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.

New rules for soft infant and toddler carriers

Photo courtesy of Benutzer via Wikimedia

It's been a while since I've written about the Consumer Product and Safety Improvement Act of 2008 (CPSIA). While the goal of the law was worthy, the application continues to be problematic. It's clear that Congress passed a law with little understanding of what it was they were asking to be implemented. The result is that the fallout continues. The regulatory burden continues to increase, the cost of doing business continues to increase, and more businesses continue to leave the market with little to no improvement in overall safety.

Don't assume that I oppose safety rules. Quite the contrary. The child product industry has supported the implementation of safety rules and testing. But they want to do it by incorporating risk analysis, practicality, and good common sense. Instead we are being given regulations drafted by academics from the halls of Ivy League schools with no practical industry experience or understanding. (If you think I'm making this up, believe me I'm not. You can get a degree to learn how to create public policy).

In any event, a new regulation has now been published that establishes rules for soft infant and toddler carriers. Definitions are important in government legalese. This rule does NOT cover slings.

ASTM F2236-14's definition of a “soft infant and toddler carrier” distinguishes soft infant and toddler carriers from other types of infant carriers that are also worn by a caregiver but that are not covered under ASTM F-2236-14, specifically slings (including wraps), and framed backpack carriers. Soft infant and toddler carriers are designed to carry a child in an upright position. Slings are designed to carry a child in a reclined position. However, some slings may also be used to carry a child upright. Thus, the primary distinction between a sling and a soft infant and toddler carrier is that a sling allows for carrying a child in a reclined position. Different hazard patterns arise from carrying a child in a reclined position. Accordingly, slings are not covered by the standard for soft infant and toddler carriers. Like soft infant and toddler carriers, framed backpack carriers are intended to carry a child in an upright position. However, framed backpack carriers are distinguishable from soft infant and toddler carriers because typically, backpack carriers are constructed of sewn fabric over a rigid frame and are intended solely for carrying a child on the caregiver's back.

Just because this regulation does not cover slings, do not assume that regulations for slings are not forthcoming. The statement above, highlighted in yellow, states there are safety hazards and implies that standards will come.

You'll notice that ASTM F2236-14 becomes codified in law, which you must pay to access. Though a recent lawsuit* has changed this, I don't expect this standard to be made available in the public domain unless a similar lawsuit against ASTM forces it.

Some other observations:

1. The style of the this regulation is different from previous regulations that I've read. In other words, the regulatory statement includes context in the form of quotes from regulated parties along with a response from the CPSC.

2. This regulation primarily affects 32 of 39 possible businesses that manufacture this type of product.

3. The regulators apparently spent a lot of time debating the font size for text on warning labels.

4. The regulators referred to the ASTM standard as voluntary. It's really not.

5. Manufacturers of this product support the regulation.

6. This standard overlaps other standards including the third-party testing requirement found in CPSIA.

The take away from this regulation, despite being "new", is that very little changes. Most manufacturers were already complying with the ASTM standard. The difference now is that the standard becomes law with a few minor additions.

*The organization that won this lawsuit has been primarily focused on making building codes available in the public domain. Standards for children's products are not currently on their radar. Maybe someday it will be.

Wedding Dress Care/Content Labeling follow-up

I admit that sometimes I make mistakes. A person reading my previous blog entry on a wedding care/content label pointed out some inaccuracies in how I wrote my suggested label. The FTC has some guidelines on how to write labels, both for content and care. I've read these instructions many times, but I sometimes need a refresher. Yes, it would be a good idea for anyone who has to write labels to read the instructions themselves rather than rely on a blog entry (or an anonymous commenter).*

Care instructions follow the general form:

Washing
Bleaching
Drying
Ironing
Warnings

If a dress truly cannot be dry cleaned, then the label should include that instruction. My label suggestion would be more accurate if I had included that instruction. I had also placed the bleaching instruction in the wrong order. Perhaps a better, more accurate, and perhaps correct label (changes in bold) would read:

100% Polyester
Do not dry clean.
Hand wash or
Spot clean in cold
water with mild
soap. Do not bleach.
Hang to dry.
Do not iron.
Made in China
RN12345 (<------ Made up)
---------------------
Avoid the use of
alcohol based products
such as hairspray,
perfume, etc., as these
may damage the dress.

