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Children's Sleepwear Seminar - 12/2/2016


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The US Consumer Product Safety Commission held a seminar on the Flammable Fabrics Act (FFA) and Federal Hazardous Substances Act (FHSA).

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Children's Sleepwear Seminar - 12/2/2016

  1. 1. This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of the Commission. 1 Children’s Sleepwear Seminar Mary Toro U.S. Consumer Product Safety Commission December 2016
  2. 2. Seminar Overview 2  Welcome  Housekeeping Notes  Morning Seminar Agenda  CPSIA  Requirements for Children’s Products  Best Business Practices  Children’s Sleepwear Session
  3. 3. CPSC Organization* *This is a simplified functional organization chart that does not include many key support groups within the CPSC, including Administration, Human Resources, Information Services, Budget, Planning, Inspector General, Equal Employment, Office of the Secretary, and Congressional Affairs.
  4. 4. CPSC Jurisdictional Authority Jurisdictional Authority from several Acts:  Consumer Product Safety Act (CPSA)  Federal Hazardous Substances Act (FHSA)  Flammable Fabrics Act (FFA) 4
  5. 5. Consumer Product Safety Act  Enacted in 1972, the CPSA is CPSC’s umbrella statute.  CPSA  Established the agency  Defines basic authority  Authorizes CPSC to develop standards and bans  Gives CPSC the authority to pursue recalls and to ban products under certain circumstances 5
  6. 6. Consumer Product Safety Improvement Act Amendment to the statutes under which CPSC’s authorities are executed. CPSIA  Established new consumer safety mandates  Reauthorized the CPSC  Amended civil penalties  Imposed new mandatory requirements for consumer products for both non-children’s products (adult) and children’s products 6
  7. 7. Consumer Product Safety Improvement Act Many of the requirements are specifically for children’s products and child care articles. Children’s products: Designed and intended primarily for children 12 years or younger. Child care articles: Used to facilitate sleeping and feeding for children 3 years or younger. Additional requirements for child care articles. 7
  8. 8. Consumer Product Safety Improvement Act Key Chemical Requirements  Lead content and lead surface coating limits must be met  Phthalate limits for child care articles (for children 3 and under) and for children’s toys Key Procedural Requirements  CPSC-accepted accredited laboratory  Certification  GCC or CPC  Tracking labels 8
  9. 9. CPSIA - Lead Requirements 9 Total Lead Content  Children’s products  Limits total lead in accessible parts to 100 ppm Lead in Paint and Surface Coatings Phthalate limits
  10. 10. CPSIA Lead - Clothing and Textiles 10  Lead content and surface coating limits must be met for certain accessible components of textile products, clothing, and clothing accessories.  Buttons, snaps, grommets and zippers must meet total lead content requirements.  Painted buttons and snaps, painted zippers, heat transfers, and screen prints are subject to the lead in surface coating ban.  Inaccessible lead component parts are exempt.  Component part testing
  11. 11. Lead Determinations - Textiles 16 CFR Section 1500.91: Certain materials will not exceed lead limits  Includes dyed or undyed textiles and nonmetallic thread Does not require third party testing 11
  12. 12. Screen Printing 12  Screen printing—generally considered to be a surface coating  Subject to the lead in paint and surface coating limits (90 ppm)  Compliance and Testing  Test finished product at accredited CPSC-accepted laboratory  Component part testing—Obtain testing results or CPC from print ink, paint, pigment supplier  Screen printing on children’s sleepwear for children under 3 (child care article) subject to phthalate requirements
  13. 13. Phthalates - Child Care Articles 13  Phthalates are chemical plasticizers that are often used in the production of many types of plastics, certain inks, paints, and other products.  Six types of phthalates are prohibited in toys and child care articles:  Three types permanently banned (DEHP, DBP, BBP) in any amount greater than 0.1 percent (computed for each phthalate, individually)  Three types interim banned (DINP, DIDP, and DnOP)  Applies to:  Plasticized component parts in toys and child care articles  Accessible component parts
  14. 14. Testing - Children’s Products 14  Children’s products must be tested by an accredited CPSC-accepted third party laboratory.  Types of third party testing for Children’s Products:  Initial Testing  Material Change Testing  Periodic Testing  Component Part Testing  Children's Product Certificate (CPC) based on passing results of the third party testing
  15. 15. Children’s Product Testing 15  Initial Testing/Certification: Tested for compliance with applicable children’s product requirements.  Material Change/Reissue Certification: Tested when product design, manufacturing process, or component part changes.  Periodic Testing: Tested on the continuing production of a children's product to ensure continued compliance over specified time frames.  Component part testing may be used to support the testing.
