The new January 9, 2006 Risk Assessment of toxic chemical in flame proof mattresses from the CPSC has a lot of problems. They examine Antimony, Boric Acid, and DBDPO (Deca, a FR other groups are trying to get banned due to health risks.) and conclude all of these are safe. Of 13 barriers studied 7 contain Antimony and 5 contain Boric Acid. Both Antimony and DBDPO are known to cause cancer. The CPSC excludes children under age five from the risk analysis. They assume all these children will be protected by a vinyl sheet over their mattresses, and that this will protect them from exposure to these known acutely toxic chemicals. Parents will never know their new mattresses contain toxic chemicals as there are no labeling requirements.
The CPSC report proves:
For simplicity and to save space we will examine only the risks from Antimony below:
The CPSC assumes a Percutaneous (Skin) absorption rate of only .002 per hour of the chemical that has leached or migrated to the surface of our mattresses. This is only 2/1,000 ths of the available chemical.
The CPSC says: “As with any risk assessment, there are assumptions, limitations, and sources of uncertainty. … it should be noted that percutaneous [skin] absorption data were not available for antimony.” P 40
Thus they are only guessing about how much Antimony will be absorbed through our skin. 2/1,000’s of the chemical migrated to the surface of our mattress is a very small number. If they are wrong, it could make their calculations completely invalid that we only absorb only .8 mg of Antimony daily. We might absorb at lot more than this every day.
We know we absorb many things readily through our skin, i.e. Nicotine and Drug patches.
The Department of Health and Human Services, Agency for Toxic Substances & Disease Registry (ATSDR) http://www.atsdr.cdc.gov/ disagrees with many of the assumptions in the CPSC report. Antimony is contained in their 2005 CERCLA Priority List of Hazardous Substances, “which are determined to pose the most significant potential threat to human health due to their known or suspected toxicity and potential for human exposure.”
Here are some quotes from the ATSDR document regarding Antimony from: http://www.atsdr.cdc.gov/toxprofiles/tp23-c2.pdf
“Death was observed in rabbits following a single [dermal] application of Antimony. p 22
Two out of four rabbits died after 6-8 topical applications of antimony trioxide paste. The antimony trioxide was combined with a mixture formulated to resemble acidic sweat.
Antimony seems to absorb readily through our skin and the CPSC assumptions could be very wrong.
In Table 16 the CPSC assumes an ADI (Acceptable Daily Intake) of Antimony of 2.3 mg/kg/d. For their average person of 160 pounds, 72.25 kg, this translates to an acceptable daily intake of 166 mg. This seems a high number for a known acutely poisonous and cancer causing chemical. By comparison, many drugs we take are in the range of .25 mg, 5 mg, or 10 mg.
The CPSC internal risk assessment was reviewed by an independent group called Toxicology Excellence for Risk Assessment (TERA, www.tera.com). This review found significant problems, errors, and omissions with the CPSC report. Seven of TERA’s comments related to CPSC ADI assumptions being inaccurate. The CPSC refused to change their ADI assumptions saying they were obligated by law to use data from a Hazard Guideline from 1992. Perhaps we should consider newer science before we put our entire population at risk?
The ATSDR, a division of the CDC, also strongly disagrees with many of the CPSC ADI assumptions:
Inhalation and oral MRLs [Minimal Risk Level, the equivalent of ADI] for antimony and compounds were not derived. Damage to the lungs and myocardium has been observed in several species of animals following acute, intermediate, and chronic inhalation exposure (Brieger et al. 1954; Bio/dynamics 1985, 1990; Gross et al. 1952; Groth et al. 1986; Watt 1983). These effects have also been observed in humans chronically exposed to airborne antimony (Brieger et al. 1954; Potkonjak and Pavlovich 1983). At the lowest exposure levels tested, the adversity of the effects was considered to be serious. Thus, the data were inadequate for the derivation of an acute-, intermediate-, and chronic-duration inhalation MKL values.
The ATSDR says there is no safe level of exposure for Antimony! Also none are listed for Antimony in their list of MRL’s on another web page : http://www.atsdr.cdc.gov/mrls.html , “ATSDR MINIMAL RISK LEVELS (MRLs) December 2005”
Here are more quotes from the ATSDR health effects of Antimony:
Developmental Effects. An increase in the number of spontaneous abortions was observed in women exposed to airborne antimony in the workplace.