The commenter also pointed out that if there is a reasonable basis for care instructions, then a manufacturer does not need to destroy a dress to prove it. I guess the question that must be determined is what is reasonable? In my opinion (and just for this commenter, this IS my opinion, for what it's worth), a new wedding dress manufacturer should destroy a few dresses to prove their labels. If you think something can be dry cleaned, you should be able to prove it. Same with any other care instructions. Over time, you may be able to reduce the type and amount of testing provided you do not change your component parts. This is probably the reason behind some of the testing requirements in the CPSIA. When you change a component (sometimes even from the same source), you have introduced a variable which may result in different testing guidelines.

I know wedding dresses are expensive, even the initial samples. Is it reasonable that every dress be tested to prove the care instructions? I am not sure every manufacturer goes to that extreme. But it is reasonable that a few have been. Testing a whole complete unit is the only way to test for compatibility of components. Testing a whole complete unit will tell you what a customer will experience. Wedding dresses have a lot of sentimental value and you wouldn't want a customer to have a dress ruined by poor or incorrect cleaning instructions. But this decision is best left to the manufacturer and the responsibility they are willing to bear if something were to go wrong.

As a manufacturer develops, it is reasonable to also test components. It is common for a manufacturer to use the same polyester satin in multiple styles and all they do is change up the trimming. In this case, the satin has probably been washed tested a few times and they know how it should be cleaned. But the trimming is different. In this case, I take some yardage, stitch the trim on and wash it (or dry clean it) - multiple times.

I can recall some concern I had about some flocked glitter on a chiffon. The glitter can fall off because the dry cleaning solvents will dissolve the glue. Washing by hand or machine can cause the glitter to fall off due to abrasion. So we tested various scenarios and came up with a reasonable basis for care. The same scenario can be applied to beads. Though I must say, based on my experience testing, some beads can be dry cleaned and some cannot. Some will fall apart even when hand washing. You won't know unless you test.

It is reasonable that a manufacturer has proof for the testing they recommend. I believe this includes documentation. You won't have documentation unless you test something. These days, I am not sure that a government regulator will appreciate your good intentions or your word without some kind of proof.

And finally, it is true that the CPSIA does not specifically mention wash testing (as I stated in my previous blog entry). It does imply that any testing be done by a certified 3rd party lab. When I worked various private label programs for Big Box stores, they required wash testing by an approved 3rd party testing lab. At that time we were able to negotiate creating an in-house wash testing program to save money. We were required to submit a copy of our test results with the 3rd party testing reports to the technical designers of the big box stores. In the days of CPSIA, I imagine this is no longer possible (I haven't worked on any private label programs in a while, so someone else who has will have to clarify this point). So while the law may not specifically mention wash testing by a certified lab, Big Box retailers might require it anyway. This is thus my reasoning for why I said what I said.

*When I wrote my original blog entry, the FTC site was down and had been down for a few weeks. My intention was to verify and correct my article and I didn't do that because I couldn't. It was one of those things that fell off my radar and I didn't get back to it. My apologies to anyone if I misled. I appreciate comments that politely correct me when I have misstated something. However, I won't print comments that are insulting and offensive.

Warning: Tagless labels in baby clothes and the CPSIA

My sister sent me an update on the problem. It appears that the re-formulated paints may include latex tainted paint, similar to silk screen paint. My niece had another reaction even worse than previous because her entire back flared up red. The pediatrician suggested my niece now has a latex allergy and possible nickel allergy. Latex allergies can develop over time with multiple exposures.

