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Table 1. Incidence of FFACTS Cases For Selected Item Types
(First-to-Ignite), By Sex of Victim

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primarily male; and both sexes were involved almost equally in upholstered furniture cases. Table 2 shows the number of cases in FFACTS for which matches, cigarettes, cigars and pipes, kitchen ranges, and open fires were the ignition sources. Matches and cigarettes involved both sexes, kitchen ranges involved more females, and open fires involved more males. Neither the item type/sex classification of incidents such as in table 1 nor the ignition source/sex classification of table 2 is sufficient for our hazard definitions.

Table 2.

Incidence of FFACTS Cases For Selected Ignition
Sources By Sex of Victim, Where Item First to Ignite Is Known

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The categories of table 3 further define hazards by a cross tabulation of numbers of cases by item type and ignition source. Sex is used to modify the item type classification only where the involvement of that item is primarily for one sex. Age is introduced in the first two item type classes, to more specifically define particular problem areas. For our purposes today, the data in table 3 are adequate to provide examples of hazards. We will return to these data to discuss seven different hazards and the potential effectiveness of item type flammability standards, ignition source safety improvement and public education in addressing them. First, let us define generalized criteria for assessing the potential effectiveness of each remedial approach, in terms of a series of questions. These questions fall into three categories - state-of-the-art, public acceptance and protection of some at the expense of others -- and these questions will be addressed relative to each of our three approaches in turn.

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First, for fabric item flammability standards:

Does state-of-the-art technology permit the development of flame retardant material, and does potential industry capacity exist for production of sufficient material?

Will the properties and the cost of the new product meet public acceptance? (If not, will public rejection in favor of homemade items or substitutes counter the intent of the standard?)

Does the standard protect one group at the expense of others?

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@Includes cigars and pipes.

bThis item type primarily involved a specific age group or sex. Only the indicated data have been included to more specifically identify the particular hazard.

Improvements in ignition source safety may be made in production quality control to reduce the incidence of defective products, and in product re-design to reduce the hazard inherent in its normal use (or misuse). In terms of the three categories above, we ask relative to ignition source safety improvement:

Does state-of-the-art technology permit enough improvement to be made to significantly reduce the hazard, and will the changes impair the primary function of the product or inadvertently introduce new safety hazards?

ance?

Can the changes be made within the constraints of cost and public accept

Will the changes protect one group at the expense of others?

Public education does not require increased industrial capacity or tradeoffs between safety and product performance. However, we ask:

Is the state-of-the-art in educational programs adequate both to reach the intended audiences and to significantly influence behavior?

Is education cost effective?

Returning to table 3, let us examine in turn the hazards represented by adult female sleepwear, male shirts and pants, female dresses, upholstered furniture, mattresses, kitchen ranges, and cigarettes. They were chosen to illustrate the potential effectiveness of the three approaches to hazard reduction, rather than necessarily to reflect the greatest hazards.

First, consider hazards potentially addressable by item type standards. The hazards related to upholstered furniture and mattresses are suggested for this category, for the following reasons:

1.

2.

State-of-the-art technology permits the development of the required materials.

Although a single ignition source category, cigarettes, cigars and pipes, is involved in 75 percent of upholstered furniture cases and 59 percent of mattress ignitions, it is not likely that improved safety in these ignition sources can easily be obtained.

3.

Looking at the cigarette column of table 3 we see that 94 plus 38,
or 132 cigarette ignitions, 55 percent of the total of 240 cases,
involved the two item types, upholstered furniture and mattresses.
This indicates that these two item type standards would also address
55 percent of a major ignition source hazard.

Second, let us consider hazards addressable by improved safety in ignition sources. There are two categories of item types in table 3 which present hazards not directly addressable by item type standards. Adult female sleepwear is the first item type. Non-flammable material is not at present available in sufficient quantity to produce flame resistant sleepwear for all adult women. The hazard is most severe for elderly women, but unlike the situation with regard to children's sleepwear, there is no size difference to permit a distinction to be made between elderly female sleepwear and other adult female sleepwear. Even if sufficient fabric were available for an overall female sleepwear standard, a large portion of the population would be unnecessarily subjected to the higher cost and changed product characteristics of flame resistant sleepwear. The second item type not directly addressable by an item type standard is dresses, for similar reasons. It appears that the improvement of safety in kitchen ranges offers good potential for the reduction of kitchen range accidents in general (20 percent of all first-to-ignite cases involve ranges), and for the reduction of the adult female sleepwear and dress hazards as well. Table 3 shows that 54 adult female sleepwear cases (42 percent of the total) and 30 dress cases (32 percent of the total for dresses) involve ranges.

Finally, consider hazards partially addressable by public education. The hazard represented by male shirt and pants ignitions is at present not completely addressable by either item type standards or improved ignition source safety, for the following reasons:

1.

2.

3.

Of the 193 cases in which male shirts were first to ignite 135 (70 percent) involved males age 16 and older. This indicates that the shirt fire hazard is largely an adult problem, and at present sufficient flame resistant shirt fabric is not available.

