A Reflection on the TB 117 Standard and the Way Forward for Truly Comprehensive Safety Standards

A feasibility study released this month by the Consumer Product Safety Commission (CPSC), The Feasibility, Benefits and Costs of Adopting TB 117-2013 as a Mandatory National Standard, concluded that TB 117-2013 did not effectively address the hazard of smoldering ignition and should not be adopted as a mandatory national standard.

A bit of history provides some context for the reasons for this decision and perhaps points to a path forward for truly comprehensive safety standards.


In the 1970’s, the State of California passed a law requiring all upholstered furniture sold in California to be flame retardant. California TB 117 was developed and mandated by law in 1975 for all residential upholstered furnishings sold in the state of California. For furniture manufacturers selling product in California, TB 117 became the requirement and absent any federal regulation, TB 117 became the de facto standard for the entire country. At the time, little was known about the health and environmental impacts of commonly used flame retardants. In many cases, certain furniture materials had to incorporate flame retardants or would fail to pass TB 117.

Amid growing concerns about the potential risks posed by flame retardants to human health and the environment, TB 117 was revised in 2013 to remove the open flame testing component. This allowed furnishings not containing potentially hazardous flame retardants to comply with the revised standard. In essence, a tradeoff was made, allowing increased flammability in exchange for furnishings that pose less risk to human health.  However, without the stringent flammability test, TB 117 loses some of its value and that contributed to the decision not to recommend it for a national mandatory standard.

The Way Forward

As a trusted standards development institution and third party testing company, UL hopes to help advance safety testing for furnishings across the board. It is important to note that TB 117, while not endorsed to become a national standard, is not likely to disappear.  Well engrained in the testing regimen of any furniture manufacturing selling product in the state of California, flammability testing will continue as it has for the past 4 decades. The bigger question is how to move forward to create and adopt a standard that reflects safety across all critical attributes.

UL strives to develop standards that achieve the highest levels of safety and acceptability across multiple criteria such as flame resistance, human health and sustainability. For this reason, UL is constantly pursuing better science as fire safety and protection begin to merge with human health. It is possible and progress is being made –but it may take some time.