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US Consumer Products Safety commission open public comment period on new law, Closes March 14, 2005, click here for email, fax, and mailing address to send your comments

Short Story : An Open Letter to Mattress Retailers (This letter was successfully faxed to 17,192 Furniture Retailers)

International Sleep Products Association (ISPA) response to above letter (they omit Inhalation exposure and more, and try to tell us we would have to eat our mattress to absorb poison. Then they try to tell us that since Boric Acid kill insects differently than humans, it's not poison to people):

Strobel's Response to ISPA's defense of Boric Acid in Beds

‘Society of Toxicology,’ News Release warns more study needed before putting these chemicals in beds

Quotes from the Consumer Products Safety Commission draft of new law on health effects
The following hot-links will take you to different parts of this report

Doctors Oppose New Law that puts Poisonous Chemicals in All Our Mattresses (Intro)
Quotes and Links from recent Science, EPA, and CDC
Boric Acid Material Safety Data Sheet (MSDS)
Pesticides Linked to Stillbirths
Quotes from other sources
Doctors Quotes on this issue
Background and Summary of the Law
What Proponents Say and Rebuttals
Modacrylics -- Metal Oxide Flame Retardant Chemical
What Proponents Say about Boric Acid, and Rebuttals
Cutaway Photo of Boric Acid Innerspring Mattress
Amount of Boric Acid in Mattresses by Size
A simple way to stop this law in California
Hippocrates left us with the admonition: "First do no harm.”
A note to Retailers

Doctors Oppose New Law that puts Poisonous Chemicals in All Our Mattresses


 A new law is being enacted nationwide by the CPSC within the next year, and goes into effect in California January 1 2005, which requires all mattresses to resist ignition from open flames. The primary chemical used, as a flame retardant, is a poisonous pesticide called Boric Acid, yes exactly the same chemical shown at left (H3BO3). Our recent science gives us many more warnings on human exposure. The EPA and CDC warn of Reproductive, Developmental, and Neurological Damage. It has many known health risks including, genital damage, brain damage, anemia, infertility, birth defects, and death, and at the very least may dry and irritate your skin and lungs.

This Poisonous chemical is going in our beds, not in some plastic part on your computer. Our Beds, where we sleep, are intimate, and lay our newborn babies with us. These chemicals are concentrated in the surface of our mattresses and absorb through our skin and breathing. Doctors agree long close exposure on a mattress eight hours every day increases risks.

This issue is urgent because these chemicals are already being added to many new mattresses nationwide in anticipation of this new law. The law becomes effective January 1st in California and probably within the next year for the entire United States. While Boric Acid is an ancient method to fireproof cloth, it is also a known poisonous pesticide/insecticide. When Roaches, Ants, and other insects walk through its dust it kills them, and their entire colony within three weeks. It may be safe use to fireproof something like booth drapes at a convention. But this time they are putting a large amount of it in the surface of our mattresses!

Boric Acid is a poisonous pesticide: Effectively kills roaches, silverfish, ants, fleas, palmetto bugs and water bugs. Most people have the common sense not to put a pound or more in the surface of their mattress.

They have a saying in the pesticide industry, “There are no safe pesticides, only safe use.” Respected Doctors agree: Boric Acid in the surface of mattresses is not safe use.

Most people have trouble believing industry and government are putting this poisonous chemical in our mattresses to make them fireproof, and think, they must use a different chemical or something else. No, it is exactly the same chemical as the pesticide (H3BO3). Check the mattress Law Tag; if it says ‘Treated Cotton’ it’s likely Boron/Boric Acid.

How is this happening? It appears industry and government have taken the attitude, ‘Well, we have been making cloth fireproof for years with Boric Acid and don’t know of killing anyone yet. They consider it a good chemical because it can protect us from fire. Then they make the stretch that it is OK to concentrate a large amount of this chemical in the surface of our mattresses. Does the Consumer Products Safety Commission (CPSC) not know what another branch of our government is doing? The Agency for Toxic Substances and Disease Registry (ATSDR) a division of the Center for Disease Control (CDC) cites Boron/Boric Acid as one of 275 substances “which pose the most significant potential threat to human health”  

Perhaps the CPSC and industry are unaware there are a lot more new scientific discoveries in the last 30-years that prove and warn of the human exposure risks from Boric Acid. One mattress with this chemical claims: “Contains no harmful chemicals.”

Quotes and Links from our Science, EPA, and CDC

The following quotes are from the conclusions of a recent EPA document:

 June 2004



Studies in laboratory animals conducted by oral exposure have identified the developing fetus and the testes as the two most sensitive targets of boron toxicity in multiple species (Weir and Fisher, 1972; Seal and Weeth, 1980; NTP, 1987; Fail et al., 1991; Price et al., 1996a,b; Field et al., 1989).

The developmental effects that have been reported following boron exposure include high prenatal mortality, reduced fetal body weight and malformations and variations of the eyes, central nervous system, cardiovascular system, and axial skeleton (Price et al., 1996a,b; Field et al., 1989).