Even if technological considerations permitted a standard to be pro-
mulgated, a large portion of the hazard would not be addressed. This
is because the fabric fire hazard to adult males is strongly related
to flammable liquid involvement. Forty-four percent of male shirt and
pants ignitions involved flammable liquids. Even a flame retardant
fabric will support combustion if it is soaked in gasoline.

There are many ignition sources involved with shirt and pants ignitions; therefore, improved ignition source safety would require effort in many areas.

For these reasons, public education should be explored, perhaps in concert with the other two approaches, to fully address the male shirt and pants hazard. The examples given above are intended to illustrate the complexity of the fabric flammability problem. The item type standards now in force and in various stages of development address obvious hazards. The voluntary actions of the kitchen range and book match industries, which are currently considering ways to make their products safer, address another segment of the problem. Public education is a third approach which should be explored, because the magnitude and complexity of flammable fabric hazards make it necessary to use all available approaches to reduce these hazards.

NATIONAL BUREAU OF STANDARDS SPECIAL PUBLICATION 411, Fire Safety Research, Proceedings of a Symposium Held at NBS, Gaithersburg, Md., August 22, 1973, (Issued November 1974)

DEVELOPMENT OF THE STANDARDS FOR THE FLAMMABILITY
OF CHILDREN'S SLEEPWEAR

Emil Braun, James H. Winger and James A. Slater
National Bureau of Standards, Washington, D.C.

The general methodology used in the development of a mandatory flammability Standard is presented. An illustrative summary is given of the hazard analysis of the accident data and the subsequent test development and laboratory investigations conducted in the development of the children's sleepwear flammability standards (DOC FF-3-71 and DOC PFF-5-73). Some of the problems encountered in the development of a mandatory standard and the resolution of those problems are discussed.

Key words: Children; flammable fabrics; sleepwear; standards development; statistics.

1. INTRODUCTION

In 1967, Congress issued amendments to the 1953 Flammable Fabrics Act [1] that directed the Secretary of Commerce1 to issue mandatory standards for limiting the flammability of fabrics, wearing apparel, and interior furnishings in those areas where "unreasonable risk" has been shown to exist. The act further stipulated that all standards must be reasonable, appropriate, and technologically practicable. In an effort to insure that standards comply with these criteria, they must logically be developed from a careful study of acciThe end product of this study is a mandent data and laboratory experiments. datory flammability standard that removes "unreasonable risk" from the market place.

First,

Flammability standards are a synthesis of three distinct elements. Then there is the acceptance there is the basic test method that must, as far as possible, relate small scale performance to real world performance. criterion that sets the level of performance desired; and, finally, a sampling plan that insures that an allowable level of statistical risk to the consumer In this paper we will concern ourselves only with the develis not exceeded. the test method and the superimposed acceptopment of the first two points ance criterion.

The Proposed Children's Sleepwear Standard [2] for ages 6-12 years old, and the manner in which it differs from the Children's Sleepwear Standard [3] for ages 0-5 years old will provide illustrative examples of the evolutionary history of a test method and the acceptance criterion that form the foundation upon which a mandatory flammability standard is built. These standards will also serve to illustrate the direct relationship between the analysis of accident statistics and the finding of need for a standard, its scope, and the appropriateness of the test method employed.

2. TEST METHOD

A flammability test method is effectively determined by specifying four the variable to be measured, the source of ignition, interrelated parameters:

the specimen configuration, and the preparation of the specimen prior to testing. Each item must be carefully defined so that the end result is a test that is repeatable and reproducible, as determined by an interlaboratory evaluation, and that reflects real life performance as far as is consistent with the requirements of a practical test method.

1The Consumer Product Safety Act of 1972 has since transferred the standards setting responsibilities to the Consumer Product Safety Commission effective May 14, 1973.

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There are several different variables that can be used to describe the relative degree of the flammability of a fabric. One could measure the time to ignition, the burn rate, or both simultaneously as is done in CS-191-53 (Flammability Standard For General Wearing Apparel). The tendency of a fabric to self-extinguish before it is consumed could also be measured or the rate of heat transfer to a known substrate. Procedures have already been developed to measure any one of these variables. The question that first must be answered is which procedure is appropriate for children's sleepwear?

Accident data2 [4], tables 1 and 2, indicate that children between 0 and 12 years old are more prone to flammable sleepwear injuries than any other age group. Table 1 is a percentage breakdown of all sleepwear cases in the National Bureau of Standards' Flammable Fabrics Accident Case and Testing System (FFACTS) [5]. Table 2 is a normalization of table 1 based on the actual percentage of the population [6] represented by each age group. Table 2 shows that as a subtotal of the entire U.S. population, children 0 to 5 years old and 6 to 12 years old are found in the data base far in excess of what would be expected from population figures 2.7 and 1.7 times, respectively. From this information along with data from other sources [4], it was concluded that children under age 13 are exposed to sleepwear fires more frequently than other segments of the population or are less capable of correctly initiating a protective reaction at the first sign of danger.

Table 1. Age and Sex Distribution of Persons Involved in All
FFACTS First-to-Ignite Uncontaminated Sleepwear Incidents

Table 2.

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Ratios of Persons Involved in FFACTS Sleepwear Incidentsa to Corresponding U.S. Population Totals By Age Group

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2Accident statistics are based on a FFACTS data file containing 1,964 cases.

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