Reference MBS

Publications

NBSIR 78-1580

NAT L INST OF STAND «. TECH R.I.C.

A 11 ID 4 51436b

Flammability Testing of Solids

Under the Federal Hazardous

Substances Act

Richard D. Peacock and

Marianne P. Vaishnav

Center for Fire Research

National Engineering Laboratory

National Bureau of Standards

U.S. Department of Commerce

Washington, D C. 20234

April 1980

Final Report

Sponsored in part by

U.S. Consumer Product Safety Commission

Washington, D.C. 20207

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78-1580

1980
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NBSIR 78-1580

4

! FLAMMABILITY TESTING OF SOLIDS

UNDER THE FEDERAL HAZARDOUS

SUBSTANCES ACT

NATIONAL BOE-SD Of STANDARDS

LIBRARY AUG 1 2 1980

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1980

Richard D Peacock and

Marianne P. Vaishnav

Center for

1 Fire Research

National Engineering Laboratory

National Bureau of Standards

U S. Department of Commerce

Washington, D C. 20234

April 1980

Final Report

Sponsored in part by

U.S. Consumer Product Safety Commission

Washington, D.C. 20207

U.S. DEPARTMENT OF COMMERCE, Philip M. Klutznick. Secretary

Luther H. Hodges, Jr., Deputy Secretary

Jordan J. Baruch, Assistant Secretary for Productivity. Technology, and Innovation

NATIONAL BUREAU OF STANDARDS. Ernest Ambler, Director

TABLE OF CONTENTS

Page

LIST OF FIGURES iv

LIST OF TABLES iv

Abstract 1

1. INTRODUCTION 1

2. THE FEDERAL HAZARDOUS SUBSTANCES ACT

2.1 Legislative History

2.2 General Definitions Under the FHSA

2.3 Flammability Under the FHSA 4 2.4 §1500.44 of the Regulations Under the FHSA

2.5 The Scope of the FHSA as It Applies to the Flammability

of Solids 8 2.6 Recommendations for Improvements of the Act and Regulations . 11

3. METHODS FOR TESTING OF SOLIDS UNDER THE FHSA 12

4.

TEST METHOD I FOR FIBERS, SHREDDED MATERIALS, AND SLIT FILMS ... 14

4.1 Introduction and Background 14

4.2 Accident Scenarios and Simulations 14

4.3 Apparatus and Test Method • 15

4.4 Results and Discussion 16

4.4.1 Specimen Weight 16

4.4.2 Equipment Cooling 17

4.4.3 Specimen Trough Insert and Top Restraint 17

4.4.4 Timing of the Flame Spread Rate 17

4.4.5 Type of Ignition 17

4.5 Test Criteria IS

5. TEST METHOD II FOR POWDERS, PASTES, AND GRANULAR SUBSTANCES ... 18

5.1 Apparatus and Test Methods 19

5.2 Trough 20

5.3 Ignition 21

5.4 Measurement of Flame Spread Rate 22

5.5 Possible Test Criteria 22

6. TEST METHOD III FOR EXTREMELY FLAMMABLE SOLIDS 23

6.1 Introduction and Background 23

6.2 Test Methods for Spark Ignition 23

6.3 Initial Equipment Design and Evaluation 25

6.4 Apparatus and Test Method 26

6.4.1 Power Supply and Timing Circuitry 26

6.4.2 Specimen Holder and Electrode Assembly 27

6.4.3 Test Criteria 27

7. CONCLUSIONS AND SUMMARY 28

8. REFERENCES 29

9. APPENDICES 31

APPENDIX A A-l

APPENDIX B B-l

iii

APPENDIX C C-l
LIST OF FIGURES

Page

Figure 1. Gas burner 32

Figure 2. Specimen holder 33

Figure 3. Test apparatus 34

Figure 4. Comparison of manual and automatic timing 35

Figure 5. Average burn time with 95% confidence interval for

10 samples each of various shredded films 36

Figure 6. Trough flammability test apparatus 37

Figure 7. Schematic for electric spark tester 38

Figure 8. Initial spark apparatus 39

Figure 9. Specimen holder and electrode assembly .......... 40

Figure 10. The energy released for various resistors 41

Figure 11. Schematic diagram of spark tester 42

Figure 12. Spark apparatus 43

Figure 13. Power output of spark discharge ..... 44

Figure 14. Ignition times of various substances .... 45

LIST OF TABLES

Page

Table 1. Material description 46

Table 2. Details of Easter baskets used in initial experiments ... 47

Table 3. Description of top restraints 48

Table 4. Investigation of parameters 49

Table 5. Burning behavior of various types of Easter grass 50

Table 6. Substances which did not ignite, or if ignited, were

self-extinguished before any significant flame spread ... 51

Table 7. Substances that burned too fast for flame spread

measurements 52

Table 8. F^me spread rates for substances in two troughs 53

Table 9. Effect of test conditions on results of "trough"

flammability test 54

Table 10. Operator bias 55

Table 11. Samples exposed to 0.2 sec arc 56

iv
FLAMMABILITY TESTING OF SOLIDS UNDER THE

FEDERAL HAZARDOUS SUBSTANCES ACT

Richard D. Peacock and Marianne P. Vaishnav

Abstract

The objective of the Federal Hazardous Substances

Act is to protect the consumer from hazards that arise

from a large variety of products. The Act and its

regulations have several provisions pertaining to the

measurement of the flammability of substances. Some

are detailed and explicit; others provide only general

guidelines

This report presents the results of a program to

provide improvements to particular provisions of the Act

and includes test methods that may be used for the testing of various solid materials. An extensive review of

the Federal Hazardous Substances Act, its predecessor,

and the legislative history provides the basis for some

specific recommendations for improvement or clarification.

Experimental work performed for the improvement of test

methods for shredded or slit films, powders, pastes, and

granular substances, and for extremely flammable solids

is discussed. This report is based on work sponsored by

the Consumer Product Safety Commission and performed from

1974 through 1976.

Key words: Federal Hazardous Substances Act; flammability;

granulars; hazardous substances; pastes; powders; shredded

and slit films; solids; sparks; test methods.

1. INTRODUCTION

The objective of the Federal Hazardous Substances Act is to protect the

consumer from hazards that arise from a large variety of products. The Act

and its regulations have several provisions pertaining to the measurement of

the flammability of substances. Some are detailed and explicit while others

provide only general guidelines.

1
The results of a program to provide improvements to particular provisions

of the Act and to develop test methods that may be used for the testing of

various solid materials is presented. An extensive review of the Federal

Hazardous Substances Act, its predecessor, and the legislative history provides

the basis for some specific recommendations for improvement or clarification.

Experimental work performed for the improvement of test methods for shredded

or slit films, powders, pastes, and granular substances, and for extremely

flammable solids is discussed. This report is based on work sponsored by the

Consumer Product Safety Commission (CPSC) and performed from 1974-1976.

2. THE FEDERAL HAZARDOUS SUBSTANCES ACT

2.1 Legislative History

In 1927, Congress passed the Federal Caustic Poison Act which required

the labeling of caustic or corrosive substances. It listed only 12 chemical

substances that required labeling. By 1960, many new substances for household

use had been introduced into commerce, some potentially hazardous. No warning

labeling indicating possible hazard (s) was required for these new substances,

since they were not covered by the 1927 Act. To remedy this situation,

Congress passed the Federal Hazardous Substances Labeling Act (FHSLA) in

1960. It was intended to protect the health and safety of the public by

establishing uniform standards for the labeling of those hazardous substances

which are used in and around the household [1]^. These labels were meant to

(a) warn the user of any hazard in the normal use of the product and (b) list

the hazardous ingredient (s) to aid the physician in case an accident did occur

[2], The bill covered those substances that were toxic, corrosive, flammable,

irritants, strong sensitizers, and those that generate pressure. It also

covered some radioactive substances [3].

In 1966, Congress determined that for most products this cautionary

labeling offered sufficient protection, but that there were products

(particularly among those intended for use by children) which were so extremely

hazardous that they could not be made safe for household use by cautionary

labeling [4,5]. Congress thereafter amended the FHSLA by passing the Child

Protection Act of 1966. This combination became the Federal Hazardous

Substances Act (FHSA) . The amendment was intended to empower the enforcing

'"Numbers in brackets refer to the literature references listed at the end of

this report.

2
authority to ban hazardous toys, other hazardous articles meant for children,

and any other article that was judged to be so hazardous as to be unsafe in

the household, no matter what labeling was required. It also made the

FHSA applicable to unpackaged articles that were intended to be used in

the household [6].

In 1969, Congress became aware that the FHSA, as amended in 1966, failed

to protect children from toys and other articles intended for use by children

which are hazardous due to the presence of electrical, mechanical, or thermal

hazards. The FHSA was limited by its definition of hazardous substance which

confined the Act to substances that were toxic, corrosive, flammable, irritating, strongly sensitizing, or pressure generating through decomposition,

heat, etc. [7]. Consequently, Congress amended the FHSA by passing the Child

Protection and Toy Safety Act of 1969, thereby protecting children from toys

and other articles intended for use by children whose primary source cf hazard

stemmed from electrical, mechanical, or thermal sources [8]

The FHSA was further amended in 1970 by the Poison Prevention Packaging

Act of 1970 and in 1976 by the Consumer Product Safety Commission Improvements

Act.

2.2 General Definitions Under the FHSA

As far as flammability is concerned, the FHSA defines a hazardous

substance as any substance which is combustible, if such substance can cause

substantial personal injury or illness as a result of reasonably foreseeable

handling or use by the public. A misbranded hazardous substance is any hazardous household substance (including toys and children's articles) that is

either not labeled or the label fails to comply with all the labeling requirements of the FHSA. If the source of the hazard is flammability, the label

must contain (a) the name and place of business of the manufacturer, packer,

and distributor or seller; (b) the common name of the substance that is the

source of the hazard; (c) the signal word DANGER if the item is "extremely

flammable;" (d) the signal word WARNING or CAUTION if the item is "flammable"

or "combustible;" (e) the name of the principal hazard, such as "flammable,"

"causes burns," etc. (the wording must clearly describe the hazard involved);

(f) a list of the precautionary steps the user should take; (g) instructions

for first aid in case an accident does occur; (h) storage and handling

instructions—whenever such information is necessary for the safe storage

and handling of the item by the user; and (i) either the statement "Keep Out

of the Reach of Children" or if it is a hazardous substance (but not a banned

hazardous substance) designed to be used by children it should contain

3
sufficient directions so that the item can be safely used by children. The

label must be located prominently, and the information on it must be in

English, in legible and conspicuous type, and contrasting markedly with other

printed matter on the label. A banned hazardous substance is a toy or item

intended for use by children (except those specifically exempted by the Act)

,

or any other substance used in or around the home that the Consumer Product

Safety Commission determines to be so hazardous that in spite of labeling its

presence or use in households still poses a hazard of personal injury or illness

.

2.3 Flammability Under the FHSA

Except for certain toys, items and substances that present an imminent

hazard to the consumer, the FHSA is a labeling act. By means of definitions

and test methods, it classifies hazardous substances into three labeling categories: extremely flammable, flammable, and combustible. Unfortunately, the

terms flammable, combustible, and extremely flammable do not have distinctly

different meanings to either laymen or technicians. For labeling purposes, it

would be more useful to the consumer to use the more common term "flammable" on those products whose burning characteristics are such that the consumer should

be warned. The regulations should then specify appropriate tests to determine

whether the product should be banned or labeled as flammable. Furthermore,

the regulations should prohibit labeling with terms such as "nonflammable,"

"not flammable," "not combustible," etc., on products which pass the test, for

most materials will burn given the appropriate conditions. Therefore, meeting

the criteria of a small-scale flammability test does not necessarily indicate

that the material or substance is not flammable (i.e., cannot burn).

The FHSA directs the CPSC to define the three labeling terms of

"flammable," "extremely flammable," and "combustible" for the contents of

self-pressurized containers and for substances which are solids. For all

other substances, these three terms are defined by a test method and criteria

specified in the FHSA itself. This test method, that the Act specifies, is

the Tagliabue (Tag) Open Cup Test which consists of placing the sample in

the cup of the Tag Open Cup Tester and heating it at a specified constant

rate [the temperature of the sample should rise at a rate of 1.1 + 0.3°C/min

(2 + 0.5°F/min)]. A 0.4 cm (5/32 in) long test flame is passed over the

heating sample at a specified rate at specified intervals. The flash point is

considered to be that temperature at which the test flame causes the surface

vapors of the sample to ignite but not to continue burning. This test is

limited, by practical considerations, to liquids. Gases are covered by this

Act only if they happen to be the contents of self-pressurized containers.