  16. 16. Component Part Testing 16  Allows testing of component parts:  Manufacturers and importers may use test results or certification from component part supplier Exercise due care:  Ensure validity of results  Documentation and access to records  CPSC-accepted third party laboratory Component part testing may be sufficient for a material change to only one component.
  17. 17. Sleepwear Testing and CPSIA 17  Periodic Testing of the flammability portion of Children’s Sleepwear is met through required production testing in the standard.  Other notions, components, things subject to lead and phthalates are covered under the periodic testing requirements.
  18. 18. Small Batch Manufacturers 18 Small Batch Manufacturers  Total gross revenue from prior year is $1 million or less  Manufacture no more than 7,500 units of the same covered product Must register and apply  Issued a number by CPSC  Registration required each year Exclusion from some third party testing requirements for children’s products
  19. 19. Children’s Product Certificate (CPC) 19  Manufacturers and importers of children’s products must certify, in a written Children’s Product Certificate (CPC) based on test results from a CPSC-accepted laboratory, that their children’s products comply with applicable children’s product safety rules.
  20. 20. CPSIA - Tracking Information 20 A tracking label must contain certain basic information, including:  The name of the manufacturer or private labeler;  The location and date of production of the product;  Detailed information on the manufacturing process, such as a batch or run number, or other identifying characteristics; and  Any other information to facilitate ascertaining the specific source of the product.
  21. 21. Product Safety Concerns Products that fail to comply with a mandatory safety standard or ban under the Acts Products that fail to comply with voluntary standards, and Commission staff has determined such failure to be a substantial product hazard Product defects that could create a substantial risk of injury to the public 21
  22. 22. Reporting Requirements The manufacturer, importer, retailer, and distributer is required to report immediately upon obtaining information that reasonably supports the conclusion that a product:  Fails to meet a rule, regulation, standard, or ban under any statute enforced by the CPSC  Contains a defect which could create a substantial product hazard, or  Creates an unreasonable risk of serious injury or death 22
  23. 23. Violations/Prohibited Acts The statutes make it unlawful to:  Manufacture for sale, sell, offer for sale, distribute, or import any product that does not comply with a mandatory standard or ban under any act the Commission enforces;  Fail to report information as required by section 15(b) (CPSA);  Fail to certify;  Fail to include tracking labels when appropriate; and  Sell any recalled products. 23
  24. 24. Enforcement and Surveillance Compliance Programs  Firm Inspections Complaints  Industry, Consumers, Government Agencies Retail Surveillance/Internet Surveillance Reports from Manufacturers and Retailers Import Entry Points  Ports and Airports Industry Tradeshows Sample Collections 24
  25. 25. Import Surveillance CPSC/U.S. Customs Access to Customs Databases  Identify shipments of goods into the U.S.  Identify dates of arrival for shipments  Selective enforcement  Target key products and firms based upon previous violations 25
  26. 26. Regulated Products - Corrective Actions Violation of mandatory standard, ban, or rule, or regulation  Corrective Actions, Recalls  Seizure  Injunction  U.S. Customs action/Refuse admission  Penalties 26
  27. 27. Children’s Sleepwear Recalls 27
