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Author Deborah Wallace
Sr Project Leader
Consumers Union
walled@consumer.org

 
Comment
The TSAC Analysis of PVC Fires and Their Impacts

The TSAC report uses only two databases, a medical one and an environmental one. Neither of these databases contains the data and scientific discourse needed to assess the impacts of PVC fires, particularly on health. Such publications as Fire and Materials, Journal of Combustion Toxicology, Fire and Flammability, and a host of governmental reports such as that by the government of Ireland which analyzed the Stardust Disco fire of 1984 (125 people dead) contain absolutely essential data and analyses. The TSAC analysis is an utter travesty because of the ignorance it exposes with respect to the thermochemistry of PVC pyrolysis and combustion, the multifatal fires in which PVC was a major contributor to the atmospheric toxicity, and the role of building design in determining the path and concentration of the products of thermal decomposition at different stages of the fire. These data, statistical analyses, and scientific discussions are widely available and known by those who have even merely put their toes into these waters, so to speak. Failure to include them shows either a willful averting of eyes or a woeful ignorance of the field. Such chemists of the PVC industry itself such as Michael OMara published papers showing the mass emission of HCl from PVC at 250C and the emission of a myriad of organic compounds as the temperature rises toward ignition (600C). Jeremy Stone wrote the keystone paper on the role of soot its respirable size and the adsorption of HCl onto its surfacein the lung damage consequent on PVC fires. These papers were published in the 1960s-1970s and would not appear in the databases on which TSAC foolishly relies.

Other relevant publications include Fire Engineering and the journals of the fire service across the country.

The fires that TSAC uses to conclude that PVC is not a special problem in fires were viewed from their outdoor aspects only and were not fires in inhabited buildings. Numerous fires that occurred in various types of inhabited buildings (residences, workplaces, hotels, and places of public assembly such as nightclubs and restaurants) have been described in fire science literature. The enclosing of the space in which the fire occurs prevents the venting of the smoke and keeps the concentrations in the pyrolytic fumes and the smoke high. Furthermore, the design of the building determines where these plumes go and how concentrated they are at the various sites along the pathway. The smoke of the MGM Grand Hotel fire (1980) rose through the elevator shafts and plumbing pipe spaces and concentrated at the top of the building from which it diffused downward. This fire began as a PVC fire in the wire insulation behind a refrigerator display case on the groundfloor; PVC made major contribution to the smoke, as analysis of the metals in the soot from the respiratory tracts of the corpses showed (deposition of Merritt Birky in the litigation; Merritt Birky had been the chemist of the NIST Fire Research Center but later migrated to the National Transportation Safety Board). The design of the building is a crucial factor in the impact of PVC fires (and other fires), and NIST had sponsored much work on modeling fires that included building design among the model parameters. Additionally, reconstruction of many of these fires in hotels, restaurants, stores, and office buildings included a wide range of data such as soot analysis that showed the roles of the various combustible materials. TSAC failed to draw on this rich database. The NFPA does not have (and has never had) competent fire scientists or engineers to reconstruct the mass fatal fires for which it issues reports under contract to FEMA. But insurance companies such as Swiss Reinsurance have done better; Swiss Reinsurance has issued reports over the past 30 years on the role of PVC in mass fatal and very damaging fires in Europe because that company has to pay for rebuilding after the fire and for the liability in the case of injuries and deaths. Factory Mutual, the lab oצP*Sr Project Leaderh*ئConsumers Union ئ*)G7PT**
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