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Industry Guide to Futon Flammability Requirements in Canada

2005
ISBN: 0-662-68845-7
Cat. No.: H46-2/05-396

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Table of Contents

• Preface
• Legislation
• Test Method
• Futon Flammability: The Impact of Futon Design, Materials and Construction Methods
• Educating Consumers on Fire Safety
• Canadian Exports to the United States
• Roles and Responsibilities
• Appendix A - List of Health Canada Product Safety Offices
• Appendix B - Canadian Mattress Testing Laboratories
• Appendix C - Canadian Information Resources
• Appendix D - United States Information Resources
• Appendix E - Sleep Products Safety Council (SPSC)

Preface

The intent of this document is to:

• provide information about the legislation in Canada that applies to hazardous or potentially hazardous products
• explain how this legislation applies to futon mattresses
• describe the test methods for futon mattresses
• discuss the influences of design, materials and construction methods on the flammability characteristics of futon mattresses
• discuss the importance of consumer education on fire safety
• outline the roles and responsibilities of industry and government

Legislation

Consumer Product Safety (CPS) of Health Canada's Product Safety Programme (PSP) works closely with partners and stakeholders to protect consumers and children from product-related hazards and to promote the safe use of products. CPS gets its regulatory authority from the Hazardous Products Act (HPA), which covers the advertising, sale, and importation of a variety of hazardous or potentially hazardous products. The onus is on industry to comply with the legislation. Enforcement actions taken by Product Safety Officers on noncompliant products range from negotiation with industry for the voluntary removal of these products from the market to seizure and/or prosecution under the HPA. Any person or company that advertises, sells or imports noncompliant products that result in property damage, injury or death may also face civil penalties.

Mattresses are defined in Item 32 of Part II of Schedule I to the HPA as products intended, promoted or normally used for the purpose of being slept on that contain resilient material enclosed within a ticking, whether or not those products are commonly referred to as mattresses, other than

1. mattress pads;
2. sleeping bags;
3. box springs and other mattress foundations and supports;
4. parts of upholstered furniture that may be used for the purpose of being slept on that are not separate mattresses;
5. infant product pads and crib mattresses; and
6. one-of-a-kind prescription mattresses.

Futon mattresses fall under the jurisdiction of the HPA and must meet the minimum flammability requirements set out in the Hazardous Products (Mattresses) Regulations prior to being advertised, sold, or imported into Canada:

Futon mattresses advertised, sold or imported into Canada must also meet federal labelling requirements set out in the Textile Labelling Act and the Textile Labelling and Advertising Regulations administered and enforced by Industry Canada, as well as any applicable provincial requirements for labelling.

For more information on legislative requirements for futon mattresses, refer to Appendix C - Canadian Information Resources, on page 25 of this document.

Test Method

In accordance with CGSB CAN 2-4.2, Method 27.7-M77:
Combustion Resistance of Mattresses - Cigarette Test, 10 specimens, each measuring 300 mm (height) x 300 mm (width) x 50 mm (depth), are cut from the surface of the product sample. Each specimen is mounted in an uncovered flame-resistant box measuring approximately 300 mm (height) x 300 mm (width) x 300 mm (depth) at a tension which is approximately that of the product sample at the point of sale. A lit cigarette is placed in a central position on the specimen, along the length of a crevice, tufting indentation or seam where possible. The test ends when charring or melting of the surface exceeds a distance of 50 mm in any horizontal direction from the lit cigarette, or 10 minutes after the cigarette has extinguished. The specimen fails if charring or melting of the surface extends beyond 50 mm in any horizontal direction from the lit cigarette, or if there is any continuing combustion anywhere in the specimen 10 minutes after the cigarette has extinguished.

A product sample complies with the flammability requirements if 0-1 specimens fail the test.

A product sample does not comply with the flammability requirements if 2-10 specimens fail the test.

For detailed information on this test, refer to the "Test Method for Evaluating Mattresses for Combustion Resistance by the Cigarette Smouldering Test - Method F-06" listed in Appendix C - Canadian Information Resources, on page 25 of this document

Futon Flammability: The Impact of Futon Design, Materials and Construction Methods

The first futon mattresses to emerge in the Canadian market in the late 1960s and early 1970s were the traditional simple Japanese mattresses consisting of 100% cotton batting enclosed by a 100% cotton ticking, valued for their simplicity, hypoaller-genic and therapeutic properties.

No futon is fireproof, but there are ways to make them resistant to a smouldering cigarette. Futons can also be made to resist intense burning after being exposed to an open flame.

Treatment with Fire Retardants

Fabrics can be made more smoulder-resistant by applying a fire retardant in the resin backcoating applied to the finished fabric, or other topical means. Cotton battings, the traditional filling of choice in futons, are quite smoulder-resistant and flame-resistant if an adequate level of boric acid (minimum 10-12% by weight) is distributed evenly throughout the batt. Or look for cotton batting that is certified by the U.S. National Cotton Batting Institute (NCBI) to be smoulder-resistant and flame-resistant.

