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September 9,1997 FILE COPY. ORIGINAL DATE

JULY 1,1997

Ms. Ann Brown, Chairman

Consumer Product Safety Commission
East West Towers
4340East West Highway
Bethesda, MD 20814

Subject: Smoke As An Untenable Condition

Dear Ms. Brown:

When a fire initiates and remains a smoldering type fire for a substantial period of time
(let's say at least Yzhour), smoke will nearly always be the first life threatening condition that
develops in a home. That is, a serious level of smoke (obscuration) will likely occur prior to the
development of deadly levels of toxic gases (including carbon monoxide) or heat.

The problem is not that the smoke itself will kill, but rather that the potential victim may
find it impossible (or too frightening) to traverse through the smoke to reach the exit and safety.
Having been trapped by the smoke, soon thereafter the toxic gases, a reduction in orygen or heat
(individually or in combination), may cause serious injury or death. Death could occur quite
rapidly if a smoldering fire converts to a flaming fire after the smoke has reached a level that
would prevent those trapped from reaching an exit door to the outside.

It makes sense, therefore, that a warning of the existence of the fire should occur prior to
the smoke reaching a level that would prevent an orderly escape, or the prompt control of
the fire. In many instances a parent will find it necessary to "round up" small children, and
escape, prior to the smoke reaching an untenable level. Therefore, there should be safety factors
in the time allowed after the alarm sounds, until the smoke reaches a level that will trap the
occupants.

Accordingly, the questions I raise are these:

1. What is the level of smoke obscuration (in terms of percent light reduction per
foot), that your orguization has established as the maximum smoke level to be tolerated, which
will still allow an orderly escape from a home or other building?

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 2. Based on the available research and fire tests, have you developed a "probable
time frame" for upholstered furniture and/or bedding to produce this i'untenable; condiiion, due
to a smoldering-type fire?

I am enclosing an article that deals with this issue, which may provide some further insight
into the information I seek.

Yours Truly,

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Richard M. Patton
Registered Fire Protection Engineer
President, Crusade Against Fire Deaths, Inc.

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 Federal Emergency Management Agency
United States Fire Administration
Emmit.sburg, Maryland 21727

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Mr. Richard M. Patton
Registered Fire Protection Engineer
Crusade Against Fire Deaths, fnc-
P.O. Box 196
Citrus Heights, California 9561 1-0196

Dear Mr. Patton:

Thank you for your letter of July i in which you asked questions concerning smoke
obscuration and occupant tenability. It is not the role of the United States Fire
Administration to set standards or guidance for these conditions, however, guidance on
occupant safety has been developed by the National Fire Protection Association [NFPA).

The NFPA Committee on Safety to Life is responsible for NFPA 101, Life Safety Code
and related codes. Ron Cote, NFPA Secretary to the NFPA Committee on Life Safety
may be contacted at I Batterymarch Paric, P.O. Box 9101, Quincy, Massachusetts,02269-
9101.

Another possible source of information is the NFPA Toxicity Technical Advisory

Committee. Mr. Cote is Secretary to this committee too. The Chair of this committee is
Jack E. Snell, Deputy Director Building and Fire Research Laboratory, National Institute
of Standards and Technology, Gaithersburg Marylan d 20899.

Thank you for your interest in fire safety, and if you have additional questions, please
contact me at the above address.

Sincerely,
/' .1

l-C-lzt'V'z-
Carrye B. Brown
U.S. Fire Administrator
 U.S. CONSUMER PRODUCT SAFETY COMMISSION
WASHINGTON, D.C.2O2O7

JuLy 22, L997

Mr. Richard M. Patton

Presideni.
Crusade Against. Fire DeaEhs, fnc.
P.O. Box 195
Citrus HeighCs, California 95511-0195
Dear Mr. Patt.on:
Thank you for your July 1. lgg7, let,t.er to Chairman Ann Brown.
The Commi ssion has been active in ad.d.ressing upholstered,
'

furaiture anC mat,t.ress f ires since t.he early L970s. These products
are/ of course, freguently involved in smo'ldering fires, especially
those ignited by cigarettes. Our approach has been to influence the
manufacture of Lhese prod.uct,s so that they will resist ignition,. We
have observed a 74 percent, reduction in cigareLte-igniCed. upholstered.
furniEure fires between 1980 and L994 and a 72 percent reduction in
cigareEt.e-igniE,ed mattress and bedding fires over che same period.
Deaths in these cigarette-igrnited furni-ture fires declined G5 percent
whj-le deat.hs in t.hese cigarette-ignieed mattress/bedding fires-
declined 6L percent.
Si-nce our primary strategy has been to prevent ignition, w€ have
not est,ablished a maximum smoke level to be tolerated nor have we
cieveloped a probable time frame for these prod,uct,s to produce such a
smoke level. Acceptable smoke levels have been established by
Underr^rriters Laboratories Inc. t,o evaluate the performance of smoke
detectors.
Sincerely,

r.(lr*,,//."2*4'"
7 t' James
-l,r/ -F. lioebel
Chief Engineer for Fi-re Hazards
DirectoraEe for Engineering Sciences
 Memo

Date: September 9, 1997

To: Friends of the Crusade

From: Richard M. Patton

Crusade Against Fire Deaths
P.O. Box 196
Citrus Heights, CA 95611-0196

Subject: What Do The Feds Fear?

