Regulatory requirements for fabrication of adult and children's clothing

1. U.S. Consumer Product Safety
Commission
CPSC requirements for adult and children’s clothing
This presentation was prepared by CPSC staff, has not been reviewed or
approved by, and may not reflect the views of, the Commission.

2. Mission
Protecting the public against unreasonable
risks of injury from consumer products
through education, safety standards
activities, regulation and enforcement.

3. 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

4. Product Hazard Prevention Strategies
• Engaging in product safety
system processes by
supporting improvements
to voluntary
standards/codes
CPSC staff promotes • Creating and enforcing
consumer product safety
} technical regulations and
bans
through 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

5. 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 inadequacies
CPSC staff does not vote.

6. Voluntary Standard Development
Organizations for Consumer Products
ANSI (American National Standards Institute)
– Motorized Equipment
– Lawn & Garden Equipment
– Household Products
– Safety Labeling
ASTM International
– Children’s Products
• Recreational Products
Underwriters Laboratories (UL)
– Electrical and other products

7. Voluntary Standards and Recalls
In some cases, failure to comply with a consensus
voluntary standard indicates to the CPSC that a
product contains a defect that presents a substantial
product 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.

8. Technical Regulations
Regulatory process can be started by vote of the
Commission 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

9. 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

10. Flammability of Clothing Textiles
• The Standard applies to all adult and
tight fitting children's sleepwear
–Except traditional children’s
sleepwear, which must meet a more
stringent standard.
–Does not apply to certain hats, gloves,
footwear, interlining fabrics.

11. 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.

12. 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).

13. 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

14. 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.

15. 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

16. Children’s Sleepwear - Exceptions
Category 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

17. Children’s Sleepwear - Exceptions
• Tight-Fitting Sleepwear
– Must meet specific maximum dimensions.
– Must comply with 16 CFR Part 1610.
– Must meet labeling requirements.

18. 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.

19. 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.

20. 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.

21. 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

22. 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)

23. What’s Required-Clothing
• Adult clothing:
– 16 CFR Part 1610 (Flammability)
– GCC required, including for products
that are exempt from testing

24. Responsibility to Comply with Voluntary
Standards and Technical Regulations
All equally responsible
Manufacturers
Distributors Retailers
Importers
Importers, although reliant on foreign producers,
are directly responsible for the safety of products
they bring into the United States.

25. Importance of Using U.S. Technical Regulations
and Voluntary Standards
To avoid entry problems with the U.S.
government (Customs and CPSC), foreign
manufacturers SHOULD comply with BOTH:
– CPSC Regulations (mandatory)
– Private Sector Standards (consensus
voluntary standards)
Both play essential safety roles.

26. How the CPSC Works with
Manufacturers
Develop guidance and help firms comply
with the law through:
• International program outreach
• Domestic manufacturer seminars
• Participation at ICPHSO symposiums
• Advice and guidance to trade associations
and consultants

27. Best Manufacturing Practices
Manufacturers and importers should use best
practices to ensure safe products enter into the
chain 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.

28. 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”.

29. 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.

30. Best Manufacturing Practices

31. 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