what you need to know about us testing and certification - apparel sourcing show 2012

U.S. Consumer Product Safety

Commission

What You Need to Know About U.S. Testing and Certification

Allyson Tenney

Regulatory Enforcement Division

Guatemala City, May 2012

These comments are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily reflect the views of, the Commission.

Outline

• Introduction

• What is CPSC?

• What standards and requirements apply to

apparel and clothing?

– Flammable Fabrics Act (FFA)

– CPSIA

• Why must regulations be met?

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• CPSC is an independent federal (United States

government) regulatory agency created to protect

the American public from unreasonable risks of

injury associated with consumer products.

• Commissioners are appointed by the President for

multiyear terms with confirmation by the Senate.

U.S. Consumer Product Safety

Commission (CPSC)

CPSC Jurisdiction

• Jurisdiction over thousands of different consumer products under the Consumer Product Safety Act

• Excludes some products covered by other federal agencies, such as:

– cars and related equipment (NHTSA);

– food, drugs, medical devices, cosmetics (FDA);

– firearms (BATF);

– airplanes (FAA);

– boats (Coast Guard); and

– pesticides (EPA). 4

Product Safety Concerns

• Products 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, such as strangulation and

entrapment hazards from drawstrings on children’s

upper outerwear;

• Products that contain a defect which could create a

“substantial product hazard”; and

• Products that create an “unreasonable risk” of serious

injury or death.

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Jurisdictional Authority

• Jurisdictional Authority in 7 Acts – Consumer Product Safety Act (CPSA)

– Federal Hazardous Substances Act (FHSA)

– Poison Prevention Packaging Act (PPPA)

– Refrigerator Safety Act (RSA)

– Virginia Graeme Baker Pool & Spa Safety Act

(VGBA)

– Children’s Gasoline Burn Prevention Act

(CGBPA)

– Flammable Fabrics Act (FFA)

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Flammable Fabrics Act

(FFA)

• Regulated Products

– Clothing Textiles, 16 CFR Part 1610

– Vinyl Plastic Film, 16 CFR Part 1611

– Children’s Sleepwear, 16 CFR Parts

1615/1616

– Carpets and Rugs, 16 CFR Parts

1630/1631

– Mattresses and Mattress Pads, 16 CFR

Part 1632

– Mattress Sets, 16 CFR Part 1633 7

16 CFR Part 1610-Standard for the

Flammability of Clothing Textiles

• 16 CFR Part 1610 – commonly known as the General Wearing Apparel Standard

• Enacted in the 1950s

• Keeps the most dangerously flammable textile products and garments out of the marketplace

• The Standard applies to all adult and children’s wearing apparel, except children’s sleepwear, which must meet a more stringent standard.

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16 CFR Part 1610

• The Standard provides testing procedures and determines the relative flammability of textiles used in apparel using three classes of flammability.

• A 16 mm (5/8 in) flame impinges on a specimen mounted at a 45 degree angle for 1 second. The specimen is allowed to burn its full length or until the stop thread is broken (burn time is recorded).

• The burn time of several specimens is averaged and a Class (Class 1, 2, or 3) designation is made based on the average burn time (speed of burning) and surface characteristics of the sample.

• Class 3 textiles are considered dangerously flammable and are not suitable for use in clothing due to their rapid and intense burning.

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General Overview of Test

Procedures: Part 1610

Step 1 – Testing in the original state

• Determine fabric type:

– plain surface textile fabric

– raised surface textile fabric

• Specimen size: 50mm x 150mm

(2 inches x 6 inches)

• Preliminary trials: to determine the

fastest burning area and direction of the

fabric

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Procedures: Preliminary Trials

• Plain surface fabrics:

i) Cut two specimens—long dimension of one

specimen is in the vertical (warp) direction of the

fabric, and one is in the horizontal (filling) direction.

ii) Test to determine if there is a difference in burn

time.

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Procedures: Preliminary Trials

• Raised surface fabrics: – i) Prepare the specimen so that the

direction of the lay is parallel to the long dimension of the specimen.

– ii) Determine the lay of the fabric pile by:

a) tactile and visual observation, or

b) preliminary tests to determine the fastest burning direction.

