The Consumer Products Safety Commission also disagrees with ISPA and warns Boric Acid and Antimony Oxide are not safe to use in mattresses. Please also see Quotes-CPSC.htm

Millions of People are already sleeping in new mattresses with a pound or more of a poisonous pesticide, Boric Acid, in the surface of the mattress, to make it flameproof. A new law will soon have all of us sleeping in poison.

 Background: On Monday Nov. 8, Mark Strobel, faxed and emailed, a letter to 17,192 furniture retailers warning of the health dangers of chemicals being added to the surface of new mattresses to make them flameproof. They are using Antimony Oxide (linked to cancer, liver, and heart damage) and Boric Acid (a pesticide that is poison to humans, and the EPA links it to sterility, fetal death, and birth defects). This letter got a lot of response with many retailers voting at our website and making comments against this chemical use and new law. Many more retailers asked their mattress suppliers what is going on? By Friday Nov. 12, ISPA (Innerspring Mattress Manufacturers Association) issued a Special Edition Newsletter in response to Mark’s letter. This newsletter glossed over, omitted, and misstated the key issues of public health dangers. They do admit they use Antimony Oxide and Boric Acid to flameproof mattresses and defend this use.  Please see the letter I sent retailers, the whole story, a cutaway photo of how over a pound of Boric Acid is being used in mattresses, retailer and leading doctor quotes on this issue at www.Strobel.com/vote.htm This law is effective Jan 1 in California and is being enacted nationwide by the CPSC.

Mark Strobel's response to: ISPA (International Sleep Products Association), Special Edition Newsletter, November 12, 2004 written by Richard M. Doyle, President.

 Doyle:
“What about the recent questions regarding the safety and toxicity of some materials being used to meet the new flammability standards? These statements are irresponsible, and are based on reports that are outdated … “

 Strobel:
Doyle should read my report before he accuses me of making irresponsible statements based on outdated reports. A cotton-batting manufacturer wrote me they rely on reports from 1968-1972 to justify their use of Boric Acid in cotton batting. They admit the safety question comes up regularly every year. Perhaps Doyle is not fully informed on these issues.

 I quoted: A June 2004 report by the EPA, ‘Toxicological Review of Boron and Compounds,’ and, The Agency for Toxic Substances and Disease Registry (ATSDR) a division of the Center for Disease Control (CDC), [Health Effects of Boric Acid] (this report is quoted by the EPA 2004 report) a July 1992 report. An MSDS on Antimony Oxide dated 5-8-03. Boric Acid Material Safety Data Sheet (MSDS) dated 3-3-2004. And more. I was very careful to be truthful in my report. It is well documented with links to my quotes where you can easily see the dates. These reports never anticipated we would put a pound or more of Boric Acid in the surface of our mattresses. Please read my report and check references at www.strobel.com/newsrelease.htm

Doyle:
“What about the specific materials that the critics have attacked?

Modacrylic Fiber: Some mattress manufacturers use materials made from Modacrylic fiber, which contains Antimony Oxide …”

 Strobel:
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: http://www.jtbaker.com/msds/englishhtml/a7236.htm

The CPSC reports Antimony Oxide is not chemically bound and is released from Modacrylic fibers. Please also see Quotes-CPSC.htm

Doyle:
Boric Acid-Treated Cotton Fiber: Another popular fire retardant material that has been safely used for years is cotton treated with boric acid.”

Strobel:
“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.”

Doyle omits many things: Inhalation, Boric Acid is absorbed through inhalation. Inhalation and Ingestion are considered synonymous in toxic research, except less chemical is required to reach toxic levels than through ingestion. We breathe at the surface of our mattress eight hours per day for the rest of our lives. It is also “Readily absorbed through damaged or burned skin.” We don’t have to eat our mattress to absorb Boric Acid.

"EPA has determined, ... use of the substance without dermal protection may result in serious chronic and developmental effects." (EPA)

We know Boric Acid is poison to humans and now we know even more. Here are a few quotes from the conclusions of an EPA document (real science, not speculation): www.epa.gov/ncea/pdfs/boron/tox_review_boron.pdf

“6.1. HUMAN HAZARD POTENTIAL, 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 ). [The EPA reports they have high confidence in these studies] http://www.epa.gov/iris/toxreviews/0410-tr.pdf

Doyle:
[Boric Acid] “wears off through use only in harmless miniscule amounts.”

Strobel:
We know the developing fetus is unusually susceptible to this toxin. Exactly how miniscule an amount would a pregnant mother have to breathe eight hours every night to harm her unborn child?

A cotton batting manufacturer told me they rely on reports from 1968-1972 to justify their use of Boric Acid in cotton batting. They admit the safety issue comes up regularly every year. I am shocked we ever justified this use; even thirty years ago we knew Boric Acid is poison to humans. This treated cotton has been used in a relatively limited number of mattresses so far. I saw where it is used in some prison mattresses. Our science of the last 30-years warns Boric Acid can do damage to humans with no external symptoms: Liver, Kidney, and Neurological damage, “Demonstrated injury to the gonads and to the developing fetus,” High prenatal mortality, birth defects, reduced fertility, and sterility. We may have already harmed people and not know it.

