Thank you very much for joining us today for our CPSC webinar. This is the fifth webinar in our monthly webinar series. Today's topic is mattresses. My name is Shelby Mathis. I'm the small business ombudsman here at the Consumer Product Safety Commission and a brief disclaimer before we talk about the agenda. I am a CPSC staff member and I put together this presentation.  As a staff member, I may not necessarily reflect the views of the commission. All right, so for the agenda today, we've got a lot to cover and I'm going to be mindful of time. But again, if you have questions, you can submit those throughout the webinar. We're going to start by going through the scope of the standards and mainly doing some definition discussion. And then we're going to do what I hope you'll find fun, which is an interactive audience polling section, where I'm going to put up some photos of mattress products and you're going to guess whether or not these would fall under the mattress regulations. After that fun, hopefully fun, interactive audience polling section, I'll talk about prototypes and we'll define the different types of prototypes. We'll talk about pooling requirements and then we'll move into the testing requirements under the two mattress flammability tests, the 1632 and 1633 testing requirements. After testing, we'll move to labeling and I've broken it into two sections for mattress sets and mattress pads. And then we'll touch on two types of mattresses that we receive a lot of questions about because they are somewhat unique. And that's crib mattresses and inflatable air mattresses. Then we'll move on to quality assurance and record keeping requirements that come straight from the regulations. And I'll include citations on where I'm getting those requirements from along with some resources that I think might help you comply with those. We'll touch on certificates, general certificates of conformity and children's product certificates, when you have to prepare them, what's involved in them and who you need to supply them to. And then I'll highlight some CPSC business resources available on our website and other webinars like this one that you might find useful. And then finally at the end, depending on time, we'll do a quick Q&A session based on the questions that you guys submit throughout the webinar. So first let's do a little bit of definitions. So first definition in a mattresses webinar should be what is a mattress? And the good news is that's defined in both of the mattresses regulations, which again are 16 CFR 1632 and 1633. And a mattress is defined as a ticking filled with a resilient material used alone or in combination with other products intended or promoted for sleeping upon, including mattresses that have undergone renovation. And that's a term that we'll define in just a second. For mattress pads, this is defined under 1632. A mattress pad is a thin flat mat or cushion and or ticking filled with resilient material for use on top of a mattress. And then mattress sets are defined in 1633. And a mattress set can be either a mattress and foundation that's labeled for sale as a set or a mattress labeled for sale without any foundation. And you heard me refer to in the definition of mattress the word renovation. So what renovation is is defined in 16 CFR 1633. And it means altering an existing mattress set for resale and includes any one or a combination of the following. Replacing the ticking or batting, stripping a mattress to its springs, rebuilding the mattress or replacing the components with new or recycled materials. Renovation as defined in 1633 does exclude alterations if the intent is to retain the renovated mattress for personal use. So who is responsible for complying with the standards that we're going to get into in more detail in just a second. Responsible parties or manufacturers and importers of mattress products and retailers are also responsible for ensuring that they're selling compliant sets. In terms of what falls under the standard, the standard applies to all mattresses, mattress pads and mattress sets manufactured, imported or renovated. And for 1632, that's the smoldering test. Again, we're going to get into the details of that in just a second. But that smoldering test applies to mattresses and mattress pads. And it's applicable to any mattress or mattress pad that meets the above definition as of April of 1972. In 1633, otherwise known as the open flame flammability test, that applies to mattress sets that meet the definition above as of July the 1st, 2007. All right, now we're going to move into what I hope is a fun part of today's presentation, which is a little bit of interactive section with the audience. So I am putting up a picture on your screen right now. You can see that's a crib mattress. And the question is, does this mattress fall under CPSC's mattress regulations? So I'm actually going to give you guys just a second to look at that crib mattress and think about whether or not you think it falls under the CPSC mattress regulations. Then I'm going to post this question that's going to appear on your screen and you have the ability to submit your answers, which your options are yes, no, or maybe. And I'm going to give everybody a few seconds to get their answers in. Thank you everybody for participating. I'll give you just a few more seconds. It looks like there is a pretty resounding response on whether or not this mattress, this crib mattress falls under our CPSC regs. I'm going to close out the poll and let's see as a group whether or not we thought this fell under our regulations. And it looks like resoundingly the group thinks the answer is yes, that crib mattresses do fall under our mattress regulations. 