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On 1 November 2018, the USA Consumer Product Safety Commission (CPSC) has implemented an Interim Enforcement Policy1 allowing reduced testing for mattress pads which are subject to 16 CFR 1632 – Standard for the Flammability of Mattresses and Mattress Pads due to a shortage of standard reference material (SRM) cigarettes.
The Standard 16 CFR 16322 requires pre-market prototype testing for each new mattresses and mattress pads. The prototype testing must also be performed when there is a change in materials of an existing prototype design that could influence the cigarette ignition resistance. Six mattress and mattress pad surfaces must be tested for each prototype. The prototype test consists of exposing each mattress pad surface to a minimum of 18 lighted cigarettes—nine in the ‘bare’ mattress pad tests and nine in the ‘two-sheet’ tests.
To perform the flammability test, the standard reference material (SRM 1196) cigarette developed by the National Institute of Standards and Technology (NIST) are used as ignition source. CPSC recently learned that the inventory of the SRM cigarettes is critically low, and NIST does not currently have a source to produce it and will be looking for a new producer. Due to this shortage of SRM cigarettes, CPSC, by implementing this Interim Enforcement Policy, allows mattress pad manufacturers to reduce flammability testing from six mattress pad surfaces to two mattress pad surfaces.
This reduced testing requirement of mattress pad is also in line with the earlier Interim Enforcement Policy which has been implemented only for Mattresses since 1 May 2006.3
Additionally, this policy also allows to use SRM cigarettes from previously opened package (or leftovers from prior testing).
This policy became effective on 1 November 2018, and will remain effective until further notice.