Reproductive Effects. Human exposure to antimony dust in the workplace has resulted in disturbances in menstruation (Belyaeva 1967). In animals, the failure to conceive and metaplasia in the uterus have been observed following inhalation exposure to antimony trioxide (Belyaeva 1967)… These data suggest a potential for antimony to cause reproductive effects in humans.
2.7 POPULATIONS THAT ARE UNUSUALLY SUSCEPTIBLE
Individuals with existing chronic respiratory or cardiovascular disease or problems would probably be at special risk, since antimony probably exacerbates one or both types of health problems. Because antimony is excreted in the urine, individuals with kidney dysfunction may be unusually susceptible.
2. HEALTH EFFECTS
Adverse health effects in humans following antimony exposure appear to target on the respiratory and cardiovascular systems. Eye and skin irritation have also been noted.
Antimony may be found in the blood and urine several days after exposure. [Antimony accumulates in our bodies.]
Chronic-Duration Exposure and Cancer. There are several human and animal chronic inhalation studies that indicate the targets appear to be the respiratory tract, heart, eye, and skin (Brieger et al. 1954; Cooper et al 1968; Potkonjak and Pavlovich 1983). … A no-effect level (NOEL) for respiratory or cardiovascular effects following exposure to antimony was not identified in the available literature. The NOEL is an important level in evaluating the risk of exposure to antimony, and it can be used along with protective uncertainty factors to help determine the amount of antimony humans can be exposed to without experiencing health effects. … Chronic toxicity information is important because people living near hazardous waste sites might be exposed to antimony for many years.
Oral studies have shown that antimony tends to accumulate in the liver and gastrointestinal tract (Ainsworth 1988; Sunagawa 1981)”
Above quotes from: http://www.atsdr.cdc.gov/toxprofiles/tp23-c2.pdf
Antimony MSDS: “Potential Health Effects: ... May cause heart to beat irregularly or stop. … Chronic Exposure: Prolonged or repeated exposure may damage the liver and the heart muscle.
Quoteing the CPSC risk assessment: CPSC staff has chosen to examine older children (5 year olds) because younger children's mattresses are more likely to be waterproofed due to their higher likelihood of bedwetting. This waterproofing, either with fluid-resistant ticking or mattress covers, is expected to reduce contact with FR chemicals, …”
This seems crazy to exclude children under age five from the risk assessment. This group is the most vulnerable to poisoning and developmental effects. Numerous studies over the past 30 years have shown young children are particularly sensitive to even very low levels of toxic exposure, i.e. Lead. Antimony is also a heavy metal like Lead. The flame proofing law also applies to youth and crib mattresses.
It is also ridiculous to assume all these young children will be protected by a vinyl cover over their mattresses. Of the parents I have spoken with, all said they never used a plastic cover on their children’s mattresses.
It is probably wrong to assume a vinyl cover would protect from toxic chemical exposure. Antimony is proven to leach through vinyl in crib mattresses by Jenkins; Craig; Goessler; Irgolic, in their study, “Antimony leaching from cot [crib] mattresses and sudden infant death syndrome (SIDS),” Others have said is not conclusively proven that Antimony in mattresses is linked to SIDS. It is difficult to conclusively prove because we absorb Antimony from many other sources. They did prove Antimony leached from vinyl covered crib mattresses. High levels of Antimony were found in the livers of dissected dead human infants. Antimony is a very commonly used flame retardant used in many household products such as carpets. It is thus difficult to prove direct cause and effect. It took over 20 years and many studies to prove Asbestos is harmful.
Antimony Trioxide accumulates in our bodies. When pressed by TERA about the cancer risk from Antimony Trioxide the CPSC admits: “The cancer effects are cumulative. Every exposure contributes to the overall lifetime risk of developing cancer.”
It seems unwise to put our entire population, 300 million people at risk to protect 300 from fire. Most people would rather take the 1 in one million risk of dying in a mattress fire rather than the risk of sleeping in known toxic chemicals.
All new mattresses sold in California, and one third of all new mattresses sold nationwide already contain toxic chemicals to meet the new law. Please stop this law.
You previously informed California their law is invalid and unenforceable because there is an existing federal flammability standard for mattresses for cigarette ignition. Please tell them again and stop them from enforcing this law.
See much more information at www.PeopleForCleanBeds.org or more simply www.CleanBeds.org