United States General Accounting Office

GAO Report to Congressional Committees

November 1999 CONSUMER PRODUCT

SAFETY COMMISSION

Additional Steps Needed

to Assess Fire Hazards of

Upholstered Furniture

GAO/HEHS-00-3

GAO United States

General Accounting Office

Washington, D.C. 20548

Health, Education, and

Human Services Division

B-282713 

November 17, 1999

The Honorable Christopher Bond

Chairman

The Honorable Barbara A. Mikulski

Ranking Minority Member

Subcommittee on VA, HUD,

 and Independent Agencies

Committee on Appropriations

United States Senate

The Honorable James T. Walsh

Chairman

The Honorable Alan B. Mollohan

Ranking Minority Member

Subcommittee on VA, HUD,

 and Independent Agencies

Committee on Appropriations

House of Representatives

In 1994, the Consumer Product Safety Commission (CPSC) began

preliminary work on setting a flammability standard that would make it

harder for sofas, chairs, and other upholstered furniture to catch fire. CPSC

estimated at that time that nearly 700 people died annually from such fires.

During the 5 years that the agency has been studying the potential

standard, the need for such a standard has remained an issue of

considerable debate. Proponents, such as fire protection groups, contend

that without such a standard, the public is subject to an unnecessary risk.

Opponents, including upholstered furniture manufacturers and the Small

Business Administration, respond that the magnitude of the problem is not

great enough to warrant the risks or added expense involved in treating

fabrics with flame-retardant chemicals or taking other steps to make

fabrics more flame-resistant. Opponents also contend that more

cost-effective solutions may exist, such as making more use of smoke

detectors to warn when furniture has caught fire.

To issue a flammability standard, the CPSC commissioners must determine

that the standard’s benefits bear a reasonable relationship to its costs.1

 To

do this, CPSC assesses in quantitative terms whether the lives and property

saved would justify the additional expense or risks associated with

building furniture that complies with the standard. In the conference

1

15 U.S.C. 1193 (j)(2)(B) (1994).

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report for CPSC’s 1999 appropriations act,2 the Congress directed us to

review CPSC’s process for establishing a potential flammability standard.3

Because CPSC’s work on the potential standard is still in process, we did

not conduct a comprehensive analysis of all aspects of the agency’s

preliminary computation of the risks, costs, and benefits. As agreed with

your offices, we focused our efforts primarily on analyzing CPSC’s approach

to quantifying the fire hazards that are the basis for computing the

standard’s potential benefits. We addressed the following questions:

• What methodology does CPSC use to estimate the magnitude of the fire

hazard that the standard would address?

• How reliable is this methodology for producing sound estimates of the

hazard that the standard would address?

To answer these questions, we reviewed the process, including the

underlying assumptions, that CPSC used to develop its initial estimates of

the magnitude of fire hazards from upholstered furniture. We conducted

limited tests of the effects of certain assumptions on the estimated

benefits of the standard. We also looked at the capacity of CPSC’s

methodology to produce sound fire hazard estimates when using the most

current data available. We conducted our work between May and

October 1999 in accordance with generally accepted government auditing

standards. Appendix I describes our scope and methodology in more

detail.

Results in Brief Because no single national data source exists on the magnitude of hazards

and losses caused by upholstered furniture fires, CPSC blends information

from two different sources. One source provides national estimates on the

total number of fires in four general categories and the extent of losses,

but it provides no information about specific types of fires, such as

upholstered furniture fires. The second source provides detailed

information for specific types of fires, but for only a portion of all fires in

the United States. CPSC uses the details from the second source of data and

the national estimates from the first source to calculate national estimates

of fire losses from the kinds of upholstered furniture fires the standard

would address.

2

H.R. Rep. No. 105-769 at 267 (1998).

3

CPSC’s appropriations act directed the National Academy of Sciences to study the potential

toxicological risks of all flame-retardant chemicals identified by CPSC and the Academy as likely

candidates for use in making upholstered furniture resistant to ignition.

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At present, CPSC cannot ensure that its methodology provides a complete

picture of the national fire losses that the potential standard would

address. For example,

• CPSC has not developed a statement of precision for the estimated losses

from upholstered furniture fires. Without this, CPSC’s estimates of fire

losses do not adequately disclose the range of benefits that may be

associated with its potential standard.

