APPAREL QUALITY MANAGEMENT JURY

ASSIGNMENT

PRODUCT SAFETY GUIDELINES

SUBMITTED TO: SUBMITTED BY:

MR. SUMIT KUMAR DEBANSHEE CHOUDHURY
BFT/19/252

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CONTENTS
• INTRODUCTION
• DEFINITION OF SAFE TO WEAR
• PRODUCT SAFETY ASSESSMENT
• MANDATORY PRODUCT SAFETY
• OBLIGATIONS FOR PRODUCER W.R.T SAFETY
• HAZARDS
▪ FLAMMABILITY
▪ DRAWSTRING HAZARDS
▪ PINS
▪ BROKEN NEEDLE POLICY
▪ CHOKING & INGESTION HAZARD OVERVIEW
▪ STRANGULATION & ENTRAPMENT HAZARD OVERVIEW
▪ SHARP EDGES & POINTS HAZARD OVERVIEW
▪ CHEMICAL TOXICITY HAZARD RESTRICTED SUBSTANCE LIST
▪ CHEMICAL TOXICITY HAZARD
▪ RESTRICTED SUBSTANCE LIST
• OTHER SOURCES OF HAZARDS OVERVIEW
• CASE STUDY-1
• CASE STUDY-2
• CONCLUSION
• REFERENCE

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INTRODUCTION
Product safety is the ability of a product to be safe for intended use, as
determined when evaluated against a set of established rules. It is unlikely that
anyone would deliberately place an unsafe product on the market, but what is
meant by safe?
The legislation sets out clear test and documentary requirements that
manufacturers and distributors placing equipment on the European market,
must follow to demonstrate that their products meet defined safety criteria
and are safe for intended use. Evidence that the prescribed legislation has
been conformed with can be demanded by the enforcement authorities
(Trading Standards, HSE etc.), within strict timeframes (normally 48 hours).
These are called product safety guidelines.
Here we have each attribute in its own right, with parameters to further
explain their significance. Here in this document we discover why each
guideline is essential and why they are often grouped.

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DEFINITION OF SAFE TO WEAR
A “safe product” is any product which under normal or reasonably foreseeable
conditions of use presents no risk or only the minimum risk compatible with
the product’s use and which is consistent with a high level of protection for
consumers.
This can take the form of being protected from the event or from exposure to
something that causes health or economical losses. It can include protection of
people or of possessions.
During recent years consumer health and safety has become an important
issue in international trade. Public authorities, consumers and also industries
themselves are extremely sensitive to any negative impact a product may have
during or after its use.
Safe to wear is defined as a product safety standard that:
• Has been developed by Inditex in conformity with the most stringent
legislation on product safety.
• Regulates product features which if present in product could present
hazards for safety such as entrapment, strangulation, tripping, choking,
cuts and puncture wounds.
• Additionally, safe to wear sets requirements for parameters not
contemplated by the legislation but are considered to be best practice.
• Lastly safe to wear includes the General Product Safety Directive as the
EU regulation of mandatory compliance for all Inditex suppliers.
Safe to wear is of general and mandatory application for all clothing and textile
products garments supplied to Inditex and certain accessories such as belts,
hats and scarves.
The responsibility of the manufacturers and/or suppliers for guaranteeing
compliance with the products supplied to Inditex with safe to wear does not
exempt them from complying with any other Law or Act that applies to these
articles, even if it is not specifically included in this Standard
Products not included in the scope of this standard are, among others:
jewellery, sunglasses, watches, food contact articles, carpets, curtains, sheets,
toys, candles, electrical and electronic devices, cosmetic and cleaning products,

