Product safety

Compiled material for AQM- BFT VII

Divya Satyan [email protected]

Understanding Product Safety During recent years consumer health and safety has become an important issue in international trade. Public authorities, consumers and also industries themselves are extremely sensitive to any negative impact a product may have during or after its use.

Major disasters in the products containing dangerous substances (soft toys for small children) are some examples that lead to public attention and often to more legislation, but also to initiatives of industries themselves in order to ensure public confidence. Together with the power of the media, industries are trying to minimise the risks, sometimes even aim for zero-tolerance, in order to stay out of negative media coverage. What is a SAFE product: A safe product is any product which under normal or reasonably foreseeable conditions of use presents no risk or only the minimum risk compatible with the products use and which is consistent with a high level of protection for consumers. This can take the form of being protected from the event or from exposure to something that causes health or economical losses. It can include protection of people or of possessions. The existence of higher levels of safety, or availability of products presenting lesser risk, will not in itself mean that a product is unsafe. What is Product Safety Regulation An official rule, law, or order stating what may or may not be done or how something must be done for the condition of being protected against physical, social, financial, political, occupational, or other types or

consequences of failure, damage, error, accidents, harm or any other event which could be considered non-desirable. Producers and distributors have for many years been obliged by product safety legislation to provide information and warnings as to the risks their products posed where those risks were not obvious and, where necessary, to provide instructions adequate to consumers needs as to the safe operation/use of the product. These Regulations maintain that requirement. Need for Safety Regulation for Apparel Products: Apparel market has witnessed high growth rates, especially in the chemical industrial protective apparel sector. Increased competition is forcing

manufacturers to invest in research to develop robust product lines to carve a niche for themselves in the market. Manufacturers are seeking to make apparels more protective ,comfortable and lightweight, with improved visibility and mobility, particle holdout, and breathability. Advanced materials and fabrics are being used to enhance the quality and performance of protective apparels. Sensitivity to environmental impact of these protective apparels is likely to challenge manufacturers that are now looking for materials that are biodegradable, reusable or recyclable, and eco-friendly. A few industries have already implemented feedback mechanisms to foster better understanding of the varied segmentation of the end-user base and any lacunae existing between the supply and demand. The safety of a product is assessed with regard to a number of matters, in particular: The products characteristics; Packaging; Instructions for assembly and maintenance, use and disposal; The effect on other products with which it might be used;

Labeling and other information provided for the consumer; and The categories of consumers at risk when using the product, particularly Children and the elderly. Mandatory Product Safety: There are two types of mandatory product standards: -Safety standards - goods must comply with particular performance, composition,contents, methods of manufacture or processing, design, construction, finish or packaging rules. -Information standards - prescribed information must be given to consumers when they purchase specified goods (e.g. labelling for cosmetics, tobacco products and care labelling for clothing and textile products).

Obligations on Producers w.r.t Product Safety A producer has a primary duty to place on the market only safe products but he also has more specific duties: to provide relevant information to enable consumers to assess the risks inherent in a product throughout the normal or reasonably foreseeable period of its use where such risks are not immediately obvious to the user. This should include information on the precautions to be taken to avoid those risks (for example, the need to wear protective gloves); and to adopt measures commensurate with the characteristics of the products which he supplies, to enable him to be informed of the risks which these products might present and to take appropriate action, including, where necessary, withdrawing the product in question from the distribution chain.

Examples of such measures include: marking the products, their packaging or other materials supplied with the product (e.g. instruction booklets) with the name and address of the producer (name and postcode is acceptable), product reference, and batch number where appropriate, so that they can be identified (in many cases the manufacturers normal quality control procedures will mean that batch marking is already in place); sample testing of products on the market; investigating complaints relating to safety, and keeping a register of such complaints; and/or informing distributors of the monitoring work and the results. Product suppliers and manufacturers have an obligation to ensure that only safe products are marketed, by: -Providing clear instructions for use, including warnings again possible misuse. -Being aware of and meeting industry and mandatory standards. -Developing product recall plans and procedures including effective communication strategies to the public (eg advertisements in papers) -incorporating safety into product design. -Developing appropriate safety standards through product improvement. -Implementing a quality assurance program which includes consumer feedback. -Responding quickly to safety concerns that arise. The above are not mandatory requirements in every case and which of them will be appropriate to a particular product will be determined by the nature of the product, the group of consumers for whom it is intended and the type

of activity in which the producer is engaged. In the case of producers, monitoring may, for a low risk product, consist largely of assessing complaints from consumers. Compliance with consumer product safety and information standards is mandatory. This means that all suppliers of goods including manufacturers, distributors, importers and retailers must ensure their goods comply with the mandatory requirements. Consumers also have a responsibility to purchase safe products and to use them in a safe manner.

FLAMMABLE FABRICS SAFETY REGULATIONS

The flammable fabric act of 1953 prohibits the sale or manufacture of dangerously flammable fabrics. Amendments in 1967 extended this coverage to all textile products considered to be wearing apparel or interior furnishings. The need for legislation became evident in 1952 with a series of incidents that Stone (1977) terms as the torch sweater episode. A number of people were badly burnt while wearing highly flammable sweaters. The situation was such that, many clothing manufacturers saw virtue in governments regulations that would provide public assurances of safety
Safety Regulations and Restrictions on Childrens Sleepwear

Nightwear can burn rapidly, when accidentally set alight by contact with an open fire or a electric fire or source, and injury the elderly especially In gas or other heat cause serious children and being vulnerable. consequence,

various mandatory and voluntary measures have been taken to control the fire performance of the fabrics used in nightwear and to make the public more aware of the dangers. The Regulations apply to all persons who supply nightwear and garments used for a similar purpose in the course of carrying on a business, whether or not that business is one of dealing in nightwear.