The testicular effects that have been reported include reduced organ weight and organ:body weight ratio, atrophy, degeneration of the spermatogenic epithelium, impaired spermatogenesis, reduced fertility and sterility (Weir and Fisher, 1972; Seal and Weeth, 1980; NTP, 1987; Fail et al., 1991; Dixon et al., 1979; Linder et al., 1990; Treinen and Chapin, 1991; Ku et al., 1993 ).

Boron is readily absorbed from the gastrointestinal tract following oral exposure (Schou et al., 1984; Vanderpool et al., 1994). Boron is also absorbed following inhalation exposure, although it is not clear how much is absorbed directly through the mucous membranes of the respiratory tract and how much is cleared by mucociliary activity and swallowed (Culver et al., 1994).

Boric acid and borate compounds in the body exist primarily as undissociated boric acid, which distributes evenly throughout the soft tissues of the body (Ku et al., 1991; Naghii and Samman, 1996b). Although it does not accumulate in the soft tissues, boron does accumulate in bone, reaching steady-state levels approximately 4-fold higher than plasma levels after 1-4 weeks, depending on dose (Ku et al., 1991; Chapin et al., 1997). Boric acid is not degraded in the body, but can form complexes with various biomolecules by mechanisms that appear to be concentration dependent and reversible (IEHR 1997; WHO, 1998a). Boric acid is excreted primarily in the urine. It is cleared from the plasma with a half-life of approximately 21 hours (Jansen et al., 1984a), but eliminated very slowly from bone (Chapin et al., 1997).

Confidence in the principal developmental studies is high; they are well-designed studies that examined relevant developmental endpoints using a large number of animals. Similar developmental effects were noted in rats, mice and rabbits. Confidence in the data base is high due to the existence of several subchronic and chronic studies, as well as adequate reproductive and developmental toxicology data.

Occupational exposure to boron dust and exposure to boron in consumer products (e.g., cosmetics, medicines, insecticides) are other potentially significant sources (ATSDR, 1992). [I don’t think these researchers or EPA ever considered the possibility that we would put 1.5 pounds of Boric Acid powder as loose dust in the surface of Queen mattresses.]


Millions of people are unknowingly already sleeping in this poison in anticipation of this new law. Industry, CPSC, and California will soon force our entire population to sleep in these chemicals.

It seems industry is relying on the report from J.R. Blasius (not even a doctor) on a NCBI web page to justify use of this chemical. We know Boric Acid is poison. Why has no one considered our modern science?

“EPA has identified health concerns for reproductive and blood toxicity based on data on structurally similar borons. … EPA has determined, however, that manufacture, process, or use of the substance without dermal protection may result in serious chronic and developmental effects. Also, based on analogy to boron, EPA is concerned that toxicity to aquatic organisms may occur at a concentration as low as 300 ppb of the PMN substance in surface waters.”



Boric acid (CAS No. 10043-35-3); Tetraborate and its salts, including sodium borate


Male reproductive toxicity has been manifested as testicular atrophy and adverse effects on sperm production.


Female reproductive toxicity has been manifested as decreased numbers of litters produced, and decreased numbers of corpora lutea.


Developmental toxicity has been manifested as reduced viability, reduced fetal weights, and an increase in the frequency of morphological variations.

The US Environmental Protection Agency (US EPA, 1993a and 1993b) concluded that: "In chronic oncogenicity studies using mice, rats and beagle dogs, boric acid and borax were found not to be carcinogenic; however, testicular effects and decreases in body weight resulted at high dose levels." "In reproductive and developmental toxicity studies using rats, mice, and rabbits, maternal liver and kidney effects and decreased weight gain as well as decreased fetal body weights were observed. In two studies, at the highest dose levels, no litters were produced. Prenatal mortality occurred at the highest dose levels in the rabbit study." The numbers of corpora lutea were found to be decreased in a multi-generation study conducted in rats, indicating a decreased frequency of ovulation. When treated female rats were mated with control males, there was a decrease in the number of litters produced, and pup survival was compromised.”

“Chronic dermal exposure to boron in neonates was fatal (Litovitz et al. 1988).” 

“Women exposed during early pregnancy to chemicals such as cockroach and ant insecticides for one month in the home environment were found to have a70% raised risk for stillbirths due to congenital defects,” the researchers conclude. (Occupational and Environmental Medicine, 1997;54:511-518)”

“Animal studies demonstrated that boron can cause injury after intermediate and chronic exposure to the gonads in animals, especially the testes. (Seal and Weeth 1980)” 

“Oral studies in animals demonstrated injury to the gonads and to the developing fetus. (NIEHS 1990a; NTP 1987; Weir and Fisher 1972).”

“Chronic inhalation exposure caused irritation of the upper respiratory tract (Garabrant et al. 1984, 1985).”

“Boron does cause health effects following acute dermal exposure.”

There is one human study that showed reproductive damage with a sample size of 28 men. (Tarasenko et al. 1972)

Death. Human studies have shown that boron can be lethal following short-term exposure. The minimal lethal dose of ingested boron (as boric acid) was reported to be 2-3 g in infants, 5-6 g in children and 15-20 g in adults (Locatelli et al. 1987; Wong et al. 1964).”