88% of you guys said yes. So let's see if you were correct. And the great news is everybody was absolutely correct. Crib mattresses do fall under our mattress regulations. I'll highlight the requirements on crib mattresses a little later in today's webinar. But crib mattresses require testing and compliance with both 1632 and 1633. And part of the reason we're going to highlight them just a little bit later is because crib mattresses are children's products. And as a result, they need to additionally meet some CPSIA requirements. All right, so you guys, you're on a roll. Let's move to the next product, which is a futon mattress. And I'll give you just a second to look at this product. And then I'm going to put up the exact same question that I put up a second ago, which is whether or not this futon mattress falls under CPSC's mattress regulations. All right, and the answers are coming in. I will give you guys just a few more seconds to get your answers in. This is not as clear of an answer based on the responses that are coming in. All right, I'm going to close the audience polling here and let's see whether or not as a group, we thought this futon mattress would fall under CPSC's mattress regulations. It looks like 73% said yes, 24% said no, and 3% said maybe. So it looks like as a group, the majority thinks that the answer is yes. Let's see if futon mattresses would fall under CPSC's mattresses regulation. The answer here is yes. Futon mattresses require testing and compliance with 1632 and 1633. And I should have said this previously when we started the interactive audience polling. I'm showing you pictures here of actual products and I'm using them just for illustration purposes. This is not meant as our agency endorsing any of the products that I'm showing here. So let's see if I can trip you guys up because it seems like you're pretty good at this audience polling. The next product up is another type of mattress and it's actually a waterbed mattress. And I guess you know that because I found a nice image with water under the mattress. So I'm going to put up the same question as before, which is does this waterbed mattress fall under CPSC's mattresses regulation? And you've got the options of yes, no, or maybe. I'm going to give you guys a little bit of time to get your answers in because it looks like we're a little split on what the answer is. All right. And it looks like most everybody's gotten their answers in. So I'm going to go ahead and close the voting and let's see as a group whether or not we thought this waterbed mattress would fall under the mattresses regulation. So it looks like 61% say no, 24% say yes, 15% say maybe. So let's see what the real answer is. The answer is maybe. It depends. Only waterbed mattresses that contain upholstery material between the ticking and the mattress core require testing and compliance with 1632 and 1633. So let's continue on our mattresses product. We've got a mattress pad here. I'm going to put up the same question for you guys with this mattress pad fall under CPSC's mattresses regulations. And again, you're going to have your options of yes, no, or maybe. And the answers are coming in. I'm going to give you guys just a few more seconds to get your votes in. All right. It looks like there's a pretty big consensus on one of the answers. I'm going to close the poll and let's see as a group whether or not we thought this mattress pad would fall under our mattresses regulation. Looks like the large majority of you guys said that the answer is yes, that this mattress pad would fall under our mattresses regulation. Let's see if everybody was correct. The answer is yes. So the majority of you guys were correct mattresses pads mattress pads do fall under mattresses regulation. However, mattress pads only require testing to 1632. So our final question is on this product. And this is a convertible sofa mattress. And I'll give you guys just a second to take a look at it and determine whether or not you think that this convertible sofa mattress would fall under our mattresses regulation. Meaning it would need flammability testing. And I'm going to put the same question up on your screen that I've been putting up throughout. And your answer options are again, yes, no, or maybe on this convertible sofa mattress. And again, the photos for illustration purposes and I'm not meaning to endorse any kind of product. And everybody voted very quickly on this last one. So I think I'm going to go ahead and close the polling because the answers are very, very similar. And there's a large majority of you that think that the answer actually, let me share the result. 