Post-Consumer FPF Recycling Article
Post-Consumer Flexible Polyurethane Foam Scrap Used In Building Products
Rebecca Stamm and Wes Sullens – July 29, 2016
Most post-consumer flexible polyurethane foam (FPF) collected for recycling today contains highly toxic flame retardants. The vast majority of this scrap material is recycled into one type of new building product: bonded carpet cushion. While the practice of diverting vast amounts of FPF from landfills represents a recycling success story, the potential health hazards to vulnerable populations make us question whether the benefits of recycling are worth the risk.
Our findings indicate that most post-consumer FPF collected for recycling contains flame retardants, but the industry only minimally tests for these substances. Due to the presence of these materials in carpet padding in homes, people (particularly crawling children) can be exposed to hazardous flame retardant chemicals released from carpet pad. 
The EPA notes that “as carpet padding ages, foam dust will be generated and become airborne with traffic on carpet.” 
Additionally, flame retardants can migrate over the life of the product and deposit in household dust that building occupants inhale or ingest.
While the state of this industry today is grim, our report suggests there is good news ahead.
About Waste Foam Recycling
Upholstered furniture, mattresses, and car seats contain FPF. In the U.S., foam manufacturers have long redirected their pre-consumer scrap from landfills into new bonded carpet cushion. This foam has contained a range of toxic flame retardants that manufacturers added to meet flammability standards.
More recently, some post-consumer FPF in the form of old carpet cushion entered the recycling supply chain. This old carpet cushion is contaminated with legacy flame retardants, and the practice of recycling these materials into new bonded carpet cushion propagates these toxicants into new products.
Legacy Flame Retardants and Testing
From 1980 until a voluntary phase-out in 2005, the industry relied upon a highly toxic flame retardant called PentaBDE.  Unfortunately, researchers found that replacement flame retardants pose similar toxicity concerns.  These halogenated flame retardants are chemicals that are persistent and bioaccumulative  — meaning they are long-lived in the environment and concentrate in the food chain. These additive flame retardants can migrate out of the material over the life of the product during installation, use, recycling, and disposal.
The industry association, Carpet Cushion Council (CCC), has periodically tested PentaBDE content in carpet cushion. Results indicate that the proportion of PentaBDE in new cushion has been decreasing since the phase-out of its use in virgin FPF. However, current industry testing is limited to 8-12 samples per year, 
and, given the variability of the stock, it is questionable how representative this average is for an industry that creates over 500,000 tons of carpet cushion each year. 
Furthermore, the CCC does not report test results for the flame retardants that replaced PentaBDE, so the amounts present in new products or scrap materials is unknown.
The methods currently used to test for flame retardants in foam are expensive and time-consuming. Field-appropriate test methods should be developed and implemented at the frequency and scale necessary to ensure that health-protective thresholds are met for new products.
Pathways for Optimization
Recycling materials offers many advantages over other waste management options, but the potentially negative impacts on humans and the environment must also be considered. There is no easy solution to the problem of flame retardant contaminated foam, but there are pathways to deal with current contaminated foams and assure clean future feedstock.
The good news is this: After California amended its upholstered furniture flammability requirements (Technical Bulletin 117) in 2014, 
many furniture manufacturers began using flame retardant-free foams, creating flame retardant-free pre-consumer
trim scrap. The Polyurethane Foam Association (PFA) estimates that less than 1% of 2016 U.S. slabstock foam production for use in residential upholstered furniture will contain flame retardant additives. 
Carpet cushion companies are already incorporating flame retardant-free trim scrap into new bonded carpet cushion and the industry reports efforts to verify flame retardant content in their pre-consumer scrap. These efforts should expand to include transparency and labeling throughout the foam supply chain. Labeling flame retardant-free products readily identifies foam for future recycling. This will help to provide a safer feedstock for future post-consumer recycling, increase the value of those feedstocks, and reduce health concerns related to legacy flame retardants.
Rebecca Stamm is a Researcher at Healthy Building Network. Follow Rebecca on Twitter @HBNRebecca
Wes Sullens is a Green Building Program Manager at StopWaste. Follow Wes on Twitter @wessullens
This paper is the third in a series of evaluations conducted under the Optimizing Recycling framework. We developed this framework in collaboration with StopWaste and the San Francisco Department of the Environment. An overview white paper, and additional research papers, are available on this Healthy Building Network page.
Join HBN Founder, Bill Walsh, and Research Director, Jim Vallette at the International Living Future Institute’s second annual Living Product Expo in Pittsburgh, PA, Sept 13-15, 2016.
The International Living Futures Institute says “The Living Product Expo is an accelerator for product innovation, and the leading event for designers, manufacturers and CSR professionals to connect around the latest trends in sustainable products. Join us in the collaborative design process as we craft a healthy and inclusive materials economy.”
Researchers have also found that carpet installers and recycling workers are exposed to flame retardants. See Stapleton, Heather M, Andreas Sjödin, Richard S Jones, et
al. 2008. Serum levels of polybrominated diphenyl ethers (PBDEs) in foam recyclers and carpet installers working in the United States. Environmental science & technology
42, no. 9: 3453-3458.
United Nations Industrial Development Organization. “Guidance on Best Available Techniques and Best Environmental Practices for the Recycling and Disposal of Articles Containing Polybrominated Diphenyl Ethers (PBDEs) Listed Under the Stockholm Convention on Persistent Organic Pollutants,” 2012. http://bit.ly/2aA7kzD
; Blum, Arlene. “Flame Retardants, Health, and Environment: How Peer-Reviewed Science Can Impact Regulatory Decision-Making.” In Organohalogen Compounds, 71:2322-27, 2009. http://www.dioxin20xx.org/pdfs/2009/09-474.pdf
DiGangi, Joseph, Arlene Blum, A?ke Bergman, Cynthia A. de Wit, Donald Lucas, David Mortimer, Arnold Schecter, Martin Scheringer, Susan D. Shaw, and Thomas F. Webster. “San pdf. Antonio Statement on Brominated and Chlorinated Flame Retardants.” Environmental Health Perspectives 118, no. 12 (October 28, 2010): A516-18. doi:10.1289/ehp.1003089. http://ehp.niehs.nih.gov/1003089/
Personal communication with Bob Clark, Executive Director Carpet Cushion Council, May 12, 2016.
The open flame requirements for furniture foam in California TB117, which had become the de facto national standard, could not be easily met without the inclusion of flame retardant additives. In 2014, California removed this part of the requirement due to evidence of negative health impacts of added flame retardants and the limited benefit in terms of fire safety. (Dedeo, Michel, and Suzanne Drake. “Healthy Environments: Strategies for Avoiding Flame Retardants in the Built Environment,” October 15, 2014. http://perkinswill.com/sites/default/files/PerkinsWill_FlameRetardantAlternatives.pdf
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