Fire, Legalities and Wool

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The story goes, in the seventies, when everyone lit up and the number of deaths due to cigarettes in bed was rising, tobacco companies were urged to make their cigarettes safer.  However, since the best way to make cigarettes safer would be to not use them, tobacco companies went another route.  The three Big Tobacco Companies created an alliance called Citizens for Fire Safety. This committee lobbied heavily for flame retardants to be put into bedding and other products.

Now that media has exposed who is actually behind the Citizens for Fire Safety, the tobacco companies have disbanded that committee for a new one. However, their previous website can still be found. Their new alliance is called North American Flame Retardant Alliance. The Chicago Tribune does a good job exposing their recent manipulation of a particular legislation.


Because of current legislation that was initiated in the seventies by these companies, mattress producers must pass a smolder test and a burn test of their product. The smolder test is outlined in law 16 CFR 1632. It specifically “measures the ignition resistance of a mattress or mattress pad by exposing the surface to lighted cigarettes in a draft-protected environment…At least 18 cigarettes are burned on each mattress test surface, 9 on the bare mattress and 9 in between sheets placed on the mattress…Individual cigarette test locations pass the test if the char length is not more than 2 inches (5.1 cm) in any direction from the nearest point of the cigarette. “

The burn test is outlined in law 16 CFR 1633. A burn lab will burn a minimum of three mattresses and box springs, at about a $600 per mattress. The mattresses are ignited with a pair of open flame propane burners, much like a blow torch, on the side and the top of the mattress. The test measures how quickly the mattress burns, how hot it burns and how quickly the flame extinguishes after the torch is removed. To pass, your mattress must self extinguish in a particular amount of time as well as only have a certain percentage of surface area burned.


If you have read this far, you’re wondering what we do about this legislation. Quite simply, it doesn’t apply to us, so we don’t have to do anything.

We sell supplies, parts that would be useful if you wanted to assemble them to make your own mattress. You can make a mattress out of our parts, just as you could out of a few bales of straw and a futon case. True, unzipping a three-sided zipper on a piece of ticking and stuffing it full of latex or wool is not difficult for either us or a customer to do, but we deliberately do not assemble mattresses.

Our supplies model enables us to be exempt from the burn test law. Both laws define mattress as follows “Mattress means a resilient material or combination of materials enclosed by a ticking (used alone or in combination with other products) intended or promoted for sleeping upon.”

We do not sell parts enclosed in ticking, so we need no fire barrier and no burn test. No burn test for us, no chemicals and no government agency deciding what you can and can’t sleep on.


Interestingly enough, our quilted ticking could pass the test. Wool is a natural fire barrier, especially when it is compressed so tightly that air, which fire needs to live, cannot penetrate it. The company who makes it for me reports many of their customers passing the burn test with it.

Testing over many years has confirmed that the high keratin protein and moisture content of wool make it naturally resistant to burning. It is difficult to set alight under most conditions and burns only weakly, forming a cold char, which tends to extinguish burning. It is important to note that wool is naturally fire resistant, not a fire retardant. Fire retardants reduce the flammability of materials by either blocking the fire physically or by initiating a chemical reaction that stops the fire. Pure wool without any added chemical fire retardants performs well as a fire barrier if it is used in the proper weight (app. 1.8 oz per square ft.) and is either mechanically densified (needle punched) or densified by the quilting process itself. Wool will burn at 600 degrees F; however if air is removed from the batting by densification, it performs very well and will pass the CFR 1633 burn test. This has been proven time and time again by many credible mattress manufacturers.

There are certain types of processed wool that perform better than others. Not performing well is wool batting that contains synthetic bonding agents; this batting sometimes does not act as a robust fire barrier due to the synthetic polyester used to bond the wool batting together. Another type of wool, raw grease wool is required by law to be scoured or cleaned and cannot be used as fire barrier in its uncleaned state. Some commercial wool available to bedding manufacturers is chemically scoured with hydrochloric acid. This process causes carbonization which strips the wool fiber of lanolin and even can destroy the outer sheath of the wool fiber itself, thus diluting its natural fire resistant properties. Carbonization is the term for the conversion of an organic substance into carbon or a carbon-containing residue through pyrolysis or destructive distillation. Carbonized wool smells like chemicals and is often bleached; two very good reasons we avoid it at all costs. The best performing wools are wools that are scoured in a mild biodegradable detergent without removing all the lanolin or stripping the outer sheath of the wool fibers. Natural pure wool processed in this fashion will pass CFR 1633 burn tests with very good results if used in the proper weight (1.8 oz per sq. ft).

Wool grown on farms or ranches utilizing sustainable ranching techniques without the use of chemical pesticides and overgrazing on pastures that contain no chemical herbicides or chemical fertilizers is the best conditions for purity of the wool. This is our wool.

fancy line

To read about flame retardants and their ability to impact our health, view this short video.

For more details on chemicals and mattresses, visit People for Clean Beds.
Some on the details of wool borrowed from Mattress Consultant.

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