4
The Act defines the limits in terms of the Tag test for the three degrees of

flammability as follows:

Extremely Flammable - any substance which has a flash point at or below

-6.7°C (20°F) as determined by the Tagliabue Open Cup Tester.

Flammable - any substance which has a flash point of above -6.7°C (20°F)

to and including 27°C (80°F) as determined by the Tagliabue Open Cup Tester.

Combustible - any substance which has a flash point above 27°C (80°F)

to and including 66°C (150°F) as determined by the Tagliabue Open Cup Tester.

These classifications and their definitions are an expressed part of the

Act (rather than the associated regulations which CPSC can change as the need

arises), and therefore, cannot be changed, except by Congress.

The definitions are based on flash points and indicate only the class

for which the substance should be labeled; no test methods or criteria are

given to determine when a substance actually becomes a banned hazardous substance, nor is the Commission directed to define such criteria and test

methods. There are a considerable number of thermal burn accidents involving

liquids each year, and one questions the adequacy of these definitions, based

on flash point only, to protect the public health and safety. However, since

the classifications and their definitions are part of the Act (rather than the

regulations) , the Commission cannot redefine the above labeling classifications

to accurately reflect possible hazards involved in the use of these substances.

The Commission can ban substances--for banning takes only a finding by the

Commission that in spite of any cautionary labeling the hazard of the substance

is such that it cannot be safely used around the household. Banning requires

neither a standard test method nor a test criteria.

The FHSA directs the Commission to specify the test method and hazard

definition of "extremely flammable," "flammable," and "combustible" for solids

and for the contents of self-pressurized containers. Therefore, for solids

and for contents of self-pressurized containers, the method of testing for

hazards and their hazard criteria is to be set forth, not in the Act itself, but

under its addendum of "Regulations." It is unfortunate that the Act directs

such a classification scheme of flammability, for it implies that substances

passing a flammability test method under the FHSA cannot burn, which may or

may not be true. Items in many flammability tests may pass the pass/fail

criteria, indicating a certain level of safety, but may still be capable of

burning. This type of labelincr gives the public an erroneous concept of the

5
safety of the substance and may itself be a hazard simply because it is

misleading the public regarding the true physical behavior of the substance

in the presence of ignition sources.

The "Regulations" (in section 1500.3) define an extremely flammable solid

as a solid substance that ignites and burns at an ambient temperature of 80 °F or less when subjected to friction, percussion, or electrical spark. A flammable solid is defined as a solid substance that ignites and burns with a selfsustained flame at a rate greater than 0.25 cm/sec (0.1 in/sec) along its major

axis in a vaguely defined horizontal burn rate test. Combustible solid is not

defined. "Extremely flammable contents of a self-pressurized container" are

defined as the contents of a self-pressurized container that have a flash point

below -6.7°C (20°F) when tested by the Tagliabue Open Cup Test and a flashback flame extending back to the dispenser when tested by a roughly described

flame flashback test. "Flammable contents of a self-pressurized container" are

defined as the contents of a self-pressurized container that exhibit a flame

projection greater than 18 inches when tested by the same loosely-defined flame

flashback test that defines extremely flammable contents of a self-pressurized

container. "Combustible contents of self-pressurized containers" are not

defined in the Regulations.

2.4 §1500.44 of the Regulations Under the FHSA

Section 1500.44 of the Federal Hazardous Substances Act Regulations

(known as the Regulations) is entitled "Method for Determining Extremely

Flammable Solids." It contains two modes of sample preparation and one method

of testing, with one criterion for passing the test method. The test method

(and criterion) described in the Regulations reflects the definition given for

"flammable solid" and bears no relationship to the definition given for

"extremely flammable solid." The word "Method" in the title of the section is

used in the singular, thereby implying that the method of test given in the

section is intended to apply to both "extremely flammable solid" and "flammable

solid .

The criterion for all "flammable solids" is set by the definition given

for flammable solid: a rate greater than 0.25 cm/sec (0.1 in/sec) along the

major axis. This fails to take into account the fact that different types of

solids under different end-use conditions may present different types of flammability hazard situations, requiring different test methods and criteria to

reflect the actual hazard presented. It also fails to consider the fact that

not all solids (such as shredded materials, granular materials, spheres, etc.)

have a major axis.

6
The two modes of sample preparation given are (a) for granules, powders,

and pastes and (b) for rigid and pliable solids. For "granules, powders, and

pastes" the method of sample preparation given directs one to pack the sample

into a flat, rectangular metal boat with inner dimensions 15.2 cm long by 2.5

cm wide by 0.6 cm deep (6 in x 1 in x 1/4 in) . No mention is made as to what

density is to be obtained in the packing—should one pack loosely, tightly,

...? Every experimenter is allowed his/her own interpretation, which could

lead to differing test results with some materials. Work on improving the

test method for powders, pastes, and granules was previously reported [11] and

specific recommendations will be made.

The method of sample preparation for "rigid and pliable solids" directs

one to measure the dimensions of the sample and to support it by means of

metal ring stands, clamps, or any other suitable means in such a manner that

the major axis is oriented horizontally and the maximum surface is freely

exposed to the atmosphere. Measuring the dimensions of an object can become

very complicated, since most solid objects are not rectangular or spherical,

but odd-shaped. The directions imply that all dimensions of the item need to

be measured, yet the burn rate is based on the rate of burning along the major

axis. What constitutes the sample? Does the sample consist of the entire

centerpiece, decoration, toy, etc., or does it consist of a component which

has an entity of its own, such as a plastic or dried flower, small figurine

candle, or candle holder which is part of the "arrangement?" Again, it is

left up to the person conducting the test to determine the sample definition,

and again, each experimenter is left free to come up with a definition differing from that of his predecessor or competitor. The sample is to be supported

by means of metal ring stands or other suitable devices as needed. Many systems of specimen support, considerably different from one another, may be

"suitable," i.e., capable of supporting the sample. Since different experimenters are left free to use different specimen support systems for identical

specimens, they are quite likely to obtain different test results. Which

results, in such a situation, are legally valid? According to the definition

and test method, as specified in the Regulations, all test results (even those

differing radically from one another) can be valid. The specimen is to be

supported in such a manner that its major axis is oriented horizontally.

Aside from the fact that some specimens do not have a major axis (for example,

shredded materials) , and other specimens have a major axis that shifts directions (such as torus shaped solids) , is the hazard presented by the solid to

be tested reflected by the measurement of burn rate along the major axis

oriented horizontally if the solid in question is generally used in such a manner that its major axis is not horizontally oriented? For that matter, is

7
burn rate necessarily the parameter which reflects the hazard presented by

that solid under the conditions of its general or possible use?

The test procedure under §1500.44 of the Regulations specifies that the

sample be ignited by holding a burning paraffin candle so that the flame is

in contact with the surface of the sample at the end of the major axis for

5 seconds (or until the sample ignites, whichever is less). Unfortunately,

this does not let the experimenter know whether to ignite on the top surface,

bottom surface, etc. Since the ignition source is a burning candle, the

simplest mode of ignition would be that of holding the flame under the sample.

Flame propagation along its underside, however, may not be the normal mode of

flame propagation for that solid and may yield results indicating a much lower

level of hazard than would be obtained if the sample were ignited in such a manner that flame propagation could occur along the surface in its end-use

configuration. If the sample is ignited on the upper surface, one has to

contend with dripping wax resulting from the fact that this mode of ignition

necessitates that the candle be turned nearly upside down in order to obtain

flame contact with the upper surface of the sample. Since the dripping wax

contaminates the sample being tested, erroneous (but legally valid) test

results may be obtained. The candle ignition source specified may itself be

a hazard in the testing laboratory, for it is not a very stable object,

particularly when an experimenter is trying to quickly set it on a laboratory

bench after ignition of the sample has occurred, while at the same time

attempting to time the burning of the specimen.

2.5 The Scope of the FHSA as It Applies to the

Flammability of Solids

The criteria for inclusion under the FHSA are (a) that the solid be used

in or around a household, (b) that the solid be capable of causing substantial

personal injury or illness because of its flammability properties (the

Regulations consider a substantial personal injury or illness any illness or injury of a significant nature, excluding only those that are negligible)

,

(c) the solid is not specifically exempted by the Act, and (d) the solid is

not already covered by another act, such as the Flammable Fabrics Act, for

example

Two lazge categories of solids (not already covered by another act)

found in a household that may be potentially capable of causing personal

injury or illness due to their flammability properties are decorations and

toys. The following list indicates the types of items that may have to be

considered in the design of test methods under the FHSA.

8
Wall Decorations

-- Pictures

. Framed/Unframed

Cardboard

Wallboard — Wreaths/Floral Arrangements Made of

. Natural Materials

Cellulosic

Protein

. Synthetic Polymeric Materials

Thermoplastic Materials

Thermosetting Materials

. Fabrics

-- Carvings

. Wood

. Wax

-- Textile Wall Hangings

-- Animal Skins — Preserved Animal Heads, Etc. — Clock Frames

-- Wall Sconces — Wall "Planters"

. of Plastic Materials

. of Natural Dried Materials — Wall Plaques — Plastic Mirrors and Frames

Table Decorations

-- Floral Arrangements Made of

. Natural Dried Materials

. Artificial Materials

. Fabrics — Candles — Candle Holders

9
— Carvings

-- Figurines Made of

. Wax

. Wood

. Straw

. Cloth

. Plastic

Seasonal Decorations — Easter

. Easter Baskets

. Easter Grass

. Easter Eggs (Artificial)

. Easter Bunnies

-- Christmas

. Trees

. Hanging Tree Decorations

. Under Tree Blankets

. Garlands

-- Halloween

-- Thanksgiving

-- Seasonal Dolls (Type Incorporated in "Arrangements")

General Party Decorations Such as Those Used at Weddings,

Showers, Birthdays, Etc.

-- Accordian Tissue-Paper Shapes or Figures

-- Streamers

Toys —• Puppets — Stuffed Toys (and Their Clothes) — Dolls and Their Clothes

-- Construction Toys — Puzzles

-- Building Blocks

10
-- Balls, Hoops

-- Baby Toys Such as Rattles, Mobiles

Some other possible sources of burn injuries from solids found in the

household are

— Mobiles

-- Pompoms

-- Pot Holders — Cleaning Equipment Such as Brooms, Mops

Priority for the design of these test methods should be determined by

demonstrated need for a test method for a given type of solid, based on

accident/injury information involving that type of solid. If the item is new

to the marketplace, accident data cannot be expected to exist, and priority

setting must then depend upon the less desirable method of prediction of possible accident situations and sequences and simulating them in the laboratory

to determine the probable nature of the hazard of the item.

2.6 Recommendations for Improvements of the Act and Regulations

Based on this review of the Act and its regulations, the following

recommendations were made by NBS to CPSC in August 1976:

(a) That Congress be petitioned to amend the FHSA to remove the

classification of extremely flammable, flammable, and combustible from the

Act itself, allowing the Commission to determine the flammability labeling

terminology that would most appropriately protect the public; to further

amend the FHSA to remove the flammability test method and criteria from the

Act itself, allowing the Commission to determine flammability test methods

and criteria for all hazardously flammable substances (not covered by other

acts) that reflect the hazard presented by the various flammable substances;

(b) That the definitions for the terms extremely flammable solid and

flammable solid as presently given in the Regulations be abolished and that

labeling terms be defined for different types of solids with a test method

that approximates the end-use of the product and, therefore, relates to the

hazard presented by the solid;

11
(c) That the flammability test method for solids given in the

Regulations be abolished and replaced by test methods that appropriately and

repeatedly measure the hazard presented by the different types of solids;

(d) That test methods be designed not only to allow the appropriate

labeling of hazardously flammable solids, but that test methods also be

designed to determine when a hazardous substance should be banned;

(e) That priorities be set by CPSC to determine the order in which these

test methods are to be developed;

(f) That CPSC conduct in-depth flammability-accident investigations for

the various types of solids so that proper priorities for test method development may be set and that the resulting test methods may reflect the hazard

posed by the different solids.

3. METHODS FOR TESTING OF SOLIDS UNDER THE FHSA

NBS was requested to place special emphasis, initially, on the

development of a method for the testing of shredded or slit films such as Easter grass, and to follow up with methods for testing decorations and other

items until all products or product categories that are covered by the flammable solids regulations can be adequately tested and the regulations enforced

by CPSC. It is anticipated that a series of test methods will be required to

address the multitude of products covered by the flammable solids regulations.

A tentative categorization of test methods for various products is shown below.

These represent initial groupings, but are apt to be changed as materials are

actually tested, potential hazards are reviewed, and test capabilities are

evaluated.

Test Method I — Trough: Deep

Shredded or slit films (as used for Easter grass)

.

Loose, fibrous materials (as used for artificial hair in wigs, beards).

Shredded materials (stuffing for dolls, animals).