• CPSC’s methodology for calculating fire losses has the effect of including

losses that are not likely to be addressed by the standard. Fire losses

involving upholstered furniture are counted even though other factors not

addressed by the standard may have been responsible, such as fires that

are intentionally set. Also, for those fires for which the cause or origin is

unknown, CPSC assumes that upholstered furniture fires will occur in the

same proportion they occur in fires with a known cause. Our testing

shows that these methods are likely to overstate fire losses that the

standard would address, and as a result, they could have a material effect

on the associated benefits expected from the potential standard. Various

analyses can be used to assess the validity of underlying assumptions and

ultimately strengthen CPSC estimates, but so far CPSC has not used them.

We are recommending that, as CPSC continues to consider the need for a

mandatory flammability standard for upholstered furniture, it should

conduct additional analyses to identify the level of imprecision in the

methodology’s fundamental assumptions and apply any necessary

revisions to its cost-benefit analysis of the potential standard.

Background Although CPSC has reported that upholstered furniture fires account for

only 3 percent of all residential fires that occur each year, these fires take

a high toll in human life and property damage. CPSC reports that of all the

products the agency regulates, upholstered furniture is the leading cause

of household fire death. Under the Flammable Fabrics Act,4

 which

authorizes the issuance of flammability standards for clothing, upholstery,

and other products, CPSC has the authority to issue mandatory

performance and labeling standards for upholstered products.

To address the hazards of upholstered furniture fires, the National

Association of State Fire Marshals petitioned CPSC in 1993 to issue a

flammability standard for residential upholstered furniture by adopting

4

15 U.S.C. 1191 (1994).

Page 3 GAO/HEHS-00-3 Furniture Flammability Standard
B-282713 

three California standards.5 In 1994, after studying national estimates on

the incidence and severity of household fires, CPSC granted part of the

petition. This part of the petition dealt with small open flames such as

matches and candles. By a 2-to-1 vote, CPSC published an Advance Notice

of Proposed Rulemaking to announce its consideration of issuing a

flammability standard or other regulation to address the risks posed by

these upholstered furniture fires. CPSC commissioners deferred action on

the cigarette portion of the petition in order to first assess the

effectiveness of and industry compliance with an existing voluntary

furniture flammability standard for cigarettes. However, on the basis of

their initial laboratory testing, CPSC staff now believe a small open-flame

standard will also address cigarette-caused fires.6

 As a result, they have

taken that assumption into account in developing estimates of the fire

losses the standard would address and the benefits it would produce.

Proponents of a mandatory standard point to its ability to prevent death,

injury, and property damage as the major benefits. Opponents recognize

that these losses should be avoided, but they believe the potential costs

associated with the proposed standard are too great. Possible costs cited

include those related to health risks—both to employees of furniture

manufacturers and to consumers—posed by flame-retardant chemicals

that may be used; increased prices consumers would have to pay for

upholstered furniture to cover a variety of additional manufacturing costs;

diminished feel and texture of fabric treated with flame-retardant

chemicals; and loss of consumer choice because some materials may be

eliminated if they cannot be made flame-resistant.

CPSC activities conducted since the Advance Notice of Proposed

Rulemaking have included in-depth fire investigations, technical analyses

and laboratory tests, development of a draft standard, and initial estimates

of the standard’s potential costs and benefits. CPSC’s 1999 appropriations

act prevents the standard from proceeding past this stage until CPSC fully

considers the fundings and conclusions of the National Academy of

Sciences’ congressionally mandated review on the potential toxicity of

flame-retardant chemicals. This review is to be completed in January 2000.

5

California has standards for upholstered furniture fires started by large open flames in public

buildings that lack a sprinkler system, upholstered furniture fires started by smoking materials, and

those started by small open flames, such as candles. Separate standards were requested for small open

flames and cigarettes because some materials have different probabilities of catching fire, depending

on the heat source.

6

CPSC staff said that, for this reason, they will not take further action on the cigarette portion of the

petition until after the technical work for the small-open-flame portion is completed.

Page 4 GAO/HEHS-00-3 Furniture Flammability Standard
B-282713 

CPSC Uses Two Data

Sources to Estimate

the Magnitude of the

Upholstered Furniture

Fire Problem

To estimate the incidence of fires and losses resulting from upholstered

furniture being ignited by cigarettes or small open flames, CPSC uses

aggregate fire data from a national survey, detailed data on a portion of

individual fires, and a methodology to combine the two databases. This

approach is necessary because no single data source exists that provides

the information needed to estimate the magnitude of the problem the

standard is intended to address. The aggregate survey data provide

national fire loss estimates for four general categories of fires (such as

residential or vehicle fires) but provide no information about detailed

characteristics of the fires. This information is from a survey conducted by

the National Fire Protection Association (NFPA), a nonprofit fire protection

association. In contrast, the second source consists of detailed

information linking fire losses—deaths, injuries, and damages—with

specific types of fires, such as those originating in upholstered furniture.

