U.S. Consumer Products Safety Commission (CPSC) proves flameproof mattresses give daily dose of poisons, final vote on new national flameproof mattress law is Feb 16, 2006 (Law Passed) For printer friendly version of the page click here In their Jan-06 Risk Assessment the CPSC proves the average adult will absorb a daily dose of .802 mg of Antimony, .081 mg Boric Acid, and .073 mg DBDPO (Deca) from flame proof mattresses. (It's True! See CPSC Table 16 below) All three are acute poisons and two cause cancer. (Most people do not want themselves or their children to absorb any amount of poisons from their mattresses every day, to avoid the one in one million risk of dying in a mattress fire.) Plus, Children under age five excluded from risk assessment. The CPSC assumes all these children will be protected by a vinyl sheet over their mattresses due to bedwetting problems, and that this will protect them from exposure to these known acutely toxic chemicals. There are no labeling requirements. Parents will never know their new mattresses contain toxic chemicals. Unlike other flame retardants that we initially think are non-toxic like Asbestos, and later find them harmful, we already know these are acutely toxic and cancer causing. Antimony: Quote from College Chemistry Textbook: “Antimony resembles Arsenic very closely; the difference in its behavior being almost entirely accounted for by the fact that antimony is slightly more metallic.” This helps explain why it is so poisonous. Quotes from ATSDR a division of the CDC on Antimony: “An increase in the number of spontaneous abortions, disturbances in menstruation, failure to conceive, May cause heart to beat irregularly or stop. … Chronic Exposure: Prolonged or repeated exposure may damage the liver and the heart muscle." “In long-term studies, animals that breathed very low levels of antimony had eye irritation, hair loss, lung damage, and heart problems. Problems with fertility were also noted.” "Two studies reported lung tumors in rats exposed to relatively low levels of antimony trioxide." Antimony tends to accumulate in the liver and gastrointestinal tract.” The CDC cannot determine a safe level of Antimony exposure because: “At the lowest exposure levels tested, the adversity of the effects was considered to be serious.” On cancer risks of Antimony even the CPSC admits: “The cancer effects are cumulative. Every exposure contributes to the overall lifetime risk of developing cancer.” Boric Acid, also used as Roach Killer, is a known reproductive and developmental toxin, a known respiratory irritant, Demonstrated injury to the gonads and to the developing fetus. high prenatal mortality, Neonatal children are unusually susceptible. There are already 6,463 U.S. cases of Boric Acid poisoning each year. One human exposure study showed reduced sperm counts and reduced sexual activity in humans. DBDPO, Deca, is in the family of PBDE’s, is known to bioaccumulate, is linked to cancer, and groups are trying to get it banned. The CPSC has completed extraction studies that show the percentage of FR chemicals contained in various mattress flame barriers. (See CPSC Table 1 below, It shows 7 of 13 barriers contain Antimony, and 5 of 13 contain Boric Acid) They have also completed leaching and migration studies that prove these chemical reach the surface of our mattresses through the sheets, to be absorbed by our bodies, and base the above poison absorptions calculations on this data. All mattresses sold in California, and one half of mattresses sold nationwide already contain FR chemicals for this law. Why do all flame proof mattress manufacturers try to say they don’t use chemicals, when the CPSC proves them wrong? Because almost no one wants to sleep in known toxic and cancer causing chemicals, to avoid the one in one million risk of dying in a mattress fire. The CPSC has received over 800 public comments against this law when they would normally only receive about twenty from interested parties on most issues. This generated an article in the Washington Post titled: “Fire Resistant Mattresses Ignite Fear of Chemicals.” Many Doctors oppose this law: 9 M.D.’s (many of them prominent), a Medical School Professor PhD who studies toxicology, 2 PhD Chemists, and a PhD Professor of Mathematics who researches and teaches probability theory. One M.D. calls it “Ethically Unacceptable” to put any person at this risk of poisoning and cancer, much less our entire population. Another M.D. says: “If the CPSC pushes this law forward, they need to change their name.” And another M.D. says: “I know many chemically sensitive people who do not tolerate treated mattresses. And how many are intolerant who don't know why they can't sleep or feel bad?” Yet the CPSC rebuts and ignores all