# A.I.U.F.F.A.S.S.

Association lnternationale des Utilisateurs de Fils de Filaments Artificiels et Synthetiques etde Soie Naturelle
International Association of Users ofArtificial and Synthetic FilamentYarns and of Natural Silk



### TO THE OFFICE OF THE SECRETARY U.S. NUCLEAR REGULA TORY COMMISSION WASHINGTON. D.C. 20555-0001
Attn:**BYI.~m~KLIJ9§ ~m:t,A.djudications_Staff** 



### A.I.U.F.F.A.S.S. is the Association of European silk and man made filament weavers and represents 95% 

### of European silk users (twisters, weavers and finishers) mainly located in Italy and France.
You will find herewith enclosed a petitioning for rulemaking that A.I.U.F.F.A.S.S. is submitting with the aim of amending the Standard for the flammability of clothing textiles 16 CFR 1610 that was published in the Federal Register (vol. 73, No. 58) in March 25, 2008. Here is our contact reference: g.tettarnanti@unindustriacomo.it


### We thankyou for taking our petition into proper consideration.
Yours sincerely,

January, 27, 2015

Encl.

Guido Tettamunti 

### Franc Ghiringhel\i A.I.U.

. 

### .5.5. President

Via Raimondi I

- 22I00 Como- T. +39 031 234 280- Mobile: +39 3292297499- Email: g.tettamantl@unlndustrlacomo.it Laurninc Panaye 2 rue des Miiriers 69009 Lyon- T. +33 4 72 53 72 OS Email: lpanaye@unitex.frA.I.U.F.F.A.S.S. PETITIONING FOR AMENDING THE STANDARD FOR THE FLAMMABILITY OF CLOTHING TEXTILES (16 CFR 1610) REGARDING SILK PRODUCTS

PETITIONER

A.I.U.F.F.A.S.S. is the "INTERNATIONALASSOCIATION OF USERS OF ARTIFICIAL AND SYNTHETIC FILAMENT YARNS AND OF NATURAL SILK". It comprises Silk Weavers from Italy, France and Switzerland, representing 95% of European silk weaving industry. They are usual suppliers of luxury brands in Italy, France and all over the world. It is supported by Ufficio Italiano Seta (Como, Italy), lntersoie (Lyon, France) and Swiss Silk Group, (Zurich, Switzerland), the most important groups of silk entrepreneurs in Europe. A.I.U.F.F.A.S.S. Head Office is: Villa Creatis- 2 rue des Muriers- 69009 Lyon FranceTelephone +33(0)472537205 E.mail: lpanaye@unitex.fr or g.tettamanti@unindustriacomo.it

STATUTE UNDER CONSIDERATION: STANDARD FOR THE FLAMMABILITY OF CLOTHING TEXTILES (16 CFR 1610)

The latest amendment to the Standard for the flammability of clothing textiles 16 CFR 1610 was published in the Federal Register (Vol 73, No. 58) on March 25, 2008. All clothing textiles (fabrics and garments) for adults and children (except children's night clothes, which are subject to Standards 16 CFR 1615-1616) fall within the scope of Standard 16 CFR 1610.CRITICAL ASPECTS OF 16 CFR 1610 

### concerning silk products

1. Technical approach
According to the procedures foreseen by Standard 16 CFR 1610, the sample of fabric is first tested in its original state (ready for use as a clothing article), then, if found acceptable (class 1), subjected to further testing after having been refurbished as required. Before running the test, the specimens need to be dried in an oven at 1

# osoc for 30 minutes, then placed in a desiccator and left to cool for at least 15 minutes. The fabric. as a result of such treatment. loses all its humidity content. This is an extreme condition not found in reality. Silk in its natural state and under normal conditions of use, as silk garment, is a hygroscopic material and its relative humidity is about 11% and never less than 9%.

There are exceptions to the provisions foreseen by Standard 16 CFR 1610. The Standard does not apply to specific kinds of hats, gloves, interlinings, etc. and a few special cases where products can be exempted from testing. The first case for exemptions is for "Plain surface fabrics weighing 88.8 g/m2 

### (2.6 oz/ya2) 

### or greater, regardless offiber content".

There is no scientific evidence to support the upper limit of 88.8 g/s.m (2.6 oz/ s.ya), it is a simple matter of experience and tradition. A.I.U.F.F.A.S.S. has conducted almost 130 tests on silk fabrics of different structures with a weight between 20 and 88 g/m2, each one of these single fabrics has been tested according to the Standard 16 CFR 1610 and it has been classified Class 1. Several reports are assembled in Annexe 1.
Lightest silk fabrics sometimes may be only a little bit below the limit set for conformity, but A.I.U.F.F.A.S.S. has also done laboratory tests which demonstrate that the conditioning atmosphere is the real critical point of the Standard 16 CFR 1610.15 samples of different silk fabrics with a mass per unit less than 30 g/m2 were tested in accordance with the conditioning conditions described in the Standard 16 CFR 1610 (30 min at 105°C} versus the standardized conditions oftest (according to ASTM 1776-04* and/or ISO 139**): 20°C- 65%HR