  28. 28. Top Violations FY2012-FY2016 31% 15% 11% 7% 6% 4% 3% 3% Sleepwear Flammability, 347, 3% 2% 15% Lead Tracking Label Pool/Spa Drain Cover Small Parts/Balls Phthalates Third Party Certificates Cribs Fireworks & Pyrotechnics Sleepwear Flammability Poison Product Packaging/Labeling Other
  29. 29. Sleepwear Violations by Violation Code FY2012-FY2016 220 85 24 15 3 Sleepwear Flammability Failure Exceeds Tight-Fitting Dimensions Sleepwear Labeling Sleepwear Policy Other Children's Sleepwear
  30. 30. Recalls by Violation FY2012-FY2016 Sleepwear Flammability , 65, 33% 17% 10% 7% 5% 5% 4% 4% 3% 3% 9% Sleepwear Flammability Lead Poisonous Product Packaging/Labeling Mattress Flammability Clothing Flammability Bicycle Helmets Pool/Spa Drain Covers Durable Nursery Products Fireworks & Pyrotechnics Small Parts
  31. 31. Sleepwear Recalls by Violation Code FY2012-FY2016 46 17 1 1 Sleepwear Flammability Failure Exceeds Tight-Fitting Dimensions Sleepwear Labeling Sleepwear Policy
  32. 32. Lauren Kleinman Trial Attorney Office of General Counsel Division of Compliance FOR OFFICIAL USE ONLY This presentation has not been reviewed or approved by the Commission and may not reflect their views. Penalties Available Under the Flammable Fabrics Act
  33. 33. Civil Penalties Under the FFA Under section 5(e) of the FFA, any person who knowingly violates a regulation or standard issued under section 4 of the FFA, 15 U.S.C. § 1193, shall be subject to a civil penalty not to exceed $100,000 for each such violation. The Commission may seek a civil penalty of up to $100,000 per violative product, up to a maximum penalty of $15.15 million for any related series of violations. (76 Federal Register 71554-55, November 18, 2011)  Effective January 1, 2017, the new adjusted maximum civil penalty amounts are $110,000 for each violation, and $16,025,000 for any related series of violations.
  34. 34. Definition of “Knowingly” The term “knowingly” is defined in section 5(e) (4) of the FFA, 15 U.S.C. § 1194.  Knowingly means (A) having actual knowledge, or (B) the presumed having of knowledge deemed to be possessed by a reasonable person who acts in the circumstances, including knowledge obtainable upon the exercise or due care to ascertain the truth of representations.
  35. 35. Civil Penalty for Sale of Flammable Children’s Sleepwear In May 2001, Federated Department Stores, Inc., of Cincinnati, OH, agreed to pay an $850,000 civil penalty to settle CPSC charges that it knowingly sold flammable garments as children’s sleepwear.  CPSC charged that on numerous occasions from January 1999 through January 2000, Federated Department Stores sold, offered for sale or imported about 600,000 loose-fitting, 100-percent, untreated cotton garments that were marketed, promoted or designed as children’s sleepwear or robes.
  36. 36. Civil Penalty for Sale of Flammable Children’s Sleepwear, Cont.  The garments were sold on racks in children’s sleepwear departments/sections with or next to garments specifically labeled as sleepwear. Retail sales clerks told CPSC investigators that the garments were sleepwear.  In addition to paying the penalty, Federated Department Stores initiated a program that included the following:  Tag or sticker all children’s sleepwear on the sales floor so that it is clearly and easily distinguished from playwear and underwear; and  Implement a comprehensive children’s sleepwear training program for Federated Department Store employees.
  37. 37. Civil Penalty for Sale of Flammable Children’s Sleepwear, Cont. In August 2001, The Limited Inc., of Columbus, OH, and its subsidiary, Mast Industries, of Andover, MA, agreed to pay a civil penalty of $500,000.  The penalty settled CPSC allegations that the companies violated the FFA by knowingly importing and selling flammable children’s sleepwear.
