Advisory opinion letter

Dear Sir:

This is to request an advisory opinion as to the applicability of Regulation DOC FF 2-70, “Standard For The Surface Flammability Of Small Carpets And Rugs,” issued under the Flammable Fabrics Act, to terry bath mats (as distinguished from small bath rugs or carpets). This Regulation becomes effective in December 1971 and the requesting party is not the subject of a pending investigation or other proceeding by the Commission or any other governmental agency. The terry bath mat product to which this request applies is a distinctive product and defined as an absorbent mat which (a) has dimen- Request 79 F.T.C.

sions of less than one square yard, (b) is woven on terry looms of textile fiber of a heavy terry construction, (c) has no face, pile or backing characteristic of a rug or carpet, and (d) is made and intended to be temporarily stood upon in the bathroom for water absorbency purposes immediately following the bath. This question has been discussed with representatives of the Commission and the Department of Commerce and is of significant importance to the towel and bath mat industry. Your advisory opinion is needed in the near future in order to make production arrangements in ample time prior to the effective date of the Regulation should they be required.

Attached hereto is a brief in support of the position of this company that such products are not properly within the scope of the Standard. We will be glad to provide further information or evidence upon request. A specimen terry bath mat is being forwarded under separate cover to illustrate statements set out in the attached brief. The writer can be reached by telephone at 919-623-8147. I would appreciate acknowledgment. of receipt of this request.

Very truly yours,
(S) W. B. Lucas,
General. Counsel.