CONSUMER PRODUCTS AND RETAIL E-SSENTIALS

USA: CPSC implements 2020 interim enforcement policy for mattresses and mattress pads

MARCH 2020 – RELEVANT FOR: HARDLINES, SOFTLINES

On 10 March 2020, the USA Consumer Product Safety Commission (CPSC) revised the Interim Enforcement Policy¹ for mattresses and mattress pads that is subject to the CPSC’s flammability standard, 16 CFR part 1632, due to the availability of a new standard reference material cigarettes (SRM 1196a) that is recently released by the National Institute of Standards and Technology (NIST)².

The standard reference material cigarettes (SRM), developed by the NIST, are used as ignition source for performing the flammability test. Due to the shortage of the earlier version of the SRM (i.e, SRM 1196), the CPSC implemented several interim enforcement policies:

• allowing flexibility on the use of commercially available cigarettes; 
• not requiring a repeat test if a cigarette extinguishes before burning its full length;
• permitting the use of opened packages of SRM 1196 cigarettes. 

The revised 2020 Interim Enforcement Policy superseded those previous policies; however, it still allows the mattress manufacturers and importers to test only two mattress surfaces for newly developed mattress prototypes.

Therefore, with the implementation of the new Interim Enforcement Policy, the following previous interim enforcement policies are superseded: 

• the Interim Enforcement Policy for Mattresses Subject to 16 CFR Parts 1632 and 1633, May 15, 2006,³ 
• the Interim Enforcement Policy for Mattress Pads Subject to 16 CFR part 1632, November 1, 2018 ⁴ and,
• updated Interim Enforcement Policy for Mattresses and Mattress Pads Subject to 16 CFR Part 1632, December 21, 2018. ⁵
  
  

Requirement of the flammability standard:
The Standard 16 CFR 1632⁶ requires pre-market full scale prototype testing for each new mattress and mattress pad. 

In addition, prototype testing must be performed when there is a change in materials of an existing prototype design that could influence the cigarette ignition resistance. Six mattresses and mattress pads surfaces must be tested for each prototype. The prototype test consists of exposing each mattress or mattress pad surface to a minimum of 18 lighted cigarettes—nine in the ‘bare’ mattress pad tests and nine in the ‘two-sheet’ tests.

The prototype is accepted if the char length of each individual cigarette location on all six surfaces is not more than 2 inches in any direction from the nearest point of the cigarette.

While evaluating the mattresses and mattress pads for compliance with the Flammability Standard, SRM 1196 and SRM 1196a are considered as appropriate ignition sources. However, when conducting the test, only SRM 1196 or SRM 1196a, not a combination thereof, must be used to evaluate a specimen.

This updated policy will become effective on 8 June 2020 and will remain effective until further notice.

[1] The Revised 2020 Interim Enforcement Policy

[2] NIST’s New Standard Cigarette

[3] The Interim Enforcement Policy for Mattresses Subject to 16 CFR Parts 1632 and 1633, May 15, 2006

[4] The Interim Enforcement Policy for Mattress Pads Subject to 16 CFR part 1632, November 1, 2018

[5] Updated Interim Enforcement Policy for Mattresses and Mattress Pads Subject to 16 CFR Part 1632, December 21, 2018

[6] Flammability Standard 16 CFR 1632

[7] E-ssentials on updated interim enforcement policy for mattresses and mattress pads; January 2019