The European Union has set an enormous quantity of legislation to protect consumer health and safety. As legislative requirements are mostly related to requirements on the end product, presently there seems to be a development towards more attention on tracking and tracing in the production chain, in order to control the product through its entire life cycle.

General Product Safety Regulations 1994

These Regulations implement the provisions of Council Directive 92/59/EEC on general product safety. They impose requirements concerning the safety of products intended for consumers or likely to be used by consumers if such products are to be placed on the market by producers or supplied by distributors.

Regulation 7 provides that a product may not be placed on the market unless it is a safe product. Regulation 8 imposes requirements on a producer to provide information to consumers and adopt measures to inform him of risks a product might present and identifies some measures which might be taken.
o Children's Clothing Regulations 1976

THE CHILDREN'S CLOTHING (HOOD CORDS) REGULATIONS 1976 These Regulations specify that the hoods of childrens outer garments must not be designed to be secured by means of a cord drawn through the material. The Regulations define a childs outer garment as: a raincoat, overcoat, anorak or other garment suitable for use as outer wear having a measurement

not exceeding 44 cm across the chest when the finished garment is laid out as flat as possible without distorting its natural two-dimensional shape and buttoned or otherwise fastened as it is designed to be in normal wear.

The hood cord Regulations date back to 1976 when garments were closely fitted. Changing fashion to loose fit and wadded garments means that many outer garments for young children fall outside the scope of the legislation. The safety of childrens outer garments exceeding the size restrictions in the hood cord Regulations is covered by the General Product Safety Regulations 1994 in conjunction with the Code of Practice on the design and manufacture of childrens clothing

The General Product Safety Regulations it would be reasonable to expect that outer garments intended for children up to say, seven years of age, should not have cords drawn through the material of the hood. (A European standard which is currently under development provides that there should be no cords in the hood or neck area of garments intended for children under seven years of age).

There is a British Standard Institution (BSI) Code of Practice which gives recommendations for materials, design and manufacturing to promote the safety of childrens clothing. The Code, reference number BS 7907:1997, is available from BSI.

The Nightwear (Safety) Regulations 1985 Flammability Regulations

Nightwear can burn rapidly when accidentally set alight by contact with an open fire or a gas or electric fire or other heat source, and cause serious injury - children and the elderly being especially vulnerable. In consequence, various mandatory and voluntary measures have been taken to control the fire performance of the fabrics used in nightwear and to make the public more aware of the dangers.

From March

1987,

tougher

performance

requirements

regarding

flammability came into force. They are compulsory for children's nightdresses and dressing gowns. There are improved safety provisions for the full range of nightwear garments for babies, children and adults.

COUNTRY UNITED KINGDOM

BASED ON General Product Safety Regulations 1994 (SI 1994/No. 2328) The Nightwear (Safety) Regulations 1985

CATEGORIES The standard creates four categories of acceptable garments for nightwear:

Category One: garments made from fabrics with low flame propagation properties;

Category Two: garments, which because of their design, are less likely to catch alight and if they do, the spread of flames is reduced because of the design features; Category Three: all-in-one style garments made predominantly from knitted fabrics, in sizes 00 to 2; Category Four: garments that are assigned a high flammability rating.

Nightwear can burn rapidly, when accidentally set alight by contact with an open fire or a gas or electric fire or other heat source, and cause serious injury - children and the elderly being especially vulnerable. In consequence, various mandatory and voluntary measures have been taken to control the fire performance of the fabrics used in nightwear and to make the public more aware of the dangers.

MEASUREMENT REQUIREMENTS

Children's nightwear: ie garments for children over 3 months and under 13 years of age and not exceeding any of the following maximum measurements. Nightdresses Chest measurement: 91 cms (approx 36") Length: 122 cms (approx 48") Dressing Gowns, Bath Robes and other similar garments Chest measurement: 97 cms (approx 38") Sleeve measurement: 69 cms (approx 27")

SAFETY REGULATIONS

Nightdresses, dressing gowns and other similar garments commonly worn as nightwear must satisfy the flammability performance requirements specified in Clauses 3.1.1 and 3.2.1 of British Standard 5722. Pyjamas and cotton terry towelling bath robes do not have to comply with the flammability standard. However, they must carry a permanent label showing whether or not they meet the flammability standard. The flammability performance requirements relate to the whole area of the garment including all threads, trimmings, decorations, and labels. However, elastic and elastic thread used for making gathers in material are exempt from the flammability requirements. Nightwear made of and trimmed with synthetic fabric which melts without decomposing when ignited as part of the British Standard test can be taken to meet the flammability performance requirements Nightwear which has been treated with flame retardant chemicals must carry the appropriate warning label about washing and suitability of the washing agent.

LABELLING REQUIREMENTS The standard establishes burn tests for each category. For Categories 2, 3 and 4 it also sets out design/ dimension specifications. Garments that do not meet the requirements of any of these categories are considered to have a

very high flammability rating and are therefore unacceptable for supply as nightwear.

Categories 1, 2 and 3 must have a white label stating 'LOW FIRE DANGER'

Category 4 garments must have a red label with a fire emblem, stating 'WARNING - HIGH FIRE DANGER - KEEP WAY FROM FIRE'.

FLAMMABILITY PERFORMANCE 1. Nightwear which does not meet the flammability performance requirements must carry a label with the words: 'KEEP AWAY FROM FIRE' (in red letters) 2. Nightwear which meets the flammability performance requirements must carry a label with one of the following forms of words: 'LOW FLAMMABILITY TO BS 5722' (in black letters), or 'LOW FLAMMABILITY TO BS 5722' (in black letters) and 'KEEP AWAY FROM FIRE' (in red letters), or 'KEEP AWAY FROM FIRE' (in red letters). 3. All words must be in medium letters of 10 point in upper case. 4. You should note that children's nightdresses and dressing gowns which

must meet the flammability performance requirements do not need to carry a label. However, suppliers may choose to confirm compliance using one of the above forms of words.

