Ethical Questions on the Use of Flame Retardants
Now, we will turn to flame retardants as a case where industry, chemists, regulators, and governments face significant ethical questions in deciding whether to use chemicals even though they may be toxic. Flame retardants are chemicals that are used in a wide range of household products (including clothes, electronics, and furniture) as well as building materials to inhibit flammability. For example, this cushion contains flame retardants in its polyurethane stuffing, even though you can’t detect the chemicals. These chemicals do not necessarily prevent fires: they slow the ignition of products, giving people time to escape from the potential fire, and they are claimed to reduce the likelihood of flashover explosions.
Flame retardants are fairly recent in their use and are associated with the adoption of chemical-based materials. “In the 1960s, naturally fire-resistant materials such as wood, cotton, wool, and leather were replaced with more flammable synthetic materials such as polyurethane and plastics. In an attempt to reduce fire losses, flammability regulations were promulgated beginning in the 1970s for materials used in furniture, electronics, transportation, building, and other applications. Brominated and chlorinated flame retardant chemicals were found to be the most cost effective ways to meet the new flammability requirements.” (Blum et al, 2010).
Regulation has played a key role in creating a market for flame retardants. “In 1975, with the implementation of Technical Bulletin 117 (TB 117), California set the toughest furniture flammability standards in the United States and is currently the only state with fire safety regulations for upholstered furniture. TB 117 requires upholstered furniture to withstand 12 seconds of an open flame, from heat sources such as candles, lighters and matches, without igniting.” (American Chemistry Council, 2012.)
Many types of flame retardants are now in use. “To meet flammability standards, five brominated flame retardants (BFRs) have been used extensively: tetrabromobisphenol A
(TBBPA), hexabromocyclododecane (HBCD), and three commercial mixtures of polybrominated diphenyl ethers (PBDEs) – decabromodiphenyl ether (deca-BDE), octabromodiphenyl ether (octa-BDE), and pentabromodiphenyl ether (penta-BDE).
Chlorinated flame retardants used include TDCPP or [tris (1,3-dichloro-2-propyl) phosphate] also known as chlorinated Tris; TCEP or tris(2-chloroethyl) phosphate; TCPP or tris(1-chloro-2-propyl) phosphate, Dechlorane Plus, and chlorinated paraffins.” (Blum et al, 2010.)
Industry actors say that there are strong reasons to use flame retardants as a protective strategy against fire, irrespective of any environmental or health effects they may have.
1.
Chemical companies and consumer product manufacturers point to a history of decreasing fatalities and injuries associated with flammable products, in response to intensifying regulatory requirements for fire safety.

“Flame retardants give up to 15 times more additional escaping time. In practice, this would mean for example that when a non-flame retarded TV catches fire and gives only 2 minute escape time, the flame retarded one can provide up to 30 minutes escape time. This should allow sufficient time for the fire brigade to reach your place before it is too late. In 2000 in the US, more than 4,000 fire deaths were estimated to be avoided thanks to the use of brominated flame retardants according to an industry evaluation under the Voluntary Children’s
Chemical Evaluation Program. In the United Kingdom alone, government scientists have estimated that more than 3,000 lives were saved in the period from
1988 – 2000 as a result of flame retardants.” (Bromine Science and
Environmental Forum, 2012.)
“In September 2009, at a conference on flame retardants and firefighter health, the
Materials Flammability Group of the National Institute of Standards and
Technology presented the following findings: flame retardant products studied provide a 15 times greater escape time compared to non-flame retardant treated products, and flame retardant treated products had a three-to-four times lower heat release rate and lower quantity of toxic gases released relative to the non-flame retardant product tests.” (American Chemistry Council, 2012).
2.
Industry also argues that the environmental and health effects of flame retardants are still uncertain and speculative, whereas using flame retardants is a costeffective strategy. It doesn’t cost much to use flame retardants in electronics and clothes, whereas redesigning these products to use different materials (like wool rather than polyester) might be costly. Even if some chemicals are toxic, other safer flame retardants can be developed, which is already happening.
Conversely, a growing number of researchers, environmental health NGOs, and chemists argue that flame retardants should be eliminated in favor of safer alternatives.
1.
Existing flame retardants cause many environmental and health problems. PBDEs have been associated with toxicological effects in humans and wildlife.
“Halogenated flame retardants, including PBDEs, have been associated with cancer, immune and endocrine disruption, and reproductive and neurodevelopmental effects in humans and a variety of animal species. A large body of experimental data, both in vivo and in vitro , shows that pentaBDE can disrupt the endocrine system in mammals, birds, and fish, resulting in effects on thyroid, ovarian, and androgen function. The PBDE concentrations in the North American general population are 10 to 40-times higher than the concentrations reported for populations in Europe and other parts of the world. A positive correlation between pentaBDE concentrations in house dust and breast milk has been shown. In
California, populations have been shown to be disproportionately exposed to pentaBDE, likely due to the state’s fire regulation TB117 that has led to high usage of halogenated flame retardants in furniture and baby products. Exposure to