Well over two years ago, Carter's and the CPSC issued an advisory to parents about tagless or heat transfer labels located in the back neck of their clothing. They had received reports that the labels were causing allergic reactions and irritation. The advisory stated that the reported incidents were rare and a small percentage of the thousands of units produced. The affected product was primarily the Fall 2007 line. This means the product was manufactured early 2007 or late 2006.

It is difficult to know what ingredient in the labels is causing the reaction. Some have suggested formaldehyde. Others suggest it is the pthalates, which exist at a far higher concentration than other products. It is puzzling that with documented problems that neither Carter's or the CPSC have done a more thorough investigation. Instead the CPSC is bogged down with debates over the amount of lead in the brass ball of an ink pen or whether a bicycle manufacture can use lead in a tire valve. Surely the CPSIA, that ultimate guardian of children's safety would not have allowed this kind of problem to persist. One has to wonder where the consumer protection groups are on this? Why aren't they making a big stink?

You would think that a product that proved to be a problem would have been resolved by now. No. Carter's released their Spring 2009 line with a reformulated ink and label style - two years later. Because there was no product recall there is an untold amount of product still floating around. (Even with a recall, there would still be a lot of product out there because recalls rarely recover 100% of sold merchandise).

You can accuse me of hysteria or panic if you choose. I'm most guilty of cynicism about federal regulations that don't seem to actually accomplish intended goals. But the reason I am writing this is because my youngest niece suffered a reaction to a tagless label. I was even more incensed when I saw this picture.

You see this label does not even belong to Carter's. It's an Arizona Jean Co. bodysuit, a private label product for JCPenny. The brown around the label is actually my niece's blood! You can see the rash on her back below.

My sister purchased the bodysuit in Fall of 2008 in anticipation of need later in 2009. It wasn't after her baby had worn the bodysuit a few times that she realized the source of the problem. My sister reported the problem to JCPenny and was told she would be refunded her money and receive new product. She was also advised to report the problem to the CPSC herself (which she is doing). Huh? Since I have worked on private label programs for JCPenny, I know how meticulous and thorough they are with safety. This is surprising to say the least.

This is all rather troubling. Doesn't the CPSC require companies to report safety problems immediately? Of course the CPSC may receive a report but how long will it take for them to react, especially now? This problem illustrates how upside down the whole system has become*. We focus all of our energy in silly debates about ink pens, ban rhinestones with no bio-available lead and spend all of our time recalling toys with minuscule amounts of lead - all with no reported injuries. Compare that with the many reports of injuries related to these labels, and we get, well, nothing.


Spring 2009 is two years after the initial reports. Why so long? Why not switch to traditional labeling in the interim? Carter's claims they went tagless to improve the comfort factor - no scratchy label. Well, a scratchy label can be cut out and the problem removed. A tagless label on a baby's bodysuit is not easily removed and must be thrown out. After all this, I think I prefer traditional labels.

*In fairness, the CPSC is working on a consumer database to report incidents as required by law. They are in the process of comment gathering and workshops. Problems can be reported now, but the information required by the CPSIA is not publicly available. If anything, the CPSC should look at a complete overhaul of their entire website which is a disorganized mess. But that is an argument for another day.

A Warning on Labeling Bamboo Textiles

Bamboo fabric has long been considered a miracle green fabric. It is super soft, absorbent, biodegradable, and considered antimicrobial. It is true that bamboo is considered an eco friendly plant because it can be grown quickly without the use of chemicals. Many products have been produced from bamboo - from floors to textiles. Some of the eco friendly claims have come under scrutiny, especially bamboo textiles.

Bamboo textiles are produced by two methods. One can be considered sort of green and the other not. With the first method, bamboo stalks are crushed and broken down with enzymes and then combed out. The second utilizes harsh chemicals to break down the bamboo stalks into pulp which is extruded by spinnerets. This second method is the same process in which Rayon fabrics are manufactured.

