U.S. CPSC
This presentation was prepared by CPSC staff, has not been reviewed or
approved by, and may not reflect the view...
2
Mary Toro, Director, Office of Compliance,
Regulatory Enforcement Division, moderator
Jacqueline Campbell, Textile Techn...
3
Flammable Fabrics Act
1. Wearing Apparel
2. Vinyl Plastic Film
3. Children’s Sleepwear
4. Carpets and Rugs
5. Mattresses...
Children’s Clothing Requirements
1. Relevant Mandatory Flammability Standard
2. Children’s Product Certification of Confor...
Violations/Prohibited Acts
• Manufacturing for sale, offering for sale, importing,
delivery for introduction, transporting...
All Regulated LOA’s
FY08-FY13
0
500
1000
1500
2000
2500
915
1044
1926
1677
2316
1685
FY08 FY09 FY10 FY11 FY12 FY13 as of 9...
All Flammable Fabrics Act LOA’s
FY08-FY13
0
20
40
60
80
100
120
140
160
49
75
63
71
152
97
FY08 FY09 FY10 FY11 FY12 FY13 a...
Flammable Fabrics Act LOA’s
FY08-FY13 by Product Type
0
10
20
30
40
50
60
70
80
90
47
1 1
32 36
7
52
8
3
48
15
8
60
81
11
...
FY13 - Recalls, Stop Sales and Seizures
as of 9/6
1127
793
21
0 200 400 600 800 1000 1200
Recalls
Seizures
Stop Sales
Requirements for Clothing
Textiles and Children’s Sleepwear
This presentation was prepared by CPSC staff, and it has not b...
Overview
• Specific requirements that apply to
clothing, textiles used for clothing, and
sleepwear
– Regulations under the...
16 CFR PART 1610
Standard for the Flammability
of Clothing Textiles
16 CFR Part 1610: Background
• Commonly referred to as the General Wearing
Apparel Standard
• Enacted in the 1950s
• Keeps...
16 CFR Part 1610: Summary
• Applies to all adult and children’s wearing
apparel.
– Some exceptions and exemptions
• Specif...
1610.1(c): Exceptions
• Interlining fabrics
• Most hats, gloves, and footwear
Examples that are not exempt:
– Gloves longe...
1610.1(d): Specific Exemptions
• Plain surface fabrics ≥88.2 g/m2 (2.6
oz/yd2), regardless of fiber content
• Plain and ra...
16 CFR Part 1610: Test Summary
• 16 mm (5/8 in) flame impinges on specimen mounted at
45-degree angle for 1 second
• Allow...
16 CFR Part 1610: Test Summary
• Determine fiber and fabric
type
• Preliminary test
• Prepare and condition
• Test
• Preli...
16 CFR Part 1610: Classifications
• Class 1 – plain and raised surface fabrics that have no
unusual burning characteristic...
16 CFR Part 1610: Classifications
Code
Description Time
Reported
SF uc Surface flash, under stop thread, but does not brea...
16 CFR Part 1610:
Common Noncomplying Fabrics
• Sheer 100% rayon skirts and scarves
• Sheer 100% silk scarves
• 100% rayon...
16 CFR PARTS 1615 AND 1616
Standards for the Flammability
of Children’s Sleepwear
16 CFR Parts 1615 & 1616: What is Covered?
• Any product of wearing apparel intended to be
worn primarily for sleeping or ...
16 CFR Parts 1615 & 1616: Exceptions
• Diapers and Underwear (exempt)
– Must comply with 16 CFR Part 1610
• Infant garment...
16 CFR Parts 1615 & 1616: Exceptions
Tight-Fitting Sleepwear (exempt)
• Tight-fitting garments (defined by the Standards) ...
16 CFR Parts 1615 & 1616: Requirements
• Children’s sleepwear (that is not tight-fitting)
must pass the flammability requi...
16 CFR Parts 1615 & 1616: Requirements
• Multiple stages of testing are required, following
prescriptive sampling plans
16 CFR Parts 1615 & 1616: Summary
• Test fabric, seams, and trim
• Test sample of five specimens
• Vertical orientation
• ...
16 CFR Parts 1615 & 1616: Summary
• Five 8.9 cm x 25.4 cm (3.5 inches
x10 inches) specimens of
fabric, seams, and trim.
• ...
16 CFR Parts 1615 & 1616: Requirements
• The average char length of 5 specimens cannot
exceed 17.8 cm (7.0 inches).
• No i...
FFA Guidance
• http://www.cpsc.gov/en/Regu
lations-Laws--
Standards/Regulations-
Mandatory-Standards--
Bans/Regulated-Prod...
ASTM F1816-97
Drawstrings on Children’s
Clothing
Drawstring Requirements
Children’s Clothing
• CPSC issued guidelines (1996) later adopted by ASTM in
1997 (ASTM F1816-97)
...
THE CONSUMER PRODUCT
SAFETY IMPROVEMENT ACT
Textiles and Related Products
What’s Required: Clothing
• Adult clothing:
– 16 CFR Part 1610 (Flammability)
– GCC Required, including for products that
...
What’s Required: Children’s Clothing
• Children’s Clothing:
– 16 CFR Part 1610 (Flammability)
– CPC Required, Third Party ...
What’s Required: Children’s Sleepwear
• Children’s Sleepwear:
– 16 CFR Parts 1615 and 1616 (Flammability)
• 16 CFR Part 16...