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home fragrances, household products (non-textile), decorative items,
furniture, cots, high chairs, bassinets and similar products supplied to Inditex.
The exclusion of other articles does not exclude the compliance with any
applicable law or regulation and/or certain specific standards of Inditex group
for such articles.
The Supplier is responsible for the compliance of the products supplied to
Inditex with safe to wear.
Lastly, and regardless of the commitment accepted by the Supplier to control
the parameters regulated in safe to wear, Inditex will verify its correct
implementation at any phase of the manufacturing process of those products
that are manufactured, commercialized and/or distributed by it, by carrying
out “Routine” and “Random Sample” analysis on determined “Models/Quality”
at any point of their “Production Cycle”. Safe to wear is applied through the
following families of products, which are defined according to article type:All
clothing including hosiery and accessories intended for persons up to the age
of 14 years i.e. babies, infant’s and children’s clothing
• All Nightwear intended for persons up to the age of 14 years
• Adult Nightwear
• Adult Daywear and accessories
PRODUCT SAFETY REGULATION
Producers and distributors have for many years been obliged by product safety
legislation to provide information and warnings as to the risks their products
posed where those risks were not obvious and, where necessary, to provide
instructions adequate to consumers’ needs as to the safe operation/use of the
product

PRODUCT SAFETY ASSESSMENT

• The safety of a product is assessed with regard to a number of matters,
in particular
• The product’s characteristics;
• Packaging;
• Instructions for assembly and maintenance, use and disposal;
• The effect on other products with which it might be used;
• Labelling and other information provided for the consumer; and

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 • The categories of consumers at risk when using the product, particularly
Children and the elderly.

MANDATORY PRODUCT SAFETY

There are two types of mandatory product standards: -
• Safety standards - goods must comply with particular performance,
composition, contents, methods of manufacture or processing, design,
construction, finish or packaging rules.
• Information standards - prescribed information must be given to
consumers when they purchase specified goods (e.g. labelling for
cosmetics, tobacco products and care labelling for clothing and textile
products).

OBLIGATIONS FOR PRODUCER W.R.T SAFETY

• A producer has a primary duty to place on the market only safe products
but he also has more specific duties:
• to provide relevant information to enable consumers to assess the risks
inherent in a product throughout the normal or reasonably foreseeable
period of its use where such risks are not immediately obvious to the
user.
• Product suppliers and manufacturers have an obligation to ensure that
only safe products are marketed, by:
o Providing clear instructions for use, including warnings again
possible misuse.
o Being aware of and meeting industry and mandatory standards.
o Developing product recall plans and procedures including effective
communication strategies to the public (e.g. advertisements in
papers) -incorporating safety into product design.
o Developing appropriate safety standards through product
improvement.
o Implementing a quality assurance program which includes
consumer feedback.
o Responding quickly to safety concerns that arise.
• This means that all suppliers of goods including manufacturers,
distributors, importers and retailers must ensure their goods comply

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 with the mandatory requirements. Consumers also have a responsibility
to purchase safe products and to use them in a safe manner.

HAZARDS
Hazards are defined as the potential source of harm. For children’s apparel and
accessories, the most prevalent hazards have been identified. For each, an
overview is provided for the nature of the hazard and how it presents dangers
for children. The key hazards are:
• Chemical Toxicity
• Choking & Ingestion
• Sharp Edges & Points
• Strangulation & Entrapment
• Other Sources of Hazard
FLAMMABILITY
Flammability is defined as the ability of a material or product to ignite and
burn with a flame under specified conditions. Fabric flammability performance
is mainly classified according to flame spread speed and the way of the base
fabric burns.
Where is the risk?
Non-acceptable flammability performance for a fabric, when it comes into
contact with a flame, could be due to different factors. A particularly high risk
arises from the use of the following fabrics and/or materials:
i. PLAIN SURFACE FABRICS:
o Fabrics made of natural or regenerated fibers (e.g. cotton, viscose,
linen, silk) with a fabric weight less than 90 g/m2.
o Fabrics blend weighing less than 90 g/m2 and made of natural or
regenerated fibers and any of the following fibers (or a
combination thereof): acrylic, modacrylic, nylon, olefin, polyester,
wool.
o All raised surface fabrics, especially those fabrics with a pile
average length longer than 0.5 cm.
o Fabrics made of or containing feathers. The design and
construction of the garment will also have an impact on its
flammability performance, for example garments with tassels or

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 fringes. This should be considered as part of garment safety
assessment along with the potential impact of any non-textile
materials and components. The greatest flammability hazard
arises when a particular material configuration and composition
can be ignited and is consumed in the shortest time.