90% of you said that the answer is yes, that this convertible sofa mattress would fall under the mattress regulations requiring flammability testing. Let's see if you guys were correct. And you are correct convertible sofa mattresses that contain a detachable mattress. It does appear that this convertible sofa mattress is completely detachable, require the mattress to be tested and compliant with 1632 and 1633. All right. So hopefully you guys enjoyed the polling section of today's presentation. Let's get to defining prototypes and talk about pooling requirements because this is something that trips some folks up and that generates a lot of questions. So I'm going to start by defining some terms. First, we're going to talk about what a qualified prototype is. And a qualified prototype is a prototype that has had three specimens tested in accordance with 16 CFR 1633.7. And that's the flammability testing of 1633, which we'll detail in just a second. And a qualified prototype must meet the test criteria of 16 CFR 1633.3B, which is actually shown below. That means that the specimens that were tested did not have a total heat release over 15 megajoules in the first 10 minutes. And that the peak heat release at any time during the 30 minute test was under 200 kilowatts. So that's a qualified prototype. And from qualified prototypes, we get a subordinate prototype, which is a mattress set based on a qualified prototype that is one part of a pooling arrangement. And two is the same as a qualified prototype with respect to materials, components, design and methods of assembly. And three, where at least one specimen of the mattress set has been tested in accordance with 16 CFR 1633.7. Again, that's the flammability testing of 1633. And then it meets the testing criteria, the two testing criteria that we just talked about from 1633.3B, which is that total heat release less than 15 megajoules in the first 10 minutes of the test and a peak heat release of less than 200 kilowatts at any time during the 30 minute test. So now that we've defined qualified and subordinate prototypes, let's move on to confirmed prototypes. So a confirmed prototype is a prototype that is part of a pooling arrangement and is the same as a qualified prototype with respect to materials, components, design and methods of assembly. And where at least one specimen of the mattress set has been tested in accordance with 1633.7. Again, that's the flammability testing of 1633 and that at least one tested specimen meets the test criteria, which is the total heat release under 15 megajoules in the first 10 minutes and peak heat release under 200 kilowatts at any time during the 30 minute test. So what is prototype pooling? Prototype pooling is a cooperative arrangement whereby mattress sets are built based on a qualified prototype and a manufacturer, excuse me, that relies on another's qualified prototype known as a pooling manufacturer must perform a confirmation test on the mattress set it manufactures. The benefits of prototype pooling is that it reduces costs to manufacturers for testing and that it allows manufacturers to pool their prototypes and the records associated with them thereby reducing some of the paperwork burden. Prototype pooling may be accomplished, provided that, and again this is straight from our regulations, the prototype meets the requirements of 16 CFR 1633.4. The mattress sets are the same as the qualified prototype with respect to materials, components, design and methods of assembly and the manufacturer producing the mattress sets in reliance on a qualified prototype has performed a confirmation test, which includes, and again this is going to sound very familiar, testing at least one specimen of the mattress set in accordance with 1633.7, again that's the flammability testing, and the at least one tested specimen meets the testing criteria of 1633.3B, which is the total heat release and the peak heat release that we've been discussing. So what happens in the event of a confirmation test failure? That is actually outlined in the regulation at 16 CFR 1633.5B. And here's what happens. If a confirmation test specimen fails, a pooling manufacturer can't manufacture mattresses or mattress sets based on that failing prototype and needs to correct the problem and test a new specimen before bringing a product to market. And the manufacturer needs to notify the original prototype manufacturer of the failure. Causes for notification of a confirmation test failure would be things like a material, component, and or design flaw during that confirmation test. So it's great to talk about definitions, but how does this really work in the real world? I've got what I hope isn't a nice explanation here on the chart on your screen. So let's start with manufacturer or plant A on the left hand side. They develop a new design for a mattress set and say it's a pillow top in this case. That manufacturer from plant A is going to conduct the necessary testing in order to have a qualified prototype on their pillow top design mattress. From that qualified prototype, manufacturer or plant A can then create three subordinates, and those subordinate prototypes would need to meet the requirements explained in the definitions that we discussed earlier for subordinate prototypes. From that qualified prototype from manufacturer or plant A, that qualified prototype may be shared with manufacturer or plant B. And plant B can create a confirmed prototype again following the steps from the definition that we discussed earlier to create a confirmed prototype. Once a confirmed prototype is set or you have a passing confirmed prototype, you can then create three subordinates from the confirmed prototype at plant B, subordinate prototype 1, 2, and 3. So let's move on to testing, which is probably what everybody attending the webinar today is interested in. We're going to start with the older of the two flammability test, which is the smoldering test in 1632. What must be tested to the smoldering test? Prototype designs for mattresses and mattress pads fall under 1632 testing requirements. And in terms of when to test, testing needs to take place pre-market or at the time of a material change that could influence the flame resistance. Now there's an exception here, and it is that