New Info, CDC Doctor Proves Mattresses Toxic

I wrote to the CDC asking what level of Antimony exposure is safe. I got a reply from Dr. Selene Chou, a toxicologist from the CDC. (See my question and her reply in the email string below.) Dr. Chou replied: “ATSDR has not derived a chronic MRL 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.

Comparing these numbers to the CPSC assumptions in their table 16, tab d, p 45, shows:

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.

The CPSC claims their risk assessment was reviewed by an independent group, TERA.org. But when you look at the TERA comments and CPSC responses you see the CPSC flatly rebuts almost every recommendation TERA made and insists the CPSC is right. Seven of TERA’s comments recommend different assumptions for ADI, Acceptable Daily Intake, which the CPSC again rebuts. For instance TERA commented: “Comment 11. CPSC staff should consider harmonizing methods of calculating ADI's with other organizations.” Which the CPSC again rebutted. It does not matter if you call it ADI (Acceptable Daily Intake), MRL (Minimal Risk Level), or RfD (Refference Dose) they all mean the same thing and are interchangeable, and different government agencies use different terms. The key is which is a safe level of poison for us to absorb. Many of us do not want to absorb any level of poison from our beds. Indeed, if the CPSC had followed TERA’s advice and coordinated ADI’s with other organizations, it would have proved flame proof mattresses to be unsafe for the public, as the CDC Doctor has proven above.

It seems clear the CPSC is trying to prove poison laden mattresses are safe. There are many other problems with this risk assessment. Again over TERA’s objections they changed all the rules of the child sucking test to obtain lower numbers. We believe Boric Acid would fail a properly designed child sucking test, with realistic exposure data. This test is designed to protect a one year old child. The CPSC did not even consider children under five in their risk assessment. They said: “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 is terrible to exclude young children, any proper risk assessment would include them and other sensitive populations.

TERA also points out that a good risk assessment should include exposures from other sources: “Comment 14. Exposures from other sources (e.g., upholstered furniture) and their potential impact on risk should be mentioned.” Again, the CPSC flatly refuses saying they are only studying mattresses, even though they are pushing through another law on open flame resistance of upholstered furniture that will also require these chemical exposures. By then the only time we will not be absorbing poisonous chemicals is while we are standing up.

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

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. This seems a very small number. The correct number might be much higher and we may absorb much more than the CPSC calculations predict.

Dr. Chou points out: “ATSDR has not derived a chronic MRL for antimony.” They can not derive one because as stated in their health effects document on antimony they say: “At the lowest exposure levels tested, the adversity of the effects was considered to be serious.”

As shown in Table 1, tab H, Antimony is used in more than half of the flame barrier systems for mattresses (7 of 13). Boric Acid is used in 5 0f the 13. Many other chemicals are also used to flame proof mattresses including Silicon, Deca, Formaldehyde, and Ammonium Polyphosphate. The CPSC says large amounts of Ammonium Polyphosphate leach from mattresses, but they consider this non toxic while other agencies disagree.

We have super close, super chronic, exposure in mattresses unparalleled in any other exposure. Any one of these chemicals could prove harmful over many years of absorption. Consider the magnitude of our entire population sleeping in and absorbing these poisons. Any one variable going wrong would harm millions.

All the mattress manufacturers try to say they don’t use chemicals to flame proof their beds. Why, because no one wants to sleep in known toxic chemicals. The CPSC has received over 800 public comments against this law when they would normally receive only about twenty comments on most issues. This public outrage generated a story in the Washington Post titled: “Fire-Resistant Mattresses Ignite Fear of Chemicals”

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.”

Dr. Selene Chou of the CDC and the EPA has proven CPSC safety assumptions wrong. Dr. Chou has also proven CPSC exposure and absorption calculations of poison absorbed from flame proof mattresses will exceed toxic levels by 27.5 times.

Please stop this law!

See much more information at www.PeopleForCleanBeds.org or more simply www.CleanBeds.org

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

From: Chou, Selene [mailto:cjc3@cdc.gov]
Sent: Tuesday, February 07, 2006 10:00 AM
To: Mark Strobel
Subject: RE: What is MRL for Antimony?

ATSDR has not derived a chronic MRL for antimony.  However, the U.S. EPA chronic oral reference dose for antimony is 4E-4 mg/kg/day.

Selene Chou

From: Mark Strobel [mailto:mark@strobel.com]
Sent: Monday, February 06, 2006 10:31 PM
To: Chou, Selene
Subject: What is MRL for Antimony?

What is the Minimal Risk Level for Antimony Trioxide for chronic absorption? I don’t find it listed on your web page of MRL’s. I have heard the MRL for chronic Antimony exposure is 2.3 mg/kg/day, could this be correct?

Thank you for a prompt reply,

Mark