Use of Smoulder-Resistant Fabrics and Filling Materials

Synthetic fabrics, fibre battings and threads, as well as polyurethane foams are generally smoulder-resistant. However, they will melt and burn easily with an open flame unless a flame-retardant is added. A variety of flame-resistant filling materials are also available, such as cellular foams (e.g., melamine-loaded polyurethane, combustion modified high resiliency, neoprene, etc.) and new fibre battings specifically formulated to resist flaming and melting.

Use of Barrier Materials

A variety of barrier materials, used below the outer fabric, offer varying levels of protection from open-flame ignition sources without sacrificing aesthetic and physical qualities, such as:

• fabrics with specific flame-resistant materials built into the fibre or with inherently flame-resistant fibres (e.g., fibreglass, neoprene, vinyl, other proprietary flame-resistant additives, etc.);
• fabrics with an applied flame-retardant backcoating; and
• cushioning materials available in thin configurations, such as boric-acid treated cotton pads.

Certain combinations of these may also work to reduce costs and increase flame resistance.

It has been noted that a cotton or cotton/polyester blend fabric over a flame-resistant barrier or interliner is not very likely to lead to a major flashover situation.

The choice and thickness of barrier should take into consideration information such as the size and design of the futon mattress (innerspring [Figure 1], foam core [Figure 2], cotton batting core [Figure 3], pillowtop, etc.), the type and level of flame resistance of the outer fabric, and the amount and order of layering of the filling materials.

Structural Integrity

Even if the best fire barrier material is used, fire can penetrate the barrier at seams made with non-flame retardant threads or fasteners. Use of flame-retardant tufting threads is also important in preventing flame penetration.

Thicker and heavier futon mattresses often have more stitching and tufting to maintain their shape and appearance. Stitching and tufting can dislocate or disturb the underlying material, and can push deeper layers closer to the surface. If these deeper layers are not smoulder-resistant, they will likely contribute to the product failing to meet the flammability requirements.

Consideration should also be given to the integrity of the crevice of a futon mattress formed when it is placed in the seat/ back configuration. Research has shown that crevice areas of furniture are one of the most probable areas where a sustained fire may occur, especially a smouldering fire caused by a lit cigarette, which may easily roll into a crevice and go unnoticed.

For further information, refer to the Futon Association International, the Sleep Products Safety Council, and the National Cotton Batting Institute listed in Appendix D - United States Information Resources, on page 26 of this document.

Educating Consumers on Fire Safety

The Sleep Products Safety Council (SPSC) is a non-profit service organization established by the International Sleep Products Association (ISPA). The SPSC's mission is to provide consumer safety information, support research and promote activities aimed at reducing hazards associated with mattresses and other sleep products. The SPSC, together with Health Canada and Fire Prevention Canada, have developed fire-safety messages for mattress consumers in Canada. These messages are available on SPSC mattress hangtags (see Appendix E on page 27 of this document).

• Keep matches and lighters in a secured drawer or cabinet, out of reach of children.
• Check under beds and in closets for burnt matches, evidence your child may be playing with fire.
• Keep lit candles away from bedding, curtains, sleepwear and anything else that can ignite easily; do not leave lit candles unattended; extinguish all candles when leaving a room or before going to sleep.
• Do not smoke in bed.
• Keep bedding, clothes, curtains and other flammable items at least 1 metre away from portable heaters.
• Do not store old mattresses in the home or garage; they are a fire hazard.
• Make sure everyone in your family knows at least two escape routes from their bedrooms, and practice these often.
• Install and maintain at least one working smoke alarm on each level of your home, preferably outside of each bedroom. Change the battery once a year.
• Teach children to "stop, drop and roll" if their clothing catches fire.

If you are not currently using the SPSC hangtag on your futons, you are encouraged to do so. Use of the hangtag will provide consumers with important safety information, and will identify your company as a safety-conscious futon producer concerned about improving fire safety and reducing residential fires. To purchase SPSC hangtags, or to find out about other SPSC activities and resources for the sleep products industry, refer to the Sleep Products Safety Council listed in Appendix D - United States Information Resources, on page 26 of this document.

Canadian Exports to the United States

Futon mattresses manufactured in Canada and shipped to the United States are subject to the federal mattress flammability standard for resistance to ignition by a lit cigarette issued and enforced by the United States Consumer Product Safety Commission (CPSC). At the time of this publication, the CPSC was also in the process of developing a new federal standard to address the resistance of mattresses to ignition by an open flame. Futon mattresses shipped specifically to California must also meet the requirements of Technical Bulletin 603 for resistance to ignition by an open flame issued and enforced by the California Bureau of Home Furnishings and Thermal Insulation (BHFTI). For more information, refer to Appendix D - United States Information Resources, on page 26 of this document.

Although the current federal test criteria are similar in Canada and the United States, the test method mandated in the United States is more complex. The United States standards also specify requirements for labelling and record keeping.