The above quotes come largely from The Agency for Toxic Substances and Disease Registry (ATSDR) a division of the Center for Disease Control (CDC) published report called ‘Health Effects’ that reviews all the known science on Boric Acid. Please see the entire 36 page report at:  Below are quotes from the conclusions of this document:

  •  “Demonstrated injury to the gonads and to the developing fetus. …
  • Boron (as boron oxide and boric acid dusts) has been shown to cause irritation of the upper respiratory tract in humans. …
  • Boron does cause health effects following acute dermal exposure. …
  • Neonatal children are unusually susceptible to boron exposure. …
  • Neurological damage is an area of concern following exposure to boron …
  • In spite of the absence of reliable human data, limited evidence of reproductive effects in animals suggest that reproductive toxicity may be an area of concern following boron exposure in humans.”


We know the most about Boric Acid from numerous human and animal studies that cover not only ingestion, but also inhalation, skin contact, and genital contact. All these studies show serious risks for humans. Our government gives us strong warnings about Boric Acid chronic exposure risks with the greatest risks being neurological, and reproductive damage.

Studies with dogs showed genital contact with Boric Acid attacked, damaged, and shrunk the gonads.

“Studies in humans, particularly infants, show that boron (as boric acid) can be lethal following ingestion. Infants who ingested formula accidentally prepared with 2.5% aqueous solution of boric acid died within 3 days after exposure (Wong et al. 1964). … 5 of 11 infants died … Degenerative changes were seen in the liver, kidney, and brain.”

“One study was reported involving occupational exposure (10 years or greater) to boron aerosols (22-80 mg/m3) in males engaged in the production of boric acids (Tarasenko et al. 1972). The study group was small, consisting of 28 men. Low sperm counts, reduced sperm motility and elevated fructose content of seminal fluids were observed.”

“Dogs were fed 29 mg boron/kg/day as borax and boric acid (1,170 ppm), respectively in the diet for 38 weeks (Weir and Fisher 1972). Testicular atrophy and spermatogenic arrest were reported. Reproductive effects were reported in rats following chronic exposure. In rats fed up to 58.5 mg boron/kg/day (as borax or boric acid) for several generations, there was a lack of viable sperm in atrophied testes and ovulation decreased in females (Weir and Fisher 1972).”

“Boric acid was detected in urine of patients 23 days after a single ingestion (Wang et al. 1964).”

“In animals, prenatal exposure of mice (79 mg boron/kg/day as boric acid) and rats (13.6 mg boron/kg/day as boric acid) during gestation days 0-17 and 0-20 caused developmental effects consisting of reduced fetal body weight or minor skeletal changes and possibly delay in maturation (Heindel et al. 1991). There was degeneration of the seminiferous tubules and impaired spermatogenesis in mice exposed to dose levels of 111 mg boron/kg/day as boric acid for 2 generations (NIEHS 1990).”

Boric Acid MSDS

Boric Acid is absorbed through skin contact, particularly damaged skin, and inhalation. Quoting the federally required Material Safety Data Sheet (MSDS) for Boric Acid (H3BO3):

Potential Health Effects

Causes irritation to the mucous membranes of the respiratory tract. May be absorbed from the mucous membranes, and depending on the amount of exposure could result in the development of nausea, vomiting, diarrhea, drowsiness, rash, headache, fall in body temperature, low blood pressure, renal injury, cyanosis, coma, and death.
Symptoms parallel absorption via inhalation. Adult fatal dose reported at 5 to > 30 grams.
Skin Contact:
Causes skin irritation. Not significantly absorbed through the intact skin. Readily absorbed through damaged or burned skin. Symptoms of skin absorption parallel inhalation and ingestion.
Eye Contact:
Causes irritation, redness, and pain.
Chronic Exposure:
Prolonged absorption causes weight loss, vomiting, diarrhea, skin rash, convulsions and anemia. Liver and particularly the kidneys may be susceptible. Studies of dogs and rats have shown that infertility and damage to testes can result from acute or chronic ingestion of boric acid. Evidence of toxic effects on the human reproductive system is inadequate.
Aggravation of Pre-existing Conditions:
Persons with pre-existing skin disorders or eye problems, or impaired liver, kidney or respiratory function may be more susceptible to the effects of the substance.”

See full MSDS: 

Pesticides Linked to Stillbirths

“Maternal exposure to workplace or household pesticides in early pregnancy increases the risk for stillbirths, The study authors discovered that one month of maternal exposure to workplace pesticides during the first two months of pregnancy resulted in a 2.4 times increased risk for stillbirth due to congenital defects, compared with mothers with no such exposure. Pregnant women with one-month workplace pesticide exposures during their first trimester (three months) also faced a 70% raised risk for stillbirths due to placental, cord, and membrane complications

Home exposure was by far the most common site for maternal pesticide exposure Women exposed during early pregnancy to chemicals such as cockroach and ant insecticides for one month in the home environment were found to have a 70% raised risk for stillbirths due to congenital defects, the researchers conclude. Occupational and Environmental Medicine (1997;54:511-518)”

“Exposure to pesticides, especially during early pregnancy, had a clear positive association with stillbirths regardless of cause of death.”

