Bonded Polyurethane Carpet Cushion Profile

Bonded carpet cushion produced in the United States in accordance with general industry practice complies with U.S. law in terms of PentaBDE content, in that (1) its PentaBDE content does not exceed the limits adopted in any state in the United States, i.e., 0.1% by weight, and/or (2) is exempt from such limits because the PentaBDE content of bonded carpet cushion is solely attributable to its recycled foam content.

• Bonded carpet cushion represents over 85% of the total carpet cushion produced in the United States.

• Bonded carpet cushion consists of 100% recycled (post-industrial and /or post-consumer scrap foam).

• Flame retardants containing Poly-Brominated Diphenyl Ethers (PBDE) are not used in the bonded manufacturing process.

• Since the end of 2004 post-consumer scrap is the only source of PentaBDE in cushion.

• The Carpet Cushion Council has independently tested the PentaBDE content of post-consumer scrap since 2005.

• Beginning in 2006 and since, the Carpet Cushion Council has sponsored independent testing on a full range of densities of bonded carpet cushion manufactured with post industrial and post consumer scrap.

• Beginning in 2006 and since, the Carpet Cushion Council has sponsored independent testing on a full range of densities of bonded carpet cushion manufactured with post industrial and post consumer scrap.

While US Bonded Carpet Cushion Manufacturers comply with the previously established PentaBDE limit of 1000 parts per million (0.100% by total weight of carpet cushion), the mean PentaBDE content of the tested samples has fallen annually and in December 2015 was at a level of approximately 200 parts per million by total weight of the carpet cushion (i.e. 0.020%).


PBDE’s IN BONDED CUSHION MADE USING RECYCLED CARPET CUSHION FOAM

Summary: Bonded carpet cushion produced in the United States in accordance with general industry practice complies with US law in terms of PBDE content in that (1) its PentaBDE content does not exceed the limits adopted by any state in the United States and / or (2) is exempt from such limits because the PentaBDE content of bonded carpet cushion is solely attributable to its recycled foam content.


Introduction and Industry Background:

Bonded foam carpet cushion represents in excess of 85% of US annual sales of carpet cushion (all types). Production of bonded carpet cushion is generally regarded as among the most significant examples of the benefits of recycling.

Bonded foam carpet cushion consists of 100% recycled foam, a mix of varying percentages of post-industrial and post-consumer scrap foam, i.e., mixing formula. The percentage of post-consumer scrap used tends to increase as the density of the bonded cushion increases. Under general industry practice, the percentage of take-up foam cushion used in new bonded cushion, if any, varies between 5% - 20% (for medium density products) and 40% - 55% (for high density products).

Prior to mid - 2005, PentaBDE could have been present both in the post-industrial and post-consumer scrap foam used to make new bonded carpet cushion. From the late 1960s/early 1970s until late - 2004 /early - 2005, PentaBDE was used as a fire retardant in foam where customer specifications required the foam to comply with flammability standards. These standards applied to some furniture, mattress and automotive foams. The amount of pentaBDE used varied by the specification. For example, compliance with MVSS 302 (automotive) required use of less PentaBDE than compliance with Cal. Tech. Bull. No. 117 (upholstered furniture). The post-industrial scrap foam from all of these manufacturing operations became part of the raw materials mixing formulas used in the production of bonded carpet cushion.

PentaBDE is not and has not been used in bonded carpet cushion as a fire retardant.

Since mid - 2005, the only source of PentaBDE in new bonded carpet cushion is the post-consumer (take up) scrap portion of the mixing formula for new bonded.


Testing and Assessments:

Testing of bonded cushion for its PentaBDE - content is a process that typically take several weeks from the time test samples are collected, making it impractical to test the post-consumer scrap or the new bonded production for its PentaBDE - content prior to shipment of the finished product. As a consequence, to gauge the PentaBDE - content of the finished product, producers of bonded cushion are obliged to blend post-industrial and post-consumer scrap in the context of what is known about the PentaBDE - content, on average, of post-consumer scrap being collected at the time.