WASHING INSTRUCTIONS

1. Any nightwear which is treated with flame retardant chemicals must carry a label with the words: 'DO NOT WASH AT MORE THAN 50 degree CELCIUS. CHECK SUITABILITY OF WASHING AGENT (in black letters).

2. The words must be in medium letters of 6 point in upper case.

Nightwear (Safety) Regulations 1985 - Examples of print sizes for Labelling Requirements

UNIVERS MEDIUM (55) 10pt 2.4 mm

KEEP AWAY FROM FIRE (in RED letters) LOW FLAMMABILITY TO BS 5722 (in BLACK letters)

UNIVERS MEDIUM (55) 6 pt 1.8 mm DO NOT WASH AT MORE THAN 50oC CHECK SUITABILITY OF WASHING AGENT (in BLACK letters)

HELVETICA MEDIUM 10pt 2.5 mm KEEP AWAY FROM FIRE (in RED letters) LOW FLAMMABILITY TO BS 5722 (in BLACK letters)

HELVETICA MEDIUM 6pt 1.7 mm DO NOT WASH AT MORE THAN 50oC CHECK SUITABILITY OF WASHING AGENT (in BLACK letters) POSITION OF THE LABELS

1. Labels showing flammability performance and washing instructions must be permanent and securely sewn into the garment. 2. The words may appear in a variety of positions providing that the information is not obscured by any other label or part of the garment. They may appear on: a separate label on the inside of the neck of the garment; or any label giving size details of the garment, in which case the wording must appear

immediately below that information; or

a label immediately beside any other permanent label giving size details of the garment. 3. If both flammability performance information and washing instructions are required and are to appear on the same label the washing instruction warning must appear immediately below the flammability performance information. 4. The words must be in durable print and must appear on a label of sufficient - colour contrast to enable them to be clearly seen. 5. You should note that: If a loop label is used we recommend that the flammability performance information should be given on the front of the label. For pyjamas, we recommend that the flammability performance information and any washing instruction warning should be given at least on the jacket of the garment.
Safety regulations for children wear in USA

On September 19, 1996, the Commission issued a final rule amending the flammability standards for children sleepwear to exclude from the definition "children's sleepwear" the following: 1. Garments sized for infants nine months of age or younger; 2. Tight-fitting sleepwear garments for children older than nine months.

These amendments permitted the sale of tight-fitting sleepwear and sleepwear for infants 9 months or under, even if the garments did not meet the flammability standards ordinarily applicable to such sleepwear.

The Commission defined tight-fitting garments as those that did not exceed certain measurements in the chest, waist, seat, upper arm, thigh, wrist and ankle for each size ranging from over nine months through children size 14. In the amendments, the Commission specified maximum allowable measurements for each of these locations for each size garment. The CPSC reached its result based on staff findings that there were virtually no injuries associated with single-point ignition incidents of tight-fitting sleepwear, or of sleepwear worn by infants under one year. The data demonstrating this absence of injury were buttressed by staff findings that: (1) Tight-fitting sleepwear is less likely to come into contact with a flame; (2) Even when ignited, tight-fitting sleepwear is not apt to burn readily because it does not trap air that feeds a fire and the proximity of the skin soaks up heat that would otherwise cause the fire to spread; and (3) Infants under six months are insufficiently mobile to expose themselves to sources of fire. These amendments became effective January 1, 1997. ACCORDING TO THE CPSC. The hangtag states: "For child's safety, garment should fit snugly. This garment is not flame resistant. Loose-fitting garment is more likely to catch fire." The rule to be promulgated will specify the size, font, and text of the hangtag. The tags will have black lettering against a yellow background. The neck label will provide a shorter message. The label will state: "Wear Snugfitting, Not Flame Resistant." It must appear on the front of the sizing label below the size designation and contrast with the background color of the label.

In July 1999, the U.S. Consumer Product Safety Commission ("CPSC" or "Commission") voted to keep changes to the sleepwear flammability regulations in place. The changes, adopted three years ago, exempt tightfitting sleepwear, or sleepwear intended for infants under 9 months of age. The CPSC also voted for an added requirement that tight-fitting sleepwear garments be sold with mandatory hangs tags and permanent neck labels indicating that the garments were not flame-resistant and should be worn with a snug fit. The vote capped a long, heated battle between industry proponents who favored the flexible approach adopted by the CPSC to exempt such garments and to allow them to be sold, and politicians and advocacy groups who were opposed to any change in the original sleepwear regulations because they believed such changes diminished the protection afforded to children by the original regulations.

In voting to continue the exemptions, a majority of the commissioners noted that the exemptions were intended to provide the public with a safe alternative (i.e., tight-fitting sleepwear) to the increased use of traditional underwear and long underwear garments being used as sleepwear. The Commissioners noted that traditional pajamas, robes and nightgowns are still required to be flame-resistant and subject to the sleepwear flammability regulations. They urge retailers to segregate non-sleepwear from sleepwear garments on the store floor, and they voted to add labeling regulations which required mandatory hang tag and neck labels on the exempt sleepwear so consumers would be educated about the type of garments they were buying A garment sized nine months or smaller intended for use by infants is not required to meet the standard if:

(1) It is a one-piece garment and is not longer than 25 inches, or it is a two-piece garment and has no piece longer than 15 inches; and

(2) It has a label stating in months the age of the children for whom it is intended.

Requirements for labeling and keeping records (1) each article of children's sleepwear must have a permanent label with instructions on how to take care of the garment to protect it from chemicals or Other treatments that can reduce its flame resistance;

(2) children's sleepwear must have a permanent label with a unit identification (number, letter, date, or combination thereof) so manufacturers can track the garment's associated fabric and garment production lots in the event of a recall;

(4) Manufacturers and importers must maintain written records as specified in the regulations.