Quotes from other sources

 “The National Academy of Sciences reports that children may be uniquely sensitive to chemicals and pesticide residues because of their rapid tissue growth and development.”

“Effects can be subtle and can show up decades or generations after exposure, so it is difficult to prove an immediate cause and effect. The best way to minimize pesticide risks is to avoid use in the first place. Follow the example of the National PTA, which has endorsed minimizing children's exposure to toxic agents.”

“Other adverse effects that do not include any immediate symptoms of illness can occur when smaller amounts of boron are used on a regular basis. These injuries are not as well known but involve stunted growth (in experimental animals) and infertility in human beings.”“Boric acid is cited as one of the pesticides/fungicides that can induce adverse skin reactions such as contact dermatitis and hyperkeratosis with dermal contact of treated surfaces.” 

“Pesticide poisoning is a commonly under-diagnosed illness. Health care providers generally receive a limited amount of training in occupational and environmental health, especially in pesticide-related illnesses.”

“Alopecia [Hair Loss] was completely reversed by elimination or reduction of exposure to boron-containing materials in all 3 patients. We conclude that occupational topical exposure to boron in solutions may cause reversible alopecia.”

Doctors Quotes on this issue


Dr. Liberman made the following statement:

We live in a very technologically advanced world, which advocates the advantages of these technologies but rarely ever considers the disadvantages or potential harm. Everything in life must be considered on a cost/effectiveness ratio basis.


It seems ill advised to expose hundreds of millions of people to a potential health hazard in order to protect a very few.  …. I am absolutely opposed to adding the proposed toxic chemicals to mattresses. I render my opinion based on my education, training and experience in the field of occupational and environmental medicine.”




Allan D. Lieberman, MD

Consultant in Occupational and Environmental Medicine

Diplomate, American Board of Environmental Medicine
Member, American College of Occupational
& Environmental Medicine

N. CHARLESTON, SC. 29420-4297
Phone 843-572-1600 / Fax 843-572-1795
Website: E-mail:

Dr. Rapp made the following statement:


“The world has gone completely crazy. Until the powers that be can prove that what they propose for protecting mattresses against fire will not harm a pregnant woman, an unborn baby, an infant, a child, the elderly or a normal male or female they should UNQUESTIONABLY NOT EVEN CONSIDER PUTTING CHEMICALS INTO EVERY MATTRESS.

What can we do to stop the nonsense!!!



Doris J. Rapp, MD, F.A.A.A., F.A.A.P.   Is a board-certified environmental medical specialist and pediatric allergist. She was a clinical assistant professor of pediatrics at the State University of New York at Buffalo. Dr. Rapp is the founder of the Practical Allergy Foundation and is a past President of the American Academy of Environmental Medicine. She is also the author of several books.

• 1421 Colvin Blvd • Buffalo, New York 14223 Phone 716-875-0398 •

Fax 716-875-5399 • Website: Email

These respected Doctors oppose not only Boric Acid, but also any chemical that is known to be toxic. They also oppose any new flame retardant chemical to be put in our mattresses that have not been thoroughly tested for human toxicity for use in this application.

Background and Summary of the Law


As a Mattress Manufacturer who has been in business for thirty years I began investigating what is required to meet a new law where mattresses must pass open flame ignition tests. At first I was concerned because we have not had a good history with trying to make things fireproof. We have created nightmares with Asbestos and Flame Retardant Chemicals. PCB FRC’s were banned in 1976 after much human and environmental damage that continues to this day. PBDE’s were found in women’s breast milk in 2003. In 2004 we find still another FRC that should be banned. As I investigate the chemicals required to be used in mattresses under this fire standard I become more and more alarmed. They create a health risk that could be catastrophic.

Even though an existing 1973 federal law requires mattresses not ignite from cigarettes burning all the way down -- A new law will require mattresses to also resist open flame ignition. This new law has been called “the toughest fire standard, of any kind, ever.” The test method requires mattresses to withstand a large flame from a propane torch for about a minute and then not ignite for 30 to 60 minutes. To meet this standard mattresses must be completely encased in a thick fire barrier fabric just under the outer ticking. This fire barrier requires a large amount of flame retardant chemicals to pass this test. Mattress manufacturers are free to meet this standard with any chemicals they choose. The chemicals used will be Modacrylics (acrylic fibers modified by the addition of Metal Oxide flame retardant chemicals) and Boric Acid (a flame retardant that is also a poisonous pesticide and known toxin). The most cost effective and widely used solution is and will be cotton batting with a large amount of Boric Acid added. Boric Acid is not chemically bound and exists as loose dust mixed with the cotton fibers.

According to USA Today, “Though the USA has the world's toughest flame retardancy standards, 3,000 people die in fires each year. The Chemical Manufacturers Association estimates the number would be up to 960 higher without the [1.2 Billion pounds of] flame-retardant chemicals we now use [annually]. (2)  “From 1980 to 1998, bedroom fires dropped 68 percent and their related deaths by 52 percent, according to the U.S. Consumer Product Safety Commission. Why? -- A standard that was enacted in 1973 that prevents mattress ignition from cigarettes. Do we need more regulation?