• Nightwear can burn rapidly when accidentally set alight by contact with
an open fire or a gas or electric fire or other heat source, and cause
serious injury -children and the elderly being especially vulnerable.
o In consequence, various mandatory and voluntary measures have
been taken to control the fire performance of the fabrics used in
nightwear and to make the public more aware of the dangers.
o The flammable fabric act of 1953 prohibits the sale or
manufacture of “dangerously” flammable fabrics. Amendments in
1967 extended this coverage to all textile products considered to
be wearing apparel or interior furnishings.
o UNITED KINGDOM - General Product Safety Regulations 1994 (SI
1994/No. 2328) & The Nightwear (Safety) Regulations 1985
The standard creates four categories of acceptable garments for nightwear:
• Category One: garments made from fabrics with low flame propagation
properties;
• Category Two: garments, which because of their design, are less likely to
catch alight and if they do, the spread of flames is reduced because of
the design features;
• Category Three: all-in-one style garments made predominantly from
knitted
• fabrics, in sizes 00 to 2;
• Category Four: garments that are assigned a high flammability rating.
• Categories 1, 2 and 3 must have a white label stating 'LOW FIRE
DANGER'
• Category 4 garments must have a red label with a fire emblem, stating
• 'WARNING - HIGH FIRE DANGER - KEEP AWAY FROM FIRE‘ Labels
showing flammability performance and washing instructions must be
permanent and securely sewn into the garment.

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FLAMMABILITY REGULATION AND PERFORMANCE
• Nightwear can burn rapidly when accidentally set alight by contact with
an open fire or a gas or electric fire or other heat source, and cause
serious injury - children and the elderly being especially vulnerable.
• In consequence, various mandatory and voluntary measures have been
taken to control the fire performance of the fabrics used in nightwear
and to make the public more aware of the dangers.
• The flammable fabric act of 1953 prohibits the sale or manufacture of
“dangerously” flammable fabrics. Amendments in 1967 extended this
coverage to all textile products considered to be wearing apparel or
interior furnishings.
• Nightwear which does not meet the flammability performance
requirements must carry a label with the words:
• 'KEEP AWAY FROM FIRE' (in red letters)
• Nightwear which meets the flammability performance requirements
must carry a label with one of the following forms of words:
• 'LOW FLAMMABILITY TO BS 5722' (in black letters), or 'KEEP AWAY
FROM FIRE' (in red letters).
• All words must be in medium letters of 10 point in upper case.
• You should note that children's nightdresses and dressing gowns which
must meet the flammability performance requirements do not need to
carry a label. However, suppliers may choose to confirm compliance
using one of the above forms of words
• EU Directive 2001/95/EC of the European parliament and of the council
of 3 December 2001 on general product safety - General Product Safety
Directive
• Sweden Konsumentverket, Brandrisk i kläder (Fire hazard in clothes),
enforced under GPSD
• Netherlands National Voluntary requirement enforced under GPSD.
• EN 14878:2007 Burning Behaviour of Children’s Nightwear –
Specification
• USA: Code of Federal Regulations CPSC “Flammable Fabrics Act (16 CFR
II, Subchapter D)” Code of Federal Regulations CPSC Part 1610
“Flammability of Clothing Textiles”
• USA: Code of Federal Regulations CPSC “PART 1611—Standard for The
Flammability of Vinyl Plastic Film

