This is the story of how I came to make and sell DIY mattress kits, my experience in the mattress industry and what I needed to do to comply with The Federal Standards of Flammability for Mattresses.
If you are planning on making your own mattress, you need to understand the flammability regulations pertaining to DIY mattresses.
It all started in my back yard. I had just spent a frustrating week trying to figure out how I could afford three natural, chemical free mattresses for my family. My kids had outgrown their hand-me-down mattresses and my back was hurting from sleeping on my worn out foam mattress.
I was in pain. I was cranky. I got angry.
I was angry because I did not have thousands of dollars for a natural mattress which meant we would have to sleep on mattresses that contained untested, undisclosed flame retardant chemicals. Did you know that mattress tags do not have to disclose the type of chemical flame retardant the mattress contains? My research revealed the reasoning of the lawmakers was that our world is filled with these chemicals already! "How unfair," I thought, "that they could so casually make this decision for everyone".
Then, it hit me. I could make my own chemical free mattresses! I am an avid DIY'er and I make most things for my home verses buying them. Why did I not think of this first? I thought a mattress had to have a pretty quilted cover and last for 25 years. I imagined the cross section diagram of my new DIY mattress containing layers of varied natural materials. Looking back, I see that I was affected by years of mattress marketing. I field many questions a day, and I see that my customers have been too.
After spending a few weeks online, sorting through many blog posts and mattress forums, flame retardant chemicals and fire safety issues were now on my mind.
I felt like going back to a time before we relied so heavily on chemicals.
I could not find much history on mattresses. Basically, beds started out as boxed, wood frames supported off the ground and filled with readily available natural materials that could be easily fluffed and replaced as needed. I liked the sound of that. I do not remember where I read this during my research, but it stuck in my head: "Emperors slept on mattresses filled with hulls".
"If it was good enough for Emperors", I thought, "maybe there is something special about sleeping on hulls."
The next day, I ordered a bag of buckwheat hulls. I enjoyed working with them, smelling them, running my hands through them. I decided hulls would be my top layer. I still felt many different layers of materials were needed to make a comfortable mattress.
I decided to make a mattress topper first. Next, I thought I needed the spring from latex foam. I happened to have a roll of natural latex stored in the shed from an old furniture project. I rolled it out and put my new topper on it. Even though that was only part of the diagram in my head, it was good enough for now. My husband and I slept on that configuration for quite a while. I had an Etsy shop so I thought I would take a photo and make some custom ordered topper covers. They got some notice and I got busy thinking I could actually make this into a business.
My first hull mattress:
I was in my back yard again, thinking that buckwheat hulls must burn fairly easily and I wondered if I should recommend them to fill the mattress toppers.
I took out a match and held it up to a small pile of buckwheat hulls on my patio table. They did not ignite and I said, "that's strange". I went inside and got a lighter. Surely, the match was not hot enough. I then had to get my video camera. Balancing the camera in one hand and the lighter in the other, I took this shaky video.
Why do non-roasted buckwheat hulls not ignite? I thought they must with a bigger flame.
This also made me think "Why would anyone in their right mind want to sleep on foam? It is SO incredibly flammable that it should be the last thing anyone would choose to sleep on, and why does our Government enforce safety standards that pollute our world with chemicals and not focus on creating a truly safer sleeping environment by banning combustible mattresses fillings in the first place."
My husband broke is back rock climbing and he now has a fused spine. When he said, "Hey Babe, can we make the mattress a bit thicker? I do love it but I feel my back needs a bit more support", I was right on it. It took many prototypes, complicated labor and material intensive designs (the Original Twist) and hulls all over our house for many years, but I finally found the solution: tubular, stretchy fabric!
Once I filled and twisted my first tube, I knew this was going to be a lot of fun.
I came up with many designs using the tubular fabric because there were so many ways to twist it to come up with beautiful patterns and comfortable solutions. I put many of these designs up for sale. My inbox was flooded with excited customers wanting to know which design was best. They liked "this" about one design but wanted "that" from the other. I was making custom kits everyday. I knew if I wanted to continue my business, I needed a standard kit. I set out to combine the best aspects of each design into one easy to construct kit that used the least amount of materials to keep the price down.
The result was the New Twist Mattress Kit.
I had found an economical way to help others make their own mattresses. I contacted NY state to get my mattress license and they told me I did not need one, I was just selling materials to make mattresses and not a finished mattress. Ok, another great thing about these DIY kits but I still always wondered about the flammability issue. I did not know back then that the Sate and Federal levels of our Government do not coordinate their regulations very well and you have to check in with both levels of Government to get the whole story.
I thought if you made something yourself, or supplied materials to folks who want to make their own furnishings, the Government had no say in it, unless it was something known to be illegal. Turns out I was wrong.
In January of 2014 I received an email from a Compliance Officer with the Consumer Product Safety Commission. This agency, also referred to as the CPSC, told me if I marketed my materials as a mattress, under Federal Law, it needs to comply to the same regulations as any other mattress. Ok, this made sense and I wanted to comply. The Compliance Officer told me the first step was to send an email inquiry to the Commission asking if my kit was indeed a mattress to get an official ruling in return. I did and I expect one day the CPSC will rule my kit materials to be a mattress.
Even if they came back and said I did not have to comply, getting the flame testing done was just the right thing to do.
I was curious and excited about the tests. Could hulls be proven a safe mattress filling without the need for chemical flame retardants?
I found a Government approved lab 3 hours drive from where I live, also near where I grew up. This worked out well, as I could stay with family during the testing. I chose the option to view the burn tests. I was so curious about the process. Larger mattress companies simply pick up the phone and have a few mattresses pulled off the line and shipped to the lab for testing. I had a tight budget, so my situation was a bit different. I had to hand make five mattresses, load them into a rented cargo van and drive them to the lab myself.
