Does the Risk outweigh the benefit?
July 1, 2007 it the final deadline for compliance with the new national 
fireproof mattress regulation. While the regulation has good intentions it 
creates a new health risk.
The Risk: It requires known acutely toxic and cancer causing chemicals in to be 
used in the surface of new mattresses to pass the two-foot wide blowtorch open 
flame test, and it is proven we will absorb theses toxins, to avoid a one in 
1.111 million mattress fire risk.
We have made toxic mistakes in the past. In 1973 we banned PCB flame retardants 
after finding harm, then we banned TRIS flame retardants, then we found 
Asbestos, primarily used for its fireproof properties, had done great human 
damage, and in 2003 we banned PBDE flame retardants. Initially we thought all 
these flame retardant chemicals were nontoxic only to years later find great 
human harm.
In 2003 several independent studies found PBDE flame retardants in American 
women’s breast milk in growing and alarming quantities, at levels 10 to 20 times 
those found in European women. It is not known exactly how these chemicals enter 
the body. It is known they have been widely used in mattresses for many years 
and some suspect this is a probable source. But "this is another wake-up call," 
says Linda Birnbaum, director of the Environmental Protection Agency's 
experimental toxicology lab. Levels of PBDEs in humans are doubling every two to 
five years, she says. One of the studies authors, Arnold Schecter, professor of 
environmental sciences, says "These are our babies. Do we want them to be dumber 
than we are because their brains are being attacked by these toxic chemicals?"
Unlike the flame retardant chemicals now banned that we initially thought were 
non toxic, we already know the chemicals used to make mattresses flame proof are 
acutely toxic and cancer causing.
“Though the USA has the world's toughest flame retardancy standards, 3,000 
people die in fires each year. The Chemical Manufacturers Association estimates 
the number would be up to 960 higher without such flame retardants.” The USA 
currently uses 1.2 Billion pounds of flame retardant chemicals each year. This 
is four pounds of chemical every year for every man, woman, and child in the 
USA. Some say greater use of smoke detectors would save half of all fire deaths.
For comparison to other American risks the National Safety Council says, 6,091 
die as pedestrians, 16,337 die as car occupants, and 17,550 die from “Accidental 
poisoning by and exposure to noxious substances.”
Many doctors say there is insufficient science to justify this use of toxic 
flame retardant chemicals in mattresses, and that their use is unsafe in this 
application.
Dr Lawrence A. Plumlee, MD of the Chemical Sensitivity Disorders Association in 
Dallas says “The benefits do not outweigh the risks. I know many chemically 
sensitive people who do not tolerate treated mattresses. And how many are 
intolerant who don't know why they can't sleep or feel bad?
Dr. Doris Rapp, MD, F.A.A.A., F.A.A.P., says “they should UNQUESTIONABLY NOT 
EVEN CONSIDER PUTTING CHEMICALS INTO EVERY MATTRESS."
Dr. Alan D. Liberman, M.D., F.A.A.E.M., says: “We live in a very technologically 
advanced world, which advocates the advantages of these technologies but rarely 
ever considers the disadvantages or potential harm. It seems ill advised to 
expose hundreds of millions of people to a potential health hazard in order to 
protect a very few. …. I am absolutely opposed to adding the proposed toxic 
chemicals to mattresses. 
Dr. Margo Mayer-Proschel, a professor and researcher at the University of 
Rochester School of Medicine, says, “After doing my own literature research it 
is quite incredible that law makers are willing to risk the health of millions 
of people. According to available scientific data it is NOT clear whether the 
levels of chemicals one is exposed to on a chronic basis by sleeping on treated 
mattresses is safe, especially for children and pregnant women. I have yet to 
find a single scientific study that supports the use of these chemical in 
mattresses and labels them as "safe". It is another example of ignorance beyond 
reason and one begins to questions the true motivation of the individuals 
pushing for a national law to include these chemical in all mattresses. Maybe 
one should start to ask who would financially benefit from such a law to get the 
true motivation?
The innerspring mattress manufacturer’s association, International Sleep 
Products Association (ISPA) supported both the California fireproof bed law that 
became effective on January 1, 2005, and the new national fireproof mattress 
regulation passed by the US Consumer Products Safety Commission (CPSC) by a 3-0 
vote of the commissioners in February 2006.