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. This is exactly the risk in mattresses, close, low dose, and long-term exposure.

From the MSDS: http://www.rosemill.com/html/msds/chem_boric_acid_msds.pdf “Inhalation: Causes irritation to the mucous membranes of the respiratory tract. … 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. … Skin Contact: Causes skin irritation. Not significantly absorbed through the intact skin. Readily absorbed through damaged or burned skin. … Chronic Exposure: Prolonged absorption causes weight loss, vomiting, diarrhea, skin rash, convulsions and anemia. Liver and particularly the kidneys may be susceptible.” Persons with pre-existing conditions may be more susceptible to this poison.

From other sources including EPA and CDC:  “Does cause health effects following acute dermal exposure.” Linked to dermatitis. “Has been shown to cause irritation of the upper respiratory tract in humans.” “Demonstrated injury to the gonads and to the developing fetus.” “Neonatal children are unusually susceptible to boron exposure.” Children are more susceptible to toxic agents and pesticide residues. Pesticides have been linked to stillbirths. “Boron does accumulate in bone.” EPA is concerned our exposure could already be excessive through food, cosmetics, medicines (eyewash?), and insecticides. (They have not considered exposure in mattresses) EPA is concerned about environmental damage in concentrations as low as 300 parts per billion. “Elemental boron is not found in nature.” Boric Acid exists as loose dust mixed in with the cotton fibers. I disagree that a pound and a half or more of Boric Acid dust in the surface of a Queen mattress is a small amount. It’s true we don’t know of killing anyone yet from this use. But we may soon find damage as this issue is raised. At least one asthma suffer has reported he can’t sleep on a Boric Acid mattresses because it causes difficulty for his breathing. The real issue is not killing healthy adults. Boric Acid can do damage with no external symptoms. Recent science gives strong warnings of Reproductive, Neurological, and Developmental damage. It is very clear Boric Acid is poison. People have suffered all sorts of ill effects and permanent damage, including death. Why do we want to sleep in poison?

Doyle Concludes:
“While Boric Acid is an effective and preferred pesticide because it interferes with an insect’s digestive abilities, it does not have this same effect on humans or mammals and does not harm the environment.”

Strobel:
Doyle tries to infer it’s not poison for humans. Boric Acid does not kill humans and mammals the same way it kills insects. Our science knows how it harms us. The EPA and CDC say the developing fetus and the testicles are the most sensitive targets of Boric Acid. It results in high prenatal mortality and birth defects. Boric Acid exposure attacks and shrinks the male genitals. Infertility, Sterility, Neurological (Brain) damage, we also know it attacks the liver and particularly the kidneys. All of these things can happen with no external symptoms and we would never know it is related to Boric Acid.

 It's time for ISPA to quit arguing we have always done it that way. There is a ton of new science in the last thirty years that warns of huge risks from sleeping in Boric Acid. We knew it was poison 30-years ago. We should have had the common sense to have never used it in the first place.

Doyle:
“What kind of safety “due diligence” has the industry performed in meeting the new standard? … In developing mattresses to meet the new flammability rules, mattress manufacturers and component suppliers have researched various types of human exposure, including skin contact and absorption, inhalation and ingestion.”

Strobel:
This is a very broad statement that they have done all this testing. Did they use laboratory animals or humans? Are there chronic exposure studies of six months or more? Is this research adequate to predict it is safe for all of us to sleep in these chemicals with full body and breathing contact eight hours a day for the next thirty years or more? Where is this research? I can’t find any. I have poured over ISPA’s web site and all I find is tests of burning mattresses, nothing on human exposure. I can’t find anything anywhere that supports this as safe use. I don’t think this research exists! If Mr. Doyle can produce it I would love to see it. I question the industry’s “Due Diligence” I question if they have even read a Material Safety Data Sheet (MSDS) on the chemicals they choose. The only North American Modacrylic fiber supplier admits -- There is no toxicological research! I did find a National Cotton Batting Institute (NCBI) web page that makes a weak case for Boric Acid exposure in cotton. (see Boric Acid Rebuttals in my full report) They do admit, “the question of Boric Acid safety comes up regularly every year.” It should! Perhaps we can finally resolve this question. Modern science gives us strong warnings this is not safe use. I have leading doctors, MD’s, who specialize in environmental medicine. This type of chemical exposure in mattresses is their field; they oppose these chemicals in mattresses. What doctors does ISPA have who say these systems to fireproof mattresses are safe for our entire population to sleep in for the rest of our lives?

A 'Society of Toxicology' News Release reports:

… However, more must be known about the toxicology of these chemicals before manufacturers use them to meet new fire safety standards. ... Some scientists report that the chlorinated phosphate esters may be carcinogenic, and that boric acid may be a reproductive toxicant for male children. The manufacturers of these chemicals state that their products are safe when used as intended. To date, none of these claims has been thoroughly assessed by credible, independent scientists.