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 • USA CFR 1615 Standard for the Flammability of Children’s Sleepwear:
Sizes 0 Through 6X
• USA CFR 1616 Standard for the Flammability of Children’s Sleepwear:
Sizes 7 Through 14
• Canada Textile Flammability Regulations, SOR/2011-22 CAN/CGSB-4.2
No. 27.5, entitled Textile Test. Methods — Flame Resistance — 45°
Angle Test — One-Second Flame Impingement, as amended from time
to time.
• Canada Consumer Product Safety Act SOR/2011-15 Children’s Sleepwear
Regulations
• Australia: Consumer Goods (Children’s Nightwear and Limited Daywear
and Paper Patterns for Children’s Nightwear) Safety Standard 2017.
• AS/NZS 1249:2014 Children’s nightwear and limited daywear having
reduced fire hazard.
• China GB31701 safety technical code for infant and children’s textile
products.
• CNTAC Guidance on Implementation of GB31701 Safety Technical Code
for Infants and Children Textile Products
• Norway FOR-1984-02-13-427 Forskrift om forbud mot svært brennbare
tekstiler (Regulations prohibiting highly flammable textiles)
• UK Regulation “The Nightwear (Safety) Regulations 1985, S.I. 2043 and
Amendment 1987, S.I. 286. [NOTE specific dated standards apply to this
regulation]
• Ireland SI 215/1979 Industrial Research and Standards (Section 44)
(Children’s Nightdresses) (Amendment) Order, 1979.

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COUNTRY SPECIFIC REQUIREMENTS AND ACCEPTABLE LIMITS

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DRAWSTRING HAZARDS
Certain features of the design of garments that may present entrapment,
strangulation and similar hazards, based on its dimension and position in the
garment. Such features include drawstrings, decorative or functional cords,
adjusting tabs, tied belts, sashes, belt loops, shoulder straps and ties, among
others.
Where is the risk?
The level of risk is largely determined by the position on the garment of these
features and their length or size. Cords, drawstring and loops on children´s
clothing have been implicated in several fatalities in the past. National accident
statistics show that there are many different accidents depending, among
others, on the position of the feature and the age and behaviour of the wearer.
This risk shall be considered and evaluated in all garments intended to be worn
by Children from birth up to 14 years.

GUIDELINES
• The U.S. Consumer Product
Safety Commission (CPSC) &
ASTM F1816-97, “Standard
Safety Specification for
Drawstrings on Children’s
Upper Outerwear” remove
the hood and neck
drawstrings from all

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 children’s upper outerwear, including jackets and sweatshirts, sized 2T
to 12.
• "Choking Risks to Children “- a research
report evaluated the effectiveness of the
‘small parts cylinder’ test in preventing
choking accidents to children under four
from small toys or parts Garments and
recommended a maximum size for the
same.
• EU Directive 2001/95/EC of the European parliament and of the council
of 3 December 2001 on general product safety - General Product Safety
Directive
• EN 14682: 2014 Safety of children’s clothing — Cords and drawstrings on
children’s clothing — Specifications
• USA CPSIA: 16 CFR II Consumer Products Safety Improvement Act 2008.

• ASTM F1816-97 Standard Safety Specification for Drawstrings on

Children’s Upper Outerwear
• New York State General Business Law, Section 391-b (2) and Wisconsin
State Law. ATCP 139.055 Banned children’s products.
• China GB 31701-2015 Safety Technical Code for Infants and Children
Textile Products.

PINS
• Neither pins nor staples are to be used at any point in the garment
manufacturing process.
• This includes all stages of cutting, accessories collation, sewing lines,
inspection and, packing.
• Staples must not be used on paperwork on the manufacturing floor.

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BROKEN NEEDLE POLICY
Supplier must operate a Broken Needle Policy that will include the following
operating procedures:
• Machinists must not hold spare needles – they must be distributed by an
authorized supervisor.
• All parts of broken needles must be retrieved and stored along with an
incident record.

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 • If parts of a broken needle are not located the garment being sewn must
be passed through a metal detector.
• If the missing needle parts are not locatable as a result the garment
must be disposed of and not included in the bulk shipment.
• Old needles must be disposed of safely by an authorized supervisor.
• These procedures must operate in all areas of garment construction
including embroidery, appliqué and any outsourced sewing operations.
• All procedures must be documented and available for inspection if
requested.
CHOKING & INGESTION HAZARD
One of the most prevalent and potentially dangerous hazards for young
children is small parts or pieces that break-away or pull-away from garments or
accessories. Once these small pieces become accessible to young children,
they often find their way into children’s mouths, upon which they present a
choking or ingestion.
Detached small parts can arise through a number of circumstances:
• “Normal” use: Where attachments or parts of items create small parts
through the conditions of use. By example: Bows at the neckline being
plucked or sucked; Toggles on drawstring being sucked/chewed;
• Washing treatments: Garments and accessories are placed under
physical duress whenever laundered. Any weaknesses in methods of
attaching components can be exposed through the laundering process.
By example: Diamantes glued to fabrics that become loose once washed.
• Fitting or removing a garment: Attachments such as buttons or snaps
that are placed under stress whenever used, have the potential to
separate and thereby create a small part. Risks are greater for the very
young. It is generally recognised that children under the age of three are
most susceptible to severe outcomes from small part being swallowed.
At young ages, the gag-reflex (i.e., the ability to cough to remove a
blockage) has not adequately developed. If small parts are swallowed,
they can create a blockage that then becomes fatal. Unfortunately,
children are often reluctant to confess to their actions. This can make it
difficult to establish the circumstances leading to them feeling unwell or
having a reaction to something they have swallowed.