these comments just as they rebut the comments of their independent reviewer. The CPSC is required by law to get an independent review of the risk assessment justifying this law. The reviewer, TERA.org, found serious problems including: Children under age five were excluded from the risk assessment. The CPSC assumes all these children will be protected by a vinyl sheet over their mattress, and therefore not absorb as much toxic chemical. Of course, there are no labeling requirements and parents will never know their mattress contains toxic chemicals, or that their child is receiving a daily dose of poison. Another very serious problem develops when the reviewer points out the CPSC should coordinate their assumptions of the safe levels of absorption of poisons with other agencies. The CPSC again rebuts them claiming their assumptions are correct and that coordinating with other agencies would not make a substantial difference. New Info, EPA Proves Mattresses Toxic I wrote to the CDC asking what level of Antimony exposure is safe. I got a reply from the CDC: “ATSDR has not derived a chronic MRL [Minimal Risk Level] for antimony. However, the U.S. EPA chronic oral reference dose for antimony is 4E-4 mg/kg/day.” This is .0004 mg/kg/day, or 4/10,000’s of a milligram/ per kilogram of body weight/ per day. This is a far different number than the CPSC assumption of a safe level of 2.3 mg/kg/d. In fact, it is 5,750 times more than the EPA minimal risk number. It also changes everything and proves our antimony absorption from flame proof mattresses is unsafe by 27.5 times. In a proper risk assessment, this would stop this law. Comparing these numbers to the CPSC assumptions in their table 16, tab d, p 45, shows: Parameter Antimony (CPSC Assumptions) Antimony (CDC/ATSDR/EPA numbers) Difference CPSC/EPA ADD Total (mg/kg/d) (Average Daily Dose) 0.011 0.011 ADI mg/kg/d (Acceptable Daily Intake) 2.3 .0004 5,750 Hazzard Index, HI (numbers below one are considered safe) .005 27.5 5,500 CPSC tests prove we will absorb 0.011 mg/kg/d of Antimony from new flame proof mattresses. The only question is what is a safe level? The CPSC says 2.3 mg is safe while the EPA says only .0004 is a safe level. If we accept the EPA number it proves new mattresses are toxic by 27.5 times more than the safe level. The CPSC risk assessment repeatedly states the hazard index should be below one, meaning anything one or above is unsafe. Clearly a hazard index of 27.5 is very unsafe for our entire population to sleep in. The science of toxicology, when given the correct assumptions, proves flame proof mattresses are unsafe for human exposure. I question what else in the CPSC risk assessment is invalid? We might absorb a lot more poison than they predict. It seems clearly designed to justify and force this law through. It does not meet the standards of a good risk assessment, young children and other sensitive populations were not included. Many more chemicals are also used to flameproof mattresses that were not considered or studied. For instance the CPSC preferred melamine resin system is made from the reaction of melamine and formaldehyde, and contains free formaldehyde, but formaldehyde was not studied. And as TERA pointed out a good risk assessment should include our exposure from other sources, i.e. upholstered furniture. This was again rebutted even though the CPSC is in the final stages of requiring these same chemicals in upholstered furniture in another open flame law about to be enacted. Additionally, the CPSC is about to enact another FR law covering our top of the bed items including mattresses pads, comforters, and pillows, which will again require these same toxic chemicals. Then, the only time we won’t be absorbing poisons is while we are standing up. The U.S. already uses 1.2 Billion pounds of flame retardants every year, and the Chemical Manufacturers Association estimates this saves up to 960 people annually. The CPSC estimates of saving up to 272 people annually from this law alone seem overly optimistic. In the 350 fire deaths where the mattress or bedding was the first item to ignite, 80% of the time the bedding ignited first, not the mattress. But it does not matter if it saves 30 or 300. We are putting 300 million people, our entire population, at risk to sleep in known toxic chemicals, and receive a daily dose of poison. It seems likely this law will kill more than 300 sensitive people annually. But what if any one of these chemicals proves toxic over many years? Perhaps many of our children might be dumber than we are, or it could be catastrophic. If one third of our mattresses are toxic, it will harm 100 million people, If only 15% of our mattress prove toxic, it will be 45 Million people harmed. If only 1% prove toxic, it