Children's Sleepwear Seminar - 12/2/2016

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 ToroU.S. Consumer Product Safety

CommissionDecember 2016

Seminar Overview

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Welcome Housekeeping Notes Morning Seminar Agenda

CPSIA Requirements for Children’s

Products Best Business Practices Children’s Sleepwear Session

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.

CPSC Jurisdictional Authority

Jurisdictional Authority from several Acts: Consumer Product Safety Act (CPSA) Federal Hazardous Substances Act

(FHSA) Flammable Fabrics Act (FFA)

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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

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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

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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.

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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

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CPSIA - Lead Requirements

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Total Lead Content Children’s products Limits total lead in accessible parts to

100 ppm

Lead in Paint and Surface Coatings

Phthalate limits

www.cpsc.gov/lead

CPSIA Lead - Clothing and Textiles

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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

Lead Determinations - Textiles

16 CFR Section 1500.91: Certain materials will not exceed lead limits Includes dyed or undyed textiles

and nonmetallic threadDoes not require third party testing

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Screen Printing

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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

Phthalates - Child Care Articles

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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 partswww.cpsc.gov/

phthalates

Testing - Children’s Products

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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 testingwww.cpsc.gov/

testing

Children’s Product Testing

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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.

Component Part Testing

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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.

Sleepwear Testing and CPSIA

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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.

Small Batch Manufacturers

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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

http://saferproducts.gov/SmallBatchManufacturers/

Children’s Product Certificate (CPC)

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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.

CPSIA - Tracking Information

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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.

Product Safety ConcernsProducts 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

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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

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Violations/Prohibited ActsThe 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.

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Enforcement and Surveillance

Compliance Programs Firm Inspections

Complaints Industry, Consumers, Government Agencies

Retail Surveillance/Internet SurveillanceReports from Manufacturers and

RetailersImport Entry Points

Ports and AirportsIndustry TradeshowsSample Collections

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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

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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

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Children’s Sleepwear Recalls

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Top Violations FY2012-FY2016

31%

15%

12%

7%

6%

4%3%

3%

Sleep-wear

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

Sleepwear Violations by Violation Code FY2012-

FY2016

220

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2415

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Sleepwear Flammability Failure

Exceeds Tight-Fitting Dimensions

Sleepwear Labeling

Sleepwear Policy

Other Children's Sleepwear

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

Other

Sleepwear Recalls by Violation Code

FY2012-FY2016

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Sleepwear Flammability Failure

Exceeds Tight-Fitting Di-mensions

Sleepwear Labeling

Sleepwear Policy

Lauren KleinmanTrial 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

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.

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.

Civil Penalty for Sale of Flammable

Children’s SleepwearIn 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.

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.

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.

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.

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.

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.

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.

Business Panel

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Interactive Questions with Paige Witzen and Carrie

Carlin

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Which garment is considered sleepwear?

1. 2.

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Which garment silhouette appears to be traditional sleepwear?

1. 2.

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Which garment appears to be tight fitting?

1. 2.

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Can tight-fitting children’s sleepwear garments have a hood?

1. Yes

2. No

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What type of children’s sleepwear requires a hangtag?

1. Tight-Fitting Garments2. Traditional Sleepwear3. Robes

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Is an FPU or GPU number required on traditionally styled children’s sleepwear garments?

1. Yes 2. No

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Are there mandatory labeling requirements for children’s sleepwear?

1. Yes 2. No

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

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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

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Are certain fabrics composed of specific fibers exempt from the

testing requirements for children’s sleepwear?

1. Yes

2. No

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Is there a hangtag requirement that states a garment is flame resistant or

flame retardant?

1. Yes 2. No

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Which item below would be defined as trim under the Standards and requires testing?

1. Screen Print2. Spaghetti Strap3. Neck Label4. Hangtag5. Trim less than 2

inches6. Zipper 56

Would a sleepwear garment sized 6-12 months require testing under the

Sleepwear Standard?

1. Yes 2. No

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Can tight-fitting sleepwear garments be offered exclusively in small, medium, and large sizes?

1. Yes 2. No

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Do tight-fitting children’s sleepwear garments require measurement by a CPSC-

accepted accredited third-party laboratory?

