A question on the drawstring rule and children's clothing

I received a question about drawstrings* and elastic waists.

I want to design skirts with elastic waists and a ties that are sewn in by the hem, which then connect to a bow. Is this not acceptable to the Drawstring rule CPSIA? So confused on this. If isn't acceptable, can I do a skirt with elastic waists and sew a bow in the middle?

In the United States there is a safety rule about drawstrings on children's upper outerwear.** This rule does not allow drawstrings in hoods or waists of jackets or hoodies, for example. A drawstring is a cord with or without a toggle that is inserted in a channel. The intent of a drawstring is to cinch up a waist or hood opening to make it smaller. This rule was enacted because children have died when the toggle or knot on the drawstring became entangled on playground equipment and bus doors. It appears the CPSC has added a bit of clarity to the original rule. You actually can have drawstrings so long as the drawstring does not extend more than three inches and has been securely stitched through in the middle of the channel so it cannot be pulled out.

This hoodie uses ribbing to help it fit closer around the head, instead of a drawstring.

But if I were you, I would avoid using drawstrings altogether in children's clothing. The reason is rather simple. There continue to be drawstring recalls even with almost no reports of injury or death. As of 2012, there have been more than 130 recalls involving drawstrings. The most recent is of a rain poncho. In this example it's clear there are no toggles or knots on the drawstring, the string is just too long (no reports of injury). The rule covers children 2T-16, but there have been recalls on infant clothing too. There was an odd recall of an elastic waist belt on a jacket (no injuries).

The recent rule revision appears to focus almost entirely on upper outerwear like jackets, sweaters, and hoodies. But historically there have been recalls on pants with drawstring waists. For this reason, I do not recommend drawstrings on any children's clothing. The risk is too great. Even though the majority of the recalls in the last 10 years have had no injuries or death, there have been a few. Also, the CPSC seems to inconsistently apply the rule, including the apparent exception of a three inch extension. There is just no way to predict what might happen.

To answer the first question above, I would try to avoid sewing things onto the ends of ties. That seems to fall into the drawstring with toggles or knots category. I think a bow sewn securely through on top of an elastic waist should be ok.

Waist ties and belts have not been involved in any product recalls, as far as I know, and are not included in this rule. Girls dresses, in particular, frequently have waist ties or belts. Even though the rule excludes this type of application, I would still exercise caution. Waist ties should only be long enough to tie with tails that are not too long. The tail of a belt or waist tie should not extend below the hem of a dress or touch the floor - it could become a trip hazard. Also, be sure there are no knots or toggles on the ends.

BTW, there is an ASTM standard for drawstrings, ASTM F1816. It costs $42 to buy a copy of this rule.

*I'm not a lawyer. The statements above are my opinion and should not be construed as legal advice on how to comply with government regulations. If you are manufacturing children's products, you should seek legal advice, follow all applicable rules, and seek out a certified testing laboratory as required.

**The CPSC has updated their website since I last visited and they have made it even more difficult to find safety rules with their "robot regulator". You have to jump through a questionnaire to find the safety rule you are looking for. This is the direct link to the drawstring rule, however long it remains a valid link.

Taggies brand rompers recalled

I have posted previously about Taggies brand blankets and related products. They are known for aggressively enforcing and protecting their patent on their security blankets. I have previously talked about how this kind of patent is ridiculous, but there is not much that can be done unless someone wants to be a test case in a patent infringement lawsuit.

Anyway, the company Rashti and Rashti (They are listed as the importer and official licensee) has issued a recall for Taggies infant sleepers. The sleepers are being recalled for snaps that can detach. The sleepers were sold in several big box retailers. This kind of recall is not unusual. Improperly applied snaps can easily fall or pull out. Painted snaps should be tested for lead.

I would post the pictures of the sleepers here, but the Taggies people are so aggressive about sending out cease and desists, I don't want any trouble (even though the images are technically in the public domain). Just follow the links to the official recall notice. There is a small link on the main Taggies page about the recall.

