RECOMMENDATION ON THE SAFETY OF SOLID FIRELIGHTERS (July 2009) A definition that does reflect neither the market nor the use of the products… • A solid firelighter is « a solid substance or preparation, which is readily ignitable through by the application of a naked flame and which can be used to ignit solid barbecue fuels and grill applicances » (Standard NF EN 1860-3 « Firelighters for igniting solid fuels for use in barbecue appliances – requirements and test methods » clause 3.1). Accident data on solid firelighters in France(1) •Few accidents in the official injury data base (5 accidents between 2004 and 2006) • Many descriptions to poison centers (2105 between 1999 and the end of 2008, almost 200 calls a year) Accident data on solid firelighters in France (2) • 99 % ingestion accidents • 90 % are asymptomatic (42 % for liquid firelighters) 5 % cause digestive disturbance et 4 % respiratory disturbance • Principal victims : young children (90 % under 4 among which 10 % under 1) • All types of products are involoved, whether presented in cubes or in divisible plaks • 97 % of the accidents happen indoors et 56 % between October and April Risk analysis Nature of the risk Circonstances of accidents Causes Aggravating factors Ingestion or inhalation of a fire-lighting cube, of a Accessibility to the product. The product is displayed in divisible plaks, do not allow to Asphyxiation because of an fragment, of dust or crumble (false passage). The product is easy to break or friable. control the size and the form of the pieces taken off.. obstruction of the alimentary The product is attractive because of its Absorbent nature of the basic product ( wood, vegetable canal form, its aspect, its smell. Possible fibers). confustion with food. Ingestion of a cube or a detachable part Form of the pieces of the ingested products. Presence of Damages on the alimentary splinters or of very thin particles (silica) in the products made canal of compressed wood. Succion or ingestion of a fire-lighting cube, of a Accessibility to the producit. The victim is proned to allergies. Absence of traceability of fragment, of dust or crumble. Succion of the The product is attractive because of its produicts exogenous to the manfacturing process of the cubes packaging or of a part of the body in contact with form, its aspect, its smell. Possible (solvents for paraffin, phytosanitary products for the product. confustion with food. Presence of vegetables..). Digestive intoxication harmful, irritating, allergenic or toxic substances in the product (kerosene, paraffin, resins, insecticides, fungicides, formaldehyde…). Inhalation of dust or gaz emerging from the Ingredients of the product, presence of The victim is proned to allergies. product or the fumes during combustion. preservatives or of treatments undergone Absence de traçabilité des composants ou produits de Respiratory intoxication Systemic effect of the ingestion of petrol-based by the components. Deterioration of the traitement des composants. fire-lighters. product in the course of time (fungus attack on vegetables). Burn and fire Flash effect during the ignition. Embrasement Ingredients of the product. No respect of instructions for use (accumulation of the cubes Sudden blaze of the fire-lighters. Size of the in one point of the hearth ; use of too many cubes). Not flames. Explosion of the product in contact with enough distance between the user and the hearth. the flame Flow of the molten product. Projections of matter, of sparks. Lighting time too long or no lighting at all of the hearth at the first attempt. Nother attempt to light again a burning ember. Contact of the skin, of the mucous membranes or Irritation of the skin or of the of the eyes with the product, its packagning or the eyes burning fumes. The market of solid firelighters (1) • Three types of firelighters : preparations based on kerosene, des préparations à base de paraffin and « natural » vegetable products •represent 50 to 80 % of the sale of firelighters, according to the professionals • A use less expensive than that of liquid and gelified firelighters (0,35 € for a solid fire-lighter, vs 0,45 € for a liquid or a gelified one) • various uses in summer and in winter (barbecues, fire places, stoves ) The market of solid firelighters (2) • Kerosene based firelighters - 50 % of the sales - two presentations in « cubes » or in divisible plaks - 70 to 85 % kerosene + 15 to 20 % water +3 to 5 % preservaties and binding agents and sometimes lignite - a strong smell of hydrocarbon Kerosene is considered to be dangerous because easily flamable, noxious in case of ingestion and irritating for the skin The market of solid firelighters (3) • Paraffin-based solid firelighters - 25 % of the sales - a presentation in about 10 g white « cubes » -They are composed of paraffins more or less without oil (gatsch), of water and of tensioactiv agents, sometimes of kerosene in order to lower the flash point - they are sold as « odourless » -Paraffin is considered to be a dangereus substance because easily flammable and noxious (R 65) The market of solid firelighters (4) • « natural » firelighters - 25 % of the sales - various presentations (cubes, bulks, bundles, balls..) - 100 % of barks or conifers ou 50 % of wood and compressed fibres + 50 % of paraffin - No guaranties on the terms « natural », « environment-friendly », « not toxic », « clean » that are given to them by the manufacturers. The regulations applicable to solid firelighters (1) • For those preparations, directives 67/548/CEE et 1999/45/CE modified apply, as well as 04/20/1994 et 11/09/2004 decrees on the marketing of dangerous substances and preparations • No specific regulation on « natural » fire-lighters • Clause 31 of Regulation CE n° 1907-2006 REACH on the registration of safety data • On the other hand, decree n° 92 of 09/09/1992 on the prevention of the risks from the use of products imitating food does not apply if you follow the interpretation of the Repression of Frauds because natural firelighters « do not imitate » food. Decree n° 92 