Technical Bulletin — August 2011

August 2011

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.

Summary of current work

The committee has held conference calls in May, June, July and August, but progress has been slow. Notable points are as follows:

  1. The Flame-Retardant Product Transmittal form was discussed. This document is to be included with every fabric or chemical submitted to the CSFM for certification. CSFM staff explained at the August 11 conference call that they will be reviewing all comments submitted and making a decision shortly.
  2. The Inherently Flame Retardant (IFR) Fabrics Task Group has recommended that IFR fabrics be required to be retested every four years. It was unclear where this language would be in Title 19.
  3. Article 7 (Field Test): The field test has been rewritten to specify that a butane lighter be used as an ignition source rather than a wooden match. This is no longer up for debate. What is still being discussed is the sample size. Technical difficulties bumped this issue out to the September conference call.
  4. Article 8 – the issue of requiring validation stickers for certificates has been discussed in depth. A database system was suggested as an alternative, but the CSFM staff doesn’t have the resources or authority to pursue it at the current time. A manual method of tracking certs, such as the sticker method, will have to be implemented.

I am hopeful that the validation would be required of fabrics that are treated for flame retardance and not those that come from the factory flame retardant. Members of the advisory committee were asked to create flow charts of how they understand the certification system works now; to identify issues; and, finally, suggest how it should work.


The CSFM staff was hoping to be complete with the main revision work in August, with a language review taking place in September and statements of reason for changes to be drafted in October. The committee is behind, so it seems unlikely those deadlines will be met.

The Title 19 revision will go out for a public comment period after the advisory committee’s work has been completed. I will continue to keep IFAI members informed so that we, as an industry, can comment, 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 takes place on September 21, 10:00 a.m. – 12:00 p.m. (Please note that this is Pacific time).

PLEASE NOTE: Anyone is welcome to participate, but only advisory committee members have voting rights.