Resource: Small Business Ombudsman
http://www.cpsc.gov/en/Business--Manufacturing/Small-Business-Resources/
Resource: Searchable List of Laboratories
http://www.cpsc.gov/cgi-bin/labsearch/
For Further Information:
Jacqueline Campbell
Textile Technologist
Office of Hazard Identification and Reduction
301-987-20...
www.intertek.com41
Seemanta Mitra
Senior Director – North America Softlines
seemanta.mitra@intertek.com
CPSC SEATTLE SAFET...
www.intertek.com42
For more than 127 years, companies around
the world have depended on Intertek to ensure
the quality an...
www.intertek.com43
16 CFR 1610 – Standard for the
Flammability of Clothing Textiles
 16 CFR 1615/1616 – Standards for th...
www.intertek.com44
 16 CFR 1120: Substantial Product Hazard List
Drawstrings
www.intertek.com45
Overview of 16 CFR 1610 –
Standard for the Flammability of Clothing Textiles
• The standard provides me...
www.intertek.com46
Overview of 16 CFR 1610 –
Standard for the Flammability of Clothing Textiles
www.intertek.com47
16 CFR 1610 – Issues That Come Up Regarding The
Regulation
• Is leather apparel exempted from the
regul...
www.intertek.com48
16 CFR 1610 – Issues That Come Up Regarding The
Regulation
www.intertek.com49
16 CFR 1610 – Issues That Come Up Regarding The
Regulation
CPSC Comments:
Sample A: Design has a float ...
www.intertek.com50
16 CFR 1610 – Issues That Come Up Regarding The
Regulation
Sample D: Sample is a ‘burn-out’ or flat wov...
www.intertek.com51
16 CFR 1610 – Lab Data Sheet
Surface type: Plain Raised
Tested side: Face Back
Original State
After one...
www.intertek.com52
16 CFR 1610 – Lab Data Sheet
Prepared by: Tested by: Checked by:
Date _______________ Date ____________...
www.intertek.com53
Children’s sleepwear & non-sleepwear flammability regulation
requirement:
Product
Requirements
16 CFR
1...
www.intertek.com54
Sample Preparation:
Specimen size 3.5” x 10.0”
•FPU – Original state
•10 specimens
•FPU – 50 laundering...
www.intertek.com55
General Criteria:
a)Average char length
per sample shall not
exceed 7.0”
a)No individual specimen
shal...
www.intertek.com56
1 2
16 CFR 1615/1616
www.intertek.com57
3 4
16 CFR 1615/1616
www.intertek.com58
5
16 CFR 1615/1616
www.intertek.com59
Fabric Weight Load
g / m2 oz / yd2 gram pound
Less than
101
Less than 3 54.4 0.12
101 to 207
3 to Less
...
www.intertek.com60
16 CFR 1615/1616 – Issues That Come Up Regarding The
Regulation
• Stages of testing (FPU, prototype sea...
www.intertek.com61
16 CFR 1615/1616 – Issues That Come Up Regarding The
Regulation
CPSC Response: If the baby wears pajama...
www.intertek.com62
16 CFR 1615/1616 – Issues That Come Up Regarding The
Regulation
CPSC Response: We would not
consider th...
www.intertek.com63
16 CFR 1615/1616 – Issues That Come Up Regarding The
Regulation
CPSC has recalled this
product for fail...
www.intertek.com64
Drawstring: A non-retractable cord, ribbon or tape of
any material to pull together parts of upper oute...
www.intertek.com65
Drawstrings – Issues That Come Up Regarding The
Regulation
New York
Law
Wisconsin
Law
CPSC /
ASTM
What ...
www.intertek.com66
Drawstrings – Issues That Come Up Regarding The
Regulation
Waist or Bottom Drawstring Requirements
Sta...
www.intertek.com67
Drawstrings – Issues That Come Up Regarding The
Regulation
Are ties considered drawstrings?
Yes – CPSC ...
www.intertek.com68
Drawstrings – Issues That Come Up Regarding The
Regulation
Are belts considered drawstrings?
No. Belts ...
www.intertek.com69
Drawstrings – Issues That Come Up Regarding The
Regulation
What if the garment is not sized using a
num...
www.intertek.com70
Drawstrings – Issues That Come Up Regarding The
Regulation
Garments in girls' and boys' letter or word...
www.intertek.com71
Valued Quality. Delivered.
Hardy Poole
Vice President, Regulatory and Technical Affairs
National Council of Textile Organizations
at the
Henry M. Jac...
• NCTO was formed in 2004 from the members of the
American Textile Manufacturers Institute and the
American Yarn Spinners ...
Manufacturing members are companies that
produce:
- Fibers
- Yarns
- Fabrics
- Dye/finish/print substrates
- Textile end-i...
•Goal of Consumers
•Goal of Government
•Goal of the Textile Industry
Safe Consumer Products
Regulated Textile Products:
• General Wearing Apparel
• Children’s Sleepwear
• Carpets & Rugs
• Mattresses & Mattress Pads...
• 16 CFR 1610 or 45 Degree Angle Test
• Effective since 1953 when FFA became Law
• Agency Reviews Standard Periodically
La...
• Two Standards:
 16 CFR 1615 (Sizes 0-6x)
 16 CFR 1616 (Sizes 7-14)
• TRIS – Topical Flame Retardant Treatment
• 1977 B...
• Important chemical used in small amounts in
textile dyes and finishes
• Animal testing in the 1980’s suggested it might ...
• CPSC’s Director of Health Sciences
participated in:
• Developing the test protocol,
• Managing the animal testing,
• Rev...
• Identified potential problem
• Assembled best minds available to define and
address the issue
• Worked cooperatively in ...
• TB 117 has been in place since 1970’s
• California was first and only state to have a
mandatory furniture flammability s...
• Regulatory body under the California
Department of Consumer Affairs
• Mission: to protect and serve consumers while
ensu...
• TB 117-2013 -- proposed a smolder rather
than open-flame standard
• Agree that addressing the smolder
component initiall...
