2013 Flammability Requirements for Apparel and Sleepwear & Drawstrings in Children's Upper Outerwear, 2013 Safety Academy

1. U.S. CPSC
This presentation was prepared by CPSC staff, has not been reviewed or
approved by, and may not reflect the views of, the Commission.
SEATTLE SAFETY SEMINAR
FLAMMABLE FABRICS, SLEEPWEAR, DRAWSTRINGS
SEPTEMBER 16, 2013

2. 2
Mary Toro, Director, Office of Compliance,
Regulatory Enforcement Division, moderator
Jacqueline Campbell, Textile Technologist, CPSC
Seemanta Mitra, Senior Director, Textiles, Intertek,
Hardy Poole, Vice President, National Council of
Textile Organizations
Panelists

3. 3
Flammable Fabrics Act
1. Wearing Apparel
2. Vinyl Plastic Film
3. Children’s Sleepwear
4. Carpets and Rugs
5. Mattresses, mattress pads
6. Mattresses, mattress pads
1. 1610
2. 1611
3. 1615/1615
4. 1630/1631
5. 1632: Cigarette Ignition
6. 1633: Open Flame Ignition
16 CFR Part and Title

4. Children’s Clothing Requirements
1. Relevant Mandatory Flammability Standard
2. Children’s Product Certification of Conformity (CPC)
3. Third Party Testing
4. Lead Content
5. Lead in Surface Coatings
6. Tracking Labels
7. Phthalates (e.g., child care articles, sleepwear for
children < 3 years)
8. Small Parts (exemptions for buttons, fabrics)
9. Drawstrings in Children’s Upper Outerwear

5. Violations/Prohibited Acts
• Manufacturing for sale, offering for sale, importing,
delivery for introduction, transporting in commerce, of
any product or fabric that does not comply with a
flammability standard
• Failing to furnish information required by Section
15(b)
• Failure to issue a certificate of conformity
5

6. All Regulated LOA’s
FY08-FY13
0
500
1000
1500
2000
2500
915
1044
1926
1677
2316
1685
FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6

7. All Flammable Fabrics Act LOA’s
FY08-FY13
0
20
40
60
80
100
120
140
160
49
75
63
71
152
97
FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6

8. Flammable Fabrics Act LOA’s
FY08-FY13 by Product Type
0
10
20
30
40
50
60
70
80
90
47
1 1
32 36
7
52
8
3
48
15
8
60
81
11
32
62
3
FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6
Mattress Data Sleepwear Data All other apparel

9. FY13 - Recalls, Stop Sales and Seizures
as of 9/6
1127
793
21
0 200 400 600 800 1000 1200
Recalls
Seizures
Stop Sales

10. Requirements for Clothing
Textiles and Children’s Sleepwear
This presentation was prepared by CPSC staff, and it has not been reviewed or
approved by, and may not reflect the views of, the Commission.
Jacqueline Campbell
Combustion and Fire Sciences Division
Engineering Sciences Directorate
U.S. Consumer Product Safety Commission

11. Overview
• Specific requirements that apply to
clothing, textiles used for clothing, and
sleepwear
– Regulations under the Flammable Fabrics Act
(FFA)
• Flammability of clothing textiles
• Children’s sleepwear
– Drawstring requirements (children’s clothing)
– Requirements under the Consumer Product
Safety Improvement Act of 2008 (CPSIA)

12. 16 CFR PART 1610
Standard for the Flammability
of Clothing Textiles

13. 16 CFR Part 1610: Background
• Commonly referred to as the General Wearing
Apparel Standard
• Enacted in the 1950s
• Keeps the most dangerously flammable textile
products and garments out of the marketplace

14. 16 CFR Part 1610: Summary
• Applies to all adult and children’s wearing
apparel.
– Some exceptions and exemptions
• Specifies testing procedures used to determine
the relative flammability of textiles used in
apparel as one of three classes of flammability.
• Fabrics that meet a specific exemption do not
require testing.

