CPSC OGC Advisory Opinion No. 27

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August 29, 1973

Anthony F. Essaye, Esquire

Royal 1, Koegel ts \·!el1s

1730 K. Street, N.W.

Washington, D. C.

20006

Dear Tony:

This is in response to your letter of July 3, 1973, 1n which

you indicate problems mattress manufacturers are encountering in

obtaining appropriate sheets and binding tape to coDply with the

requirerr:ents of the Flammabil1ty Standard for Mattresses.

The Car.mission recognizes the potential problem 1n the

i

1

supply of 100 percent combedcotton percale sheets, as indicated

~ •

by the ar:~2nd;:,cnt to section

.4{b)(6) of the Standard,

\·1hich al10:-1s

approval of other types of she;ets.

A CoLmiiss1on investigation

has ...

alternate

types of sheets on an interim basis.

As to binding tape, 1t 1s our opinion that the definition of

"mattress prototype" in section .l(h) of the Standard would allow

ter,1porary substitution

of other types of tape, provided data sub­

mitted sho~s to the Cor:Jission's satisfaction

that the alternate

tape 1s not l css cigJ.rcttc

rcsist.:i.nt them the polyester

tape.

i-:e

will be happy to rev1ev any data submitted on th1s point.

Sincerely,

Michael A. Brown

Acting General Counsel

rcve.iled at leas

It

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ti-

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percale she:ets:

Therefore,

the

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MAFreeston/MABrown:tdr:8/29/73

cc:

Sc:rctary

- Official Files

S. Parent

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M. Fre.::stcn