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STRANGULATION & ENTRAPMENT HAZARD OVERVIEW
Strangulation and entrapment hazards arise through the use of cords, bows or
ties used functionally or as decoration on garments. Long ties and cords have
the potential to either wrap around necks or, for ties used in hoods (for
example), to tighten around necks and cause strangulation. Globally, there are
reports of very serious injuries and deaths occurring when knots, toggles or
cord ends become snagged or caught into moving parts or closing doors. Ties
and cords with bulky cord ends are particularly susceptible to being entrapped,
especially when their length and positioning on garments allows them to hang,
drape or swing away from the body. To address the variety of hazards that
arise from the use of cords and ties, consideration should be given to the
following:
• Eliminating functional ties & cords, especially for the younger age groups
• Limiting the length of both functional and non-functional ties and cords
• Securing functional ties so they are unable to be removed. As an
example: Bar tack the draw cord at the centre back of a hood so it will
not slide out through the channel.
• Remove all knots, toggles, aglets etc. from the ends of draw cords to
minimise potential entrapment hazards (NB: Also removes potential
choking and ingestion hazards)
• Cords and ties around the neckline are high risk zones for strangulation
hazards. Long ties and cords at the extremities (wrists, ankles) or on
waistbands of jackets are high risk zones for entrapment hazards.
SHARP EDGES & POINTS HAZARD OVERVIEW
Safety risks arise for children when buttons, trims and attachments create
sharp edges or sharp points. These create potential:
• Penetration risks
• Piercing risks, or
• Slicing risks These risks can present themselves during:
• Regular use (e.g., a sharp corner edge on a buckle that causes a
slicing risk when arms pass across the edge)
Fitting or removing a garment (e.g., a star-shaped button on a front placket
that creates a sharp point risk when removing the garment over the head)
Risks are greater for the very young who are unable to communicate their

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discomfort or act to remove/eliminate the risk (e.g. consider a zipper on a
grow suit with sharp teeth that cause scratching and abrasions around the
neckline, compared to the same zip issue for an older child’s track top). Sharp
points and edges should be identified through a risk assessment during the
product development and approval stages, then eliminated through re-design,
re-engineering or reprocessing. Sharp edges and points can also arise via
contamination during the production process (e.g. Broken needles, pins or
staples). It is important that post-production quality controls are implemented
to identify and rectify any risks introduced through the production process.
Sharp edges and sharp points are often associated with the following:
• Badges, brooches or decorative pins.
• Beads, diamantes, sequins,
• Buttons, studs, rivets
• Zips, zip teeth, zip pullers
• Contamination: Often metallic (e.g. broken needles, pins) but
could also be non-metallic (e.g. nylon Kimble residues)
CHEMICAL TOXICITY HAZARD
Chemicals, toxins, impurities and contaminants are the hidden hazards in
textile production, as these are invisible, often odourless and generally difficult
to detect and understand. Research into the effects of certain chemicals and
the determination of what levels should be considered hazardous is ongoing.
There inconsistent regulations internationally regarding acceptable limits and
whether negative consequences outweigh the utility of certain chemicals,
especially in view of substitution with less studied substances. Therefore,
standards currently vary between regions. The more stringent regulations and
bans are in place in Europe and North America.
Generally young children are more vulnerable to chemical hazards. Their
bodies, internal organs and major physiological systems are still developing.
Metabolic, immunological, hormonal and reproductive systems are immature
and more vulnerable to toxins. Innate behaviour such as sucking and frequent
hand to mouth contact means they ingest substances present in their
immediate surroundings. The following section aims to provide guidance on
the common uses of chemicals in the supply chain. With awareness regarding
substances having the potential to be harmful to humans or an adverse impact
on the environment, avoiding