mattresses that are primarily intended for children 12 and under, such as a crib mattress, require more frequent testing than pre-market or at the time of a material change. And we'll address that in just a second in this webinar. To do the smoldering test, the test materials that are needed are some testing samples. You need two mattress surfaces, and this is per our agency's enforcement policy, the hyperlink of which is available in the handout on the right-hand side of your screen. It'll show as a hyperlink, but you can't click on it now. And that enforcement policy came out when 1633 came online. So two mattress surfaces or six mattress pad surfaces are what you need as a testing sample for the smoldering test. Additionally, you'll need sheets, and the regulation is very specific here. They need to be white, 100% cotton sheets. They need a specified thread count and a specified fabric weight, again, all outlined in 1632. Those sheets cannot be treated with a chemical finish. And then finally, for test materials for the smoldering test, you'll need an ignition source, which is SRM 1196 cigarettes. A minimum of 18 are needed, and those cigarettes are available through NIST. Prior to the testing, mattress pads that are treated with a chemical flame retardant need to be laundered 10 times, and sheets that are used in testing mattresses need to be laundered once prior to the test. And all the samples have to be conditioned at very specific atmospheric conditions, which are outlined in 16 CFR 1632.4C for 48 hours prior to testing taking place. So for the smoldering test, the test is conducted in the case of a mattress on a bare mattress and a two sheet sample. You can actually see on the right hand side of your screen, and again this diagram is straight from the regulations, the mattress preparation, which shows that half of the mattress is bare, and the other half of the mattress is two sheets where the first sheet has been tucked under. In terms of surface locations for the testing, there are four. Smooth surface, tape or seam edge, a quilted surface or a tufted surface, and a minimum of three cigarettes are burned at each of the shown locations, which you can see on the cigarette location section on the right hand side of your screen, and again this diagram is straight from the regulation itself. You can see the cigarette laying on the bare mattress underneath the two sheets, and then at the tape edge with a pin keeping the cigarette from falling off the side of the mattress. If only two of the surface locations that I listed before exist, then four cigarettes are burned on the smooth surface, again as shown above in the bare cigarette location, and five are on the other surface. A sample passes the smoldering test if no char length in any direction from an individual cigarette is longer than two inches, which is the same as 5.1 centimeters. Now I want to talk about ticking substitution, because this is also outlined in the 1632 reg, it's at 1632.6. Ticking substitution allows ticking of a mattress to be changed on a prototype without retesting. The ticking is classified by the methodology outlined in the standard, which breaks the ticking into class A, B, and C ticking. In the case of class A ticking, it can be used on any qualified mattress prototype without conducting new prototype tests. Class B ticking can be used on any mattress prototype qualified with a class B or C ticking, and class C ticking requires a new prototype test before it is used in production. Now let's move on to the second flammability test applicable to mattresses, which is 1633, the open flame test. And what gets tested here? All manufactured, imported, or renovated mattress set prototypes are subject to the open flame test, and mattresses labeled for sale with a foundation should be tested with their foundation. Testing needs to take place pre-market, or when there's been a material change that could influence the flame resistance. And there's an exception here, again, for mattresses primarily intended for children 12 and under, such as a crib mattress, that requires more frequent testing than the pre-market or material change testing for standard mattresses. Testing materials needed for the open flame test are going to be test samples, which are three specimens for each qualified prototype unless a manufacturer is complying with prototype pooling and confirmation testing requirements, which we've discussed previously. The ignition source for the open flame test is actually two T-shaped burners, one that impinges a flame on the top surface, and one that impinges a flame on the side of the foundation. And the testing procedure is a pretty lengthy one. It is detailed in very, very serious detail in 16 CFR 1633.7. So I'm not going to belabor the point, and we'll just refer you guys to the actual testing procedure in 1633.7. How do you know if a specimen is passing the open flame test? Well, it has to comply with two test criteria, which are going to sound very familiar. When we were just defining prototypes, we talked about these over and over. And the two criteria are that the total heat release during the open flame test shall not exceed 15 megajoules in the first 10 minutes, and the peak heat release shall not exceed 200 kilowatts at any time within the 30-minute test. So if the specimens comply with both of those criteria, then that is a passing sample. And there is a testing exception on the open flame test, and it is that a manufacturer may sell a mattress set that has not been tested to 1633.7 if that mattress