Mattress Smoldering and Open-Flame Flammability

Part 1632 addresses mattresses and mattress pads; part 1633 addresses mattress sets as defined in that rule. A mattress sold without a foundation is also a mattress set for part 1633 purposes. Some toppers, pads and other sleep-related articles fall outside particular definitions. Classify the actual construction and intended use rather than extending a mattress report to every upholstered sleep accessory.

Part 1632 evaluates resistance to smoldering ignition from a specified cigarette source. Part 1633 uses controlled open-flame exposure and measures heat release from the mattress set. Its criteria include a peak heat-release rate not exceeding 200 kW during the 30-minute test and total heat release not exceeding 15 MJ during the first ten minutes. Passing one test does not establish compliance with the other.

The open-flame rule has prototype testing, pooling and confirmation provisions. A mattress labeled for sale with a foundation is tested with that foundation; one labeled for sale without a foundation is tested alone. Record the qualified construction, components, assembly methods and supported configurations. Size or material substitutions require the regulatory basis specified for subordinate prototypes, not an assumption that all models behave alike.

Part 1633 requires quality assurance to keep production consistent with the qualified or confirmed prototype. Incoming materials, assembly controls, production-lot identity and inspections connect the test to subsequent sales. A replacement fire barrier, foam, thread or seam construction can alter performance. Review changes against the rule’s provisions and document the basis for any continued reliance on previous qualification results.

Maintain the prototype, testing, production and labeling information required by the applicable parts. General-use products can require a GCC; children’s products have applicable CPC and third-party-testing considerations. The mattress label’s foundation statement must match the assessed configuration. Preserve the evidence behind the certificate rather than treat a generic laboratory summary as the entire production-compliance record.

Crib mattresses also have separate requirements under part 1241 and associated durable-product obligations. Adult mattress flammability evidence does not establish compliance with crib dimensions, firmness or other infant-product requirements. Neither federal flammability standard means that a mattress cannot burn. Use this record to distinguish product category, ignition test, prototype family and production evidence before making a statement about the supplied sleep product.