Technical Bulletin — March 2012

March 2012

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 used by the industry ever since, but had not been vetted through the CSFM's official process.

A revision draft has already been 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.

Christine Malmgren, IFAI, was appointed to the Office of the State Fire Marshal (OSDM) Flame Retardant Advisory Committee on March 8, 2012.

Summary of current work

A meeting was held March 6, 2012.

Some key points from this meeting include:

  1. The committee reviewed the Certificate of Flame Resistance. It was noted that the certificate was required for chemical applications and the subheading be added: “for chemical applications.” It was noted that the date of issue refers to the date when the chemical application is done. A committee member noted that the control number may be confusing for certain chemical application companies and the word batch should be added next to control for added clarity. The committee noted that dry cleaning be included next to washing where the form refers to if the flame process used will/will not be removed by such cleaning.
  2. The committee discussed the Registered Flame Resistant Product Certificate. It was noted that there would be one form for fabric and another for chemicals, however both forms will maintain the same content. The CFSM staff noted that a copy of the form should be given to the customer buying the fabric and copy to the customer purchasing the end product. The committee recommended the removal of the line wholesaler/retailer on the form, since the certificate applies to the manufacturer. It was noted that the date of registration line refers to the product registration date and not the date when the chemical expires.
  3. The Seal of Registration, Article 9, was reviewed. The committee noted that the revisions needed were grammatical.
  4. Article 10 and 11, Approval of Testing Laboratories and Violations and Penalties, were reviewed briefly for minor grammatical and gender neutral errors. It was decided to end the discussion due to the nature of the changes and because some of the committee members did not have the opportunity to review the sections before the meeting.


The CSFM staff will spend the next few months putting together all the proposed regulations in order. During this time, CFSM staff may be contacting committee members for comments as it pertains to their particular area of specialty.

IFAI members will be informed so that we can comment as an industry, as well as individuals. Please feel free to forward this update to any party you feel might be interested.


The CSFM Flame Retardant Advisory Committee roster, meeting announcements and minutes are available here.

The next conference call/web meeting is to be announced. The CFSM staff plans to bring the committee back together in a few months, but the date next is to be announced. Anyone is welcome to participate, but only advisory committee members have voting rights.