How to get a 16 CFR Part 1213 Test Report?

The U.S. Consumer Product Safety Commission (CPSC), from the perspective of protecting human health, has established safety standards for adult and children’s bunk beds. The 16 CFR Part 1213 "Safety Standard for Entrapment Hazards in Bunk Beds" outlines the requirements for adult bunk beds, while 16 CFR Part 1513 "Requirements for Bunk Beds" specifies requirements for children's bunk beds. However, the requirements in both standards are essentially the same. Additionally, 16 CFR Parts 1632 and 1633 specify flammability requirements for mattresses.

CPSC also issued accreditation requirements for third-party conformity assessment bodies for toddler beds, mandating that all toddler beds must pass testing by a CPSC-accredited third-party testing laboratory such as JJR Laboratory before being marketed in the U.S.

Bunk Bed Safety Requirements (16 CFR 1213 & 1513)

Both 16 CFR Part 1213 and 1513 require that bunk beds meet the following criteria:

1. Guardrail Requirements

a. If the lower bunk’s foundation is more than 30 inches (760 mm) above the floor, at least two guardrails are required—one on each side of the upper bunk.

b. The guardrail on the wall side must be fully attached to the headboard and footboard, with no gaps larger than 0.22 inches (5.6 mm) between the guardrail and bed ends to prevent finger entrapment.

c. The guardrail on the non-wall side may have openings at each end less than 15 inches (380 mm) from the head and foot of the bed.

d. For bunk beds with a ladder on one side, the full-length guardrail must be installed on the opposite side.

e. Guardrails must not be removable unless deliberate loosening of hardware is required.

f. After placing a mattress of specified thickness, the vertical distance from the mattress surface to the top of the guardrail must be at least 5 inches (130 mm).

g. Without the mattress, there must be no structural openings between the upper bed slats and the bottom of the guardrail.

Inspectors must measure three areas: guardrails, the head and foot structures of both the upper and lower bunks. These areas must be evaluated using three test probes: a wedge block, a spherical probe, and a neck probe to detect potential hazards.

2. Labeling Requirements

1. Each bunk bed must carry a permanent label showing the name and address (including city, state, and zip code) of the manufacturer, wholesaler, or retailer, along with the product model and date of manufacture.

2. A permanent safety warning label must be placed on the inside of the upper bunk where it will not be covered by bedding (though it may be covered by a pillow).

3. Instruction Manual

Manufacturers must provide an instruction manual including:

1. Mattress and bed slat dimensions (length, width, and maximum mattress thickness that complies with guardrail height requirements).

2. The following safety warnings:

a. Children under 6 years old should not use the upper bunk.

b. Guardrails must be used on both sides of the upper bunk.

c. No horseplay on or under the bed.

d. Only one person is allowed on the upper bunk.

e. The ladder must be used to access and exit the upper bunk.

f. If placed against a wall, the side with the continuous guardrail must be next to the wall to prevent entrapment between the bed and the wall.

Flammability Requirements for Mattresses and Pads – 16 CFR Part 1632 (Cigarette Ignition Test)

16 CFR Part 1632 applies to all mattresses made in or imported into the U.S., including:

1. Mattresses for adults, children, and infants (including portable cribs),

2. Bunk bed mattresses,

3. Mattresses with cores for waterbeds and airbeds,

4. Sofa beds.

Exemptions: sleeping bags, mattress pads without cores, airbeds without cores, and sleeping chairs.

Test Method:

1. A mattress passes if the char length from the cigarette ignition point does not exceed 2 inches (50.8 mm) in any direction.

2. Typically, at least 18 cigarettes are tested.

3. A mattress fails if any one ignition site exceeds the standard.

4. Products treated with flame retardants must be labeled with a “T” to indicate treatment.

Flammability Requirements for Mattress Sets – 16 CFR Part 1633 (Open Flame Test)

California implemented new flammability regulations in 2004 (TB 603), which became mandatory in 2005. The 16 CFR Part 1633 standard, based on TB 603, was introduced by the CPSC on March 15, 2006, and enforced from July 1, 2007. TB 603 was repealed on this date.

Scope:Applies to all imported, manufactured, or refurbished mattress sets (mattress and foundation) or standalone mattresses after the effective date.

Test Method (open flame):

1. Peak heat release ratemust not exceed 200 kW during the 30-minute test period.

2. Total heat releasein the first 10 minutes must be below 15 MJ.

3. A minimum of three samples must be tested. A mattress fails if even one sample fails both criteria.

Documentation and Labeling:

1. Manufacturers must maintain documentation and provide permanent labels to prove compliance.

2. Labels must include:

a. Manufacturer name,

b. Manufacturer address (street, city, state),

c. Month and year of manufacture,

d. Model identification number,

e. Prototype identification number,

f. Certification that the product meets the standard.

Mandatory Standard for Toddler Beds – 16 CFR Part 1217

In April 2011, the CPSC issued 16 CFR Part 1217 “Mandatory Standard for Toddler Beds,” based on ASTM F1821-09. It applies to toddler beds and converted cribs.

The standard addresses hazards such as:

1. Entrapment at the headboard,

2. Entrapment between the guardrail and side slats,

3. Failure of mattress support systems or components,

4. Risks of clothing being snagged on extended corner posts.

To prevent falls and injuries, the standard mandates:

1. Guardrails must extend at least 5 inches above the mattress surface;

2. Guardrail testing force increased from 177.9 N to 222.4 N;

3. Static load testing of fixed components (guardrails, sides, slats) requires 355.8 N;

4. Separate permanent warning labels must be applied for both entrapment and suffocation risks.

Additional Regulatory Requirements for Toddler and Infant Beds

Toddler and infant beds must also comply with the following hazardous substances bans and standards:

1. 16 CFR Part 1303– Ban on lead-containing paint and certain products bearing such paint;

2. 16 CFR 1500.48– Sharp metal or glass edge testing for toys and similar products for children under 8;

3. 16 CFR 1500.50– Simulated use/misuse testing for toys and articles used by children;

4. 16 CFR 1501– Small parts regulation for toys intended for children under 3, addressing choking, ingestion, and inhalation hazards.

Summary of U.S. Laws and Regulations Applicable to Furniture

Furniture must comply with both environmental legislation and safety regulations issued by the U.S. CPSC under the Consumer Product Safety Act (CPSA). These are categorized into two main areas: hazardous substancesand product safety.

Major U.S. Acts and Corresponding Furniture Industry Requirements:

Acts (Environmental & Chemical Safety):

1. Clean Air Act – Controls VOCs and other pollutants;

2. Clean Water Act – Prevents harmful discharges;

3. Emergency Planning and Community Right-to-Know Act – Mandates disclosure of hazardous substances;

4. Federal Insecticide, Fungicide, and Rodenticide Act – Controls chemical treatments in materials;

5. Marine Protection, Research and Sanctuaries Act – Regulates marine waste disposal;

6. Resource Conservation and Recovery Act – Governs hazardous waste;

7. Safe Drinking Water Act – Prevents toxic contamination in water;

8. Toxic Substances Control Act – Governs all hazardous chemicals.

CPSC Safety Regulations:

1. 16 CFR Part 1213 – Bunk bed entrapment hazards standard;

2. 16 CFR Part 1303 – Lead paint ban;

3. 16 CFR Part 1500 – Hazardous substances regulation;

4. 16 CFR Part 1513 – Bunk bed structural safety requirements;

5. 16 CFR Part 1632 – Mattress flammability (cigarette test);

6. 16 CFR Part 1633 – Mattress set flammability (open flame).