To: Heads of Fire Departments
From: Stephen D. Coan, State Fire Marshal
Date: December 20, 2002
Re: 527 CMR 29.00: Upholstered Furniture, Molded Seating and
Re-Upholstered Furniture

At the November 7, 2002 meeting of the Board of Fire Prevention Regulations, the Board was asked a question regarding the need for plastic molded chairs to meet the test standards required in 527 CMR 29. The attached letter is the Board's reply to the manufacturer. This letter provides clarification on meeting the requirements of 527 CMR 29.

Begin Text of Letter:

November 7, 2002


This letter is in response to your requests seeking guidance relative to Massachusetts Fire Prevention Regulation 527 CMR 29.00: Upholstered Furniture, Molded Seating and Re-Upholstered Furniture. We apologize for the delay in getting back to you.

This Board has concern about the ease of ignition and rate of heat release of molded plastic chairs, especially when they are stacked up. The Board is aware of a major fire at the Tri-County Regional Vocational Technical High School in Franklin, MA that resulted in extremely heavy smoke production in the occupied building along with significant structural damage. The primary fuel involved was stacked plastic chairs that were ignited by an open flame. This Board is also aware of other institutional occupancies, primarily correctional facilities where intentional open flame ignition is not uncommon, that have had significant fires in stacked plastic chairs.

The requirement for chairs in 527 CMR 29.00 in unsprinklered facilities is to comply with the requirements of California Bulletin 133 for flammability OR ASTM E- 1537 AND meeting the test criteria of CTB 133. In sprinklered facilities, compliance with California Technical Bulletin 117, for smoldering ignition is acceptable.

We concur that CTB 117 test protocols are intended for resilient material and are difficult to apply to molded seating without padding. On the other hand, the seating should be able to pass this testing with no problem. It is this Board's opinion that CTB 133 open flame ignition testing is appropriate and 527 CMR 29.00 is the applicable regulation in the Commonwealth of Massachusetts for molded seating.

This Board is in the process of promulgating a new state fire code, based on NFPA 1, Uniform Fire Prevention Code, 2003 edition. Any input that you would like to provide as far as testing for ease of ignition, especially open flame, or heat release rates of molded plastic seating would be welcome.

Thank you for your interest.

V. Carlisle Smith, Chairman
Board of Fire Prevention Regulations

End Text of Letter

If you have any questions please contact the Code Compliance and Enforcement Unit at 978-567-3300 or in Western Massachusetts at 413-587-3181.