Pelleted materials (stuffing for dolls, animals).

Chipped materials (stuffing for dolls, animals).

12
Components (smaller than 1 inch) of multicomponent structures (such as puzzles,

building blocks).

Other related materials.

Test Method II — Trough: Shallow

Granules

Powders

Pastes

Test Method III -- Spark Ignition

Materials that may be subjected to a spark in typical end-use conditions.

Test Method IV -- Vertical: Frame-Supported

Fabrics and films used in doll clothes, costumes, other toys.

Materials used in toys or decorations that must be frame-supported to hold

the material in place and may be used as a vertical surface in the end-use

configuration.

Test Method V — Vertical: Not Frame-Supported

Decorations and toys of such a nature that they should be tested in the

vertical mode but are not of a configuration amenable to being supported by

means of a frame-type holder.

Test Method VI -- Horizontal: Frame-Supported

Decorations and toys of such a nature that they should be tested in the

horizontal mode and are of a configuration which is easily supported by means

of an appropriate frame.

13
Test Method VII — Horizontal: Not Frame-Supported

Decorations and toys of such a nature that they should be tested in the

horizontal mode but are not of a configuration amenable to being supported by

means of a frame- type holder.

Test Method VIII — Top Ignition

Decorations which by the nature of their use are likely to be ignited from the

top (such as candle holders)

.

Before a particular test method is extended to types of materials not

tested during the development process of that test method, additional testing

will be required to insure that the test method is truly applicable to the

testing of the material being proposed for inclusion in the scope of that test

method. A prime objective is to minimize the number of different test methods,

but to have test methods that are repeatable and reproducible and validly

assess the hazards of the products tested.

4. TEST METHOD I FOR FIBERS, SHREDDED MATERIALS, AND SLIT FILMS

4 . 1 Introduction and Background

In the development of a test method for fibers, shredded materials, and

slit films, Easter grass was selected as representative of the type of material that would be tested by this method. As currently covered by the Federal

Hazardous Substances Act under a procedure for rigid and pliable solids, these

grasses are to be tested horizontally along a major axis. No guidelines are

included to define a sample of material and no provisions are made for materials which do not clearly indicate a major axis. Since Easter grass and

similar materials (having no major axis) are not amenable to testing in this

manner, it was necessary that a better defined and more suitable method for

testing such materials be developed.

4.2 Accident Scenarios and Simulations

While there are no documented cases of injury or property loss involving

Easter grass in either the Flammable Fabrics Accident Case and Testing System

(FFACTS) or the National Electronic Injury Surveillance System (NEISS)

,

14
scenarios can be developed to point out the most likely ways for injury and

property loss to occur. The following scenario seems probable. A child playing with a potential ignition source (matches, cigarette lighter) may either

drop the ignition source onto Easter grass accidently, or hold the flame to

the grass intentionally. In either case, if the grass will ignite, it will

burn at a fire spread rate corresponding to its inherent flammability. As

the grass burns, it may further involve the child's clothing or other nearby

materials

To ascertain the validity of this scenario, a number of preliminary

experiments were conducted to determine the burning behavior of various grasses

when exposed to a small ignition source. Easter grasses were obtained which

are described in table 1 and placed in different Easter baskets as shown in

table 2. After ignition by a wooden match placed centrally on top of the grass,

four general classes of burning behavior were observed:

(a) Untreated thermoplastic grasses were difficult to ignite and flames

from the burning grasses spread slowly. As the burning continued, molten grass

formed puddles burning with larger flames when unrestrained by items such as eggs or candy.

(b) Treated thermoplastic grasses, also difficult to ignite, burned with

a tenuous flame and extinguished as soon as the match burned out.

(c) Untreated cellulosic grasses were ignited readily and flames spread

quickly over the entire surface of the grass. Burning continued with very

large flames, consuming the remaining grass in a short time.

(d) Treated cellulosic grasses could not be ignited when exposed to a match ignition source.

Thus, the ignition and subsequent growth of fire depends on two important

parameters

(a) The ease of ignition of the Easter grass, and

(b) The rate of the spread of fire if the grass ignites.

4.3 Apparatus and Test Method

The apparatus designed for the testing of Easter grasses was constructed

similar to an apparatus used for the testing of powders and pastes in an

15
earlier NBS study [11]. The apparatus, illustrated in figures 1 through 3,

consists of a horizontal trough into which the grass is placed and ignited

at one end with a flame from a gas burner. The grass is allowed to burn and

the rate at which the flames travel down the trough is measured. Engineering

drawings are included in the attached Proposed Test Method for the Flammability

of Solids Under the Federal Hazardous Substances Act; Method I, for Fibers,

Shredded Materials, and Slit Films, appendix A. Briefly, the features of the

new apparatus are

(a) A gas burner ignition source equipped with a needle valve to control

the gas flow and flame length;

(b) An aluminum trough 30 cm (11-7/8 in) long, 10 cm (4 in) wide, and

7 cm (2-3/4 in) deep with a wire mesh insert to hold the specimen;

(c) Use of a wire mesh top restraint to hold the specimen in place

(table 3)

;

(d) The use of trip threads strung across the trough 15 cm (6 in)

apart which burn through as the flame travels down the trough to allow

accurate timing of the flame spread rate.

4.4 Results and Discussion

A number of grasses were tested under several test configurations.

Table 4 presents the results of experiments investigating the following test

parameters: (a) specimen weight, (b) equipment cooling, (c) type of insert

and specimen top restraint, (d) timing of the flame spread rate, and

(e) ignition source.

4.4.1 Specimen Weight

Preliminary testing indicated that the specimen weight should be between

10 and 15 grams to insure sufficient flame travel to obtain a measurement of

the flame spread rate. As table 4 shows, test results obtained with 10-gram

specimens were considerably less variable than those obtained with the 15-gram

specimens. A possible explanation may be that the increased density of the

tightly-packed 15-gram specimens affected the measurements. The 10-gram

specimen weight was used for all further testing.

16
4.4.2

Equipment Cooling

The variability of the test results was also reduced by allowing the test

apparatus to cool between tests and inserting a clean aluminum foil liner for

each test. 4.4.3

Specimen Trough Insert and Top Restraint

It was found that a 1.3 cm (1-2 in) mesh insert was preferable to a solid

insert from the view of reducing the variability of the test results for both

thermoplastics and cellulosics. Since some thermoplastic specimens had a higher

tendency to puddle than others (strands of thermoplastic specimen tend to melt

into the flame zone rather than the flame progressing along the specimen when

the strands are free) , it was found necessary to use a top restraint to hold

the thermoplastic specimen in place in order to measure the flame spread rate

and to simulate candies or eggs placed on the grass. For thermoplastics, a top restraint running across the specimen rather than along it yielded less

variable results. Unfortunately, this top restraint tended to greatly increase

the times obtained for cellulosic specimens, since there was a smothering effect

on the cellulose whenever the flame-front reached one of the restraining crossbars. Consequently, it became necessary to design a top restraint that would

not interfere appreciably with the natural burning of the cellulosic specimen

and still restrain the thermoplastic specimen sufficiently to obtain a reading.

It was found that a top restraint of type D in table 3 yielded results for cellulosics similar to those obtained without a top restraint (type B in table 3)

yet restrained the thermoplastics sufficiently to consistently yield a reading.

4.4.4

Timing of the Flame Spread Rate

Time of flame travel was noted for both the 10 and 15 cm (4 and 6 in)

spacing between the trip threads. As table 4 indicates, the results were less

variable for the times taken over the 15 cm (6 in) distance. Burn times were

recorded by both manual (stopwatch) and electrical means. From figure 4, it

can be seen that no appreciable differences in results were obtained by either

timing mode, particularly for times greater than 30 seconds.

4.4.5

Type of Ignition

The validity of results for the two types of ignition were mixed,

increasing for some specimens, and decreasing for others. The average coefficient of variation for five different grasses was slightly higher for gas

ignition (15.8%) than for match ignition (14.2%). It should be noted, however.

17
that these experiments were performed with five replicates by one operator and

with one type of match. It was felt that match ignition is much more prone to

between-operator variability than is gas flame ignition and that additional

error would be introduced into the tests by noncontrollable variations between

match batches and sources. Since a gas flame is easily defined and consistentlv

reproduced, it was felt that, for the purposes of a standard test method, a gas

burner should be used for ignition. Consequently, the burner shown in figure 1

was used in the final testing for all available shredded or slit films that we

were able to obtain.

4.5 Test Criteria

After determination of the optimum operating parameters, the available

shredded and slit films were tested in accordance with the test procedure

described in appendix A. Table 5 and figure 5 summarize the results of these

tests. The untreated cellulosics had average burn times ranging from 11.3

seconds to 18 seconds. The untreated thermoplastics had average burn times

ranging from 47.3 seconds to 74 seconds. Overall averages for the untreated

cellulosics and the untreated thermoplastics were 13.5 and 61.4 seconds,

respectively. Based on these preliminary results, an acceptance time of 40

seconds could provide discrimination between the untreated cellulosic and the

thermoplastic grasses.

Although this method was designed to assess the flammability hazard of

shredded or slit film such as Easter grass, it should be equally applicable to

the testing of any loose fibrous material used in small quantities. The test

procedure presented in this report should be subjected to an inter laboratory

study, the scope of which should include shredded or slit films, loose fibrous

materials, shredded materials, pelleted materials, chipped materials, and any

other material suitable for testing in this test configuration. It is further

suggested that when other types of materials are found to be amenable to testing by this method, the test method should again be subjected to laboratory

evaluation to verify the applicability of the test method (or a variation

thereof) to the type of material in question.

5. TEST METHOD II FOR POWDERS, PASTES, AND GRANULAR SUBSTANCES

The present method of testing the flammability of powders, pastes, and

granular substances consists of packing the material into a small, horizontal

trough, igniting with the flame from a paraffin candle and determining the

flame spread rate. This method presents some difficulties in use. The

18
difficulties include making proper contact between the flame and the substance

being tested, contamination of the substance by dripping wax, inappropriate

shape of the candle flame when it is tipped to contact the horizontal surface

of the substance, determining when ignition of the substance has actually

occurred, lack of a procedure for packing a material into the trough, and timing the flame spread rate. There is a need for improvement and clarification

of the test method.

An apparatus which was designed to replace the candle and trough currently

in use is described in detail in the attached test method, appendix B. Briefly,

the features of the new apparatus are

(a) A gas ignition source instead of a candle;

(b) A low heat capacity trough, with leveling screws to maintain a horizontal surface to measure the flame spread on substances which melt;

(c) Use of stop cords 15 cm (6 in) apart which burn through to allow

accurate timing of the flame spread rate;

(d) Use of an aluminum foil liner for the trough to minimize cleaning

problems

A substance is placed into an aluminum foil lined trough and smoothed to

the surface level of the trough. Stop cords are strung across the trough at

distances of 7.6 and 22.9 cm (3 and 9 in) from the end of the trough. The

substance is ignited using a methane gas flame at one end of the trough and

allowed to burn. When the flame burns through the first trip thread, timing

of the burning rate begins. The time of burning between the breaking of the

first and second trip threads is measured.

5.1 Apparatus and Test Methods

The apparatus that was developed for testing powders, pastes, and

granular substances is illustrated in figure 6 and detailed in the engineering

drawings in the attached Proposed Test Method for the Flammability of Solids

Under the Federal Hazardous Substances Act; Method II, Powders, Pastes, and

Granular Substances, appendix B. The details of the design are described

below.

A number of substances were procured and tested under several test

configurations in addition to testing in accordance with the existing test

19
method. Several different trough materials and several different ignition

sources were explored.

Table 6 lists a number of materials which either did not ignite or did

not show significant flame spread in the test as specified in the FHSA. It

is noteworthy that one product, a tile cement, could not be ignited though

it was labeled, "Caution- -Combustible Mixture, N.Y.F.D.C. of A., Ho. 1640 - Use adequate ventilation - Open doors and windows; keep air circulating - Keep away from heat and flames." This designation indicates that the material

ignited in the Tag Open Cup Test at temperatures between 43° and 149°C (110°

and 300 °F) . While the material had not hardened completely, some solvent in

the material may have evaporated, pointing out the importance of testing with

fresh samples. Table 7 lists some substances which ignited readily, but

burned faster than 0.1 second for the 15.2 cm (6 in) distance (the minimum

time measuring capability of the apparatus)

.

Tables 8 and 9 list substances which exhibited flammability behavior

intermediate between the substances listed in tables 6 and 7. As with the

substances in tables 6 and 7, there was no uniformity of labeling; however,

with one exception, all these substances were labeled with regard to their

flame hazard in some manner. The behavior of the substances also made it

possible to make comparisons between various test method variables to determine appropriate parameters for the final test method. The results presented

in tables 8 and 9 represent testing under a variety of test conditions in

order to compare the various test method parameters. Variations from the

prescribed test method are noted on the tables.