  38. 38. Civil Penalty for Sale of Flammable Children’s Sleepwear, Cont. CPSC alleged that The Limited and Mast placed children at risk by knowingly importing and selling through Limited Too stores (an independent retail chain formerly owned by The Limited) 100 percent polyester pajamas with a satin finish and 100 percent polyester fleece bathrobes that failed to comply with federal sleepwear flammability standards.
  39. 39. Criminal Penalties Under the FFA Under section 7 of the FFA, 15 U.S.C. § 1196, violation of sections 3 or 8(b) of the FFA or failure to comply with section 15(c) of the FFA is punishable by:  Imprisonment for not more than five years for a knowing and willful violation;  a fine; or  both.
  40. 40. Criminal Penalties Under the FFA, Cont. • Criminal penalties to include asset forfeiture: (1) In addition to the penalties provided by § 7, the penalty for a criminal violation of this Act or any other Act enforced by the Commission may include the forfeiture of assets associated with the violation. (2) In this subsection, the term “criminal violation” means a violation of this Act or any other Act enforced by the Commission for which the violator is sentenced to pay a fine, be imprisoned, or both. • The Criminal Fine Improvements Act of 1987, Pub. Law 100- 185, [18 U.S.C. § 3571] increased maximum criminal penalties under the FFA to $100,000 for individuals and $200,000 for organizations; unless a death occurred, in which case the maximum fine is $250,000 for individuals and $500,000 for organizations.
  41. 41. Criminal Case Under the FFA In 1993 Denton Mills, Inc., the U.S. Attorney for the Northern District of Mississippi charged that Denton Mills shipped to retail constomers approximately 1,200 pairs of children’s pajamas that the firm had tested and found to fail CPSC flammability regulations.  The firm pled guilty to a five-count criminal information alleging violations of federal law and regulations that ban flammable clothing. Under the plea agreement, the firm agreed to pay a $100,000 criminal penalty. Criminal penalties are available and CPSC has pursued them where warranted as in this case.
  42. 42. Business Panel 42
  43. 43. 43
  44. 44. Interactive Questions with Paige Witzen and Carrie Carlin 44
  45. 45. Which garment is considered sleepwear? 1. 2. 45
  46. 46. Which garment silhouette appears to be traditional sleepwear? 1. 2. 46
  47. 47. Which garment appears to be tight fitting? 1. 2. 47
  48. 48. Can tight-fitting children’s sleepwear garments have a hood? 1. Yes 2. No 48
  49. 49. What type of children’s sleepwear requires a hangtag? 1. Tight-Fitting Garments 2. Traditional Sleepwear 3. Robes 49
  50. 50. 50 Is an FPU or GPU number required on traditionally styled children’s sleepwear garments? 1. Yes 2. No
  51. 51. 51 Are there mandatory labeling requirements for children’s sleepwear? 1. Yes 2. No
  52. 52. When is a sleepwear garment subject to the phthalate requirements or limits? 1. Sized for children 14 and under 2. Sized for children 3 and under 3. All children’s sleepwear 52
  53. 53. If your tight-fitting children’s sleepwear garments are sold directly to consumers in a properly labeled package, do they also require a hangtag? 1. Yes 2. No 53
  54. 54. Are certain fabrics composed of specific fibers exempt from the testing requirements for children’s sleepwear? 1. Yes 2. No 54
  55. 55. Is there a hangtag requirement that states a garment is flame resistant or flame retardant? 1. Yes 2. No 55
  56. 56. Which item below would be defined as trim under the Standards and requires testing? 1. Screen Print 2. Spaghetti Strap 3. Neck Label 4. Hangtag 5. Trim less than 2 inches 6. Zipper 56
  57. 57. Would a sleepwear garment sized 6-12 months require testing under the Sleepwear Standard? 1. Yes 2. No 57
  58. 58. Can tight-fitting sleepwear garments be offered exclusively in small, medium, and large sizes? 1. Yes 2. No 58
  59. 59. Do tight-fitting children’s sleepwear garments require measurement by a CPSC- accepted accredited third-party laboratory? 1. Yes 2. No 59
