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Good morning.

I am Tony Wolf, a cotton batting, mattress, and futon manufacturer from Fort Wayne, IN. My family’s company, The Wolf Corporation, was founded in 1873 and has been a cotton, bedding and upholstery manufacturer for more than 130 years.

I am here today representing the National Cotton Batting Institute and serve as its President.

The National Cotton Batting Institute represents U.S. companies that manufacture and sell batting for use in mattresses, futons, home furnishings, and upholstered products. The Institute has a long record of research and development leading to safe and cost-effective products that meet or exceed current open-flame and smolder-ignition standards.

Any Institute member that supplies flame resistant cotton batting for mattresses, futons and upholstered furniture must comply with the Institute’s certification program that is based on federal and state standards and ASTM testing procedures. Underwriters Laboratory, as an independent third party, monitors compliance with the program, inspecting the products of each manufacturer on a quarterly basis for compliance with flammability standards.

Mr. Chairman, our industry thanks you for holding this hearing on 16CFR 1633, the proposed standard for the open flame flammability of mattress and mattress foundation/sets. Our industry has advocated the need for such a standard that goes beyond the current federal standard requiring mattresses and mattress pads to be resistant to cigarette ignition. We commend the Commission for developing this broader rule that addresses open flame ignition and are pleased to offer comments in support of the standard.

The Institute has supported adoption of the full-scale test method incorporated in California Technical Bulletin 603 (TB603) as the basis for a national standard. CPSC staff has been diligent in its research into the issue and its approach to testing. The attempt to gather comments from all segments of the sleep products industry has provided ample opportunity for input from manufacturers and component suppliers having a stake in the issue.

Based on a review of capacity within the industry, the Institute agrees with the Commission staff’s assessment that the alternatives in flame retardant chemicals and flame resistant materials are sufficient to provide wide flexibility in meeting a mattress flammability standard, and that the environment and human health will not be adversely affected by the use of these materials.

We urge the Commission to establish a fast track to implementation of this standard. California’s record of success in establishing a new law bodes well for a successful implementation of a national standard.

We also recommend that the Commission incorporate appropriate steps to enforce the standard, particularly against manufacturers that are found deliberately attempting to circumvent the law. These penalties should be progressive, with little flexibility for first offenders.

In addition to providing these comments and suggestions in support of a national mattress flammability standard, I want to address briefly questions that have been raised about the effect of materials used to render cotton batting flame resistant on the environment and human health.

A process developed by the USDA’s Agriculture Research Service more than 30 years ago is the standard applied today to produce a safe flame-resistant and smolder-resistant cotton filling.

The system of applying boric acid, a boron-based product derived from borates, to the cotton fibers was developed in a cooperative research project by the National Cotton Batting Institute and ARS scientists at the Southern Regional Research Center in New Orleans to meet the standards of the day.

Mattresses constructed with boric acid-treated cotton batting fared extremely well in flammability testing leading up to the adoption of the California standard.

Cotton properly treated for flame resistance is self-extinguishing. Use of treated cotton batting in mattresses, futons, and upholstered furniture significantly reduces the risk of injury because of its negligible burn factor and reduced emission of toxic fumes.

As for health and safety, the record speaks for itself: There are millions of mattresses in use today that contain boric acid-treated cotton, and there is no record of human health risk related to sleeping on mattresses containing this combination of materials.

Some question the toxicity of boron and in particular boric acid. Toxicological research that addresses human health and environmental effects of boric acid and borates has shown them to be safe in consumer products. They have low intrinsic toxicity and there is essentially no exposure to borates from these products, since the boric acid-treated batting is inside the product and does not dust out of the cotton batting. Toxic doses to humans are unattainable from use of boric acid in mattresses, futons, and upholstered furniture.

Last August, the National Center for Environmental Assessment raised the allowable daily dose of human consumption of boron. The NCEA is the division of the Environmental Protection Agency charged with assessing health risks associated with substances found in the environment.

The increase from 6.3 milligrams to 14 milligrams was the result of a multi-year assessment of more than 200 studies on boron's health effects.

The great benefit of boron-treated cotton batting is boric acid’s ability to be absorbed into the cotton fiber. However, as with any water-soluble compound, it is possible that some of the boric acid could be removed from the inner core of the bedding if water penetrated that deep. For that to happen, however, would require water damage sufficient to result in the total loss of the bedding or upholstered furniture.

Like cotton, boric acid is a safe product that also is used in products consumers use every day – in pharmaceuticals, topical medicines for skin and even contact lens solution. It also is a necessary micronutrient to produce the fruits and vegetables we eat every day.

Our greatest exposure to borates is the one to three milligrams we eat every day, but we also encounter borates in countless household items - from wallboard and insulation to cookware and eye drops.

The National Cotton Batting Institute continues to monitor and refine the process of developing flame retardant cotton. Currently, we are gathering additional evidence that our product, cotton and borates, is very innocuous and presents no human health risk when properly used as a fire barrier in mattresses. We will present this evidence in written comments to the Commission later this month.

Mr. Chairman, I hope that this brief review sheds some light on how borates are used in creating a safe, cost-effective flame retardant for use in producing flame resistant mattresses, futons, and upholstered furniture.

In summary, the National Cotton Batting Institute supports the adoption of the proposed national flammability standard for mattress and mattress foundation/sets. Enforcement of this standard will greatly improve the safety of today’s sleep products.

Thank you for the opportunity to provide these comments.