PRODUCT SAFETY REQUIREMENTS

Transcription

1 PRODUCT SAFETY REQUIREMENTS 1. CHILDREN PRODUCT SAFETY Attachment Strength Stone Washing Small Parts Faux Fur (Pile) Trimming Sharp Points and Edges Pompoms Hook and Loop Fastenings Straps, Cords and Elastics Magnets Children s Denim Products with Assorted Finishes Children s Apparel Safety Updated: April, 2015

2 1. Children Product Safety The safety requirements apply to apparel/accessories intended for children under 14 years old are listed below. 1.1 Attachment Strength All Decorations, functional small parts and or trim components in the product included, but not limited to buttons, bows, beads, zipper head, rivet and snaps should test for the attachment strength and withstand a torque force of 4 in-lbs and tension force of 15 lbs for 10 seconds. The detached part from products intended for children under 6 years of age will subject to test for the small part requirement. Some trims or components included but not limited to beads, sequins and rhinestones, may be of dimensions that can not fitted in conventional test equipment or are too delicate and known not to meet the requirement of Minimum. 15 lbs. These kinds of trims are not permitted to present in the products intended for children under 6 years of ages. 1.2 Stone Washing Due to the danger and hazard of babies/kids eating or choking any loose pumice stones that may have been left in pockets or turn ups of garments. We aim to prevent choking hazard to babies or kids pursuant to the General Safety Regulation of Consumer Product in countries, for example but not limited to, Alternatives Rubber Balls ( Ø 32mm) and enzyme wash can be used to achieve similar Stone Wash effect. Other alternatives, e.g. stones, balls or else, must be >Ø 32mm. Exemption When stonewashing aesthetics cannot be duplicated by alternate methods, then it is required to approve by Vice President, Technical Services, TEO USA Consumer Product Safety Commission 16 CFR 1501 Europe European Community - General Product Safety Directive This requirement does not apply to adult products and is aim for products intended for children under 6 years of ages. 2

3 1.3 Small Parts A small part is any object that fits completely into a specially designed test cylinder 2.25 inches long by 1.25 inches wide that approximates the size of the fully expanded throat of a child under three years old (Figure 1). Figure 1: Small parts Cylinder If a small part, (1) A whole article, (2) A separate part of an accessories or article or (3) A piece of an accessories article that breaks off during attachment strength testing, fits completely into the cylinder, and intended for use by children under three, the accessories or article is banned due to ingestion or choking hazard. 1.4 Faux Fur (Pile) Trimming Faux Fur may be inappropriate in certain applications of accessories for toddlers and infants. This kind of trim can be used if the pile height fulfilled the following criteria, For infant products size up to 24 months, the pile of fur must not exceed 1½ inches in length. For children 2-6 years old, the pile must not exceed 2 inches in length. For children 7 years and older, the pile can exceed 2 inches in length. 3

4 1.5 Sharp Points and Edges Accessories or articles intended for use by children under 8 years of age are subject to sharp points and edges requirement before or after use and abuse testing, or both, as specified in 16 CFR part / 16 CFR / ASTM 963. An illustration of a sharp point and sharp edge tester is shown in figures below. Figure 2: Sharp point tester Figure 3: Sharp edge tester No sharp points or edges are allowed exist on any Kate Spade & Company product, packaging or hardware intended for used by children under 8 years of ages before or after testing. 4

5 1.6 Pompoms Pompoms detached during the test specified in ASTM F963 and pass entirely through the 1.75 in. (44.5 mm) test fixture (see Fig. 4) under their own weight, must not used for Kate Spade & Company products for toddlers or infants under 36 months of age. Figure 4: Test fixture for small balls 1.7 Hook and Loop Fastenings Hook and loop fastening tape should have rounded edges to eliminate risk of laceration. 1.8 Straps, Cords and Elastics Strings, cords, necklaces are a strangulation hazard. Usually, the string, cord, or necklace caught on some product such as a cot or playpen. In other cases, the string or cord became tightly wrapped or twisted around the child s neck while playing. Straps, ties, cords and elastics included with or attached to articles intended for children less than 24 months of age shall be less than 12 in. (300 mm) long when measured to the maximum length in a free state and under a load of 5 lb (2.25 kg). If cords, straps or elastics or multiple cords, straps or elastics can tangle or form a loop in connection with any part of the article, including beads or other attachments on the ends of cords, straps or elastics, the loop shall not permit the passage of 5