  60. 60. 60
  61. 61. This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of the Commission. 61 Children’s Sleepwear Seminar Allyson Tenney U.S. Consumer Product Safety Commission December 2016
  62. 62. Seminar Overview 62  Welcome Back  Afternoon Seminar Agenda  Requirements and Testing  Testing and Laboratory Panel  What to Expect When You’re Inspected  Closing Remarks and Q & A
  63. 63. Sleepwear Standards and Testing Requirements 63
  64. 64. Children’s Sleepwear Standards Mandatory Federal Standards Developed in the early 1970s  Two size ranges 0 – 6X 7 – 14  Scope – protect children from small open-flame sources 64
  65. 65. Children’s Sleepwear Standards Intent of the Standards Risk of Injury Reduce risk of personal injury or death Contact with a small ignition source Not intended to protect against large fire sources 65
  66. 66. Children’s Sleepwear Standards Test Method – Good Predictor of Flammability Performance  The Standards require that the test specimen must self-extinguish.  In general, many polyester fabrics self- extinguish.  Unless treated, cotton and cotton blends do not meet the flammability requirements. 66
  67. 67. Children’s Sleepwear Standards Standards have been amended over the years Sampling Plans Residual Flame Time Testing Trim Laundering Procedures Tight-fitting and Infant Garments 67
  68. 68. Children’s Sleepwear Standards Tight-fitting Garments  Sizes - Larger than 9 months to size 14  Garments must not exceed maximum dimensions specified for each size  Labeling rule Hangtag Permanent Label 68
  69. 69. Children’s Sleepwear Standards  Infant Garments  Sized 9 months or smaller  The Amendment requires that Tight- fitting Garments and Infant Garments meet the flammability requirements found in the General Clothing Textile Standard 69
  70. 70. Children’s Sleepwear Standards Cleared Testing Video Clip 70
  71. 71. 71 Testing
  72. 72. 16 CFR Parts 1615 & 1616- Standards for The Flammability of Children’s Sleepwear Children’s sleepwear means any product of wearing apparel intended to be worn primarily for sleeping or activities related to sleep in sizes 0 through size 14. Nightgowns, pajamas, robes, or similar or related items (such as loungewear) are included. 72
  73. 73. Tests of fabric, seams, trim and garments. Each test sample consists of five specimens. Tests conducted in original state and after 50 laundering cycles (if the sample passes the original state test) Tested samples required to be retained General Overview of Test Method 73
  74. 74. 74 Fabric Production Unit (FPU or Unit):  Up to 5,000 linear yards of finished fabric for normal sampling.  Finished fabric means fabric in its final form after completing its last processing steps as a fabric, except for slitting.  Different colors or prints can be combined if the fabric remains unchanged, but cannot have both different colors and prints.  Samples need to be taken from the beginning and end of the FPU for both laboratory testing and record keeping. Fabric Production Unit (FPU)- Normal Sampling
  75. 75. 75 To include different colors or different print patterns (or the same pattern in different colorways), three samples from each color or print must be tested and not show significantly different char lengths. Test all initial FPUs in the finished state (either as produced or after one laundering cycle). If the FPU has not been tested to the 50 laundering cycles, the GPU must be tested. Fabric Production Units (FPU)- Normal Sampling
  76. 76. Prototyping  Prototype testing is done to assess the flammability of pre-production seam and trim construction.  Each seam and trim should be tested and evaluated, which may lead to numerous seam and trim constructions.  The prototype must mimic the orientation in the garment (vertical or horizontal).  Functional Trim is exempt from testing.  A new prototype test is required when the style of garment is changed, or if trim color, materials or design are modified. 76