However, the detailed data do not provide national totals and are not

collected in a way that permits them to be used by themselves for national

projections. The detailed data are collected from more than a third of the

nation’s fire departments and are found in the National Fire Incident

Reporting System (NFIRS), a federal database. This database is maintained

by the U.S. Fire Administration (USFA), within the Federal Emergency

Management Agency. The NFIRS data contain information on more than 20

different fire characteristics, such as the source of the fire and what

caught fire first.

Because neither NFPA estimates nor the NFIRS data can produce a

nationwide estimate of fire losses for specific types of fires, CPSC uses a

methodology for combining the two. The process of blending the two

sources of data was developed jointly by NFPA, CPSC, and USFA to

approximate and report on fire trends for the fire-fighting community and

the general public. CPSC, NFPA, and USFA use this general process to track

and report on fires and fire losses nationally. They have all used this

process for many years and try to apply it consistently so that conflicting

estimates are not produced, which could confuse the public and those

who use the data.

The methodology is based on the proportional relationship of the NFIRS

data to the NFPA estimates. If NFIRS data contain half of the total number of

fires estimated by NFPA, for example, NFIRS numbers for specific types of

fires are doubled to produce national estimates for these specific fires. The

NFIRS data also include a number of fires for which the first item ignited is

unknown. The methodology adds a proportional number of these fires and

fire losses to the NFIRS fires known to have started in upholstered

Page 5 GAO/HEHS-00-3 Furniture Flammability Standard
B-282713 

furniture. In the 1994 NFIRS data, for example, upholstered furniture fires

constituted 3 percent of all fires with a known item of origin. Therefore,

3 percent of the fires with an unknown item of origin also would be

allotted to upholstered furniture fires.

Extent of Fire Losses

Is Uncertain

CPSC has not fully addressed the uncertainty surrounding key data and

underlying assumptions that it uses in developing national fire loss

estimates. Particularly important are (1) the need to account for

imprecision surrounding the data used to make national fire loss estimates

and (2) the assumption that the potential standard could address all

upholstered furniture fires classified as being ignited by either small open

flames or cigarettes. So far, CPSC has not accounted for this imprecision or

tested the soundness of this assumption, and as a result, the full range of

fire losses is not known. Our limited testing demonstrates the importance

of these steps in developing sound estimates of fire losses that the

standard is designed to address.

CPSC Has Not Tested Key

Issues

Several issues raise uncertainties about the underlying assumptions

related to the NFPA and NFIRS data (see table 1). These issues include the

low response rates to the NFPA survey, the voluntary nature of reporting

NFIRS data, and the fact that some upholstered furniture fires started by

small open flames or cigarettes will not be addressed by the standard.

These issues raise questions about whether the fire and fire loss data

provided by NFIRS and NFPA result in a representative picture of the

incidence and severity of residential fires that occur nationally. In relying

on these data for standard-setting, it is important to understand whether

the data are representative and, if they are not, whether they overestimate

or underestimate the national fire problem.

Page 6 GAO/HEHS-00-3 Furniture Flammability Standard
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Table 1: Key Issues Potentially

Affecting the Validity of CPSC

Estimates

Assumption Issues that raise uncertainty

Subject of

preliminary

testing by GAO

NFPA survey data

NFPA national fire and fire

loss estimates are

representative of fires

nationwide.

Low response rate (21 percent of fire

departments surveyed)a and limited

review of nonrespondents results in

uncertainty about extent that national

projections accurately represent the

national fire problem.

Yes

No outside review of the analysis

used to produce national estimates

was conducted. Such a review,

usually conducted by a party with a

background in methodology and

statistics, is commonly used to help

identify flaws or constraints in

estimating methodologies.

No

Potential exists for survey

respondents to provide inaccurate

information. Limited follow-up or

corroboration of survey responses is

a way to ascertain the degree to

which these responses are accurate

and supported.

No

NFIRS data

Any upholstered furniture fire

classified as being ignited by

a small, open flame or

cigarette could be addressed

by the potential standard.

Some upholstered furniture fires that

were started by cigarettes or small

open flames also involve other

factors that place them outside the

category of fires the standard

addresses, raising concern that too

many fire losses may be linked to the

potential standard.

Yes

Fire and fire loss data

reported by local fire

departments are

representative of fires that

occur nationally.

