The Flammable Fabrics Act (FFA) sets flammability standards for certain textile products such as clothing, children’s sleepwear, and carpets. In this guide, we list several product types and categories covered by the FFA – and examples of related flammability standards.
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What is the Flammable Fabrics Act (FFA)?
The Flammable Fabrics Act (FFA) was enacted by the CPSC to regulate the flammability in fabric products such as clothing, upholstered furniture, carpets, and mattresses. Importers and manufacturers can find the FFA-associated standards in 16 CFR Subchapter D.
Here is an overview of the established standards for different products:
a. 16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles
b. 16 CFR Part 1611 – Standard for the Flammability of Vinyl Plastic Film
c. 16 CFR Part 1615 – Standard for the Flammability of Children’s Sleepwear: Sizes 0 through 6x (ff 3-71)
d. 16 CFR Part 1616 – Standard for the Flammability of Children’s Sleepwear: Sizes 7 through 14 (ff 5-74)
e. 16 CFR Part 1630 – Standard for the Surface Flammability of Carpets and Rugs (ff 1-70)
f. 16 CFR Part 1631 – Standard for the Surface Flammability of Small Carpets and Rugs (ff 2-70)
g. 16 CFR Part 1632 – Standard for the Flammability of Mattresses and Mattress Pads (ff 4-72, amended)
h. 16 CFR Part 1633 – Standard for the Flammability (open flame) of Mattress Sets
i. 16 CFR Part 1640 – Standard For The Flammability Of Upholstered Furniture
In the following sections of this article, we cover the product categories mentioned in the above standard:
- Clothing textiles and vinyl plastic film for apparel
- Children’s sleepwear
- Carpets and rugs
- Mattresses and mattress pads
- Upholstered furniture
It is possible that more product categories will be added in the future, as the CPSC keeps studying and investigating the risks caused by flammable fabric materials, and sets up new safety standards accordingly. As a matter of fact, 16 CFR Part 1640 was only added in 2021.
Clothing Textiles and Vinyl Plastic Film for Apparel
16 CFR Part 1610 covers textile products that are intended to be worn as clothing, with the exception of hats, gloves shorter than 14 inches, footwear, and interlining fabrics.
The standard classifies fabrics into three categories:
- Class 1 – Normal flammability
- Class 2 – Intermediate flammability
- Class 3 – Rapid and intense burning
This classification determines the test methods for flammability of clothing and textiles; for example, burn time measurement.
The standard does not apply to Class 1 fabrics, which are deemed to have a low level of risk. Specifically, Class 1 fabrics are defined as the following:
a. Plain surface fabrics with a minimum weight of 2.6 ounces per square yard
b. Any fabric (of any weight and surface) made of acrylic, modacrylic, nylon, olefin, polyester, and/or wool
16 CFR Part 1611 covers garments or products that are made of non-rigid, unsupported vinyl plastic film, for example, disposable diapers. The standard mainly focuses on testing methods and procedures. For example, it states that the burning rate should not exceed 1.2 in./sec, under the prescribed testing conditions.
Flammability Standards
a. 16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles
b. 16 CFR Part 1611 – Standard for the Flammability of Vinyl Plastic Film
Examples
- Sweaters
- Jeans
- T-shirt
- Underwear
- Raincoats
- Disposable diapers
- Socks
Children’s Sleepwear
The Flammable Fabrics Act covers sleepwear that is intended to be worn by children. The flammability requirements for children’s sleepwear are outlined in 16 CFR Part 1615 and 1616 and include:
- Product scope
- Test procedures
- Labeling requirements
- Sampling and acceptance procedures (sampling plan and unit acceptance guide)
Children’s sleepwears’ importer or manufacturers should attach a prominently, conspicuously, and legibly label with the required information such as below:
- Care label
- Size label
- Flammability statement label
Here is an example of a hangtag statement:
“For child’s safety, garment should fit snugly. This garment is not flame resistant. Loose-fitting garment is more likely to catch fire”
Flammability Standards
a. 16 CFR Part 1615 – Standard for the Flammability of Children’s Sleepwear: Sizes 0 Through 6X
b.16 CFR Part 1616 – Standard for the Flammability of Children’s Sleepwear: Sizes 7 Through 14
Examples
- Pajamas
- Robes
- Nightgowns
- Bodysuit Sleepwear
- Wearable blankets
Carpets and Rugs
The FFA also regulates the surface flammability of carpets and rugs, under 16 CFR 1630 and 1631. It applies to all types of carpets and rugs used as floor covering materials regardless of their fabrication (e.g natural or synthetic fibers or films). The standards cover requirements such as:
- Test procedure
- Labeling
- Fire-retardant treatment
- Washing procedure
- Policy on recall of non-compliant
16 CFR 1630 and 1631 provide alternative washing procedures and labeling requirements for fire-retardant treatment carpets or rugs. For example, if a carpet or rug has had a fire-retardant treatment, it should be labeled with the letter “T” on the product.
Flammability Standards
a. 16 CFR Part 1630 – Standard for the Surface Flammability of Carpets and Rugs
b. 16 CFR Part 1631 – Standard for the Surface Flammability of Small Carpets and Rugs
Examples
- Nylon carpets and rugs
- Olefin carpets and rugs
- Acrylic carpets and rugs
- Wool carpets and rugs
Mattresses, Mattress Pads, or Mattress Sets
The FFA establishes the flammability requirement for most types of mattresses, from youth mattresses to adult mattresses. In particular, 16 CFR Part 1632 and 1633 address the ignition source and open flame hazards (e.g lighted cigarettes) of mattresses, and provide guidelines for the following:
- Test procedure
- Ticking procedure
- Tape edge substitution
- Labeling requirement
- Quality assurance requirements
16 CFR Part 1632 and 1633 also set requirements for mattress pads that contain a chemical fire retardant treatment. For example, importers or manufacturers should attach a precautionary instruction label and the letter “T” on the product.
Flammability Standards
a. 16 CFR Part 1632 – Standard for the Flammability of Mattresses and Mattress Pads
b. 16 CFR Part 1633 – Standard for the Flammability (Open Flame) of Mattress Sets
Examples
- Adult mattresses
- Youth mattresses
- Crib mattresses
- Bunk bed mattresses
- Water beds
- Air mattresses
Upholstered Furniture
Upholstered furniture is defined as seating furniture that is intended for indoor use and constructed with an upholstered seat, back, or arm, for example, chairs and cushions. 16 CFR Part 1640 requires that upholstered furniture must comply with the flammability requirements of California Technical Bulletin (TB) 117-2013
It also specifies the following:
- Certification requirements
- Labeling requirements
16 CFR Part 1640 requires that upholstered furniture should include the following statement on a permanent label located on the product, which indicates that the product complies with that standard:
“Complies with U.S. CPSC requirements for upholstered furniture flammability”
Flammability Standards
16 CFR Part 1640 – Standard for the Flammability of Upholstered Furniture
Examples
- Couches
- Cushions
- Chairs
- Ottoman chairs
Does this apply to a cushion for a pet?
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