CPSC and Its Textile Flammability Regulations

CPSC and Its Textile Flammability Regulations

Jacqueline Campbell

AATCC Fall 2014 Committee Meetings

November 12, 2014

This presentation was prepared by CPSC staff, has not been reviewed

or approved by, and may not reflect the views of, the Commission.

Overview• What is the CPSC?

• Textile Flammability Regulations

• Other Requirements for Textiles

• Recent Activity

• Resources

What Is the CPSC?

U. S. Consumer Product Safety Commission

• Independent, federal agency

• Created in 1972

• 5 Commissioners

• Over 500 staff

• Headquarters in Bethesda,

MD

• Laboratory in Rockville, MD

Organization

What Do We Regulate?

What Do We Not Regulate?• Alcohol, tobacco

products, firearms (ATF)

• Drugs, cosmetics, food

(FDA, USDA)

• Motor vehicles for road

use (NHTSA), aircraft

(FAA), boats (USCG)

• Pesticides (EPA),

medical devices (FDA),

workplace products

(OSHA and others)

Jurisdictional Authority• Consumer Product Safety Act (CPSA)

• Federal Hazardous Substances Act (FHSA)

• Poison Prevention Packaging Act (PPPA)

• Refrigerator Safety Act (RSA)

• Virginia Graeme Baker Pool & Spa Safety Act

(VGBA)

• Children’s Gasoline Burn Prevention Act (CGBPA)

• Flammable Fabrics Act (FFA)

Jurisdictional Authority• Consumer Product Safety Act (CPSA)

o As amended in 2008 by the CPSIA and 2011 by HR 2715

• Federal Hazardous Substances Act (FHSA)

• Poison Prevention Packaging Act (PPPA)

• Refrigerator Safety Act (RSA)

• Virginia Graeme Baker Pool & Spa Safety Act

(VGBA)

• Children’s Gasoline Burn Prevention Act (CGBPA)

• Flammable Fabrics Act (FFA)

Flammable Fabrics Act

Flammable Fabrics Act• Codified at 15 U.S.C. Sections 1191-1204

o https://www.cpsc.gov//PageFiles/107013/ffa.pdf

• Promulgated by Congress in 1953

• Transferred to CPSC in 1973

• Prohibits the introduction or movement in interstate

commerce of any product, fabric, or related

material that fails to conform to an applicable

standard or regulation issued or amended under

the provisions of Section 4 of the Act

Flammable Fabrics Act• 16 C.F.R. part 1610

Clothing Textiles

• 16 C.F.R. part 1611

Vinyl Plastic Film

• 16 C.F.R. parts 1615/1616

Children’s Sleepwear

• 16 C.F.R. parts 1630/1631

Carpets and Rugs

• 16 C.F.R. part 1632

Mattresses and Mattress Pads (smoldering ignition)

• 16 C.F.R. part 1633

Mattress Sets (open-flame ignition)

16 C.F.R. Part 1610: Wearing Apparel• Applies to all adult and children’s wearing

apparel.o Some exceptions and exemptions

• Specifies testing procedures used to determine the relative flammability of textiles used in apparel as one of three classes of flammability.

• Fabrics that meet a specific exemption do not require testing.

§1610.1(c): Exceptions

• Interlining fabrics

• Most hats, gloves, and footwear

• Examples that are not exempt:

o Gloves longer than 14 inches and/or attached to

a garment

o Hats that cover the neck, face, or shoulders

o Footwear that consists in whole or in part of

hosiery or is part of another garment

§1610.1(d): Specific Exemptions

• Plain surface fabrics ≥88.2 g/m2 (2.6 oz/yd2),

regardless of fiber content

• Plain and raised surface fabrics made of:o acrylic,

o modacrylic,

o nylon,

o olefin,

o polyester, wool, or any combination of these fibers,

regardless of weight.

16 C.F.R. Part 1610: Test Summary

• 16 mm (5/8 in) flame impinges on specimen mounted at 45-degree angle for 1 second

• Allowed to burn full length or until stop thread breaks

• Results of several tests are averaged and a Class designation is assigned

16 C.F.R. Part 1610: Test Summary

• Determine fiber and fabric type

• Conduct preliminary test

• Prepare and condition specimens

• Test specimens

• Make preliminary classification

• Refurbish and repeat test

• Make final classification

• Report results

16 C.F.R. Part 1610: Classifications

• Class 1 – plain and raised surface fabrics that have no unusual burning characteristics and are acceptable for use in clothing

• Class 2 – raised surface fabrics only, intermediate flammability- use with caution

• Class 3 – fabrics are dangerously flammable and CANNOTbe used in wearing apparel

Classification Plain Surface Raised Fiber Surface

Class 1 Average burn time > 3.5 s Average burn time > 7.0 s OR Average burn time is 0-7 s with no base burns (SFBB)

Class 2 N/A Average burn time is 4-7 s with base burn (SFBB)

Class 3 Average burn time < 3.5 s Average burn time < 4.0 s with base burn (SFBB)

16 C.F.R. Part 1610: Classifications Code

Description Time Reported

SF uc Surface flash, under stop thread, but does not break thread. NoneSF pw Surface flash, part way; does not break thread. None

SF poiSurface flash, at point of impingement only; equivalent to DNI for plain surface fabrics.