  77. 77. 77 Garment Production Unit (GPU or Unit):  Quantity of finished garments up to 500 dozen (or 6,000 units) that have a specific identity that remains unchanged throughout the Unit, except for size, trim, findings, color, and print patterns, as specified in 1615.4(b). Garment Production Unit (GPU)
  78. 78. 78 The production testing performed in the GPU selects specimen seams only. Different solid colors or different print patterns on the same fabric may be included in the same GPU, as long as three or more samples from each solid color or print pattern are tested and do not show significantly different results. You cannot combine solid colors and print patterns or combine knits and wovens of the same print fabric in the same GPU. Garment Production Units (GPU)
  79. 79. Garment Production Unit (GPU)  Samples should be taken from the GPU population randomly.  Typically a minimum of 5 samples are needed for testing.  15 specimens needed per GPU, separated into 3 sample sets.  No more than 5 specimens can be taken from a single garment.  All specimens from a single garment must be included in the same sample set. 79
  80. 80. Rejected Product  An FPU or Prototype that fails or is rejected may be reworked to improve flammability performance.  After a rework is done on an FPU that failed, a tightened sampling plan must be used for testing.  After a rework is done on a Prototype that failed, it must be re-tested.  A failing or rejected GPU that has been offered for sale must be reported under Section 15.  If the product cannot be reworked to meet the requirements of the Standards, the disposition of the rejected unit must be kept in the production records and must be marked properly to say that it does not meet the requirements of 16 C.F.R. 1615 and 1616. 80
  81. 81. 81 Summary of Test Method  Five 8.9 cm x 25.4 cm (3.5 inches x10 inches) specimens of fabric, seams, and trim.  Specimens are conditioned before testing.  Each specimen is placed in a metal holder and suspended vertically in the test cabinet.  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. Specimen is placed in a metal holder
  82. 82. 82 General Overview of Test Method Determine Fabric Weight Measure fabric weight before testing (Conditioned for at least 8 h at 21±1.1°C and 65 ±2% relative humidity) Different loads to be used for different fabric weights
  83. 83. 83 General Overview of Test Method Cutting Specimens Specimen size: 8.9 cm x 25.4 cm (3.5” x 10.0”) For fabric specimens, cut two specimens in one fabric direction (warp or filling) and three specimens in the other fabric direction for each test sample.
  84. 84. 84 General Overview of Test Method Mounting Specimens Mount specimen in the specimen holder.  The bottom edge of the specimen is to be even with the bottom of the specimen holder.  The sides of the specimen holder shall be clamped with clamps, and the specimen may be taped in the holder as well.
  85. 85. 85 General Overview of Test Method Conditioning Specimens Conditioning Requirements: Oven Temperature 105 ± 3°C (221 ± 5 °F) Duration 30 ± 2 minutes Place the specimen in oven
  86. 86. 86 General Overview of Test Method Conditioning Specimens Remove the specimens from the oven and place them in the desiccator for 30 minutes to cool, but no more than 60 minutes.
  87. 87. 87 General Overview of Test Method Testing Light the burner and check that the flame height is 3.8 cm (1.5 inches).
  88. 88. 88 General Overview of Test Method Testing Remove the specimen from the desiccator. Suspend the specimen vertically in the test cabinet.
  89. 89. 89 General Overview of Test Method Testing Impinge the burner flame on the bottom edge of the specimen for 3.0 ±0.2 seconds.
  90. 90. 90 General Overview of Test Method Char (Burn) Length Measurement Remove the specimen from the cabinet and holder when flame/afterglow has ceased, and place it on a flat surface. Fold and crease the specimen firmly by hand lengthwise along a line through the highest peak of the charred area.