set differs from a qualified or confirmed prototype only with respect to the following. Mattress foundation, length and width, but not depth. Ticking, unless the ticking of the qualified prototypes has characteristics designed to improve performance on the test. Any component, material, design or method of assembly, and the manufacturer can demonstrate objectively that such differences will not cause the mattress to exceed the test criteria. Now that we've talked about the flammability testing for mattresses, let's move on to labeling. And I've broken this into mattress sets and mattress pads to help parse it out. So mattress sets must be conspicuously and permanently labeled with the following, and this needs to be in English. Again, straight, this is straight from the regulation at 16 CFR 1633.12. Manufacturer name, for imported mattress sets, the importer and foreign manufacturer name need to be conspicuously and permanently on the label. Also, the manufacturer's complete physical address if it's being made domestically. For imported mattress sets, the complete physical address of the foreign manufacturer and the U.S. importer or location of records in the U.S. needs to be on the label. Along with the month and year of manufacture, model identification, prototype ID number if you're using prototypes, and a certification that the mattress complies with 1633. And you can actually see the language that needs to be on the label at 1633.12.6. And I'll show you an example in just a second. You also need on the label for a mattress set a statement identifying whether the mattress intends or whether the manufacturer intends the mattress to be sold alone or with the foundation. Additionally, mattress sets need to meet the following format requirements for their labels. And again, this is straight from 1633.12. The label needs to be two and three quarters in width, and the length is going to vary based on the quantity of text that needs to be on there to comply with the labeling requirements. The text can only be black and white, and there are font size and style requirements for each part of the label. And I've highlighted those below. For mattress labels and for mattress foundation labels, those are the specific references on where you can find the language. For a mattress that's got English on the front, you do have the ability on the reverse side of the label to put the exact same information in another language. But again, the front side of that label must be in English. All right, and I've got two examples of compliant or straight with the standard labeling for mattress sets. On the left-hand side of your screen is a domestic mattress label example. And you can see it contains the manufacturer information, mailing address, the date of manufacture, the model, prototype ID, that certification that it meets the flammability requirements of 1633, and reference that it's intended to be sold with a foundation and reference to the foundation ID. On the right-hand side of your screen is a foundation label, again straight from the regulation. It's got the manufacturer information, date of manufacture, model ID, prototype ID, and foundation ID. And more labeling examples are available at 16 CFR 1633.12. For a mattress pad labeling, mattress pads must be permanently labeled with the following in accordance with 1632.31. The location and that city and state of manufacture, the month and year of manufacture, and then mattress pads which contain a chemical fire retardant shall also have the following. It needs to be prominently labeled with the letter T and contain instructions with the mattress pad on how to protect the pads from chemicals that will reduce the flame-resistant properties. All right, I wanted to highlight two types of products that I think can trip up companies. And the first one is crib mattresses. Crib mattresses are unique in that they must comply with the mattress requirements of the flammability test of 1632 and 1633 that we've been going through. But they're also crib mattresses are primarily intended for use by children 12 and under, meaning they're a children's product, and therefore they have to comply with the CPSIA, the Consumer Product Safety Improvement Act requirements. And those are listed below in bullets on your screen. The first is lead content testing must be conducted on crib mattresses. And there's a 100 ppm limit on accessible parts. If you have a crib mattress that has screen printing on the ticking, then lead and paint and similar surface coatings testing would apply and the limit there is 90 ppm. And also because this is a children's product and specifically a child care article that facilitates sleeping, phthalates testing would apply and phthalates are plasticizers. There are six phthalates that you have to make sure to test the crib mattresses for, and none of those phthalates can exceed more than 0.1%. In terms of testing frequency, and I highlighted this earlier because crib mattresses are a little unique. They must be tested in accordance with 1107.21 as opposed to the testing frequency which was pre-market and at the time of a material change from 1632 and 1633. Crib mattresses are going to need initial testing or pre-market testing, and then periodic testing is required at a minimum of one of the following. Once per year, every two years if you have a production testing plan in place, or every three years if you're using a testing lab that's accredited to the ISO standard that appears on your screen. The takeaway here is that the vast majority of manufacturers