None

_._ secActual burn time (sec) measured and recorded by the timing device.

Yes

_._ SF Time (sec), surface flash only; no damage to the base fabric. Yes

_._SFBBTime (sec), surface flash base burn starting at places other than the point of impingement as a result of surface flash.

Yes

_._SFBBpoiTime (sec), surface flash base burn starting at the point of impingement.

Yes

_._SFBBpoi*

Time (sec), surface flash base burn possibly starting at the point of impingement; the asterisk is accompanied by the following statement if there is a question as to the origin of the base burn: Unable to make absolute determination as to source of base burns.

Yes

Note: A result of SFBBpoi or SFBBpoi* does not qualify as a base burn under the current interpretation of 16 CFR Part 1610.

16 C.F.R. Part 1610:Common Noncomplying Fabrics

• Sheer 100% rayon skirts and scarves

• Sheer 100% silk scarves

• 100% rayon and rayon/nylon chenille

sweaters

• Long animal hair sweaters

• Polyester/cotton and 100% cotton fleece

garments

• 100% cotton terry cloth robes

16 C.F.R. Part 1611: Vinyl Plastic Films

• Covers non-rigid, unsupported, vinyl plastic

filmo transparent, translucent, and opaque material

o plain, embossed, molded or otherwise surface treated

• Shall not burn faster than 1.2 in/sec

• Recent recalls have included Halloween

costume capes and masks

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16 C.F.R. Parts 1615 & 1616:

Children’s Sleepwear

• Any product of wearing apparel intended to be

worn primarily for sleeping or activities related to

sleep in sizes larger than 9 months through size

14.

o Nightgowns, pajamas, robes, and similar or related items, such as loungewear

• Several factors determine if a garment is

sleepwear:

o Suitability for sleeping, likelihood of garment to be used

for sleeping

o Garment and fabric features

o Marketing, merchandising/display, intended use

16 C.F.R. Parts 1615 & 1616: Exceptions

• Diapers and Underwear (exempt)o Must comply with 16 C.F.R. part 1610

o http://www.cpsc.gov/pagefiles/126618/diapers01242012.pdf

• Infant garments (exempt)o Sizes 9 months or younger

o One-piece garment does not exceed 64.8 cm (25.75”) in length

o Two-piece garment has no piece exceeding 40 cm (15.75”) in length

o Must comply with 16 CFR Part 1610

16 C.F.R. Parts 1615 & 1616: Exceptions

Tight-Fitting Sleepwear (exempt)

• Tight-fitting garments (defined by the Standards)

are exempt from testing to the sleepwear

requirements.

• Must:

o Not exceed specified dimensions.

o Comply with 16 C.F.R. part 1610.

o Meet labeling requirements.

16 C.F.R. Parts 1615 & 1616:

Requirements

• Children’s sleepwear (that is not tight-

fitting) must pass the flammability

requirements.

o All fabrics and garments must be flame

resistant and self-extinguish (not continue to

burn) when removed from a small, open-

flame ignition source.

16 C.F.R. Parts 1615 & 1616:

Requirements

• Multiple stages of testing are required,

following prescriptive sampling plans

16 C.F.R. Parts 1615 & 1616: Summary

• Test fabric, seams, and

trim

• Test sample of five

specimens

• Orient vertically

• Test in original state and

after 50 laundering

cycles

16 C.F.R. Parts 1615 & 1616: Summary

• Prepare five 8.9 cm x 25.4 cm

(3.5 inches x10 inches)

specimens of fabric, seams,

and trim.

• Condition specimens before

testing.

• Apply a gas flame of 3.8 cm

(1.5 inches) to the bottom

edge of the specimen for 3

seconds.

• Measure char (burn) after the

flame/afterglow has ceased.

Preparing to apply ignition source to specimen

16 C.F.R. Parts 1615 & 1616:

Requirements

• The average char length of 5 specimens cannot exceed 17.8 cm (7.0 inches).

• No individual specimen can have a char length of 25.4cm (10.0 inches).

o No individual specimen may burn its full length.

• Production testing and recordkeeping requirements are required.

o Tested samples must be retained.

