This is a response to a Trevor Butterworth article posted on The Huffington Post. Mr Butterworth severely attacked everything about People For Clean Beds, the flameproof mattress chemical risks, and Mark Strobel. You can see Mr. Butterworth’s article at: http://www.huffingtonpost.com/trevor-butterworth/panic-in-the-bedroom-act_b_71654.html
http://www.stats.org/stories/2007/attack_killer_mattresses_nov6_07.htm
Dear Mr Butterworth,
It is easy to be a skeptic because it is hard to believe the chemicals in mattresses could be that bad, until you look at the facts. I ask that you read the government report used to justify the regulation that you cite as “extensive testing” or at least read the lines and notes highlighted of the report at: http://www.peopleforcleanbeds.org/CPSC_Risk_Assessment_Selected_Pages_Highlighted_4.pdf
Also please read Strobel’s ‘fight history’ at: http://www.peopleforcleanbeds.org/fight_history.htm and the Washington Post article linked from: http://www.peopleforcleanbeds.org/making-news.htm. You will see Strobel fought the regulation for 2.5 years before the US Consumer Products Safety Commission (CPSC) commissioners voted 3-0 to enact it into law, only 38 days after the flawed risk assessment was completed. The Washington Post article points out Strobel generated over 500 public comments sent to the CPSC in an effort to stop the regulation before it passed. All for no financial gain, only a sincere effort to stop the regulation.
At the “making-news” link you will see many more news stories you failed to cite. You did mention news we received from “CBS Philadelphia, CBS Phoenix, CBS Sacramento, NBC Missoula, and NBC Butte/Bozeman.” You failed to mention the other news we have received from affiliates of all the networks including CBS, NBC, ABC, FOX, in New York, Boston, Tampa, Orlando, Jacksonville, Denver, San Diego, Indianapolis, Evansville, Austin, Charleston, Minneapolis, Cincinnati, Louisville, Boise, and Milwaukee. Nor do you mention the print stories in many magazines and newspapers including the Chicago Tribune, Washington Post, San Francisco Chronicle, and American Chiropractic Association to name a few. The Chicago Tribune did a great job of exposing the risks of the regulation. These reporters saw the facts firsthand by reading the lines highlighted in the risk assessment.
If you will take a moment to read the highlights you will see the government report is not “extensive testing”, but rather a report designed to reach a pre-existing conclusion. Here are some quotes you will see highlighted:
“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.”
A proper risk assessment always includes young children. This one should too since the regulation also requires all crib mattresses to be flameproof and contain toxic chemicals including Boric Acid and Antimony. In the CPSC assumption that all children’s mattresses will be covered with vinyl cites “Midgett’, a CPSC employee whose report says only 20% of young children have bedwetting problems.
The European study that linked Antimony from crib mattresses to SIDS may not have proven that point conclusively for all cases of SIDS, but the study did prove Antimony leaches through vinyl on crib mattresses.
“As with any risk assessment, there are assumptions, limitations, and sources of uncertainty. These are discussed below. Risk assessment is an iterative process. Data on carcinogenicity, developmental and reproductive toxicity, or neurotoxicity were not available for all chemicals. Furthermore, it should be noted that percutaneous [skin] absorption data were not available for antimony.”
The CPSC measured the amount of toxic chemicals that leach from mattresses and contacts out skin. In CPSC Table 8 you will see they assumed we would absorb only 2/1,000’s of the Antimony, 1/1,000’s of the BDBPO, and 1/10,000’s of the Boric Acid that has leached from the mattress and contacts our skin. We know we absorb medicines through our skin from small patches. These absorption assumptions seem very low.
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. See: http://www.peopleforcleanbeds.org/antimony-risks.htm
Even with low absorption assumptions the CPSC says in Table 16 that the average adult will absorb .802 mg Antimony, .081 mg Boric Acid, and .073 mg DBDPO, every night for our entire lives.
Even the predicted absorption of .802 mg of Antimony is 27 times more that the EPA says is safe. http://www.peopleforcleanbeds.org/cdc-doctor.htm
The ATSDR can not determine a safe level of Antimony absorption and says, “At the lowest exposure levels tested, the adversity of the effects was considered to be serious.”
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 (Acceptable Daily Intake) 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 independent reviewer complained strongly that the CPSC changed the rules of the “child sucking test” from the “National Academy of Sciences' (NAS) National Research Council (NRC) study of flame retardant chemicals (2000) for use in upholstered furniture.” Then the CPSC did not even apply the test to one year old children who the test was designed to protect. The CPSC choose to exclude children under age five from their analysis. We believe flameproof mattresses would fail this test and Strobel had previously urged the CPSC to apply this test before the regulation passed. See Child Sucking Test: http://www.peopleforcleanbeds.org/sucking_test.htm
Here are some of the independent reviewer’s comments, and the CPSC answers:
“Comment 11. CPSC staff should consider harmonizing methods of calculating ADI's [Acceptable Daily Intake] with other organizations.
Answer. CPSC staff is obligated to assess the potential hazards of chemicals using the methodology outlined in the Federal Hazardous Substances Act (FHSA) and the supporting Chronic Hazard Guidelines (CPSC, 1992). … does not result in substantial differences in risk as compared to that used by other organizations.
Comment 12a. Derivation of the ADI for decabromodiphenyl oxide (DBDPO) should consider new studies.
Answer. CPSC staff reviewed the new studies on DBDPO. The new studies did not alter the DBDPO ADI
.
Comment 12b. The possible carcinogenicity of DBDPO should be discussed.
Answer. CPSC staff previously determined that DBDPO is a possible carcinogen.”
The CPSC assumptions of ADI safe levels is 320 times more than what the EPA says is safe for DBDPO, and the CPSC assumption of acceptable daily intake for Antimony is 5,750 times more than the EPA says is safe.