5.2 Trough

A trough, 2.5 cm (1 in) wide, 30.5 cm (12 in) long, and 0.64 cm (0.25 in)

deep, is cut into a block of "Teflon," a fluorocarbon based plastic, low heat

capacity material. This trough was compared with a similar trough cut into

asbestos cement (Transite) and one made of aluminum. Although the flame

spread rate, shown in table 9 for the asbestos cement and aluminum troughs

and table 10 for the Teflon trough is not appreciably affected by the trough

material, the coefficients of variation are generally lower for the aluminum

and Teflon troughs than for the Transite trough. It was observed during testing that the temperature of the trough affects the results, presumably because

certain substances melt more rapidly or lose more solvent by evaporation in a trough retaining heat from previous tests. For these reasons, a trough material

was chosen that would cool quickly, but with enough structural strength to allow

spreading and leveling of the substances.

20
The test method included as appendix B describes a procedure for filling

the trough with a substance to be tested and for leveling the surface of the

substance. This operating procedure should be followed very carefully, especially with respect to the manner in which the trough is filled. Overfilling

appears to result in somewhat higher flame spread rate than underfilling, as shown by the following typical results:

Car Wax #2 — 0.32 cm (0.125 in) trip thread height,

automatic ignition with hypodermic needle

cm/sec inches/sec

overfilled 0.38 0.15

as per procedure 0.33 0.13

underfilled 0.28 0.11

In some cases, it was difficult to smooth the surface of the substance.

A rough surface resulted in a somewhat slower flame spread rate for materials

which melt before burning. The molten material flows ahead of the flame and

is slowed by high or low spots on the surface.

5.3 Ignition

There are several difficulties in igniting substances with the candle

as prescribed in the current regulations. One is establishing the exact time

of ignition of the substance since the flame from the candle is not easily

distinguished from that of the substance, and the bulk of the candle interferes

with visual observation of the ignition. In addition, there are drawbacks to

using the candle as discussed earlier. To improve the ignition source, NBS

investigated several methods of ignition and tested those that appeared

promising and compared the results to those obtained with the candle. A

micro-burner, hypodermic needle burner, and hypodermic needle burner designed

for automatic flame impingement on the specimen surface were investigated.

The results are shown in table 9. There appears to be no systematic effect of

the various ignition methods on the flame spread rate or on the variability

of the results. The reason for this is the new arrangement for flame spread

measurement: It starts at a point at least 5.1 cm (2 in) from the application

of the flame [7.6 cm (3 in) from the end of the trough], when the flame spread

is likely to have attained a stable rate. This is in contrast to the present

method which specifies a visual estimate of the time when the substance starts

burning and when it reaches the far end of the trough.

21
The burner described in the attached recommended test method is a form

of the manual hypodermic needle burner. As recommended for use with shredded

or slit films, it is used with a needle valve to allow accurate gauging of the

flame length. A pressure regulator is used to furnish the gas to the ignition

source at a pressure of 130 + 25 mm (2-1/2 + 1/2 psig) at the needle valve

inlet. Technical grade, 97 percent pure methane is used.

5.4 Measurement of Flame Spread Rate

Two cotton threads are placed at right angles to the trough. These trip

threads are 15.2 cm (6 in) apart, and the first trip thread is 7.6 cm (3 in)

from the right edge of the trough. The variability of the data is considered

under these conditions. In addition, changing the first trip thread to a distance of 10.2 cm (4 in) did not seem to affect the results. Based on the data

shown in table 10, a trip thread height of 0.32 cm (1/8 in) is recommended in

the attached test method. At this height, the thread is severed by even quite

low flames, but not likely to contact the substances during threading.

The use of the trip threads for timing allows accurate timing of the

linear burn time. The proposed test method is written to allow, at the

tester's option, the use of either manual or automatic timing of the burning

rate. Both methods, however, make use of the trip threads and microswitches

to keep tension on the threads during the test.

Table 10 shows that the effect of operator is statistically insignificant

when the procedures outlined in the proposed test method are followed carefully.

5.5 Possible Test Criteria

Pending further testing, the acceptance criterion in the current

regulations, a flame spread rate of 2.5 mm/sec (0.1 in/sec) or less, would

provide differentiation between obviously hazardous materials such as gunpowder and other materials less hazardous. However, it is necessary to

perform a hazard study in order to select an appropriate pass-fail criterion

that passes materials that do not exceed a predetermined risk level. A

program should be set up to evaluate this new test method and apparatus

fully before a final decision is made on the criterion.

22
6. TEST METHOD III FOR EXTREMELY FLAMMABLE SOLIDS

6.1 Introduction and Background

The Federal Hazardous Substances Act regulations define "extremely

flammable" solids as those which ignite when subjected to an electrical spark,

percussion, or friction, at an ambient temperature of 23°C (80°F) or less.

However, no definition of these ignition sources is given.

A spark is an unstable electrical discharge which ionizes the medium

between two electrodes. An arc is a stable electrical discharge; it can be

a prolonged electrical spark or it can be created by initial contact and

subsequent separation of two electrodes carrying current [12] . While the

duration of the discharge, to a large extent, would determine the materials

that would be ignited, a suitable duration could be defined through a study

of materials involved in accidents where sparking was the ignition source

along with laboratory testing of these materials. The ignition of substances

by an electrical discharge, be it spark or arc, requires that certain conditions

be met. The electrical discharge must supply sufficient energy to the substance,

maintained for a sufficient period of time, to insure that a minimum mass of

material is raised to the ignition temperature to sustain burning.

Two theories for the energy transfer from electrical discharges to

substances have been proposed--one based on hydrodynamic (shock wave) phenomena

and the second on thermal transport (convection) . An analysis of the relative

importance of these two phenomena indicated that either phenomenon could theoretically account for ignition [13] , but experiments by two investigators

indicated that for low energy discharges, the primary mode of energy transfer

appears to be thermal [12,13].

6.2 Test Methods for Spark Ignition

In the beginning stages of the project, a state-of-the-art survey was

performed to identify existing test methods for spark ignition, as well as accident situations in which such ignition may have occurred. Several

documents pertaining to tests for ignition due to percussion, friction, and

electrical sparks were located [14-22]. Primarily, these test methods were

designed to test explosives, blasting accessories such as detonators and

detonating cords, oxidizing agents, propellants, and flammable liquids. The

test methods have been developed and used by agencies such as the Bureau of

Mines, Department of Transportation, Naval Ordnance Laboratories, Picatinny

Arsenal, and suppliers and developers of explosives and propellants. The

23
substances for which these tests were developed may be expected, in many

instances, to be much more sensitive to ignition than many of the substances

under the Federal Hazardous Substances Act. The details of the test apparatus,

the precautions given for the actual testing, the statistical methods used for

evaluating the tests, and the typical test results discussed in these reports

provided information for the development of a test method for spark ignition

under the FHSA.

The spark ignition testers consist of several essential parts--an energy

storage source, such as a capacitor; electrodes; a specimen holding arrangement for testing of many substances; and a line resistor. The latter is often

used to modify the discharge rate of the capacitor which in turn affects the

duration of the spark discharge and allows for modification of the character

of the spark.

Westgate, et al. [12], performed extensive experiments on the spark

sensitivity of explosives. They found that threshold voltage value for

ignition did not vary with electrode material or capacitor size, if no series

resistance was used. Furthermore, with the particular electrode configuration

employed in this work, measurement of the efficiency of the spark revealed

that only 15 percent of the stored energy was delivered through the gap

through a given series resistance. Kirshenbaum [23] compared test results

for explosive materials using two electrode geometries. He found better

reproducibility with a parallel plate configuration than with a probe pointing

at a platform electrode from above because the powder specimens tended to fly

away from the spark zone in the latter configuration. The efficiency of energy

discharged determined through the air gap was approximately the same in the two

configurations

.

Westgate [12] and Kirshenbaum [23] , working with explosives, and Fitt

[24] , working nylon films in oxygen enriched atmospheres, found that insertion

of series resistors into the circuit reduced the rate of energy input into the

spark gap, but that the result of this lowered delivery rate was an increased

sensitivity of some materials to spark ignition. This could be an important

phenomenon in the design of a spark ignition test.

Westgat^ [12] also investigated the effect of humidity on the test

results, a factor generally neglected by other workers. He found that an increase in humidity of the atmosphere caused a decrease in the threshold

voltage necessary for specimen ignition where the sample moisture content

was constant. The water vapor affects the dielectric constant of the air

24
and this affects the energy transfer. The ambient atmosphere thus apparently

has an effect on the rate of energy transfer and should be considered in test

design.

6.3 Initial Equipment Design and Evaluation

Based on the concepts discussed above and in the above-mentioned papers,

a preliminary instrument was designed and constructed. Figure 7 shows the

overall arrangement. The main features of this apparatus consist of an automotive or similar ignition coil, capacitors, the test chamber, and an adjustable

series resistor. For the purposes of experimentation, an oscillograph is

attached via a voltage divider, to enable an investigation of the effect of

voltage and current variations on the charge energy density and the ignitability

of various substances. Figure 8 shows the details of the spark power circuitr . A timing device and voltage adjustment provides a means to vary the length and

intensity of the electrical discharge. The design also allows measurement of

the discharge voltage and current providing information on the energy released

by the spark. The specimen holder and electrode assembly is shown in figure 9.

It consists of two replaceable copper electrode tips held in nonconducting

nylon supports. The specimen holder is constructed of "Teflon," a fluorocarbon

based, low heat capacity material with excellent flammability and electrical

resistance. The specimen holder and electrode assembly is mounted on an optical

bench to allow precision measurement of electrode to electrode and electrode to

specimen spacing. Equally important, this design allows flexibility in spacing

the electrodes and specimen holder to allow study of the effect of spacing and

determination of the optimum operating conditions for a final test method.

A number of substances were procured that would exhibit a range of

flammability characteristics. These materials in their end-use configuration

were subjected to a spark ignition source to gain information for the following

experiments

(a) Different series resistors were used to vary the average power

dissipated in the discharge;

(b) Different samples were exposed to the same discharge;

(c) The amount of energy necessary for ignition was measured for

different materials.

25
Figure 10 illustrates the energy released on the spark discharge for

this initial apparatus. With no specimen present, the spark was discharged,

and the discharge time was varied. By changing the resistor in series with

the discharge capacitors, the average power and discharge time can be varied,

while the total energy remains the same. Table 11 shows the energy dissipated

and the ignition/nonignition of various materials when exposed to a 0.2 sec

spark discharge. The spark discharge grazed the surface of the specimen, and

a determination was made of whether sustained burning occurred. In addition,

it was determined whether the same materials could be ignited using a bookmatch

as the ignition source. The energy dissipated for discharges with materials

present is generally higher than simply the spark discharge in air, also shown

in this table.

During the testing, several deficiencies of the apparatus became evident.

With use, the copper electrode tips became dull and pitted causing the energy

output to change. In addition, the high rate of energy release inherent in the

design made it difficult to ignite an obvious "extremely flammable" substance,

granular gunpowder. The main source of error, however, was due to machine

malfunction (current leakage) which became worse as the machine was used more.

A second generation apparatus, described below, was designed to prevent these

problems

.

6.4 Apparatus and Test Method

As a result of these machine failures, a new apparatus was designed and

constructed. The apparatus is detailed in the attached Proposed Test Method

for the Flammability of Solids Under the Federal Hazardous Substances Act;

Method III, for ignition resistance of substances to electric sparking,

appendix C. The details of the design are described below.

6.4.1 Power Supply and Timing Circuitry

The power supply and timing circuitry, shown in figure 11 and detailed

in appendix C, provides power to the electrodes and to an electromagnet under

the sample holder. Circuitry for the timing of the spark duration and for

a safety switch to allow safe operation of the apparatus during specimen

preparation and cleaning of the specimen holder is also included in the

design. A high voltage transformer provides a dependable high voltage output

to the electrodes, with timing provided by an electronic clock capable of

timing accuracy of 0.01 sec for times up to 99.99 sec.

26
6.4.2 Specimen Holder and Electrode Assembly

The specimen holder and electrode assembly, as detailed in appendix C,

is a modification of the assembly used with the earlier apparatus. The

modified holder is shown in figure 12. The main features of the modified

assembly are the addition of an electromagnet within the specimen holder to

direct the spark discharge downward into the sample being tested, and a design

of a removable top plate of the specimen holder to allow different specimen

holders to be used for different materials if needed. In addition, the holder

has been designed so that the electrodes are directly above the center of the

magnetic field to direct the discharge properly into the specimen. In earlier

testing of substances under the FHSA, it was observed that the temperature of

the specimen holder affected test results [25]. In addition, the extremely

high temperatures of the spark discharges required the use of a material with

excellent flammability resistance. For these reasons, Teflon was chosen for

the specimen holder as a material that would cool quickly, but with enough

structural strength and with properties that would allow repeated exposure

to the spark discharge.

