Technical Bulletin — November 2011

November 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

A September meeting was canceled and the committee was unable to find a common date in October. The latest meeting took place on November 3.

The committee was informed that the CSFM has appointed a new staff chair of the committee, the fourth since this revision process began. Jason D. DeWitt, Deputy State Fire Marshal, is now the chair. DeWitt stated that he wants to move forward starting with Article 8 and not go back to previous articles that have already been discussed.

Some key developments happened in this meeting. Specifically:

    1. The issue of requiring validation stickers on CSFM certificates has been stricken from this revision. (Article 8, Section 1322) While the CSFM staff like the idea and would like to keep it in mind for future revisions, they do not feel that they have the infrastructure to deal with it at this time.
    2. Companies that apply FR chemicals and/or sell FR chemicals will NOT be required to reveal their propriety formulas on the Flame-Retardant Product Transmittal form. Instead, there will be a statement to the effect that the chemicals used do not violate Proposition 65 requirements.
    3. The cessation of the validation sticker idea means that the CSFM will need to have samples of registered fabrics and fabrics treated by registered applicators. The CSFM doesn’t anticipate doing testing on these samples unless there is a fire or dubious field test. The CSFM staff is working on clarifying this requirement and the size of the samples.


The CSFM staff would like for the committee’s work on reviewing the revision to be complete by the end of January 2012. With the removal of the validation sticker issue and the change to the Product Transmittal Form, it seems likely that the timeline will be met. From that point, there would still be several months of work on the CSFM staff’s part before the revision is sent out for public comment. DeWitt estimated June 2012.

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 takes place on Wednesday, Dec. 7, 10:00 a.m. – 12:00 p.m. (Please note that this is Pacific time). Anyone is welcome to participate, but only advisory committee members have voting rights.