Mark Strobel, President and owner of Strobel Technologies, a specialty mattress 
manufacturer says he called the president of the mattress manufacturers 
association and asked what ISPA was doing to fight the pending California law? 
The ISPA president replied, “Nothing, the members support the new law, and in 
fact ISPA went to the CPSC and asked for the same regulation nationwide. Strobel 
says he was shocked, why would an industry ask for more regulation? In an effort 
to get Strobel on his side ISPA told him “It would help keep the imports out.” 
While Strobel is no fan of imports either, he says he quickly realized it had 
many more benefits for the large mattress manufacturers and was not about fire 
safety. 
Strobel says it becomes clear that all the manufacturers costs would go up 
equally since they all had to comply, and that they would simply raise prices 
and make more money on the same number of units sold, and the testing and 
compliance costs would drive most of the small competitors out of business, plus 
help keep imports out. There are about 550 mattress manufacturers in the US and 
the top 15 control about 85% of the market. The new fireproof bed regulation 
would help the big boys get rid of many small pesky competitors, most of whom 
are small factory directs who make mattresses out of the back room and sell 
wholesale to the public through a storefront. Thus it would be a Win-Win-Win for 
the big manufacturers, and not at all about caring for people with fire safety.
After the conversation with ISPA and not being able to find a nontoxic system to 
fire proof his mattresses, Strobel says he decided to fight the new regulation. 
He put up the website www.PeopleForCleanBeds.org and generated 800 doctor and 
public comments against the new regulation, when the CPSC only gets about 20 on 
most new rules. Strobel got news in many newspapers across the country from the 
San Francisco Chronicle to the Washington Post, and some radio and TV coverage. 
But it was not enough and the regulation still passed.
There is an exception in the law that allows Physicians including Osteopaths and 
Chiropractors that allows them to prescribe clean mattresses free of the toxins 
required by the regulation. Strobel says all he can do now is offer prescription 
beds free of toxic chemicals, which he does through Chiropractors, dealers, and 
www.PrescriptionBeds.com.
The CPSC worked on this regulation for more than eight years and had good 
intentions. They hope to save up to 270 people from fire annually after all 
existing mattresses are replaced. They are also proud of the new regulation as 
it is the first major rule ever passed in the small agency’s history. A major 
rule is one that will cost consumers more than 100 million dollars annually. The 
CPSC says it will cost 1.11 Billion. The regulation also limits liability for 
mattress manufacturers and requires the full name and address of the foreign 
manufacturer to be placed on the mattress for imported mattresses. The official 
statements from the CPSC say there are numerous choices available to mattress 
manufactures to meet the regulation that do not pose an appreciable health risk 
to consumers. There are no labeling requirements for the chemicals used to flame 
proof mattresses and manufacturers are free to choose any untested chemicals 
they wish to pass the open flame test of the regulation.
The CPSC did internal tests to measure the chemicals contained in fire proof 
mattresses, and they measured the amounts of Toxic chemicals that leach from 
mattresses and contact our bodies. Then two CPSC employees generated an internal 
risk assessment to determine the amounts of toxic chemicals we are likely to 
absorb nightly. The CPSC report predicts the average person will absorb .081 mg 
Boric Acid, .073 mg DBDPO, and .802 mg Antimony, every night. Their report 
concludes this amount of poison absorption is safe for everyone, except children 
under age five who they excluded from their analysis. They excluded these young 
children by assuming all these children will sleep on vinyl sheets due to bed 
wetting problems, and that this will protect them from the toxic chemicals in 
their mattress.
Strobel says a short review of the short CPSC risk assessment shows a number of 
problem, errors and omission, and that it seems clear the risk assessment was 
agenda driven to reach a preexisting conclusion.
First, he says, they underestimated the amount of toxic chemicals we will 
absorb, and overestimated the amount that is safe to absorb. Quoting the CPSC 
risk assessment: “As with any risk assessment, there are assumptions, 
limitations, and sources of uncertainty. … Data on carcinogenicity, 
developmental and reproductive toxicity, or neurotoxicity were not available for 
all chemicals. Furthermore, it should be noted that percutaneous [skin] 
absorption data were not available for antimony.” Without comparable skin 
absorption data they assumed we will absorb only 1/10,000’s of the Boric Acid, 
1/1,000’s of the DBDPO (Deca), and 2/1,000’s of the Antimony, that contacts our 
bodies. We know from other research that one to four skin applications of 
Antimony Trioxide, the exact form used in mattresses, kills rabbits. And we know 
small patches are used to give medications through our skin. Thus, it seems 
likely we will actually absorb much more poison than they predict.
