Listed in the letter of comments (hyperlink) are statements from the published notice of the proposed action and associated scientific comments. The Flammability Reduction Group provides these comments to offer scientific feedback on statements made in the proposed rulemaking.
Recently, bills have been proposed – Senate bill S.1341 (introduced May 7, 2019) and House bill HR 2647 (introduced May 9, 2019) – to adopt California’s Technical Bulletin 117-2013 as a federal flammability standard.
The Flammability Reduction Group drafted this letter as part of its continued commitment to reduce the flammability risk of Residential Upholstered Furniture (RUF). This effort is a key goal the Reduced Flammability of Residential Upholstered Furniture and Flammability Reduction Technologies Projects.
 Technical Bulletin 133 – Flammability Test Procedure for Seating Furniture for Use in Public Occupancies Bureau of Electronic and Appliance Repair, State of California, https://bhgs.dca.ca.gov/industry/tb133.pdf, last viewed on May 14, 2019.
 Technical Bulletin 117-2013 - Requirements, Test Procedure and Apparatus for Testing the Smolder Resistance of Materials Used in Upholstered Furniture, Bureau of Electronic and Appliance Repair, State of California, https://bhgs.dca.ca.gov/laws/attach_11.pdf , last viewed on May 14, 2019.