  91. 91. 91 General Overview of Test Method Char Length Measurement Unfold the specimen and insert the hook with correct weight (determined by sample fabric weight, see the Standards for details) in the specimen on one side of the charred area 6.4mm (0.25”) from the lower edge. Tear the specimen by grasping the other lower edge of the specimen and raising the specimen.
  92. 92. 92 General Overview of Test Method Char Length Measurement Measure the char length – the distance from the end of the tear to the bottom edge of the specimen. Report the value of char length for each specimen and the average char length for each set of five specimens.
  93. 93. 93 General Overview of Test Method Test Criteria  The average char length of 5 specimens cannot exceed 17.8 cm (7.0 inches).  No individual specimen can have a char length of 25.4 cm (10.0 inches) (full-specimen burn).
  94. 94. 94 General Overview of Test Method Laundering If the sample meets the test criteria, then launder the sample 50 times following AATCC Test Method 124-2006. Repeat the same test as in the original state testing after laundering. 94
  95. 95. 95 What is Children’s Sleepwear?
  96. 96. Exemptions Diapers and Underwear  Must comply with 16 C.F.R. 1610 Infant Garments  Sized 9 months or younger  One-piece garment not exceeding 64.8 cm (25.75 in)  Two-piece garment not exceeding 40 cm (15.75 in)  Must comply with 16 C.F.R. 1610 Tight-Fitting Garments (as defined in the Standards)  Must comply with 16 C.F.R. 1610 96
  97. 97. Sleepwear Determination Whether a garment is children’s sleepwear depends on the facts and circumstances present in each case. Relevant factors to be considered when deciding whether a particular garment is an item of children’s sleepwear include:  The nature of the product and its suitability for use by children for sleeping or activities related to sleeping.  The manner in which the product is distributed and promoted.  The likelihood that the product will be used by children for sleeping or activities related to sleeping in a substantial number of cases.  The type of fabric, decorative features and print pattern. 97
  98. 98. “Loungewear” The CPSC staff view children’s “loungewear” ( or other similar garments marketed as comfort wear) as garments worn primarily for sleep related activities and, therefore, loungewear must comply with the Children’s Sleepwear Standards. 98
  99. 99. Traditional Children’s Sleepwear Examples 99
  100. 100. Recalled Sleepwear 100
  101. 101. 101 Summary-Children’s Sleepwear  Children’s Sleepwear: • 16 CFR Parts 1615 and 1616 (Flammability) • CPC Required, Third Party Testing • Lead Content • Lead Surface Coating • Tracking Labels • Phthalate Requirements (sleepwear for children under three)
  102. 102. Any Questions? ??? 102
  103. 103. Tight-Fitting Information and How to Measure 103
  104. 104. Tight-Fitting Sleepwear  Tight-fitting garments are exempt from testing to the sleepwear requirements.  Must meet specific maximum dimensions.  Must comply with 16 C.F.R. Part 1610.  Must meet labeling requirements.
  105. 105. Tight-Fitting Sleepwear
  106. 106. Recalled Tight-Fitting Sleepwear
  107. 107. Tight-Fitting Labeling 107 Mandatory labeling is required for tight-fitting sleepwear. Permanent neck label that reads: WEAR SNUG-FITTING NOT FLAME RESISTANT. A hangtag that gives point-of-purchase safety information (yellow tag) or a specified label can be used on prepackaged garments.
  108. 108. Labeling Requirements for Tight-Fitting Sleepwear 108 WEAR SNUG-FITTING NOT FLAME RESISTANT Neck label must be at least 5 point sans serif font, all capital letters, set apart from other text by line border, on a contrasting background and not covered by other labels. Hangtag must be yellow (specified color code) and measure 1.5”x 6.25” with a 1”x 5.75” text box Arial/Helvetica black 18 point font For child’s safety, garment should fit snugly. This garment is not flame resistant. Loose-fitting garment is more likely to catch fire.