An independent review of the CPSC risk assessment is required by law and the 
reviewer complained about many things being wrong with the risk assessment. The 
CPSC simply rebutted the reviewers’ recommendations and made no changes. Two of 
the reviewers’ strongest complaints were that the CPSC assumptions of safe 
levels of toxin absorption do not agree with other government agencies, and that 
they changed the rules of the National Academes of Sciences “Child Sucking Test” 
and then did not even apply it to one year old children that the test was 
designed to protect.
For instance, for Antimony the CPSC assumed it is safe to absorb 166 mg per day. 
We know Antimony is an ancient poison as potent as Arsenic. A college chemistry 
textbook will tell you Antimony is a heavy metal similar to mercury and lead, 
and that Antimony is almost identical to Arsenic, with the only difference in 
its behavior being accounted for by the fact that Antimony is slightly more 
metallic than Arsenic. We know Antimony accumulates in the body and also causes 
cancer.
The Agency for Toxic Substances and Disease Registry, a division of our Center 
for Disease Control, says they can not determine a safe level for Antimony 
absorption because even at the lowest levels tested there were serious harmful 
health effects.
The US Environmental Protection Agency (EPA) says it is safe to absorb only .03 
mg of Antimony per day. The CPSC says we will absorb .8 mg every day from our 
flameproof mattresses even with their low skin absorption assumptions. This 
shows mattresses are toxic by 27 times the safe level, and we will likely absorb 
much more than they predict.
The CPSC changed the rules of the “Child Sucking Test” and then did not even 
apply it to young children. Strobel says his calculations show Boric Acid 
mattresses would clearly fail this test.
There are many other errors and omissions in the CPSC risk assessment. A notable 
one is that they did not test for formaldehyde content or release. In the CPSC 
table 1 that shows the percentage of toxic chemicals in fireproof mattresses 
they show Melamine Resin systems and test for Melamine release. In a 2004 CPSC 
document the same authors of the 2006 risk assessment talk about formaldehyde. 
They say Melamine Resin systems are made from the reaction of Melamine and 
Formaldehyde and know these systems contain Formaldehyde. They also know 
Formaldehyde causes cancer. These same authors say “Data are needed to determine 
the conditions for, and potential releases of, formaldehyde from barriers made 
with melamine/formaldehyde resin fibers.” Yet these same authors do not test for 
or even mention Formaldehyde in their 2006 risk assessment.
Formaldehyde concentrations of 10 to 15 parts per million have been found to 
cause nasal cancer in rats, and in June 2004 the International Agency for 
Research on Cancer reclassified formaldehyde as a known human carcinogen. The 
limit of detection of other chemicals with CPSC test equipment is 30 parts per 
million, but they did not even test for Formaldehyde release. 10 to 15 parts per 
million is a very small number and causes cancer. How much Formaldehyde will our 
fireproof mattresses really release? Formaldehyde is a simple poison that causes 
blindness and death. Will millions of Americans die or develop cancer from 
lifetime close chronic exposure?
Chemical fire proofing treatments are applied to the surface of the mattress, 
sometimes applied as a back coating to the ticking fabric of Boric Acid and 
Antimony, and in the case of treated cotton batting is directly under the 
ticking or with no more than a thin 1/8 inch layer of porous breathable 
polyester or foam between the ticking and the cotton batting. Modacrylic fibers 
contain Antimony and are often mixed with polyester fibers and used as the fill 
directly below the ticking. Melamine/Formaldehyde resin fibers are also placed 
directly below the ticking. Kevlar is only used it the thread to hold the 
mattress and fire barrier system together. The chemical treatment needs to be at 
the surface to protect the inner components from fire.
There are no labeling requirements for the flame retardant chemicals in 
mattresses. It is typical for mattress manufacturers to deny using chemicals. 