16 C.F.R. Parts 1630 & 1631

(Carpets and Rugs)

• Intended to protect

consumers from surface

ignition of carpets and

rugs

• Must pass specified

flammability testso The char does not extend to within

1 inch of the flattening frame

• Labeling provision under

16 C.F.R. part 1631

30

16 C.F.R. Part 1632:

Smoldering Ignition of Mattresses

• Must pass specified flammability tests

o The char does not extend beyond 2 inches from the

ignition source, a lit cigarette

• Mattresses and mattress pads are included

• Includes component tests for tickings and tape

edges

31

Recent Activity

• Current ANPR to amend or revoke the standard

(2005)

• Updated to specify SRM cigarette designed by NIST

• Compliance stay of enforcement with testing

decreased to two surfaces

• Recent project evaluated effect of reduced

ignition propensity (RIP) cigarettes on soft furnishings

32

Summary of 16 C.F.R. Part 1633:

Open-Flame Ignition of Mattresses

• Covers mattress sets

• Outlines testing, labeling, and recordkeeping

requirements

• Open-flame ignition source (two propane burners)

• Specifies two performance criteria:

o Cannot exceed peak heat release rate (HRR) of 200kW

during a 30 minute test

o May not exceed total heat release (THR) of 15 MJ in first 10

minutes of test

33

Recent Activity• July 2007

• 2008 Technical amendments

• ISO/FDIS 12949o Standard for Measuring the Heat Release Rate of Low Flammability

Mattresses and Mattress Sets

34

Other Requirements for Textiles

Drawstring Requirements forChildren’s Clothing

• CPSC issued guidelines (1996) later adopted by

ASTM in 1997 (ASTM F1816-97)o May 2006 letter to industry

(http://www.cpsc.gov/PageFiles/135448/drawstring.pdf)

• Substantial product hazard (15(j)) in 2012

• Applies to drawstrings on upper outerwear, such as jackets, and sweatshirts• Sizes 2T-12 (or equivalent) with neck or hood drawstrings

• Sizes 2T-16 (or equivalent) with waist or bottom drawstringsthat do not meet specified criteria

• Dresses are not upper outerwear

• Belts are not drawstrings

The Consumer Product Safety Improvement Act of

2008

What’s Required: Adult Clothing• 16 C.F.R. part 1610 (Flammability)

• GCC Required, including products that are exempt

from testing

What’s Required: Children’s Clothing

• 16 C.F.R. part 1610 (Flammability)

• CPC Required, Third Party Testing

• Lead Content

• Lead Surface Coating

• Tracking Labels

• Drawstring Requirements

What’s Required: Children’s Sleepwear

• 16 C.F.R. parts 1615 and 1616 (Flammability)o 16 C.F.R. part 1610 if tight-fitting

• CPC Required, Third Party Testing

• Lead Content

• Lead Surface Coating

• Tracking Labels

• Phthalate Requirements o Sleepwear for children 3 years old or younger

Recent Activity

Recent Activity• Furniture Flammability

o http://www.cpsc.gov/PageFiles/129840/ufmemos.pdf

o http://www.slideshare.net/USCPSC/tag/upholstered-furniture

• Bedclothes ANPR

• 16 C.F.R. part 1632 lab manual update

• Cigarette Ignition Risk (CIR) Reporto http://www.slideshare.net/USCPSC/nfpa-presentation-s-

mehtaapprovedfor-slideshare-23808922

o http://www.cpsc.gov//PageFiles/139713/CIRProjectMemoApproved.pdf

Resources

Resource: Small Business Ombudsman

www.cpsc.gov/SmallBiz

Helpful Links• Recent Staff Presentations

o http://www.slideshare.net/USCPSC

o 2013 Safety Academy FFA Session

o 2014 NFPA Conference

• Loungewear lettero http://www.cpsc.gov//PageFiles/121300/loungewear.pdf

• 1632 Enforcement Policyo http://www.cpsc.gov//PageFiles/117365/InterimMattress.pdf

• NIST SRM 1196o https://www-s.nist.gov/srmors/quickSearch.cfm

FFA Laboratory Manuals

46

• http://www.cpsc.gov/en/Busi

ness--Manufacturing/Testing-

Certification/Testing/

• 1610 lab manual

• 1615/16 lab manual

• 1632 lab manual

• 1633 lab manual at:

https://www.cpsc.gov//PageFiles/1

17388/labmanual.pdf

Resource: Searchable List of Laboratories

http://www.cpsc.gov/labsearch

For Further Information:

Jacqueline Campbell

U.S. Consumer Product Safety Commission

Division of Combustion and Fire Sciences,

Directorate for Engineering Sciences

301-987-2024

[email protected]

www.cpsc.gov