is still 3 million people harmed. Even with all its risks, and their risk analysis proven wrong, it seems the CPSC can’t see the forest for the trees, and will likely enact this law right after Valentine’s Day, on Thursday February 16, 2006. The CPSC studies have proven me right It is no longer just me saying poisonous chemicals are used to flame proof mattresses, and major mattress manufacturers saying they don’t use chemicals. Now the CPSC Table 1 proves which chemicals and their percentages are used. There are no chemical free systems that can pass this blow torch open flame test. It is no longer just me saying these toxic chemical can leach out and get us while mattress manufacturers say they are chemically bound and can’t get out. The CPSC migration studies prove these chemicals leach through the sheets and are absorbed by our bodies. In fact the CPSC proves we will get a daily dose of poisons of .802 mg of Antimony, .081 mg of Boric Acid, and .073 mg of DBDPO, every day for the rest of our, our children’s, and our grandchildren’s lives. The EPA has proven CPSC safety assumptions wrong. The EPA has also proven CPSC exposure and absorption calculations of poison absorbed from flame proof mattresses will exceed toxic levels by 27.5 times. We hope you will report this story. With all mattresses sold in California required to be flame proof, and half of new mattress sold nationwide already flameproof in anticipation of the new law, millions and millions of people are already sleeping in and absorbing a daily dose of poisons. The rest of us will eventually sleep in and absorb these poisons. People have a right to know the truth. You don’t have to take my word for the truth. The truth and proof is in CPSC Tables 1 and 16. Please give me a call, I can give you a lot more information including contact information for the many doctors and others who oppose this law and chemical use, and contact information for people who claim their new flame proof mattresses made them sick. Sincerely Mark Strobel Who is Strobel? Mark Strobel is founder and owner of Strobel Technologies, a 32 year old company that manufactures specialty mattresses including Supple-Pedic, a patented visco foam mattress with patented "Lever Support System" or "Air Lever System," and Airbeds, Waterbeds, and Latex beds, all the newer technologies compared to innerspring mattresses. Strobel in not a Sealy or Serta, but does sell nationwide and worldwide and maintains permanent wholesale showrooms at the major furniture markets including the largest at High Point NC. Strobel’s Supple-Pedic mattress is seen nationally regularly on CBS’s show “The Price is Right.” Unable to find a chemical free and safe system for his beds, Mark Strobel was appalled at the toxic chemicals required to flameproof mattresses. The more he researched the issue, the more concerned he became that the risks could prove catastrophic and harm hundreds of millions of people. Mark eventually started the group PeopleForCleanBeds.org that generated over 800 public comments against the law, and generated news for the issue with many newspapers and TV stations. It was the many public comments that generated a news article in May by the Washington Post, and this article was reprinted by many newspapers across the country. Mark has tried to fight the issue with the CPSC directly, even sending them bottles of Boric Acid Roach Killer powder, and this earned him a CPSC audit of his company’s compliance with the 1973 mattresses cigarette ignition law. The CPSC even purchased a Strobel mattresses at retail for testing under this law, (perhaps an attempt to get him?) but Strobel mattresses comply with the law without chemicals and this audit is still being worked out. This slowed down his direct contact for a while but he latter resumed it by sending the CPSC numerous emails and letters of new facts he continued learn. The CPSC even has the newest data of the EPA proving their risk assessment wrong. In spite of it all, it appears the CPSC will pass this new mattress fire law. References, Tables from the CPSC: We see the following table in the CPSC report: P 45, http://www.cpsc.gov/library/foia/foia06/brief/matttabd.pdf In the table above ADD is Average Daily Dose. You can see above that CPSC calculations show we will get a daily dose of .802 mg of Antimony, .081 mg of Boric Acid, and .073 DBDPO. ADI is the CPSC assumptions of Acceptable Daily Intake. The CPSC concludes this amount of poison absorption is safe for everyone, But other agencies disagree, including the ATSDR, CDC, and EPA. The CPSC knows which chemicals are used to flameproof mattresses as presented in their table below: "BARRIER SAMPLE ID AND FRC LOAD Information on the various barrier samples along with the average