Voluntary reporting carries the

potential that certain types of fire

departments, such as large fire

departments, will be over- or

underrepresented in the data, or will

only report major fires, which would

affect the extent to which data are

representative of the fire problem

nationally.

Yes

There is potential for data reported

by local fire departments to be

inaccurate. Limited verification and

corroboration of reported data is a

way to ascertain the level of

accuracy of the reported data.

No

(Table notes on next page)

Page 7 GAO/HEHS-00-3 Furniture Flammability Standard
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aFire departments protecting a larger number of people (over 50,000) responded to the survey at

a rate more than twice that of departments protecting fewer people (under 50,000). As a result,

NFPA reported that it received responses from fire departments that serve 40 percent of the

population.

Testing of Issues Showed

Potential for Inaccuracy

We selectively tested three key issues that affect the validity of CPSC’s

estimates:

• the extent to which the data used to project NFPA estimates provide

nationally representative and precise estimates,

• the extent to which data on fire losses that the potential standard does not

address are included in developing estimates of fire losses the standard is

expected to address, and

• the extent to which fire departments in the NFIRS database are

representative of fire departments nationally and provide nationally

representative fire data.

Our selective testing showed mixed results, indicating that CPSC needs to

more fully analyze some of its assumptions in order to provide greater

assurance that its fire loss estimates are valid.

Representativeness and

Precision of NFPA Estimates

Because of the overall low response rate to the NFPA survey (21 percent),

we conducted a limited test to assess the accuracy of NFPA estimates.

Corroborating survey projections to another data source is a common way

of assessing the representativeness of survey data. This type of

comparison can be a general gauge of how well the survey represents the

nation as a whole. To do this, we compared the NFPA death estimates with

the Centers for Disease Control and Prevention (CDC) death estimates. CDC

obtains this information from death certificates recorded in the 50 states

and the District of Columbia. The data classify deaths by the underlying

cause of death, which is determined from the death certificate

information.7

 Our testing indicated that CDC death data fall within the

bounds of NFPA’s estimates. On the basis of this general test, the data

appear to provide representative estimates of fire deaths. We did not

assess the representativeness of the NFPA national estimates of injuries and

property damage from fires.

To provide a complete picture of fire losses, CPSC needs to account for the

range of precision around NFPA’s estimates. Because the estimates are

7

While these data may not be 100-percent accurate either, they are subject to numerous tests and

checks and are widely used within the health research community.

Page 8 GAO/HEHS-00-3 Furniture Flammability Standard
B-282713 

based on a survey, they have a margin of error that needs to be

incorporated into national upholstered furniture fire loss estimates. Survey

researchers routinely report the margin of error in the results of their

surveys and polls. CPSC has not accounted for the margin of error around

NFPA estimates for deaths, injuries, and property damage. Although CPSC

stated that the margin of error for the total number of fires (2.5 percent)

was not significant for its estimates, we found that the margins of error for

deaths and injuries were considerably larger than the margin of error for

the total number of fires. In 1997, the largest margin of error was for the

estimated number of deaths, which could be off by as much as 350 deaths

(10 percent) in either direction. Because deaths, injuries, and property

damages are the factors for estimating losses from the kinds of fires

covered under a potential standard, they all need to be considered. By not

obtaining and using all of this information in developing its estimates of

upholstered furniture fire losses, CPSC runs the risk of conveying a false

sense of precision about its results.

CPSC’s Calculation of Fire

Losses

CPSC’s methodology for estimating fire losses that the potential standard is

expected to address also warrants additional refinement. First, in

estimating total fire losses, CPSC identifies all fires in NFIRS data known to

have involved the ignition of upholstered furniture by small open flames or

cigarettes.8

 Second, when NFIRS data lack complete information to link fire

losses to a specific type of fire, CPSC classifies a portion of these fires as

upholstered furniture fires involving small open flames or cigarettes. Our

work shows that both of these procedures are likely to overstate the fire

losses the potential standard is designed to address, and as a result, they

have a material effect on the benefits ascribed to the standard.

With regard to counting fires for which the origin and cause are known,

CPSC includes upholstered furniture fires that were classified in NFIRS as

being started by small open flames or cigarettes. However, our

examination of the same data shows that other factors were involved in

the cause of some of these fires, making them fires the standard would not

appear to address. For example, the standard is not designed to address

fires intentionally set or those in which a small open flame ignites a paper

or flammable liquid that is on or near an upholstered couch that in turn

ignites the couch. CPSC, however, has not yet excluded these types of fires

in its estimate.