BTW, if you visit the What's New page at the Taggies website, you can see the types of products they will attempt to protect with their patent. The patent is supposed to protect related products and you can see their version of related products is extensive. All they've done is add ribbon loops to various products. To me this is not a question of protecting a unique product worthy of a patent. Instead it is a form of brand protection over a certain look. I am still flummoxed on how they achieved patent protection over the simple idea of inserting a ribbon loop into a seam. Maybe I should try to patent shoelaces?

Drawstrings and Child Safety

Below is an article that I wrote about Drawstrings. It appeared at Fashion-Incubator on December 17, 2007. This edition includes a picture of a bib with bias ties that was not previously included.

In 1996 the US Consumer Product Safety Commission (CPSC) created guidelines for the use of drawstrings in children's upper outerwear. The guidelines specifically target drawstrings found in the hoods and waistlines of sweatshirts. They were created after reports of several injuries and even death of children who wore such clothing that became entangled. The guideline applies to clothing sized 2T-16 and is considered voluntary.

CPSC’s drawstring guidelines do not represent a standard or mandatory requirement set by the agency. And, while CPSC does not sanction them as the only method of minimizing drawstring injuries, CPSC believes that these guidelines will help prevent children from strangling by their clothing drawstrings.

Even though the guideline is considered voluntary, it would be in a DE's best interest to follow them. In the first two weeks of December 2007, there have been 5 recalls of children's clothing with drawstrings!



The latest recalls are representative of the type of drawstring issues that keep showing up. The jacket has a drawstring at the waist (picture does not show it). The two pants are borderline with the ties at the waistline. They are not technically drawstrings, but they are knotted belts. The belt on the jeans appears to be stitched to the belt loops, but is being recalled because it is a related style to the other. The bright pink shirt with long pink ties are located near the neck. The hooded striped sweaters have knotted velvet ribbon ties. All of these products were found in major department and chain stores. The irony is all of these stores should know better because these guidelines have been in place for over ten years. The buyers should know. The quality auditors should know. The manufacturers should know. The technical designers should know. And yet, the problem continues to show up. As you can see, there is broad interpretation with the guideline and how it is applied. The original guideline applies to outerwear and the recalled jacket certainly fits. But what about the recalled t-shirt and pants?

The difficulty comes with understanding the difference between an industry standard, voluntary guideline, regulation, and law. For example, the lead levels in painted products began as a guideline and has now morphed into a regulation that can result in severe fines and penalties if not properly followed. The transition began with voluntary recalls by manufacturers and the CPSC. As the public became more aware of the problem and the danger explained, children's products that contain lead are now under mandatory recall. I believe the drawstring guideline is starting to go down the same path. The pattern right now is in voluntary recalls and public information. As public awareness increases, there will be public pressure to make this guideline a law or regulation. From a public or consumer point of view there is no difference between a voluntary guideline, regulation or law.What began as a voluntary guideline for drawstrings in upper outer wear for children 2T-16 has resulted in unintended consequences for related products. Any childrenswear designer has to question the use of ties for any age child in any piece of clothing. Potential sources of strangulation or entrapment are everywhere. Consider this bib:

This bib was purchased about 2 years ago from a discount retailer. Pre-guidelines, this bib would have been sold with knots on the end of the bias bindings. Now, it is sold without the knots. Yet, it becomes a strangulation issue because the ties could still become caught in a high chair. Do the guidelines cover this too? Sure there are other types of closures, but they pose potential choking hazards. Snaps, buttons, and velcro pieces can come loose if not applied properly. What to do? Feed the baby naked and hose them down afterward?

Other products that can cause concern:

• Bibs with ties made of bias binding, ribbon, or fabric.
• Girls dresses with waist ties made of fabric or trim. The ties may contribute to the design of the dress, but also provide a fitting mechanism.
• Dresses with detached sashes. Some sashes may measure 60-72 inches and are not permanently affixed to the garment.
• Dresses, tops, or pants with added trim that may be loose, especially ribbon dangles.
• Hats with ties made of ribbon or fabric.
• Hats with straps, either attached on both ends or attached on one end with some type of closure on the other.

