NOTICE OF A PROPOSAL TO CHANGE THE MATCH AND CIGARETTE TESTS IN THE FURNITURE AND FURNISHINGS (FIRE) (SAFETY) REGULATIONS 1988 (FFRs)

Summary paper written by Terry Edge of the Department for Business, Innovation and Skills, and Steve Owen of Intertek Ltd.

Summary of the Proposal

The Department for Business, Innovation and Skills (BIS) intends to propose changes to the match and cigarette tests of the FFRs. Subject to approval by government Ministers, these proposals will be put out to full public consultation around Spring 2014. In advance, BIS is circulating the following notes to interested stakeholders regarding the changes, and welcomes any comments (see below for contact details).

Main points of proposed changes

  • New match test for cover fabrics to be undertaken over combustion-modified foam, not non-fire retardant polyurethane foam as with the current test.
  • Removal of the need to perform the cigarette test on fabrics which pass the match test, and for invisible linings.

Main benefits

  • A possible reduction in flame retardant chemical usage for the match test by 30-50%:
  • UK furniture as fire-safe as now, more so in some cases;
  • Savings to the furniture manufacturing industry of around £30-50m (rough estimate only) per year (mostly from FR reduction; some from removal of cigarette test);
    Greener UK furniture.

Costs


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  • Small amount of additional testing for some products but these costs greatly outweighed by savings.

Timing

Subject to Ministerial clearance and public consultation, BIS proposes to implement these changes in April 2015.

Work is also proceeding on amendments to the FFRs in general – clarifying and simplifying the requirements – and BIS intends to implement these (again subject to Ministerial clearance and public consultation) in 2016.

Lead-in times

The new match test/cigarette test will include suitable lead-in times to a) allow industry to develop new compliant products, and b) to sell off existing stock (compliant with the current tests). The final lead-in period will be determined by the feed-back BIS receives during the consultation period but this may be around 12-18 months from the implementation date.

Background

BIS is currently undertaking a review of the Furniture and Furnishings (Fire) (Safety) Regulations 1988 (FFRs). The original aim of this review was to simplify and clarify the requirements towards saving costs for the enforcement authorities, fire services and business. Between 2010 and 2013 BIS worked with stakeholders on the various amendments required to modernise the Regulations. BIS aims to have these changes in place by 2016.

However, during the course of the review another issue has grown in significance: the levels of flame retardant chemicals (FRs) used to meet the requirements of the FFRs, in particular the match test. There is growing evidence to suggest that FRs, in particular some brominated flame retardants, adversely affect the environment, wildlife and human health (references and links to key research will be included in the consultation paper). Whatever the exact degree of harmfulness, BIS is concerned that this issue, if not addressed, could jeopardise the future of the FFRs, chiefly though two factors: consumer concern and resistance from EU countries that are opposed to the use of FRs in furniture.

In November 2013, California announced a new furniture flammability test that will effectively remove FR chemicals from US furniture. While BIS believes this test offers poor fire-safety, it nevertheless reflects growing concern amongst US consumers about the negative effects of FRs. The UK furniture industry report that they are receiving similarly concerned and increasing numbers of enquiries from UK consumers.

Over the past year, therefore, BIS has explored ways in which FR levels in UK furniture might be reduced, without lowering fire safety levels. During this time, Steve Owen of Intertek has worked with BIS on alternative test methods which could achieve this goal. In July 2013, a discussion paper was circulated to a selection of stakeholders, outlining various options for a new match test. This summary paper and the forthcoming public consultation paper/impact assessment take into account feed-back received on the discussion paper, as well as various follow-up meetings and conversations since then.

Costs

We believe the proposed changes could lead to a slight increase in testing for some products; however, we expect that this will be more than off-set by the removal of the need for the cigarette test in most cases.

Savings

Potential savings of around £30-50m per year are based on the reduced costs of FR chemicals, e.g. a 50% reduction could produce savings of around £8 per 3-piece suite, based on treatment costs of around £1.30 per metre.

BIS is aware that these figures are very much rough estimates and would be grateful for more specific figures that industry might be able to supply either now or during the consultation proper.

To discuss these proposed changes or comment on them please contact:

Terry Edge – for general points
BIS, 4thFloor, Orchard One
1 Victoria Street, London SW1H 0ET
Tel: 0207 215 5576
Email: terry.edge@bis.gsi.gov.uk

Steve Owen – for technical questions

Intertek
The Warehouse
Brewery Lane, Leigh WN7 2RJ
Tel: 01942 265700
Email: steven.owen@intertek.com

Further information relating to the consultation is also available via the BFC secretary