8

As pointed out earlier, CPSC has determined that the potential standard will address both

small-open-flame and cigarette fires, and as a result, CPSC estimates fire losses for both types of fires.

Page 9 GAO/HEHS-00-3 Furniture Flammability Standard
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CPSC’s allocation of unknown fire losses also warrants additional attention.

In 1997, about 35 percent of the residential fire deaths in the NFIRS data

were not identified by what first caught fire, such as upholstered furniture,

draperies, chimneys, or walls. When NFIRS data lack complete information

to link fire losses to a specific type of fire, CPSC allocates these losses on

the basis of how the fire loss data are distributed across all fires in which

the specific type of fire is known. In other words, if 19 percent of all

residential fire deaths are attributed to upholstered furniture, the same

percentage of deaths that stem from fires not attributed to specific types

of fires is assigned to upholstered furniture fires. CPSC officials told us they

proportionally allocated unknown fire loss data because they had no

evidence that the data should be allocated differently.

Methods and data exist that could categorize the origin and cause of fires

better before calculating the fire losses the standard could possibly

address. The NFIRS data are useful in this regard because information

available in NFIRS allows certain types of fires to be ruled out as likely to be

addressed by the standard. As a result, the NFIRS data can be used to test

the effect of CPSC’s method of calculating total fire loss data.

We tried such a test using NFIRS data for 1997. We analyzed detailed

information on fires—those known to be upholstered furniture fires

started by a small open flame or cigarette and those with an unknown

origin or cause—looking for characteristics to identify fires that the

potential standard would not appear to address. For example, fires we

recategorized include those that were intentionally set, those involving

electrical short circuits, and those involving flammable materials not used

to upholster furniture (such as gases, flammable liquids, or cardboard).

Our reclassification of fires reduced CPSC’s estimate of fire losses that the

standard is designed to address by up to 152 deaths, 434 injuries, and

$70 million in property damages (see app. I for more details on these

reductions). Adjusting for this reclassification of fires could reduce the

benefits CPSC attributes to the standard from $885 million to $610 million,

or 31 percent of the total benefits. On the other hand, additional and more

thorough investigation of some fires by CPSC could identify other factors

that show that some of these fire losses would be prevented by the

standard.

Also, our test should not be taken as the most definitive or comprehensive

approach to this issue. For example, more comprehensive analytical

approaches to assess and allocate unknown fire losses could yield results

that would make the estimates more precise. Our selective testing was

Page 10 GAO/HEHS-00-3 Furniture Flammability Standard
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done mainly to determine whether the underlying assumption of CPSC’s

approach appears sound. Our results indicate that some of CPSC’s current

assumptions have a level of uncertainty that is material and as such

warrants attention.

Representativeness of the

Fire Departments That

Report NFIRS Data

NFIRS data are based on reports submitted by a little more than a third of

the 31,000 fire departments nationwide. Because the fire departments

reporting to NFIRS do so voluntarily, it is important to determine how

representative this group is of fire departments and fire experiences as a

whole. For example, 11 states have no fire departments reporting

information to NFIRS, and only a portion of the fire departments in the

other states participate. If certain types of fire departments, such as large

urban fire departments, are more likely or less likely to report to NFIRS, or

if fire departments tend to report only major fires, this could skew

estimates of the fire problem.

Testing the extent that NFIRS data are representative of fire and fire losses

that occur nationally can be conducted in several ways. We did so by

assessing the extent to which the types of fire departments reporting data

to NFIRS resembled the types of fire departments nationally on the basis of

two factors: the size of the fire department and whether it is

predominantly a volunteer or a paid fire department. This analysis

indicated that NFIRS-reporting fire departments fall into the various fire

department size and type categories at roughly the same proportions as all

fire departments across the country. As a result, any differences in fire

losses that is related to fire department size or type are probably

appropriately represented in the NFIRS data.

Effect of Selected Testing

on Cost-Benefit Estimates

Although the selected testing we conducted resulted in a decline in

estimated benefits expected from the potential standard, the tests should

not be taken as a comprehensive assessment of CPSC’s overall cost-benefit

calculation. For example, we did not review or evaluate CPSC’s

assumptions about the effectiveness of the potential standard in

preventing upholstered furniture fires ignited by small open flames or

cigarettes, which also have a major impact on the estimated benefits of the

standard. We also did not assess the validity or scientific basis for CPSC’s

assumptions concerning the extent to which a small-open-flame standard

will also address cigarette-caused fires. CPSC estimated that the potential

standard would prevent 80 percent of the small-open-flame losses and

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50 percent of the cigarette-related losses.9 However, this key assumption is

subject to further laboratory testing by CPSC.