of 09/09/1992 « Products Products that are not food, but that it is reasonably foreseable that the consumers, in particular children, might confuse with food, considerong their characteristics, particularly their shape, their smell, their colour, their aspect, their packaging, their labelling, their volume or their size, must not present, for the safety or for health risks of choking, intoxication, the perforation or the obstruction of the alimentary canal. » (Clause 1). • To that purpose - Their level of certain substances (heavy metals) is limited (clause 2) ; - Their dimension must not allow them to be ingested by children under 36 months (clause 3) Solid firelighters and NF EN 1860-3 standard • A standard that is obsolete, not well known and not really applied no requirements on the composition and the performances of firelighters sold as « natural » No quantified indicators to characterize a safe use of solid figherlighters Unspecified and incomplete indicators of performance The risk of ingestion and of choking is not met (resistance of the packaging and cylinder test) on the packaging, no mention of the components, no message of prevention agains the risks of burning The tests made for the Commission (1) • Their goal : to better understand the risks of burning and of intoxication for the users of solid firelighters through the analysis of the composition of the products, through their fire behavious and the characteristics of their packaging : • The method : subject about ten solid firelighters to standardized tests, using several referentials (standard NF En 1860-3; standard En 71-1, NF En ISO 1924-2, of WHO and INRS toxicological values…). • The result : a classification of the global usage risk of each of these products. The tests made for the Commission (2) The burning risk the risk of burning or of fire is much less important with solid fire-lighters than with liquid or gels. the fire behaviour is relatively homogenous for all the types of products, with no projections or sudden blaze the period of combustion varies from 10 to 15 mn the calorific values are different : kerosene 35 MJ/kg ; paraffin 40 MJ/kg; compressed wood and paraffin 35 MJ/kg; compressed wood 17,6 MJ/kg Les essais de la Commission (3) The risks of intoxication six fire-lighters exceed the admitted dose of sulpher and all contain benzene. On these points they are not in conformity with standard NF En 1860-3 In case of ingestion, the risk of intoxication is low In case of inhalation of the fumes, there can be a severe intoxication by sulpher elements, benzene, acroleine, formaldehyde, nitrogene oxides and carbon monoxide even for « natural » products The tests made for the Commission (4) The risks of ingestion and false track for young children • A correct resistance to humidity • A proven risk of access to the product for the young children : no packaging is in conformity with the requirements of resistance to traction in the standards on the safety of child-care articles and toys (50N à 90 N) • An important risk of choking : 7 produits out of 10 do not pass the cylinder test The global risk assessment P1 P2 P3 P4 P5 P6 P7 P8 P9 P 10 Risks/products Main K K K P P P B B B B component (a) Burning 4 7 10 6 8 9 3 2 1 5 classification Intoxication 10 7 5 6 9 8 2 1 3 4 classification Ingestion 5 7 6 4 8 9 1 3 1 2 classification IRG 6 7 8 5 9 10 2 4 1 3 classification • On the whole, the « natural » products seem to be the less dangerous ones The recommendations of the CSC To the public authorities to improve the epidemiological knowledge on the etiology of burnings and intoxications in France, notably on the accidents caused by solid firelighters. when their presentation and their characteristics justify it, to apply to solid fire-lighters the clauses of decree n° 92-985 of September 9 1992. To see that the professionnal use the appropriate terms pointing out the natural, biological, environment- friendly or safe characteristics of solid firelighters To the authorities in charge of standardization To intervene at the European level for the european standard NF EN 1860-3 : - To include tests of traction on the packaging and the cylinder to meet the risk of ingestion and suffocation for young children - To define with indicators and test methods the caractéristics of fire behaviour, the safety requirements and the performances of all the solid firelighters and of their packagings ; - To specify the conditions of the use of the terms “natural”, “environment- friendly”, « non toxic » for certain solid firelighters; - to impose the presence on the packagings of the mention of the main components ; the words « not to be used on live embers or flames » and « do not breathe the fumes ». To the professionals manufacturers and dealers of solid firelighters to favour, in their range of firelighters, solid products that are the less toxic presented in separate cubes. to import, produce, package or market only solid firelighters meeting a minima the requirements of standard NF EN 1860-3. to be involved in the works for the revision of standard NF EN 1860-3, and, in the pending period : - To submit their products and their packagings to the cylinder test and to traction tests to meet the risk of ingestion and of suffocation of young children - To put on the packaging the mention of the main components ; the words « not to be used on live embers or flames » and « do not breathe the fumes ». To the consumers to prefer solid firelighters packaged in separate cubes to liquid or gel firelighters not to let solid firelighters within reach of young children to respecter scrupulously the instructions for use of solid firelighters and in particular : - To use them in statisfactory conditions of ventilation - To avoid to inhale their fumes - for barbecues, to wait until the end of the combustion la of the fire-lighters and the quenching of the flames before cooking the food ; - Not to rekindle embers with a solid fire-lighter and not to throw a fire-lighting product on the burning flames.
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