*ASTM 1776-04: Standard Practice for Conditioning and Testing Textile **ISO 139: Standard atmospheres forconditioning and testing

The results are summarized in the following table:

16 CFR 1610 Conditioning ofsamples: 30 min at 105oC Humidity ofsamples: 0 %HR
Average weight g/m2 burning time Class

21 2,9 3 21 3,1 3 22 3,1 3 10 2,8 3 17 3,3 3 17 3,6 1 19 4,7 1 19 IBE 1 19 3,1 3 24 4,4 1 24 4,2 1 26 5,9 1 27 5,1 1 30 IBE 1 30 IBE 1 IBE =IGNITION BUT EXTINGUISHED The reports are assembled in Annexe.2 ISO 139 "testing conditions for apparel/textile" Conditioning of samples": Temperature : 20°.±. 2oc Humidity: 65.±. 4% HR Average burning Class time 3,6 1 3,5 1 3,8 1 3,9 1 3,6 1

5,3 1

The overwhelming majority of silk fabrics can reach a performance Class 1 when they
are conditioned in the standard humidity ratherthan subjected to the conditioning oven and desiccator at 0 percent humidity.Standard 16 CFR 1610 foresees very severe conditioning requirements that are not developed according to usual international methods and that are not adequate for testing the flammability of silk fabrics for apparel.

2.Scientific approach

The second case for exemptions is for "Plain or raised surface fabrics, regardless of fabric weight, made, entirely or in a combined form, from the following fiber types: acrylic, modacrylic, nylon, olefin, polyester, wool."

Scientific community at international level has no discussion at all about the fact that silk is considered among the less flammable fibers, as well as wool. Silk is a protein fiber. It burns slowly, it tends to self-extinguish, in contact with a flame it is difficult to ignite.

The flammability behaviour of fibers is scientifically represented by L.O.I. (limiting oxygen index) value, which is the most authoritative measure of flammability characteristics oftextile. L.O.I. provides a measure of flame retardancy through the amount of oxygen needed to support combustion.

In the following table, you'll find L.O.I.% value for some textile fibers available in literature

Cotton PET silk wool 16- 17 20-22 22-23 24-25

L.O.I. for silk (22-23) is very similar to nylon (22-24, exempted from testing) and it is much less flammable than polyester (20-22, exempted from testing) and acrylic (18- 20, exempted from testing).

There is no scientific reason to submit silk to mandatory testing.3.Consumer Safety approach
European silk weavers are well aware of the utmost importance of consumer safety. They are striving for improving these aspects in the sake of final consumers. They supply international markets and their European silk fabrics do not face any problem at all with flammability standards all over the world but in the U. S.

As far as we know, silk fabrics do not exhibit "rapid and intense burning". Italy and France have a very long tradition in silk industry. In these two European countries silk fabrics and clothes have been produced since the 151 h Century. Manufacturers have neither produced nor sold items "so highly flammable as to be dangerous when worn by individuals". The precautionary principle applies to internal market and external trade. As you know, this principle has been even enshrined in the French Constitution. For all we know in Europe no injuries from silk goods consumption have ever been recorded. European manufacturers of silk fabrics and items are fully conversant with whatever may jeopardize consumers' health and safety. They are unwilling to imperil their own customers. They obviously have the same respect for public security and the same ethical behavior towards American customers.

There is no relevant safety reason for impeding the free commercial movement ofsilk goods

4.Economic approach

U.S. market is fundamental for European Silk Industry and Standard 16 CFR 1610, with its complex certification procedure, has affected severely European exporters of silk products.
European silk sales always consist of several lots of small quantities and they regard fashion articles which always vary deeply, according to various colours and various patterns developed on various kinds offabrics.

### For this reason the economic impact of certification procedures on E.U. industry has been very relevant also because customers are used to reverse it entirely on their suppliers.

CONCLUSION AND REQUEST FOR AMENDMENTS

For all the reasons stated above, A.I.U.F.F.A.S.S has been asking for long to include silk in the exemption list. As there has been no agreement on this from the CPSC, A.I.U.F.F.A.S.S is now asking for the following amendments to be included in 16 CFR Part 1610.



### The comments are mainly linked to the conditioning procedure of the specimen tests foreseen by 16 CFR 1610 in order to align them with international practice ISO standard 139 and/or ASTM 1776-04

In the past even the National Cotton Council of America suggested that cotton fabrics should have been tested in standard humidity conditions. In its answer, Consumer Product Safety Commission stated that more severe conditions in the Standard could provide a greater level of safety, but it also acknowledged N.C.C argument was right.