• Standard was proposed and hearing
completed last spring
• Precision and Bias Study near completion
• Final 15-day commen...
• Fabrics tested by TB 117-2013 or a similar
method* can be sold after the effective date
without additional testing
• New...
• Consumers, Government and the Textile
Industry have the same goals – Safe Products
• Working together, we are able to ad...
What is the General Concept Behind CPSC’s
Pilot System for Risk Assessment?
Integrates available risk information to model...
What Improvements are Expected from CPSC’s
Production System for Risk Assessment?
Seattle Safety Academy 2013
• Higher rat...
What are the Societal Benefits to CPSC’s
Production System for Risk Assessment?
• Save Lives and Prevent Injuries
• Facili...
Other Questions
• If I am an importer who brings in product that
does not meet mandatory requirements, am I
required to fi...
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2013 Flammability Requirements for Apparel and Sleepwear & Drawstrings in Children's Upper Outerwear, 2013 Safety Academy

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2013 Flammability Requirements for Apparel and Sleepwear & Drawstrings in Children's Upper Outerwear, 2013 Safety Academy

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  • This slide presents Children’s clothing regulations under the Consumer Product Safety Improvement Act of 2008.Certification: A General Certification of Conformity (GCC) is required for all products subject to a rule, ban, standard or regulation enforced by the CPSC. Lead in paint and other surface coatings, including screen printing, coated zippers, and all labels, must not exceed 90ppm. Exemptions do not apply to other parts of clothing such as decorations and fasteners made of metal, plastic, vinyl, crystal and coated leather that might contain lead. These must be third party tested.“Child care article” - a consumer product designed or intended by the manufacturer to facilitate sleep or the feeding of Child care article is a product forchildren age 3 years and younger, or to help such children with sucking or teething.Small parts – buttons exempt from small parts regulation, but should be secure. If buttons start falling off due to poor constructions, report to CPSC immediately as a possible hazard.Phthalates – pajamas with footies – screen printing on clothing. Phthalates in excess of 0.1%Permanent ban in use in all toys and child care articlesDEHPDBPBBP
  • The purpose of the standard is to reduce the risk of injury and loss of life and property by providing standard test methods and rating the flammability of textiles and textile products for clothing use, keep dangerously flammable textiles and garments made from those textiles out of commerce. This is a minimal standard and applies to both adult and children’s wearing apparel. (next slide)
  • First step: Determine fabric type and specificationsPlain surface textile fabric or raised surface textile fabricFabric weightFiber content Preliminary burns are conducted to determine the fastest burning area and direction of fabric.Fabrics are conditioned and then tested in their original state, 5 specimens Tested in direction of fastest burn timeRaised surface fabrics are brushed to raise fibersClass 1 and 2 fabrics are refurbished and tested again, another 5 specimensAll samples are dry cleanedAll samples are washed and tumble dried, 1 cycle The burn time of several specimens is averaged and a Class (Class 1, 2, or 3) designation is made based on the average burn time (speed of burning) and surface characteristics of the sample.
  • *This slide may be removed for presentation (may be too much detail for audience).
  • What are the potential benefits, measured or anticipated, of having a fully built Production System?Expect to grow with additional efficiencies and staff.
  • What is the benefit to society?–Creation of a production risk system may save an estimated 19 lives and prevent an estimated 20,600 to 23,000 injuries annually that occur as a direct result of hazardous imported consumer products.– By identifying lower-risk importers and manufacturers who supply consistently compliant products into U.S. commerce, the CPSC can allow them reduced review at importation, resulting in reduced port processing and savings of costs and time. Through improved targeting, high-risk cargo will be stopped at ports of entry. Thus, the system will protect companies and industries better from the cost and legal exposure of distributing and retailing products that are hazardous and may ultimately be subject to recall.
  • YES, but if an importer is responsive and complying with addressing the problem, Compliance uses it’s discretion and would say that a separate report is not necessary.When CPSC screens a product at importation and finds the product to violative, we request the certificate to see if the product was tested. CPSC if first and foremost concerned about the health and safety aspect of the product. We currently treat certificates as a secondary violation. If however, product continues to be entered and product continues to not pass, it is highly unlikely that CPSC will allow the cargo to move until product is tested. This causes great delay in delivery schedules and costs for storage.
