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Statement to California Bureau of Home Furnishings

A recent NIST report concludes that many deaths can be avoided if a bed fire does not "flashover" beyond the bedroom to other rooms in the residence. The best way to improve fire safety by minimizing the risk of flashover is to base the standard and relevant testing equipment on a scientifically sound approach.

In selecting such equipment, the real world "predictive" capabilities of different devices should not be evaluated based on which apparatus "fails" more products, but instead on which burner can better replicate real world fire scenarios. Unlike the TB-129 burner, scientific research documents the NIST burner's relevance for testing the fire performance of mattresses used in residential settings. In particular, the NIST burner was designed to replicate the impact of burning bedclothes on mattresses and foundations, since this is the ignition source that a residential mattress typically confronts. The SPSC is concerned that a test that arbitrarily uses a TB-129 burner, which was designed to address mattress fires originating in trash cans in a hotel or institutional setting, could unnecessarily reject mattress designs that substantially reduce the likelihood of residential flashovers and may be better suited for the marketplace.

As a result of this research, the NIST burner was designed to focus on several characteristics of a residential bed fire that the TB-129 device does not address. For example, children often ignite that part of a bedclothes comforter that hangs over the side of the bed. The hanging comforter burns quickly up the vertical side surface and then spreads across the top horizontal surface more slowly. Similarly, a pillow's filling material often melts and forms a "pool fire" on the mattress top, presenting a concentrated fire insult to the mattress. To mimic this behavior, the NIST approach uses two burners to apply flames to both the side and top mattress surfaces. The TB-129 burner, however, impinges only the mattress' side surface. As a result, a mattress that has been made flame-resistant only on the product's perimeter might "pass" a TB-129 burner test that presents a flame to the mattress side panels, but might be vulnerable to ignition on the top surface. The top burner on the NIST device, however, simulates this real world situation, and therefore more accurately replicates the true impact of a burning comforter.

Likewise, as a mattress burns, gravity pulls the burning bedclothes into the product. The pivoted NIST burner replicates this action, while the stationary TB-129 device does not, possibly permitting some dangerous mattress designs to pass a TB-129 burner test.

Finally, when the U.S. Consumer Product Safety Commission issues its federal mattress flammability standard, it is more likely to use the NIST burner because science supports its use in residential bed fire scenarios. It would be highly inefficient and costly to the mattress industry and consumers for California to require manufacturers that sell into that state to comply with one standard, only to make them later adjust to a different federal rule that supercedes California's standard. This situation is particularly problematic because the manufacturers that must comply with the Bureau's standard are not limited to companies operating within California, but also to dozens of companies in the western United States and elsewhere that ship into that state, as well as many large national firms that may decide to implement the standard voluntarily for their full product line.

California has the opportunity to take the lead in setting a science-based mattress flammability standard. For the above reasons, the SPSC urges the Bureau to issue a standard that uses the NIST burner to test the fire performance of mattresses and foundations.

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