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them in the production of children's clothing should be easier. The following
classifications can be made:
• toxic substances that remain in textiles and can affect or transfer to the
wearer
• substances that affect workers during production
• bio-accumulative substances with potentially long-term effects on the
environment
The Regulatory Environment in Australia: For consumer goods, there are few
chemical restrictions or guidelines. Heavy metal restrictions are found within
the mandatory standard for toys and as part of import regulations. The ACCC
provides some guidance on the Product Safety
• Australia website: By example:
• Formaldehyde limits for clothing,
• Diethylhexyl phthalate (DEHP) in children’s plastic products, and
• Azo dyes which reduce to aromatic amines. Responsibility for the use of
chemicals in Australia is overseen by the National Industrial Chemicals
Notification and Assessment Scheme (NICNAS).
The NICNAS mission is to aid in the protection of the Australian people and the
environment by assessing the risks of industrial chemicals and providing
information to promote their safe use.
The regulated environment in Europe and USA differs considerably from
Australia. In Europe, the REACH system (Registration, Evaluation, Authorisation
and Restriction of Chemical substances) makes industry responsible for
assessing and managing the risks posed by chemicals and providing
appropriate safety information to their users. This is a more expansive and
engaged framework than what exists in Australia.
RESTRICTED SUBSTANCE LIST
This Restricted Substances List (RSL) was created by a special working group of
the American Apparel & Footwear Association's (AAFA) Environmental Task
Force. The RSL is intended to provide apparel and footwear companies with
information related to regulations and laws that restrict or ban certain
chemicals and substances in finished home textile, apparel, and footwear
products around the world.

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Some of these are nickel, antimony, Lead, chromium, phthalates, Azo dyes in
leather good or specified apparels, phenols, formaldehydes, PVC, Pigments and
many more.
Some Countries also have their additional requirements for safety for
customer.
Harmful Chemicals List
The list represents the collective state-of-knowledge on health effects
associated with chemicals.

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OTHER SOURCES OF HAZARDS OVERVIEW
The hazards identified as being the most significant and relevant for children’s
apparel and accessories have been covered in detail in other sections. It is
worth noting however that there are numerous other hazards which do not
present risks generally for children’s apparel or accessories. These hazards are
listed below as an additional source of reference for risk-assessments. Burn
hazards: Hazards with the potential to cause injury by heat, friction, chemicals
or solar radiation. Flammability hazards for children’s nightwear are covered
by a mandatory standard (AS/NZS 1249). Sun protective fabrics can be tested
and assessed according to the standard AS/NZS 4399. Eye impact hazards:
Hazards arising from projectiles (e.g., objects shot or fired, usually from a toy).
The toy standard (AS/NZS ISO 8124.1) contains test requirements for
projectiles. Insertion hazards: Hazards arising from children placing small
objects into body openings (e.g., ears, nose, but not the mouth). Small parts
create the risk, similar to choking and ingestion hazards. The toy standard
(AS/NZS ISO 8124.1) provides methods to assess small parts. Pinching hazards:
Hazards arising from closing mechanisms that can pinch or squeeze the skin.
(e.g., Alligator clips on suspenders, overalls or hair accessories)
Projection hazards: Hazards arising from pieces or components of
garments/products which protrude in a way that could cause them to push-
into or penetrate the body. (e.g., long or elongated buttons or toggles)
Tripping hazards: Hazards arising from parts of garments that can float/sit on
or near the feet (e.g. long belts on robes, draw-cords at/near ankles on pants)