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Procedures: Cutting

Specimens

• After preliminary trials,

cut five specimens with

the long dimension in

the direction with the

fastest burn time, as

determined by the

preliminary testing.

13


Procedures: Mounting

Specimens

Label specimen holder. Place back plate of specimen holder

on brushing device carriage.

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Procedures: Mounting Specimens

Position specimen on back plate. Secure specimen in holder.

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Tape may be used to

secure specimen further.

Specimens in specimen holding rack.

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Procedures: Mounting

Specimens • (For raised surface

fabrics)

Use a fingernail to

determine the lay of the

pile, place the specimen

on the holder (the lay of

the pile is directed away

from the closed end of

the holder), and lower the

brush onto specimen.

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• (For raised surface fabrics)

Brush specimen to raise fibers, and place brushed specimen in

specimen holding rack.

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Procedures: Conditioning Specimens

Conditioning Requirements:

Oven Temperature 105 ± 3 °C (221 ± 5 °F), Duration 30 ± 2 minutes

Place specimens in

oven.

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Procedures: Conditioning

Specimens

• Place specimens over a bed of anhydrous silica gel

desiccant in a desiccator until cool, but not less than 15

minutes.

Place specimens in a desiccator to cool.

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Procedures: Testing

16 mm (5/8 in)

Light Burner Check Flame Length 16mm (5/8 in).

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Procedures: Testing

• Place specimen on the specimen rack, which allows the specimen to be held at a 45-degree angle, and adjust the specimen rack so that the indicator finger just touches the surface of the specimen.

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Procedures: Testing

Pull stop thread through guides. Attach stop weight (30.0 0.5g).

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Procedures: Testing

• Impinge flame (1 second). • Test 5 specimens. • Determine the average

burn time. • Determine burn type and

record proper test result code (raised fiber).

• Determine the next step in

testing, using test sequence in Standard.

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Sample Classification

Summary of Sample Classifications

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)

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Procedures Refurbishment

• Only Class 1 or 2 .

• Dry clean all samples before laundering.

• Use ballast composed of 80% wool and 20% cotton

fabrics.

Requirements for Dry Cleaning

Solvent Perchloroethylene, Commercial Grade

Detergent Class Cationic

Cleaning Time 10-15 minutes

Extraction Time 3 minutes

Drying Temperature 60-66 °C (140-150 °F)

Drying Time 18-20 minutes

Cool Down/Deodorization Time

5 minutes

Load 80% of machine capacity

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General Overview of Test Procedures:

Laundering

• After dry cleaning, perform one laundering of the sample

following AATCC Test Method 124.

Washing and Drying Conditions

Washing Cycle Normal/Cotton Sturdy

Wash Temperature 49±3°C (120±5°F)

Rinse Temperature < 29°C (85°F)

Drying Procedure Tumble, Permanent Press

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 8 lbs (3.63 kg)

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

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Procedures: Testing (Step 2)

• Once the refurbishment process is completed,

repeat the entire test procedure (including

preliminary tests) with the refurbished specimens.

• The test procedure is the same as for Step 1 –

testing in the original state.

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Final Sample Classification

Summary of Sample Classifications

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)

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General Overview of

Part 1610: Results

• Class 1 – fabrics have no unusual burning characteristics and are acceptable for use in clothing

• Class 2 – intermediate flammability- use with caution

• Class 3 – fabrics are dangerously flammable and CANNOT be used in wearing apparel

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Procedures: Specific Exemptions

1. Plain surface fabrics ≥88.2 g/m2 (2.6 oz/yd2),

regardless of fiber content

2. Plain and raised surface fabrics made of:

acrylic,

modacrylic,

nylon,

olefin,

polyester,

wool,

or any combination of these fibers, regardless of weight.

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Common Noncomplying

Products (Part 1610)

• Sheer 100% rayon skirts and scarves

• Sheer 100% silk scarves

• 100% rayon chenille sweaters

• Rayon/nylon chenille and long hair

sweaters

• Polyester/cotton and 100% cotton fleece

garments

• 100% cotton terry cloth robes

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16 CFR Parts 1615 & 1616- Standards

For The Flammability of Children’s

Sleepwear • The children’s sleepwear standards, 16 CFR Parts 1615

and 1616) were developed in the early 1970s to address

the ignition of children’s sleepwear, such as nightgowns,

pajamas, and robes.