INDIA (BUREAU OF INDIAN STANDARDS) Limited flame spread materials and material assemblies are used in clothing in order to reduce the possibility of their burning and thereby itself constituting a fire hazard. This includes children wear of all kinds and also other protective clothing where protection against heat and fire mainly due to accidental contact with small igniting flames is required in circumstances where there is no significant heat and fire hazard. The performance of such clothing is expressed in terms of a limited flame spread index.

Following three indexes of performance have been covered: Index 1 Materials which do not spread flame but may form a hole on contact with a flame. Index 2 Materials and material assemblies do not spread flame and do not form a hole on contact with a flame. Index 3 Materials and material assemblies do not spread flame and do not form a hole on contact with a flame. They also give only limited after flame. It is not possible to specify a higher index for materials and material assemblies which do not give any after flame or damage at all, because classification has been found to be inconsistent due to slight inter laboratory variations.

1. Childrens Upper Outerwear with Drawstrings Definitions

Neck area: means the area one inch above and below the seam between the body of a garment and the collar or hood.

Upper outerwear: means clothing, such as jackets and sweatshirts, which is generally intended to be worn over other garments. Childs Outer Garment: An outer garment (raincoat, overcoat, anorak or other outer garment for use as outer wear) having a measurement not exceeding 44 cm (17.32 in.) across the chest when the finished garment is laid out as flat as possible without distorting its natural two-dimensional shape and buttoned or otherwise fastened as it is designed to be in normal wear.

Drawstring: Cord, chain, ribbon, string or tape of any textile or non-textile material that passes through a channel, loop(s) or eyelets(s) or similar, to adjust the size of the opening, or part of the garment or to fasten the |garment itself. The ASTM definition specifies that a drawstring is a non-retractable cord. The drawstrings usually pull the clothing tight to prevent air and/or water (rain or snow) seepage. The tightening systems (non-exhaustive list) can be found on the following garment parts, Upper neck hem Hood hem Jacket or trouser waist-tightener Trouser or leg gaiter Glove wrist tightener, etc

Different kinds of hoods and collars may require more drawstrings and locks.

Decorative Cord: Cord, chain, ribbon, string or tape of any textile or non-textile material with or without embellishment, such as toggle, pom-pom, feather or bead, of fixed length and not intended to be used to adjust the size of the opening or to fasten the garment itself.

Functional Cord: Cord, chain, ribbon, string or tape of any textile or non-textile material with or without embellishment, such as toggle, pom-pom, feather or bead, of fixed length, which is used to adjust the size of the opening, or part of the garment or to fasten the garment itself.

Hood: A loose, pliable covering for the head, either detachable or permanently attached to upper outerwear.

Loop: Cord or narrow strip of fabric curved in shape, which may be fixed or adjustable in length, where both ends are attached to the garment.

Sash: Drawstring, decorative or functional cord of textile material of not less than 30 mm (~1 inch) in width worn around the waist of a garment and tied into a bow.

Toggle: Wooden, plastic, metal or otherwise composed piece attached to, or present on, a drawstring for decorative purposes or to prevent the drawstring from being drawn through its channel.

Introduction
Drawstrings on childrens apparel can be hazardous and have led to deaths and injuries. Therefore several countries have taken measures through standards or safety advisories to reduce the risk of marketing and sale of garments with drawstrings that can be hazardous or even fatal to children. However, many retailers and manufacturers sell apparel in multiple countries and variations in drawstring requirements among various countries can be confusing. One set of requirements that cover their needs for selling in the United States (US), Canada and European Union (EU) would be ideal. Drawstrings on childrens apparel can be hazardous and have led to deaths and injuries. Drawstrings can catch on playground equipment, cribs, bus doors, etc. and potentially strangle a child. Therefore Canada, the United States and the European Union have all issued standards or guidelines to minimize the risk of accidental entrapment by drawstrings or cords.

Death and Injuries that can be caused by Childrens Upper Outerwear with Drawstrings

Waist drawstrings can become entangled in a bus door

Hood and neck drawstrings can become entangled on playground equipment,

cribs, and other common items.

Managing loops/cords by cutting it short and separating them

Country: (USA)

United States of America

Guidelines for Drawstrings on Childrens Upper Outerwear

The U.S. Consumer Product Safety Commission (CPSC) is an independent federal regulatory agency that was created in 1972 by Congress in the Consumer Product Safety Act. The CPSC issued a voluntary guideline (US Consumer Product Safety Commission Guidelines for Drawstrings on Childrens Outerwear) and ASTM issued a standard (ASTM F1816-97, Standard Safety Specification for Drawstrings on Childrens Upper Outerwear) in 1997.

In addition to the CPSC/ASTM guidelines, the states of New York and Wisconsin have implemented mandatory laws. Wisconsins standard applies to a broader range of sizes (0-16) than the CPSC/ASTM and New York (2T-12). Additionally, the New York requirements for waist and bottom drawstrings apply to all childrens clothing, as opposed to only childrens upper outerwear for CPSC/ASTM and Wisconsin.

CPSC recommends that parents or caregivers completely remove the hood and neck drawstrings from all childrens upper outerwear, including jackets and sweatshirts, sized 2T to 12. CPSC recommends that consumers purchase childrens upper outerwear that has alternative closures, such as snaps, buttons, Velcro, and elastic.

\ Canada
Canadas advisory notice (Potential Strangulation from Drawstrings on Childrens Outerwear) mirrors the ASTM standard (ASTM F1816-97).

When selling apparel in throughout the US and Canada Canada has adopted ASTM F1816-97. However, Wisconsins drawstring requirements are more stringent than that of the CPSC/ASTM and New York in most areas. Most notably, Wisconsins requirements apply to a wider size range (0-16). However, New Yorks requirements for the waist or bottom apply to all childrens clothing (not just childrens upper outerwear as in the PSC/ASTM and Wisconsin requirements).