15. 1610.1(c): Exceptions
• Interlining fabrics
• Most hats, gloves, and footwear
Examples that are not exempt:
– Gloves longer than 14 inches and/or attached to a
garment
– Hats that cover the neck, face, or shoulders
– Footwear that consists in whole or in part of hosiery
or is part of another garment

16. 1610.1(d): Specific Exemptions
• Plain surface fabrics ≥88.2 g/m2 (2.6
oz/yd2), regardless of fiber content
• Plain and raised surface fabrics made of:
acrylic,
modacrylic,
nylon,
olefin,
polyester,
wool,
or any combination of these fibers, regardless of
weight.

17. 16 CFR Part 1610: Test Summary
• 16 mm (5/8 in) flame impinges on specimen mounted at
45-degree angle for 1 second
• Allowed to burn full length or until stop thread breaks
• Results of several tests are averaged and a Class
designation is assigned

18. 16 CFR Part 1610: Test Summary
• Determine fiber and fabric
type
• Preliminary test
• Prepare and condition
• Test
• Preliminary classification
• Refurbish and repeat test
• Final classification
• Report

19. 16 CFR Part 1610: Classifications
• Class 1 – plain and raised surface fabrics that have no
unusual burning characteristics and are acceptable for
use in clothing
• Class 2 – raised surface fabrics only, intermediate
flammability- use with caution
• Class 3 – fabrics are dangerously flammable and
CANNOT be used in wearing apparel
Classification Plain Surface Raised Fiber Surface
Class 1 Average burn time > 3.5 s Average burn time > 7.0 s OR Average burn time is
0-7 s with no base burns (SFBB)
Class 2 N/A Average burn time is 4-7 s with base burn (SFBB)
Class 3 Average burn time < 3.5 s Average burn time < 4.0 s with base burn (SFBB)

20. 16 CFR Part 1610: Classifications
Code
Description Time
Reported
SF uc Surface flash, under stop thread, but does not break thread. None
SF pw Surface flash, part way; does not break thread. None
SF poi
Surface flash, at point of impingement only; equivalent to
DNI for plain surface fabrics.
None
_._ sec
Actual burn time (sec) measured and recorded by the timing
device.
Yes
_._ SF Time (sec), surface flash only; no damage to the base fabric. Yes
_._SFBB
Time (sec), surface flash base burn starting at places other
than the point of impingement as a result of surface flash.
Yes
_._SFBBpoi
Time (sec), surface flash base burn starting at the point of
impingement.
Yes
_._SFBBpoi*
Time (sec), surface flash base burn possibly starting at the
point of impingement; the asterisk is accompanied by the
following statement if there is a question as to the origin of
the base burn: Unable to make absolute determination as to
source of base burns.
Yes
Note:
A result of SFBBpoi or SFBBpoi* does not qualify as a base burn under the
current interpretation of 16 CFR Part 1610.

21. 16 CFR Part 1610:
Common Noncomplying Fabrics
• Sheer 100% rayon skirts and scarves
• Sheer 100% silk scarves
• 100% rayon and rayon/nylon chenille sweaters
• Long animal hair sweaters
• Polyester/cotton and 100% cotton fleece
garments
• 100% cotton terry cloth robes

22. 16 CFR PARTS 1615 AND 1616
Standards for the Flammability
of Children’s Sleepwear

23. 16 CFR Parts 1615 & 1616: What is Covered?
• Any product of wearing apparel intended to be
worn primarily for sleeping or activities related to
sleep in sizes larger than 9 months through size 14.
– Included: nightgowns, pajamas, robes, and
similar or related items, such as loungewear.
• Several factors determine if a garment is sleepwear:
– Suitability for sleeping, likelihood of garment to
be used for sleeping
– Garment and fabric features
– Marketing, merchandising/display, intended use