You can bet that the majority of the bamboo fabrics on the market are manufactured by the second method. Because of this, the FTC has declared that bamboo fabrics must be labeled Rayon with the qualifier from bamboo. While this is a controversial position taken by the FTC, it is more accurate due to the actual processes being used. The FTC has clamped down on some companies claiming their bamboo textiles are "green". The charges include falsely advertising some of the more outlandish claims of being antimicrobial and biodegradable.

Anyway, be careful of how you label bamboo. The FTC has further guidance on how to deal with bamboo.

The problem with Exemptions and the CPSIA

I think I have been a part of a very minor group of protesters who want a repeal of the CPSIA 2008. The idea has generally been quashed because it doesn't give the appearance "of playing along" or "of being cooperative". See, everyone wants the safest products for children so they are willing to play along with stricter regulations. Perhaps some new safety rules are needed, but the CPSIA is a bureaucratic, chaotic mess.

A repeal may be near impossible to get. It would require vote hungry lawmakers to admit they made a mistake. Who wants to admit they didn't read the darn thing before voting on it? We know most of them didn't because they by and large act with shock when their constituents tell them the truth. What lawmakers want to face angry constituents who insist on stronger regulation to protect children? No, they all patted themselves on the back because they did something to protect a vulnerable population. It was feel good legislation built on a foundation of emotionalism and fear mongering.

So anyway, every industry touched by this wants an exemption. Bicycle makers can't make strong welds without lead. Clothing has little to no lead, which washes out). Book makers use soy ink, so few books would have lead. Electronic devices have internal lead which is inaccessible, micro cottages want permission because they do one-of-a-kind or sell to a very small customer base (small exposure). Resale shops could never test all of their random product. All of these are legitimate reason to exempt a particular industry. If the exemptions we need are granted, we will kind of be back where we started pre-CPSIA.

The CPSC has issued a couple of exemptions. Though the exemptions are largely lip service without any real meat behind them. For example the natural materials exemption. Natural materials such as wood and cotton are exempt as long as they are left in their natural state. Well such an exemption doesn't really help the textile industry because nearly all textiles are processed in some way. White cottons have been bleached and/or dyed white. Such actions mean that the exemption no longer applies. Have you seen unbleached and unprocessed cotton? It's not all that attractive. But if you can build a clothing company around unbleached cotton muslin with unfinished wood buttons, be my guest.

Let's face another fact. Lead is a natural element of our planet. So according to the exemption (if we were to take the extreme interpretation), we could sell unprocessed lead because it is a natural material. But that wouldn't make sense, now would it.

The next exemption on resale stores is another problem. Perhaps the CPSC was begining to feel the pressure. But if you read the actual press release, resale stores are not really off the hook. They can continue their business, but if they do happen to sell product that does not conform they still face criminal prosecution. Floating around twitter is this statement:

Thrift exempt is like telling your kid they don't need to brush teeth, but spanking them if they have bad breath!

Resale shops could still have the CPSC police show up at their door. (I guess we could trust the CPSC when they say they won't target thrift stores, but the language of the law and the exemption hasn't changed. IOW, the door is still open that they could inspect your business if and when they have enough money and CPSC police). All it would take is a guerilla group or investigative reporter to go into any shop with an XRF gun and turn you in. Really, there are regular retail shops dealing with this scenario now.

So Resale shops exercise their business at their own risk. And really, most retailers will be operating like this on February 10, 2009. The hammer won't necessarily fall on that day, but it will when a CPSC policeman or bureaucrat wants to look like they accomplished something.

We never needed this new legislation. I know it sounds unbelievable that Congress really didn't need to act. The CPSC already had sufficient power to enact new safety rules. They had this power when the agency was created in the 1970's to develop safety standards, issue recalls, and ban certain products. If new lead regulation was needed, the agency could have acted on its own. It had that power. The idea that it required an "act of congress" to create new regulations was false. Perhaps Congress could have passed something that said, "We are increasing the fines and we expect new regulations that address concerns with lead in toys to be enacted within the next year." Maybe Nancy Nord didn't want to stick her neck out and actually accomplish something other than lobbyist paid trips.