6 the head probe (Fig. 6) when tested in accordance with ASTM F963. Specifically, the loop shall not allow the head probe to be inserted so deep that it admits the base of the probe. The configuration of the loop shall be determined by using all components that makeup the loop. Drawstrings are not permitted on hats or gloves for infants of 24 months or below but they may be used for older children when the ends are in loop configuration. Figure 5: Head probe for cords Cords, Straps, and Elastics Containing a Breakaway Feature Cords, straps, and elastics on accessories that have loops that admit the base of the head probe for children less than 24 months of age shall contain a functional breakaway feature that prevents entanglement by releasing at a force less than 5.0 lbf (22.2 N) when tested in accordance with ASTM F963. The free length of the individual released cord, strap, or elastic should not exceed a maximum length of 12 in. (300 mm). The breakaway feature shall be capable of being reattached without altering the characteristics of the attachment. 6

7 1.9 Magnets Loose magnet or loose magnet component which fits entirely within the volume of the small part cylinder are prohibited to present in Kate Spade & Company product intended for children 6 years and below. Product intended for children up to 14 years of age containing strong magnets, which has a magnetic flux index greater than 50, shall bear the warnings if the product, before or after abuse tests, librates a magnet of magnetic component that fits entirely within the volume or envelop of any test fixture shown in Figure 6. The labeling shall consist of the signal word WARNING and contain, at a minimum, the following text or equivalent text which clearly conveys the same warning: This product contains (a) small magnet(s). Swallowed magnets can stick together across intestines causing serious infections and death. Seek immediate medical attention if magnet(s) are swallowed or inhaled. Figure 6: Hazardous magnet shapes and sizes 7

8 1.10 Children s Denim Products with Assorted Finishes Below listed the guidelines for Children s Denim Products with Assorted Finishes, both chemical and physical/mechanical finishes must comply with Restricted Substances requirements: Chemical Finishes Enzymes & Bleach Caustic soda & Peroxide Pigment printing Tint Allowed with extra rinse, Must neutralize and ensure ph is within allowed limits. Allowed with extra rinses. Must neutralize and ensure ph is within allowed limits. Allowed. Must ensure it does not scratch the skin. Test for Lead and Formaldehyde in the minimum. Allowed with extra rinses. Must use only dyes that are restricted substances compliant. Test for ph. Binder (form of resin) & Resin Allowed with extra rinses. Test for Formaldehyde content and ph. Potassium Permanganate Not allowed. Physical/ Mechanical Finishes Holes Allowed, but these should not be too big that it can easily catch on something and be hazardous. If in doubt, please send sample for review to Regional Product Safety associate. No long threads. Sand blasting Grinding Hand sanding Tacking Allowed. Must 100% inspect and ascertain garments are free of any residue. Allowed. Must inspect and ensure no grinding remnants on garments. Allowed. Must inspect and ensure no residues on garments. Allowed in manufacturing process. Must do 100% inspection and remove tacks from garments. 8

