New Info, CDC & EPA
Proves Mattresses Toxic
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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.
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.
http://www.epa.gov/iris/subst/0006.htm
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.
The CDC 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.”
The
CDC and the EPA has proven CPSC safety assumptions wrong. They have 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!
From CPSC Table
17 you will see that for 5-year old Children the CPSC says they will absorb
.50829 mg of Antimony every day. For the average 20 kg child this is .025415
mg/kg/day. Compared to the EPA safe level of .0004 mg/kg/day this gives a
hazard index of 63.54. In other words five year old children will absorb 63
times more Antimony every night from flameproof mattresses than the EPA says
is safe.
Younger children were
not studied and even crib mattresses must be flameproof and often contain
both Boric Acid and Antimony.
DBDPO
Also in CPSC Table
17 you will see they assumed the ADI (Acceptable Daily Intake) is 3.2
mg/kg/day for DBDPO. Compare this to the EPA published safe level of .01
mg/kg/day. This is a difference of 320 times. In other words the CPSC
assumed it is safe to absorb 320 times more than the EPA says is safe to
absorb for DBDPO. A substantial difference.
http://cfpub.epa.gov/ncea/iris/index.cfm?fuseaction=iris.showQuickView&substance_nmbr=0035
If you combine a more
reasonable skin absorption rate of only 2% with the EPA safe level for DBDPO
it would prove that DBDPO in mattresses exceeds safe levels and is toxic,
with their own calculations.
See much more information at
www.PeopleForCleanBeds.org or more simply
www.CleanBeds.org
CPSC Risk Assessment of Flameproof
Mattresses, see the facts firsthand:
Short version, 21 selected
pages highlighted
Full version, 77 pages Bookmarked
Highlighted, Searchable
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
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