Strobel says he has seen one of the two top brands admit using Boric Acid and 
other chemicals to the Washington Post, only to deny using chemicals when 
customers have gotten sick from their mattress.
Strobel says there are no natural or nontoxic systems to flameproof mattresses 
and that you can see the proof in CPSC documents and in their table 1, of the 
most commonly used chemicals and their percentages in mattresses. If chemical 
free or natural systems exist, why doesn’t the CPSC point them out?
Manufacturers often try to say Boric Acid is safe and boron is found in fruits 
and vegetables. Even if it were safe, which Strobel disagrees with, it is not 
just Boric Acid, there are also many other chemicals. The CPSC’s table 1 shows 
all the Boric Acid systems also contain Antimony.
Even if safe systems exist, what happens to the unfortunate millions of people 
who sleep in an unsafe system?
Boric Acid is mixed as loose dust in the cotton batting in mattresses. The NIST 
has a shaking machine they use on mattresses before they fire test it to shake 
out loose boric acid. People do breath it from mattresses and many Asthma 
suffers can not tolerate it. There is at least one unsubstantiated case of a 
person dying from an Asthma attack from Boric Acid.
A study of Boric Acid miners showed reduced sperm counts and reduced sexual 
activity.
Borates are Boron. Boron is an element found in nature primarily in compounds; 
Boric Acid is a concentrated form of boron made from the reaction of Sulfuric 
Acid and Borax. It occurs in nature in only one place in the world, a sulfur 
spring in Italy. 
There can be .5 pounds of Boric Acid in a crib mattress, and 1.5 pounds in a 
queen size mattress, plus other flame retardant chemicals such as Antimony.
Many humans have actually died from Boric Acid poisoning. Experience has shown a 
dose as small as 2g has killed children, and 5g has killed adults. 
There are 6,463 cases of Boric Acid poisoning in the US each year, with 200 from 
topical preparations. (8)
Boric Acid is Roach Killer, simple acute poison, and a known reproductive and 
developmental toxin. "Demonstrated injury to the testes and the developing 
fetus." (7) 
Antimony seems to be readily absorbed through our skin. Antimony is a heavy 
metal almost identical to Arsenic. Antimony is known to accumulate in our 
bodies. Antimony is an ancient poison they used to knock off rivals. Antimony 
MSDS: “Chronic Exposure: Prolonged or repeated exposure may damage the liver and 
the heart muscle. … May cause heart to beat irregularly or stop." (6) If the 
poison doesn't kill us first, Antimony Trioxide is also known to cause cancer 
and even the CPSC admits: “The cancer effects are cumulative. Every exposure 
contributes to the overall lifetime risk of developing cancer.” (1)
Many people have already reported getting sick from treated mattresses.
Here is a quote from the CPSC where they are responding to public comments 
against the regulation:
“Comment
Some individuals commented that the "precautionary principle" should be applied 
to FR chemicals, that is, they should not be used until proven safe (7,26,44,47, 
and 51).
Response
All of the statues that provide regulatory authority to the CPSC explicitly 
require risk-based decision making, thus precluding application of the 
"precautionary principle."”
The CPSC has already said it is up to other agencies to ban chemicals if they 
are found unsafe, and if human harm is found from this regulation that specific 
chemical could be banned.
Strobel says it will be a little late to ban a chemical after we find we have 
harmed or killed millions of people. And we may again find years later another 
chemical causes harm. Common sense should tell us, there are no safe chemicals, 
only safe use.
Some individuals who commented call the regulation “A human experiment without 
consent.”
According to the National Safety Council 17,550 Americans already die each year 
from “Accidental poisoning by and exposure to noxious substances,” this number 
now exceeds deaths in car accidents. (9)
Now, every American, all three hundred million of us will be eventually forced 
to unknowingly sleep in and absorb poisonous and cancer causing chemicals for 
the rest of our and our children’s lives. All to avoid a one in 1.111 million 
mattress fire risk. 
July 1, 2007 is National Toxic Bed Day. This day may also go down in history as 
“National Toxic Day,” the day we crossed the line in poisoning our people.
You may agree the risk outweighs the benefit.
Fortunately, the law allows Physicians, including Osteopaths and Chiropractors, 
to prescribe toxin-free mattresses, to those lucky few who learn the truth.