Technical Bulletin

August 2013

The California State Fire Marshal (CSFM) is updating its textile flammability document, Title 19, for the first time since 1993. A change to the pass/fail for the small-scale test was drafted in 1993 and has been used by the industry ever since, but it had not been vetted through the CSFM's official process.

A revision draft was prepared by a working group comprised of CSFM staff and industry members in 2008/09. The CSFM has created a Flame Retardant Advisory Committee to analyze this draft and make any changes before it is submitted for public comment. It was emphasized that this Flame Retardant Advisory Committee serves in an advisory capacity only; the CSFM has authority over final changes.

Summary of current work

A meeting was held August 6, 2013. Key points from this meeting include:

Article 9 of the California Title 19 regulation was approved with exceptions to 1307, 1310, 1331 by the Flame Retardant Advisory Committee.

The committee discussed adopting language from NFPA-705 in lieu of the current language in section 1295, Taking Specimens, because it provides more detailed information on how to do a field test. Most of the committee members are in favor of adopting the language from NFPA-705, but asked for an opportunity to review the document before making a decision. CSFM will send the committee members a copy to review and tabled the discussion for the next meeting.

The committee asked that the language in section 1307, Flame-Retardant Application Certification, be clarified since it is not clear if the section refers to interior or exterior fabrics. Another issue of concern is the difficulty for the fabric manufacture to determine where the certified fabrics are being used and which Authority Having Jurisdiction should receive the certificate. CSFM staff decided to form a subgroup to address the language and present it to the committee on the next call.

Re-treating fabrics after laundering, from section 1310e, was discussed, since it is not necessary to test fabrics after they have already passed the small scale test that included weathering and leaching. It was agreed that re-testing fabrics was not necessary and that an exception should be added to section e to address the issue. CSFM staff agreed to look at rewording the section.

CFSM staff announced that they decided to adopt PSI units of measurement as the primary units for the document, which are referred to in section 1331, Test Standards, and other parts of the regulation.

In addition, the language “not less than” was stricken from section 1331, since most lab technicians test samples that are 3-1/2 inches by 10 inches and it was agreed that the language left room for error.

In section 1331 c, Large Scale Test, the sample size was changed from a 7-foot sample to a 5-foot-by-4-foot sample, because the 4-foot sample meets the necessary requirements for the test, and 7-foot sample could not be accommodated by most of the testing laboratories.

Several other issues were raised about section 1331c:

  • Is the large-scale test relevant if the fabrics have already passed the small-scale requirements of leaching and weathering? CSFM staff agreed to review the requirement for the large-scale test for relevance and tabled the discussion for the next meeting.
  • Does the section refer only to outdoor fabrics? This discussion was tabled until it is determined if the large-scale test is needed.
  • The large-scale test does not address securing the test samples. The committee agreed that a picture would help to clarify how a test sample should be secured. CFSM staff will provide a picture for the committee to review.
  • Should AATCC 169-2009, option 4, be added as an acceptable test method for weathering? It was agreed that a subcommittee be formed to review AATCC 169-2009, option 4, as a possible weathering standard for section 1331.

A concern was raised about whether or not inks and paints that are added to certified fabrics cause them to become flammable. CSFM staff explained that the CSFM 19 regulation only applies to the fabric and not the ink/paint that is applied to the fabric. CFSM staff agreed to table the discussion for the next meeting.


The CSFM staff has another call scheduled in September to review the remaining articles. CFSM staff has not concluded when the California Title 19 regulation will be completed.


The CSFM Flame Retardant Advisory Committee roster, meeting announcements and minutes are available the Office of the State Fire Marshal.

The next conference call is Sept. 17, 2013, 9:00 a.m.–11:00 a.m. Pacific Time. Anyone is welcome to participate as a guest on the call, but only advisory committee members have voting rights.