9 1.11 Children s Apparel Safety No. Test Item / Description Test Method Requirements Flammability- Children s Sleepwear Must comply with 16 Parts CFR 1615 & 16 CFR Parts 1615 & Parts 1616 Sizes Must Test in Three Phases: 1. Average char length not to exceed Finished Fabric. inches (17.8 cm), and i. Flame Resistant Children's Sleepwear 2. Garment Prototype. 2. NO individual specimen shall have a char 3. Production Garment. length of 10 inches (25.4 cm). 16 CFR Tight-fitting garments must NOT 1 exceed the maximum dimensions specified in the regulation. Sizing Charts are enclosed. ii. Tight-Fitting Children's Sleepwear 2. Tight-Fitting Garments must meet special labeling requirements. Labeling requirements are enclosed. 3. Must meet the standard for the Flammability of Clothing Textiles 2 Flammability- General Wearing Apparel 16 CFR Part 1610 Class 1- Normal Flammability 3 Resistance to Saliva BVL B :2011 Min Grade 5 GB /T Min Grade 4 AATCC 81/ ISO 3071/ 4 ph GB/T CFR Part Sharp Points/ Sharp Edges - 16 CFR Part Examples include but not limited to safety 5 pins, straight pins, exposed prongs of ASTM F963 Section 4.7, 4.8, and snaps / studs / rivets / rhinestones / zipper 4.9 parts, decorative pins, broken needles, etc. 6 Small Parts/ Choking Hazard - Any item that fits into the small parts cylinder (1.25 x 2.25 ) is considered a choking hazard. Examples include but not limited to trimmings such as bows, tack buttons, rosettes, hasps & sliders, loops, snaps, buttons, toggles, rhinestones/studs/rivets, beads & sequins, appliqués, etc. 16 CFR Part (enclosed) or ASTM F Small Parts Test ASTM F963 Section Tension Test ASTM F963 Section Torque Test 16 CFR Part ASTM F963 Sections 8.8 and 8.9: Torque and Tension Tests (<36 months) (>36 months) NOT ALLOWED for up to 8 years of age Must control sewing needles in factory to ensure products are free of broken needles. NOT ALLOWED. Must comply with 16 CFR Part Minimum 15-Lbs pull force for 10 seconds required when used for children up to 6 years of age. Minimum 4.0 in-1bf torque for children up to 6 years of age. Minimum 15-Lbs pull force for 10 seconds required for children up to 6 years of age. Minimum 4.0 in-1bf torque for children up to 6 years of age. Aluminum tooth zippers are NOT ALLOWED. 7 Zippers and Components All metallic zippers (Excluding Outerwearclothing designed to be worn outside other garments such as Jacket, Hoodie, Cardigan, Blazer, Coat, Vest, Parkas, etc.") must have zipper guard or facing to prevent direct contact with the skin Plastic top/bottom stops are recommended for all zipper types. Zip pullers including any embellishment shall be no longer than 3 in length from zip slider. Zip pullers with or without embellishment shall not hang below the 9

10 No. Test Item / Description Test Method Requirements lower edge of garments designed to finish at the ankle. Decorative zipper slides are NOT permitted for use with zippers that are size 4 and under zippers. When used, decorative zipper pulls must be securely adhered to the zipper slider and must withstand a 15-Lb pull force minimum. Zippers and Components (cont d) Decorative Zippers are not limited to below examples: Non-Decorative Zippers are not limited to below examples: 8 Pompoms Functional Drawstrings ASTM F963 Sections 4.37, 8.17, 8.8, and 8.81 Must meet minimum requirements to minimize the potential for chocking hazard. CPSC s Guidelines for drawstrings Must comply with CPSC s Guidelines. Head / Neck Area - above chest Cuff / Sleeve Openings Bottom Hem - below knee cap Back Area NOT ALLOWED for Sizes 0 20 NOT ALLOWED for Sizes Waist - chest and above knee cap/ KS&C#5 For Sizes 7-20, drawstrings: 1. Must be securely tacked at midpoint 2. Cannot extend more than 3 from exit point when garment is fully extended. 3. Ends must be clean finished - no knots 4. Shall not hang below the edge of the garment Toggles, knots or other decorative findings are NOT ALLOWED. The free ends should be secured to prevent fraying, e.g. by heat sealing or bar tacking. The ends may be doubled or folded provided no hazard of entrapment is created. 10 Mock Drawstrings - A cord, ribbon or tape of any material with two loose hanging ends applied to the exterior of a garment for decorative purposes Neck / Head Area Scoop Neck Area Plastic tips (aglets) must be securely adhered and withstand a 15-Lb pull force minimum. Sizes 0-20 NOT ALLOWED When used on garments intended for children up to 6 years of age, mock drawstring must withstand a 15-lb pull Cuff / Sleeve Openings - below elbow 10

