OSHA Conformity Sought in Proposed Furniture Sustainability Standard

Developers of a proposed American National Standard addressing furniture sustainability are now dealing with comments that arrived by the Aug. 11 deadline. BIFMA E3-2008, Business and Institutional Furniture Sustainability, underwent a 45-day public comment period that brought comments from EPA and others about its contents, which are based on the LEED building rating system and include a program for amassing credits for reducing office furniture's environmental impact. The standard was developed by the Business and Institutional Furniture Manufacturers Association (BIFMA) International and NSF International.

BIFMA E3-2008 is divided into four basic elements consisting of various prerequisites and credits available to organizations seeking product conformance to the standard. The four elements are materials, energy and atmosphere, human and ecosystem health, and social responsibility. Each credit has one or more points that accumulate toward a level of conformance: silver (32 to 44 total points), gold (45 to 62 points) and platinum (63 to 90 points). For materials, for example, a prerequisite is that the organization implements a design for environment (DFE) program. One point is earned by demonstrating that at least 30 percent of the final product weight consists of climate-neutral materials (this means materials with zero net greenhouse gases measured in terms of CO2 equivalent emitted over the life cycle of the material).

Representatives of furniture makers, environmental enforcement agencies, and trade associations participated in the consensus standard's development, and comments generally were supportive of the process and the contents. The American Chemistry Council submitted comments Aug. 11 urging that the 100 ppm chemical assessment floor be made consistent with OSHA standards. The draft standard would provide credits if the organization/applicant identifies and assesses chemicals down to 100 parts per million, but MSDSs must list the hazardous chemicals that are found in a product in quantities 10,000 ppm or more (1,000 ppm or more if the chemical is a carcinogen), according to the council's comments. "This standard seeks identification and assessment at a level that is lower than current OSHA requirements for chemicals that are considered carcinogens," it noted. "We also believe that an approach that seeks to eliminate particular chemicals or compounds by category without an appropriate scientific basis is flawed and unsupportable. Basic principles of hazard and risk assessment dictate that the mere presence of a compound does not result in a negative (or positive) health effect. Exposure also must be taken into account in assessing the potential risks, in any, posed by a given compound. Since the hazard of compounds vary, 100 ppm of a particular compound in a finished furniture product could be considered a safe exposure level, while exposures of 10,000 ppm of another compound could be the safe exposure level for that compound. One size does not fit all with respect to assessing potential risks and the determination of safe exposure levels."

The EPA Office of Pollution Prevention and Toxics submitted comments suggesting a credit be added for using alternatives to polybrominated diphenyl ether (PBDE) flame retardants. "If fluorinated resins are used for water-proofing or stain-proofing furniture products, a credit related to avoidance of chemicals of concern may be appropriate. Alternatives are limited at present, but a voluntary credit in this area could provide a good incentive. OPPT staff working on PFOA/fluorotelomers could help to define the chemicals of concern," the EPA office added. "Another observation is that the description of the activity in Section 7.5.1 Elimination from Products really does not live up to the title. First of all it is not based on active elimination/reduction but is based on proving a negative (at least down to a de minimis level). Also it could result in a "passive credit" because a lot of the substances in Annex B are not likely to be found in final products anyway."

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