|Received:||10/31/2007 3:29:32 PM|
|Organization:||Independent Textile Testing Service, Inc.|
|Agency:||Federal Trade Commission|
|Rule:||Rules and Regulations Under The Textile Fiber Products Identification Act|
Comments:Dear FTC, Over the past 10 years we have been involved in extensive testing of the PTT fiber pertaining to carpet usage. Testing has included everything from pedestrian traffic, soiling, staining, static, colorfastness to atmospheric contaminants, flammability and many others. Based on our experience with the PTT fiber, it would seem that the test results consistently show a marked difference when compared to PET in regards to performance. Not knowing the chemistry patents and processes for this PTT yarn, we are at the understanding that the polymeric structure is very similar to PET. However, the significant overall performance of the fiber to foot traffic and in use areas is remarkably better. It is of our opinion that the differences shown do indeed indicate that a need for a seperate classification is a good idea. It would be very difficult to continue to try and let the marketplace seperate these on its own. PTT indeed performs much better in general than PET in traffic ratings and it would benefit the consumer to know that there were distinct differences, thereby eliminating PET from being confused with PTT. We think a seperate class of fiber generic name would be in good order and an overall benefit to end users. Thank you for your time and consideration. Best regards, L.Kent Suddeth Executive Vice President Independent Textile Testing Service, Inc.