Toxic flame retardant chemicals added to a wide range of ubiquitous consumer products are now commonly found in house dust, breast milk, and blood. Significant exposures to synthetic chemicals are not limited to emissions from factories or industrial practices. Industrially produced chemicals are embedded in the ordinary materials and objects that populate our everyday lives, including materials used to make our homes and buildings, vehicles, food packaging, furniture, and commonly owned electronics. Studies have established that some of these chemicals are toxic to human life. Many more of these chemicals are suspected to be toxic. Once these chemicals are built into the products and materials of everyday life, they become ubiquitous, exposing people to potential health harms on a regular basis. Such exposures are difficult to avoid, and almost impossible to remove once they are in our environments. These are called Built-In Exposures. Some chemicals, such as Polychlorinated biphenyls (PCBs), which were used as flame retardants in the 1960s, have been banned. However, because they were built-in to our homes, workplaces, and everyday objects, they are still found in the blood and urine of all the Canadians who have been tested today.
Exposures to toxic flame retardant are an environmental justice problem. Though they are widespread and nearly ubiquitous in our environments, flame retardants affect some people more than others. At low doses, for example, fetuses and infants are affected more than adults. In addition, the uneven distribution of these chemicals in our environments means that people who rely on hunting and fishing for food, people who live near heavy industry, and people who have lower incomes can have higher levels of flame retardants in their bodies and communities.
Current Canadian regulatory efforts to solve the problem of exposures to flame retardant chemical are flawed. Some of the most common flame retardant chemicals used today have been declared “toxic” by the federal government and their manufacture has been prohibited. However, Canadian regulations prohibiting the manufacture and use of PBDEs explicitly do not apply to consumer products or parts of products, such as foam. For this reason, Canadians continue to be exposed to these chemicals regularly. Moreover, the implementation of strict flammability standards for consumer products and furniture may exacerbate the problem as those standards often result in the addition of high volumes of flame retardant chemicals, both those that are already known to be toxic, as well as their “substitutes” that have not yet been assessed for toxicity.
But there are things that can be done to protect the health and wellbeing of Canadians. This white paper, Toxic by Design, makes policy recommendations that take account of complex scientific, legal, economic, and social factors. It summarizes the state of scientific research on the toxicity of common flame retardants, including proposed alternatives, as well as their efficacy for fire safety. It also questions our flammability standard-setting process in light of international debates. Our recommendations are guided by the principles of environmental and reproductive justice.
We recommend that the Government of Canada:
1) Prohibit consumer products and components of consumer products containing any flame retardant chemical for which there is evidence of harm, including alternative flame retardants, and those that have no environmental health assessment confirming their safety. Such action recognizes that the current substance-by-substance approach under the Canadian Environmental Protection Act (CEPA) and the slow timeline of assessment cannot adequately address the proliferation and distribution of replacement flame retardant chemicals. It also recognizes that the product-by-product approach of the Consumer Product Safety Act (CCPSA) cannot adequately address the widespread use of flame retardants in many kinds of products and materials.
2) Develop a strategy on the use of alternative flame retardant chemicals that meaningfully implements the precautionary principle. This requires, at minimum, that the government address the way that flammability standard-setting processes work at cross-purposes to the aims of CEPA. The government must integrate decision-making across these domains so as to address the problem of Built-in Exposures.
The full report can be found here.