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WORDS ON FIRE
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by Timothy Jacobs
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 Flammability Updates & News
The New National Flammability Standard, 16 CFR 1633, is Now a Reality
Why We Should Focus on Product Quality More Than Ever
On February 16, 2006, the US Consumer Products Safety Commission approved the new national flammability standard for mattresses and futons. This new nationwide standard, officially known as 16 CFR 1633, will go into effect on July 1, 2007. While the new US CPSC standard does not specify how manufacturers are to design their mattresses, it does specify what flame-resistance criteria they must meet. In this new performance standard, the peak heat release rate of a mattress subjected to the required flame source is limited to 200 kW during a 30-minute test, and the initial total heat release is limited to 15 MJ within the first 10 minutes of the test.
Mattress and futon companies will also have to comply with the pre-existing cigarette smolder standard, 16 CFR 1632. As stated in a February 16, 2006, press release by the International Sleep Products Association, ISPA and the Sleep Products Safety Commission have “asked the CPSC to make several changes to Part 1632…in order to reduce some of the burdens of testing under both Parts 1632 and 1633.” As of this writing, there’s been no definite response to this request.
Other Aspects of the New Law
You May Not Be Aware Of
In a February 16, 2006, US CPSC press release, CPSC Commissioner Thomas Moore points put that the Preamble to 16 CFR 1633 cites the standard as prevailing even in states where previously existing flammability laws are in effect.
Manufacturers, wholesalers, importers and retailers should be aware, then, that both 16 CFR 1632 and 16 CFR 1633 will be part of your flammability compliance planning wherever you sell in the United States.
Industry participants would be wise to contact local and state compliance authorities to see how 16 CFR 1633 affects compliance responsibilities in your areas of operation. Other aspects of 16 CFR 1633 clarify the responsibilities of mattress importers and mattress renovators.
Renovated mattresses and imported mattresses must meet all of the new ruling’s requirements. All testing, quality assurance and other vital records pertaining to the mattresses must be on hand at the respective company offices in the United States, and all documentation must be in English.
Importers must include their company name and United States address on a tag attached to each mattress.
Other Aspects of the New Law You May Not Be Aware Of
Also, as quoted in the CPSC’s February 16 press release, CPSC Chairman Hal Stratton says that 16 CFR 1633 “has the virtue of flexibility: manufacturers are required to meet performance standards and thus have considerable flexibility in choosing among a range of component materials…On the other hand, the Rule is stringent and significantly raises the basic level of safety that all mattresses must meet.” The press release also quotes CPSC Commissioner Thomas Moore as saying, “The National Institute of Science and Technology and the mattress industry were instrumental in making this new standard possible. I would be remiss if I did not also acknowledge the work done in this field by the State of California's Bureau of Home Furnishings and Thermal Insulation.”
ISPA and the SPSC will hold a series of SHOPtalk seminars to answer questions about the new standard.
Visit www.sleepproducts.org/shoptalk/flammability for information on SHOPtalk events. To download a complete copy of the16 CFR 1633
regulation, go to http://www.cpsc.gov/BUSINFO/frnotices/fr06/mattsets.pdf.
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