Anyway, the CPSC has passed various regulations over the years. Flammability and sleepwear, painted metal, drawstrings, and children's jewelry. They even repealed one (Tris in pajamas). All this happened without much intervention from Congress. Does this agency not have a backbone? Let's repeal this act and let's allow industry and science be involved in the crafting the few rules that are needed.

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.

Lead Test Kits

I had a light bulb moment. Why not use this kit to test trims like buttons, zippers, and metal trims. When I buy buttons, I have no idea where they come from because I buy them from a jobber. All I receive is a bag of buttons. Lead testing at a certified lab can be expensive, not to mention the extreme backlog that is occurring right now. Lead tests start at $35 and can vary by lab. (BTW, getting pricing information is extremely difficult and requires lots of phone calling). Why not use one of these kits?

Consumer Reports states that the kits are only useful for detecting high concentrations of surface lead. False positives/negatives are a real possibility. The CPSC says there are no reliable home lead test kits. The CPSC is in conflict with Consumer Reports and it is difficult to know who to believe. CR actually used the test kits to check toys in actual use by children. Any toys that indicated high lead levels were sent for further testing. The results were surprising as they found some toys not on any recall list with extremely high levels.

While no one should rely solely on the home test lead kits for definitive information, I think it could at least give an indication of a problem. I may buy a kit despite what the CPSC says.

Here are some links to testing labs that require further research. At this point, I can't recommend one over the other. These labs can test for lead as well as most textile testing.

Intertek
STR - lab highlighted by an ABC news article, also does textile testing
Bureau Veritas - formerly Acts Testing

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.

Clothing for Children: Chapter 3, part 2

The next section discusses safety. Imagine my surprise by the following statement:

A drawstring should not be used in the neck of a baby's garment. Such a string is dangerous, for it may get pulled too tight about the baby's neck and strangle him. Long ribbons, sometimes used as trimming on babies' clothing, are undesirable for the same reason.

This statement came from a publication published about 1949. The only difference between then and now is that the Consumer Product Safety Commission has issued guidelines (links to a PDF) for children's outerwear (2T-16). Drawstrings are not permitted in clothing for this age group. While the agency does not include infants, it is almost a given that the same guidelines would apply. The drawstring issue is a continual battle. The CPSC issued a recall notice as recently as April 2007. So please be careful.

The chapter also mentions oft over-looked safety issues such as snaps and buttons. Snaps or buttons which easily pull off are considered choking hazards and the CPSC will issue recalls for items that fail. Buttons can break during laundering. If the wrong type of snap is used or the snaps are improperly applied, they can fall apart or pull out of the fabric. So test, test, test.

Finally, the chapter mentions the use of safety pins. In the past, safety pins have been used with cloth diapers. But any trimming attached with a safety pin is a big no-no. They are not only a potential choking hazard, but also a poking hazard. And yes, I have seen manufacturers try to use regular safety pins to attach trims. This is a picture of an acceptable pin back which may be used to attach removable trims such as silk flowers:


This pin back is nickel and has a safety latch. The sharp point is covered. It can either be hot-glued or stitched securely to an item.

Clothing for Children: Chapter 3, part 1

I am going to do a series of posts on Chapter 3 of Clothing for Children because each section deserves its own emphasis. This is perhaps the best chapter in the book. It discusses standards, layettes, diapers, various pieces of clothing, etc.

The first section of the chapter is titled Standards for Infants' Clothing, pages 103-104. Most of the information is still relevant today and designers should keep these things in mind when designing. If you have an opinion or question of how these standards apply today, please leave a comment.

1. A baby's clothes should be made of material that is soft, pliable, and absorbent. Garments worn next to the skin, especially, should not be irritating.

