George Edwardes considers whether proposed regulatory changes for the fire safety of furniture will usher in a new era for smoke toxicity regulations.

With the government’s consultation on the proposed changes to the regulations for […]

Dec 2023
George Edwardes considers whether proposed regulatory changes for the fire safety of furniture will usher in a new era for smoke toxicity regulations.

With the government’s consultation on the proposed changes to the regulations for the ‘Fire safety of domestic upholstered furniture’ closing in October, it brings about a new era for smoke toxicity regulations. This will be the first regulation to focus on smoke toxicity outside the mass transport industry and probably the first of many to come. The way the government chooses to control the toxicity of smoke produced from burning furniture will undoubtedly affect the way smoke toxicity is handled throughout the rest of the fire industry.

Smoke toxicity and its impact

It is a commonly reported fact that toxic smoke is the number one cause of death during a fire. The increased use of plastic materials and flame retardants has led to the production of significantly more toxic smoke. But if you took away the smoke would people die from the fire anyway? If you took away the toxic gases released, would people die from other components of fire smoke instead?

The horrendous accounts from some of the Grenfell Tower fire survivors certainly paint a chilling picture of the horrors of smoke exposure:

It was pitch black. My eyes were stinging; I was almost crying. It was impossible to breathe.”

I realised that with each breath I was inhaling more horrible smoke and I could feel my throat burning from it.

I can only describe it as what I imagine smelled like chemicals. It was something I had never smelled before in my life.

Even more distressingly, some of the victims tragically lost their lives while still on the phone. This isn’t something that happens from exposure to cleaner, less toxic fire smoke and yet smoke is still unregulated. There are currently a number of banned substances, but the only comprehensive regulations are in the mass transport industry. Outside of this, there are no limits on the toxicity of smoke. At least, for now.

The potency of smoke is a combination of the fire conditions and the chemical composition of the materials being burnt. A well-ventilated fire will mostly react oxygen with carbon to produce carbon dioxide. The worse the ventilation conditions, the more inefficient the combustion, leading to the production of less carbon dioxide and more toxicants (especially carbon monoxide and hydrogen cyanide). Poor ventilation is influenced by the fire size and the size of any openings such as windows. There are also scenarios where the room is well ventilated, but the fire is not because it is a deep-seated fire, or it is in a particularly dense material. This is when smouldering occurs – a process that also increases the production of toxicants.

The widespread use of plastics across all society has led to an increase in both the growth rate and severity of fires. This increased presence also produces higher concentrations of toxicants, which combine to create significantly more deadly fires. For example, PVC (polyvinyl chloride), commonly used in window frames, can produce gases such as hydrogen chloride, which dissolves in the water on skin or in the throat to produce hydrochloric acid.

The increase in plastic usage has also coincided with an increase in flame retardants. These reduce the production of carbon dioxide by forming other reactions, which produce less energy, thus retarding the fire. However, the products of these other reactions are often highly toxic and include gases like hydrogen cyanide and carbon monoxide.

Hydrogen cyanide is an acute toxicant, due to its immediate risk to life. But burning chemical flame retardants can also cause long term issues due to the production of chronic toxicants, increasing the risk of cancer, neurological issues, respiratory issues, and damaging the immune system.

Even without a fire, chemical flame retardants can still cause harm just through being slowly released from everyday products into your home environment. These increase your risk of cancer and can cause reproduction and hormone disruption. Most worryingly, they can cause neurological issues, with young children being most at risk. It is even more disturbing when you hear that they can pollute human bodies and have been found in mothers’ breast milk.

They have also been shown to readily pollute the environment, having been found in soil, water, air, and animals across the globe. Astoundingly, they have been found in both polar bears and penguins, animals living at opposite extremes of the globe and neither being known for their love of flame-retardant sofas. This pollution risk also causes problems with the circular economy as furniture becomes more difficult to recycle or dispose of.

UK versus EU flame retardants

The UK has some of the highest exposure rates to chemical flame retardants in the world because we have some of the strictest furniture and furnishings fire safety regulations. But have the challenging flammability tests in the UK actually led to a reduction in fire deaths?

The UK saw major changes to the furniture regulations in 1988, 1993, and 2010, with no real effects seen in the number of fire deaths. The rest of Europe has less strict regulations but records a similar number of fire deaths. Indeed, New Zealand has no furniture fire regulations at all and appears to have an almost identical rate of fire deaths as the UK.

The argument has been made that while flame retardants reduce the direct threat from the fire by slowing the rate of burning, they increase the secondary threat from fire smoke toxicity and this completely negates any positive impact.

Proposed furniture regulations

Due to the overwhelming evidence against the use of chemical flame retardants, the government has agreed to review the UK’s furniture fire safety regulations, with a public consultation recently closing on 24 October. How the government chooses to handle smoke toxicity with these furniture regulations could impact how every other area of the fire industry handles it.