This was one of the craziest experiences of my life!
I had visions of the lab's larger flames engulfing my mattress and all my years of work going up in flames. Before I left for my flame test, my husband helped ease my anxiety by burning a sample pod in the back yard. We set an alarm for the 70 seconds the mattresses would be subjected to flames during the actual test and below is what happened.
I pulled into the lab parking lot. The pile of burned mattresses outside the loading dock was not a welcoming sight. The lab techs unloaded my mattresses while I completed the necessary paperwork.
The mattresses need to be acclimated to a very specific humidity before testing. This takes 48 hours in a specially designed room with glass viewing windows. The lab was wonderful and scheduled the testing soon after this period for me. When I returned to view the tests, I was very nervous.
Everything about the test and the lab's set up is for a foam slab or coiled spring mattress. They had to make special provisions for my test, adding wires across the open metal frame base to support my modular mattress. My hull filled pods drooped and fell between the wires, resembling a pile of marsh mellows ready to be roasted.
The lab techs brought me to a safe viewing area with a machine with lots of knobs and read out screens with graphs showing the heat the burning mattress produces over the half an hour test. I grabbed the techs arm. I hope I was not squeezing too tightly once the large flames shot out of the apparatus that was positioned across the side and top of my mattress.
I could not see anything through the flames, so I diverted my attention to the readouts on the machine. There was a spike. The tech told me that was normal and we should have a good idea of whether I passed or not after the first 40 seconds. That was a very long 40 seconds!
When he told me "I think you may have a home run", I thought I would cry.
I did not want to get too excited, and jinx things as we still had four more mattresses to burn. It was going to be a long day. After the third mattress passed, I knew I had my 16 CFR-1633 open flame test certification.
The New Twist passed the test!
Here is the video of my open flame test. The flame lasts for 70 seconds and then they let the mattress smolder for a half hour. You probably will want to only watch the first few minutes, as the mattress smoldering part is not very exciting. Grab a beverage, put your feet up and enjoy.
Now if you want to see the same test done with a foam and spring coil mattress (sans flame retardants I suspect) watch this video, filmed at the same lab as my flame test. It shows a very detailed process of the CFR 1633 Open Fame Test. I feel so much better knowing my children sleep on hull filled mattresses with out any foam.
Believe it or not, the huge flame test was not the test I was really worried about!
The next test was the one that concerned me. The dreaded 16 CFR-1632; "the cigarette burn test" I call it. For this test, the lab tech lays down 18 cigarettes all over the mattress. 8 are laid between two small squares of cotton cloth to represent sheets. The problem is, they do not use regular cigarettes which are now, by law, made to self extinguish. This test must use what I call "trick cigarettes" that are designed not to go out and replicate the heat given off of the hottest burning cigarette from the 1970's!
The test requires the entire cigarette to burn out completely. If one cigarette goes out on its own during the test another cigarette must be lit, placed on the mattress in a different spot, and the test continues until that cigarette goes out. Luckily, this only happened once on one of the two mattresses they needed to test this way. Some cigarettes burned for over 40 minutes.
The cigarette cannot make a burn mark or hole more than 2 inches in any direction during the test. Our tubular fabric is our mattress ticking which is 100% cotton. Our fabric is delivered to our customers NOT TREATED WITH ANY FLAME RETARDANTS, so I knew it would ignite and continue to burn passed this 2 inch mark. Hull mattresses have lots of air flow throughout, so as soon as one strand ignites it continues to slowly burn.
We knew we needed to add something to the fabric to pass this test, but I refused to put anything on my mattresses that I would not myself eat. I ended up brushing the fabric with a solution I made in my kitchen from baking soda and vinegar. It tasted like salty salad dressing :)
The result was I passed the CFR-1632 as well.
I now go into the details on this simple solution application in the e-book kit instructions to inform you how we made a mattress that passes the tough Federal flame testing, because every mattress (DIY or not) must pass this test. Would you want to sleep on a mattress with this solution applied to it? It is a bit messy, I admit. I would if it was my only choice without flame retardants. The fabric feels stiff / salty like it has been starched and the application process was a bit messy too. The solution we made will not hold to the fabric and will eventually flake off. But one strange fact is that the flame retardant one chooses to pass the tests is not required to last for any given amount of time. Only the new, fresh off the line mattresses are tested. If the flame retardant disappears shortly after the test (an hour, a day, a month or year), it does not seem to matter. This part was confusing to me.
Most mattresses today have flammable fillings and chemically treated (non flammable) outer coverings. We have the opposite situation: a non flammable inside filling with a flammable ticking. All my mattresses were tested with the baking soda solution applied as the five sample mattresses must all be delivered to the lab as identical.
I have told my story in detail because the more you know, the more you will understand why flame retardant chemicals and barriers are added to mattresses: to protect flames from spreading and igniting the inside (most likely an extremely flammable) filling material. What makes the most sense in my opinion, is to simply ban all flammable mattress filings in the first place, especially for children's mattresses.
So, at the end of a very long day of testing, I collected my hulls up from the burning chamber, loaded my van and smiled the whole three hour drive home. The 450 pounds hulls from the burn test were all perfectly fine and I will be using them for some projects around my home.
I was told I was the first person in the lab's history that wanted their mattresses back after the flame testing.
I look forward to working with the CPSC, keeping up our flammability standard testing and sharing every detail with our customers.
If you have any concerns or questions regarding the fire safety of your mattress, or if you would like a copy of our test results, please feel free to contact me directly at firstname.lastname@example.org