24. 16 CFR Parts 1615 & 1616: Exceptions
• Diapers and Underwear (exempt)
– Must comply with 16 CFR Part 1610
• Infant garments (exempt)
– Sizes 9 months or younger
– One-piece garment does not exceed 64.8 cm (25.75”)
in length
– Two-piece garment has no piece exceeding 40 cm
(15.75”) in length
– Must comply with 16 CFR Part 1610

25. 16 CFR Parts 1615 & 1616: Exceptions
Tight-Fitting Sleepwear (exempt)
• Tight-fitting garments (defined by the Standards) are
exempt from testing to the sleepwear requirements.
• Must:
– Not exceed specified dimensions.
– Comply with 16 CFR Part 1610.
– Meet labeling requirements.

26. 16 CFR Parts 1615 & 1616: Requirements
• Children’s sleepwear (that is not tight-fitting)
must pass the flammability requirements.
– All fabrics and garments must be flame resistant
and self-extinguish (not continue to burn) when
removed from a small, open-flame ignition source.
• Multiple stages of testing are
required, following prescriptive sampling
plans.

27. 16 CFR Parts 1615 & 1616: Requirements
• Multiple stages of testing are required, following
prescriptive sampling plans

28. 16 CFR Parts 1615 & 1616: Summary
• Test fabric, seams, and trim
• Test sample of five specimens
• Vertical orientation
• Test in original state and
after 50 laundering cycles

29. 16 CFR Parts 1615 & 1616: Summary
• Five 8.9 cm x 25.4 cm (3.5 inches
x10 inches) specimens of
fabric, seams, and trim.
• Specimens are conditioned
before testing.
• 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.
Preparing to apply ignition
source to specimen

30. 16 CFR Parts 1615 & 1616: Requirements
• The average char length of 5 specimens cannot
exceed 17.8 cm (7.0 inches).
• No individual specimen can have a char length
of 25.4cm (10.0 inches) (full-specimen burn).
• Production testing and recordkeeping
requirements
– Tested samples must be retained

31. FFA Guidance
• http://www.cpsc.gov/en/Regu
lations-Laws--
Standards/Regulations-
Mandatory-Standards--
Bans/Regulated-Products/
– Search by product (use
wearing apparel and
sleepwear)
– http://www.cpsc.gov/busi
nfo/loungewear.pdf

32. ASTM F1816-97
Drawstrings on Children’s
Clothing

33. Drawstring Requirements
Children’s Clothing
• CPSC issued guidelines (1996) later adopted by ASTM in
1997 (ASTM F1816-97)
– May 2006 letter to industry
(http://www.cpsc.gov/PageFiles/135448/drawstring.pdf)
• Substantial product hazard
• Applies to drawstrings on upper outwear, jackets, and
sweatshirts
• Sizes 2T-12 (or equivalent) with neck or hood drawstrings
• Sizes 2T-16 (or equivalent) with
waist or bottom drawstrings
that do not meet specified
criteria
• Dresses are not upper outerwear
• Belts are not drawstrings

34. THE CONSUMER PRODUCT
SAFETY IMPROVEMENT ACT
Textiles and Related Products

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

36. What’s Required: Children’s Clothing
• Children’s Clothing:
– 16 CFR Part 1610 (Flammability)
– CPC Required, Third Party Testing
– Lead Content
– Lead Surface Coating
– Tracking Labels
– Drawstring Requirements

37. What’s Required: Children’s Sleepwear
• Children’s Sleepwear:
– 16 CFR Parts 1615 and 1616 (Flammability)
• 16 CFR Part 1610 if tight-fitting
– CPC Required, Third Party Testing
– Lead Content
– Lead Surface Coating
– Tracking Labels
– Phthalate Requirements (sleepwear for
children three years old or younger)