We think differences in safe levels between government agencies of 320 times for one chemical, and 5,750 times for Antimony is substantial and cause for concern.
When pressed by the independent reviewer about the cancer risks from Antimony the CPSC admitted: “The cancer effects are cumulative. Every exposure contributes to the overall lifetime risk of developing cancer.”
Here is the response of the CPSC to some of the more than 500 public comments Strobel generated and were sent to the CPSC before the regulation passed:
“Comment
Some individuals commented that the "precautionary principle" should be applied to FR chemicals, that is, they should not be used until proven safe (7,26,44,47, and 51).”
“Response
All of the statues that provide regulatory authority to the CPSC explicitly require risk-based decision making, thus precluding application of the "precautionary principle."”
These chemicals are not proven safe to sleep in.
There are no labeling requirements and manufacturers are free to use any chemicals they choose. The CPSC choose not to study many of these chemicals. The CPSC risk assessment authors had previously stated “Formaldehyde is a known sensitizer, and is also regarded as a carcinogen. If melamine-containing products release formaldehyde, sensitization (induction and elicitation of symptoms) may result in some susceptible individuals. Data are needed to determine the conditions for, and potential releases of, formaldehyde from barriers made with melamine/formaldehyde resin fibers.” But the latest risk assessment made no mention of formaldehyde.
A widely used system contains Silicon which is Silica Glass and other chemicals, often Antimony. Silicon release or absorption is another not studied. “Several epidemiological studies have reported statistically significant numbers of excess deaths or cases of immunologic disorders and autoimmune diseases in silica-exposed workers. These diseases and disorders include scleroderma, rheumatoid arthritis, systemic lupus erythematosus, and sarcoidosis. … renal diseases and subclinical renal changes. Crystalline silica may affect the immune system, leading to mycobacterial infections (tuberculous and nontuberculous) or fungal, …Occupational exposure to breathable crystalline silica is associated with bronchitis, chronic obstructive pulmonary disease (COPD) and emphysema. … Lung cancer.”
Like Asbestos the Silica Glass may be what is causing health problems for the mattress factory workers or the many individual sleepers, and couples, who also complain of health problems from flameproof mattresses. But it is hard to pinpoint because so many different chemicals are used and they are all acutely toxic.
The CPSC studied only three of the many chemicals used to flameproof mattresses and concludes Antimony, Boric Acid, and DBSPO are safe. Proper assumptions of absorption rates and/or safe levels would have proven all three toxic, with their own calculations.
The CPSC says DBDPO is safe. Many scientists are reporting that even very low amounts of this chemical are toxic to children.
We have made toxic mistakes in the past with flame retardants including PCB, Tris, Asbestos, and PBDE. All are now banned after we found human harm.
All of these were initially thought to be non-toxic because test animals could consume large amounts without harm. Later scientists found these chemicals defied traditional toxicology that dose is everything and found even very small amounts were harmful to children. A lot of research over the last thirty years is showing the same thing. http://www.peopleforcleanbeds.org/new_research_march_2005.htm
We already know the chemicals used to flameproof mattresses are acutely toxic and cancer causing. While many try to say Boric Acid is safe, The American Association of Poison Control Centers reports an average of 6,463 cases of Boric Acid Poisoning each year.
The EPA says Antimony is 500 times more poisonous than Boric Acid. Antimony is a heavy metal almost identical to Arsenic and just as poisonous. Antimony is known to attack the liver and heart muscle and may cause the heart to beat irregularly or stop. Antimony is also known to cause cancer.
Many MD’s side with Strobel, they agree the chemicals are very dangerous, that there is insufficient study to justify the regulation, and that the risk outweighs the benefit.
According to USA Today, “Even though the
By comparison, the National Safety Council says 16.337 people die in car accidents each year, and 17,550 people die each year from “Accidental poisoning by and exposure to noxious substances.”
We need to pay more attention to the chemical risks in our lives, not force every American to unknowingly sleep in and absorb toxic chemicals to avoid a one in 1.111 million mattress fire risk
Yes, as part of leading the fight Strobel now offers toxin-free prescription mattresses. This could create a control group for a later epidemiological study that could prove flameproof mattresses toxic. A relatively small percentage of our population was exposed to Asbestos. Everyone sleeps on a mattress. Asbestos workers complained early on of health problems but no one listened. It took 40 years and half a million deaths to prove toxic. Now mattress factory workers and sleepers are complaining and again no one is listening. How many toxic mistakes do we have to make to develop common sense? The CPSC will soon require all upholstered furniture and our filled top of the bed items including mattress pads, comforter, bedspreads, and pillows to also be flame proof and contain the same chemical systems. There are millions of chemically sensitive people, millions of health impaired, and millions of Asthma suffers. Most people don’t realize many people die from Asthma attacks. How many deadly Asthma attacks will occur from these mattresses alone? Will it be more than we save from fire? Putting 300 million Americans at any level of risk becomes a huge risk. What will we learn in the next 40 years? If only 15% of our mattresses prove toxic it will be 45 million people harmed.
As a recent newspaper article conclusion pointed out: “Fortunately, there is an escape hatch for consumers. Doctors, including chiropractors, can prescribe toxin-free mattresses and avoid the regulation. The prescription will also save people the sales tax, make the purchase tax deductible, and they can use their health savings account. … Consumers can hope that if enough prescription mattresses are sold, the regulation may eventually be reversed.”
We applaud previous and future journalists who have the foresight to look at the facts and report this story. You can see a few recent news releases at Strobel’s blog http://poisonbeds.blogspot.com/ and a lot of detail with links to references at www.PeopleForCleanBeds.org
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