Figure 13 shows the power output of the tester for different sets of test

conditions. The power is constant above about 1 sec. Below 1 sec, the energy

output drops, presumably since the spark is not as intense. In addition, some

time is necessary for the discharge to stabilize.

6.4.3 Test Criteria

Figure 14 presents the ignition times for various substances when

exposed to a spark discharge on the apparatus. These results should be

considered preliminary. A discharge time of 0.3 sec provided a good differentiation between the few obviously extremely flammable substances tes:

and other substances. However, since this value of 0.3 sec is based on such

a small population of substances, it is only provided as a basis of discussion.

A hazard study should be performed in order to select an appropriate pass/fail

criterion that passes materials that do not exceed a predetermined risk level.

A program should be set up to evaluate this new test method and apparatus

fully and to determine the criterion for differentiation for those materials

considered hazardous.

27
7. CONCLUSIONS AND SUMMARY

This report presents the results of a program of the Federal Hazardous

Substances Act and its regulations to identify those provisions related to

flammability and to provide recommendations for revisions to those provisions

and meaningful test methods for materials covered by the Act [26]

.

As described

in section 2.6, a number of recommendations were made to the CPSC in August

1976 to provide the CPSC with enforceable regulations. An outline was proposed

in section 3 providing a tenative categorization of products by expected test

methods. CPSC priorities and funding limitations did not permit development

of all test methods or extensive research on all of the recommendations made

to the CPSC.

NBS was requested to place emphasis on the development of three particular

test methods: a test for fibers, shredded materials, and slit films [27]; a test for powders, pastes, and granulars [11,25]; and a test using electric

sparking as an ignition source. The development of these three test methods

is described and a proposed test procedure is presented for each. However, a number of limitations that were outside the scope of this study are apparent:

(a) Only a small number of samples were used during the development of

each test method. Although not within the scope of this study, a program

should be developed to evaluate the new test methods fully before they are

used for regulatory purposes.

(b) Hazard studies should be performed to determine materials that are involved in accidents to select appropriate criteria for the test methods.

(c) The effect of draft across the specimen surface, relative humidity,

or ambient temperature was not studied fully. Variations due to these effects

should be investigated.

The test development for ignition by electric sparking showed it most

difficult to ignite most materials with a spark discharge. Those that did

ignite would also show extreme flammability by other tests including those

described in this report. The usefulness of this test method and the

definition of extremely flammable solids in the FHSA is therefore questionable.

28
8. REFERENCES

[1] New Safety Labeling Requirements, Food Drug Cosmetic Law Reports,

No. 273, p. 6 (July 13, 1960).

[2] Hazardous Substances for Household Use, Senate Report No. 1158, 86th

Congress, p. 3 (March 10, 1960).

[3] Federal Hazardous Substances Labeling Act, House of Representatives

Report No. 1861, 86th Congress, p. 2 (June 14, 1960).

[4] Child Protection Act of 1966, Senate Report No. 1551, 89th Congress,

p. 2 (August 30, 1966).

[5] Child Protection Act of 1966, House of Representatives Report No. 2166,

p. 2 (October 1, 1966) .

[6] Child Protection Act of 1966, Public Law 89-756, 89th Congress, S. 3298

(November 3, 1966).

[7] Toy Safety Act of 1969, Senate Report No. 91-237, 91st Congress, 1-2

(June 17 , 1969 )

[8] Child Protection and Toy Safety Act of 1969, Public Law 91-113, 91st

Congress, S. 1689 (November 6, 1969).

[9] Federal Hazardous Substances Act Regulations, Federal Register, Vol . 33,

No. 187, Part II, p. 27015 (September 27, 1973).

[10] FHSA, as amended, January 1971, U.S. Government Printing Office: 1974,

733-501/2301.

[11] Krasny, J. F., Quarterly Reports on Improvement of Test Methods, FHSA

July-September 1974 and October-December 1974.

[12] Westgate, C. R. , Pollack, B. D., and Kirshenbaum, M. S., Electrostatic

Sensitivity Testing for Explosives, Picatinny Arsenal, Technical Report

4319 (April 1972) .

[13] Kowalewicz, A., Dynamics of Spark-Ignition of Two-Phase Mixtures,

Archiwan Procesow Spalania, Vol. 1, No. 1, 25-48 (NTIS-Translation

A71-20068) (1970).

[14] Clear, A. J., Standard laboratory procedures for determining sensitivity

brisance and stability of explosives, Picatinny Arsenal, Dover, New York

07801 (1970).

[15] Hough, R. , Lasseigne, A., and Pankow, J. , Hazard classification of

flammable and oxidizing materials for transportation-evaluation of test

methods. Report Number TES-20-73-1, Department of Transportation (19~3).

[16] Lasseigne, A. H., Hazard classification of explosives for transportation

evaluation of test methods. Report Number TES-20-73-2, Department of

Transportation (1973)

[17] Jensen, A. V., (ed.). Hazards of chemical rockets and propellants

handbook, Vol. TI, Chemical Propulsion Information Agency, Johns Hook ins

University Applied Physics Laboratory, Silver Sprina, Maryland 20°10,

NTIS AD 870258.

2 9
[18] King, P. V. , Sr. and Lasseigne, A. H., Hazard classification of oxidizing

materials and flammable solids for transportation-evaluation of test

methods, Report Number TSA-20-72-6, Department of Transportation (1972).

[19] Kuchta, J. M. and Smith, A. F., Classification test method for flammable

solids, Bureau of Mines Report of Investigation Number RI-7593 (1972).

[20] Kuchta, J. M. , Furno, A. L., and Imhof, A. C., Classification test method

for oxidizing materials, Bureau of Mines Report of Investigation Number

RI-7594 (1972) .

[21] Macek, A., Sensitivity of explosives, Chemical Review, 62_, p. 41 (1967).

[22] Mason, C. M. and Aiken, E. G., Methods for evaluating explosives and

hazardous materials, Information Circular 8541, Bureau of Mines (1972).

[23] Kirshenbaum, M. S., Response of lead azide to spark discharges via a new parallel-plate electrostatic sensitivity apparatus, Picatinny

Arsenal, Technical Report 4559 (June 1973).

[24] Fitt, P. W. , Co31ings, N. , and O'Neill, D. , The ignition of solid

materials in oxygen by electrical sparks. Journal of Fire and

Flammability, Vol. 4, p. 185 (July 1973).

[25] Braun, E., Krasny, J. F., and Peacock, R. D., Flammability testing of

solids under the Federal Hazardous Substances Act, method II for powders,

pastes, and granular substances, NBS Report to CPSC (February 1977),

unpublished.

[26] Vaishnav, M. P., The Federal Hazardous Substances Act and Flammability,

NBS Report to CPSC (August 1976), unpublished.

[27] Vaishnav, M. P., Flammability Testing of Solids Under the Federal

Hazardous Substances Act, Method I, NBS Report to CPSC (April 1976)

,

unpublished

.

30
9. APPENDICES

Proposed Test Methods for the Flammability of Solids

Under the Federal Hazardous Substances Act

The attached appendices present three proposed test methods for testing

of materials under the Federal Hazardous Substances Act and its associated

regulations. These test methods are based on the work presented in this paper.

Preliminary choices are provided based on laboratory testing for a number of

test parameters and possible sampling plans are included as a basis of discussion. Further data developed during a full laboratory round-robin evaluation

of the methods may indicate more appropriate test parameters, test criteria,

or sampling plans. The Consumer Product Safety Commission, of course, has the

authority to determine the final test methods, criteria, and sampling plans.

31
Figure 1. Gas burner

32
(a)

Top view of specimen holder

(b)

Specimen holder with insert

(c)

Front and side view of specimen holder

Figure 2. Specimen holder

33
(a) Without specimen holder

(b) With specimen holder

(c) With specimen holder and insert

Figure 3. Test apparatus

34
MANUAL

STOPWATCH

TIMING

CSEC?

AUTOMATIC ELECTRICAL TIMING <SEC>

Figure 4. Comparison of manual and automatic timing

35
If> OJ

CO

CO UJ

<tQ_ EliJLXWHO<(!ClQO'5D^ —I CO

Figure 5. Average burn time with 95% confidence interval

for 10 samples each of various shredded films

36

AVERAGE

BURN

TIME

(SEC)
A- TRIP THREADS

B - THREAD GUIDES

C - THREAD GUIDE ROD

D - TRIP SWITCH

E - THREAD CLAMP

F - SPOOL ROD

G - SPECIMEN HOLDER

H - BASE

J - THREAD SPOOL

K - SPOOL RETAINER

L - LEVELING BLOCK M - ELECTRIC STOP CLOCK

Figure 6. Trough flammability test apparatus

37
A

CL

UJ . o a. o. o.

&o

s •

c o. 3 8

w * 5 2

• « So

g

o

X

g

q:ujo

CD

38

Figure

7.

Schematic

for

electric

spark

tester
fr

39

Figure

8.

Initial

spark

apparatus
ASSEMBLY IS SUPPORTED ON AN OPTICAL BENCH

TO ALLOW PRECISION MEASUREMENT OF ELECTRODE

AND SPECIMEN-ELECTRODE SPACING

Figure 9. Specimen holder and electrode assembly

40
Energy

Released

(J)

Figure 10. The energy released for various resistors

41
z

LJ2

o

Ul

CL

CO

CO

UJO

a: o

ui

o cl _i H CO Ul

Figure 11 Schematic diagram of spark tester

42
r

il

r

£

|

;

i

|

J

3

Figure 12. Spark apparatus

43
SFARK DURATION (sec)

Figure 13. Power output of spark discharge

44
o>

CM*

6 &

O 0- o k_

LS_ &

®

£= ®

»- =FT 0 0.“- £ o c

Q. 2 ® ® E 33 += S « 5

£ P

< 03 O

®

®£

c/> ®

c

_®

®£

®

_>» o

CLO

®o

w® k_

®

CL £

o

CLC

3

cd

®

•oo

w

O®££o jOJO « o ®

C 8

o.c O X o ® 3

cr 2

E - o J5 o 2

c

o

E

3

£

Q.O

”©

®

o

E

CDO

>N®H—o

ll_ Q- X o CO CD CO

LU U_ o X ~3

J I I I I I 00 O 00 CO M" CM O

(,_°®S) 3INI1 N0I1IN9I ~IV00ddl03& Vl

Figure 14 . Ignition times of various substances

45
Table 1. Material description

Grass

Designation

Type of

Material Material Color

Type of

Shredding

A Thermoplastic Polypropylene Green Coarse & Uneven

B Thermoplastic Polypropylene Pink Coarse & Uneven

C Thermoplastic Polypropylene Yellow Coarse & Uneven

D Thermoplastic Polypropylene Yellow Coarse & Uneven

E Thermoplastic Polypropylene Pink Coarse & Uneven

F Thermoplastic Polypropylene Yellow Coarse & Uneven

G Cellulosic Cellophane Purple Fine & Even

H Thermoplastic Polypropylene Yellow Fine & Uneven

I Thermoplastic Polypropylene Pink Fine & Uneven

J Cellulosic Cellophane Green/Clear Fine & Fven

K Cellulosic Cellophane Green/Clear Fine & Fven

L Cellulosic Cellophane Yellow/Clear Fine & Even

M Treated

Thermoplastic

Treated

Polypropylene

Green Fine & Even

N Treated

Cellulosic

Treated Paper Green Fine & Even

0 Cellulosic Parchment White Coarse & Even

P Cellulosic Cellophane Green Fine & Fven

Q Treated

Cellulosic

Treated Paper Green Fine & Uneven

R Treated

Cellulosic

Treated Paper Green Fine & Fven

S Thermoplastic Polypropylene Green Fine & Uneven

T Treated

Cellulosic

Treated Paper Green Fine & Uneven

U Cellulosic Cellophane Red Coarse & Uneven

46
Table 2. Details of Faster baskets used in initial experiments

Type #

1

1A

3

4

5

Material

Wood

Wood with plastic

Plastic

V7oven

liner Basket

Liner

Solid

Construction

woven

solid

Plastic

Solid with

punched-out

design

Plastic & wood Woven

Plastic, wood & cardboard Woven

47
Table 3. Description of top restraints

Type Description

A

Cross-rods spaced 1 inch apart (except

rod #1 and 2 which are 1-1/2 inches &

3 inches from right inner edge of trough)

.

Threads placed across trough at 3 inches

& 9 inches from right inner edge of trough.

Rods placed along trough 2 inches apart &

1 inch from front & back edge of trough.