I am sure blog readers could come up with other examples. When you take safety issues to the extreme, there are all sorts of hidden dangers in clothing. From a realistic and practical design perspective, you can not design a 100% safe product. The pressure is more extreme with children's clothing. No one wants to unintentionally injure or contribute to the injury of a child. What to do?

I have had employers and DE's ask me (I question myself) about products on the above list. I don't have an easy answer for them. The first place I turn to is the CPSC website. There are no further guidelines other than the drawstring guideline issued in 1996. The next place to look for industry standards is ASTM. ASTM has the same drawstring standards as the CPSC, but charges you $30 for a licensed copy (read ASTM licensing requirements before purchasing anything from them. You might be surprised at the kind of restrictions you will be under). Another option (not necessarily the best) is to look and see what other companies are doing. How long are their waist ties on dresses, for example? The concern is that even major retailers have trouble following their own internal guidelines (and yes, most of them do have internal guidelines regarding drawstrings). Finally, your company can come up with your own company standard.

I would prefer a voluntary industry standard for the above listed products. I think this is something that can be done. In this endeavor, I am currently working on a letter to send to the CPSC, and possibly ASTM. I will be requesting further clarification on drawstrings and ties in children's clothing, especially for infants. The drawstring conversation is just beginning. Post any comments or questions you might have about this issue.

The dangers of lead in children's products

This will probably be a link heavy post. Lead is getting a lot of exposure of late because of its discovery in toys, but lead tainted products have been around for a long time - many common, everyday items. Lead can be found in:

• Garden hoses (this is why children should not drink from them)
• Ceramic glazes (The US blocks the importation of lead tainted ceramic dishes)
• Lead Glass, including crystal dinnerware and swarovski crystals
• Plumbing (pipes and solder)
• Paint
• Gasoline
• Some candles
• Roofing materials
• Car batteries
• Vinyl baby bibs

The danger from these items vary and depend on the amount of exposure. In the past the biggest concern has been focused on gasoline and paint. California has passed a law banning lead in jewelry, especially for children. Children have a tendency to put things in their mouth, so any lead containing products should be kept away. The CPSC has also issued guidelines about lead in children's products.

For years, Big Box retailers have required factories to submit any metal or painted metal products for lead testing. They may expand this to include plastic findings. So many trim details come from China, it is impossible to know if they are lead free unless they are tested. Later I will post some sources for testing labs.

The health effects of ingesting lead, especially by small children is well documented. Lead can affect adults too, especially reproductive, cardiovascular, and mental health.

Childrens clothing and small objects

It may seem obvious that children should not have small objects. The Consumer Product Safety Commission announces recalls about small toys and objects that are choking hazards for children every year. This only proves there are still many opportunities for children to find small objects and put them in their mouths. This even includes small objects found on clothing.

There are many small objects that can be found on children's clothing. Buttons, ribbon flowers, zipper pulls, snap parts and other attached trims can easily work themselves loose and become a choking hazard. If you are a designer of children's clothing, this is something you must pay attention to.

Any attached trims must be securely attached. There are various methods by which this can be done, so I won't detail them here. The important thing is to test your clothing by sending it to a testing lab or by performing the test yourself. In fact, you should test a pre-production sample, test during production, and test post-production. This may sound like overkill, but I have inspected product and found problems all three times. I have inspected imported (and domestic) goods where the contractors sewed ribbon flowers on with only three stitches or buttons by a couple of hand stitches. These problems were serious enough, I have sent entire production runs for repair.

I call this kind of test a pull test. A testing lab may call it something else. The test is performed by determining the amount of force required to pull a trim off. When I worked on some private label programs the amount force a trim was required to withstand was 10lbs of force for 10 seconds. If you are also involved in a private label program, this information should be included in a quality manual, as it may vary with each company. I don't know where this particular standard came from (probably ASTM), but it seems to be a good guide in my experience. BTW, you can purchase quality standard information from ASTM.