Also, as stated earlier we did not analyze assumptions and methodologies

used to estimate the costs of the standard. It is important to recognize that

the testing of other issues and assumptions—especially those relating to

costs—may offset, at least in part, the decline in estimated potential

benefits that our testing found.10 As a result, we present no estimates of

the effect our testing has on the net costs or benefits of the potential

standard. Rather, our testing demonstrates the need for CPSC to further

refine its analysis.

Conclusions To promulgate a mandatory standard, the CPSC commissioners must

determine that benefits produced by the standard bear a reasonable

relationship to its costs. A high degree of assurance about the soundness

of these estimates is an important part of accurately assessing this

relationship. As matters stand, CPSC’s current approach is not likely to

generate the necessary degree of assurance. To provide this assurance,

CPSC needs to demonstrate, to a greater degree than now exists, the

validity of the assumptions on which the estimate is based. This will

require testing that so far has not been part of CPSC’s approach.

Recommendations To resolve issues surrounding the data and assumptions used in preparing

the cost-benefit analysis for a potential standard to protect against fire

hazards associated with upholstered furniture, we recommend that the

Chairman, CPSC, direct CPSC staff to conduct additional and more detailed

analyses of key assumptions including, but not limited to,

• assessing the precision surrounding NFPA national fire loss estimates and

their impact on estimated benefits attributable to the standard and

• identifying a more accurate method to calculate fire losses that could be

addressed by the standard.

We also recommend that any necessary revisions identified by these

analyses should be incorporated into the cost-benefit analysis of the

potential standard.

9

In applying this rate of effectiveness, CPSC also reduced cigarette-related losses by an additional

24 percent to account for the effect of the existing voluntary industry flammability standard.

10It is also possible that this testing would lower the estimates even further.

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Agency Comments

and Our Response

In its comments on our draft report, CPSC agreed with our

recommendations. It stated that CPSC staff have already begun to address

the issues we raised as they refine their fire loss estimates for upholstered

furniture. (See app. II for the complete text of CPSC’s comments.)

However, CPSC stated that the report overall downplayed the positive

findings about CPSC data and overemphasized the data problems. In fact,

after reviewing our report, CPSC provided us with new information and

perspective on the representativeness of the NFPA data. After considering

this additional information, we modified our draft to agree with CPSC that

our limited testing did not disclose any obvious data problems. However,

this does not indicate that the data are fully reliable, because our testing

did not address all the issues surrounding the underlying data. For

example, NFPA and NFIRS data are based on data reported by individual fire

departments that have not been subject to verification or corroboration.

As a result, we believe our report, as modified, presents an appropriate

characterization of our results and the remaining uncertainties

surrounding the underlying data.

CPSC also commented that our analysis overstated the significance of the

issues surrounding NFIRS data. CPSC concluded that it was not appropriate

for us to quantify the effect of these data problems and said that our

analysis was flawed for two reasons:

• Our analysis eliminated those fires that available information indicated

were inconsistent with the scope of the potential standard. However, CPSC

stated that this process could result in eliminating too many fires.

• Our analysis erroneously adjusted the fire data where the cause was

unknown. CPSC commented that we did not include the correct proportion

of fires with unknown origin or source in arriving at a total number of fires

that the potential standard is designed to address.

We do not agree with CPSC’s conclusion. First, our approach was to

determine whether data classification issues could have a material effect

on CPSC’s estimated losses that the potential standard would address. We

believe our analysis was a reasonable one for this purpose and that it

shows a likelihood of significant effect that warrants attention. The report

appropriately qualifies the results and acknowledges that our tests should

not be taken as the most definitive or comprehensive approach. Rather, it

is CPSC’s responsibility to develop more precise estimates, as it proceeds in

its rulemaking process.

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Second, we believe that our approach properly distributed the number of

“unknown” fires to the total number of fires that the potential standard is

designed to address. In our opinion CPSC’s approach overstates the true

proportion because it classifies as unknown some fires that available data

indicate are not subject to the proposed regulation. Consequently, our

methodology corrects the data to account for the ”greater chance of

containing upholstered furniture cases.” In making this adjustment,

contrary to CPSC’s comments, we did not eliminate fires from

consideration. Rather, we reclassified fires as known not to be

upholstered furniture fires that the potential standard is designed to

address. We then recalculated the proportion of unknown fire losses on

the basis of our reclassification.