• All fabrics and garments must self-extinguish (not continue

to burn) when removed from a small, open-flame ignition

source.

• The standards are designed to protect children from small

open-flame sources, such as matches/lighters, candles,

fireplace embers, stoves, and space heaters.

• The standards are not intended to protect children from

large fires or fires started by flammable liquids, such as

gasoline.

Children’s Sleepwear Standards

16 CFR Parts 1615 & 1616

• Children’s sleepwear means 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.

• Nightgowns, pajamas, robes, or similar or

related items (such as loungewear) are

included.

• Exceptions are:

1. diapers and underwear;

2. infant garments (sizes 9 months or younger);

3. tight-fitting garments (as defined in the

Standards). 1615/16: Children’s Sleepwear

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16 CFR Parts 1615 & 1616

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

1615/16: Children’s Sleepwear 35


16 CFR Parts 1615 & 1616

Tight-Fitting (exempt)

• Tight-fitting garments (defined by the

Standards) are exempt from testing to the

sleepwear requirements.

• Must meet specific maximum dimensions.

• Must comply with 16 CFR Part 1610.

• Must meet labeling requirements.


Tight-Fitting Sleepwear

• The sizes of chest, waist, seat, upper arm, thigh,

wrist, and ankle do not exceed the maximum

dimension specified in the Standards for different

sizes of garments.

• Has no item of fabric, ornamentation, or trim

extend more than 6 mm (1/4’’) from the point of

attachment to the outer surface of the garment


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Tight-Fitting Labeling

• A mandatory labeling requirement was

developed for tight-fitting garments in

2000.

• Permanent neck label that reads:

WEAR SNUG-FITTING

NOT FLAME RESISTANT.

• A hangtag that gives point-of-purchase

safety information (yellow tag) or a

smaller version of the hang-tag can be

used on prepackaged garments.

Tight-Fitting Garment Measurement Illustration (See the Standards for measurement details and requirements)

Chest Measurement Upper Arm Measurement



Wrist Measurement Waist Measurement



Waist Measurement

Seat Measurement



Thigh Measurement Ankle Measurement



16 CFR Parts 1615 & 1616

• Children’s sleepwear (that is not tight-

fitting) must pass the flammability

requirements and must be flame

resistant and not continue to burn when

removed from a small flame.

• The fabric and garments must pass

certain flammability tests.

• This includes nightgowns, pajamas,

bathrobes, and loungewear (loungewear

policy).

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General Overview of Test Method

• Tests of fabric, seams, and trim testing

• 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)

• Production testing and recordkeeping

requirements

• Tested samples required to be retained


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



Determine Fabric Weight

Measure fabric weight before testing

(Conditioned for at least 8 h at 21 1.1 C

and 65 ±2% relative humidity)

Different loads to be used

for different fabric weights

1615/16: Children’s Sleepwear

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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.



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.



Conditioning Specimens

Conditioning Requirements:

Oven Temperature

105 ± 3°C (221 ± 5 °F)

Duration 30 ± 2 minutes

Place the specimen in oven



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.



Testing

Light the burner and check that the flame height is

3.8 cm (1.5 inches).



Testing

• Remove the specimen from the desiccator.

• Suspend the specimen vertically in the test

cabinet.



Testing

Impinge the burner flame on the bottom edge of the

specimen for 3.0 0.2 seconds.



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.



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.



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.



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

25.4cm (10.0 inches) (full-specimen burn).



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

CPSIA Requirements:

Adult Clothing

• Certification by manufacturer or importer to

meet requirements for all apparel (February

2010)

• General Certificate of Conformity (GCC)

required

• Under 16 CFR Part 1610: GCC required for

specific exemptions

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CPSIA Requirements-Children’s

Clothing and Sleepwear “Children’s product” – Congress defined

children’s product to mean a product designed or intended primarily for children 12 years of age or younger.

• Certification based on testing performed by an accredited third party laboratory recognized by the CPSC

• Children’s Product Certificate (CPC) required

• Lead content and surface coating limits must be met for certain components of textile products.