and importers of crib mattresses are going to have to test these once per year. Retesting is also required when a material change is made and what constitutes a material change is actually defined at 16 CFR 1107.23. I also want to highlight inflatable air mattresses, which are another consumer product item that we do get some questions on. 1632 and 1633, the flammability test for mattresses applies only to air mattresses with upholstery material between the ticking and the mattress core. So inflatable air mattresses that do not meet that requirement would not be subject to the flammability test of 1632 and 1633. However, if the air mattress does have upholstery material between the ticking and the mattress core, it would be subject to the two flammability test on your screen. For inflatable air mattresses, additionally there's a voluntary standard that is ASTM F2755-14. That's a safety standard specification for cautionary labeling of inflatable air mattresses. And it has a permanent label or sewed on tag that they recommend placing in a conspicuous location. CPSC recommends compliance with this. The label appears on your screen and that's straight from the regulation itself. It's addressing your risk of suffocation for infants under 15 months and cautioning consumers not to place an infant 15 months or younger to sleep on an inflatable air mattress. And it also says how to make sure that these are used safely for children over 15 months old. For manufacturers or importers of these products, this label needs to be permanent and sewn on and in a conspicuous location on that inflatable air mattress. And again, a voluntary standard, but a labeling recommendation. Now let's move on to quality assurance requirements on mattress manufacturers and importers. You need to have a QA program in place, which includes at a minimum, controls on all incoming materials and components to ensure that they're identical to the prototypes, inspection of finished products to ensure they're identical to the representative prototypes, and product lot designations. You also need to do production testing QA. This is strongly encouraged because this is a good way to ensure that the finished product consistently performs like a qualified prototype. It also helps identify problems early and limit possible recall populations for your mattress products. I'm going to go through each of the record keeping requirements. The first one here is test records. And again, this is straight from the mattresses regulations at 1633. The test records that you need to keep are going to be on the test results, including each of the tests performed. And that does include failures of testing. You'll also need to keep video and or a minimum of eight photographs of the testing of each mattress set. Manufacturers and importers need to ensure that they also maintain prototype records. Prototype records need to include a unique ID number for the qualified or confirmed prototype and a list of the unique ID numbers for each subordinate prototype based there on. A detailed description of all materials, components and methods of assembly. A list of which models and production lots of mattress sets are represented by each qualified, confirmed and or subordinate prototype ID number. And records on FR treatments, fibers and other materials used. There's also a pooling records requirement in the record keeping section of 1633 pooling records should include a prototype ID number assigned by qualified prototype manufacturer. The name and complete physical address of a qualified prototype manufacturer and a copy of the qualified prototype test records. And then lastly quality assurance records. You'll need to maintain those including a written copy of QA procedures, records of any production tests that have been performed. And then for each qualified, confirmed and subordinate prototype, the number of mattress sets in each production lot based on that prototype, along with the start and end dates of production of that lot and component material and assembly records. So in terms of responsibility associated with record keeping, who is responsible for making sure that you're staying in compliance? Importers and manufacturers are responsible and must maintain these record keeping records in English. The location of records. If you are a domestic mattress manufacturer, you need to maintain records at the plant or factory where the mattress sets are made. And if you're importing mattress sets, you need to maintain records at the U.S. location that's indicated on the label. In terms of how long to maintain the records, the records need to be kept for as long as a prototype is in production and then for three years thereafter. Alright, let's talk about certificates. I've got on your screen a general certificate of conformity. And there's a caveat here, you see the asterisk, and it is that most mattresses, actually all mattresses that are not primarily intended for use by children 12 and under, require a general certificate of conformity certifying compliance. However, for mattresses that are primarily intended for children 12 and under, such as a crib mattress, those are going to require a children's product certificate instead of a general certificate of conformity. The good news is that a GCC and a CPC have the exact same seven questions. They're in the exact same order. So the only difference is going to be the title. I've put a general certificate of conformity on the screen and that's what we're going to go through. But if you're making crib mattresses, you