38. Resource: Small Business Ombudsman
http://www.cpsc.gov/en/Business--Manufacturing/Small-Business-Resources/

39. Resource: Searchable List of Laboratories
http://www.cpsc.gov/cgi-bin/labsearch/

40. For Further Information:
Jacqueline Campbell
Textile Technologist
Office of Hazard Identification and Reduction
301-987-2024
jcampbell@cpsc.gov
Allyson Tenney
Lead Compliance Officer
Office of Compliance and Field Operations
301-504-7567
atenney@cpsc.gov
www.cpsc.gov

41. www.intertek.com41
Seemanta Mitra
Senior Director – North America Softlines
seemanta.mitra@intertek.com
CPSC SEATTLE SAFETY ACADEMY
FLAMMABLE FABRICS, SLEEPWEAR,
DRAWSTRINGS
SEPTEMBER 18, 2013

42. www.intertek.com42
For more than 127 years, companies around
the world have depended on Intertek to ensure
the quality and safety of their
products, processes and systems.
Intertek is the industry leader with over 36,000
people in 1,000 locations in over 100 countries.
Intertek has one of the largest number of CPSC
approved laboratories to conduct CPSIA testing
on consumer products.
Introduction - About Intertek

43. www.intertek.com43
16 CFR 1610 – Standard for the
Flammability of Clothing Textiles
 16 CFR 1615/1616 – Standards for the
Flammability of Children’s Sleepwear
 Drawstrings (ASTM F1816-97)
Intertek has made all reasonable efforts to ensure the
accuracy of the information provided. However, the
information provided should not be relied upon as
legal advice, or a substitute for legal advice.
Discussion Topics

44. www.intertek.com44
 16 CFR 1120: Substantial Product Hazard List
Drawstrings

45. www.intertek.com45
Overview of 16 CFR 1610 –
Standard for the Flammability of Clothing Textiles
• The standard provides methods of testing
• Establishes three classes of flammability
• Sets requirements for clothing textiles and
apparel
• Warns against the use of unsuitable textiles

46. www.intertek.com46
Overview of 16 CFR 1610 –
Standard for the Flammability of Clothing Textiles

47. www.intertek.com47
16 CFR 1610 – Issues That Come Up Regarding The
Regulation
• Is leather apparel exempted from the
regulation?
• Is the inside surface of socks exempted
from the regulation as unexposed surface?
• Are belts covered by the regulation?
• Interpretation of plain and raised-surface
fabrics

48. www.intertek.com48
16 CFR 1610 – Issues That Come Up Regarding The
Regulation

49. www.intertek.com49
16 CFR 1610 – Issues That Come Up Regarding The
Regulation
CPSC Comments:
Sample A: Design has a float yarn, sheared at the edges forming
a fiber tuft. The edge is intentionally raised.
Overall comment: Raised surface
Sample B: The edges are not intentionally raised.
Overall comment: Plain surface
Sample C: Design has a float yarn, sheared at the
edges forming a fiber tuft. Edge is intentionally raised.
Overall comment: Raised surface

50. www.intertek.com50
16 CFR 1610 – Issues That Come Up Regarding The
Regulation
Sample D: Sample is a ‘burn-out’ or flat woven construction
without an intentionally raised fiber surface. The slight ‘fringe’ on
some edges occurs because the satin weave anchoring the
filling yarns is not tightly woven.
Overall comment: Plain surface
Sample E: Design is similar to sample ‘A’ and ‘C’ with a float
yarn, sheared at the edges forming a fiber tuft. Edge is
intentionally raised.
Overall comment: Raised surface
Sample F: The black and white yarn design is woven
into the fabric as a pattern, but does not have an intentionally
raised edge.
Overall comment: Plain surface