We all want to save lives. Does the risk outweigh the benefit? Proponents of the new regulation want to reduce open flame ignition of mattresses by requiring a thick chemically saturated fire suit on every mattress. This has been called ‘the toughest new fire standard ever.’ ISPA (International Sleep Products Association) estimates some 300 people die from open flame ignition of mattresses each year. Are 10% of the fire deaths a high estimate? They also estimate up to one third, or 100 people might be saved by this new law, after twenty or more years, when all existing mattresses are replaced -- A best estimate gain of five lives per year. These estimates are debatable. In a fire toxic gasses from the new FRC’s might kill more than they save. Of course 100, 5, or even one life are hugely important. But there is also an associated risk. We will test hundreds of millions of people, our entire population, with chronic exposure to these chemicals. What if, we find years from now that the lawyers get rich again and we have sterilized, harmed, or killed massive amounts of people? Is the benefit worth the risk?

What Proponents Say and Rebuttals

The innerspring mattress industry generally supports this law. ISPA (International Sleep Products Association) went to the CPSC (Consumer Products Safety Commission) and asked that this new fire law be established nationwide. From reading ISPA’s web site it appears they also started and supported the law in California. Why would an industry group ask for more government regulation? Perhaps their interests are pure and they are only concerned about public safety. Or, do they have other reasons that serve their self-interest? The innerspring mattress industry has seen their market share decline as specialty, newer technology, beds have recently grown to over twenty to thirty percent of the market. It might be easier and less costly to protect metal wire coil spring mattresses from fire than it is for other types of mattresses such as Visco-Elastic, Foam, Air, or Latex mattresses. Are they thinking that testing costs to comply will drive many of their smaller competitors out of business? Are they thinking that since everyone’s costs and prices will go up that they will earn more revenue and profit on the same number of unit sales? Do they see this as a win-win-win for themselves that keeps people sleeping on metal wire innerspring mattresses that were invented in 1871, increases profits, and squashes specialty and smaller competition? As Doctor Rapp said: “Follow the money trail to see the real reason for this law.” Could Dr. Doris Rapp be right?

ISPA (International Sleep Products Association) has been pushing hard to get this new law enacted and tries to obscure that manufacturers use Flame Retardant Chemicals.  See their website:  See Item 24, paragraph 2: They tell us they don’t use flame retardant chemicals, but inherently flame retardant fibers and mention para-aramids, melamines, and modacrylics. This is a clever play on words because these technical names are Flame Retardant Chemicals. Para-aramids appear to be Kevlar and is used in the thread to hold the fire barrier together. Melamine is a flame retardant chemical, Melamine is toxic, gives sore throat, coughing, eye irritant pain, and there is a risk of formation of stones in the urinary bladder.

(ISPA now admits it requires Flame Retardant Chemicals to meet this new flame standard. They admit manufacturers are using Antinomy Oxide and Boric Acid. 'ISPA, Special Edition Newsletter' 11-12-04)

Modacrylics -- Metal Oxide Flame Retardant Chemical

Modacrylics are modified acrylic fibers. The brochure and web site from the only North American Modacrylic fiber supplier, tells us they modify acrylic fiber by adding a Metal Oxide flame retardant chemical.

The full name for Modacrylic fibers is: Acrylonitrile-Vinylidene Chlorine Copolymer containing Metal Oxide FR Synergist. According to ISPA, they use Antimony Oxide as the flame retardant chemical. The above web link also links to their Material Safety Data Sheet (MSDS) on Modacrylics. If you read this document it tells you Modacrylics are only “Slightly Toxic” for skin contact, and

“Avoid eye contact. … Minimize skin contamination … Avoid breathing dust. … Use approved respiratory protection equipment … Provide natural or mechanical ventilation to minimize exposure. … Handle in accordance with good industrial hygiene and safety practices. These practices include avoiding unnecessary exposure and removal of material from eyes, skin and clothing.  …

ECOLOGICAL INFORMATION: Solutia has not conducted environmental toxicity or biodegradation studies with this material. …

TOXICOLOGICAL INFORMATION: Solutia has not conducted toxicity studies on this material and no toxicological information was obtained in a reasonably extensive search of the available scientific literature.”


Here are some quotes from the MSDS on Antimony Oxide:

“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. Prolonged skin contact may cause irritation, dermatitis, itching, and pimple eruptions. There is an association between antimony trioxide production and an increased incidence of lung cancer.” see it yourself at:


I strongly disagree with ISPA saying there are no flame retardant chemicals in fire barrier systems for mattresses. I have been unable to find any fire barrier solution to meet this standard that does not require the use of FRC’s. But all of the above may be meaningless because Boric Acid fire barrier solutions are by far the most cost effective and will be the most used in mattresses most people sleep on.

In defense of Mattress Manufacturers who are aware of some risks of Boric Acid, and are trying to find a chemical free system, it’s not easy. Fire barrier suppliers try to be secretive about their systems and tell us there are no chemicals, but inherently flame resistant fibers. There are not that many types of fibers out there. When you ask for a MSDS they somehow always forget to send it. When you push hard enough, you find out it is a Modacrylic system.