Cross-rods at 2-3/4 inches & 9-3/16 inches

from right inner edge of trough.

48
Table 4. Inveatigation of parameters

PARAMETER DESCRIPTION MATERIAL DESCRIPTION RESULTS 5-SAMPLE AVERAGE

Parameter Code Grass Material

Time (sec)/6" CV(%) for T SEM ±T at 95%CL w. 4° of freedom

A B A B A B A B

Weight of specimen A = lOg

B = 15g

E Thermoplastic 90.5 109.1 5.5 24.2 2.2 15.3 6.2 42.4

Liner changed and equip, allowed to cool

A = yes

B = no

E Thermoplastic 90.5 103.9 5.5 11.0 2.2 5.1 6.2 14.2

Type of insert - no top restraint

A = 1/2" mesh

B = solid

A

J ThermoplasticCellulosic

59.2 13.658.0

17.4

27.5

7.5 13.2

7.9

7.3 0.5

3.4 0.6 20.2

1.3

9.5

1 .

Mesh insert - no top restraint

A = 1/4" mesh

B = 1/2" mesh E Thermoplastic 94.1 1C3.9 28.7 11.0 12.1 5.1 33.6 14.2

Type of insert with top restraint "D" A = 1/2" mesh

B = solid

A

EJ

Thermoplastic

Thermoplastic Cellulosic

52.0 70.2

14.7

57.4 76.8

17.0

8.4

8.1

12.3

10.6

16.0

18.7

2.3

2.8 0.8

2.7

5.5

1.4

6.5 7.9

2.2

7.5

15.3

3.9

Type of top restraint - solid insert

A = top restr. B

B = top restr. C

A

E

J

P

Thermoplastic

Thermoplastic

Cellulosic Cellulosic

58.0 84.1

17.4

16.3

56.8 81.3

16.6

17.4

13.2 20.9 7.9

14.8

9.7 11.4

7.6 13.9

3.4 7.8 0.6

1.1

2.5 4.1 0.6

1.1

9.5 21.8

1.7

3.0

6.9

11.5 1.6

3.0

A = top restr. C

B = top restr. A

A

EJ

P

Thermoplastic

Thermoplastic

Cellulosic Cellulosic

56.8

81.3

16.6

17.4

70.1 85.5

43.3

26.0

9.7

11.4 7.6

13.9

8.7 9.5

18.4

10.4

2.5 4.1 0.6

1.1

2.7

3.6 3.6

1.2

6.9

11.5

1.6 3.0

7.5

10.1 9.9

3.4

A = top restr. A

B = top restr. D

C

A

E

J0

P

Thermoplastic

Thermoplastic

Thermoplastic Cellulosic

Cellulosic

Cellulosic

67.5 70.1 85.5

43.3

27.6 26.0

53.6

57.4 76.8

17.0

20.9

17.8

10.4 8.7

9.5

18.4 8.1

10.4

19.4 10.6 16.0

18.7

6.1

3.1 2.7

3.6

3.6 1.0

1.2

4.7

2.7 5.5

1.4 0.6

8.7

7.5

10.1 9.9

2.8 3.4

12.9

7.5

15.3

3.9

1.6

Type of top restraint - 1/2" mesh insert

A = restr. B

B « restr. D

A

J Thermoplastic Cellulosic

59.2

13.6 62.0

14.7 27.57.5

8.4

12.3 7.3

0.5

2.3 0.8 20.2

1.3 6.5

Distance over which time

is measured

A = 4"

B - 6"

C

A

E

J0

P

Thermoplastic

Thermoplastic

Thermoplastic Cellulosic

Cellulosic

Cellulosic

50.2 49.7

56.0

26.8 18.9

17.7

67.5

70.1 85.5

43.3

27.6 26.0

14.8 10.0 10.0

25.6

10.7

17.0

10.4 8.7

9.5

18.4 8.1

10.4

3.3

2.5

3.1 0.9

1.3

3.1

3.6

3.6

1.0

1.2

9.2

6.2 7.0

6.5

2.5

3.7

7.5

10.1 9.9

3.4

Type of ignition - solid insertA match

B - gas

C

A

E

J0

Thermoplastic

Thermoplastic

Thermoplastic Cellulosic

Cellulosic

53.6

57.4 76.8

17.0

20.9

75.3

66.1 82.9

18.8 22.2

19.4

10.6 16.0

18.7 6.1

27.5

17.7

14.8

11.3 7.6

4.7

2.7

5.5 1.4 0.6

9.2

5.2 5.5

1.0 —0.6

3.2 0.9 L_

12.9

7.5

15.3 3.9

1.6

25.7

14.5

15.3 2.6

Type of ignition - 1/2" mesh insert

A - match

B - gas

A

J Thermoplast ic Cellulosic

62.0

14.7 52.514.

8.4

12.3

13.5 13.6 0.8 6.5 I $.9

Time — Average time for five samples of flame spread between stop cords at 6“ spacing unless otherwise note.*. CV(») — Coei^icient of Variation in percent for five samples. SEM — Standard Error of the Mean for five samples.

±T — 954 Confidence limits for five samples.

49
Table 5. Burning behavior of various types of Easter grass

MATERIAL DESCRIPTION RESULTS

Type of Material

Time (sec)/6" Standard Error of the Mean

CV

(% Coefficient

of Variation)

95% Confidence

Interval for Mean

Number

Mean Median

of Samples

G Cellulosic 11.3 11.3 0.60 11.9 9.6 to 13.0 5

L Cellulosic 11.4 11.4 0.79 15.4 9.2 to 13.6 5

K Cellulosic 12.4 12.4 1.10 17.8 8.9 to 15.9 4

U Cellulosic 13.5 13.2 0.52 12.3 12.3 to 14.6 10

J Cellulosic 14.1 14.0 0.56 12.5 12.8 to 15.4 10

0 Cellulosic 18.0 18.4 0.70 12.3 16.4 to 19.6 10

D Thermoplastic 46.5 45.9 1.72 11.7 42.6 to 50.4 10

B Thermoplastic 47.3 47.0 1.03 6.9 45.0 to 49.6 10

A Thermoplastic 54.2 52.7 1.85 10.8 50.0 to 58.4 10

C Thermoplastic 55.8 54.0 2.82 16.0 49.4 to 62.2 10

I Thermoplastic 56.0 56.0 2.05 8.9 50.7 to 61.3 6

S Thermoplastic 63.1 62.8 3.73 17.8 54.5 to 71.7 9

H Thermoplastic 69.8 69.2 4.76 21.6 59.0 to 80.5 10

F Thermoplastic 70.6 71.0 2.78 12.5 64.3 to 76.9 10

E Thermoplastic 74.0 70.0 5.00 21.4 62.7 to 85.3 10

M Thermoplastic, Treated 108.6 107.9 5.94 16.4 94.9 to 122.3 9

N Cellulosic, Treated DNI - - - - 10

Q Cellulosic, Treated DNI - - - - 10

R Cellulosic, Treated DNI - - - - 10

T Cellulosic, Treated DNI - - - - 10

50
Table 6. Substances which did not ignite, or if ignited, were

a self-extinguished before any significant flame spread

Tile Cement

Plastic Resin Glue

Linoleum Paste

Petroleum Jelly

Sun Tan Lotion

Car Wax

Dry Cleaner for Rugs

Instant Chocolate Flavored Mix

Instant Tea

Instant Coffee

Sugar

Flour

Rice

Fruit Cereal

Silver Polish

Fertilizer (10-6-4)

a Testing was performed as specified in the FHSA except an aluminum trough

with microburner ignition was used.

b Label indicates that the product represents a fire hazard and refers to

N.Y.F.D.C. of A.

51
Table 7. Substances that burned tog fast for

flame spread measurements3

Canned Fuel Gel°

Cement for Plastic*3

Q Sporting Black Powder

General Purpose Household Glue*3

Panel and Dry Wall Adhesive*5

Polystyrene Plastic Model Cement*3

Wood Filler*3

Testing was performed as specified in the FHSA except an aluminum trough

with microburner ignition was used. Measurement was possible to 0.1 second

for the 6-inch length.

Label indicates that product represents a fire hazard and refers to N.Y.F.D.C.

of A.

Label indicates that product represents a fire hazard.

52
Table 8. Flame spread rates for substances in two troughs

(8 x 3-3/4 x 1-inch asbestos-cement block with a

6 x 1 x 1/4-inch trough with a 1-ply aluminum

foil inner lining) compared with aluminum (20 mil

thick) trough (6 x 1 x 1/4-inch) with 1-ply aluminum foil inner lining. Five replicates for each

sample

Source of Ignition: Microburner

Substance

Paste Wax

Bowling Alley Wax

Smokeless Powder

Rate of Flame

Spread

in.

sec

Transite Al

Block Trough

0.43 0.44

0.45 0.54

0.45 0.43

Std . Dev.

in

sec Transite Al

Block Trough

0.061 0.046

0.087 0-035

0.046 0-019

53
CTi 0>

J3

<0

Micro

Burner

Manual 1/16”

>

• aP U

11 5 9 10

Av.

Rate

in

.

/sec

0.57 0.49 0.36 0.30

Hypo.

Needle

Auto 1/16” |

C.V. :%

10 4 4 4 6

Av.

Rate

in.

/sec 0

.54

0.41 0.31 0.55 0.29

o

0)

T3

0)

a) z

o

CU

>1 X

Auto 00\

C.V. %

13 6

Av.

Rate

in.

/sec

0.63 0.60

Micro

Burner

Manual 1/8"

C.V. % 7 10 13

Av.

Rate

in.

/sec

0.63 0.56 0.31

Hypo.

Needle

Auto 1/8”

C.V. % 5 4 6 3 10 5 7 1

Av.

Rate

in.

/sec

0.63 0-51 0.35 0.58 0.29 0.38 0.13 0.48

Hypo.

Needle

Manual \

C.V. % 7 2 5 4 7 12

Av.

Rate

in.

/sec

0.63 0.50 0.35 0.56 0.32 0.36

Hypo.

Needle

Auto 1/4"

C.V. % 3 9 7 11 10 4

Av.

Rate

in.

/sec

0.66 0.45 0.35 0.57 0.32 0.40

Micro

Burner

Manual None

C.V. % 6 13 4 10 4

Av.

Rate

in.

/sec

0.54 0.38 0.41 0.44 0.43

.0

0)

TJcu

Manual None

> <*> u

12 9 13 13 3

Av

.

Ra

te

in.

/sec

0.50 0.39 0.39 0.40 0.43

Burner

Type

Ignition

Thread

Height

Substances:

Bowling

Alley

Wax

Vinyl

Top

Dressing

Car

Wax

11

Paste

Wax

Boot

Polish

Shoe

Polish

Car

Wax

#2

Smokeless

Gunpowder

13 U TD

54

Testing

was

performed

in

apparatus

as

specified

in

appendix

A

with

exceptions

as

noted

above,

five

samples

each.

Testing

was

performed

in

6-inch

asbestos-cement

trough

without

trip

threads.

1st

thread

4

inches

from

trough

end;

all

other

tests

with

1st

thread

3

inches

from

end.

Coefficient

of

variation.
01

<0 •H

jauo

4-1 (0P

0)04 oo

oi rH

XI

<0 Eh

CMP0

X*

(0P&O

CJ

u

0) d) -P 01

cd \CEj • c

•H

u o

(U 01 4J 01 \&> <#> u o 0) 01 •P 01c

•H

VO

(0

r-~ in

in

ooin

oo

in

01 CM 4J

C

01

X 10 01

O 10 -H C X s oi u

«0 10 T3 -H

4J S 01 (0 144 01 4J 0) UH A P 01 P 0) 3 <0 10 0

l/l

u (x Eh o

oo\

4H0

'O

<001 4J

oac

•Hc*?

4JC

01UP

0)ac

•HCo

•H

4-1 <0

•rlp

10>

UHo

55
Table 11. Samples exposed to 0.2 sec arc

Sample3 Energy

(Joules)

Ignition

Spark

Ignition

Match

Lens Paper 64 Yes Yes

Foam 53 No Yes

Ironing Board Foam 54 Yes Yes

Sponge 51 NO Yes

Plastic Bag 55 No Yes

Shelf Liner 55 No Yes

Crepe Paper (FR) 56 No No

Foam (FR) 48 NO No

Polyethelene Sheeting 55 NO No

Camphor 66 NO Yes

Steel Wool 44 NO No

Air Conditioner Cover 48 No Yes

Plastic Tablecloth 55 Yes Yes

Dust Cloth 61 NO Yes

Paper Tablecloth 68 Yes Yes

Drop Cloth 46 No No

Polishing Cloth 51 No Yes

Polystyrene Foam 41 NO Yes

Polymethylmethacrylate 48 NO No

Polymethylmethacrylate (FR) 52 No No

Air (No Sample) 44 No NO

Industrial samples, exact composition unknown.