2. The material should be durable, easily laundered, and, whenever possible, it should not require ironing.

3. The clothing should be light in weight but sufficient to keep the body at the normal uniform temperature of 98.6 degrees. The material and garment should both be constructed to allow ventilation.

4. The design of the garments should make them easy to put on and to remove. If you plan to make the garment, the design should be one easy to make.

5. The garments should be comfortable and allow freedom of movement.

6. The clothing should be well constructed with smooth flat seams and have easy simple fastenings.

7. The design, as well as any decoration, should be simple. Trimming should not add to the bulk of the garment. Baby's clothing should be attractive, but this does not depend on elaborateness.

8. The garments should be designed to allow for growth and development of muscles.

9. The garments should be safe.

Most of the standards seem pretty straight forward and practical. You can read my blog entry on Clothing for Children, Chapter 9 for my opinions about standard #7. I am not sure how to take standard #8. Most of the designs I have seen that allow for growth (such as an extra deep hem, tucks, etc), have been ugly. Plus, by the time a child has grown, the garment is worn out. I would like to see a practical solution to allowing for growth.

From a practical stand point, #2 is true for the majority of children's clothing sales. But as your price point moves up, the more likely that your customer may be willing to buy a dry clean or hand wash item. A higher price point customer expects specialty fabrics and they are willing to buy them despite special care. Still, I think higher-end designers tend to go overboard with feather boa trimmings and sparkles. There is a happy medium somewhere.

The point of #3 is that babies need to have their temperature moderated. Not too hot or too cold. It would be easy to assume that babies need to be bundled up all of the time, but it is better to remove or add layers as needed.

Finally, the authors give some sage advice. They suggest buying minimum amounts of clothing before the baby arrives. It is hard to know the size of the baby until born, plus babies grow fast. It is wiser to invest in clothing as needed. At baby showers moms are overwhelmed by lots of clothing sized 0-3M. If you do buy clothing to give, try buying clothes sized 6-12M as that size is mostly overlooked.

Country of Origin labeling examples

One comment from a reader on my Designers hate care/content labeling blog made a good point. Labels can be very irritating to the end user. Rest assured, it is perfectly legal to remove labels after purchase. The size and placement of labels should concern designers because it is all related to your brand. I searched through my stash to find examples of how other designers deal with US labeling requirements. I could not find any pieces that did not comply with labeling requirements. I guess I tend to buy product that is honest in their labeling. Clothing that leave off labels or fail to place them properly says something about your company (and it isn't good IMO). All of these examples have the labels correctly placed near the back neck with the country of origin prominently displayed.

Country of origin as part of the brand label. This is also one of my rare Made in USA pieces.










A size tag/country of origin label stitched to the bottom of the brand label.









A separate size/country of origin label placed next to the brand label.










This is a typical example. The brand label is stacked on top of the care/content tag. The country of origin clearly shows below the brand tag.

Designers hate care/content labels

I was shopping a week ago or so in one of my favorite discount stores, Ross Dress for Less. As I was working my way through the blouse rack, I noticed a significant problem with most of the blouses on the rack. The blouses did not have a proper notification of country of origin (I would of counted how many were not in compliance, but DH was getting bored). According to FTC recommendations, items with a neckline must have a label stating the country of origin at or near the inside center back neck. These blouses only had a small brand label. A separate care label was attached to a side seam, with country of origin disclosed there.

I have read the FTC recommendations dozens of times and I am always surprised of the amount of non-compliance that exists in the marketplace. Some companies must be ignoring (or are ignorant) of the requirement. Further, many of the items in this store are imports. This means they had to pass custom inspections. I don't get it.

I follow the rules, and yet I have seen many designers insist they don't have to place a label at the back neck. After all, it is ugly and takes away from hanger appeal. If no one else is doing it, why should they. Children's clothing poses an additional challenge - there is only so much space in the back neck.