51. www.intertek.com51
16 CFR 1610 – Lab Data Sheet
Surface type: Plain Raised
Tested side: Face Back
Original State
After one dry cleaning and laundering per
AATCC TM 124, option (1)(IV)(A)(iii)
Preliminary Test Preliminary Test
Length Burn Characteristics Time (s) Length Burn Characteristics Time (s)
Up Up
Down Down
Width Burn Characteristics Time (s) Width Burn Characteristics Time (s)
Up Up
Down Down
Final Test Final Test
Test Burn Direction: Length Width Test Burn Direction: Length Width
Specimens Burn Characteristics Time (s) Specimens Burn Characteristics Time (s)
1 1
2 2
3 3
4 4
5 5
6 6
7 7
8 8
9 9
10 10
Average: Average:
Classification:  Class 1, Normal Flammability,
 Class 2, Intermediate Flammability, Raised surface
 Class 3, Rapid and Intense Burning,
 No Evaluation Due to Insufficient Sample submitted for testing
Sample Identification: _______________________Fabric Weight (oz/yd2) ________
Claimed Fiber Content: ________________________________________________

52. www.intertek.com52
16 CFR 1610 – Lab Data Sheet
Prepared by: Tested by: Checked by:
Date _______________ Date _________________ Date ___________
 Sample is exempt because it is a plain surface fabric which weighs 2.6 oz/yd² or more. Actual fabric weight is _____ oz/yd².
 Sample is exempt because of its fiber content. The claimed fiber content is _____________________.
Test additional five specimens (both original and after refurbishment) if
Plain Surface
Only 1 burn time & it is <3.5s; Average burn time <3.5s.
Raised surface
Only 1 burn time & it is <4s with SFBB; Average burn time <4s with 2 or more SFBB.
Explanation of Flammability Results:
For plain surface fabric
DNI Did not ignite
IBE Ignited but extinguished (no time)
*IBE
Ignited, but extinguished, the asterisk (*) denotes a burn that goes under the cord without breaking the cord.
0.0 BB Actual time of burn from ignition until the flame severs the cord directly above the specimen.
For raised surface fabric
SF uc Surface flash, under stop cord, but does not break the cord (no time)
SF pw Surface flash, part way. No time shown because the surface flash did not break the cord.
SF poi Surface flash, at point of impingement only (equivalent to “did not ignite” for plain surfaces).
0.0 SF only
Time in seconds, surface flash only. No damage to the base fabric.
0.0 SFBB
Time in seconds, surface flash base burn. Base starts burning at points other than that point of impingement.
0.0 SFBB poi
Time in seconds, surface flash base burn starting at the point of impingement.
* 0.0 SFBB poi
Time in seconds, surface flash base burn possibly starting at the point of impingement. The asterisk is accompanied by the
following: “Unable to make absolute determination as to source of base burns.” This note is added to the result of any specimen if
there are questions as to origin of the base burning. It does not qualify as a base burn under the current interpretation of CFR
1610.

53. www.intertek.com53
Children’s sleepwear & non-sleepwear flammability regulation
requirement:
Product
Requirements
16 CFR
1615 /
1616
16 CFR
1610
Tight
fitting
Specs
Children’s Sleepwear
Loose fitting *
Tight fitting * *
Innerwear, Long
Underwear, Daywear
*
Flammability Regulation

54. www.intertek.com54
Sample Preparation:
Specimen size 3.5” x 10.0”
•FPU – Original state
•10 specimens
•FPU – 50 launderings
•10 specimens
•Prototype
•15 specimens of each construction type
•Garment
•15 longest seam specimens
16 CFR 1615/1616 – Standards for the
Flammability of Children’s Sleepwear

55. www.intertek.com55
General Criteria:
a)Average char length
per sample shall not
exceed 7.0”
a)No individual specimen
shall have a char
length of 10.0”
Flammability Test Apparatus
for Children’s Sleepwear
16 CFR 1615/1616