  • 2013 Flammability Requirements for Apparel and Sleepwear & Drawstrings in Children's Upper Outerwear, 2013 Safety Academy

    1. 1. U.S. CPSC This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission. SEATTLE SAFETY SEMINAR FLAMMABLE FABRICS, SLEEPWEAR, DRAWSTRINGS SEPTEMBER 16, 2013
    2. 2. 2 Mary Toro, Director, Office of Compliance, Regulatory Enforcement Division, moderator Jacqueline Campbell, Textile Technologist, CPSC Seemanta Mitra, Senior Director, Textiles, Intertek, Hardy Poole, Vice President, National Council of Textile Organizations Panelists
    3. 3. 3 Flammable Fabrics Act 1. Wearing Apparel 2. Vinyl Plastic Film 3. Children’s Sleepwear 4. Carpets and Rugs 5. Mattresses, mattress pads 6. Mattresses, mattress pads 1. 1610 2. 1611 3. 1615/1615 4. 1630/1631 5. 1632: Cigarette Ignition 6. 1633: Open Flame Ignition 16 CFR Part and Title
    4. 4. Children’s Clothing Requirements 1. Relevant Mandatory Flammability Standard 2. Children’s Product Certification of Conformity (CPC) 3. Third Party Testing 4. Lead Content 5. Lead in Surface Coatings 6. Tracking Labels 7. Phthalates (e.g., child care articles, sleepwear for children < 3 years) 8. Small Parts (exemptions for buttons, fabrics) 9. Drawstrings in Children’s Upper Outerwear
    5. 5. Violations/Prohibited Acts • Manufacturing for sale, offering for sale, importing, delivery for introduction, transporting in commerce, of any product or fabric that does not comply with a flammability standard • Failing to furnish information required by Section 15(b) • Failure to issue a certificate of conformity 5
    6. 6. All Regulated LOA’s FY08-FY13 0 500 1000 1500 2000 2500 915 1044 1926 1677 2316 1685 FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6
    7. 7. All Flammable Fabrics Act LOA’s FY08-FY13 0 20 40 60 80 100 120 140 160 49 75 63 71 152 97 FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6
    8. 8. Flammable Fabrics Act LOA’s FY08-FY13 by Product Type 0 10 20 30 40 50 60 70 80 90 47 1 1 32 36 7 52 8 3 48 15 8 60 81 11 32 62 3 FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6 Mattress Data Sleepwear Data All other apparel
    9. 9. FY13 - Recalls, Stop Sales and Seizures as of 9/6 1127 793 21 0 200 400 600 800 1000 1200 Recalls Seizures Stop Sales
    10. 10. Requirements for Clothing Textiles and Children’s Sleepwear This presentation was prepared by CPSC staff, and it has not been reviewed or approved by, and may not reflect the views of, the Commission. Jacqueline Campbell Combustion and Fire Sciences Division Engineering Sciences Directorate U.S. Consumer Product Safety Commission
    11. 11. Overview • Specific requirements that apply to clothing, textiles used for clothing, and sleepwear – Regulations under the Flammable Fabrics Act (FFA) • Flammability of clothing textiles • Children’s sleepwear – Drawstring requirements (children’s clothing) – Requirements under the Consumer Product Safety Improvement Act of 2008 (CPSIA)
    12. 12. 16 CFR PART 1610 Standard for the Flammability of Clothing Textiles
    13. 13. 16 CFR Part 1610: Background • Commonly referred to as the General Wearing Apparel Standard • Enacted in the 1950s • Keeps the most dangerously flammable textile products and garments out of the marketplace
    14. 14. 16 CFR Part 1610: Summary • Applies to all adult and children’s wearing apparel. – Some exceptions and exemptions • Specifies testing procedures used to determine the relative flammability of textiles used in apparel as one of three classes of flammability. • Fabrics that meet a specific exemption do not require testing.
    15. 15. 1610.1(c): Exceptions • Interlining fabrics • Most hats, gloves, and footwear Examples that are not exempt: – Gloves longer than 14 inches and/or attached to a garment – Hats that cover the neck, face, or shoulders – Footwear that consists in whole or in part of hosiery or is part of another garment
    16. 16. 1610.1(d): Specific Exemptions • Plain surface fabrics ≥88.2 g/m2 (2.6 oz/yd2), regardless of fiber content • Plain and raised surface fabrics made of: acrylic, modacrylic, nylon, olefin, polyester, wool, or any combination of these fibers, regardless of weight.
    17. 17. 16 CFR Part 1610: Test Summary • 16 mm (5/8 in) flame impinges on specimen mounted at 45-degree angle for 1 second • Allowed to burn full length or until stop thread breaks • Results of several tests are averaged and a Class designation is assigned
    18. 18. 16 CFR Part 1610: Test Summary • Determine fiber and fabric type • Preliminary test • Prepare and condition • Test • Preliminary classification • Refurbish and repeat test • Final classification • Report
    19. 19. 16 CFR Part 1610: Classifications • Class 1 – plain and raised surface fabrics that have no unusual burning characteristics and are acceptable for use in clothing • Class 2 – raised surface fabrics only, intermediate flammability- use with caution • Class 3 – fabrics are dangerously flammable and CANNOT be used in wearing apparel Classification Plain Surface Raised Fiber Surface Class 1 Average burn time > 3.5 s Average burn time > 7.0 s OR Average burn time is 0-7 s with no base burns (SFBB) Class 2 N/A Average burn time is 4-7 s with base burn (SFBB) Class 3 Average burn time < 3.5 s Average burn time < 4.0 s with base burn (SFBB)
    20. 20. 16 CFR Part 1610: Classifications Code Description Time Reported SF uc Surface flash, under stop thread, but does not break thread. None SF pw Surface flash, part way; does not break thread. None SF poi Surface flash, at point of impingement only; equivalent to DNI for plain surface fabrics. None _._ sec Actual burn time (sec) measured and recorded by the timing device. Yes _._ SF Time (sec), surface flash only; no damage to the base fabric. Yes _._SFBB Time (sec), surface flash base burn starting at places other than the point of impingement as a result of surface flash. Yes _._SFBBpoi Time (sec), surface flash base burn starting at the point of impingement. Yes _._SFBBpoi* Time (sec), surface flash base burn possibly starting at the point of impingement; the asterisk is accompanied by the following statement if there is a question as to the origin of the base burn: Unable to make absolute determination as to source of base burns. Yes Note: A result of SFBBpoi or SFBBpoi* does not qualify as a base burn under the current interpretation of 16 CFR Part 1610.