In spite of the above warnings, the innerspring mattress industry is charging ahead and already putting these chemicals in millions of mattresses nationwide, even though they have been warned it may not be safe for human exposure. The above news release was reported in Furniture Today, the leading trade magazine. International Sleep Products Association (ISPA) has not even done a simple independent risk assessment that reviews known science and factors in amount and duration of exposure, on any of the chemicals they are putting in mattresses, even though one could be had for ten to twelve thousand dollars. I don’t think any of the chemicals they are choosing would pass a risk assessment.

Doyle:
“Why does the industry support new mattresses flammability standards?

Strobel:

A little more than a year ago I had a conversation with Mr. Doyle. I was shocked to hear him tell me they went to the CPSC and asked for this law. Why I asked? He gave me the standard answer and added "it will help to keep imports out" and "this is what the members wanted." While I am no fan of imports either, I quickly realized it would do more than just hurt imports. It would also hurt the smaller manufacturers and particularly the Mom & Pop factory direct manufacturers who sell directly to the public out of a storefront. It would also put specialty sleep products at a disadvantage to comply since many use thin non-quilted covers to attain maximum comfort and most use zippered covers for access to components.  ISPA members pay dues based on their sales volume. So it should be easy to see who controls ISPA. It is not unusual for industry groups to ask for regulations that protect their turf and restrain competition.

ISPA has pushed very hard for this law. Why would an industry group ask for more government regulation? I can only speculate. 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.”

 Retailers and Manufacturers should be very careful which chemicals they choose for the mattress surface. While we know the most about boric acid right now, one of these other chemicals might turn out to be worse. The human risk parallels the legal risk. Most businesspeople are happy it they can make the right decisions 51% of the time. If we make the wrong decisions now on this choice, we may regret it later. If we find years from now we have done human damage, lawyers will be advertising on television looking for victims. Retailers and Manufacturers may be sued by millions of people.

How Millions of People are already sleeping in poison, and how to know
Some mattresses manufacturers are putting these chemical systems, and particularly Boric Acid, in all their mattresses nationwide in anticipation of the new law. A cotton-batting manufacturer who is supplying 'Treaded Cotton' to mattress manufacturers to meet the new law told me, it contains both Modacrylic fibers (with Antimony Oxide) and Boric Acid! Other systems use Modacrylics with Polyester quilted into the surface. Retailers and Consumers can at least avoid Boric Acid systems. Check the law label, the little white tag that says do not remove under penalty of law. If the tag says the mattress contains 'Treated Cotton', it's likely Boric Acid.

 If retailers and consumers oppose this law we are going to have to fight this ourselves.

Conclusion

Most people don’t want to sleep in chemicals. They have learned commonsense from the toxic legacies of the past. PCB flame-retardants were banned in the 70’s after much environmental and human damage that continues to this day. Some researchers believe today’s ADHD children are the result of PCB’s. We learn to late the lessons of Asbestos. Another flame retardant was banned from children’s sleepwear. We are told the new PBDE’s are safe; only to recently find them in women’s bodies and breast milk in dangerous amounts. Our science doesn’t even know how these chemicals enter the body. In 2004 we find still another flame retardant, Deca, should be banned. What is next?

 There are many impaired, sensitive, and allergic people in the US. These people will likely have reactions and be unable to get away from these chemicals once they are in all mattresses. Does this alone harm more people than we save?

 Three thousand people die in fires each year. ISPA estimates up to 300 people will be saved annually under the new law, after all existing mattresses are replaced, after ten or more years. These estimates are debatable. For now, the chemical industry estimates that up to 960 people are saved with the 1.2 billon pounds of flame retardant chemicals the US uses annually. Have we already harmed more people than we have saved? Now we want to rush in and save more people by putting known toxic and untested chemicals in our mattresses of all places. This is close and chronic exposure unparalleled in any other use. What will be the affect on a child who spends their whole life sleeping in poison? It seems likely we will find out too late! What if, history repeats itself, and we later find we have harmed millions of people?

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

 Is the benefit worth the risk of exposing our entire population?

 As one retailer wrote: “Why doesn't the media expose the truths for our safety!!”

Sincerely,

Mark Strobel
President

Strobel Technologies
3131 Industrial Parkway
Jeffersonville, IN 47130

health@strobel.com, www.Strobel.com, Phone: 812-280-6000, 800-457-6442, Fax: 812-282-6528,

Please feel free to contact me with questions. Please learn more, find links to your legislators, see retailer comments, and vote on this issue at www.strobel.com/vote.htm

Here is a link to ISPA’s response to my letter to retailers, to which I responded above:
http://www.sleepproducts.org/Content/ContentGroups/Advocacy/Flammability2/CPSCLegtalkingpoints.pdf

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.