56. www.intertek.com56
1 2
16 CFR 1615/1616

57. www.intertek.com57
3 4
16 CFR 1615/1616

58. www.intertek.com58
5
16 CFR 1615/1616

59. www.intertek.com59
Fabric Weight Load
g / m2 oz / yd2 gram pound
Less than
101
Less than 3 54.4 0.12
101 to 207
3 to Less
than 6
113.4 0.25
207 to 338 6 to 10 226.8 0.50
Greater than
338
Greater
than 10
340.2 0.75
To Determine Char Length of Specimen
16 CFR 1615/1616

60. www.intertek.com60
16 CFR 1615/1616 – Issues That Come Up Regarding The
Regulation
• Stages of testing (FPU, prototype seams and
trims, GPU) – from the perspective of the test
applicant
• Interpretation of product as children’s
sleepwear

61. www.intertek.com61
16 CFR 1615/1616 – Issues That Come Up Regarding The
Regulation
CPSC Response: If the baby wears pajama, and
is placed into the bag, then the bag itself is not
considered children’s sleepwear. In this case, the
bag must comply with Part 1610. If the baby is
put directly into the bag wearing just a diaper,
then the bag is considered sleepwear and must
comply with Part 1615. It should be made clear
on any marketing or package materials how the
manufacturer expects the garment to be used.

62. www.intertek.com62
16 CFR 1615/1616 – Issues That Come Up Regarding The
Regulation
CPSC Response: We would not
consider this to be children’s
sleepwear. We wonder whether or not
the orange/red item would be
comfortable for sleeping since it has
a hood (with eyes & nose) and the bulky
pieces at the two upper corners. We
have seen similar items and they were
used as towels, rather than blankets.

63. www.intertek.com63
16 CFR 1615/1616 – Issues That Come Up Regarding The
Regulation
CPSC has recalled this
product for failing to meet
the Standard for the
Flammability of Children's
Sleepwear, and pose a risk
of burn injury to children
due to the possible ignition
of the garment.

64. www.intertek.com64
Drawstring: A non-retractable cord, ribbon or tape of
any material to pull together parts of upper outerwear
to provide for closure.
Drawstrings – ASTM F1816-97

65. www.intertek.com65
Drawstrings – Issues That Come Up Regarding The
Regulation
New York
Law
Wisconsin
Law
CPSC /
ASTM
What types
of apparel
are affected?
All children’s
clothing
All children’s
clothing
Upper
outerwear
What sizes? 2T-12 0-16 2T-12
What are the
requirements?
No hood /
neck
drawstrings
are allowed
No hood /
neck
drawstrings
are allowed
Drawstrings
should not be
used in the head
/ neck area
 State laws – NY and WI laws on drawstrings
Hood and Neck Drawstring Requirements

66. www.intertek.com66
Drawstrings – Issues That Come Up Regarding The
Regulation
Waist or Bottom Drawstring Requirements
State laws: NY and WI laws on drawstrings
New York
Law
Wisconsin
Law
CPSC /
ASTM
What types
of apparel
are affected?
All children’s clothing Children’s upper outerwear Children’s upper outerwear
What sizes? 2T-16 0-16 2T-16
What are the
requirements?
No more than 3 inches of
the drawstring shall be
outside of the drawstring
channel when the garment
is extended to its fullest
width
The drawstring shall be
attached to the garment at
its midpoint.
Toggles, knots or other
attachments shall not be
used at the ends of the
drawstrings
No more than 3 inches of
the drawstring shall be
outside of the drawstring
channel when the
garment is extended to its
fullest width.
Toggles, knots or other
attachments shall not be
used at the ends of the
drawstring.
The drawstring shall be
sewn at the midpoint of
the channel so that it
cannot be completely
pulled out of the channel.
No more than 3 inches of the
drawstring shall be outside of the
drawstring channel when the garment is
extended to its fullest width.
Toggles, knots or other attachments
shall not be used at the ends of the
drawstring.
The drawstring shall be sewn at the
midpoint of the channel so that it cannot
be pulled long enough to catch on
something.