    21. 21. 16 CFR Part 1610: Common Noncomplying Fabrics • Sheer 100% rayon skirts and scarves • Sheer 100% silk scarves • 100% rayon and rayon/nylon chenille sweaters • Long animal hair sweaters • Polyester/cotton and 100% cotton fleece garments • 100% cotton terry cloth robes
    22. 22. 16 CFR PARTS 1615 AND 1616 Standards for the Flammability of Children’s Sleepwear
    23. 23. 16 CFR Parts 1615 & 1616: What is Covered? • Any product of wearing apparel intended to be worn primarily for sleeping or activities related to sleep in sizes larger than 9 months through size 14. – Included: nightgowns, pajamas, robes, and similar or related items, such as loungewear. • Several factors determine if a garment is sleepwear: – Suitability for sleeping, likelihood of garment to be used for sleeping – Garment and fabric features – Marketing, merchandising/display, intended use
    24. 24. 16 CFR Parts 1615 & 1616: Exceptions • Diapers and Underwear (exempt) – Must comply with 16 CFR Part 1610 • Infant garments (exempt) – Sizes 9 months or younger – One-piece garment does not exceed 64.8 cm (25.75”) in length – Two-piece garment has no piece exceeding 40 cm (15.75”) in length – Must comply with 16 CFR Part 1610
    25. 25. 16 CFR Parts 1615 & 1616: Exceptions Tight-Fitting Sleepwear (exempt) • Tight-fitting garments (defined by the Standards) are exempt from testing to the sleepwear requirements. • Must: – Not exceed specified dimensions. – Comply with 16 CFR Part 1610. – Meet labeling requirements.
    26. 26. 16 CFR Parts 1615 & 1616: Requirements • Children’s sleepwear (that is not tight-fitting) must pass the flammability requirements. – All fabrics and garments must be flame resistant and self-extinguish (not continue to burn) when removed from a small, open-flame ignition source. • Multiple stages of testing are required, following prescriptive sampling plans.
    27. 27. 16 CFR Parts 1615 & 1616: Requirements • Multiple stages of testing are required, following prescriptive sampling plans
    28. 28. 16 CFR Parts 1615 & 1616: Summary • Test fabric, seams, and trim • Test sample of five specimens • Vertical orientation • Test in original state and after 50 laundering cycles
    29. 29. 16 CFR Parts 1615 & 1616: Summary • Five 8.9 cm x 25.4 cm (3.5 inches x10 inches) specimens of fabric, seams, and trim. • Specimens are conditioned before testing. • The gas flame of 3.8 cm (1.5 inches) is applied to the bottom edge of the specimen for 3 seconds. • Char (burn) length is measured after the flame/afterglow has ceased. Preparing to apply ignition source to specimen
    30. 30. 16 CFR Parts 1615 & 1616: Requirements • The average char length of 5 specimens cannot exceed 17.8 cm (7.0 inches). • No individual specimen can have a char length of 25.4cm (10.0 inches) (full-specimen burn). • Production testing and recordkeeping requirements – Tested samples must be retained
    31. 31. FFA Guidance • http://www.cpsc.gov/en/Regu lations-Laws-- Standards/Regulations- Mandatory-Standards-- Bans/Regulated-Products/ – Search by product (use wearing apparel and sleepwear) – http://www.cpsc.gov/busi nfo/loungewear.pdf
    32. 32. ASTM F1816-97 Drawstrings on Children’s Clothing
    33. 33. Drawstring Requirements Children’s Clothing • CPSC issued guidelines (1996) later adopted by ASTM in 1997 (ASTM F1816-97) – May 2006 letter to industry (http://www.cpsc.gov/PageFiles/135448/drawstring.pdf) • Substantial product hazard • Applies to drawstrings on upper outwear, jackets, and sweatshirts • Sizes 2T-12 (or equivalent) with neck or hood drawstrings • Sizes 2T-16 (or equivalent) with waist or bottom drawstrings that do not meet specified criteria • Dresses are not upper outerwear • Belts are not drawstrings
    34. 34. THE CONSUMER PRODUCT SAFETY IMPROVEMENT ACT Textiles and Related Products
    35. 35. What’s Required: Clothing • Adult clothing: – 16 CFR Part 1610 (Flammability) – GCC Required, including for products that are exempt from testing
    36. 36. What’s Required: Children’s Clothing • Children’s Clothing: – 16 CFR Part 1610 (Flammability) – CPC Required, Third Party Testing – Lead Content – Lead Surface Coating – Tracking Labels – Drawstring Requirements
    37. 37. What’s Required: Children’s Sleepwear • Children’s Sleepwear: – 16 CFR Parts 1615 and 1616 (Flammability) • 16 CFR Part 1610 if tight-fitting – CPC Required, Third Party Testing – Lead Content – Lead Surface Coating – Tracking Labels – Phthalate Requirements (sleepwear for children three years old or younger)
    38. 38. Resource: Small Business Ombudsman http://www.cpsc.gov/en/Business--Manufacturing/Small-Business-Resources/
    39. 39. Resource: Searchable List of Laboratories http://www.cpsc.gov/cgi-bin/labsearch/
    40. 40. For Further Information: Jacqueline Campbell Textile Technologist Office of Hazard Identification and Reduction 301-987-2024 jcampbell@cpsc.gov Allyson Tenney Lead Compliance Officer Office of Compliance and Field Operations 301-504-7567 atenney@cpsc.gov www.cpsc.gov
    41. 41. www.intertek.com41 Seemanta Mitra Senior Director – North America Softlines seemanta.mitra@intertek.com CPSC SEATTLE SAFETY ACADEMY FLAMMABLE FABRICS, SLEEPWEAR, DRAWSTRINGS SEPTEMBER 18, 2013
    42. 42. www.intertek.com42 For more than 127 years, companies around the world have depended on Intertek to ensure the quality and safety of their products, processes and systems. Intertek is the industry leader with over 36,000 people in 1,000 locations in over 100 countries. Intertek has one of the largest number of CPSC approved laboratories to conduct CPSIA testing on consumer products. Introduction - About Intertek