1. Yes 2. No

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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 TenneyU.S. Consumer Product Safety

CommissionDecember 2016

Seminar Overview

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Welcome Back Afternoon Seminar Agenda

Requirements and Testing Testing and Laboratory Panel What to Expect When You’re

Inspected Closing Remarks and Q & A

Sleepwear Standards and

Testing Requirements

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Children’s Sleepwear Standards

Mandatory Federal StandardsDeveloped in the early 1970s Two size ranges

0 – 6X7 – 14

Scope – protect children from small open-flame sources

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Intent of the StandardsRisk of Injury

Reduce risk of personal injury or death

Contact with a small ignition source

Not intended to protect against large fire sources

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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.

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Standards have been amended over the years

Sampling PlansResidual Flame TimeTesting TrimLaundering ProceduresTight-fitting and Infant Garments

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Tight-fitting Garments Sizes - Larger than 9 months to

size 14 Garments must not exceed

maximum dimensions specified for each size

Labeling ruleHangtagPermanent Label

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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

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Cleared Testing Video Clip

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Testing

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.

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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

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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

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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

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.

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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)

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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)

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.

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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.

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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

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General Overview of Test Method Determine Fabric Weight

Measure fabric weight before testing(Conditioned for at least 8 h at 21±1.1°Cand 65 ±2% relative humidity)

Different loads to be usedfor different fabric weights

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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.

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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.

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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

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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.

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General Overview of Test Method Testing

Light the burner and check that the flame height is

3.8 cm (1.5 inches).

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Remove the specimen from the desiccator.

Suspend the specimen vertically in the test cabinet.

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Impinge the burner flame on the bottom edge of the specimen for 3.0 ±0.2 seconds.

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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.

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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.

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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.

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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).

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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.

Technical Requirements for Laundering Washing Machine Conditions Water Level 18 ± 1 gal Agitator Speed 179 ± 2 spm Washing Time 12 min Spin Speed 645 ± 15 rpm Final Spin Cycle 6 min Wash Load Max 3.64 kg (8 lbs) Detergent AATCC 1993 Std Reference Detergent Powder Amount 66.0 ± 0.1 g Dryer Conditions Exhaust Temperature 66 ± 5 °C (150 ± 10 °F) Cool Down Time 10 min

Washing and Drying Conditions Washing Cycle Normal/Cotton Sturdy Wash Temperature 60±3°C (140±5°F) Rinse Temperature < 29°C (85°F) Drying Procedure Tumble, Permanent Press

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What is Children’s Sleepwear?

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

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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.

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“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.

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Traditional Children’s Sleepwear Examples

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Recalled Sleepwear

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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)

Any Questions?

???

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Tight-Fitting Information and How

to Measure

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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.

Tight-Fitting Sleepwear

Recalled Tight-Fitting Sleepwear

Tight-Fitting Labeling

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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.

Labeling Requirements for Tight-Fitting Sleepwear

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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 boxArial/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.

Tight-Fitting Garment Measurement

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Measuring the Chest Measure the

distance from armpit seam to armpit seam (A to B) Flatten seams and finger press any folds

A

B


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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


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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.


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Measuring the Wrist or CuffLong-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


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Measuring the Waist of the PantMeasure 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


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Measuring the SeatFold 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


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Measuring the ThighMeasure 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


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Measuring the AnkleFor 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


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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.


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Close-up of Trim

Bows, tags or any other ornamentation is measured in the same way.


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Lettuce EdgingThis 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.

Tight-Fitting Children’s Sleepwear

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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.

Tight-Fitting Children’s Sleepwear

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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.

Any Questions?

???

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Testing and Laboratory Panel

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What to Expect When You’re

Inspected

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Available Resources

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http://www.ecfr.gov/

http://www.cpsc.gov/

Contact Information

Allyson Tenney Mary ToroDirector DirectorDivision of Engineering Office of Compliance,

Regulatory Enforcement301-987-2769 [email protected] [email protected]

Carolyn Carlin Linda Fansler Paige WitzenTextile Flammability Textile Technologist Textile

TechnologistCompliance Officer301-504-7889 301-987-2059 [email protected] [email protected]

[email protected]

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www.CPSC.gov

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Thank You for Participating in our

Children’s Sleepwear Seminar!

127

Government & Nonprofit

Children's Sleepwear Seminar - 12/2/2016