CPSC Reviews Mattress Safety, Small flame bench scale test recommended
Small flame bench scale test recommended.
On August 23, the U.S. Consumer Product Safety Commission (CPSC) released a briefing package developed by Commission staff detailing the need for a national standard on mattress flammability and specifically focusing on open-flame ignition of mattresses and bedding.
This briefing package--which will likely be voted upon by the three CPSC Commissioners in either late September or early October--came with the recognition that mattress and bedding fires continue to be a leading cause of injury and are second only to upholstered furniture as the primary ignition source for residential fires. Moreover, according to CPSC staff, the lethal nature of mattress fires has not been adequately addressed by standards that were implemented in the 1970s to reduce mattress and bedding fires caused by cigarettes. Foreign exchange: commerce company exports mattresses to address Chinese consumers' worries about product safety
While CPSC staff notes in the briefing package that cigarette standards had been successful in achieving a significant reduction in injuries and deaths related to mattress fires, they also point to mattress fires caused by open-flame sources such as candles, lighters and matches. In addition, the victims of these fires are often young children.
As CPSC staff note in its briefing package, "In 1998, mattress or bedding items were first to ignite in about 18,100 residential fires that resulted in 390 deaths, 2160 injuries and $208.3 million in property damage. During the five-year period from 1994 to 1998, children under age 15 represented more than 75% of the deaths in fires." Development of the briefing package is also in direct response to four petitions that have been filed with CPSC by the Children's Coalition for Fire Safe Mattresses (CCFSM).
In response to these petitions and its own concerns, CPSC staff has joined the Sleep Products Safety Council in sponsoring research being conducted at the National Institute for Standards and Technology to develop a test method for addressing mattress flammability issues. Based largely on this research, the CPSC briefing packet provides data and support for developing a national standard as requested within two of the CCFSM petitions, but it also recommends that the two other petitions (which call for new label warnings and hang tags) be rejected.
Nonwoven fabrics are used extensively in mattress construction and, if the CPSC Commissioners vote to move forward with a rulemaking, it would have a significant impact on our industry. To date, INDA, Association of the Nonwoven Fabrics Industry, Cary, NC, has filed comments with CPSC urging the Commission to give careful consideration to the matter and to withhold publication of a proposed standard until comprehensive research on mattress flammability issues has been concluded. INDA has also worked with CPSC staff in an effort to educate the Commission on materials used in mattress construction as well as performance characteristics of nonwoven fabrics that could be incorporated into a future standard.
In its briefing book, CPSC staff report that a large number of the mattress fires involve open flame ignition of the bedding, which are especially lethal because they expose a mattress to higher fire temperatures than a smoldering cigarette and, once ignited, mattress fires tend to spread rapidly As CPSC staff explain: "Since mattress fires first often involve an ignition source of burning bedding and because few materials can resist such a large ignition source, the typical approach of preventing ignition of a mattress through a product performance standard is not reasonable." CPSC staff also note that mattress fires are especially dangerous because they can result in "flashover," a term used to describe the phenomena whereby a fire becomes so intense that it literally feeds off the air. This causes the fire to spread rapidly and exponentially.
Developing a standard that helps prevent flashover, therefore, would significantly reduce the number of mattress fire deaths and injuries that occur each year, according to CPSC. Specifically, CPSC staff estimate that the "total percentage of mattress/bedding fire deaths addressable by an open flame standard preventing flashover is 63% (300 deaths/year) and the percentage of injuries is also 63% (1460 injuries/year)." New Hillside name reflects strategy
In preparing the briefing package, CPSC staff also reviewed existing standards related to mattressflammability and identified 13 sets of such standards that are currently in place. For instance, the U.K., California as well as several government agencies and private standard-setting bodies have all developed a standard. While existing standards take differing approaches to the issue of mattressflammability, each of them is based on some form of flammability testing. Full-scale flammability tests are generally considered the most accurate means of predicting mattress performance and are required under nine of 13 existing standards according to CPSC. Unfortunately, these tests are costly and can be impractical considering that there are only 12 facilities in the U.S. that conduct such tests.
Small-scale testing, on the other hand, is more cost-effective and these tests are easier to conduct, but they only involve certain components of a mattress and, as such, do not produce a realistic mattress fire scenario, according to CPSC staff. What is needed is a bench-scale test that could be designed to provide the accuracy of a full-scale mattress test with the convenience and safety of a small-scale test. To see if such a test is feasible, CPSC staff has implemented a research project that involves two phases. Under Phase 1, which was completed in June 2000, heat generation and the flammability of "bedclothes" (e.g. mattress pads and sheets) was reviewed to determine the potential amount of heat that could be generated if these materials were ignited by a small open flame. Under Phase 2, which is currently underway, CPSC staff intend to determine"...the ability of small-scale mattresses to predict burning behavior of twin size and larger bedding systems. Phase 2 will also provide an analytical basis fo r estimating the performance characteristics needed to address and reduce the hazard."
During Phase 2, CPSC staff will also analyze data provided by the National Fire Incident Reporting System to better understand basic issues such as: 1) the typical location of people when mattressfires occur; 2) whether it is common for people involved in such fires to have "intimate contact" with the blaze; 3) the size of the room where the fire originated and 4) the flammability of any surrounding objects. Using these data, NIST will determine what reduction in fire intensity is needed to significantly reduce fatalities.
While Phase 2 is underway, the feasibility of developing a small-scale screening test is being reviewed as a possible replacement for full-scale or burner tests. According to Commission staff, the primary benefit of such a test is that it could be used to ensure compliance while providing manufacturers with the ability to test their products in-house rather than contracting with a test lab. To offer maximum utility, CPSC staff recommends that a bench-scale test use an ignition source representative of a small-flame ignition and that mattresses are tested in a realistic state.
Lastly, the CPSC briefing packet contains data indicating it may not be feasible to establish a standard that requires that victims who are in direct contact with a mattress fire be saved. Instead, the briefing package calls for a standard that would reduce deaths and/or injuries that occur to those who are either outside the room where the fire originated or are otherwise not in direct contact with a burning mattress. This differs from the approach that the Commission has taken with furniture flammability standards that, to date, have been based on an attempt to require that upholstered furniture be "self-extinguishing." queen futon mattress
As this article went to press, the CPSC Commissioners were expected to consider the briefing packaging in a public meeting scheduled for September 21 and later vote on whether further action should be taken. If the Commissioners approve further action, staff intends to publish an Advance Notice of Proposed Rulemaking in the Federal Register soliciting public comment on the issue. Based on comments received, the Commission will decide whether to develop a proposed standard. Assuming that such a standard is ultimately drafted, it too will be published in the Federal Register as a Notice of Proposed Rulemaking and public comment will be solicited.
Author's Note: Jessica Franken of Mayberry & Associates was instrumental in researching and preparing this article.
Peter Mayberry is the director of government affairs for INDA, Association of the Non woven Fabrics Industry.