    43. 43. www.intertek.com43 16 CFR 1610 – Standard for the Flammability of Clothing Textiles  16 CFR 1615/1616 – Standards for the Flammability of Children’s Sleepwear  Drawstrings (ASTM F1816-97) Intertek has made all reasonable efforts to ensure the accuracy of the information provided. However, the information provided should not be relied upon as legal advice, or a substitute for legal advice. Discussion Topics
    44. 44. www.intertek.com44  16 CFR 1120: Substantial Product Hazard List Drawstrings
    45. 45. www.intertek.com45 Overview of 16 CFR 1610 – Standard for the Flammability of Clothing Textiles • The standard provides methods of testing • Establishes three classes of flammability • Sets requirements for clothing textiles and apparel • Warns against the use of unsuitable textiles
    46. 46. www.intertek.com46 Overview of 16 CFR 1610 – Standard for the Flammability of Clothing Textiles
    47. 47. www.intertek.com47 16 CFR 1610 – Issues That Come Up Regarding The Regulation • Is leather apparel exempted from the regulation? • Is the inside surface of socks exempted from the regulation as unexposed surface? • Are belts covered by the regulation? • Interpretation of plain and raised-surface fabrics
    48. 48. www.intertek.com48 16 CFR 1610 – Issues That Come Up Regarding The Regulation
    49. 49. www.intertek.com49 16 CFR 1610 – Issues That Come Up Regarding The Regulation CPSC Comments: Sample A: Design has a float yarn, sheared at the edges forming a fiber tuft. The edge is intentionally raised. Overall comment: Raised surface Sample B: The edges are not intentionally raised. Overall comment: Plain surface Sample C: Design has a float yarn, sheared at the edges forming a fiber tuft. Edge is intentionally raised. Overall comment: Raised surface
    50. 50. www.intertek.com50 16 CFR 1610 – Issues That Come Up Regarding The Regulation Sample D: Sample is a ‘burn-out’ or flat woven construction without an intentionally raised fiber surface. The slight ‘fringe’ on some edges occurs because the satin weave anchoring the filling yarns is not tightly woven. Overall comment: Plain surface Sample E: Design is similar to sample ‘A’ and ‘C’ with a float yarn, sheared at the edges forming a fiber tuft. Edge is intentionally raised. Overall comment: Raised surface Sample F: The black and white yarn design is woven into the fabric as a pattern, but does not have an intentionally raised edge. Overall comment: Plain surface
    51. 51. www.intertek.com51 16 CFR 1610 – Lab Data Sheet Surface type: Plain Raised Tested side: Face Back Original State After one dry cleaning and laundering per AATCC TM 124, option (1)(IV)(A)(iii) Preliminary Test Preliminary Test Length Burn Characteristics Time (s) Length Burn Characteristics Time (s) Up Up Down Down Width Burn Characteristics Time (s) Width Burn Characteristics Time (s) Up Up Down Down Final Test Final Test Test Burn Direction: Length Width Test Burn Direction: Length Width Specimens Burn Characteristics Time (s) Specimens Burn Characteristics Time (s) 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9 10 10 Average: Average: Classification:  Class 1, Normal Flammability,  Class 2, Intermediate Flammability, Raised surface  Class 3, Rapid and Intense Burning,  No Evaluation Due to Insufficient Sample submitted for testing Sample Identification: _______________________Fabric Weight (oz/yd2) ________ Claimed Fiber Content: ________________________________________________
    52. 52. www.intertek.com52 16 CFR 1610 – Lab Data Sheet Prepared by: Tested by: Checked by: Date _______________ Date _________________ Date ___________  Sample is exempt because it is a plain surface fabric which weighs 2.6 oz/yd² or more. Actual fabric weight is _____ oz/yd².  Sample is exempt because of its fiber content. The claimed fiber content is _____________________. Test additional five specimens (both original and after refurbishment) if Plain Surface Only 1 burn time & it is <3.5s; Average burn time <3.5s. Raised surface Only 1 burn time & it is <4s with SFBB; Average burn time <4s with 2 or more SFBB. Explanation of Flammability Results: For plain surface fabric DNI Did not ignite IBE Ignited but extinguished (no time) *IBE Ignited, but extinguished, the asterisk (*) denotes a burn that goes under the cord without breaking the cord. 0.0 BB Actual time of burn from ignition until the flame severs the cord directly above the specimen. For raised surface fabric SF uc Surface flash, under stop cord, but does not break the cord (no time) SF pw Surface flash, part way. No time shown because the surface flash did not break the cord. SF poi Surface flash, at point of impingement only (equivalent to “did not ignite” for plain surfaces). 0.0 SF only Time in seconds, surface flash only. No damage to the base fabric. 0.0 SFBB Time in seconds, surface flash base burn. Base starts burning at points other than that point of impingement. 0.0 SFBB poi Time in seconds, surface flash base burn starting at the point of impingement. * 0.0 SFBB poi Time in seconds, surface flash base burn possibly starting at the point of impingement. The asterisk is accompanied by the following: “Unable to make absolute determination as to source of base burns.” This note is added to the result of any specimen if there are questions as to origin of the base burning. It does not qualify as a base burn under the current interpretation of CFR 1610.