can absolutely use this form to create your children's product certificate. You just need to make sure it's properly labeled as a children's product certificate. So a general certificate of conformity has seven sections. The first one is going to be a description of the products covered by the certificate. And here you're going to want to be as specific as possible in detailing the product. In section number two, and this is probably the section that trips up the most people, it is citation to each CPSC safety rule to which you are certifying compliance. And the things that appear here in number two are going to look very familiar because it's a nice summation of the testing that we've gone through today. So the first two are the two flammability test. The first being the smolder test from 1632 that applies to mattresses and mattress pads. The second one being 1633, which is the open flame test that applies to mattress sets. For those manufacturers and importers working with mattress products that are primarily intended for use by children 12 and under, the CPSIA requirements are going to apply to those children's products. And those are the last three things shown in red. The first being total leg content from 15 USC 1278A. Again, that's only going to apply to crib mattresses and that would be on a CPC, not a GCC. If there is screen printing on ticking for a crib mattress or a mattress intended for children 12 and under, then lead and paint and similar surface coatings testing is going to apply. And that's from 16 CFR part 1303. And then finally, crib mattresses because they are childcare articles that facilitate sleeping fall under the phthalates, permanent and interim bands. The phthalates testing will need to be completed on crib mattresses and that phthalates testing is detailed at 15 USC 2057C. Again, crib mattresses only on phthalates and that would be in a children's product certificate as opposed to a general certificate of conformity. Section number three on a GCC or a CPC is going to be the importer or domestic manufacturer contact information. Number four is the contact info for the person that maintains your test records. Five is the date and place of manufacture of the product that the certificate is covering. And if you're using prototypes, you're going to want to be as detailed as you possibly can here on the date and place of manufacture. Number six, the same rule applies, the location of testing and date of test in which the certification is based. For those of you that are using qualified prototypes or confirmed prototypes or even subordinate prototypes, you're going to want to really parse that out in your certificate and make sure that you're detailed on the testing, the location of testing and the date of the test for each of those prototypes. And then finally, the contact info of the testing lab. And again here, if you're relying on prototypes, you're going to want to be very detailed in the section of your certificate. All right, certificates, GCCs and CPCs. I think I've kind of done a nice job of highlighting these. But I did want to direct you to the two pages that we have available on our website, ones for GCCs and that's shown on your screen. Again, GCCs are for what applied to mattresses that aren't meant for kids or children ages 12 and under. CPCs and that's the link to the site. Again, in the handout on the right-hand side of your screen, you can follow that link directly or you can type it into a search engine. And it'll go right to our children's product certificate page that CPC would apply to crib mattresses or mattresses that are intended for children 12 and under.  And the good news is on the GCC page with the web address shown on your screen, we do have a sample general certificate of conformity available that you can actually use as a template to create your own general certificate of conformity for your mattress product. Availability of certificates, three main things to remember here. A certificate needs to accompany each product or shipment of products that's covered by the same certificate. So if you're importing, something very important to remember here. A copy of the certificate needs to be furnished to each distributor or retailer of the product. However, there's no requirement to provide it to the ultimate consumer. You do have the option of doing that, but there's no requirement to do that. And then finally, a copy of the certificate must be made available to our agency and or customs upon request. And then lastly, the good news is that our commission by rule has confirmed that certificates in electronic form are acceptable. But there is a caveat here, which is that you have to make sure that you create your certificate no later than the time of shipment if it's being imported or before first distribution within the United States if it's being made domestically. All right, I wanted to touch on a few business resources here that I think you might find helpful if you're in the mattress products industry. I've got my contact information up top, but I want to focus your attention on the bottom left hand side of the screen. So these are hyperlinks that you can just follow straight from the handout on the right hand side of your screen. You can download the PDFs of this slot or the PDF of these slides and they've got the hyperlinks active. We do have a pretty nice mattress business education page on our agency website that I think you'll find very helpful. Also, something I found very helpful when putting together the content for this