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.
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 –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 children's sleepwear
–Except traditional children’s sleepwear, which must meet a more stringent standard.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.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 • 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, • 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 • 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 • 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
Category Exceptions:
• Diapers and Underwear
– Must comply with 16 CFR Part 1610
• Infant garments
Children’s Sleepwear - Exceptions
• Infant garments
– Sizes 9 months or younger
– One-piece garment does not exceed 64.8 cm (25.75”) in length
– Two-piece garment that has no piece exceeding 40 cm (15.75”) in length
– Must comply with 16 CFR Part 1610
• Tight-Fitting Sleepwear
– Must meet specific maximum dimensions.
– Must comply with 16 CFR Part 1610.
– Must meet labeling requirements.
Children’s Sleepwear - Exceptions
Children’s Sleepwear Requirements
• Children’s sleepwear (that is not tight-fitting) must pass the flammability requirements.
• All fabrics and garments must be flame • 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 forChildren’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 forChildren’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 drawstringsSizes 2T-16 (or equivalent) with waist or bottom drawstringsthat 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 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 Content
– Lead Surface Coating
– Tracking Labels
– Phthalate Requirements (sleepwear for children under three)
What’s Required-Clothing
• Adult clothing:
–16 CFR Part 1610 (Flammability)
–Any laboratory can perform the testing for non-children’s products. for non-children’s products.
–GCC required, including for products that are exempt from testing
Responsibility to Comply with Voluntary Standards and Technical Regulations
All equally responsible
Manufacturers
ImportersDistributors Retailers
Importers, although reliant on foreign producers, are directly responsible for the safety of products they bring into the United States.
Importers
Importance of Using U.S. Technical Regulations
and Voluntary Standards
To avoid entry problems with the U.S.government (Customs and CPSC), foreignmanufacturers SHOULD comply with BOTH:
–CPSC Regulations (mandatory)–CPSC Regulations (mandatory)
–Private Sector Standards (consensus voluntary standards)
Both play essential safety roles.
Develop guidance and help firms comply with the law through:
• International program outreach
How the CPSC Works with Manufacturers
• Domestic manufacturer seminars
• Participation at ICPHSO symposiums
• Advice and guidance to trade associations and consultants
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 –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).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.costs associated with recalls and violations.
–Seek products with third party certification.
–Unauthorized component substitutions can easily lead to a recall.
–Conduct spot inspections.
Best Manufacturing Practices
John Golden
Section Chief, Safety Attaché
Contact Information
Section Chief, Safety Attaché
E-mail: [email protected]
