5) What is a mattress manufacturer's responsibility?
Once the Federal Standard is finalized, all mattress and mattress sets manufactured, imported or renovated on or after the effective date of this standard are subject to the requirements of this standard. Manufacturers who make, import, sell or distribute mattresses in the United States must prove that their products meet or exceed the criteria above with documentation and labeling. Manufacturers must obtain prototype, confirmation, and production testing to this criteria for their mattress and mattress set products (with the testing process adhering to a set of specifications provided by CPSC), maintain qualification test records, and affix permanent labels to their mattresses that comply with CPSC requirements for labeling.
6) Do I need to keep records on all the tests I conduct on my mattresses?
No. According to the CPSC, under section 1633.11 (a)(1), only testing conducted in accordance with the test method given in 1633.7, which is limited to prototype, confirmation, and production testing, is required.
7) What does "prototype testing" mean and how many must be tested?
A prototype is a specific design of a mattress set that serves as a model for the production units that will be introduced into the market. Mattress sets that are produced based on the prototype must be identical in materials, components, design, and methods of assembly. The burden of testing falls on the production plant or assembly plant, and three specimens of each prototype must be tested.
8) What is "confirmation testing?"
A confirmation test is a pre-market test engaged by a manufacturer who is relying on a qualified prototype produced by another manufacturer or prototype developer.
9) What is "production testing?"
Production testing is random testing of mattress sets being manufactured for sale as part of a quality assurance program. (See requirements of 1633.3 and 1633.7.)
10) How much more per mattress will it cost to meet the new standard?
The regulatory analysis showed an estimated range of $6.05 to $19.49 in increased costs per mattress, averaging &12.77, regardless of the size of the business. These costs reflect increased materials (i.e., fire barriers, chemical retardants) and labor needed to meet the new standard; they do not include testing costs.
11) What can a small business do to offset the potential costs of compliance?
The federal standard allows two or more establishments (plants within the same firm) or independent firms to "pool" prototypes. Small manufacturers who do not share a common market (and therefore do not compete with each other) can resemble a large producer in their testing and quality control/quality assurance efforts and therefore reduce their costs per mattress set. Also, to reduce the impact of the standard on small businesses, CPSC eliminated the requirement of keeping physical samples.
12) What about exceptions?
One-of-a-kind mattress sets may be exempted from testing under this standard in accordance with 1633.13(c).
13) What will my testing provider need to do to ensure my testing is conducted properly?
Open Flame Flamability testing providers need to comply with an extensive set of specifications including:
a) A calorimetry system calibrated at a minimum of two calibration points (75 kW and 200 kW)
b) A test area in one or both of the possible Test Configurations (A & B)
c) Welded steel bed frame of specific dimensions, height, and design.
d) Ignition source consisting of two T-shaped burners incorporating a stand-off foot, a mechanical pivot point mounting, seperate pilot lights with independently-controlled supplies of propane. The ignition system,
14) What sorts of records are required for manufacturers to generate and keep?
Manufacturers are required to keep five kinds of records:
a) Test results and details (including failures), wether for qualificaion, confirmation, or production, in accordance with 1633.7.
b) Video and/or a minimum of 8 photographs of the testing of each mattress set, in accordance with 1633.7.
c) Prototype records.
d) Pooling confirmation test records.
e) Quality assurance records.
The maintenance rules for those records are:
a) Records must be retained for 3 years.
b) Domestic records must be maintained at the plant or factory where the mattress sets are manufactured or assembled.
c) A copy of all records required of imported mattress sets must be maintained at a U.S. location, which must be identified on the mattress set label.
For dull record keeping details, consult the Standard release.
15) What else do I need to know?
The specifications for complying with the new federal open flame mattress flamability standard have been thoroughly reviewed by Stork Twin City Testing bedding testing experts. Stork TCT is one of a few laboratories in the country conducting California TB603 in addition to full-scale bedding testin programs for comfort, durability, and safety. In January 2006, work was completed on an expansion of the open flame testing laboratory to manage the increasing demand for testing to the California and federal standards.
The experts at Stork can work with you to plan, understand, and schedule your 16 CFR Part 1633 testing programs or other bedding evaluation programs efficiently, accurately, and cost-effectively. We welcome your questions and comments. Please contact michiel.graswinckel@stork.com for more information.
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