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CASE STUDY-1
An analysis of children's clothing-related injuries cases reported by the media
in mainland of China from 2003 to 2017
BACKGROUND:
Numerous reports in the media have suggested that children could be hurt due
to their clothing, yet there are few medical reports that discussed children's
clothing-related injuries. This study therefore, aimed to describe the
epidemiological characteristics of media-reported injury cases related to
children's clothing in Mainland of China.
METHODS:
This study systematically collected a total of 192 cases of children's clothing-
related injuries reported in the news reports and medical literatures published
by the Chinese media before December 2017. A content analysis of these cases
was conducted to obtain information on the characteristics of these injuries.
RESULTS:
Cases of clothing-related injuries were most common in children aged 3 to 6
years (54.7%); the ratio of the number of boys to the number of girls in the 192
cases was 1.5: 1. In addition, approximately 51% of the cases occurred in the
region of East China. The most common, location of the incidents was in the
home (35%). Furthermore, the zippers are the most common cause of injuries
(15.1%), and the most common injured body part was the genital organs
(29.2%). Besides, there were 24 cases reported death related to clothing
injuries (13%). Moreover, the locations where the injuries occurred, the
reasons for the occurrence of the injuries and the injured body parts differed
significantly by gender and age (P < .05)

CASE STUDY-2
Safety effects of drawstring requirements for children's upper outerwear
garments
Design: An interrupted time series design. Annual estimates of drawstring-
related child deaths were developed for the study period of January 1985 to
December 2009. A Poisson regression model for rate data was used to evaluate
the effectiveness of the drawstring requirements during the post intervention
period.

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Setting: United States.
Subjects: Children aged 14 years and younger.
Intervention: The application of the drawstring requirements of the voluntary
standard that were adopted in 1997.
Main Outcome Measure The estimated percentage reduction in the drawstring
related child mortality rate associated with the application of the drawstring
requirements.
METHODS
The analysis is based on reported deaths resulting from drawstring
entanglement involving children's upper outerwear garments compiled by
CPSC staff from January 1985 through December 2009. A major source of
information was the CPSC's Injury and Potential Injury Incidents database,
which drew on reports of drawstring-related deaths from a number of sources:
newspaper and other media accounts, the Medical Examiners' and Coroners'
Alert Program, state consumer protection agencies, the public (through the
CPSC's telephone hotline or website), and other sources such as the NHTSA.
Additional information was collected from the CPSC's National Electronic Injury
Surveillance System, a stratified national probability sample of US hospital
emergency departments, and from the CPSC's death certificates database.
SUMMARY
The requirements of the voluntary safety standard for drawstrings have been
highly effective in preventing deaths resulting from the entanglement of
drawstrings in children's upper outerwear garments. Drawstrings in children's
upper outerwear garments such as jackets and sweatshirts, which are
generally worn over other clothing, can result in injury or death when they
become entangled with other objects. Drawstrings in the neck and hood areas
of outerwear garments present a strangulation hazard when they become
caught in gaps or on protuberances from objects such as playground slides.
Additionally, waist-level drawstrings can become entangled in school bus
handrails or doors, presenting a hazard to children when buses pull away after
a stop.
From January 1985 through September 1995, the US Consumer Product Safety
Commission (CPSC) received reports of 17 fatal injuries and 42 cases of
nonfatal
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injuries or potential injuries involving children whose hood or waist-level
drawstrings became entangled on playground equipment, school bus
handrails, and other common items. All reports involved children aged 14
years and younger.
In 1995, after CPSC staff met with industry representatives to discuss
drawstring hazards and to develop a voluntary agreement to address the
hazards, the CPSC issued a set of voluntary guidelines designed to prevent
children from entangling themselves with drawstrings in upper outerwear. As
an alternative to neck-level drawstrings, the CPSC staff recommended the use
of other closures such as snaps, buttons, Velcro, or elastic. The CPSC also
recommended that the ends of waist level drawstrings measure no more than
3 inches from where the strings extend from the garment, reasoning that this
limitation, among others, would reduce the risk of waist-level drawstring
entanglements.
At about the same time the drawstring guidelines were being developed, the
National Highway Traffic Safety Administration (NHTSA) initiated remedial
actions to reduce the hazards associated with drawstrings being snagged on
school bus handrails and doors. These actions included recalls to address the
hazards on existing buses, requirements for improved designs on new buses,
and increased driver training. This analysis suggests that the drawstring
requirements of the
ASTM voluntary standard have been highly effective in reducing deaths
involving drawstrings in children's upper outerwear garments. Additionally,
because there have been no reported deaths involving drawstrings on school
buses since the adoption of the voluntary standard, the requirements of the
voluntary standard in combination with the remedial actions taken by the
NHTSA appear to have been particularly effective in addressing the bus-related
drawstring entanglements. After developing the drawstring guidelines, CPSC
staff worked closely with industry to develop a voluntary standard to address
the drawstring hazards. In 1997, ASTM International adopted ASTM F1816-97,
a voluntary safety standard for drawstrings on children's upper outerwear that
followed the CPSC's guidelines. The standard prohibits the use of drawstrings
in the neck area of garments sizes 2T to 12. It also requires that non-
retractable drawstrings at the waist level of garments sizes 2T to 16 meet the
following:

