CPSC supports continuous improvement to voluntary safety standards
The purpose of the standard is to protect children from the risk of injury from fire when children are unsupervised. The standards require that children’s sleepwear must be flame resistant and not continue to burn when removed from a small flame source.Children’s sleepwear means any product of wearing apparel sizes larger than nine months, intended to be worn primarily for sleeping or activities related to sleep, except: diapers and underwear, infant garments and tight-fitting garments.
PROFECO Pro-Consumer Week: Requirements for Adult and Children's Clothing-English
U.S. Consumer Product Safety CommissionCPSC requirements for adult and children’s clothingThis presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.
MissionProtecting the public against unreasonable risks of injury from consumer products through education, safety standards activities, regulation and enforcement.
Four Types of Safety Concerns• Product fails to comply with a mandatory safety standard or ban under the Acts• Product fails to comply with voluntary standards relied upon by the Commission• Product contains a defect which could create a “substantial product hazard”• Product creates an “unreasonable risk” of serious injury or death
Product Hazard Prevention Strategies • Engaging in product safety system processes by supporting improvements to voluntary standards/codes CPSC staff promotes • Creating and enforcingconsumer product safety } technical regulations and bansthrough a multi-pronged • Identifying and removing products with defects and approach hazards through surveillance activities and recalls • Developing education programs for consumers, importers, U.S. and foreign manufacturers, and retailers
CPSC Voluntary Standards Monitoring Participate in committees Propose Analyze standards injury/death development data for hazard or revisions patterns Conduct tests Review and evaluations standards for to support findings inadequaciesCPSC staff does not vote.
Voluntary Standard Development Organizations for Consumer ProductsANSI (American National Standards Institute) – Motorized Equipment – Lawn & Garden Equipment – Household Products – Safety LabelingASTM International – Children’s Products • Recreational ProductsUnderwriters Laboratories (UL) – Electrical and other products
Voluntary Standards and RecallsIn some cases, failure to comply with a consensusvoluntary standard indicates to the CPSC that aproduct contains a defect that presents a substantialproduct hazard. Example: These lights do not meet the voluntary Underwriters Laboratory (UL) standard due to insufficient wire size. They can overheat and pose a fire and shock risk. CPSC can seek a recall.
Technical RegulationsRegulatory process can be started by vote of theCommission or by a petition from an interested party CPSC statutes specify that voluntary standards should be relied upon. However, a regulation may be issued if: the current voluntary there is not standard does or substantial not adequately compliance. reduce the risk
Flammable Fabrics Act (FFA)• Regulated Products – Clothing Textiles, 16 CFR Part 1610 – Vinyl Plastic Film, 16 CFR Part 1611 – Children’s Sleepwear, 16 CFR Parts 1615/1616 – Carpets and Rugs, 16 CFR Parts 1630/1631 – Mattresses and Mattress Pads, 16 CFR Part 1632 – Mattress Sets, 16 CFR Part 1633
Flammability of Clothing Textiles• The Standard applies to all adult and tight fitting childrens sleepwear –Except traditional children’s sleepwear, which must meet a more stringent standard. –Does not apply to certain hats, gloves, footwear, interlining fabrics.
Flammability of Clothing Textiles• The Standard specifies testing procedures and determines the relative flammability of textiles used in apparel using three classes of flammability.• Fabrics that meet a specific exemption as defined in the standard do not require testing.
Clothing Textiles - Test Summary• 5cm x 15cm (2 inches x 6 inches) specimen• Conditioning requirements• Specified test cabinet• A 1.6 mm (5/8 in) flame impinges on a specimen mounted at a 45 degree angle for 1 second.• The specimen is allowed to burn its full length or until the stop thread is broken (burn time is recorded).
Clothing Textiles - 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
Flammability of Children’s Sleepwear• The children’s sleepwear standards, 16 CFR Parts 1615 and 1616, were developed to address the ignition of children’s sleepwear, such as nightgowns, pajamas, and robes.• The standards are designed to protect children from small open-flame sources, such as matches/lighters, candles, fireplace embers, stoves, and space heaters.• The standards are not intended to protect children from large fires or fires started by flammable liquids, such as gasoline.
Definition of Children’s Sleepwear• Any product of wearing apparel intended to be worn primarily for sleeping, in sizes larger than 9 months through size 14.• 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
Children’s Sleepwear - ExceptionsCategory Exceptions:• Diapers and Underwear – Must comply with 16 CFR Part 1610• Infant garments – 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
Children’s Sleepwear - Exceptions• Tight-Fitting Sleepwear – Must meet specific maximum dimensions. – Must comply with 16 CFR Part 1610. – Must meet labeling requirements.
Children’s Sleepwear 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.• The fabric, garments, seams, and trims must pass certain flammability tests.
Drawstring Requirements for Children’s Clothing• In 1996, CPSC issued guidelines later adopted by ASTM in 1997 (ASTM F1816-97).• May 2006 CPSC sent a letter to industry.• Drawstrings are considered a substantial product hazard.
Drawstring Requirements for Children’s Clothing• 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.
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
What’s Required-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)
What’s Required-Clothing• Adult clothing: – 16 CFR Part 1610 (Flammability) – GCC required, including for products that are exempt from testing
Responsibility to Comply with Voluntary Standards and Technical Regulations All equally responsible Manufacturers Distributors Retailers ImportersImporters, although reliant on foreign producers,are directly responsible for the safety of productsthey bring into the United States.
Importance of Using U.S. Technical Regulations and Voluntary StandardsTo avoid entry problems with the U.S.government (Customs and CPSC), foreignmanufacturers SHOULD comply with BOTH: – CPSC Regulations (mandatory) – Private Sector Standards (consensus voluntary standards)Both play essential safety roles.
How the CPSC Works with ManufacturersDevelop guidance and help firms complywith the law through:• International program outreach• Domestic manufacturer seminars• Participation at ICPHSO symposiums• Advice and guidance to trade associations and consultants
Best Manufacturing PracticesManufacturers and importers should use bestpractices to ensure safe products enter into thechain of commerce. – Importers/suppliers must work as a team. – Know where and how your product will be used. – Know and understand all requirements and standards. – Comply with consensus standards and technical regulations.
Best Manufacturing Practices– Design safety into product. It is your responsibility to work with the designer.– Control your supply chain (supply chain integrity).– Preventive action is better than corrective action.– Avoid long-term repercussions: Damage to Brand Name and “Made in My Country”.
Best Manufacturing Practices– To avoid problems, samples should be tested randomly, early and often.– The cost of testing is a tiny fraction of the costs associated with recalls and violations.– Seek products with third party certification.– Unauthorized component substitutions can easily lead to a recall.– Conduct spot inspections.
Contact Information Dean W. Woodard, M.S.Director, Office of Education, Global Outreach, and Small Business Ombudsman E-mail: Dwoodard@cpsc.gov Phone: 301-504-7651 Tilven M. Bernal Program Manager for the Western Hemisphere International Programs E-mail: Tbernal@cpsc.gov Phone: 301-504-7309