What Proponents Say about Boric Acid, and Rebuttals

ISPA’s web page goes on to tell us: “Boric acid treated cotton has been widely used by the U.S. mattress industry for more than 30 years with no known human toxicity or environmental problems associated with this application. In fact, boric acid solutions are often used as an eye wash.” While there are some safe uses for Boric Acid including eye wash, “In the past, boric acid was used as a topical treatment for infants with diaper rash. However, even in diluted (3%) form it caused significant toxicity and two deaths.” Our exposure in mattresses will be close and chronic.

In my own 30-years experience I have never known boric acid to be used in innerspring mattresses and double-checked with some people. I spoke with a regional manufacturer who has been making mattresses since 1958, almost fifty years. He confirmed he has never used or seen boric acid used in cotton batting in mattresses because it is not needed. He explained that mattresses easily pass the cigarette ignition test when foam or polyester is quilted into the ticking and there is no need to pay the 7% extra cost to have boric acid added to the cotton batting. I then spoke with a cotton batting manufacturer and was told that none of his innerspring mattress manufacturer customers bought boric acid treated cotton batting. They only bought untreated batting for the above reasons, they did not want to pay the extra costs and it was not necessary to meet existing federal standards for cigarette ignition. Thus I dispute ISPA’s statement that Boric Acid has been ‘widely’ used in mattresses.

From reading ISPA’s web site I can’t find any research on the safety of flame retardant chemicals they will use. I don’t think there is any. Like the Modacrylic fiber manufacturers admission – there is no toxicological research. Yet we charge ahead and put FRC’s in our mattresses that we know nothing about how they will affect people.

The only thing I can find that speaks to the safely of these chemicals is the National Cotton Batting Institute website. On a NCBI web page, , someone who is not even a doctor admits the safety question of Boric Acid exposure comes up every year. He tells us Boric Acid has been used since the days of the ancient Greeks as a food preservative. This was true until the early 1900’s when it was largely banned as a food preservative because we discovered the true dangers and people were getting sick and dying from Boric Acid. Then he says: “The Environmental Protection Agency has established that boric acid is benign.” I don’t know where he gets this statement because my research shows the EPA warns Boric Acid is a Reproductive and Developmental Toxin. The EPA warns not to have skin contact: “use of the substance without dermal protection may result in serious chronic and developmental effects.” “EPA is concerned that toxicity to aquatic organisms may occur at a concentration as low as 300 ppb” (Please see previous links to EPA statements.) Then they cite a single measure of toxicology, on a single animal species, by stating it takes huge oral quantities, 2660 milligrams of dose per kilogram of body weight, to kill half the rats in a study and compares Boric Acid to Table Salt. There are many more facts they leave out. Inhalation appears to be a much greater risk than oral and rats have died from inhaling only 28mg/m3/4h.  He does not tell us that our government reports human deaths from “2-3 g in infants, 5-6 g in children and 15-20 g in adults (Locatelli et al. 1987; Wong et al. 1964).” He does admit Boric Acid is toxic: “So are borates toxic? Certainly, and so is virtually every and anything else you come in contact with.” I guess this some how makes it OK that we are exposed to a lot of toxins, and also sleeping in them won’t matter?  He then goes on to say we don’t know of killing anyone yet by using it in mattresses. It is not just a matter of dying. Boric Acid also makes you sick from much lower quantities. Recent numerous studies on various animal species and humans with various types of exposures and durations show Boric Acid can do serious damage with no external symptoms. It appears they have not considered or addressed the huge warnings our modern science gives us.

Until now, under the new law, Boric Acid in mattresses has been very limited. It has been used in some prison mattresses and that would be a very good place for researchers to look for health or sterilization affects. “Central nervous system injury, gastrointestinal effects, and skin damage are characteristic manifestations of boron toxicity in humans. Liver and kidneys in humans and testes in animals can also be affected. Various clinical and biochemical changes associated with these effects may be measured to detect the extent of exposure to boron. There is no single biological indicator of boron exposure” It can be difficult to detect Boron poisoning. Are there unreported cases of Boron poisoning from mattresses? I read a report of one Asthma sufferer who claimed sleeping on a Boric Acid mattress made it difficult for him to breathe. He tried alternating sleeping on the Boric Acid and a ‘clean’ mattress for several days each for several trials. He finally determined the Boric Acid mattress was causing his problem. What will happen to these people when they can’t get a ‘clean’ mattress? Our healthy adult bodies can tolerate and get rid of a certain amount of poison. How about impaired people? How about children? We know “Neonatal children are unusually susceptible to boron exposure.” How about the unborn? “Exposure to pesticides, especially during early pregnancy, had a clear positive association with stillbirths regardless of cause of death.” We now experience some 30,000 infant deaths in the US each year. Are any of these related to Boric Acid? A piece of cotton batting that contains 10% Boric Acid by weight can contain up to or more than a pound of poison in the surface of your mattress. Then as you often lie on your mattress with your mouth and nostrils directly on the surface perhaps your drool causes you to ingest these chemicals. But certainly you are breathing these chemicals and absorbing them through your skin. The NCBI goes on to tell us Boric Acid will kill organisms in our mattresses and that it is also an insecticide. Should this tell us something? Yes it’s Poison. How much poison are you willing to tolerate in your mattress?