67. www.intertek.com67
Drawstrings – Issues That Come Up Regarding The
Regulation
Are ties considered drawstrings?
Yes – CPSC considers ties as drawstrings. The
standard defines a "drawstring" as a "non-
retractable cord, ribbon, or tape of any material to
pull together parts of upper outerwear to provide
for closure." The standard's "drawstring" definition
is not limited to cords, ribbons, or tapes that pass
through a channel, and the definition does not
exclude ties.

68. www.intertek.com68
Drawstrings – Issues That Come Up Regarding The
Regulation
Are belts considered drawstrings?
No. Belts are not included in the voluntary standard or the
Commission's 15(j) rule for drawstrings, and therefore, they
are not listed as an identified substantial product hazard in all
cases. However, should the Commission determine that
certain belt configurations or styles in children's upper
outerwear present a substantial product hazard under section
15(a)(2) of the Consumer Product Safety Act (CPSA), it would
seek corrective action under section 15 of the CPSA or
section 15 of the Federal Hazardous Substances Act (FHSA).

69. www.intertek.com69
Drawstrings – Issues That Come Up Regarding The
Regulation
What if the garment is not sized using a
numerical system?
To facilitate determining which garments that are
sized under a sizing system other than the numerical
system (2T to 16) are equivalent to sizes 2T to 16,
the rule provides that:
Garments in girls' size Large (L) and boys' size
Large (L) are equivalent to size 12.
 Garments in girls' size Extra-Large (XL) and boys'
size Extra-Large (XL) are equivalent to size 16.

70. www.intertek.com70
Drawstrings – Issues That Come Up Regarding The
Regulation
Garments in girls' and boys' letter or word sizes
smaller than sizes Large (L) or Extra-Large (XL), as
applicable, are equivalent to correspondingly smaller
numerical sizes.
The fact that a garment is labeled as being larger
than size Large (L) or size Extra-Large (XL), as
applicable, does not necessarily mean that the item
is not equivalent to a size in the range of 2T to 12, or
in the range of 2T to 16. The Commission may use
any other evidence that would tend to show that a
garment is a size that is equivalent to sizes 2T to
16.

71. www.intertek.com71
Valued Quality. Delivered.

72. Hardy Poole
Vice President, Regulatory and Technical Affairs
National Council of Textile Organizations
at the
Henry M. Jackson Federal Building
Seattle, Washington
September 18, 2013
CPSC Safety Academy

73. • NCTO was formed in 2004 from the members of the
American Textile Manufacturers Institute and the
American Yarn Spinners Association.
• NCTO was an entirely new association with a structure
designed to accommodate all sectors of the industry.
• In 2013, the National Textile Association and the American
Manufacturers Trade Action Coalition merged with NCTO,
creating a single voice for the U.S. textile industry.
• 150 member companies in 28 states
National Council of Textile
Organizations

74. Manufacturing members are companies that
produce:
- Fibers
- Yarns
- Fabrics
- Dye/finish/print substrates
- Textile end-items
Structure

75. •Goal of Consumers
•Goal of Government
•Goal of the Textile Industry
Safe Consumer Products

76. Regulated Textile Products:
• General Wearing Apparel
• Children’s Sleepwear
• Carpets & Rugs
• Mattresses & Mattress Pads
(smoldering ignition)
• Mattress Sets (open flame)
Flammable Fabrics Act

77. • 16 CFR 1610 or 45 Degree Angle Test
• Effective since 1953 when FFA became Law
• Agency Reviews Standard Periodically
Last Review in 2008
• Same or Similar to Wearing Apparel Standards
used by Other Developed Nations
General Wearing Apparel Standard

78. • Two Standards:
 16 CFR 1615 (Sizes 0-6x)
 16 CFR 1616 (Sizes 7-14)
• TRIS – Topical Flame Retardant Treatment
• 1977 Ban on TRIS (Health Effects)
• Amended 0-6x Standard (16 CFR 1615)
Basically Same as 16 CFR 1616
Children’s Sleepwear Standards

