Flame retardants in the aircraft cabin

1. Flame retardants in the aircraft cabin Judith Anderson, MSc CIH Industrial Hygienist Association of Flight Attendants-CWA, AFL-CIO Air Safety, Health, & Security Dept. Flame Retardant Dilemma & Beyond Symposium Berkeley, CA – Feb. 9, 2018 (Or “Things you would RATHER NOT KNOW IF YOU FLY”)

2. “The employee occasionally works in high, precarious places andis occasionally exposed towet and/or humid conditions, fumes or airborne particles, toxic or caustic chemicals, extreme cold, extreme heat, risk of electric shock, risk of radiation and vibration.” wwww.jobcircle.com -- 2010

3. Overview • History of FR use on aircraft • Relevant rules and regulations • Evidence of exposure • Example: crew uniform garments • What’s next?

4. History of FRs onboard • June 2, 1983: Air Canada Flight 797 flew from Dallas to Montreal • During cruise, cabin crew discovered smoke in the aft lavatory; could not extinguish fire, pilots made an emergency landing in Cincinnati • Cabin interiors continued to burn after landing and flash fire started 60-90 seconds after the doors were opened. • 23 people evacuated, 23 people died

5. NTSB investigated and recommended that FAA issue rules for: • Improved training for crew communication/hands on fire response • Safer wiring • Portable breathing devices for crew, smoke goggles for pilots • Tactile aisle markers leading to exits • Fire extinguishers with halon… and

6. 1983 NTSB recommendation • “Expedite the rulemaking action to require at the earliest possible date that passenger seats with fire-blocking materials be installed in transport category airplanes. (Class II, Priority Action) (A-83-78) • NSTB (1983) Safety recommendations A83-70 through -81, Sent to the FAA Administrator; signed by Jim Burnett, NTSB chairman, US National Transportation Safety Board, Washington, DC.

8. Risk of fire versus risk of FRs • One explanation for onboard smoke in 1983 was a smoldering cigarette. • Onboard smoking bans phased in starting in 1988 (<2 hour domestic flights), then 1990 (<6 hour domestic flights), 2000 (all international flights to/from US) • So isn’t risk of onboard fire lower than in 1983? • Now that the risks of exposure to FRs are becoming more widely recognized, shouldn’t the FAA adjust some regs. that manufacturers meet with FRs?

9. New and continuing fire hazards onboard Top three: Engine fire Electrical fire Cargo fire

10. Parts of cabin covered by FAA fire safety standard • Interior ceiling panels, interior wall panels, partitions, galley structure, large cabinet walls, structural flooring, and materials used in the construction of stowage compartments (other than under seat stowage compartments and compartments for stowing small items…floor covering, textiles (including draperies and upholstery), seat cushions, padding, decorative and non-decorative coated fabrics, leather, trays and galley furnishings, electrical conduit, air ducting, joint and edge covering, liners of Class B and E cargo or baggage compartments, floor panels of Class B, C, D, or E cargo or baggage compartments, cargo covers and transparencies, molded and thermoformed parts, air ducting joints, and trim strips (decorative and chafing), that are constructed of materials not covered in subparagraph (iv) below, clear plastic windows and signs, parts constructed in whole or in part of elastomeric materials, edge lighted instrument assemblies consisting of two or more instruments in a common housing, seat belts, shoulder harnesses, and cargo and baggage tiedown equipment, including containers, bins, pallets, etc., used in passenger or crew compartments, plus seat cushions… (From Part I and Part II of Appendix F to 14 CFR Part 25, Federal Aviation Administration, Jan 2006.)

11. FR regulations for aircraft • FAA does not require or ban particular FRs, and does not keep a record of which airlines use which FR in what parts of the cabin • All parts of aircraft (walls, floors, partitions, insulation, flight controls, interiors, etc.) must meet one of a variety of performance standards for materials to self-extinguish; some also can’t exceed fixed smoke and heat release values

12. Oil burner test for seat cushions Chapter 7, FAA Aircraft Materials Fire Test Handbook

13. Are flight attendant uniforms treated with FRs? • FAA performance standard regulations for flammability of cabin materials don’t apply specifically to crew uniforms

14. FAA FSAT Bulletin 97-01, eff. Jan. 1, 1997

15. AFA-CWA 2014

16. Feb. 2016

17. Address flammability without adding chemical FRs… • Some union contracts require airlines to confirm that crew uniforms pass tests required by CPSC clothing flammability standard (not so highly flammable that wearing them would be dangerous) (16CFR1610.32) • AFA and Transport Canada recommend natural fibers, long sleeves, long pants, closed-toe shoes (Transport Canada ref: ACAC 1997.12.05)

18. TwinHill uniforms at Alaska Airlines, 2011-14 • Outbreak of primarily irritant/allergenic symptoms reported by Alaska Airlines flight attendants 2011-14 (753 of 2900 workers; 27%); also 117 reports (4%) of thinning/lost hair • Tributyl phosphate (TBP) detected in all of the suiting garments tested (N=48), most of the shirts (N=12), and most of the sweaters (5); levels were up to two orders of magnitude higher in the suiting fabrics than in the shirts or sweaters; TBP can be used as a “wetting agent” in fabric production

19. AFA-CWA

20. 2007: Report on very high level of PBDEs in aircraft dust • A. Gerecke measured PBDE content in dust collected on one aircraft, funded by Swiss National Science Foundation • Total concentration of PBDEs in dust sample was 160 ug/g dust which is “among the highest concentrations ever reported for dust sample” • Sample was dominated by BDE-85