The science of toxicology uses high dose short-term exposure on various animals to predict the affect of low dose long-term exposure on humans. Chemical exposure risk greatly increases with, close contact, and length of exposure. For an infant born today this exposure on a mattress will be eight or more hours per day, every day, for the next seventy years or more.

Boric Acid, a chemical made from the reaction of Sulfuric Acid and Borax, should not be confused with Boron salts that occur in nature. Boric acid is the raw stuff. It occurs in nature in only one place in the world -- A steam vent in Italy where Sulfuric Acid mixes with Borax. (Microsoft Encarta)

Cutaway Photo of Boric Acid Innerspring Mattress



This mattress cutaway shows how Boric Acid is used in mattresses. The layer at the surface is fluffy cotton batting treated with Boric Acid. The layer next to the springs is compressed cotton batting treated with Boric Acid. The law label tells us the mattress contains: 47% Urethane Foam, 39% Treated Cotton, 13% Polyester Fiber. By weighing the cotton batting in the mattress and assuming 10% Boric Acid by weight, Boric Acid treated mattresses would contain the following amount of Boric Acid in each mattress: (3)

Amount of Boric Acid in Mattresses by Size























Here is how Boric Acid is applied to cotton batting: “Generally applied in the mixing machine prior to garnetting, boric acid is introduced to the cotton fibers along with a small amount of oil and chemical surfactant. To further achieve even distribution and adherence to the fibers, the boric acid is ground to a very fine consistency prior to application. … Applied as a white powder, boric acid is inorganic and is odorless.” (NCBI) Thus you can see Boric Acid is not chemically bound and exists as loose dust in the surface of our mattresses. As the mattress gets older and oils dry out even more Boric Acid will kick up into our faces with every body movement for us to breathe and absorb.


It would be roughly equivalent to take a pound or two of Boric Acid Roach Killer, sprinkle it on the surface of our existing mattress, and rub it in. This might make it flameproof. Does this make you feel safer?

A simple way to stop this law in California

In the 4-23-04 Market daily issue of Furniture Today an article reported that the CPSC informed California that there was an existing federal flammability standard and that California’s new CAB-603 law is thus preempted and unenforceable. It also reported that California had decided not to appeal this ruling and ask for an exemption to enforce state law over federal law. Thus this new law would simply die and go away, at least in California. Then the article quoted Dick Doyle, President of ISPA as saying California should go through the appeal process and enforce this law in California. Again I was shocked. Why does an industry association want more government regulation? This law could just die and might also die in the CPSC. Then, the next day another article reports California is going to ignore the ruling and enforce the new law as scheduled.

Federal law supersedes State Law. A California retailer or group could file an injunction to stop enforcement of this law. It might be simple and not very costly. We only need to argue one point of law. Federal law supersedes State Law and this law is therefore unenforceable. The lawyer might want to throw in the health risks the legislators did not consider in passing this law. But we only need to win on a single point of law. While this would stop it in California, we will still need to convince the CPSC to not enact this law nationwide.


As our Mothers once told us: “Don’t play with fire, it can burn you in unexpected ways.” We have been repeatedly burned by FRC’s that we latter find harms us. Have we harmed more people than we have saved? When are we going to develop some common sense?

Now we are going to sleep in these chemicals!

Even people who have no fear of these chemicals might oppose this law because it is more government regulation that will cost consumers an extra $50 to $200 for every new mattress purchased -- A new net tax on every consumer who can afford to buy a new mattress.

Most of the scientific discoveries I have reported about the dangers of Boric Acid were found after 1970. We need to consider our newer science before we force every American to sleep in Boric Acid or other chemicals that are not proven safe for this use.

Many people in the mattress industry share the concern that Boric Acid has huge risks and are choosing other more expensive chemical systems to fireproof their mattresses. Unfortunately many others do not share this opinion and are using Boric Acid systems. Are Modacrylic systems better? While we know a lot about the risks of Boric Acid we know very little about Modacrylics – they have never been tested for toxicology. They do admit Modacrylics are “Slightly Toxic” for skin contact and we should not breathe them. In another 30-years we might learn as much about Modacrylics, as we have learned about Boric Acid in the last 30-years. By then we will have tested our entire population, and it might be too late. In your own mind, is it even remotely possible that we might sterilize or harm much of our population? How about impaired or sensitive people, or Children, infants, and the unborn? Is our best choice simply to stop this law?

Respected Doctors in this field oppose this law.

Do you want your family, your children, and your grandchildren to sleep in these known toxic chemicals? The CPSC will soon force all of us to do so.



You can make a difference, and possibly prevent human suffering and save lives. Learn more about this issue and add your name and comments to a petition to stop this new law at  or email Your vote and comments will be presented to media and the Consumer Products Safety Commission. While the CPSC will be the first to enact this regulation nationwide, there is also a bill pending in congress that might make this a separate law. There are also links for you to find your legislators email, address, and phone so you can contact them at  People in some States have fought for, and won the right to ride their motorcycles without a helmet. With your help we can win the right to not have to sleep on a chemically saturated flame helmet, and keep our beds clean and pure.

Hippocrates left us with the admonition: "First do no harm.”




