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The CPSC’s Office of Compliance and Field Operations (Compliance) is exercising another update to the recent enforcement policy, due to an extreme shortage of standard reference material (SRM 1196) cigarettes. The need for this second update is due to an uncertainty of when the new SRM cigarette production will begin and many test laboratories no longer have inventory of the SRM cigarettes. The CPSC’s Compliance staff had issued an updated Interim Enforcement Policy on November 1, 2018, which had allowed testing just two mattress pad/mattress surfaces using SRM 1196 cigarettes. However, due to the overall extreme shortage of SRM cigarettes, the CPSC Compliance staff has updated the original policy to allow another means of testing under 16 CFR 1632.4(a)(2), using commercially available cigarettes with the following specifications: king size (85 mm + 2mm), non-filtered and filled with natural tobacco.
When using the commercial cigarettes, CPSC Compliance will not enforce the requirements that the test be repeated if a cigarette extinguishes before burning the full length for both mattress pads and mattresses under 16 CFR 1632.4 (d)(iii). Also, if using the commercial cigarettes for the ticking classification, Compliance will not enforce the requirement that the test be repeated if a cigarette extinguishes before burning the full length under 16 CFR 1632.6 (c)(4) (iiii). However, if the commercial cigarettes are used instead of the SRM cigarettes for the testing, the six mattress pad surfaces should be used for prototype testing. However for mattresses, testing may be reduced to two mattress surfaces, if using the commercial cigarette, since the mattresses are also subjected to open flame testing.
In addition, Compliance will continue to allow the use of opened packages of SRM cigarettes for each series of tests (16 C.F.R. § 1632.4(b)(3)). Relaxing this requirement will allow partial packs (or leftovers from prior testing) of SRM cigarettes to be used when conducting the tests to maximize the limited available supply. Compliance will also continue the Interim Enforcement Policy for mattress pads if using the SRM cigarettes to test two mattress and two mattress pad surfaces that was issued November 1, 2018.
This policy became effective on December 21, 2018, and will remain in effect until further notice. The CPSC will continue to monitor the availability of the SRM and may revert or change this policy with at least 30 days’ notice.
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