pentaBDE in umbilical cord blood is associated with adverse neurodevelopmental effects in children. Children in the highest 20 % of the exposure distribution showed lower IQ performance scores (ranging from 5 to 8 points lower) at all ages.” (Babrauskas et al, 2011.)
This situation is exacerbated by a pervasive lack of scientific knowledge about the safety of flame retardants. “Many of the current replacements are proprietary mixtures, protected by confidential business information regulations, while others lack adequate toxicity information, making it difficult to accurately assess their potential hazards.” (Blum et al, 2011.)
2.
Flame retardants can exacerbate smoke inhalation problems and don’t work that effectively.
“Most fire deaths and most fire injuries result from inhalation of fire effluents such as carbon monoxide, irritant gases, and soot. Although the incorporation of halogenated flame retardants can reduce the ignitability and heat release of a material, they also increase the yield of such toxic products when combustion occurs. Firefighters can have elevated exposure to brominated and chlorinated dioxins and furans while cleaning up after fires. Fire fighters are known to also have significantly elevated rates of four types of cancer that are potentially related to dioxin and furan exposure: multiple myeloma, non-Hodgkin’s lymphoma, prostate, and testicular cancer.” (Blum et al, 2011.)
3.
Flame retardants are not the appropriate means of reducing fire problems compared to other strategies such as reducing cigarette smoking or making cigarettes safer.
“The leading cause of fire fatalities in the U.S. is cigarettes. A large majority of residential fire deaths in which upholstered furniture was the first item ignited are caused by cigarette ignition. Between 1980 and 2005, smoking-related fire deaths in the U.S. have declined from 2,000 to 800 annually. The most recent data show a continued decline to 720 deaths in 2007. The reduction of smoking, through a combination of education, taxation and location restriction policies, has proven the single most effective fire safety strategy. Smoking rates in the United States had declined to 21% by 2004. The recent passage in all 50 states of legislation requiring the manufacture and sale of reduced ignition propensity (RIP) or “fire safe”, cigarettes, should further reduce fire deaths.” (Blum et al, 2011).
“Safer alternatives to hazardous or untested flame retardant chemicals should be considered, including using less flammable materials and changing the design of products to minimize flammability.” (Blum et al, 2011).
As you can see, there are legitimate arguments for and against producing and using flame retardant chemicals in consumer products.

* How would you use utilitarian or consequentialist ethical theory to decide whether or not to use flame retardants? What are the considerations that you would look at?
* How would you use deontological or non-consequentialist theory to decide whether or not to use flame retardants? What are the considerations that you would look at?
* Are there differences in the implications of each theory for what chemists, business managers, regulators, governments, and consumers should do? Do each group of actors have different considerations to think about?
* Which ethical theory do you prefer to use in resolving this kind of question? Why?
References:
Arlene Blum, S. Shaw, and Linda Birnbaum. 2010. PBDE S and their Replacements: Does the Benefit
Justify the Harm? Organohalogen Compounds 72: 1296-1301.
V. Babrauskas, A. Blum, R. Daley, and L. Birnbaum, 2011. Flame Retardants in Furniture Foam: Benefits and Risks. Fire Safety Science 10: 265-278.
American Chemistry Council, 2012. Available at: http://flameretardants.americanchemistry.com
Bromine Science and Environment Forum, 2012. Available at: http://www.bsef.com/flame-retardants-firesafety/