Here is a picture of an infant girl's dress. The label is correctly placed near the back neck. This placement requirement creates consistency across a broad range of products. Customers can know where to find basic product information. If I wanted to purchase Made in USA product, then it would be simple to find out.

It is only required that country of origin information be placed in a reasonable, accessible place (generally the back neck in items with a neck). Care information may be placed in a side seam, or elsewhere. Generally, children's items have the information combined on one tag. Think about your customers. Do you really want them to have to fish through an entire item of clothing to see where it was made and how it should be cleaned?

Another Care/Content Label Example

It's time to look at another care/content label. These labels were found in a 12M knit top that is part of a two-piece set.

The first thing that caught my eye was the placement of the country of origin. Country of origin information must be placed so that it can be seen without flipping the label over. Nothing can cover the country of origin information, like a brand label. It should be placed in an easily accessible area, like the back neck or waistband.

Another interesting observation is the style number and lot number information included on the front of the label. The lot number probably refers to the production lot and corresponds to a date of manufacture (lot numbers are unique to each company, so it could mean almost anything). Generally, this information is found elsewhere, like the reverse of the tag or even on a separate tag stuck into a side seam. It is certainly not anything that a customer is going to care about. I like the inclusion of this info for easy back-tracking, but it should be placed elsewhere.

This tag contains both an RN and CA numbers. The CA number is the Canadian equivalent to the the US RN number. This product was most likely sold in both Canada and the US, thus the need for two numbers.

The reverse side of the label contains all relevant information. My only nit-pick is the overall formatting. I generally prefer the content information first, followed by the care info. This label is just the opposite. Further, the content information is a different font, font size, and right-aligned compared to the care instructions. It makes the whole reverse side appear sloppy.

My final nit-pick is that the label should say "2 piece set" somewhere. Inevitably, the two pieces will be separated. This helps the shipping and store employees on the retail end realize there should be two pieces on the hanger.

Recall : Drawstrings and snaps

The consumer product safety commission issued another product recall for sweatshirts sized 8-12 with drawstrings in the hoods. These sweatshirts were sold in Ross and Gordman stores. Customers who have purchased them should remove the drawstrings immediately. In all, there were 12 recalls for drawstrings in 2006.

At this point, I am just plain annoyed. The drawstring guideline (links to a pdf) has been around since 1996! We have had 11 years to learn not to put drawstrings in children's clothing. The recalls are occurring in the same types of products and even in the same stores repeatedly. I blame the designers. I blame the manufacturers. I blame the buyers. Shame on them. They should all know better.

In another recall, Samara is recalling two-piece overall sets because the snaps contain lead. The CPSC is working on creating a rule about metal jewelry for children that contain lead. The proposed rule will ban "children’s metal jewelry that has more than 0.06 percent of total lead" Once adopted this rule will certainly apply to any metal components found on clothing, including snaps and zipper pulls. There were four additional recalls for lead in December alone. The CPSC is aggressively enforcing this rule now, even though it has not been officially adopted.

Macy's is recalling outfits because of snaps that detach and pose a choking hazard. See Kai Run, of Woodinville, Wash, is recalling children's boots for the same reason.

Just as an observation, much of the above recalled product was manufacted in China. Manufactured Chinese product may be more or less safe than product made in the USA. Certainly, there are some shady manufacturers (US and Chinese) who send approval samples and test results that pass, and then turn around and use different components. Manufacturing overseas is no excuse for ignoring safety guidelines.

Let's make 2007 a safer year for children's clothing products.

Country of origin labeling for clothing

I couldn't resist writing a blog about this particular care/content tag found in a t-shirt that was a Christmas present. This is perhaps one of the worst labels I have seen in a long time. In fact, I believe it was purposely written to make it look like it was made in the USA.

The maker of this shirt did a few things right. The tag clearly states the content of 100% Cotton and it was placed at the back of the neck. Unfortunately, this is the only thing they did right.