– For example, buttons, snaps, grommets, zippers, heat transfers, and screen prints

• Tracking labels required

• Sleepwear (childcare article) for children under 3 subject to phthalate requirements

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Standard Prohibiting Lead-Containing

Paint in Children’s Products

• Lead poisoning in children is associated with behavioral

problems, learning disabilities, and growth retardation.

• 16 CFR Part 1303 protects consumers, especially

children, from being poisoned from excessive lead in

surface coatings on certain products. Includes surface

coatings on toys or other articles intended for use by

children, including clothing accessories.

• The ban covers paint or any other similar surface coating

that contains more than 0.009% lead (lead containing

paint).

• The CPSIA reduced this level over time

• Requires third party testing and certification

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CPSIA Lead Content Limits

• Section 101 limits the amount of lead content in all

products for children 12 years of age and younger:

600 ppm (February 10, 2009) to

300 ppm (August 14, 2009) to

100 ppm (August 14, 2011)

Lead Content in Children’s

Products

• February 6, 2009, CPSC staff issued an

enforcement policy on lead that is

significant to the textile industry.

• 16 CFR 1500.91 lists determinations

made by CPSC staff where certain

materials will not exceed lead limits;

includes dyed or undyed textiles and

nonmetallic thread and trim used in

children’s apparel and fabric products.

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Requirements for Tracking Labels

on Children’s Products and Packaging

• Require manufacturers of children’s products, “to the

extent practicable,” to place distinguishing marks on

a product and its packaging that would enable the

purchaser to ascertain the source, date, and cohort

(including the batch, run number, or other identifying

characteristic) of production of the product by

reference to those marks.

• Effective Date: August 14, 2009

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Drawstrings on Children’s

Clothing

In 1996 CPSC issued guidelines later adopted

by ASTM in 1997 (ASTM F1816-97)

May 2006 letter to industry

Applies to upper outwear, jackets, and

sweatshirts

Substantial product hazard

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 65

Common Problems Found on

Children’s Clothing

• Zipper pulls - Some zipper pulls and

decorative snaps contain high levels of lead.

• Painted snaps

• Drawstrings - Drawstrings on children’s

clothing present a strangulation hazard

(ASTM F1816-97, Standard Safety

Specification for Drawstrings on Children’s

Upper Outwear)

• CPSC continues to recall those products.

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Violations/Prohibited Acts

• The Consumer Product Safety Act (CPSA), Flammable Fabrics Act (FFA), and the Federal Hazardous Substances Act (FHSA) 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; and

• fail to include tracking labels when appropriate.

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Corrective Actions

• Section 15(b) of the Consumer Product Safety Act requires manufacturers, distributors, and retailers to report to CPSC “immediately” if they obtain information raising safety concerns about products they make or sell.

• The Commission may order a manufacturer, distributor or retailer to: – Recall, notify the public of the problem, and/or to take

corrective action, and/or

– Repair, replace the product at no charge, or refund the purchase price.

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Penalties

• Any person who knowingly commits a violation is subject to a civil penalty of $100,000 for each violation (CPSIA).

• The maximum civil penalty for a related series of violations is capped at $15.15 million (January 2012).

• Criminal penalties (including imprisonment) are also possible for willful violations.

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Refusal of Admission

• Under section 17(a), a consumer product must be refused admission to the U.S. if it:

– fails to comply with an applicable consumer product safety rule (CPSA standard or ban)

– is not accompanied by a required certificate or tracking label or is accompanied by a false certificate

– is or has been determined to be imminently hazardous in a section 12 proceeding

– has a defect that constitutes a substantial product hazard

– was imported by a person not in compliance with inspection and recordkeeping requirements.

Summary-Clothing • Adult clothing:

– 16 CFR Part 1610 (Flammability)

– GCC Required

• Children’s Clothing:

– 16 CFR Part 1610 (Flammability)

– CPC Required, Third Party Testing

– Lead Content

– Lead Surface Coating

– Tracking Labels

– Drawstring Requirements 71

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)

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For Further Information:

Allyson Tenney

Lead Compliance Officer

Office of Compliance and Field

Operations

301-504-7567

[email protected]

U.S. Consumer Product Safety Commission

4330 East-West Highway

Bethesda, MD USA 20814-4408

www.cpsc.gov

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