Working your way toward FR compliance

One thing that complying with California’s open–flame bed set standard has taught the bedding industry is just how long—and how many steps—it takes to design, build and test compliant mattresses and foundations.

Simply put: It is not a quick process.

Manufacturers working to comply with the new federal open–flame standard, which takes effect July 1, 2007, should already have started the process. If you haven’t, begin now, after reading this article.

At recent Flammability SHOPtalks sponsored by the International Sleep Products Association and Sleep Products Safety Council, bedding industry veteran Bob Sabalaskey walked attendees step by step through a typical compliance process, from choosing someone in the company to be the “point person” for the project to preparing for production and maintaining compliance.

Sabalaskey is vice president of manufacturing and product engineering for Lilly Management Group in St. Charles, Ill. Among its other consulting services, Lilly Management Group recently launched FR–PRO Prototyping, a proprietary program that offers mattress manufacturers pre–packaged solutions for meeting the new open–flame standard. The program involves multiple lines of major FR solutions from primary suppliers that are incorporated into mattress prototypes, burn tested, documented and qualified to comply with the federal standard.

Sabalaskey told SHOPtalk audiences that, in general, complying with the new federal standard (known officially as 16 CFR Part 1633) should start with choosing a person in the company to be “responsible for coordinating all aspects of the flammability program within your company.” And the first thing that person should do—after making sure she has reviewed and understands all the facets of the open–flame standard—is to come up with a timeline for implementing your company’s program, taking into account the time needed to switch out lines and introduce products to retailers.

Other steps include:

  • Analyzing your product line
  • Reviewing FR systems
  • Testing FR systems
  • Qualifying prototypes
  • Preparing production
  • Maintaining compliance

Following is an overview of the process that Sabalaskey suggests.

Analyzing your product line

This requires a comprehensive inventory of the types of mattresses you currently offer. For instance, do you have single–sided or double–sided mattresses or both? Do you make firm, plush, pillow–top, euro–top or other constructions? What are your cores made of? What are your panels and borders made of? Do the same inventory of your foundations.

Another part of this step is assessing your current manufacturing processes, equipment and capacities, and the quality control procedures in each department. Look also at who your current components suppliers are.

One area many manufacturers forget to include during the initial part of this process is the sales and marketing department, Sabalaskey says. Throughout the process, it’s important to consider what their views and plans are for the future.

Reviewing FR systems

Consider your requirements for look, feel and cost when you start reviewing flame–retardant and flame–resistant components, Sabalaskey says. Will you need one set of solutions for your promotional lines but another for your luxury bed sets?

You’ll need also to do a careful assessment of suppliers. Do the suppliers you are considering have the capacity to meet your production needs? What kind of quality assurance programs do they have in place? How do they certify that the product you order is the same product you will receive time and time again?

The new regulations require “a different mindset now” regarding suppliers, Sabalaskey says. “If you don’t have the right materials, you don’t ship your product.”

Once you’ve considered those issues, you’ll need to start sampling systems. Sabalaskey recommends, among other things, performing a cost analysis, evaluating how they’ll work with your manufacturing processes, reviewing them with the sales and marketing team and, finally, selecting systems to test.

Testing FR systems

Up until this point, you won’t have spent much money on the compliance process, Sabalaskey says. But when you start testing systems, the money adds up. Industry estimates range from about $450 to $700 to burn test a bed set.

Sabalaskey suggests producing two twin–size samples for each possible FR system you’re considering to compare performance. Pick a testing lab and plan to attend the burn tests.

“Please attend the burn,” he says. “You can’t pick up things on a video that you can see in person.” Then you’ll need to carefully document the performance of the various systems you’ve tested (labs will help with this), rate them and, in consultation with your manufacturing teams, purchasing department, and sales and marketing department, pick the FR solution or solutions you plan to use.

Qualifying prototypes

The federal standard allows for the testing of prototypes and prototype pooling. The U.S. Consumer Product Safety Commission defines three types of prototypes. At the top of the hierarchy is the qualified prototype, which is a representative sample of a mattress or bed set in your line that has passed the dual–burner open–flame test three consecutive times. The other types of prototypes are confirmed prototypes, which are used in pooling arrangements and require being burn tested only once, and subordinate, which can differ from qualified prototypes only in terms of size, ticking and other non–FR components. Subordinates don’t require separate burn testing. Both confirmed and subordinates must be based on a qualified prototype.

To determine what your qualified prototypes will be, you’ll need to go back to your original inventory of the various types of constructions, materials and FR systems you’ll be using. In general, when selecting qualified prototypes to test you’ll want to choose the thickest, most complex constructions, Sabalaskey says.

“Smart prototyping is the single most important step in controlling costs during the compliance process,” Sabalaskey says. Creating and testing too many prototypes wastes time and money. But creating and testing too few increases a manufacturer’s risk of manufacturing beds that don’t comply with the regulations, he says.

Before testing, you’ll need to carefully document all the components used in each qualifying prototype, as well as the method of assembly. This is part of the recordkeeping requirements of the federal standard. And you’ll want to carefully inspect (“Inspect, inspect, inspect,” Sabalaskey cautions) the final prototypes before sending them to the testing lab.

Once your qualified prototypes have passed burn tests, you’re ready to move on to the rest of your line.

Preparing production

At this point, you’ll begin creating confirmed and subordinate prototypes, which are based on your qualified prototypes and working on changes that you likely will need to make to your manufacturing processes to consistently produce compliant beds.

Also important are recordkeeping and quality assurance programs, both required by the federal standard. Among other things, manufacturers must maintain detailed records about burn tests (including records of failures) and about the manufacturing methods and components used in qualified, confirmed and subordinate prototypes.

“There’s a lot of recordkeeping involved in this, and you need to start now to get your systems in place,” Sabalaskey reminds manufacturers.

Under the federal rules, mattress manufacturers also must have in place minimum quality assurance programs that include procedures to ensure that all products manufactured for sale are based on a qualified prototype, inspection of incoming raw materials, maintenance of production lots and inspection of final products. Companies also must maintain a written copy of their QA procedures.

Maintaining compliance

Sabalaskey recommends creating a comprehensive FR training program for all plant supervisors and workers, with an emphasis on the importance of quality assurance and inspection during the manufacturing process. Random testing, regular mattress teardowns and third–party audits also are useful in ensuring that your plant continues to produce compliant beds.

Voluntary testing protocol for Canada

Underwriters Laboratories Canada has developed a mattress flammability testing standard that would be for all mattress uses—residential, commercial and institutional.

“The standard is intended to provide an increased and consistent level of public safety for consumers and users,” according to the ULC.

At present, it is a voluntary standard that the Canadian government could later make mandatory, if it chooses.

The open–flame testing standard will be known as CAN/ULC–S137 and is designed to be a standard method of testing for open–flame fire growth in mattresses. It’s comparable to the testing methods required by the federal open–flame standard in the United States (16 CFR Part 1633) and California’s Technical Bulletin 603. Like those, the Canadian testing protocol is a test of finished mattresses and bed sets, not individual components.

The Sleep Products Safety Council and International Sleep Products Association are represented on the ULC’s working group for the project and are pressing for alignment between U.S. and Canadian standards.

For more information, contact ULC’s Jennifer Jimenez at jennifer.jimenez@ca.ul.com or 613–755– 2729 or Ryan Trainer, ISPA executive vice president and general counsel, at rtrainer@sleepproducts.org or 703–683–8371, Ext. 1118.

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