79. • Important chemical used in small amounts in
textile dyes and finishes
• Animal testing in the 1980’s suggested it might be
harmful in large doses
• The textile industry along with the fiber apparel,
retail and formaldehyde industries supported
animal research to answer the question about
human health effects
Formaldehyde -- HCHO

80. • CPSC’s Director of Health Sciences
participated in:
• Developing the test protocol,
• Managing the animal testing,
• Reviewing data and
• Forming conclusions based on the
research
Formaldehyde -- HCHO

81. • Identified potential problem
• Assembled best minds available to define and
address the issue
• Worked cooperatively in designing and conducting
research
• Evaluated test data together
• Reached same conclusion – HCHO in small
amounts does not pose a significant risk to humans
HCHO -- Model of Cooperation

82. • TB 117 has been in place since 1970’s
• California was first and only state to have a
mandatory furniture flammability standard
• Governor Jerry Brown directed the state’s
consumer agency to change the standard
• New standard should eliminate or lessen the
need for flame retardant chemicals in furniture
California TB 117-2013

83. • Regulatory body under the California
Department of Consumer Affairs
• Mission: to protect and serve consumers while
ensuring a competent and fair marketplace
• Licenses and inspects businesses that
manufacture and sell products under its
authority in California
Bureau of Electrical Appliance Repair, Home
Furnishings and Thermal Insulation

84. • TB 117-2013 -- proposed a smolder rather
than open-flame standard
• Agree that addressing the smolder
component initially is correct.
• Supportive of TB 117-2013 proposal being
based on ASTM E1353-08a.
• ASTM E1353-08a is a proven standard that
has been in place for over three decades.
Proposed TB 117-2013

85. • Standard was proposed and hearing
completed last spring
• Precision and Bias Study near completion
• Final 15-day comment period closed on
September 3
• Final rule is expected soon
Proposed TB 117-2013

86. • Fabrics tested by TB 117-2013 or a similar
method* can be sold after the effective date
without additional testing
• New fabrics manufactured on/after the effective
date are expected to comply with the TB 117-
2013 final rule
_______________________________
* ASTM E1353-08a, NFPA 260 or UFAC
Effective Date of TB 117-2013

87. • Consumers, Government and the Textile
Industry have the same goals – Safe Products
• Working together, we are able to address
consumer product safety issues and address
those problems that are deemed significant
• After all, we want the same thing – safe
consumer products
Summary

88. What is the General Concept Behind CPSC’s
Pilot System for Risk Assessment?
Integrates available risk information to model and
support Commission enforcement strategy involving
product hazards at importation.
Potential sources of risk data include:
–shipment (CBP)
–case history (CPSC & CBP)
–screening history (CPSC)
–injury and death (CPSC)
–commercial information (Third Party)
Seattle Safety Academy 2013

89. What Improvements are Expected from CPSC’s
Production System for Risk Assessment?
Seattle Safety Academy 2013
• Higher rate of product hazard detection at import.
• Higher volume of shipments sampled and detained
annually at import.
• Fewer shipments unnecessarily stopped
• Reduced recalls of dangerous products in commerce.
– In FY 2012, 3.6 million non-firework products were
stopped from entering commerce. The number of
shipments examined grew 190% over FY 2007 levels while
increasing the violation rate by 25% over the same period.

90. What are the Societal Benefits to CPSC’s
Production System for Risk Assessment?
• Save Lives and Prevent Injuries
• Facilitate Legitimate Trade
• Minimize Costs for the Trade,
Government Agencies and U.S. Customs
• Proactively Monitor Compliance
Seattle Safety Academy 2013

91. Other Questions
• If I am an importer who brings in product that
does not meet mandatory requirements, am I
required to file a report with the Commission?
• What is the agency policy with respect to
enforcement of certificates at ports of entry?
Seattle Safety Academy 2013