Mark Strobel
Strobel Technologies
3131 Industrial Parkway
Jeffersonville, IN 47130,, Phone: 812-280-6000, 800-457-6442, Fax: 812-282-6528 

 Links to References:

(1) “Government regulations and industry standards obligate manufactures to add flame-retardants to a wide range of products used everyday. Many of these flame retardant products are toxic...  The benefits of protecting people from death and property from damage resulting from fires must be weighed against exposure to chemicals that are potentially harmful to human health and the environment.”

“Demand for flame retardants in the US is projected to increase nearly four percent per year to 1.2 billion pounds in 2005... This assessment of the one billion pound US market for flame retardants...”

(2)  USA Today: “Though the USA has the world's toughest flame retardancy standards, 3,000 people die in fires each year. The Chemical Manufacturers Association estimates the number would be up to 960 higher without such flame retardants”

From the Los Angeles Times: “… Many say they are dismayed that industry and society have forgotten lessons learned from the toxic legacies of the past. … 'Didn't we learn from PCBs?'"

“… says it's a never-ending battle. Grey says she wants to know how the products get to market in the first place. … "It's only after they've been using them and that they've exposed humans to these hazards that they say it is dangerous," she says. Both Grey and Dewailly say they wonder why such effects aren't discovered during pre-testing before companies market the products.”

A note to Retailers:

As a 30-year mattress manufacturer who knows a lot about my industry, all I can do is blow the whistle on something I see as very wrong. If you speak to mattress manufacturers or chemical suppliers you have a legal right to demand a Material Safety Data Sheet (MSDS) on their fire barrier system. Free people have a right to know what chemicals and associated dangers industry and government will force them to sleep in, and be given the chance to try to stop this law. I have tried to be objective and am sorry if I get a little emotional about this issue. You can probably tell I am outraged by what is happening. But the facts should speak for themselves. I hope you will help fight this law.


 What you can do to fight this law

We are Americans, we can fight this!

Go to vote.htm and register your opposition.

Get a bottle of Boric Acid and a MSDS, show it to your customers, and ask them to sign a petition to stop this law. Contact your local media and tell them what you are doing to protect public health. You may get free publicity, which tells people to visit your store to sign this petition.

Look at the Law Label on the mattress, if it says it contains “Treated Cotton” it is probably treated with Boric Acid. But you have a legal right to demand a MSDS that will likely tell you for sure.

In your petition remember we are fighting all known toxic, or any chemicals not yet proven safe for this use, not just Boric Acid. A simple statement like this would do: “Petition, I oppose any and all Flame Retardant Chemicals in Mattresses.” Forward signed petitions to me and I will forward them in mass to the CPSC and related legislators, or send them directly to the CPSC at the address below. Download a sample petition by right clicking here, and choosing ‘save as’

Someone should form a California group to file an injunction to stop the law there. Or perhaps one company might do it alone.

Ethically you want the products you sell to be safe. If we later find harm from these chemicals retailers are likely to be sued as well. Please call me or one of my staff with questions. People in some States have fought for, and won the right to ride their motorcycles without a helmet. With your help we can win the right to keep our mattresses clean and pure.

Download a Word.doc with a preformatted label sheet like the one on the bottle for Avery 5663 labels 2.25x4” by right clicking here, and choosing ‘save as’. Or call us and we will send you a pre-labeled bottle for $15.00 shipping included. Boric Acid pesticides are often labeled as containing Orthoboric Acid, it is exactly the same, see synonyms on the MSDS.

You can get MSDS reports and Bottles of Boric Acid at the following links:


Modacrylic Fiber spec sheet: MSDS:

Boric Acid MSDS:

Boric Acid 16oz. Bottles, 4 bottles $25.95, 10 bottles $49.95, plus shipping


Boric Acid 20oz. (Same amount as in a Full size mattress) Bottle $3.71, plus shipping



You can also contact the CPSC directly:

Comments should be mailed, preferably in five copies, to the 
Office of the Secretary, Consumer Product Safety Commission, 
Washington, DC 20207-0001, or delivered to the Office of the Secretary, 
Consumer Product Safety Commission, Room 502, 4330 East-West Highway, 
Bethesda, Maryland. Comments also may be filed by email to 
Comments should be captioned ``Mattress NPR.''
FOR FURTHER INFORMATION CONTACT: Margaret Neily, Directorate for 
Engineering Sciences, Consumer Product Safety Commission, Washington, 
DC 20207; telephone (301) 504-7530.


Notice: The statements and questions contained in this notice are not intended to convey allegations regarding any particular company, person, or association. Readers should conduct their own investigation of a company or association or person to ascertain the particular policies, practices, and motivations of that entity. I have reported what I believe to be true and correct to the best of my knowledge and opinion at the time of its writing in a free speech effort to avert a public health disaster.


 Boric Acid Review, June 2004:

Boric Acid Review, 1992:

Boric Acid MSDS:

Antimony Oxide MSDS:




Vinylidene Chloride MSDS:

Decabromodiphenyl Oxide, Brominated Flame Retardant, 82% Bromine Minimum, contains free Bromine,

 Bromine MSDS:


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