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 • be limited to no more than 75 mm (3 in) outside the drawstring channel
when the garment is expanded to its fullest width;
• have no toggles, knots, or other attachments at the free ends; and
• be bar tacked if the drawstring is 1 continuous string. Garments with
fully retractable drawstrings are exempt. The standard's garment size
specifications were intended to address the hazards to children believed
to be at greatest risk: children aged 18 months to 10 years for neck-level
drawstrings and children aged 18 months to 14 years for waist-level
drawstrings.
The purpose of this study is to evaluate the effectiveness of the drawstring
requirements of the voluntary standard in preventing child deaths
CONCLUSIONS
This analysis found that the drawstring requirements of the voluntary standard
have been highly effective in reducing drawstring-related child deaths. Based
on our analysis, the drawstring requirements may have reduced the drawstring
related mortality rate by 90.9% and may have prevented about 50 child deaths
during the post intervention period from 1997 through 2009.

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CONCLUSION
Safety issues in children’s apparel have been the subject of many recent
discussions in the international forum. Apart from workmanship and
regulations of attaching different accessories used in children’s garment such
as zippers, bows, drawstrings, buttons, sequins, beads and other decorative
trims and embellishments, the restriction on the presence of lead, cadmium,
nickel, and phthalate over and above certain regulatory limit have also been
emphasized by the brands and international organizations for the health and
safety issues.
Flammability aspects in children’s clothing are also important and safety
regulations are associated to protect children from fire hazards. Thus, while
designing children’s clothing one has to take proper precaution, and adherence
to the flammability regulations is essential. If a product does not comply with
restrictions, e.g. presence of formaldehyde in denim products or banned
aromatic amines in tie and dye products, brand would take immediate action
to ensure the best possible solution taking into consideration people’s health
and the environment.
It is true that product non-compliance is a cause of concern but there is no
need of creating a panic environment in the apparel supply chain, and it is
always advisable to follow a management system approach for proper analysis
of the cause and to formulate a plan of action for how to avoid any recurrence.
Chemical audits are also conducted in addition to regular product tests and
include checking for correct documentation, labelling and quality assurance of
chemicals used in production.

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REFERENCE
• https://www.inditex.com/documents/10279/241148/Safety+Product+P
olicy_Inditex/e5ddb37f-ca6e-42e5-1d70-579bd87913b4
• http://health.gov.vc/health/images/PDF/cip_textile_case_study_report_
21_feb_2011.pdf
• https://www.ilo.org/wcmsp5/groups/public/@asia/@ro-bangkok/@ilo-
hanoi/documents/publication/wcms_159389.pdf
• https://en.m.wikipedia.org/wiki/General_Product_Safety_Regulations_2
005
• https://www.textileebook.com/2019/05/product-safety-and-restricted-
substances-in-apparel-subrata-das.html
FOR CASE STUDY
• https://journals.lww.com/md-
journal/fulltext/2020/02280/an_analysis_of_children_s_clothing_relate
d.50.aspx
• https://jamanetwork.com/journals/jamapediatrics/fullarticle/1212220

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