Finally, CPSC commented that our recalculation of its estimated fire losses,

adjusted for reclassification of unknown fire origin or cause, would

overstate the reduction in potential benefits. Our report indicates that,

while this recalculation is an upper-bound estimate for this factor, further

investigation and analysis could also influence the magnitude of estimated

fire losses. CPSC’s continuing efforts to refine its analysis—of estimated

costs as well as benefits associated with its proposed standard—will be

central to its ongoing work to determine the merits of proceeding with a

mandatory flammability standard. In addition to CPSC’s written comments,

CPSC staff provided us with oral comments, which we incorporated, where

appropriate, in the final report.

We are sending copies of this report to the Honorable Ann Brown,

Chairman, and the Honorable Thomas H. Moore and the Honorable Mary

Sheila Gall, Commissioners, CPSC; and appropriate congressional

committees. We will also make copies available to others upon request.

If you or your staffs have any questions about this report, please contact

me at (202) 512-7118 or Frank Pasquier at (206) 287-4861. Major

contributors to this report include Tim S. Bushfield, Evan Stoll, and Stan

Stenersen.

Kathryn G. Allen

Associate Director, Health Financing

 and Public Health Issues

Page 14 GAO/HEHS-00-3 Furniture Flammability Standard
Page 15 GAO/HEHS-00-3 Furniture Flammability Standard
Contents

Letter 1

Appendix I 

Scope and

Methodology

18

Range of Information Sources Used 18

Analyzing the Methodology for Making National Fire Loss

Estimates

18

Testing the Validity of Underlying Assumptions and the

Soundness of National Estimates

19

Appendix II 

Comments From the

Consumer Product

Safety Commission

21

Tables Table 1: Key Issues Potentially Affecting the Validity of CPSC

Estimates

7

Table I.1: Reduction in Fire Loss Estimates Based on

Recategorization of Fires that the Standard Is Not Designed to

Address

20

Abbreviations

CDC Centers for Disease Control and Prevention

CPSC Consumer Product Safety Commission

NFIRS National Fire Incident Reporting System

NFPA National Fire Protection Association

USFA U.S. Fire Administration

Page 16 GAO/HEHS-00-3 Furniture Flammability Standard
Page 17 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix I 

Scope and Methodology

Our work focused on the methodology and data that the Consumer

Product Safety Commission (CPSC) is using to estimate national fire losses

from the kinds of upholstered furniture fires that would be covered by the

potential flammability standard now being considered. We used a variety

of sources and methods to gather and analyze data on this issue.

Range of Information

Sources Used

We obtained information from a wide variety of agencies, interest groups,

and other sources. Among the key sources were the following:

• CPSC officials, including those responsible for calculating national fire loss

estimates and estimating the potential benefits that would result from the

standard;

• National Fire Protection Association (NFPA) officials responsible for

conducting NFPA’s annual fire surveys, calculating the survey’s national fire

and fire loss estimates, and involved in developing the methodology that

combines NFPA’s survey projections with detailed fire data collected by

local fire departments;

• U.S. Fire Administration officials responsible for overseeing and analyzing

the detailed fire and fire loss data reported to the agency’s National Fire

Incident Reporting System (NFIRS);

• officials from the National Center for Health Statistics and the National

Center for Injury Prevention and Control at the Centers for Disease

Control and Prevention (CDC);

• officials representing various segments of the upholstered furniture

manufacturing industry, such as fiber manufacturers and upholstered

furniture manufacturers; and

• private consultants who use the NFPA and NFIRS data to estimate national

fire problems.

Our work also included a review of relevant legislation and other

documents related to CPSC’s approach to considering the potential

standard.

Analyzing the

Methodology for

Making National Fire

Loss Estimates

To address the study’s first question (the methodology used to estimate

the magnitude of the fire hazard that would be addressed by the standard),

we obtained documentation describing the process and examples

illustrating the data and major steps in the process from CPSC, NFPA, and

the U.S. Fire Administration. In addition to reviewing documents and

conducting interviews to learn how these estimates had been developed,

we also obtained and analyzed the 1997 NFIRS database of actual fire

Page 18 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix I 

Scope and Methodology

incidents as well as detailed information about the 1997 NFPA survey,

including some of the characteristics of the fire departments that

responded to it.

Testing the Validity of

Underlying

Assumptions and the

Soundness of National

Estimates

To address the study’s second question (the reliability of this methodology

to produce sound fire hazard estimates), we first identified the

assumptions underlying key data and methodological steps in the process.