  109. 109. Tight-Fitting Garment Measurement 109 Measuring the Chest  Measure the distance from armpit seam to armpit seam (A to B) Flatten seams and finger press any folds A B
  110. 110. Tight-Fitting Garment Measurement 110 Measuring the Waist  This measure is taken on a 2-piece garment  Measure width at the hemline of the top from C to D.  On a one piece garment, measure at most narrow part between chest and seat measurement C D
  111. 111. Tight-Fitting Garment Measurement 111 Measuring the Upper Arm  Use a straight-edge to form a line from the waist through the armpit to the shoulder of the garment. From this point on the shoulder, measure down the arm sleeve using the appropriate value for the size of the garment. From this point, measure across the sleeve, perpendicular to the top edge of the sleeve.
  112. 112. Tight-Fitting Garment Measurement 112 Measuring the Wrist or Cuff Long-sleeved garments, measure width of end of sleeve or cuff (E) to (F) Short-sleeved garments, the sleeve must taper from the top of the shoulder to the end of the sleeve E F
  113. 113. Tight-Fitting Garment Measurement 113 Measuring the Waist of the Pant Measure the top edge of the pant in the relaxed state Pants cannot have any attachment or decoration at the waist extending more than 1/4 inch
  114. 114. Tight-Fitting Garment Measurement 114 Measuring the Seat Fold the front of the pant in half to find the bottom of the crotch. Mark the point above the crotch 4 inches perpendicular to the bottom of the crotch (J to K). Measure from point (L) through (K) to (M). L K M J
  115. 115. Tight-Fitting Garment Measurement 115 Measuring the Thigh Measure 2.54 cm (1 in) down the inseam from the bottom of the crotch (J to N). Measure from this point across the pant leg (N to O). O N J
  116. 116. Tight-Fitting Garment Measurement 116 Measuring the Ankle For pants that extend to the ankle, measure across the width of the end of the pant leg (P to Q). For shorts or capri pants that do not extend to the ankle, the pant leg may not exceed the maximum width for the thigh and must diminish in width gradually as it approaches the ankle. P Q
  117. 117. Tight-Fitting Garment Measurement 117 Tight-fitting garments must have no item of fabric, ornamentation, or trim, such as lace, appliques, or ribbon, which extends more than 6 mm (1/4 inch ) from the point of attachment to the outer surface of the garment.
  118. 118. Tight-Fitting Garment Measurement 118 Close-up of Trim Bows, tags or any other ornamentation is measured in the same way.
  119. 119. Tight-Fitting Garment Measurement 119 Lettuce Edging This edge finish should be measured and the scalloped edges should not extend more than 1/4 inch. Stand ruler on end (perpendicular to the garment) against the scallop.
  120. 120. Tight-Fitting Children’s Sleepwear 120 Two Piece Set  A set may consist of a combination of a piece that meets the tight-fitting requirements and a piece that meets the flammability requirements of the children’s sleepwear Standards.  Both pieces taper to the waist; the top tapers from the chest to the waist and the bottom tapers from the seat to the waist.
  121. 121. Tight-Fitting Children’s Sleepwear 121 Tight-Fitting Tops  Tops with front fasteners must have the lowest fastener within 6 inches of the bottom of that piece.  Boat neck style tops and envelope shoulders are not prohibited as long as the measurements do not exceed those specified in the Standards.
  122. 122. Any Questions? ??? 122
  123. 123. Testing and Laboratory Panel 123
  124. 124. What to Expect When You’re Inspected 124
  125. 125. Available Resources 125
  126. 126. Contact Information Allyson Tenney Mary Toro Director Director Division of Engineering Office of Compliance, Regulatory Enforcement 301-987-2769 301-504-7586 Carolyn Carlin Linda Fansler Paige Witzen Textile Flammability Textile Technologist Textile Technologist Compliance Officer 301-504-7889 301-987-2059 301-987-2059 126
  127. 127. Thank You for Participating in our Children’s Sleepwear Seminar! 127