As far as we know, Standard 16 CFR 1610 is one ofthe only case of standard in which it is required such an extreme conditioning for textile. The national standards of E.U. countries (UNI, BS, DIN, etc.), European EN standards, and I.S.O standards for clothing (including protective type) and furniture provide conditioning oftest specimens in the standard atmospheres for textile texting (20 or 23° and 50 or -65% R.H.) Even ASTM 1776-04 foresees that all fabrics should be tested in standardized humidity. It should be noted, also, that the tests relating to protective clothing are carried out after conditioning in a standard atmospheres according to ISO 139

For all reasons stated above, AIUFFASS submits the following amendments describing the procedure for testing with normal humidity instead of 0% humidity:

### § 1610.6 Test procedure (a) Step ]-Testing in the originalstate. (2) Plain surface textilefabrics:

... (iv) Condition specimens. Remove: 

### 64U**specime1~s me1:t1~kd**  

### iri F.'-ie heldeF!i shatlffien heplacedin a herifentalpesitie1'l en an epen Hwtal she/fin F.'-ie eveN tepermitfree eiFeHlatien &jail' aFeHnd**theH~.** The speciHiens shaU he dried**i1~** ffie even fer 3(} ,r, 2 HiiliHtes at 1(}5o,r,J 'G (221 °,r, 5 °F}, reHie';edfrem the eve19 andplaeedever a bed**&ja1~hy'6h•e1:ts** silicagel desiccant**i1~** a riesiecate1' Hntil ceel, hHt**1~et** lessffian l5**Hiii~Htes.)** Replace with:
All specimens mounted in the holders shall then be placed in a horizontal position in the standard atmosphere for testingtextiles, which is 21 

### ± 1 

# oc (70 

### ±2°F) and 65 

### ±2% relative humidity for at least 24 h. accordingto the atmosphere defined in ASTM 1776-04 The specimens before to be removed from the standard atmosphere shall be placed in a tight container and the test shall be initiated within 1 min after the opening ofthe container.
Idem for (3) Raisedsurface textile fabrics- (v) Condition specimens.



### § 1610.6 Test procedure.

Modification of: (b) Step 2-Refurbishingandtestingafter refurbishing. (1) The refurbishingprocedures are the samefor bothplain surface textilefabrics andraised fiber surface textilefabrics. Those samples that result in a Class 3, RapidandIntense Burning after Step 1 testing in the ''as received'' or original state shall not be refurbished anddo not undergo Step 2. (i) Dry cleaningprocedure. (A) Allsamples shall be dry cleanedbefore they undergo the laundering procedure. Samples shall be dry cleaned in a commercialdry cleaning machine, using thefollowingprescribedconditions: Solvent: Perchloroethylene, commercialgrade Detergent class: Cationic Cleaning time: 10-15minutes Extraction time: 3 minutes Drying Temperature: 60 ¥66 °C (140 ¥ 150 °F) Drying Time: 18-20minutes Cool Down/Deodorization time: 5 minutes(B) Samples shall be dry cleaned in a loadthat is 80% of the machine's capacity. 

## If necessary, ballast consisting of clean textilepieces orgarments, white or light in color and consisting of approximately 80% wool and20%polyester, shall be used. (ii) Launderingprocedure. The sample, after beingsubjectedto the dry cleaningprocedure, shall be washedanddried one time in accordance with sections 8.2.2, 8.2.3 and8.3.1(A) of AATCC TestMethod 124-2001 ''Appearance of Fabrics after RepeatedHome Laundering.'' Washing shall beperformed in accordance with sections 8.2.2 and8.2.3 of AATCC Test Method 124-2001 usingwash water temperature (V) (149° ± 5 °F; 60° ± 3 °C) specified in Table IIof that method, andthe water level, agitator speed, washing time, spin speedand final spin cycle specified for ''Normal/Cotton Sturdy'' in Table III. A maximum wash load shall be 8pounds (3.63 kg) andmay consist of any combination of test samples anddummy pieces. Dryingshall beperformed in accordance with section 8.3.1(A) of that test method, Tumble Dry, using the exhaust temperature (150° ± 10 °F; 66° ± 5 °C) andcooldown time of 10 minutes specified in the ''Durable Press'' conditions of Table IV (2) Testingplain surface textilefabrics after refurbishing. The testprocedure is the same asfor Step ]-Testing in the "as received" or original state described inparagraph (a)(l) of this section; also follow the test sequence§ 1610. 7(b)(2). (3) Testing raised fiber surface textilefabrics after refurbishing. The testprocedure is the same asfor Step ]-Testing in the ''as received'' or originalstate as described inparagraph (a)(3) of this section; alsofollow the test sequence in§ 1610. 7(b)(4).

Add here the following sentence: (4) Before performingthe test, accordingto test procedure described as for Step 1the specimen pre-treated will have to be conditioned accordingto the atmosphere defined in ASTM 1776-04 which is: 21 ± 1

## oc (70 ± 2°F) and 65 ± 2% relative humidity"Da: Inviato: 

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