56
APPENDIX A

Proposed Test Method for the Flammability of

Solids Under the Federal Hazardous Substances Act

METHOD I

Fibers, Shredded Materials, and Slit Films

.1 Scope.

This standard provides a test method and sampling plan to determine the

flammability classification of shredded and slit films under the Federal

Hazardous Substances Act.

.2 Definitions.

(a) "Federal Hazardous Substances Act" —the Federal Hazardous Substances

Act (1974) and the Federal Hazardous Substances Act Regulations (1973)

(b) "Horizontal burn time" means the time required for a shredded or slit

film to burn 15.2 cm (6 in) from the first trip thread and to the second trip

thread as defined in .5(c).

(c) "Ignition source" means the flame produced from the gas, burner, and

flame length specified in .5(b).

(d) "Packaged unit" means the smallest primary unit of sale of the

substance.

(e) "Production unit" means any quantity of finished material manufactured

in 12 calendar months which has a specific identity that remains unchanged

throughout the unit. For purposes of this definition, finished material means

material in its final, packaged form, ready for sale.

(f) "sample" means a set of five specimens.

(g) "Specimen" means an amount of material to fill the trough for testing

as specified in .5(c).

A-l
.3 General requirements.

(a) Summary of test method . A specimen is placed in a horizontal trough

and exposed to a standard flame on its surface for a specified ignition time

under controlled conditions. The horizontal burn time between two trip threads

located 15.2 cm (6 in) apart and 0.32 cm (1/8 in) above the surface of the

specimen is measured.

(b) Test criterion . When tested in accordance with .5, a material is

classified as follows:

(1) Materials with a horizontal burn time greater than the established

acceptance criterion shall be considered to pass the test and hence need no

labeling under the Federal Hazardous Substances Act.

(2) Materials with a horizontal burn time less than the established

acceptance criterion shall be labeled in accordance with the Federal Hazardous

Substances Act as flammable.

.4 Sampling and classification procedures.

(a) General . The test procedure of .5(c) shall be used in conjunction

with the following plan: The Consumer Product Safety Commission may consider

and approve other sampling plans that provide at least the equivalent level

of fire safety to the consumer. Alternate sampling plans approved for one

manufacturer may be used by other manufacturers without prior approval of the

Consumer Product Safety Commission.

(b) A production unit is classified according to the following plan:

(1) Normal classification sampling . Select five specimens, one sample,

from at least three different packaged units from a production unit, unless

the production unit consists of less than packaged units. Test the sample

according to .5. If all five specimens meet the criterion of the test method

defined in .3(b), the production unit shall be considered to meet the flammability requirements of the Federal Hazardous Substances Act for fibers, shredded materials, and slit films. If one specimen of the five fails the criterion of the test method defined in .3(b) and the individual responsible for

the classification is satisfied to classify the production unit as not having

met the requirements, classify the production unit as such. If one specimen

of the five fails to meet the criterion specified in .3(b) and the individual
responsible for classification desires to pass the production unit, select 10

additional specimens, two samples from at least three different packaged units

other than those selected for the initial sample and test according to . 5 . If

13 or more of the 15 specimens tested meet the criterion specified in .3(b),

the production unit shall be considered to meet the flammability requirements

of the Federal Hazardous Substances Act for shredded and slit films. If only

12 or less of the 15 specimens meet the criterion specified in .3(b), the production unit shall not be considered to meet the flammability requirements of

the Federal Hazardous Substances Act for fibers, shredded materials, and slit

films.

(2) Reduced sampling classification . The level of sampling required

to classify shredded and slit films may be reduced provided the previous 15

production units have all met the criteria specified in .3(b).

The reduced classification procedure shall be the same as the normal

classification procedure except that the production unit time limit shall be

extended to 24 months.

Reduced sampling shall be discontinued and normal sampling resumed if a production unit does not meet the criteria specified in .3(b).

.5 Test procedure.

(a) General . If previous testing indicates that the material under

evaluation will not meet the criteria specified in .3(b), the material may,

at the tester's option, be considered not to meet the criteria specified in

.3(b), and no further testing is necessary.

(b) Apparatus . — (1) Base and specimen holder support . The base and

specimen holder support assembly is detailed in engineering drawing 1. It

shall consist of a chassis base,, nominal 43 x 33 x 10 cm (17 x 13 x 4 in)

,

equipped with trip thread guides and spring loaded microswitches to hold trip

threads taut during testing and to allow electronic timing of the horizontal

burn time. It shall also be equipped with suitable leveling screws to provide

a horizontal, level surface for testing.

(2) Specimen holder . The specimen holder is detailed in engineering

drawings 2 and 3. It shall consist of a aluminum trough insert as detailed

in the engineering drawings. The insert rests in an aluminum holder that

is suspended on spacers above the base assembly.

A(3) Ignition source assembly . The ignition source assembly shall consist

of a 13-gauge hypodermic needle fastened to a brass tube to supply gas to the

burner tip as shown in engineering drawing 4

.

(4) Timing device . A stopwatch or suitable electric timer (actuated by

trip switches) shall be available to measure horizontal burn time at least to

the nearest 0.1 second.

(5) Gas . The gas shall be at least 97 percent pure methane.

(6) Trip threads . The thread used as trip threads shall be #50 white

cotton thread.

(7) Trough liners . Aluminum foil* 0.01 ± 0.005 mm (0.39 ± 0.2 mil) thick

shall be used to line the trough during testing as described in .5(c)(2).

(8) Balance . A balance shall be available to weigh specimen to the

nearest ±0.1 gram.

(c) Test procedure (1) General . — (i) All specimens shall be conditioned

for at least 8 hours in a room with forced air movement at a temperature 21 ± 3°C (70 ± 5°F) and a relative humidity of 67 percent or less.

(ii) Testing shall be performed in a room under the conditions specified

under (c) (1) (i)

,

above, provided with a hood or other smoke removal equipment.

It is suggested that the hood be equipped with both a bottom and a top exhaust

% and be in operation during testing. The maximum airflow in any direction by

the test chamber during testing shall not exceed 0.2 m/s (0.65 ft/sec). The

airflow may be increased between tests to rapidly remove the gaseous products

of combustion.

(2) Test procedure .-- (i) Test preparation . — (A) Trough preparation . Prepare trough for testing by leveling trough insert using leveling screws

provided. Fit a trough liner of aluminum foil, as specified in .5(b)(7), to

conform to the sides and bottom of the trough.

(B) Specimen preparation . Select a specimen, as defined in .4(b)(1) and

consisting of 10 ± 0.1 grams of the fiber, shredded material, or slit film,

making sure the specimen is as homogeneous as would be representative of the

production unit. Insert wire mesh in holder, place specimen on mesh insert

in specimen trough, and distribute material evenly over the mesh insert. Lower

restraint and clamp at left edge.

A(C) Trip threads . String trip threads, located on spools in back of base

specimen holder support, through grooved thread guides in back of specimen

trough and across specimen and through grooved thread guides in front of specimen trough; then guide threads around thread switch guide and over thread

switch, depressing thread switch completely, and attach thread around bolt,

securing it firmly with nut. Make certain that trip threads across specimen

are 15.2 cm (6 in) apart.

(D) Gas ignition . Light the methane gas ignition source and adjust the

flame length so that it is 2.54 ± 0.1 cm (1 ± 0.4 in) when the burner is held

in the nearly vertically downward mode.

(ii) Testing . Expose the specimen to the ignition source, for 5 seconds,

at a point centered between the front and rear edge of the trough and 1.27 cm

(1/2 in) to the left of the right edge of the trough. Allow the material to

burn down the trough and begin timing as the first trip thread is burned

through. Stop timing when the second trip thread is burned through.

(iii) Test observations . Record the horizontal burn time to the nearest

0.1 second.

(iv) Assembly cleaning and cooling . Dispose of the aluminum trough into

a covered metal can. Allow trough to cool before testing next specimen.

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APPENDIX B

Proposed Test Method for the Flammability of Solids

Under the Federal Hazardous Substances Act

METHOD II

Powders, Pastes, and Granular Substances

.1 Scope.

This standard provides a test method and sampling plan to determine the

flammability classification of powders, pastes, and granular substances under

the Federal Hazardous Substances Act.

.2 Definitions.

(a) "Federal Hazardous Substances Act" —the Federal Hazardous Substances

Act (1974) and the Federal Hazardous Substances Act Regulations (1973)

(b) "Horizontal burn time" means the time required for a powder, paste,

or granular substance to burn 15.2 cm (6 in) from the first trip thread and

to the second trip thread as defined in .5(c).

(c) "Ignition source" means the flame produced from the gas, burner, and

flame length specified in .5(b).

(d) "Packaged unit" means the smallest primary unit of sale of the

substance

(e) "Powder, paste, and granular" means any solid in paste, powder, or

granular form as defined by the Federal Hazardous Substances Act. This

definition includes, but is not limited to, paste wax, smokeless gunpowder,

bowling alley wax, vinyl top dressing, car wax, boot polish, shoe polish,

acoustical tile cement, asphalt tile cement, black gunpowder, etc.

(f) "Production unit" means any quantity of finished material manufactured

in 12 calendar months which has a specific identity that remains unchanged

B-l
throughout the unit. For purposes of this definition, finished material means

material in its final, packaged form, ready for sale.

(g) "Sample" means a set of five specimens.

(h) "Specimen" means an amount of material to fill the trough for testing

as specified in .5(c).

.3 General requirements.

(a) Summary of test method . A specimen is placed in a horizontal trough

and exposed to a standard flame on its surface for a specified ignition time

under controlled conditions. The horizontal burn time between two trip threads

located 15.2 cm (6 in) apart and 0.32 cm (1/8 in) above the surface of the

specimen is measured.

(b) Test criterion . When tested in accordance with .5, a material is

classified as follows:

(1) Materials with a horizontal burn time greater than the established

acceptance criterion shall be considered to pass the test and hence need no labeling under the Federal Hazardous Substances Act.

(2) Materials with a horizontal burn time less than the established

acceptance criterion shall be labeled in accordance with the Federal Hazardous

Substances Act as flammable.

.4 Sampling and classification procedures.

(a) General . The test procedure of .5(c) shall be used in conjunction

with the following plan: The Consumer Product Safety Commission may consider

and approve other sampling plans that provide at least the equivalent level

of fire safety to the consumer. Alternate sampling plans approved for one

manufacturer may be used by other manufacturers without prior approval of the

Consumer Product Safety Commission.

(b) A production unit is classified according to the following plan:

(1) Normal classification sampling . Select five specimens, one sample,

from at least three different packaged units from a production unit, unless

B-2
the production unit consists of less than packaged units. Test the sample

according to .5. If all five specimens meet the criteria of the test method

defined in .3(b), the production unit shall be considered to meet the flammability requirements of the Federal Hazardous Substances Act for powders,

pastes, and granular substances. If one specimen of the five fails the criterion of the test method defined in .3(b) and the individual responsible for

the classification is satisfied to classify the production unit as not having

met the requirements, classify the production unit as such. If one specimen

of the five fails to meet the criterion specified in .3(b) and the individual

responsible for classification desires to pass the production unit, select 10

additional specimens, two samples from at least three different packaged units

other than those selected for the initial sample and tesr according to .5. If

13 or more of the 15 specimens tested meet the criterion specified in .3(b),

the production unit shall be considered to meet the flammability requirements

of the Federal Hazardous Substances Act for powders, pastes, and granular substances. If only 12 or less of the 15 specimens meet the criterion specified

in .3(b), the production unit shall not be considered to meet the flammability

requirements of the Federal Hazardous Substances Act for powders, pastes, and

granular substances.

(2) Reduced sampling classification . The level of sampling required to

classify powders, pastes, and granular substances may be reduced provided the

previous 15 production units have all met the criteria specified in .3(b).

The reduced classification procedure shall be the same as the normal

classification procedure except that the production unit time limit shall be

extended to 24 hours.

Reduced sampling shall be discontinued and normal sampling resumed if a production unit does not meet the criteria specified in .3(b).

.5 Test procedure.

(a) General . If previous testing indicates that the material under

evaluation will not meet the criterion specified in .3(b), the material may,

at the tester's option, be considered not to meet the criteria specified in

.3(b), and no further testing is necessary.

(b) Apparatus . — (1) Base and specimen holder support . The base and

specimen holder support assembly is detailed in engineering drawing 1. It

shall consist of a chassis base, nominal 43 x 33 x 10 cm (17 x 13 x 4 in)

,

B-3
equipped with trip thread guides and spring loaded microswitches to hold trip

threads taut during testing and to allow electronic timing of the horizontal

burn time. It shall also be equipped with suitable leveling screws to provide

a horizontal, level surface for testing.

