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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:



Antimony (CPSC Assumptions)

Antimony (CDC/ATSDR/EPA numbers)

Difference CPSC/EPA

ADD Total (mg/kg/d) (Average Daily Dose)




ADI mg/kg/d (Acceptable Daily Intake)




Hazzard Index, HI (numbers below one are considered safe)






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.

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, 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.



 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.


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 or more simply




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:

See the CPSC quotes in this document at:

See CPSC Table 1 showing the percentage of Known Toxic Chemicals contained in various mattress flame barrier systems at: Tab H, p 17