presentation because 1632 and 1633 are very lengthy regulations. There is a regulatory summary on 1632 and it's a PDF document. It was actually created by our Office of Compliance and it's got some frequently asked questions associated with 1632. It's front and back, very useful to keep on hand. If you are a testing lab or you're working with testing labs, we do have laboratory testing manuals and they are very extensive and they're available on our website for 16 CFR 1632, the smoldering test and 16 CFR 1633, the open flame test. Again, the hyperlinks are right there. Finally, to make sure that you're complying with the record keeping requirements, we do have a suggested record keeping forms page that has suggested record keeping forms for testing for different types of prototypes that I think would be really helpful. That link there that's again active on the handout on the right-hand side of your screen will take you to a landing page that has several record keeping forms that are available for you to download and then just use internally. Finally, on the bottom right-hand side of your screen, I've got the regulatory robot. You can see it's a little green robot waving at you from a laptop. That is the address you can type into a browser. There's also a hyperlink on the handout. The regulatory robot is meant to be an interactive bot that can help you try to identify what requirements apply to your product. So specifically, if you're an importer and you're working on importing a product that you may not be familiar with, you might want to start with the regulatory robot because it will help you identify what requirements apply to that product if you're not familiar with the product area. Or frankly, I use the regulatory robot to find references within our regulations to somewhat obscure things that I don't reference very frequently. Lastly, a few more resources and then we'll get to questions. You've got my email address on your screen. The phone number on your screen is a business line where you can actually get a live person on the phone if we don't know the answer and certainly with the mattress regulations, this is a very technical topic. We often have to call in reinforcements, but if you call<PHONE_NUMBER>, you will get a live person unless we're on another line or running a webinar. Then you'll get our voicemail. Leave us a voicemail or talk to us about your consumer product and we will try to get an answer internally from the experts in our agency on your consumer product, mattress related or not. And then finally, if you're on Twitter, we do have a Twitter account and it's at CPSC Small Biz. On that Twitter account we do things like post if there's an open comment period for rulemaking that might impact a small business. We also post things about webinars which we've been trying to do monthly on pretty varied topics. So this mattresses webinar showed up there and there's usually a registration link right there if you want to sign up or you can retweet us if you are so inclined. So all right, I want to make sure that we end on time. So I'm just going to touch on a few last resources that I think you guys might find helpful. The first is that our agency actually has a YouTube channel playlist and it's got a section that's on business education that includes all of our CPSC webinars. So if you are a company that covers many product areas, please feel free to direct employees, coworkers, colleagues to the webinar series that is available on the YouTube channel playlist. Again, that link is available on the handout on the right hand side of your screen. The topic areas that we have done thus far are soft infant and toddler carriers and swing carriers, cloth diapers, stuffed toys and an intro to the new U.S. toy standard which is ASTM F9-6316. Each of the webinars are about 45 minutes to an hour in length and you watch them straight from YouTube. If you'd like a copy of the slides associated with the webinar, you can email me at the email address that appears on your screen. And then finally, one of the things that we do in the Small Business Ombudsman's Office in addition to doing monthly webinars is we send out a newsletter to businesses that have signed up and we've got a lot of people on our email distribution list. If you are interested in learning about upcoming webinars or even suggesting webinar topics to me, you've got my email address and ways to contact me, but you can also sign up for that monthly newsletter at cpsc.gov forward slash email. You'll want to make sure to select Small Business Ombudsman updates. So with all that, I really sincerely appreciate everyone's attendance and thank you for all of your questions. If I did not get to your question today, give me a business day or two to make sure that I can get those answers back to you. I've got your email address so I can get in touch with you that way. Make sure to download the handout on the right-hand side of your screen if you're interested in having the PDF slides. And then lastly, there's going to be a feedback survey that pops up on your screen at the end of this webinar. As an agency, we're trying to get more feedback from the folks that attend our trainings to see if they're actually helpful. And if not, how we can improve, I would love to get your thoughts on that if you're willing to give me 30 seconds of your day. So thank you very much for your attendance today. Again, I'm Shelby Mathis, the Small Business Ombudsman at the CPSC, and I look forward to maybe speaking with you guys next month for our next webinar.