cancer, birth defects, endocrine dysfunction, thyroid disruption, hearing deficits, reproductive dysfunction and neurological impacts, including decreased memory and learning, behavioral disorders, and hyperactivity.  This is of special concern for pregnant women and young children who are the most vulnerable to endocrine disruptors, carcinogens, mutagens, and neurological and reproductive toxicants.  For these reasons, the California Medical Association recently passed a resolution recognizing the cumulative negative effects of flame retardants and called upon regulatory agencies to limit their use when possible (CMA Resolution 711-09).  

The current national mattress flammability standard, fire safe cigarettes, and fire safe candles -- all of which have been implemented since TB604 was evaluated %u2013 have greatly diminished its potential to provide a fire safety benefit.

TB117, a similar standard which was passed in 1973, led to the highly toxic PBDE flame retardants being used in polyurethane foam furniture and juvenile products sold in California from the 1975 until 2004, when PBDEs were banned by the California Legislature.  These chemicals were then replaced by the same toxic Tris that was taken out of children%u2019s sleepwear decades earlier and other chemicals for which there is no adequate health information.

Given this history of the toxicity of flame retardants, the Bureau should require that, prior to use in bed coverings and pillows, manufacturers must provide complete toxicological information for any flame retardant material or chemical used, as well as a life-cycle assessment of the potential for human and environmental harm. These data should be reviewed by an authoritative body with no conflict-of-interest such as the Office of Environmental Health Hazard Assessment (OEHHA) or the Department of Toxic Substance Control (DTSC).  A detailed summary of this information should be publicly available. In addition, all chemicals and materials in bed clothing must be labeled, so that consumers can make informed choices.

Efforts to improve fire safety should not come at the expense of increasing human and environmental exposure to untested and potentially toxic chemicals and materials.  Given the lack of a proven fire safety benefit from this standard, we should not risk the health of Californians, and especially our children, by legislating untested and potentially toxic materials into our beds.

Sincerely,

Dr. Arlene Blum, PhD, Executive Director, Green Science Policy Institute
Arlyce Currie, Program Director, BANNANS Child Care and Family Support Agency
Bill Magavern, Director, California Sierra Club
Christopher Gavigan, Executive Director, Healthy Child Healthy World
Jeanne Rizzo, R.N, President and CEO, Breast Cancer Fund
Jean-Michel Cousteau, President, Ocean Futures Society
Joan Blades, Executive Director, Moms Rising
Joyce Bichler, Deputy Director, Breast Cancer Action
Judy Levin, Pollution Prevention Coordinator, Center for Environmental Health
Dr. Kristen Welker-Hood, ScD MSN, Director, Environment & Health, Physicians for Social Responsibility
Dr. Lin Kaatz Chay, PhD, MPH, Indiana Toxics Action
Mary Brune, Executive Director, MOM
Matt Prindiville, Project Director, Natural Resources Council of Maine
Pam Palitz, Environmental Health Advocate and Staff Attorney, Environment California
Patty Clary, Policy and Program Director, Californians for Alternatives to Toxics
Pamela K. Miller, Founder, Alaska Community Action on Toxics
Renee Sharp, California Office Director, Environmental Working Group
Sara Schedler, Clean Car Program Director, Friends of the Earth
Dr. Sarah Janssen, MD, PhD, MPH, Staff Scientist, Natural Resources Defense Council
Ted Schettler MD, MPH, Science Director, Science and Environmental Health Network
Tessa Hill, President, Kids for Saving Earth
Tony Stefanni, Board Chair, San Francisco Firefighters Cancer Prevention Foundation
Tom Lent, Policy Director, Healthy Building Network

Concurring Organizations:
Alaska Community Action on Toxics
Bananas Child Care and Family Support Agency
Breast Cancer Action
Breast Cancer Fund
California Sierra Club
Californians for Alternatives to Toxics
Center for Environmental Health
Environment California
Environmental Working Group
Friends of the Earth
Green Science Policy Institute
Healthy Building Network
Healthy Child, Healthy World
Healthy Child, Healthy World
Indiana Toxics Action
Kids for Saving Earth
Los Angeles Chapter %u2013 Physicians for Social Responsibility
MOMS (Making our Milk Safe)
MomsRising.org
Natural Resources Council of Maine
Natural Resources Defense Council
Ocean Futures Society
Physicians for Social Responsibility
Public Health Alliance
San Francisco Chapter %u2013 Physicians for Social Responsibility
San Francisco Firefighters Cancer Prevention Foundation
Science and Environmental Health Network

CC:
Secretary of State and Consumer Services Agency Fred Aguiar
Department of Consumer Affairs Director Brian Stiger
Bureau of Electronic and Appliance Repair, Home Furnishings and Thermal Insulation Chief Rick Fong
California Department of Environmental Protection Secretary Linda S. Adams,
State Assemblyman Wesley Chesbro, Chair, Committee on Environmental Safety and Toxic Materials
State Assemblyman Dave Jones, Chair, Committee on Health
State Senator Joe Simitian, Chair, Committee on Environmental Quality
State Senator Elaine Alquist, Chair, Committee on Health