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
2013 Flammability Requirements for Apparel and Sleepwear & Drawstrings in Children's Upper Outerwear, 2013 Safety Academy
May 15, 2015
2013 Flammability Requirements for Apparel and Sleepwear & Drawstrings in Children's Upper Outerwear, 2013 Safety Academy
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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, DRAWSTRINGSSEPTEMBER 16, 2013
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
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
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
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
All Regulated LOA’sFY08-FY13
0
500
1000
1500
2000
2500
9151044
19261677
2316
1685
FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6
All Flammable Fabrics Act LOA’sFY08-FY13
0
20
40
60
80
100
120
140
160
49
7563
71
152
97
FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6
Flammable Fabrics Act LOA’sFY08-FY13 by Product Type
0
10
20
30
40
50
60
70
80
90
47
1 1
32 36
7
52
83
48
158
60
81
11
32
62
3
FY08 FY09 FY10 FY11 FY12 FY13 as of 9/6
Mattress Data Sleepwear Data All other apparel
FY13 - Recalls, Stop Sales and Seizuresas of 9/6
Series1
0 200 400 600 800 1000 1200
1127
793
21Recalls
Seizures
Stop Sales
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 CampbellCombustion and Fire Sciences
DivisionEngineering Sciences Directorate
U.S. Consumer Product Safety Commission
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)
16 CFR PART 1610
Standard for the Flammability of Clothing Textiles
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
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.
§1610.1(c): Exceptions
• Interlining fabrics
• Most hats, gloves, and footwearExamples 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
§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.
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
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
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)
16 CFR Part 1610: Classifications
CodeDescription 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
_._SFBBTime (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.
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
16 CFR PARTS 1615 AND 1616
Standards for the Flammability of Children’s Sleepwear
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
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
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.
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.
16 CFR Parts 1615 & 1616: Requirements
• Multiple stages of testing are required, following prescriptive sampling plans
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
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
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
FFA Guidance
• http://www.cpsc.gov/en/Regulations-Laws--Standards/Regulations-Mandatory-Standards--Bans/Regulated-Products/– Search by product (use
wearing apparel and sleepwear)
– http://www.cpsc.gov/businfo/loungewear.pdf
ASTM F1816-97
Drawstrings on Children’s Clothing
Drawstring RequirementsChildren’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 drawstringsthat do not meet specified criteria
• Dresses are not upper outerwear• Belts are not drawstrings
THE CONSUMER PRODUCT SAFETY IMPROVEMENT ACT
Textiles and Related Products
What’s Required: Clothing
• Adult clothing:
– 16 CFR Part 1610 (Flammability)
– GCC Required, including for products that are exempt from testing
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
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)
Resource: Small Business Ombudsman
http://www.cpsc.gov/en/Business--Manufacturing/Small-Business-Resources/
Resource: Searchable List of Laboratories
http://www.cpsc.gov/cgi-bin/labsearch/
For Further Information:
Jacqueline CampbellTextile Technologist
Office of Hazard Identification and Reduction301-987-2024
Allyson TenneyLead Compliance Officer
Office of Compliance and Field Operations301-504-7567
www.cpsc.gov
www.intertek.com41
Seemanta MitraSenior Director – North America Softlines
CPSC SEATTLE SAFETY ACADEMY
FLAMMABLE FABRICS, SLEEPWEAR, DRAWSTRINGS
SEPTEMBER 18, 2013
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
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
www.intertek.com44
16 CFR 1120: Substantial Product Hazard List
Drawstrings
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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
www.intertek.com46
Overview of 16 CFR 1610 – Standard for the Flammability of Clothing Textiles
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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
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16 CFR 1610 – Issues That Come Up Regarding The Regulation
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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
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 intentionallyraised edge. Overall comment: Plain surface
www.intertek.com51
16 CFR 1610 – Lab Data Sheet
Surface type: Plain Raised
Tested side: Face Back
Original StateAfter 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: ________________________________________________
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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 surfaceOnly 1 burn time & it is <4s with SFBB; Average burn time <4s with 2 or more SFBB.
Explanation of Flammability Results:
For plain surface fabricDNI Did not igniteIBE 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 fabricSF 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 SFBBTime in seconds, surface flash base burn. Base starts burning at points other than that point of impingement.
0.0 SFBB poiTime in seconds, surface flash base burn starting at the point of impingement.
* 0.0 SFBB poiTime 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.
www.intertek.com53
Children’s sleepwear & non-sleepwear flammability regulation requirement:
Product
Requirements
16 CFR1615 / 1616
16 CFR 1610
Tight fitting Specs
Children’s Sleepwear
Loose fitting *
Tight fitting * *
Innerwear, Long Underwear, Daywear
*
Flammability Regulation
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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
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8General Criteria:
a)Average char length per sample shall not exceed 7.0”
b)No individual specimen shall have a char length of 10.0”
Flammability Test Apparatus for Children’s Sleepwear
16 CFR 1615/1616
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1 2
16 CFR 1615/1616
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3 4
16 CFR 1615/1616
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5
16 CFR 1615/1616
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Fabric Weight Load
g / m2 oz / yd2 gram pound
Less than 101 Less than 3 54.4 0.12
101 to 2073 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
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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
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.
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.
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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.
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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
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Drawstrings – Issues That Come Up Regarding The Regulation
New YorkLaw
WisconsinLaw
CPSC /ASTM
What typesof apparel
are affected?
All children’s clothing
All children’s clothing
Upperouterwear
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
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
WisconsinLaw
CPSC /ASTM
What typesof apparel
are affected?
All children’s clothing Children’s upper outerwear Children’s upper outerwear
What sizes? 2T-16 0-16 2T-16What 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.
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.
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).
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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.
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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.
www.intertek.com71
Valued Quality. Delivered.
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
• 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
Manufacturing members are companies that produce:
- Fibers- Yarns- Fabrics- Dye/finish/print substrates- Textile end-items
Structure
•Goal of Consumers
•Goal of Government
•Goal of the Textile Industry
Safe Consumer Products
Regulated Textile Products:• General Wearing Apparel• Children’s Sleepwear• Carpets & Rugs• Mattresses & Mattress Pads
(smoldering ignition)• Mattress Sets (open flame)
Flammable Fabrics Act
• 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
• 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
• 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
• 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
• 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
• 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
• 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
• 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
• 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
• 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
• 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
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
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.
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
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
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