    53. 53. www.intertek.com53 Children’s sleepwear & non-sleepwear flammability regulation requirement: Product Requirements 16 CFR 1615 / 1616 16 CFR 1610 Tight fitting Specs Children’s Sleepwear Loose fitting * Tight fitting * * Innerwear, Long Underwear, Daywear * Flammability Regulation
    54. 54. www.intertek.com54 Sample Preparation: Specimen size 3.5” x 10.0” •FPU – Original state •10 specimens •FPU – 50 launderings •10 specimens •Prototype •15 specimens of each construction type •Garment •15 longest seam specimens 16 CFR 1615/1616 – Standards for the Flammability of Children’s Sleepwear
    55. 55. www.intertek.com55 General Criteria: a)Average char length per sample shall not exceed 7.0” a)No individual specimen shall have a char length of 10.0” Flammability Test Apparatus for Children’s Sleepwear 16 CFR 1615/1616
    56. 56. www.intertek.com56 1 2 16 CFR 1615/1616
    57. 57. www.intertek.com57 3 4 16 CFR 1615/1616
    58. 58. www.intertek.com58 5 16 CFR 1615/1616
    59. 59. www.intertek.com59 Fabric Weight Load g / m2 oz / yd2 gram pound Less than 101 Less than 3 54.4 0.12 101 to 207 3 to Less than 6 113.4 0.25 207 to 338 6 to 10 226.8 0.50 Greater than 338 Greater than 10 340.2 0.75 To Determine Char Length of Specimen 16 CFR 1615/1616
    60. 60. www.intertek.com60 16 CFR 1615/1616 – Issues That Come Up Regarding The Regulation • Stages of testing (FPU, prototype seams and trims, GPU) – from the perspective of the test applicant • Interpretation of product as children’s sleepwear
    61. 61. www.intertek.com61 16 CFR 1615/1616 – Issues That Come Up Regarding The Regulation CPSC Response: If the baby wears pajama, and is placed into the bag, then the bag itself is not considered children’s sleepwear. In this case, the bag must comply with Part 1610. If the baby is put directly into the bag wearing just a diaper, then the bag is considered sleepwear and must comply with Part 1615. It should be made clear on any marketing or package materials how the manufacturer expects the garment to be used.
    62. 62. www.intertek.com62 16 CFR 1615/1616 – Issues That Come Up Regarding The Regulation CPSC Response: We would not consider this to be children’s sleepwear. We wonder whether or not the orange/red item would be comfortable for sleeping since it has a hood (with eyes & nose) and the bulky pieces at the two upper corners. We have seen similar items and they were used as towels, rather than blankets.
    63. 63. www.intertek.com63 16 CFR 1615/1616 – Issues That Come Up Regarding The Regulation CPSC has recalled this product for failing to meet the Standard for the Flammability of Children's Sleepwear, and pose a risk of burn injury to children due to the possible ignition of the garment.
    64. 64. www.intertek.com64 Drawstring: A non-retractable cord, ribbon or tape of any material to pull together parts of upper outerwear to provide for closure. Drawstrings – ASTM F1816-97
    65. 65. www.intertek.com65 Drawstrings – Issues That Come Up Regarding The Regulation New York Law Wisconsin Law CPSC / ASTM What types of apparel are affected? All children’s clothing All children’s clothing Upper outerwear What sizes? 2T-12 0-16 2T-12 What are the requirements? No hood / neck drawstrings are allowed No hood / neck drawstrings are allowed Drawstrings should not be used in the head / neck area  State laws – NY and WI laws on drawstrings Hood and Neck Drawstring Requirements
    66. 66. www.intertek.com66 Drawstrings – Issues That Come Up Regarding The Regulation Waist or Bottom Drawstring Requirements State laws: NY and WI laws on drawstrings New York Law Wisconsin Law CPSC / ASTM What types of apparel are affected? All children’s clothing Children’s upper outerwear Children’s upper outerwear What sizes? 2T-16 0-16 2T-16 What are the requirements? No more than 3 inches of the drawstring shall be outside of the drawstring channel when the garment is extended to its fullest width The drawstring shall be attached to the garment at its midpoint. Toggles, knots or other attachments shall not be used at the ends of the drawstrings No more than 3 inches of the drawstring shall be outside of the drawstring channel when the garment is extended to its fullest width. Toggles, knots or other attachments shall not be used at the ends of the drawstring. The drawstring shall be sewn at the midpoint of the channel so that it cannot be completely pulled out of the channel. No more than 3 inches of the drawstring shall be outside of the drawstring channel when the garment is extended to its fullest width. Toggles, knots or other attachments shall not be used at the ends of the drawstring. The drawstring shall be sewn at the midpoint of the channel so that it cannot be pulled long enough to catch on something.
    67. 67. www.intertek.com67 Drawstrings – Issues That Come Up Regarding The Regulation Are ties considered drawstrings? Yes – CPSC considers ties as drawstrings. The standard defines a "drawstring" as a "non- retractable cord, ribbon, or tape of any material to pull together parts of upper outerwear to provide for closure." The standard's "drawstring" definition is not limited to cords, ribbons, or tapes that pass through a channel, and the definition does not exclude ties.
    68. 68. www.intertek.com68 Drawstrings – Issues That Come Up Regarding The Regulation Are belts considered drawstrings? No. Belts are not included in the voluntary standard or the Commission's 15(j) rule for drawstrings, and therefore, they are not listed as an identified substantial product hazard in all cases. However, should the Commission determine that certain belt configurations or styles in children's upper outerwear present a substantial product hazard under section 15(a)(2) of the Consumer Product Safety Act (CPSA), it would seek corrective action under section 15 of the CPSA or section 15 of the Federal Hazardous Substances Act (FHSA).
    69. 69. www.intertek.com69 Drawstrings – Issues That Come Up Regarding The Regulation What if the garment is not sized using a numerical system? To facilitate determining which garments that are sized under a sizing system other than the numerical system (2T to 16) are equivalent to sizes 2T to 16, the rule provides that: Garments in girls' size Large (L) and boys' size Large (L) are equivalent to size 12.  Garments in girls' size Extra-Large (XL) and boys' size Extra-Large (XL) are equivalent to size 16.
    70. 70. www.intertek.com70 Drawstrings – Issues That Come Up Regarding The Regulation Garments in girls' and boys' letter or word sizes smaller than sizes Large (L) or Extra-Large (XL), as applicable, are equivalent to correspondingly smaller numerical sizes. The fact that a garment is labeled as being larger than size Large (L) or size Extra-Large (XL), as applicable, does not necessarily mean that the item is not equivalent to a size in the range of 2T to 12, or in the range of 2T to 16. The Commission may use any other evidence that would tend to show that a garment is a size that is equivalent to sizes 2T to 16.