I wrote to both the Federal Fire Administration and the Consumer Products Safety
Commission. The question was a simple one. Very simple. How much smoke will killyou.
Or, putting it anotherway, what is the maximum level of smoke obscuration that may be
allowed along an exit path before that exit way becomes untenable in the sense that people
will be afraid to travelthrough the smoke to reach safety?

When this question is applied to a hotel, for example, the person who's path is blocked
by smoke will likely become trapped in his/her hotel room. That person's survival will then
depend on the firemen controlling the fire before the toxic gases kill.

When this question is applied to a home, when a fire occurs at night, how much smoke
can be created before the occupant will likely be trapped in a bedroom. The window as an exit
may be an impossible one for some even when the home is one story. lf the bedroom is two
stories or more above ground level, it may be an impossible exit for everyone.

Because home fires are often extremely fast, to be trapped is often to be eventually
killed.

So, why are these agencies of our federal government, (which receive millions of our
dollars every year to hire experts, make studies and conduct research) not able to answer this
simple question? The Crusade has a lesser budget, but we were able to answer that question
(Crusade publication: How Much Smoke Will KillYou?) The Crusade conservatively setTo/o
smoke as the point where smoke becomes "deadly". Many who are knowledgeable consider
4o/o ?a the top permissible smoke obscuration along an exit path.

The problem the feds have is this. The smoke detectors they are helping businessmen
to sell to the public, frequently will fail to warn of the smoke prior to that smoke becoming very
thick, with dangerously high measurable levels of obscuration (percent light reduction per foot).
lf the feds name a number, and if that number is anywhere close to being a responsible
number, why then they would have to admit that the smoke detectors they are helping to sell
will fail to sound even as the smoke rises to two, three or four times that reasonable number.

I enclose the answers I received from the FFA and CPSC. Strange answers, are they
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September 10,1997

Jack E. Snell
Deputy Director Building
and Fire Research Laboratory
National Institute of Standards
and Technology
Gaithersburg, Maryland 20899

Subject: Maximum Level Of Smoke Permitted Along An Exit Path

Dear Mr. Snell:

I wrote to both the FFA (FEMA) and to the CPSC asking that they name a level of smoke
which would be the maximum level to be tolerated along an exit path. Within a home the "exit
path" would probably be the "living area". A copy of each letter is enclosed as well as my original
letter.

At the suggestion of the FFA5 I am writing to you. Are you able to provide a benchmark
for the level of smoke that will likely prevent escape along that exit path?

Richard M. Patton
Registered Fire Protection Engineer
President, Crusade Against Fire Deaths, Inc.

RMP/Iff

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September lO,1997

Ron Cote
NFPA Secretary
NFPA Committee on Life Safety
I Batterymarch Park
P.O. Box 9l0l
Quincy, Massachus etts 02269 -9 L0 1

Subject: Maximum Level Of Smoke Permitted Along An Exit Path

Dear Mr. Cote:

I wrote to both the FFA (FEMA) and to the CPSC asking that they name a level of smoke
which would be the maximum level to be tolerated along an exit path. Within a home the "exit
path" would probably be the "living aret'. A copy of each letter is enclosed as well as my original
letter.

At the suggestion of the FFAr I am writing to you. Are you able to provide a benchmark
for the level of smoke that will likely prevent escape along that exit path?

Yours Twldr/'
,7)'zz
Richard M. Patton
Registered Fire Protection Engineer
President, Crusade Against Fire Deaths, Inc.

RMP/Iff

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National Fire Protection Association

I Batterymarch Park, Quincy, Massachusetts 02269-9101 USA
Telephone (617) 770-3000 Fax (617) 770-070A

September 26,1997

Mr. Richard Patton, President

Crusade Against Fire Deaths, Inc.
P.O. Box 195
Citrus Heights, CA 95611-0196
Dear Mr. Patton:

Ron Cot6 forwarded his letter of September 23 with your original letter and
his suggestion that I might be better able to address your question.
There are multiple references in the literature to values for the extinction
coefficient (a standard measure of visual obscuration) that will dissuade
people from attempting escape by a particular route. The values cited on p.
2-LL2 of the SFPE Handbook of Fire Protection Engineering,2nd edition, are
a good starting point. The range of values is fairly wide, partly reflecting
the dependence of such values on occupant characteristics (e.9., previous
familiarity with the route vs. lack of such familiarity) and possibly also
reflecting significant variability from one individual to the next in what is
fundamentally a behavioral reaction to a physical condition.

Increasingly, such values are used in larger fire hazard analyses of

building designs, along with models of the speed of spread and of impact on
people of other frre effects (e.g., heat, toxjc gases).

Note that because smoke obscuration leads to injury only indirectly, its
effects will be dependent not only on fire development, the performance of
building fire protection systems and features, human behavior factors, etc.,
but also on the availability of a second way out that can be used if the first
one is blocked. This further complicates the process of predicting how
ofben, how quickly, and how severely injury will result from a chain of
events that included smoke obscuration of an exit path.

I hope this information is helpful.

An international nonprofit membership organization dedicated to reducing the burden of fire on the qualiry of life by advocating scientifically-based codes and standards,
research, and education for fue and related safety issues since I 896. Publishers of the National Fire Codes@, including the National Electrical Codeo and the Lile Safety Codeo
Sincerely,
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John R. Hall, Jr., Ph.D.

Assistant Vice President
Fire Analysis & Research
cc: R. Cot6
R. Fahy
D. Beller