Rebecca Stamm | July 10, 2018
In our 2017 report, Eliminating Toxics in Carpet: Lessons for the Future of Recycling, HBN identified toxic chemicals and materials that are commonly found in carpet. We also outlined pathways to optimize these products for lower health impacts and improved recyclability. Ensuring the use of materials with lower toxicity and designing carpet for recyclability is key for California to responsibly reach its mandate of doubling the rate of carpet recycling by 2020. Several recent steps in California show promise in this optimization process.
CA DTSC Proposes PFAS in Carpet as Priority Product
Per- and polyfluoroalkyl substances (PFAS) are commonly used as treatments for carpet fibers to impart stain and water resistance. In February 2018, the California Department of Toxic Substances Control (DTSC) proposed listing PFAS in carpets and rugs as a potential Priority Product through their Safer Consumer Products program. The Safer Consumer Products regulations are meant to reduce toxic chemicals in consumer products, create business opportunities, and help consumers know what’s in the products they buy. DTSC has determined that “there is potential for human and other organism exposure to PFASs in carpets and rugs,” and “the exposure has the potential to contribute to or cause significant and widespread adverse impacts.”
A key point in DTSC’s review of PFAS is that the agency considered the whole class of chemicals. This is in contrast to some restricted substances lists or “red lists” that prohibit only a subset of this class. The broader class approach helps avoid regrettable substitutions that can occur when a well-studied hazardous chemical is replaced with a less studied chemical of the same class whose hazards are not yet known.
The agency report states, “Based on the criteria in the Safer Consumer Products Regulations, DTSC has determined that PFASs have the potential to cause significant and widespread adverse impacts to sensitive subpopulations, including fetuses, infants, young children, pregnant women, carpet installers, and carpet retail sector workers; to environmentally- sensitive habitats; and to threatened and endangered species. Given the known hazard traits and the absence of data demonstrating the safety of any member of the class, replacing currently-used PFASs in carpets and rugs with other members of the PFAS class could constitute a regrettable substitution. Hence, this proposal covers the entire class of PFASs in carpets and rugs.”
DTSC is currently reviewing public comments. If it decides to formally list PFAS in carpets and rugs as a Priority Product, manufacturers must either stop using PFAS or perform an alternatives analysis. This analysis must answer the questions, “Is this ingredient necessary? Is there a safer alternative? Is that alternative feasible?” After an alternatives assessment, regulations may be imposed to protect public and environmental health.
HBN applauds DTSC for this effort to review alternatives to highly toxic PFAS chemicals in carpets.
SF Environment Adopts New Sustainable Carpet Regulation
In March 2018, the San Francisco Department of the Environment (SF Environment) released a new regulation that set minimum requirements for environmentally preferable carpet purchased for use in city construction projects. These requirements are among the most stringent in the country and include certification and transparency requirements. There are also minimum levels of recycled content and prohibitions on toxic chemicals and materials that are commonly used in carpet.
HBN is pleased to see that the chemical restrictions are in close alignment with the recommendations in our 2017 report on carpet. These include prohibition of:
SF Environment has compiled lists of carpets that meet their requirements, which are a great starting point for those looking for carpets without these harmful substances. SF Environment notes, however, that the lists are provided by the manufacturers and haven’t been confirmed. Keep in mind that for some of the carpets listed, compliance with the criteria may need to be requested. For example, for Bentley carpet tiles, the customer must request the products be made without fly ash.
Some caveats to the regulation include:
The regulation only restricts “intentionally added” antimicrobials, flame retardants, and PFAS “at or above 100 parts per million (ppm).”
This language is different than used for the other material restrictions, which require that the “carpet backing shall be free of” fly ash, PVC, polyurethane, and styrene butadiene latex. (emphasis added)
HBN’s product research suggests that if there are intentionally added flame retardants and PFAS, they would likely be present above 100 ppm. Antimicrobials may be intentionally added at less than 100 ppm.
The regulation wording suggests that all three may still be incorporated unintentionally, which is certainly possible for some types of recycled content.
All things considered, this regulation represents a big step forward in optimizing carpets. It highlights the current state of the industry and rewards manufacturers that have made significant product improvements and have engaged with the industry movement toward transparency.
 “What Is the Safer Consumer Products (SCP) Program?” CA Department of Toxic Substances Control. Accessed July 2, 2018. https://www.dtsc.ca.gov/SCP/WhatIsTheSCPProgram.cfm.
 “Product – Chemical Profile for Perfluoroalkyl and Polyfluoroalkyl Substances (PFASs) in Carpets and Rugs.” Discussion Draft. CA Department of Toxic Substances Control, February 2018. https://www.dtsc.ca.gov/SCP/upload/Product-Chemical-Profile-PFAS-Carpets-and-Rugs.PDF.
 Lovell, Tammy. “California needs ‘information on alternatives’ to achieve PFAS-free carpets.” ChemicalWatch, February 27, 2018. https://chemicalwatch.com/64276/california-needs-information-on-alternatives-to-achieve-pfas-free-carpets.
 “SCP Program Frequently Asked Questions (FAQs).” CA Department of Toxic Substances Control. Accessed July 2, 2018. https://www.dtsc.ca.gov/SCP/SCP-ProgramFAQs.cfm.
 The actual regulation language refers to the 100 ppm threshold only for antimicrobials, but the spreadsheets of products that meet the regulatory requirements include the 100 ppm threshold for flame retardants and PFAS as well.
 “San Francisco Department of the Environment Regulation #SFE 2018-01-PPO/GBRCBO Adopting Approved Alternative Products for Sustainable Carpet for City Departments,” March 9, 2018. https://sfenvironment.org/sites/default/files/policy/regulation_sfe-2018-01-ppo_gbrcbo.pdf.