You can perform this test yourself if you purchase a push-pull gauge. The gauge will come with a hook that you can hook around a trim. Apply the force gradually by pulling until you get up to about 10lbs and hold. If the trim is going to come off, it will do it while you are pulling up to 10lbs. After you do this test, make sure to record it on a quality test/audit page for each style.

A retailer should give a quick inspection to clothing before putting them on a sales rack. If you find any loose trims, return it to the manufacturer.

I have never heard of a product recall for loose buttons or trims. That doesn't mean it couldn't happen. So test, test, test.... Better safe than sorry.

Recall : Flammability Issues with child's bathrobe

The consumer product safety commission recently issued a recall for children's bathrobes because they are considered highly flammable. The robes were made of 100% cotton terry cloth. Even though a bathrobe is not technically sleepwear, it is a piece of clothing that is connected to sleeping and thus must comply with the Children's Sleepwear standard.

More information can be found on the children's sleepwear standard (read this letter on loungewear too). It took me over an hour to finally find links to these two pieces of information and I read lots of interesting information on other products. If you go to the CPSC site, be sure to click on the Business link for guides and summaries.

Since you can read the government regulations at the links above, I won't repeat much of it here. Suffice it to say, the actual Flammable Fabric Act applies to just about all fabrics and articles of clothing (there are some exceptions). Some fabrics that consistently fail flammability testing include: sheer rayon or silk, rayon chenille, cotton fleeces, and cotton terry cloth. Synthetic fabrics (polyester, nylon, acrylics) or wool fabrics are generally exempt. This is because these fabrics either simply melt or do not hold a flame once the flame source is removed.

If you design childrenswear consisting of any suspect fabric, you should take the time to send either your fabric or clothing to a testing lab. A flammability test can run anywhere from $200-$500, depending on the lab. Small change compared to a burn lawsuit.

Next time I will tackle children's safety and bedding.

2019 note - The links to the recall and the CPSC are no longer good. If you do click through, you will have to search the database for the relevant information. 

Recall : Hooded sweatshirts with drawstrings

Two recent product recalls on children's clothing prompts me to issue a reminder. There are two major safety issues in relation to children's clothing. The first is drawstrings and the second is flammability.

Drawstrings

It never fails. I have seen drawstrings in one form or another on children's clothing each season. The consumer product safety commission (cpsc) recently issued a recall for hooded sweatshirts with drawstrings. The fact that these products made it into a major department store shows multiple failures along the vendor supplier chain. Nearly all products sold in a department store must pass some form of inspection. If this is a private label for Kohl's, then the failure is even greater. A major department store chain usually has a technical designer and quality auditor over every division. A private label garment must be approved by a technical designer, who is responsible that the garment not only fits, but is safe. A quality auditor is supposed to ensure quality standards and compliance during and after manufacturing. Both individuals should KNOW of the safety guidelines on drawstrings which have been in existence since 1996.

Another layer of failure is at the buyer level. A childrenswear buyer should also know the rule and should not even consider an item with a drawstring. I can guarantee Kohl's will either severely reprimand or fire the buyers and technical designers over that division. Not only is this a major financial issue for the company, but an accident waiting to happen.

Most major department stores are so concerned about the drawstring issue, that they have self-imposed their own safety guidelines. In other words, they have banned any type of item that dangles beyond a certain point. Waist ties on dresses can only be so long. Bibs no longer have bias ties. No knots (trims, pom-poms, flowers, etc) on the end of strings. Those large, pretty sashes found on girls special occassion dresses have to be shortened. Hoodies have elastic in the hood hem instead of drawstrings.

Boutique and specialty stores do not understand this safety issue sufficiently, and I still see drawstrings on childrens clothing. If you are a children's designer, be sure to pay attention to safety issues!

Next time: Product recall on children's bathrobes.