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

Association lnternationale des Utilisateurs de Fils de Filaments Artificiels et 

Synthetiques et de Soie Naturelle 

International Association of Users of Artificial and Synthetic Filament Yarns 

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 thank you 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 - 22 I 00 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.fr 
A.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 "INTERNATIONAL ASSOCIATION 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 of fiber 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 of test (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 for conditioning and testing 

The results are summarized in the following table: 

16 CFR 1610 

Conditioning of samples: 30 min 

at 105oC 

Humidity of samples: 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 rather than 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 of textile. 

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 

of silk 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 of fabrics. 
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 of the 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 of test 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 original state. 

(2) Plain surface textile fabrics: ... 

(iv) Condition specimens. 

Remove: 

64U specime1~s me1:t1~kd iri F.'-ie heldeF!i shatl ffien he placed in a herifentalpesitie1'l en an 

epen Hwtal she/fin F.'-ie eveN te permitfree eiFeHlatien &jail' aFeHnd theH~. 

The speciHiens shaU he dried i1~ ffie even fer 3(} ,r, 2 HiiliHtes at 1 (}5 o,r,J 'G (221 ° ,r, 5 °F}, 

reHie';edfrem the eve19 andplaeed ever a bed &ja1~hy'6h•e1:ts silica gel desiccant i1~ a 

riesiecate1' Hntil ceel, hHt 1~et less ffian l5 Hiii~Htes.) 

Replace with: 

All specimens mounted in the holders shall then be placed in a horizontal position in the 

standard atmosphere for testing textiles, which is 21 ± 1 oc (70 ± 2°F) and 65 ± 2% relative 

humidity for at least 24 h. according to 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 of the container. 

Idem for (3) Raised surface textile fabrics- (v) Condition specimens. 

§ 1610.6 Test procedure. 

Modification of : 

(b) Step 2-Refurbishing and testing after refurbishing. 

(1) The refurbishing procedures are the same for both plain surface textile fabrics and raised 

fiber surface textile fabrics. Those samples that result in a Class 3, Rapid and Intense 

Burning after Step 1 testing in the ''as received'' or original state shall not be refurbished 

and do not undergo 

Step 2. 

(i) Dry cleaning procedure. (A) All samples shall be dry cleaned before they undergo the 

laundering procedure. Samples shall be dry cleaned in a commercial dry cleaning machine, 

using 

the following prescribed conditions: 

Solvent: Perchloroethylene, commercial grade 

Detergent class: Cationic 

Cleaning time: 10-15 minutes 

Extraction time: 3 minutes 

Drying Temperature: 60 ¥66 °C (140 ¥ 150 °F) 

Drying Time: 18-20 minutes 

Cool Down/Deodorization time: 5 minutes 
(B) Samples shall be dry cleaned in a load that is 80% of the machine's capacity. If 

necessary, ballast consisting of clean textile pieces or garments, white or light in color and 

consisting of approximately 80% wool and 20% polyester, shall be used. 

(ii) Laundering procedure. The sample, after being subjected to the dry cleaning procedure, 

shall be washed and dried one time in accordance with sections 8.2.2, 8.2.3 and 8.3.1 (A) of 

AATCC Test Method 124-2001 ''Appearance of Fabrics after Repeated Home Laundering.'' 

Washing shall be performed in accordance with sections 8.2.2 and 8.2.3 of AATCC Test 

Method 124-2001 using wash water temperature (V) (149° ± 5 °F; 60° ± 3 °C) specified in 

Table II of that method, and the water level, agitator speed, washing time, spin speed and 

final spin cycle specified for ''Normal/Cotton Sturdy'' in Table III. A maximum wash load 

shall be 8 pounds (3.63 kg) and may consist of any combination of test samples and dummy 

pieces. Drying shall be performed in accordance with section 8. 3.1 (A) of that test method, 

Tumble Dry, using the exhaust temperature (150° ± 10 °F; 66° ± 5 °C) and cool down time of 

10 minutes specified in the ''Durable Press'' conditions of Table IV 

(2) Testing plain surface textile fabrics after refurbishing. The test procedure is 

the same as for Step ]-Testing in the "as received" or original state described in paragraph 

(a)(l) of this section; also follow the test sequence§ 1610. 7(b)(2). 

(3) Testing raised fiber surface textile fabrics after refurbishing. 

The test procedure is the same as for Step ]-Testing in the ''as received'' or original state 

as described in paragraph (a)(3) of this section; also follow the test sequence in§ 

1610. 7(b)(4). 

Add here the following sentence: 

( 4) Before performing the test, according to test procedure described as for Step 1 the specimen 

pre-treated will have to be conditioned according to the atmosphere defined in ASTM 1776-04 

which is: 21 ± 1 oc (70 ± 2°F) and 65 ± 2% relative humidity" 
Da: 

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