Canadian companies exporting to the United States are advised to ensure compliance with the United States standards and have their goods tested prior to export.

For a partial list of laboratories which provide mattress testing services, refer to Appendix B - Canadian Mattress Testing Laboratories, on page 23 of this document.

Roles and Responsibilities

The roles and responsibilities of government and industry in ensuring the safety of futon mattresses include, but are not limited to, the following:

1. Health Canada
   
   
   • develop and enforce the legislation
     
     
   • educate and inform industry and consumers
     
     
   • monitor the marketplace, including following up on industry and consumer complaints, recalls by industry and the United States CPSC, and referrals from other agencies or governments
     
     
   • obtain samples for testing to determine compliance with the HPA flammability requirements for mattresses
     
     
   For products that do not comply with the HPA flammability requirements for mattresses:
   
   
   • take enforcement actions depending on the risk of the products to the consumer, including:
     
     
     • providing a verbal or written warning for corrective action to be taken by industry
       
       
     • negotiating with industry to voluntarily discontinue the sale of these products through removal, disposal or recall at industry's expense
       
       
     • seizing noncompliant products and/or prosecuting industry under the HPA
       
       
   • inform the United States CPSC if the noncompliant product has been shipped to the United States
     
     
   • issue a public warning or advisory (press release and/or information bulletin) if the risk to the public is determined to be serious
     
     
2. Futon Manufacturers
   
   
   • ensure that your products meet the HPA flammability requirements for mattresses
     
     
   • test your products regularly to ensure ongoing compliance with the HPA flammability requirements for mattresses
     
     
   • co-operate in any removal, disposal or recall from the marketplace of your products found to be noncompliant
     
     
3. Futon Importers
   
   
   • ensure that the products you are importing meet the HPA flammability requirements for mattresses
     
     
   • before importing the products, get proof of compliance with the HPA flammability requirements for mattresses in the form of test results from a reputable laboratory or a signed written certificate of compliance (note: a product label indicating that a product complies with the HPA flammability requirements for mattresses is not sufficient); if this information is not available, do not import the products, or have the products tested yourself
     
     
   • co-operate in any removal, disposal or recall from the marketplace of your products found to be noncompliant
     
     
4. Retailers/Buyers
   
   
   • only carry products that meet the HPA flammability requirements for mattresses
     
     
   • before purchasing the products, get proof of compliance with the HPA flammability requirements for mattresses in the form of test results from a reputable laboratory or a signed written certificate of compliance ( note:a product label indicating that the product complies with the HPA flammability requirements is not sufficient ); if this information is not available, do not purchase the products, or have the products tested yourself
     
     
   • if products are being purchased outside of Canada, ensure that they meet the HPA flammability requirements for mattresses prior to importation
     
     
   • when notified of a removal, disposal or recall of a non-compliant product, immediately remove the affected product from sale and follow any other corrective actions

Appendix A - List of Health Canada Product Safety Offices

Appendix B - Canadian Mattress Testing Laboratories

NOTICE: This listing of laboratories implies no certification or endorsement by Health Canada, nor is it necessarily a complete listing of all laboratories in Canada that provide mattress testing services.

Appendix C - Canadian Information Resources

NOTICE: For further information on futon mattresses, contact a Health Canada Product Safety Office (refer to Appendix A - List of Health Canada Product Safety Offices, on page 20 of this document) or visit the following:

• Product Safety Programme (PSP)
  www.hc-sc.gc.ca/psp
• Hazardous Products Act and Hazardous Products (Mattresses) Regulations
  http://laws.justice.gc.ca/en/H-3/index.html
• Health Canada, 2000. Test Method for Evaluating Mattresses for Combustion Resistance by the Cigarette Smouldering Test - Method F-06.
  http://www.hc-sc.gc.ca/hecs-sesc/cps/methods.htm#flam
• Industry Canada, 2000. Guide to the Textile Labelling Act and the Textile Labelling and Advertising Regulations
  http://competition.ic.gc.ca/epic/internet/incb-bc.nsf/en/ cp01144e.html

Appendix D - United States Information Resources

• Consumer Product Safety Commission (CPSC)
  http://www.cpsc.gov
• CPSC 16 CFR Part 1632 - Standard for the Flammability of Mattresses and Mattress Pads (FF 4-72, amended)
  http://www.access.gpo.gov/nara/cfr/waisidx_04/16cfr1632_ 04.html
• California Bureau of Home Furnishings and Thermal Insulation (BHFTI)
  http://www.bhfti.ca.gov
• Technical Bulletin 603
  http://www.bhfti.ca.gov/ab603.htm
• Sleep Products Safety Council (SPSC)
  http://www.safesleep.org
• Futon Association International (FAI)
  http://www.futon.org
• National Cotton Batting Institute (NCBI)
  http://www.natbat.com

Appendix E - Sleep Products Safety Council (SPSC) Safety Hangtag for Canada