Therefore, it is recommended that a combination to include the most stringent of requirements be followed, as below:

Country: European Nations (EN)

In France, investigations have shown that garment drawstrings can cause two types of accidents, i.e.,

The strangulation of young children when a drawstring is caught in community equipment (playgrounds)

Eye injuries or dental fractures to secondary school children when their hanging, elastic, hard-tipped drawstrings on their hoods are pulled The European Commission instituted a standard (EN 14682: 2004, Safety of Childrens Clothing Cords and Drawstrings on Childrens Clothing-Specifications) which limits

the use of drawstrings in childrens apparel. This standard was adopted as a national standard by member states in June 2005.

The standard was published in the Official Journal of the European Union (OJEU) 2006/C171/04 of 22 July 2006. As a result, clothing in compliance with the safety requirements prescribed by this standard are now presumed to be in compliance with the general safety requirement of the General Product Safety Directive (GPSD), 2001/95/EC of the European Parliament and of the Council of 3 December 2001 on general product safety.

Publication in the OJEU, does not make it a legal requirement that clothing must comply. However, the General Product Safety Directive is a legal requirement implemented in European countries and having articles that comply with harmonized standards such as EN 14682 is a way of demonstrating that the product is safe for aspects covered by the standard.

Therefore, if a product does not comply with EN 14682, the seller could be prosecuted for not complying with the requirements of GPSD as this would be considered to be a relevant standard. In other words, if a product does not comply with EN 14682, the seller cannot be prosecuted for noncompliance to EN 14682 per se but could be prosecuted for not complying with the requirements of GPSD as this would be considered to be a relevant standard and requirements of EN 14682 is a means to ensure a safe product.

Country: United Kingdom (UK)

In Great Britain, the SI 1976 No. 2 regulation on childrens clothing (hood drawstrings) bans drawstrings in the fabric hem of the hoods on garments where chest size is smaller than 44 centimeters. The British 1997 standard BS 1907 referring to this regulation,

Forbids drawstrings or decorative ribbons longer than 14 centimeters on clothing for children under 3, and prohibits hard buckle tips longer than 5 centimeters.

Apparel must not have strings either decorative items or drawstrings - hanging out of garment back.

Sets down exact string measurements according to location of the drawstring on a garment. Drawstrings cannot exceed 14 centimeters at the waist when the garment is fully loosened. Bottom-half drawstrings cannot be longer than 8 centimeters.

Recommends spring clips and wide vents. The standard forbids the use of any aglet likely to increase entrapment (knots or duffel-coat toggle-fastenings, for instance). Standard neck fastenings like the ones adults wear are not appropriate for children under 5. The fastenings must be easily detachable in case of entrapment. Neck fastenings must be removable (hence the recommendation for Velcro or snap fastenings).

Specifies that nightwear for children under 3 should not have hoods because they obstruct the childs line of view and hearing. Clothing with hoods must be designed to avoid said inconveniences. Hoods should preferably come off at the slightest pressure. Hood Cords for Childrens Clothing, SI 1976 No. 40 of Ireland is very similar to UK regulations. Therefore, products distributed in the UK/Ireland must comply with this requirement in addition to the requirements of EN 14682.

Country: Finland
Finland has no regulations. However on November 18, 1998, the National Consumer Association (NCA) issued a press release calling for a ban on the import of childrens apparel with drawstrings around the neck. Several children suffered near suffocation due to drawstrings.

The NCA drew on the example of Great Britain and, in agreement with Finnish manufacturers, called for safer childrens apparel by pointing to the fact that Finnish suppliers were already selling articles with other fastenings (Velcro, elastic bands, and so on) for older children. Some day-care centers have already acted on this and asked parents to cut off the drawstring on very young childrens garments. Manufacturers seem to be aware of the hazards and have designed the appropriate clothing.

Regulations when selling in throughout the US, Canada and the EU

Certain parts of the EU requirements are more stringent than the US/Wisconsin/NY requirements: All size ranges (ages up to 14) are regulated. Drawstrings hanging below the hip, cannot hang below the lower edge of the garment. Drawstrings cannot protrude from the bottom hem of coats, trousers or skirts that are designed to finish at the ankle. The standard also specifies drawstring requirements for sleeves and other parts of the garment. For hood and neck areas, EU standard covers all ages up to 14 years whereas US requirements covers up to 12 years. (Note: Age is used as an approximation as the measurement guidelines represent a retailer's average customer. In the smaller sizes (up to size 8), the size translates to approximate age.For US sizing, size 10/12 is generally for ages 9-10, 14/16 is generally ages 11-12 and size 18 is generally 13-14 years. However, certain portions of the US (including New York and Wisconsin) requirements are more stringent:

 Only 3 inches of the drawstring are allowed to extend outside the drawstring channel, as opposed to 5.5 inches (140 mm) for the EU in the waist area. For hood and neck areas, the EU allows loop drawstrings for ages 7-14 whereas US does not allow any drawstring for sizes 2T-12-CPSC/NY (approximate age 10) and 0-16WI (approximate age 12).

However, the UK national legislation does not allow drawstrings and cords (ties) for hood and neck areas in childrens outer wear with chest measurement not exceeding 44 cm (approximately up to 13 years of age).

Therefore, it is recommended to follow one separate specification for US/Canada and one for the EU. Drawstrings specifications for childrens apparel are specified in the following two (2) charts.

A research report published in November 1999 entitled "Choking Risks to Children" evaluated the effectiveness of the small parts cylinder test in preventing choking accidents to children under four from small toys or parts Garments. The Garment should not have any accessories exceeding the size mentioned below.

AUSTRALIA AND NEW ZEALAND CHOKING HAZARD INHALATION AND INGESTION.

