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  • pg 1
          (July 2009)
    A definition that does reflect neither
       the market nor the use of the

• 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
                                                                                                                                         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,

                                   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
                                   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
  - 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,
  - 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
• 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

  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
   Main            K    K    K    P    P     P     B    B      B    B
component (a)
   Burning         4    7    10   6    8     9     3     2     1      5
 Intoxication      10   7    5    6    9     8     2    1      3     4
  Ingestion        5    7    6    4    8     9     1    3      1     2
     IRG           6    7    8    5    9    10     2    4      1     3
• 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
 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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