21. Key research findings re. FR exposure on aircraft (2008-14) • Complex mixture of FRs measured on aircraft. • Levels of PBDEs in dust is consistently either high or very high • Blood levels of some congeners in some crews are elevated; overall picture needs a closer look; blood levels (and exposure) for maintenance workers are esp. high • Measurable FRs on surface of hands after one flight

22. Future of FRs onboard • FAA Technical Center knows that FR in foams add little protection and that the smoke from treated products is more toxic. It is possible to meet FAA rules for seat cushions/plastics without FRs, but more expensive. • Adding one pound of weight to a commercial airplane costs $100-300 in fuel burn over service life of aircraft. ($29.8B profit globally in 2017) • FAA doesn’t tell airlines what to do • Perception that FRs save lives; easy to overlook the ways that FRs can compromise the quality of lives.

23. What can we do now? • The high levels of FRs measured in dust samples argues for improved housekeeping by airlines; also, hand-washing post-flight and before eating. • Need to ensure that airlines provide worker uniforms that are not treated with FRs, but do offer suitable fire protections • Long pants, natural fibers (high wool blend in suiting), closed-toe shoes • Educate crews to wash their uniforms separately from the rest of their clothes. • Advocate for continued research into body burden of FRs in airline workers. Ideally, also non-chemical alternatives to FRs.

24. Thank you for your attention!Questions? Judith Anderson Industrial Hygienist Association of Flight Attendants-CWA, AFL-CIO judith@afacwa.org 206-932-6237

25. 2008: First published study on travel-related FR exposure • Christiansson et. al., 2008 – Swedish study compared serum levels of various PBDEs for 11 travelers before international flight and upon return home; also measured PBDE levels in dust samples from those aircraft. • Found small but statistically significant increase in serum levels of certain PBDEs (post-travel (≤5d) versus pre-travel (≤2d). (Exposure period was not limited to time on the aircraft…) • Levels of PBDEs in aircraft dust was about an order of magnitude higher than levels than observed in household dust. (Also, evidence that aircraft were treated with penta, octa, and deca.) • Results suggested potential workplace hazard for crew.

26. 2010: Serum PBDEs in 10 crew • Schechter, et al., 2010 measured PBDE congeners in serum of 10 crewmembers employed by one airline • Generally, did not find that serum levels were higher than those reported in general population data (incl. NHANES); exception was BDE-47 level for two crew (80, 95 ng/g) • Maybe housekeeping practices on aircraft (which could influence dust levels/exposure)vary. Maybe those aircraft were treated with other types of FRs, such as OPs. Serum levels of PBDE congeners with shorter half lives (e.g., t1/2 BDE-209 = 2 wks.) may be influenced by time between previous flight and blood draw.

27. 2013: FRs in aircraft dust and PBDEs on hands of 11 travelers • Allen et al., collected dust samples on 19 parked aircraft – two samples per aircraft (carpet, air return grille). Also collected hand wipe samples from 11 people immediately after a cross-country flight. • Dust: Found “wide range of FR compounds” in all samples • Various PBDEs, TDCPP, HBCDD, and TBPH • Levels of BDE-209 in aircraft dust contained BDE-209 “elevated by orders of magnitude” relative to other indoor environments. • Hand wipes: Elevated levels of BDE-209 compared to general population.

28. 2014: Measured FRs in dust and PBDEs in blood (crew, mechanics) • Dust: on-aircraft settled dust and air sampling during mechanics work • Found PBDEs, HBCDD, DBDPE, 1,2-bis (2,4,6-tribromophenoxy)ethane, generally at higher levels than in homes • Found significantly higher PBDEs in blood of maintenance workers than in crews • Pilots and cabin crew had similar PBDE levels as control group except for BDE-153 and BDE-154

29. 2014-16: List of OPs measured onboard from 2014-16 (3 studies) • Flame retardants: tris(chloro-ethyl)phosphate, tris(chlor-isopropyl)phosphate, tris(1,3,-diclorisopropyl)phosphate, tris(butoxyethyl)phosphate, diphenyl-2-ethylhexylphosphate • Hydraulic fluid fumes: triisobutyl phosphate, tributyl phosphate, triphenyl phosphate • Engine oil fumes: tricresyl phosphates, trixylyl phosphate

30. Research references • Allen, JG; Stapleton, HM; Vallarino, J; et al. “Exposure to flame retardant chemicals on commercial airplanes,” Environmental Health, 12:17, 2013. • Christiansson, A; Hovander, L; Athanassiadis, I; et al. “Polybrominated diphenylethers in aircraft cabins – a source of human exposure?” Chemosphere, 73(10): 1654-60, 2008. • Gerecke, AC. “Brominated flame retardants in settled dust of a commercial aircraft,” In: 4th International Workshop on Brominated Flame Retardants, 24–27 April, 2007, Amsterdam, the Netherlands, 2007. • Schecter, A; Colacino, J; Haffner, D; et al. “Discussion of ‘PBDEs in aircraft cabins – a source of human exposure?’ by Anna Christiansson et al.” 78(2): 206-8, 2010. • Strid, A; Smedje, G; Athanassiadis, I; et al. “Brominated flame retardant exposure of aircraft personnel,” Chemosphere, 116: 83-90, 2014.