This is a hazard caused by a component or failure of a component, which if inhaled or ingested by a child can create an obstruction in the airway, or poses a risk of perforation in the esophagus. Toy Standard AS/NZS ISO 8124.1:2002) Small Parts Small parts include non-porous material smaller than 3cm diameter. Small parts must be secure and not able to be removed from the garment. Known Examples: Buttons, studs, eyelets, toggles. Trims beads / sequins / pompoms / animal eyes or noses. Buckles / zip pullers. Battery case for sound box. Filling in toys. Decorative motifs, eg: butterflies; flowers. . TOGGLES _ Must securely attached _ Must pass bite test (as per AS1647.2). _ Prohibited around neck area (3 yrs and under). _ Cord must be securely attached at both ends preventing toggle from falling off or pulled off. TRIMS ZIPS Glass prohibited Zip pull to pass bite test (as per AS1647.2) Plastic zips are recommended for age 3 years and under, unless harsh wash item. Zips must be Burr free

Nylon Zip not to have excess teeth beyond top stop FASTENERS Ties to be kept to a minimum length, to be fit for purpose, eg: enough length to tie a bow, if relevant to product. Ribbon ends to be heat -sealed or bar tacked. Rope to be securely knotted at ends. Mock ties preferred in lieu of draw cord. Ties in hood & hat to be s ecured Prohibited for newborn. Chin ties to be open -ended (not looped). Elastic relaxed measurement to meet minimum size requirements to prevent lack of circulation. Soft quality elastic preferred for newborn and sleepwear. Binding ends to be kno tted or bar tacked. Elastic Cord to be secured at opening to be non-functional, loop to be no more than 2.5cm Non -stretch cord preferred Velcro to be positioned to avoid contact with skin, Corners to be rounded, Use soft quality Velcro FLOATING / LOOSE THREADS: Goods contain no floating threads in the toe or finger area for infants up to 12 months of age. The goods contain no loose and or floating threads longer than 1cm on the inside or outside of the remaining article for infants up to 18 months and 2.5cm over 18 months. Terry toweling: Looped yarn to break at 3cm when pulled by hand not to be able to be continuously pulled to form a loop. Loose or Untrimmed Threads in Feet, Hands or Crotch : PROHIBITED

BELTS Chain Belt Sold with Garment: Prohibited for 3yrs and under. Prohibited for 3yrs and under : Prohibited for 3yrs and under.

Informal Comparison Between Various U.S. Drawstring Standards

2

ASTM Standard (F
1

Wisconsin Law (ATCP 139)

1816-97) How implemented Voluntary national standard Already implemented. State regulation. Effective Date: January 1, 2000. No drawstrings in the hood and neck area of all childrens clothing. All childrens clothing. Sizes 0 to 16.

New York (A10866) (Amendment to A01865 from 2002). State law. Effective upon enactment.

Neck area prohibitions

No drawstrings in the hood and neck area of certain childrens clothing. Only childrens upper outerwear. Sizes 2t to 12.

No drawstrings in the hood and neck opening of certain childrens clothing. All childrens clothing. Sizes 0 to 12.

Waist/bottom prohibitions

Drawstrings at waist and bottom of certain childrens clothing subject to limitations. Only childrens upper outerwear. Sizes 2t to 16 Drawstrings may not extend more than 3 inches (75mm) past channel when garment is expanded to fullest width. No toggles, knots, or other attachments at free ends. Bartacked if drawstring is one continuous string.

Drawstrings at waist and bottom of certain childrens clothing subject to limitations. Only childrens upper outerwear. Sizes 0 to 16 Drawstrings may not extend more than 3 inches past channel when garment is expanded to fullest width. No toggles, knots, or other attachments at free ends. Drawstring is sewn to garment at midpoint of channel so it cannot be pulled out of channel.

Drawstrings at waist and bottom of all childrens clothing subject to limitations. All childrens clothing. Sizes 2t to 16 Drawstrings may not extend more than 3 inches past channel when garment is expanded to fullest width. No toggles, knots, or other attachments at free ends. Attached to garment at midpoint of drawstring.

Exemptions Definitions

Upper outerwear with fully retractable drawstrings. Definitions cover the terms: bartack, bottom of upper outerwear, drawstring, hood, neck area, neck opening, toggle, upper outerwear, and waist.

None. Definitions cover the terms: neck area, upper

3

None Definitions cover the terms: sell at retail, drawstring, tie, hood, neck opening, toggle, and aglet. Note: Ties are not considered drawstrings and aglets are not considered toggles.

outerwear. These terms are modeled after ASTM definitions.

Safety Regulations for Leather Goods

In case of the leather industry, measures are mainly targeted at preventing hazards through chemicals and keeping exposure to dust as low as possible. Chemicals used for several process steps, with tanning being a very important one. Substances like pesticides, solvents, dyes, finishing agents and processing chemicals are frequently toxic and persistent, both to the environment and to human health.

The health problems and safety regulations here are associated with chemicals are primarily related to skin contact or inhalation of hazardous chemicals. Exposure to certain chemicals could lead for example to disability, illness and even death in the long term.

The chemicals used in tanning and other operations may be hazardous individually or when mixed. A number of fatal accidents have occurred world wide due to the unintended generation of toxic hydrogen sulphide gas. These accidents where not only fatal for employees; the surrounding community was heavily affected too. It showed that occupational health & safety is more than the well being of employees.

Exposure, toxic effects, and the percentage of chemicals used in the leather products should therefore adhere to the standards set by the authorities.

Country Wise Legislation Laws restricting the content of Azo dyes in Leather Products

Azo dyes are often used in the coloring process of several textiles and leather products. Relatively recently it has been recognized that some Azo coloring agents may form amines (breakdown products), which have carcinogenic and mutagenic properties.

European Union Legislation Laws For Leather Products

The European Union restricts the marketing and use of certain dangerous substances and preparations (Azo colorants) in leather products. The legislation is relevant for all products made leather or in which leather is used and which come into direct and prolonged contact with the skin and mouth. These include producers of textiles and garments, leather goods, shoes, toys, furniture, decorative articles, jewellery and accessories.