11 No. Test Item / Description Test Method Requirements force minimum. All mock drawstrings should be set on properly reinforced fabric. Leg Openings - below knee cap Back Area Cuff / Sleeve Openings - at or above elbow Ends must be clean finished- no knots. Waist / Bottom Area 3 maximum Leg Openings - at or above knee cap Sizes 0-6 Sizes 7-20 Pre-Tied, Tacked Bows & Lace Up Ties For sizes 0-6, any pre-tied bow if classified as small parts, must withstand a 15-lb pull force. Bow ends must be clean finished - no knots. The loose hanging ends for tacked ties & laced up ties, and loop & tail lengths for pre-tied bows, cannot exceed the measurements outlined: Bow Loops Tail / Ties Bow Loops Tail / Ties Neck/ Head Area 1" 1" 1" 1" Chest Area 2" 3" 3" Lace up ties must be securely attached at exit point for sizes 0-6, and at midpoint for Shoulder Area 2" 3" 3" 4" all sizes: 4" 11 Cuff / Sleeve Openings - at or above elbow 2" 3" 3" 5" Bow Loop and Bow Tail measurement: Cuff / Sleeve Openings - below elbow Waist - below chest and above knee cap Leg Openings - at or above knee cap 1" 1" 2" 2" 3" 3" 4" 6" 2" 3" 3" 7" Leg Openings - below knee cap 1" 1" 1" 1" Back Area NOT ALLOWED Sizes 0-6 Sizes 7-20 Not Allowed Not Allowed The use of ties behind the neck (halter) are not limited to below examples: 12 Ties Behind the Neck / Halter Neck- Styles Visual Assessment 11

12 No. Test Item / Description Test Method Requirements Halter neck-style garment shall be constructed with no free ends in the hood and neck areas as shown below: The use of clip of fastening of two cords is acceptable, provided these do not result in free ends of cords when garment is worn: There shall be no free ends external to the garment. Permanently fixed to front and back, or attached to permit adjustment of strap length by for example buttons, press fasteners, provided the free end is inside the garment. The use of a clip or fastening of two cords is acceptable, provided these do not result in free ends of cords when garment is worn Requirements for Decorative cords attached to a shoulder as below: 13 Shoulder Ties/ Straps - shoulder ties must be submitted to lab in tied form Visual Assessment Sizes 0-6 Sizes 7-20 Non-functional: One piece from front to back Pre-Tied or Tacked Bow Circumference; max 3 Tails: max 3 Functional Ties- Bow Circumference; max 3 Tails: max 4 12

13 No. Test Item / Description Test Method Requirements 14 Sashes (for Dress or Bottom only) - A scarf-like band used in the waist area of a garment with a width of 1.25 or more. Sash ends must be clean finished - no knots. Sash must be permanently attached to the garment. Each side of the sash cannot exceed the length, which is measured from point where they are to be tied Sizes 0-6 Sizes max Tail when untied, do not hang below the hem of the garment 14.0 max Tail Tied Belts (for Dress or Bottom only) Sizes 0-6 Sizes Belts must be permanently tacked at center back and belt loops must be utilized. It is used in the waist area of a garment with a width of 1.25 or more. Belt ends must be clean finished - no knots. Each side of the belt cannot exceed the length, which is measured from point where they are to be tied 14 max when untied, do not hang below the hem of the garment 14 max Fixed loops, which protrude from the garment, for example to fasten, shall be no more than 3 in circumference. Flat loops which do not protrude from the garments, for example for belt loops, shall be no more than 3 in length, between the fixed points of attachment to the garment. 16 Fixed Loops Fixed Loops Measurement 17 Adjusting Tabs Adjusting Tabs Measurement Head, Neck and Upper Chest Area (for age below 7): the length is less than 3, and shall have no button, toggle, buckle on the free and which may present an entrapment hazard. 13

14 No. Test Item / Description Test Method Requirements Sleeves areas: no longer than 4 in length and shall not when open hang below the hem of the garment: Lower hems areas: no longer than 5.5 in length and hang below the hem of garment: Other areas: no longer than 3 in length 18 Faux Fur (Pile) Trimming Pile Height Measurement Maximum 1 1/2 inches in length for Newborn and Infants Sizes up to 24 months Max. 2 inches in length for Sizes: Girls 2-6X and Boys Sizes 2-7. Can exceed 2 inches in length for Sizes - Girls 7-16 and Boys Screen design features for potential child harm, choking, strangulation, and toxic hazards at product development. Garments must be free of loose threads. Garments must not contain floats (exclude the jacquard and embroidery design) on any part of the product over 1/4 inch long. 19 Construction Guidelines Visual Assessment Exposed ends of drawstrings and ties must be finished for sizes 0 through 20. Monofilament threads cannot be utilized. Fabric foundation for snaps, grommets, rivets, hook and bar must be even and of proper thickness. For footed garments, seam-off is to be taken behind the ankle so there will be no thread tails in the toe area. Hanger loops (straps which are attached to a product in order to hold it securely on a hanger at the point of sale) are not permitted on sizes 0-4T and 4-6X /