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USA: CPSC implements updated interim enforcement policy for mattresses and mattress pads subject to flammability standard 16 CFR 1632

JANUARY 2019 - Relevant for: Hardlines, Softlines

On 21 December 2018, the USA Consumer Product Safety Commission (CPSC) implemented an updated Interim Enforcement Policy¹ allowing an additional flexibility on use of commercially available cigarettes for testing for mattresses and mattress pads which are subject to 16 CFR 1632 – Standard for the Flammability of Mattresses and Mattress Pads due to extreme 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 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.

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.

On 1 November 2018, the CPSC implemented the Interim Enforcement Policy³ allowing the mattress pad manufacturers to reduce flammability testing from six mattress pad surfaces to two mattress pad surfaces due to critically low inventory of the SRM cigarettes by NIST. Similar Interim Enforcement Policy⁴ was also implemented for mattresses from 1 May 2006.

Recently, NIST issued a Request for Quotation (RFQ) for a contract for a new production of SRM 1196 cigarettes. Therefore, due to the current extreme shortage of SRM cigarettes and the uncertainty about the production start time of new SRM 1196 cigarette, the CPSC permit testing using commercially available cigarettes which are king-size (85 mm ± 2 mm), non-filtered and filled only with natural tobacco. This updated Interim Enforcement Policy supplements the two previous enforcement policies.

This updated policy became effective on 21 December 2018, and will remain effective until further notice.

[1] Updated Interim Enforcement Policy for Mattress Pads; 21 December 2018

[2] Flammability Standard 16 CFR 1632

[3] E-ssentials on Interim Enforcement Policy for Mattress Pads; November 2018

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