EU legislation: Azo dyes in leather articles Azo dyes are often used in the colouring process of textiles and leather. Many azo dyes exist that can be used to dye textile and leather. Part of these dyes has the capacity to release certain aryl amines which pose cancer risks. For this reason, the European Union laid down legislation to prevent exposure to these hazardous arylamines. This indirectly implies that those azo dyes that can split into these restricted amines can no longer be used to dye textile and leather products that come into contact with the skin.

Outline of the requirements of Directive 2002/61/EC

The European Commission has published legislation restricting the use of azo dyes which can release one or more specified amines in textile and leather articles. This legislation is laid down in Directive 2002/61/EC, amending Directive 76/769/EEC on the marketing and use of dangerous substances and preparations. The aim of the Directive is to protect the consumers health in the EU. The Directive is applicable to all leather products that may come into direct and prolonged contact with the human skin or oral cavity. The examples of products listed are: Clothing, bedding, towels, hairpieces, wigs, hats, nappies and other sanitary items, sleeping bags, Footwear, gloves, wristwatch straps, handbags, purses/wallets, briefcases, chair covers, purses worn around the neck, Leather toys or leather garments,

The Directive establishes that the products covered by the legislation may not contain the 22 amines listed in Table 1 in a concentration above the threshold limit of 30 ppm. This limit, 30 ppm, equals the detection limit. all parts of a product should comply with this limit, and that this limit applies to each amine separately. E.g. a textile shoelace of leather footwear needs to comply with the limit of 30 ppm, as well as the leather parts of footwear. It is not allowed to take the average concentration of a certain amine in the complete product.

The UK legislation: Azo dyes in leather articles

The restricted use of azo dyes in textile and leather articles as established in Directive 2002/61/EC and amended by 2004/21/EC was implemented in the United Kingdom by the Controls on Certain Azo Dyes and "Blue Colorant" (Amendment) Regulations.

The UK legislation is a direct transposition of the EU legislation. This means that the UK legislation sets the same requirements as the EU Directive. The table below provides a summary of the legislation.

Substance (CAS number)*:

Azo dyes that may split into harmful amines (92-67-1, 92-87-5, 95-69-2, 91-59-8, 97-56-3, 99-55-8, 106-47-8, 615-05-4, 101-77-9, 91-94-1, 119-904, 119-93-7, 838-88-0, 120-71-8, 101-14-4, 101-80-4, 139-65-1, 95-534, 95-80-7, 137-17-7, 90-04-4 and 6009-3)

Products:

Leather articles which may come into direct and prolonged contact with the skin or mouth

Requirement: Status:

Limit: 30 ppm Existing legislation implementation of EU

Source:

The Controls on Certain Azo Dyes

and "Blue Colourant" (Amendment) Regulations

*

A CAS number is a unique identifying number assigned to chemicals by

the Chemical Abstracts Service.

Legislation Laws restricting the content of Chromium in Leather Products

Hexavalent chromium, abbreviated as Cr(VI) is a substance hazardous to health. Cr (VI) can for example cause allergenic reactions in people. The substance itself is not used in the leather tanning process, but can be formed from the use of Chrome III. However, if the tanning process is optimized, the Cr (VI) level can be as low as the detection limit.

Germany Legislation- Chromium in Leather Products

The General product safety requirements in Germany are laid down in the LMBG (Lebensmittel und Bedarfsgegenstnde Gesetz). Governments use such general requirements to protect consumers for products for which there is not any specific legislation.

In Germany, it is forbidden to manufacture or distribute commodities in such a way, that "if used properly or as anticipated, they may constitute a danger to health on account of their material composition, particular through toxicological substances or impurities."

Considering the hazardous nature of Hexavalent Chromium, the German enforcement authorities strongly advise all those marketing leather products in Germany to ensure that the Cr(VI) content of the leather should not exceed 3 ppm.

Substance: CAS Number: Products: Requirement:

Hexavalent Chromium (Cr(VI)) 7440-47-3

Leather products It is strongly advised not to market leather products in which the Chromium content exceeds 3 ppm.

Status:

Interpretation requirement

of

general

product

safety

Source: JAPAN

Lebensmittel und Bedarfsgegenstnde Gesetz

Restrictions on Harmful Substances

Handling baby and childrens wear demands observing the Law for the Control of Household Products Containing Harmful Substances. These restrictions are under the jurisdiction of the Office of Environmental Chemicals Safety, Environmental Health Bureau, Ministry of Health and

Welfare, and the restrictions also apply to goods other than clothing. Details of the restrictions on baby and childrens wear grouped according to type of harmful substances are shown in the following table.

RESTRICTED SUBSTANCES LIST (RSL )

This Restricted Substances List (RSL) was created by a special working group of the American Apparel & Footwear Associations (AAFA) Environmental Task Force. The RSL is intended to provide apparel and footwear companies with information related to regulations and laws that restrict or ban certain chemicals and substances in finished home textile, apparel, and footwear products around the world.

The following table lists the various chemicals, and application areas and also the raw materials, component parts, chemicals, sundries and other things of value in which they can be expected.

TABLE - CHEMICALS DESCRIPTION AND SOME FIELDS OF APPLICATION Nickel Nickel metal that is a Nickel metal is mainly used metal parts, plating the in of alloys, natural corrosion fibers, man alloys, made fibers

element for may

be improving

present as either resistance

a pure metal or improving the hardness of as nickel alloys and is a key element in the production steel. of

compounds, e.g., salts.

stainless

Nickel

compounds can be used as pigments and as fixing agents. Both nickel metal and nickel compounds can occur as an impurity in pigments and alloys Antimony Antimony is a Antimony can be used as a leather, metal that may catalyst in polymerisation manmade be present either a as of polyester. Antimony fiber,

pure compounds can be used as natural retardants, fixing fibers, metal

metal, or as a flame

compound, e.g., agents and can be found in parts salts. pigments.