(2) Specimen holder . The specimen holder is detailed in engineering

drawings 2 and 3. It shall consist of a Teflon block insert with a 28 x 2.5

x 0.64 cm (11 x 1 x 1/4 in) centrally located trough cut in it. The insert

rests in an aluminum holder that is suspended on spacers above the base

assembly.

(3) Ignition source assembly . The ignition source assembly shall consist

of a 13-gauge hypodermic needle fastened to a brass tube to supply gas to the

burner tip.

(4) Timing device . A stopwatch or suitable electric timer (actuated by

trip switches) shall be available to measure horizontal burn time at least to

the nearest 0.1 second.

(5) Gas . The gas shall be at least 97 percent pure methane.

(6) Trip threads . The thread used as trip threads shall be #50 white

cotton thread.

(7) Trough liners . Aluminum foil, 0.01 ± 0.005 mm (0.39 ± 0.2 mil) thick

shall be used to line the trough during testing as described in .5(c) (2).

(c) Test procedure .-- (1) General .— (i) All specimens shall be

conditioned for at least 8 hours in a room with a temperature not less than

15 °C (60 °F) and a relative humidity of 67 percent or less. However, all containers should be closed at this time and at all times except when samples

are withdrawn, etc., to prevent loss of any solvent.

(ii) Testing shall be performed in a room under the conditions specified

under (c) (1) (i) , above, provided with a hood or other smoke removal equipment.

It is suggested that the hood be equipped with both a bottom and a top exhaust

and be in operation during testing. The maximum airflow in any direction by

the test chamber during testing shall not exceed 0.2 m/s (0.65 ft/sec). The

airflow may be increased between tests to rapidly remove the gaseous products

of combustion.

B-4
(2) Test procedure . — (i) Test preparation . — (A) Trough preparation . Prepare trough for testing by leveling teflon insert using leveling screws

provided. Fit a trough liner of aluminum foil, as specified in .5(b) (7), to

conform to the sides and bottom of the trough by pulling fingernails gently

along bottom edges of trough.

(B) Specimen preparation, pastes . Select a specimen as specified in

•4(b) (1) and prepare it for testing in the following manner: Using a spatula,

pack substrate into trough firmly, slightly overfilling the trough. Scrape

off excess material using a 3-inch putty knife, leveling material to the level

of the surrounding tray. Fill in any indentation with additional material and

smooth again. Clean putty knife after each use. Wipe excess material from

aluminum foil outside the trough and make sure foil liner lies flat against

teflon insert.

(C) Specimen preparation, powders, and granular

. Select a specimen as specified in .4(b)(1) and prepare it for testing in the following manner:

Pour or scoop substance into trough. Level with putty knife to the level of

the surrounding tray. Take care to avoid packing material too densely. Wipe

excess material from aluminum foil outside the trough and make sure foil liner

lies flat against teflon insert.

(D) Trip threads . String trip threads, located on spools in back of base

specimen holder support, through grooved thread guides in back of specimen

trough and across specimen and through grooved thread guides in front of specimen trough; then guide threads around thread switch guide and over thread

switch, depressing thread switch completely, and attach thread around bolt,

securing it firmly with nut. Make certain that trip threads across specner.

are 6 inches apart.

(E) Gas ignition . Light the methane gas ignition source and adjust the

flame length so that it is 2.54 ± 0.1 cm (1 ± 0.4 in) when the burner is held

in the vertically downward mode.

(ii) Testing . Expose the specimen to the ignition source, for 5 seconds,

at a point centered between the front and rear edge of the trough and 1.2” cm

(1/2 in) to the left of the right edge of the trough. Allow the material to

burn down the trough and begin timing as the first trip thread is burned

through. Stop timing when the second trip thread is burned through.

(iii) Test observations . Record the horizontal burn time to the nearest

0.1 second.

B-5
(iv) Assembly cleaning and cooling . Dispose of the aluminum trough into

a covered metal can. Allow trough to cool before testing next specimen.

B-6
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APPENDIX C

Proposed Test Method for the Flammability of Solids

Under the Federal Hazardous Substances Act

METHOD III

Electric Sparking Ignition

.1 Scope.

A test method and sampling plan is provided to determine the flammability

classification of solids when exposed to an electric spark under the Federal

Hazardous Substances Act.

.2 Definitions.

(a) "Federal Hazardous Substances Act" —the Federal Hazardous Substances

Act (1974) and the Federal Hazardous Substances Act Regulations (1973)

(b) "Packaged unit" means the smallest primary unit of sale of the

substance.

(c) "Production unit" means any quantity of finished material manufactured

in 12 calendar months which has a specific identity that remains unchanged

throughout the unit. For purposes of this definition, finished material means

material in its final, packaged form, ready for sale.

(d) "Sample" means a set of five specimens.

(e) "Specimen" means an amount of material necessary to conduct a test as defined in . 5 (c)

.3 General requirements.

(a) Summary of test method. A specimen is placed on a specimen holder

and exposed to a standard electric spark on its surface for a specified

C-l
ignition time under controlled conditions. The ignition/nonignition of the

material is measured.

(b) Test criterion . When tested in accordance with .5, a material is

classified as follows:

(1) Materials that do not ignite when exposed to the standard spark

discharge shall be considered to pass this test and hence need no labeling

as extremely flammable under the Federal Hazardous Substances Act.

(2) Materials that do ignite when exposed to the standard spark discharge

shall be labeled in accordance with the Federal Hazardous Substances Act as extremely flammable.

.4 Sampling and classification procedures.

(a) General . The test procedure of .5(c) shall be used in conjunction

with the following plan: The Consumer Product Safety Commission may consider

and approve other sampling plans that provide at least the equivalent level

of fire safety to the consumer. Alternate sampling plans approved for one manufacturer may be used by other manufacturers without prior approval of the

Consumer Product Safety Commission.

(b) A production unit is classified according to the following plan:

(1) Normal classification sampling . Select five specimens, one sample,

from at least three different packaged units from a production unit, unless

the production unit consists of less than three packaged units. Test the

sample according to .5. If all five specimens meet the criteria of the test

method defined in .3(b), the production unit shall be considered to meet the

flammability requirements of the Federal Hazardous Substances Act for extremely

flammable solids. If one specimen of the five fails the criterion of the test

method defined in .3(b) and the individual responsible for the classification

is satisfied to classify the production unit as not having met the requirements,

classify the production unit as such. If one specimen of the five fails to

meet the criterion specified in .3(b) and the individual responsible for classification desires to pass the production unit, select 10 additional specimens,

two samples from at least three different packaged units other than those

selected for the initial sample and test according to .5. If 13 or more of the

15 specimens tested meet the criterion specified in .3(b), the production unit

shall be considered to meet the flammability requirements of the Federal

C-2
Hazardous Substances Act for extremely flammable solids. If only 12 or less

of the 15 specimens meet the criterion specified in .3(b), the production unit

shall not be considered to meet the flammability requirements of the Federal

Hazardous Substances Act for extremely flammable solids.

(2) Reduced sampling classification . The level of sampling required to

classify materials may be reduced provided the previous 15 production units

have all met the criteria specified in .3(b).

The reduced classification procedure shall be the same as the normal

classification procedure except that the production unit time limit shall be

extended to 24 months.

Reduced sampling shall be discontinued and normal sampling resumed if a production unit does not meet the criteria specified in .3(b).

.5 Test procedure.

(a) General . If previous testing indicates that the material under

evaluation will not meet the criteria specified in .3(b), the material may,

at the tester's option, be considered not to meet the criteria specified in

.3(b), and no further testing is necessary.

(b) Apparatus . — (1) Specimen holder and electrode assembly . The specimen

holder and electrode assembly is detailed in engineering drawings 1 and 2. It

shall consist of two replaceable copper electrode tips mounted to copper electrode holders, and supported by nylon support assemblies, as detailed in engineering drawing 1. The horizontal distance between the two tips shall be 0.5

cm (0.2 in). The specimen holder shall be constructed with a teflon top plate

with an electromagnet mounted under it, as detailed in engineering drawing 2.

In addition, it shall be equipped with suitable vertical height adjustment or. the specimen holder to allow adjustment of the specimen to electrode distance.

It shall also be equipped with suitable leveling screws to provide a horizontal,

level surface for testing.

(2) Power supply and timing circuitry . The power supply and timing

circuitry is detailed in engineering drawing 3. It shall consist of a high

voltage transformer and an electronic clock, as detailed in engineering drawing 3, to provide power to the electrodes and timing of the spark duration.

C-3
(c) Test procedure . — (1) General. — (i) All specimens shall be

conditioned for at least 8 hours in a room with a temperature not less than

15°C (60°F) and a relative humidity of 65 ± 2 percent. However, all containers should be closed at this time and at all times except when samples

are withdrawn, etc., to prevent loss of any solvent.

(ii) Testing shall be performed in a room under the conditions specified

under (c) (1) (i)

,

above, provided with a hood or other smoke removal equipment.

It is suggested that the hood be equipped with both a bottom and a top exhaust.

The hood should not be in operation during testing. However, the airflow in

the hood should be turned on between tests to rapidly remove the gaseous

products of combustion.

(2) Test procedure . — (i) Test preparation . — (A) Specimen holder

preparation . If there is any visible residue on the electrode tips, the tips

should be cleaned or replaced, and the electrode tip spacing should be checked

(0.5 cm )

.

(B) Specimen preparation . Select a specimen, as specified in .4(b) (1),

and prepare it for testing in the following manner: Place a small amount of

the material to be tested on the specimen holder directly underneath and centered between the two electrode tips. Using the vertical adjustment provided,

adjust the specimen holder so that the top surface of the material is 0.3 ± 0.05 cm (0.12 ± 0.02 in) from the bottom of the electrode tips.

(ii) Testing . Expose the specimen to the spark for the established

duration of time.

(iii) Test observations . Record whether the specimen ignites or not.

For purposes of this test method, ignition shall be defined as sustained burning of specimen that would lead to complete consumption of the material.

(iv) Assembly cleaning and cooling . Any residue that is present on the specimen holder or the electrode tips should be cleaned and the assembly

allowed to cool before testing the next specimen.

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U.S. DEPT. OF COMM.

BIBLIOGRAPHIC DATA

SHEET

1. PUBLICATION OR REPORT NO.

NBSIR 78-1580

2. Gov't. Accession No. 5, Recipient's Accession No.

4. TITLE AND SUBTITLE

Flammability Testing of Solids Under the Federal

Hazardous Substances Act

5. Publication Date April 1980

•. Performing Organization Code

7. AUTHOR(S)

Richard D. Peacock and Marianne P. Vaishnav

8. Performing Organ. Report No.

9. PERFORMING ORGANIZATION NAME AND ADDRESS

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, DC 20234

10,Project/Task/Work Unit No.

•

11. Contract/Grant No.

12. SPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (Street, City, state, zip)

Sponsored in part by

U.S. Consumer Product Safety Commission

Washington, D.C. 20207

13. Type of Report & Period Covered Final, 1974-1975

14. Sponsoring Agency Code

15. SUPPLEMENTARY NOTES

I | Document describes a computer program; SF-185, FIPS Software Summary, is attached.

16. ABSTRACT (A 200-word or leas factual summary of moat si ghi ficant information. If document includes a significant bibliography or

literature survey, mention it here.)

The objective of the Federal Hazardous Substances Act is to protect the consumer from hazards that arise from a large variety of products. The Act and its regulations have several provisions pertaining to the measurement of the flammability

of substances. Some are detailed and explicit; others provide only general

guidelines

This report presents the results of a program to provide improvements to

particular provisions of the Act and includes test methods that may be used for

the testing of various solid materials. An extensive review of the Federal

Hazardous Substances Act, its predecessor, and the legislative history provides

the basis for some specific recommendations for improvement or clarification.

Experimental work performed for the improvement of test methods for shredded or slit films, powders, pastes, and granular substances, and for extremely flammable

solids is discussed. This report is based on work sponsored by the Consumer

Product Safety Commission and performed from 1974 through 1976.

17. KEY WORDS (six to twelve entries; alphabetical order; capitalize only the first letter of the first key word unlesa a proper name;

separated by semicolons)

Federal Hazardous Substances Act; flammability; granulars;

hazardous substances; pastes; powders; shredded and

test methods.

slit films; solids; sparks

18. AVAILABILITY JS Unlimited 19. SECURITY CLASS

(THIS REPORT)

21. NO. OF

PRINTED PAGES

1 I For Official Distribution. Do Not Release to NTIS UNCLASSIFIED 91

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20402, SD Stock No. SN003-003-

20. SECURITY CLASS

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22. Price

(X^Order From National Technical Information Service (NTIS), Springfield, VA. 22161 UNCLASSIFIED $8.00

USC O MM* D C