January 13, 2005
Part II
Consumer Product Safety Commission 16 CFR Parts 1633 and 1634
Standard for the Flammability (Open Flame) of Mattress and Mattress/ Foundation Sets; Standard To Address Open Flame Ig nition of Bedclothes;
Propod Rules
2470Federal Register/Vol. 70, No. 9/Thursday, January 13, 2005/Propod Rules
1Commissioner Thomas H. Moore issued a statement, a copy of which is available from the Commission’s Office of the Secretary or from the Commission’s Web site, v.
2Numbers in brackets refer to documents listed at the end of this notice. They are available from the Commission’s Office of the Secretary (e
‘‘Address’’ ction above) or from the Commission’s Web site (v/ library/foia/foia.html).
CONSUMER PRODUCT SAFETY COMMISSION
16 CFR Part 1633
Standard for the Flammability (Open Flame) of Mattress and Mattress/ Foundation Sets; Notice of Propod Rulemaking
AGENCY: Consumer Product Safety Commission.
ACTION: Notice of propod rulemaking.
SUMMARY: The Commission is proposing a flammability standard under the authority of the Flammable Fabrics Act that would address open flame ignition of mattress and mattress and foundation ts (‘‘mattress/ts’’). The Commission currently has a flammability standard that address ignition of mattress by cigarettes. However, that standard does not address mattress fires ignited by open flames. The propod standard ts performance requirements bad on rearch conducted by the National Institute of Standards and Technology (‘‘NIST’’). Mattress/ts that comply with the propod requirements will generate a smaller size fire, thus reducing the possibility of flashover occurring. The improved mattress should result in significant reductions in deaths and injuries associated with mattress fires. Due to the interaction of mattress and bedclothes discusd herein, elwhere in today’s Federal Register the Commission is publishing an advance notice of propod rulemaking to begin rulemaking on bedclothes.
DATES: Written comments in respon to this document must be received by the Commission not later than March 29, 2005. Comments on elements of the propod rule that, if issued in final form would constitute collection of information requirements under the Paperwork Reduction Act, may be filed with the Office of Management and Budget (‘‘OMB’’) and with the Commission. Comments will be received by OMB until March 14, 2005. ADDRESSES: Comments should be filed by email to v. Comments also may be filed by telefacsimile to (301)504–0127 or mailed, preferably in five copies, to the Office of the Secretary, Consumer Product Safety Commission, Washington, DC 20207–0001, or delivered to the Office of the Secretary, Consumer Product Safety Commission, Room 502, 4330 East-West Highway, Bethesda, Maryland; telephone (301) 504–7530. Comments should be captioned ‘‘Mattress NPR.’’
Comments to OMB should be directed
to the Desk Officer for the Consumer
Product Safety Commission, Office of
Information and Regulatory Affairs,
OMB, Washington, DC 20503. The
Commission asks commenters to
provide copies of such comments to the
Commission’s Office of the Secretary,
with a caption or cover letter identifying
the materials as comments submitted to
OMB on the propod collection of
information requirements for the
propod mattress standard.
FOR FURTHER INFORMATION CONTACT:
Margaret Neily, Directorate for
Engineering Sciences, Consumer
Product Safety Commission,
Washington, DC 20207; telephone (301)
504–7530.
SUPPLEMENTARY INFORMATION:csbte
A. Background
On October 11, 2001, the Commission
issued an advance notice of propod
rulemaking (‘‘ANPR’’) concerning the
open flame ignition of mattress/
bedding. 66 FR 51886. The ANPR was
the result of the staff’s evaluation of fire
data over the cour of veral years and
petitions filed by Whitney Davis,
director of the Children’s Coalition for
Fire-Safe Mattress (‘‘CCFSM’’).
Although the Commission has an
existing mattress flammability standard
that address ignition by cigarettes, 16
CFR Part 1632, no current Commission
standard directly address open flame
ignition of mattress. The most
common open flame sources are
lighters, candles and matches. The
Commission is now issuing a notice of
propod rulemaking (‘‘NPR’’)
proposing a flammability standard to
address open flame ignition of
mattress.1
Characteristics of mattress/bedding前鼻音音节有哪些
fires. A burning mattress generally
provides the biggest fuel load in a
typical bedroom fire. Once the mattress
ignites, the fire develops rapidly
creating dangerous flashover conditions.
Flashover is the point at which the
entire contents of a room are ignited
simultaneously by radiant heat, making
conditions in the room untenable and
safe exit from the room impossible. At
flashover, room temperatures typically
exceed 600–800 C (approximately 1100–
1470 F). In the conditions, carbon
monoxide rapidly increas, and oxygen
is rapidly depleted. Mattress fires that
lead to flashover are responsible for
about two-thirds of all mattress
fatalities. This accounts for nearly all of
the fatalities that occur outside the room
where the fire originated and about half
of the fatalities that occur within the
room of origin. A mattress that reduces
the likelihood of reaching flashover
could significantly reduce deaths and
injuries associated with bedroom fires.
[1&2]2
The size of a fire is measured by its
rate of heat relea. A heat relea rate
of approximately 1,000 kilowatts
(‘‘kW’’) leads to flashover in a typical
room. Tests of twin size mattress of
traditional construction (complying
with the existing mattress standard in
16 CFR 1632) without bedclothes have
measured peak heat relea rates that
exceeded 2,000 kW in less than 5
minutes. Tests of traditional king size
mattress measured nearly double that
peak rate of heat relea. [2]
Fire modeling and available test data
show that as a room fire grows, a layer
of accumulating hot gas and smoke
thickens downward from the ceiling.
For fires exceeding 600 kW, this layer
typically descends to less than three feet
from the floor. Heat relea rates
exceeding 500 kW are generally
considered to po a rious threat of
incapacitation and of igniting nearby
items. [2]
The objective of the propod
standard is to limit the size of mattress/
bedding fires to below 1,000 kW for a
period of time by reducing the heat
relea from the bed, specifically the
mattress and foundation, and by
reducing the likelihood that other
objects in the room will become
involved in the fire.
Rearch has shown that the mattress,
foundation and bedclothes operate as a
system in bedroom fires. Often the first
item ignited is bedclothes, which then
ignite the mattress. The gas burners
ud in the propod test method are
designed to reprent burning
bedclothes. Rearch has indicated that
bedclothes themlves can contribute
significantly to fires, even reaching heat
relea rates of up to 800 kW. [2&13]
Becau of the role of bedclothes in
mattress fires, the Commission is
initiating a rulemaking on bedclothes
through an ANPR that is published
elwhere in today’s Federal Register.
The Commission received numerous
comments on the mattress ANPR
concerning the role of bedclothes and
the need for a rule addressing them.
The comments are discusd in
ction J of this document.
2471 Federal Register/Vol. 70, No. 9/Thursday, January 13, 2005/Propod Rules
NIST rearch. The industry’s Sleep Products Safety Council (‘‘SPSC’’), an affiliate of the International Sleep Products Association (‘‘ISPA’’), sponsored a rearch program at the National Institute of Standards and Technology (‘‘NIST’’) to better understand mattress/bedding fires and establish the technological basis for future performance requirements of a standard. NIST has conducted extensive rearch, which has become the basis for California’s open flame mattress standard (Technical Bulletin or ‘‘TB’’603) and for the Commission’s propod standard.
The NIST rearch showed that a full-scale test is the most reliable method for measuring fire performance of mattress/ts becau they contain many materials in a complex construction. Becau the order of materials, method of asmbly, quantity of materials, and quality of construction, among other factors, can affect fire behavior, the complete product may perform differently in a fire than the individual components would. Bad on its rearch, NIST drafted a full-scale test method for mattress that us a pair of gas burners to reprent burning bedclothes as the ignition source. Both the Commission’s propod standard and California’s TB 603, u this test method. [1&2]
Overview of the propod standard. With certain exceptions explained in ction G below, the propod standard requires manufacturers to test specimens of each of their mattress prototypes (designs) before mattress bad on that prototype may be introduced into commerce. If a mattress and foundation are offered for sale as a t, the mattress must be tested with the corresponding foundation. The prototype specimens are tested using a pair of gas burners as the ignition source. The mattress and corresponding foundation, if any, must not exceed a 200 kW peak heat relea rate at any time during the 30 minute test, and the total energy relead must be less than 15 megajoules (‘‘MJ’’) for the first 10 minutes of the test. The propod standard is discusd in greater detail in ction G of this document.
B. Statutory Authority
This proceeding is conducted pursuant to Section 4 of the Flammable Fabrics Act (‘‘FFA’’), which authorizes the Commission to initiate proceedings for a flammability standard when it finds that such a standard is ‘‘needed to protect the public against unreasonable risk of the occurrence of fire leading to death or personal injury, or significant property damage.’’ 15 U.S.C. 1193(a).
Section 4 also ts forth the process
by which the Commission may issue a
flammability standard. As required in
ction 4(g), the Commission has issued
an ANPR. 66 FR 51886. 15 U.S.C.
1193(g). The Commission has reviewed
the comments submitted in respon to
the ANPR and now is issuing a notice
of propod rulemaking (‘‘NPR’’)
containing the text of the propod rule
along with alternatives the Commission
has considered and a preliminary
regulatory analysis. 15 U.S.C. 1193(i).
The Commission will consider
comments provided in respon to the
NPR and decide whether to issue a final
rule along with a final regulatory
analysis. 15 U.S.C. 1193(j). The
Commission cannot issue a final rule
unless it makes certain findings and
includes the in the regulation. The
Commission must find: (1) If an
applicable voluntary standard has been
adopted and implemented, that
compliance with the voluntary standard
is not likely to adequately reduce the
risk of injury, or compliance with the
voluntary standard is not likely to be
substantial; (2) that benefits expected
from the regulation bear a reasonable
relationship to its costs; and (3) that the
regulation impos the least
burdensome alternative that would
adequately reduce the risk of injury. 15
U.S.C. 1193(j)(2). In addition, the
Commission must find that the standard
(1) is needed to adequately protect the
public against the risk of the occurrence
of fire leading to death, injury or
significant property damage, (2) is
reasonable, technologically practicable,
and appropriate, (3) is limited to fabrics,
related materials or products which
prent unreasonable risks, and (4) is
楚国stated in objective terms. 15 U.S.C.
1193(b).
C. The Product
The propod standard applies to
mattress and mattress and foundation鸭肉怎么做
ts (‘‘mattress/ts’’). Mattress is
defined as a resilient material, ud
alone or in combination with other
materials, enclod in a ticking and
intended or promoted for sleeping upon.
This includes adult mattress, youth
mattress, crib mattress (including
portable crib mattress), bunk bed
mattress, futons, flip chairs without a
permanent back or arms, sleeper chairs,
and water beds and air mattress if
they contain upholstery material
between the ticking and the mattress
core. Mattress ud in items of
upholstered furniture such as
convertible sofa bed mattress are also
included. Not included as mattress
are: sleeping bags, mattress pads, or
other items ud on top of the bed, or
upholstered furniture which does not
contain a mattress. However, the
Commission could decide to address
mattress pads or other top of the bed
items in its rulemaking on bedclothes.
Under the propod standard, the
mattress must be tested with its
corresponding foundation if the
mattress and foundation are offered for
sale as a t. A foundation is a ticking
covered structure ud to support a
mattress.
According to ISPA, the top four
producers of mattress and foundations
account for almost 60 percent of total
U.S. production. In 2001, there were 639
establishments producing mattress in
the U.S. [10]
Mattress and foundations are
typically sold as ts. However, more
mattress are sold annually than
foundations; some mattress are sold as
replacements for existing mattress
(without a new foundation) or are for
u in platform beds or other beds that
do not require a foundation. ISPA
estimated that the total number of U.S.
conventional mattress shipments was
21.5 million in 2002, and is estimated
to be 22.1 million in 2003 and 22.8
million in 2004. The estimates do not
include futons, crib mattress, juvenile
mattress, sleep sofa inrts, or hybrid
海淀实验water mattress. The ‘‘non-
conventional’’ sleep surfaces are
estimated to compri about 10 percent
of total annual shipments of all sleep
products. The value of mattress and
foundation shipments in 2002,
according to ISPA, was $3.26 and $1.51
billion respectively. [10]
The expected uful life of mattress
can vary substantially, with more
expensive models generally
experiencing the longest uful lives.
Industry sources recommend
replacement of mattress after 10 to 12
years of u, but do not specifically
estimate the average life expectancy. In
the 2001 mattress ANPR, the
Commission estimated the expected
uful life of a mattress at about 14
years. To estimate the number of
mattress in u for analysis of the
propod rule, the Commission ud
both a 10 year and 14 year average
product life. Using CPSC’s Product
Population Model, the Commission
estimates the number of mattress
currently in u (i.e., in 2004) to be 233
million mattress using a ten-year
average product life, and 302.6 million
mattress using a fourteen-year average
product life. [8&10]
According to industry sources, queen
size mattress are the most commonly
ud. In 2002, queen size mattress
were ud by 34 percent of U.S.
consumers. Twin and twin XL are ud
2472Federal Register /Vol. 70, No. 9/Thursday, January 13, 2005/Propod Rules
3NIST publications can be found at NIST ’s Web
site, (v/bfrlpubs/).by 31.2 percent of U.S. consumers,
followed by full and full XL (21
percent), king and California king (11 percent), and all other sizes (2.6
percent). The average manufacturing price in 2002 was $152 for a mattress and $86 for a foundation. Thus, the average manufacturing price of a
mattress/foundation t was about $238 in 2002. Although there are no readily available data on average retail prices for mattress/foundation ts by size, ISPA reports that ts lling under $500 reprent 40.7 percent of the market. Sets lling for between $500 and $1000 reprent 39.2 percent of the market. [10]
The top four manufacturers of mattress and foundations operate about one-half of the 639 U.S. establishments producing the products. The remainder of the
establishments are operated by smaller firms. According to the Statistics of U.S. Business Census Bureau data for 2001, there were 557 mattress firms operating the 639 establishments. According to the same data source, all but twelve mattress firms had less than 500
employees. If one considers a firm with fewer than 500 employees to be a small business, then 97.8 percent (557–12/557) of all mattress firms are small
business. [9&10] The potential impact of the propod standard on the small business is discusd in ction M of this document.
D. Risk of Injury Annual estimates of national fires and fire loss involving ignition of a mattress or b
edding are bad on data from the U.S. Fire Administration ’s National Fire Incident Reporting System (‘‘NFIRS ’’) and the National Fire Protection Administration ’s (‘‘NFPA ’’) annual survey of fire departments. The most recent national fire loss estimates indicated that mattress and bedding were the first items to ignite in 19,400 residential fires attended by the fire rvice annually during 1995–1999. The fires resulted in 440 deaths, 2,230 injuries and $273.9 million in property loss each year. Of the, the staff considers an estimated 18,500 fires, 440 deaths, 2,160 injuries, and $259.5 million property loss annually to be addressable by the propod standard. Addressable means the incidents were of a type that would be affected by the propod standard solely bad on the characteristics of the fire cau (i.e., a fire that ignited a mattress or that ignited bedclothes which in turn ignited the mattress). For example, an incident that involved burning bedclothes and
occurred in a laundry room would not be considered addressable. [3]
Among the addressable casualties, open flame fires accounted for about 140 deaths (32 percent) and 1,050
injuries (49 percent) annually. Smoking fires accounted for 210 deaths (48 percent) and about 640 injuries (30 percent) annually. Children younger than age 15 accounted for an estimated 120 addres
sable deaths (27 percent) and 500 addressable injuries (23 percent) annually. Adults age 65 and older accounted for an estimated 120
addressable deaths (27 percent) and 250 addressable injuries (12 percent) annually. [3]
E. NIST Rearch Overview. NIST has conducted extensive rearch on mattress/bedding fires for SPSC and the Commission. SPSC sponsored veral phas of rearch at NIST to gain an understanding of the complex fire scenario involving mattress and to develop an effective test method to evaluate a mattress ’s performance when it is expod to an open flame ignition source. The first pha of the rearch program, known as Flammability
Asssment Methodology for Mattress, involved four main objectives: (1)
Evaluating the behavior of various
combinations of bedclothes, (2)
characterizing the heat impact impod on a mattress by bedclothes, (3)
developing burners to simulate burning bedclothes, and (4) testing the burners
on different mattress designs to ensure their consistency. NIST ’s findings,
published in NISTIR 6498, established the basis for an appropriate test method and the next pha of the rearch program. [2]3Pha 2 of the NIST rearch focud on (1) analyzing the hazard by estimating the peak rate of heat relea from a mattress with an improved design, (2) measuring a burning mattress ’s ability to involve nearby items in the room, and (3) asssing (in a limited way) bedclothes and their contribution to mattress fire hazards. This testing ud mattress with improved flammability properties while the flammability properties of
bedclothes remained unchanged. [2] The findings from Pha 2 are detailed in NIST Technical Note 1446, Estimating Reduced Fire Risk Resulting from an Improved Mattress
Flammability Standard.
Bedclothes. During pha 2, NIST
conducted tests on twin and king size
mattress with corresponding size
bedclothes. In some tests, the bedclothes contributed up to 400 kW to the fire.
NIST had previously estimated that a heat relea rate that may cau
flashover for an ordinary sized room is about 1000 kW. Thus, a mattress that contributes more than 500 kW at the same time as bedclothes are
contributing 400 kW could lead to flashover. NIST conducted additional tests concerning bedclothes for CPSC, which are discusd later in this ction. [2]
Other objects in the same room. Part of the NIST study assd the potential of a bed fire to ignite other objects in the same room. Other objects become involved by either direct flame
impingement or by fire generated radiation. Although the location of
objects in a bedroom is highly variable, their potential involvement is significantly influenced by their shape and properties relating to ea of ignition. NIST concluded from this rearch that further reducing the heat relea rate from the bed could reduce the potential for ignition of other objects and therefore reduce their contribution to the overall heat relea rate. [2]
Modeling. NIST ud fire modeling to explore the effect that heat and toxic
gas from bed fires can have throughout a home. Fire modeling is an analytical tool that us mathematical calculations to predict real-world fire
behavior. NIST ud this modeling to corroborate test data exploring the
predicted levels of heat and toxic gas for the room of origin and outside the room of origin. The modeling suggested that untenable fire conditions would occur within the room, with little difference between a small and large room, at 10 minutes and 25 MJ. [2] Gas burners’ correspondence to bedclothes. In addition to the rearch discusd above, NIST conducted parate studies for CPSC. One ries of tests evaluated improved mattress designs and further supported the correlation between full scale mattress tests with the NIST gas burners and actual bedclothes. The study, NISTIR 7006–Flammability Test of Full-Scale Mattress: Gas Burners Versus Burning Bedclothes, found that mattress designs showing good performance when tested with burners also exhibited significantly improved performance when tested with burning bedclothes. [2]
Interaction between mattress and bedclothes. NIST ’s work for CPSC also reinforced obrvations from previous NIST rearch on the interaction between the mattress and bedclothes. NISTIR 7006. Tests on improved
mattress designs with burning bedclothes as the ignition source tend to have two distinct heat relea rate peaks. The first peak is predominantly
2473 Federal Register/Vol. 70, No. 9/Thursday, January 13, 2005/Propod Rules
from the burning bedclothes, while the cond is predominantly from the mattress and foundation. In tests of good performing mattress designs, NIST found the cond peak (i.e., from the mattress/foundation) to be comparable or lower than the first peak (i.e., from the bedclothes) and to occur appreciably later. [2]
Mattress size. In another study conducted by NIST in 2004 for CPSC, NIST found that a twin size mattress made in a design that yields a very low peak heat relea rate (less than 50 kW) tested with gas burners behaves esntially the same as a queen or king size mattress of the same design. Mattress designs that yield a moderate heat relea rate peak (greater than 100 kW, but less than 200 kW) tend to behave the same for the first 30 minutes in twin size and king size. After ignition with the burners, the fire is localized (i.e., its spread is limited) and is not affected by the mattress size. [2]
NIST evaluated the same mattress designs and sizes with burning bedclothes. NIST found the mattr
ess size to have an apparent effect during the tests due to the differences in the size and fuel load of bedclothes. In tests of ‘‘well performing’’ mattress designs with burning bedclothes, the early heat relea rate peak when testing a king size mattress was triple that when testing a twin size mattress. This was driven by the burning bedclothes. Mattress designs that showed a moderate heat relea rate peak when tested with gas burners resulted in more rious fires when tested with burning bedclothes, especially in king size mattress. [2]
F. Existing Open Flame Standards
In the mattress ANPR the staff reviewed 13 existing tests or standards relevant to open flame hazards associated with mattress/bedding. The included Technical Bulletin
(‘‘TB’’) 129, TB 121, and TB 117 from California, the Michigan Roll-up Test, and Boston Fire Department (‘‘BFD’’)
1X–11, as well as standards from ASTM International (formerly the American Society for Testing and Materials) (ASTM E–1474 and ASTM E–1590), Underwriters Laboratories (UL 1895 and UL 2060), the National Fire Protection Association (NFPA 264A and NFPA 267) and the United Kingdom (British Standard (‘‘BS’’) 6807 and BS 5852). 66 FR 51886.
As directed by California Asmbly Bill 603, California’s Bureau of Home Furnishings and Thermal Insulation (‘‘CBHF’’) adopted Technical Bulletin 603 (‘‘TB 603’’), an open flame fire standard for mattress and mattress/box spring ts and futons. TB 603 is
expected to go into effect January 1,
2005 and applies to items manufactured
for sale in California. The California
standard incorporates the same test
methodology as the Commission’s
propod standard. Both are bad on
testing and rearch conducted at NIST.
Both TB 603 and the Commission’s
propod standard require that
mattress not exceed a 200 kW peak
heat relea rate during the 30 minute
test. However, the Commission’s
propod standard requires that
mattress not exceed a total heat
relea of 15 MJ in the first ten minutes
of the test, while TB 603 ts test criteria
of 25 MJ in the first 10 minutes of the
test.
The Commission believes that the
rearch NIST has conducted, discusd
above, establishes the most appropriate
basis for an open flame mattress
standard. Several comments on the
ANPR also expresd this view (e
ction J of this document).
G. The Propod Standard
1. General
The propod standard ts forth
performance requirements that each
mattress/t must meet before being
introduced into commerce. The test
method is a full scale test bad on the
NIST rearch discusd above. The
mattress specimen (a mattress or
mattress and foundation t, usually in
a twin size) is expod to a pair of T
shaped propane burners and allowed to
burn freely for a period of 30 minutes.
The burners were designed to reprent
burning bedclothes. Measurements are
taken of the heat relea rate from the
specimen and energy generated from the
fire. The propod standard establishes
two test criteria, both of which the
mattress/t must meet in order to
comply with the standard: (1) The peak
rate of heat relea for the mattress/
foundation t must not exceed 200 kW
at any time during the 30 minute test;
and (2) The total heat relea must not
exceed 15 MJ for the first 10 minutes of
the test.
2. Scope
The propod standard applies to
mattress and mattress and foundation
combinations sold as ts. Mattress is
defined, as it is in the existing mattress
standard at 16 CFR 1632, as ‘‘a resilient
material or combination of materials
enclod by a ticking (ud alone or in
combination with other products)
intended or promoted for sleeping
upon.’’ The propod standard lists
veral types of mattress that are
included in this definition (e.g., futons,
crib mattress, youth mattress). It
also refers to a glossary of terms where
the items are further defined.
Specifically excluded from the
definition of mattress are mattress pads,
pillows and other top of the mattress
items, upholstered furniture which does
not contain a mattress, and juvenile or
other product pads. Mattress pads and
other top of the bed items may be
addresd in the Commission’s
rulemaking on bedclothes.
Like the Commission’s existing
mattress standard, the propod
standard allows an exemption for one-
of-a-kind mattress and foundations if
they are manufactured to fulfill a
physician’s written prescription or
manufactured in accordance with
comparable medical therapeutic
specifications.
3. Test Method
The propod standard us the full
scale test method developed by NIST in
the cour of its rearch. Bad on the
NIST work, the Commission believes
that a full scale test is necessary becau
of the complexities of mattress
construction. Testing individual
components will not necessarily reveal
the likely fire performance of the
complete mattress.
历史的选择
Under the propod standard, the
specimen (a mattress and corresponding
foundation if they are to be offered for
sale together as a t) is expod to a
pair of T-shaped gas burners. The
specimen is to be no smaller than twin
size, unless the largest size mattress or
t produced of that type is smaller than
twin size, in which ca the largest size
must be tested.
The burners impo a specified local
heat flux simultaneously to the top and
side of the mattress/t for a specified
period of time (70 conds for the top
burner and 50 conds for the side
burner). The burners were designed to
reprent the local heat flux impod on
a mattress by burning bedclothes. The
heat flux and burner duration were
derived from data obtained from
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burning a wide range of bedding items.
As discusd above, NIST test results
using the burners have been shown to
correlate with results obtained with
羽绒棉
bedclothes.
The propod standard allows the test
to be conducted either in an open
calorimeter or test room configuration.
Tests have shown that either
configuration is acceptable. Although
room effects (i.e., the size and
characteristics of the room) can be a
factor in mattress flammability
performance, test data show that room
effects do not become an issue until a
fire reaches about 300 to 400 kW.