Arsenic

It can be present Arsenic and its compounds leather, as a pure metal, can be used in some manmade

as non-metal or preservatives, as

pesticides fiber, natural fibers, metal parts

arsenic and defoliants for cotton

compound

Chromium Chromium is a Chromium compounds can leather, (Cr) metal element be used as dyeing additives, manmade

that is present as dye-fixing agents, for after fiber, a pure metal or treatments as in order to natural

chromium improve colour fastness. fibers, metal Dyes for wool, silk and parts polyamide textiles could contain chromium

compounds

complexes, especially for dark shades. Chromium

salts are used for tanning of leather. Chromium Chromium is a Used in leather or suede Leather VI metal present that as is tanned with chromium salts a

pure metal or as chromium compounds. Cobalt Cobalt metal is that a Cobalt compounds can be leather, is used as pigments. Cobalt manmade

present

as

a metal can be used in metal fiber, natural fibers, metal parts

pure metal or as alloys cobalt compounds Lead

Lead is a metal Lead compounds can be leather, element that is used present as as stabilizers for manmade

a plastics, in pigments for fiber, or paints, e.g., natural

pure metal or as textiles

lead compounds surface paints on zippers fibers, metal and buttons, as well as in parts prints on plastic products. Mercury Mercury is a metal Mercury compounds can element that would be present in pesticides not be normally found and can be found as a in its metallic form. contaminant Mercury will in caustic

form soda. Mercury compounds

compounds with other can be used in paints, e.g., chemicals, e.g., salts. surface paints on zippers and button Phthalates Used as softener (plasticizer) in plastics, prints, print pastes, adhesives and plastics

other and rubber

products. Up to 50% of soft PVC plastic can be a phthalate softener, but other plastics or prints can contain phthalates as well. Plastic buttons could contain phthalates.

Organotin Compounds

Mainly

used

as

stabilizers

in Prints,

plastics rubber,

plastic/rubber but also as anti-bacterial and agents in textiles. Can be found in anti leather. corrosion coatings in drums containing for example dye stuff. Used as catalysts in plastic production

Phenols

Phenols (PCP/TeCP) are sometimes used natural

fibers,

to prevent mold when growing cotton man made fibers, and when storing/transporting fabrics. prints, Phenols can be used as a preservative in and print pastes. Isocyanates plastics, rubber,

leather and paper

Isocyanates are used in the production of fabrics polyurethane plastics and foams.

PCBs

These are large molecules containing They are mainly many chlorine atoms used pesticides, as but

also as softeners, carriers and

flame retardants Chlorinated agents Solvents Organic solvents are mixtures of volatile, Solvents are used commonly petroleum-derived, chemicals. whenever Many contain large amounts of something needed dissolved, to is be for Bleaching Used for bleaching textiles, paper etc

chlorinated derivatives.

example, in the dyeing/printing process, removing when spots

on ready made garments and for dissolving glue the when

making shoes Perflourinated PFOS and PFOA are included in a group PFOS and PFOA Alkylated Substances (PFAS) of chemicals called fluorocarbons. They are used in the are surfactants known to be stable, not production sensitive to heat and to repel both water fluoropolymers and oily compounds. which are used as impregnating agent on textiles, e.g., repellents. Where Expect Chemical Description Field of Application Chemicals fibers, to water of

Azo Dyes and Aromatic amines For dyeing textiles, Natural Pigments can be a part of prints the and

leather man made fibers, Both leather, prints, and

molecular products. and

structure in AZO pigments dyes used both stuff may

dye plastics

contain rubber

for natural and banned amines. synthetic materials Disperse Dyes Disperse are that penetrate dyes Mainly for dyeing Man made fibers, plastics

molecules polyester fibers but prints, can also

polyamide, and rubber.

the acetate, viscose and manmade

fiber system of other polyester. It is fibers not chemically to the

bonded

fiber but trapped inside the fiber by forces. physical Some

disperse dyes are also banned azo dyes as they can cleave to form the amines Other Dyes Flame Retardants For dyeing textiles and other materials. To decrease the flammability of the product, e.g., lowering the energy (heat) of the flame. restricted

Formaldehyde Formaldehyde is Formaldehyde volatile and formaldehyde

or Natural

fibers,

man-made fibers, plastics rubber, and

colourless and is releasing compounds prints, present in small can, for example, be and amounts in the used atmosphere, tobacco glue for pre- leather

shrinkage, easy-care paper. pre-crinkle and for or

smoke, and and air treatment,

pollution. Due to fixation its

volatility, preservation of dyes

formaldehyde is and prints. "contagious". If you place a with

garment

formaldehyde on top of a garment that does not

contain formaldehyde, the garment become "infected". Fabric samples other may

for testing need to be packed

separately plastic bags.

in

PVC

PVC is a plastic In the textile industry Prints,

plastics

that can be soft PVC could be used to and rubber or transparent coloured. may hard, make soft plastic like

or accessories

PVC badges, sequins and contain zip pullers or as

phthalates, organotin

coating on textiles for rainwear and prints. kinds of

compounds, lead Various and cadmium.

prints might be made out of PVC

BROKEN NEEDLE POLICY Supplier must operate a Broken Needle Policy that will include the following operating procedures: Machinists must not hold spare needles they must be distributed by an authorized supervisor All parts of broken needles must be retrieved and stored along with an incident record If parts of a broken needle are not located the garment being sewn must be passed through a metal detector. If the missing needle parts are not locatable as a result the garment must be disposed of and not included in the bulk shipment Old needles must be disposed of safely by an authorized supervisor These procedures must operate in all areas of garment construction including embroidery, appliqu and any outsourced sewing operations. All procedures must be documented and available for inspection if requested.

PINS Neither pins nor staples are to be used at any point in the garment manufacturing process. This includes all stages of cutting, accessories collation, sewing lines, inspection and packing. Staples must not be used on paperwork on the manufacturing floor.