    71. 71. www.intertek.com71 Valued Quality. Delivered.
    72. 72. Hardy Poole Vice President, Regulatory and Technical Affairs National Council of Textile Organizations at the Henry M. Jackson Federal Building Seattle, Washington September 18, 2013 CPSC Safety Academy
    73. 73. • NCTO was formed in 2004 from the members of the American Textile Manufacturers Institute and the American Yarn Spinners Association. • NCTO was an entirely new association with a structure designed to accommodate all sectors of the industry. • In 2013, the National Textile Association and the American Manufacturers Trade Action Coalition merged with NCTO, creating a single voice for the U.S. textile industry. • 150 member companies in 28 states National Council of Textile Organizations
    74. 74. Manufacturing members are companies that produce: - Fibers - Yarns - Fabrics - Dye/finish/print substrates - Textile end-items Structure
    75. 75. •Goal of Consumers •Goal of Government •Goal of the Textile Industry Safe Consumer Products
    76. 76. Regulated Textile Products: • General Wearing Apparel • Children’s Sleepwear • Carpets & Rugs • Mattresses & Mattress Pads (smoldering ignition) • Mattress Sets (open flame) Flammable Fabrics Act
    77. 77. • 16 CFR 1610 or 45 Degree Angle Test • Effective since 1953 when FFA became Law • Agency Reviews Standard Periodically Last Review in 2008 • Same or Similar to Wearing Apparel Standards used by Other Developed Nations General Wearing Apparel Standard
    78. 78. • Two Standards:  16 CFR 1615 (Sizes 0-6x)  16 CFR 1616 (Sizes 7-14) • TRIS – Topical Flame Retardant Treatment • 1977 Ban on TRIS (Health Effects) • Amended 0-6x Standard (16 CFR 1615) Basically Same as 16 CFR 1616 Children’s Sleepwear Standards
    79. 79. • Important chemical used in small amounts in textile dyes and finishes • Animal testing in the 1980’s suggested it might be harmful in large doses • The textile industry along with the fiber apparel, retail and formaldehyde industries supported animal research to answer the question about human health effects Formaldehyde -- HCHO
    80. 80. • CPSC’s Director of Health Sciences participated in: • Developing the test protocol, • Managing the animal testing, • Reviewing data and • Forming conclusions based on the research Formaldehyde -- HCHO
    81. 81. • Identified potential problem • Assembled best minds available to define and address the issue • Worked cooperatively in designing and conducting research • Evaluated test data together • Reached same conclusion – HCHO in small amounts does not pose a significant risk to humans HCHO -- Model of Cooperation
    82. 82. • TB 117 has been in place since 1970’s • California was first and only state to have a mandatory furniture flammability standard • Governor Jerry Brown directed the state’s consumer agency to change the standard • New standard should eliminate or lessen the need for flame retardant chemicals in furniture California TB 117-2013
    83. 83. • Regulatory body under the California Department of Consumer Affairs • Mission: to protect and serve consumers while ensuring a competent and fair marketplace • Licenses and inspects businesses that manufacture and sell products under its authority in California Bureau of Electrical Appliance Repair, Home Furnishings and Thermal Insulation
    84. 84. • TB 117-2013 -- proposed a smolder rather than open-flame standard • Agree that addressing the smolder component initially is correct. • Supportive of TB 117-2013 proposal being based on ASTM E1353-08a. • ASTM E1353-08a is a proven standard that has been in place for over three decades. Proposed TB 117-2013
    85. 85. • Standard was proposed and hearing completed last spring • Precision and Bias Study near completion • Final 15-day comment period closed on September 3 • Final rule is expected soon Proposed TB 117-2013
    86. 86. • Fabrics tested by TB 117-2013 or a similar method* can be sold after the effective date without additional testing • New fabrics manufactured on/after the effective date are expected to comply with the TB 117- 2013 final rule _______________________________ * ASTM E1353-08a, NFPA 260 or UFAC Effective Date of TB 117-2013
    87. 87. • Consumers, Government and the Textile Industry have the same goals – Safe Products • Working together, we are able to address consumer product safety issues and address those problems that are deemed significant • After all, we want the same thing – safe consumer products Summary
    88. 88. What is the General Concept Behind CPSC’s Pilot System for Risk Assessment? Integrates available risk information to model and support Commission enforcement strategy involving product hazards at importation. Potential sources of risk data include: –shipment (CBP) –case history (CPSC & CBP) –screening history (CPSC) –injury and death (CPSC) –commercial information (Third Party) Seattle Safety Academy 2013
    89. 89. What Improvements are Expected from CPSC’s Production System for Risk Assessment? Seattle Safety Academy 2013 • Higher rate of product hazard detection at import. • Higher volume of shipments sampled and detained annually at import. • Fewer shipments unnecessarily stopped • Reduced recalls of dangerous products in commerce. – In FY 2012, 3.6 million non-firework products were stopped from entering commerce. The number of shipments examined grew 190% over FY 2007 levels while increasing the violation rate by 25% over the same period.
    90. 90. What are the Societal Benefits to CPSC’s Production System for Risk Assessment? • Save Lives and Prevent Injuries • Facilitate Legitimate Trade • Minimize Costs for the Trade, Government Agencies and U.S. Customs • Proactively Monitor Compliance Seattle Safety Academy 2013
    91. 91. Other Questions • If I am an importer who brings in product that does not meet mandatory requirements, am I required to file a report with the Commission? • What is the agency policy with respect to enforcement of certificates at ports of entry? Seattle Safety Academy 2013

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