The first obvious problem is the different font sizes. Notice how the words Dominican Republic are smaller than anything else. You might think they made those words smaller so they could fit on one line of the tag. But the placement of all the words could make a consumer believe the shirt was actually made in the USA. I did when I first looked at it. Further, the addition of the phrase "of USA Fabric" is extraneous. It should simply state, "Made in Dominican Republic" period.

This tag would not be acceptable by FTC guidelines. When writing a tag, all of the words on the tag should be of a uniform, legible font size. The tag would be rejected for more than the font size issue. This particular shirt is missing a care tag and manufacturer identification. The content tag does not need to include the manufacturers name or RN number. That information should be included on the care tag and/or other packaging. It would be impossible to track down who manufactured this shirt. The FTC could go after the retailer, in this case.

This kind of thing should have been caught when the items were brought into the US. I am, however, not surprised to see it was missed.

Care/Content Label Example in Two Languages

Writing a care/content label can be difficult. There are government regulations, department store requirements, company budgets, and a lot of info to fit in a small space. Every company comes up with creative solutions. If I get stuck on how to write a care label, I go shopping (or at least my closet)! I have seen a lot of good examples and poor examples of how to write a care/content label. I may blog about care/content labels in the real world on a semi-regular basis. New designers need a better understanding of labeling requirements. Since my blog focuses on children's clothing, I will try to pull labels from children's clothing. Children's clothing presents some difficulty when creating a care/content label.

In my first example, I pulled a label from a cotton t-shirt with a screen print, sized 6-9M. I smudged out the RN# because I want to keep the manufacturer anonymous. I apologize for the pictures being a bit fuzzy - labels are harder to scan than I thought. I will do better on my next blog. The front of the label is on the left, the back is on the right.

The first thing that caught my eye about this label is the colors. The label is a folded woven, satin label with orange lettering. This kind of label is a bit more expensive than a regular printed label. I wouldn't have expected this style in an ordinary t-shirt, especially one that came from a major discounter. The label is in English and Spanish. This is a typical requirement for department and chain stores.

I had previously blogged about keeping track of production by recording some kind of information on the label. This label has a SKU # on the bottom of the reverse side of the label. It is a little unusual to see a SKU number, but it does occur. 

The only thing I would change is the repetition of the size information. The English/Spanish could be combined on one line: "Size/Talla 6/9M. It is also preferred to keep the font size for all of the characters and numbers on the tag the same size.

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.

Children's Safety and bedding

I thought I would address a few questions I have received on baby blankets and bedding with regards to flammability issues. The CPSC has issued guidelines on crib safety and bedding. I have searched high and low for any more guidelines on bedding and flammability and did not find anything more specific.

I find this curious because the CPSC has such a strong emphasis on sleepwear and flammability. After all, bedding of any kind will be associated with a sleeping activity at some point with infants. In the soft bedding guidelines, it is recommended that all extra bedding materials (small pillows, decorations, toys, extra blankets, etc) be removed from a crib when a child is there. They go so far as to say a baby should wear a sleeper instead of using blankets or sheets.

Customized baby blankets are a hot item. I have seen them in various fabrics and trimmings. The safest approach is to be sure that the fabrics comply with basic flammability guidelines (links found in my previous post). Also, make sure any attached trims are very secure. Don't have any dangling cords, ribbons, or attachments. As an extra precaution, I include a copy of the soft bedding warning in all of my blanket orders. You may wish to add a sticker or slip of paper that states the blanket should be removed from a crib while a baby is sleeping.

I love making baby blankets. It is a fun and very useful item for new moms. Since I am not a lawyer, I can not advise on liability issues. So while the above ideas make good sense, they may not legally protect you in a burn suit. Just do the best you can in making a safe product and provide a caution statement.

Next time: Children and small objects

2019 note - CPSC links have all changed. The information is still there but you will have to search for it.