Most notably, the government has not proposed meaningful changes to the flammability tests, and suggests retaining the open flame test. This is based on the belief that the tests can still be met with less toxic products. Instead, they have proposed three other major changes.

Firstly, with the exception of foam, they have proposed a change from individual component tests to a composite test representative of the final furniture item. For example, with a sofa, instead of testing the foam, other filling materials, and cover separately, they can be tested all together as a composite. This allows for more innovative designs, such as the use of a barrier material between the combustible foam and the sofa cover. This allows for the furniture flammability testing requirements to be met without excessive use of chemical flame retardants. However, it does cause some concerns with regard to damaged or re-upholstered products. If the combustible foam is exposed, will people diligently repair these products as the manufacturer intends?

Secondly, the government is planning to introduce a smart labelling system. There will be a requirement to list any chemical flame retardants used on a permanent product label and this must also be listed online. This will allow people to vote with their wallets, but this will only work if consumers understand the label. What if consumers think that a product containing flame retardants is safer than a product without them?

Disappointingly, they have not proposed any changes that will actually mandate a reduction in chemical flame retardants – there are no clauses which propose limits to their use. Instead, they have proposed the introduction of the ‘Flame Retardant Technology Hierarchy’ which must be considered when designing a product. There is a requirement to justify the chemicals chosen and a requirement not to produce a product which is harmful to human health. This raises the issue over how hard it will be for manufacturers to justify using chemical flame retardants. If the manufacturers can claim it is the only financially viable option, will these regulatory changes achieve anything?

Another concern is ‘regrettable chemical substitutions’. Manufacturers can take a harmful chemical substance, make a small insignificant change to its chemical formula and present it as a new substance that ‘isn’t known to be harmful’. It can then take another five years to prove that it was equally as harmful as the substance it replaced.

It will take time to see the impact of the proposed changes to the furniture fire safety regulations. But without any requirements to measure the toxicity of smoke produced during a fire or in furniture flammability tests, or to reduce the chemicals used in production, how effective can these changes really be?

Innovative solutions

The proposed new approach was first announced by the government in July 2019, and in response the furniture industry has been quick to provide solutions. The most obvious one is to use non-hazardous flame retardants, however these cannot just be new, supposedly ‘greener’, flame retardants that are then found to be hazardous years later. In some cases, we simply do not yet have enough proof that they are safe.

One prominent area of success is the use of barrier materials – surrounding combustible foam in a non-combustible layer like a mineral flame retardant or natural wool which protects the foam during a fire. The combustible foam can also be coated with an intumescent material that reacts and expands in a fire to form a protective layer.

Aerogels seem like a promising solution. These are gels, where all of the liquid has been removed, leaving behind an incredibly complex structure that is one of the best insulators on the planet. It is generally quite rigid, so may have limited applications in furniture, but could have huge potential in the construction industry. A lot of progress has been made in the last 20 years in producing aerogels, but they still seem too expensive for mass production.

A surprising solution emerges from the popular kitchen myth that mushrooms are impossible to burn. Whilst this myth is not true, as organic matter it will burn, due to the structure and moisture-retaining abilities of mushrooms, it can take a long time to get them to a condition where they are ready to burn. As a result, promising research into their potential as an alternative in furniture manufacturing is being done. They can be pressed into thin layers which, during a fire, can produce a protective coating similar to an intumescent. They also have some insulating properties, and there is even talk about them becoming viable cladding systems. The idea of sitting on a dark, damp mushroom doesn’t sound all that appealing, and it will certainly need a compelling marketing campaign if it intends to be the future.


In summary, the proposed regulations for the ‘Fire safety of domestic upholstered furniture’ aim to reduce smoke toxicity by reducing the use of chemical fire retardants. The government has proposed changes to the fire tests to allow for more innovative designs, but have no intentions of making the fire tests easier. They have also introduced the concept of the ‘Flame Retardant Technology Hierarchy’ and mandated that manufacturers must consider and justify the use of chemical flame retardants in their products. Any chemical flame retardants which are used must be listed on the label to improve transparency and allow customers to vote with their wallets.

The changes are all promising and could contribute to a reduction in chemical flame retardants, but without any rules mandating this reduction, serious questions remain – will the proposed regulations be significant enough? And will the rest of the fire industry follow suit?

We would like to thank environmental charity, Fidra, for their help in the production of this article, in particular Dr Joanna Cloy. Further information around this topic, including Fidra’s response to the consultation, is available on their website:

Fire & Risk Management is the UK’s market leading fire safety journal, published 10 times a year, and is available exclusively to FPA members in digital and print format depending on your requirements. You can find out more about our membership scheme here.

George Edwardes is the Technical Director at the FPA.

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