The Carpet Cushion Council has been assessing the PDBE content of post-consumer (take-up) scrap carpet cushion systematically since 2005.

In 2005 / 06, samples of medium density and high density foam from multiple collection points (12 - 14) geographically dispersed throughout all regions of the United States were analyzed for percent by weight of penta technical mixture (PentaBDE) by means of gas chromatography / mass spectrometry under the supervision of Dr. Robert Hale of the Department of Environmental & Aquatic Animal Health, Virginia Institute of Marine Science, College of William and Mary.

In the 2005 / 06 survey of post-consumer scrap carpet cushion the average for all samples of total penta technical mixture (PentaBDE) was 0.313% by weight. In a similar survey of post-consumer scrap carpet cushion in 2009 the average for all samples of total penta technical mixture (PentaBDE) was 0.273% by weight. The numerical mean results in the Carpet Cushion Council surveys described as PentaBDE also includes the PBDE congeners generally associated with OctaBDE.

The Carpet Cushion Council has been monitoring and testing the PentaDBE content of new bonded carpet cushion systematically since 2006.

In the 2006 / 07 assessment of the PentaBDE content of new bonded carpet cushion the mean PentaBDE content was 0.106%. The mean did not take into account the fact that low density bonded carpet cushion production that does not include the use of any post-consumer (take-up) carpet cushion foam.

The information available to the Carpet Cushion Council at the present time indicates that the mean PentaBDE content of new bonded carpet cushion produced in the United States is approximately 0.02%.


Current and Future PentaBDE Content of Post-Consumer Scrap Carpet Cushion Foam and New Bonded Carpet Cushion:

Reductions in the PentaBDE content of post-consumer scrap carpet cushion being collected and recycled into new bonded carpet cushion will be reflected in reductions of the PentaBDE content of new bonded produced comprised of the scrap foam collected at the time. Significantly, reductions in the PentaBDE content of new bonded will reflect the recycling into new bonded carpet cushion of post-consumer scrap cushion that will consist of “penta free” post-industrial scrap, i.e., reflecting cessation of the use of PentaBDE foam in furniture, mattress and automotive foams by mid-2005.

Carpet (and therefore carpet cushion) is generally thought to be replaced between 5 - 15 years after installation. By 2011 (five years after cessation of the use of PentaBDE as a FR in furniture foams, mattress foams and automotive foams), new bonded carpet cushion produced with mixing formulas of post-industrial and post-consumer scrap foam employed under general industry practice should contain successively lower amounts of PentaBDE each year because the post-industrial scrap component will be have been PentaBDE “free” since 2005.


Public Policy Considerations:

Based upon the information presently available, post-consumer (take-up) carpet cushion foam relegated to the landfill would have a mean PentaBDE content of about 0.1 % by weight while the same foam, when recycled into new bonded carpet cushion, will have a resulting mean PentaBDE content of approximately 0.01% by weight. A PentaBDE ban without a concentration tolerance would, in the United States, relegate 300 to 400 million pounds of post-consumer carpet cushion foam to landfills annually.

Bonded foam carpet cushion currently represents in excess of 85% of US annual sales of carpet cushion (of all categories / types). The inability to continue to utilize post-consumer (take-up) carpet cushion scrap foam in the production of new bonded carpet cushion would need to be off-set by substitution of imported post-industrial scrap foam (or post-consumer scrap from other types of products, imported or domestic), to the extent available. Absent availability of scrap foam for use in production of new bonded, pouring of foam for the purpose of converting it into new bonded cushion would be required. A very significant raw materials cost premium would be involved.

3/23/16

PBDE’s IN BONDED CUSHION MADE WITH RECYCLED CARPET CUSHION FOAM

Summary: Bonded carpet cushion produced in the United States in accordance with general industry practice complies with US law in terms of PBDE content in that (1) its PentaBDE content does not exceed the limits adopted by any state in the United States and / or (2) is exempt from such limits because the PentaBDE content of bonded carpet cushion is solely attributable to its recycled foam content.

Introduction and Industry Background: