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Possible Changes to Mattress Set Flammability Standard Under Consideration

Friday, April 03, 2015
Sandler, Travis & Rosenberg Trade Report

The Consumer Product Safety Commission is conducting a review of the Standard for the Flammability (Open Flame) of Mattress Sets to determine whether it should be (a) maintained without change, rescinded or modified to minimize any significant impact on a substantial number of small entities and/or (b) changed to reduce regulatory burden or improve its effectiveness.

The CPSC is therefore inviting through June 2 public comments on the following topics.

- whether mattresses that comply with the standard provide adequate safety from fires that may involve a mattress and if there are additional requirements or protections that could reduce the number of deaths and injuries resulting from mattress fires

- whether any aspects of the standard need to be updated to improve effectiveness as a result of technological developments since the standard went into effect

- any requirements that are especially or unnecessarily costly and/or burdensome and how the standard’s requirements might be modified to reduce costs or burdens without reducing fire safety

- any requirements that lead to a disproportionate burden on small entities

- the percent of the time and cost of mattress construction that complying with the standard represents and which requirements have the greatest impact on the cost of production

- whether manufacturers rely on information from suppliers or conduct their own testing

- whether the labeling and recordkeeping requirements are adequate, inadequate or overly burdensome

- any aspect of the standard that is unclear, needlessly complex or duplicative, particularly with the Standard for the Flammability of Mattresses and Mattress Pads

- alternative fire safety standards maintained by other government entities and how they differ from the CPSC’s approach

- any of the technical aspects of the standard that could be expanded or clarified without reducing fire safety

- whether the standard’s requirements are known to firms that manufacture new mattresses or renovate mattresses for sale or import mattresses into the U.S., including small firms and firms that build or import mattresses infrequently or in small lots

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