chemical load found by LSC are contained in Table 1. The FRC percentages listed in Table 1 are the average from 5 replicates." To help you read the table below: H3BO3 is Boric Acid SB2O3 is Antimony DBDOP is Decabromodiphenyl Oxide, also called Deca which www.ewg.org is trying to get banned. Table 1 from Tab H, p 17 http://www.cpsc.gov/library/foia/foia06/brief/matttabh.pdf Melamine Resin Barriers are made from the reaction of Melamine and Formaldehyde, and contain free Formaldehyde, but these barriers were not tested for Formaldehyde content. FORMALDEHYDE MSDS: "POISON! DANGER! SUSPECT CANCER HAZARD. MAY CAUSE CANCER. Risk of cancer depends on level and duration of exposure. VAPOR HARMFUL. HARMFUL IF INHALED OR ABSORBED THROUGH SKIN. CAUSES IRRITATION TO SKIN, EYES AND RESPIRATORY TRACT. STRONG SENSITIZER. MAY BE FATAL OR CAUSE BLINDNESS IF SWALLOWED. CANNOT BE MADE NONPOISONOUS." http://www.jtbaker.com/msds/englishhtml/F5522.htm Si is Silicon, which was not tested for either. It also has health risks: “Silicon may cause chronic respiratory effects. … Inhalation will cause irritation to the lungs and mucus membrane. Several epidemiological studies have reported statistically significant numbers of excess deaths or cases of immunologic disorders and autoimmune diseases in silica-exposed workers. These diseases and disorders include scleroderma, rheumatoid arthritis, systemic lupus erythematosus, and sarcoidosis. Recent epidemiological studies have reported statistically significant associations of occupational exposure to crystalline silica with renal diseases and subclinical renal changes. Crystalline silica may affect the immune system, leading to mycobacterial infections (tuberculous and nontuberculous) or fungal, especially in workers with silicosis Occupational exposure to breathable crystalline silica is associated with bronchitis, chronic obstructive pulmonary disease (COPD) and emphysema. … Lung cancer is associated with occupational exposures to crystalline silica http://www.lenntech.com/Periodic-chart-elements/Si-en.htm#Health%20effects%20of%20silicon Ammonium Polyphosphate is the only other chemical used to flame proof mattresses not listed above. Not as much is know of how toxic this chemical is to sleep in, but it is doubtful sleeping in and absorbing this fertilizer could be good for us. The CPSC has shown large amounts of this chemical leach from mattresses. As you can see above 7 of the barriers contain Antimony and 5 contain Boric Acid. It is no wonder there are no labeling requirements for the FR chemicals used in mattresses. Which of the above systems would you choose to sleep in? We don’t think any of these systems are safe, they all have risks. Cotton Batting barriers contain 10% poison, 7.5% Boric Acid plus 2.4% Antimony. Melamine Resin barriers contain Formaldehyde. Silicon and Formaldehyde were not studied. We keep hearing about inherently flame resistant fibers from the CPSC and mattress manufacturers. These inherently flame resistant fibers have chemicals blended with the fiber as the fiber is made. The only true inherently flame resistant fiber is fiberglass, and even that is blended with chemicals to make a barrier as you can see in the table above. We are glad to see the CPSC proved all the fire barriers contain toxic chemicals, maybe the truth can be told to the public. The new risk in our modern world is our exposure to toxic substances. The National Safety Council says 17,550 people die each year from “Accidental poisoning by and exposure to noxious substances," this number now exceeds deaths in car accidents. Thank you for your time and consideration. Sincerely, Mark Strobel

President, Strobel Technologies, www.Strobel.com

Director, People For Clean Beds, www.CleanBeds.org Phone: 812-282-4388

Fax: 812-282-6528

Email: Mark@Strobel.com Address: 3131 Industrial Parkway, Jeffersonville IN 47130 Master list of CPSC briefing packages: http://www.cpsc.gov/library/foia/foia06/brief/briefing.html See the CPSC quotes in this document at: http://www.cpsc.gov/library/foia/foia06/brief/matttabd.pdf See CPSC Table 1 showing the percentage of Known Toxic Chemicals contained in various mattress flame barrier systems at: Tab H, p 17 http://www.cpsc.gov/library/foia/foia06/brief/matttabh.pdf Notice: The statements and questions contained in my writings are not intended to convey allegations regarding any particular company, person, or association. Readers should conduct their own investigation of a company or association or person to ascertain the particular policies, practices, and motivations of that entity. I have reported what I believe to be true and correct to the best of my knowledge and opinion at the time of its writing in a free speech effort to avert a public health disaster.