We reviewed each data source separately to identify the analytical and

statistical limitations accompanying the assumptions on which the

information was based. When we identified limitations, we compared

CPSC’s process to date with various analytical and statistical methods for

testing reliability. For example, we assessed the potential implication of

NFPA’s response rate on the soundness of the data, determined what

statistical techniques could help assess the effect of these uncertainties,

and spoke with CPSC staff to determine the extent to which they had

conducted their own tests of these uncertainties. We focused more

detailed testing on three specific assumptions: the representativeness of

data used to make NFPA’s national fire estimates; the representativeness of

data in NFIRS; and CPSC’s classification of fires the standard would address,

including fires with and without a known item of origin or ignition source.

To assess the representativeness of the data used in the national fire

estimates, we conducted two types of analysis. First, we compared NFPA’s

national estimate of total fire deaths with the number of national fire

deaths compiled by CDC. Because CDC obtains information from all death

certificates in all 50 states and the District of Columbia, we concluded that

the data were a valid basis for comparison. Second, we obtained from NFPA

information on the margin of error around its national estimates of fires,

deaths, injuries, and property damages.

To assess the representativeness of data in NFIRS, we compared the

distribution of NFIRS fire departments by size with the distribution of fire

departments nationally. We did so by categorizing fire departments by

using the size of the population they protected as a proxy for fire

department size. To do this, we needed more data than were available in

NFIRS. We matched NFIRS fire departments with the NFPA database and used

the NFPA population data in those cases where a fire department appeared

on both databases. We also conducted a similar analysis comparing the

distribution of fire departments based on the type of fire fighting

personnel employed (paid or volunteer) and the severity of fires reported

by each category of fire department.

Page 19 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix I 

Scope and Methodology

To evaluate CPSC’s calculation of fire losses expected to be addressed by

the potential standard, we used data available in NFIRS to recategorize fires

the standard is not designed to address. We conducted this analysis using

information from CPSC and 1997 NFIRS data. To identify those fires the

potential standard is not designed to address, we used other information

in the NFIRS database such as the type of material ignited first, the situation

that resulted in contact between a heat source and flammable material, the

equipment involved in the ignition, and the area of the house where the

fire started.

As a result of these analyses, adjustments were made to (1) the raw

number of upholstered furniture fires and fire losses known to have

resulted from small open flames or cigarettes; (2) the raw number of fires

with an unknown origin and/or heat source that are allocated to

upholstered furniture fires the standard is intended to address; and (3) the

weights, or multipliers, used to project the raw NFIRS numbers into national

estimates. Table I.1 shows the effect of these adjustments on fire loss

estimates that the standard is designed to address.

Table I.1: Reduction in Fire Loss

Estimates Based on Recategorization

of Fires That the Standard Is Not

Designed to Address Fire loss type

Recategorized

fires with a

known source or

origin

Recategorized

fires with an

unknown source

or origin Total

Deaths 87 65 152

Injuries 296 138 434

Property damage $48 million $22 million $70 million

To determine the impact these adjustments have on CPSC’s estimate of

potential benefits, we used a two-step process. First, we compared the

total cost of fire losses based on national estimates resulting from our

adjustments with the total costs from CPSC’s national fire loss estimates.

Then we applied the difference between CPSC’s and our total cost estimates

to CPSC’s estimate of potential benefit from the standard.

A general limitation of our analysis was that it did not review the scientific

basis for the effectiveness of the potential standard. Laboratory testing to

show the extent that the standard would prevent different types of

upholstered furniture fires is ongoing, according to CPSC. Rather, the scope

of our work was limited to reviewing whether the methodology for using

existing data was sufficiently reliable to produce sound fire loss estimates.

Page 20 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix II 

Comments From the Consumer Product

Safety Commission

Page 21 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix II 

Comments From the Consumer Product

Safety Commission

Page 22 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix II 

Comments From the Consumer Product

Safety Commission

Page 23 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix II 

Comments From the Consumer Product

Safety Commission

Page 24 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix II 

Comments From the Consumer Product

Safety Commission

Page 25 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix II 

Comments From the Consumer Product

Safety Commission

Page 26 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix II 

Comments From the Consumer Product

Safety Commission

Page 27 GAO/HEHS-00-3 Furniture Flammability Standard
Appendix II 

Comments From the Consumer Product

Safety Commission

(101823) Page 28 GAO/HEHS-00-3 Furniture Flammability Standard
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