Part I

SAFETY ASPECTS IN INFANTS AND TODDLERS GARMENT

Dr. Subrata Das

Consumer Testing Laboratories (India) Limited,
No.35, 2nd Floor, Mirage Point, 80 Feet Road, ST Bed, Koramangala,
Bangalore - 560034

Brand buyers are committed to provide quality products. The need for safety is crucial and is
strongly recognized across all markets, especially for children’s clothing. The right guideline shall
assist the suppliers with safety through the product development process. It will help to establish
the required safety standards and produce apparel that will limit potential hazards. The
information, legal legislation and regulations are intended to assist with manufacturer’s legal
obligations and produce a product that meet and in some cases, exceeds all the legal and
industry requirements across all markets worldwide. Strict adherence to these standards is not
optional. If a supplied product does not meet all the required safety standards, laws, rules or
regulations, a supplier would be liable to the brand for product withdrawals / recall costs and
customer returns to store along with other legal obligations under the agreement and applicable
laws. Components used on children’s apparel, such as zippers, drawstrings, fasteners and
decorative attachments must not present any hazards to children during normal use, or as a
result of any foreseeable damage or abuse.

In view of the above facts, different accessories used in children’s apparel have been discussed
in Part 1 of the paper along with the possible hazards associated with their potential application
and the guideline on the standards of such items.

1. Small Parts – Choking Hazards

Children aged 3 years and under are particularly susceptible to choking, asphyxiation and
ingestion hazards caused by small objects. All components that could become detached from
children’s clothing are all examples of small parts, and therefore choking hazards. Some
examples of small parts are listed below:

Snaps / Studs / Rivets

Buttons
Appliques
Bows and Rosettes
Pompoms and Fringe
Dungaree Clasp (Hasps) and Slider
Zipper Components
Belt Fastenings
Toggles
Decorative and Functional Loops
Decorative Labels

If the trim or component can fit within the small parts cylinder, the item is considered a potential
choking hazard.

It is therefore, a general policy in US buyers for all small parts intended for children 3 years and
under to withstand a 15 lb – 21 lb pull force.

2. Metal Fasteners:

All metal fasteners (including any surface coatings) such as press fastener (prong), press
fastener (post), stud button, eyelet and rivet must be from an approved source like YKK, Prym,
Scovill Fastners Inc. or Morito (Kane-M) only.
Prong Post Stud button Eyelet Rivet

In order to ensure metal fasteners are securely attached to garments, the minimum pull force
requirements of 15 – 21 lbs must be achieved depending on the requirement of a buyer.

Metal fastenings on all children’s product must not contain toxic elements. For the US, this must
include those toxic elements specified in ASTM F963 and for Canada those toxic elements
specified in The Hazardous Products Act. If the component has surface coating, it must comply
with the lead requirements outlined in CFR, Title 16, Part 1303 for the USA and Hazardous
Product Act as amended on April 19, 2005 for Canada. All metal fastenings must comply with The
European Nickel Directive (94/27/EC).

The fastener and coating must be capable of withstanding washing and drycleaning in
accordance with the garment care label.

All press fasteners including stud, post, socket and cap must be metal. All metal fasteners must
be non-ferrous to ensure garments can pass through the metal detector. This includes metallic
finishes.

Fasteners must be free from rust, contamination, oxidation and all other types of degraded
corrosion.

3. Zipper Fasteners:
Zipper must be sourced from an approved supplier as a complete unit with all of the necessary
components such as top stop, slider, bottom stop etc. Zipper components must not be individually
purchased and self assembled.

For the UK, zipper and zipper pulls must comply with BS 3084 : 2005.
For the USA and Canada, zippers must comply with ASTM D 2060, D 2061.
For Germany, zippers must comply with DIN 3419 – 1, Publication date: 1998-05 Slide fasteners
– Part 1: technical delivery conditions.
For Japan, zippers must comply with JIS S 3015:1993 Slide fasteners.
In order to ensure zippers and zipper pulls are securely attached to garments, the pull force
requirement of 15 lbs is required.

For the USA and Canada, zippers used on children’s clothing under 3 years must conform to the
torque and specification in ASTM F963 and CFR Title 16-Part 1500 :

0 -18 months 2 ± 0.2 lbf. in(0.23 N.M)

18 – 36 months 3 ± 0.2 lbf. in(0.34 N.M)
36 – 96 months 4 ± 0.2 lbf. in(0.45 N.M)

Zippers on all children’s product must not contain toxic elements. If the zipper pull has a surface
coating, it must comply with the lead requirements as outlined in standard. All zippers and zipper
pulls must conform to the European Nickel Directive and must be non-ferrous to ensure garments
pass through the metal detector.

Zippers must have fully autolock or semi-autolock sliders. Pin Lock zippers are not acceptable on
childrenswear.

Top edges of zippers are to be finished so there are no sharp edges on the teeth or top stops.
Fasteners cannot have rough or sharp edges and they must be free from rust, contamination,
oxidation and all other types of degraded corrosion.

Zipper stops specially designed so that the zipper slider can be removed are not permitted for use
on children’s clothing. Coil zippers for children’s clothing must have molded plastic top and
bottom stops. For USA and Canada, metal zippers require a zipper guard or facing to prevent the
zipper being in direct contact with the skin. However, invisible / concealed zippers are not
permitted for children’s clothing 3 years and under i.e. sizes 0-5T for USA, sizes 0-3x for Canada.
 Invisible / Concealed Zipper

A zipper pull is the component used to open and close a zipper. It can be attached through either
the main body of the zipper slider or through the eye of the zip pull. Indirect attachment pulls (2
piece zipper pulls) are not allowed for children’s clothing 3 years and under.

Ring pulls or other open type designs are not permitted for children’s clothing 3 years and under.

4. Dungaree Clips (Hasps) and Sliders

Same as metal fasteners.

5. D-Rings

Same as metal fasteners.

Not allowed on sizes 0 – 24 months
Not permitted at the free ends of ties.
Must have no visible joins, designed so that they cannot become detached from the garment, and
secured close to the garment.

–Sizes 2T –5T maximum inside diameter: ½”

–Sizes
Girls :4-6X maximum inside diameter: 1”
Boys:4-7

–Sizes
Girls : 7-16
Boys : 8-18 maximum inside diameter: 1½”
6. Functional and non-functional drawstrings, cords / ties

In order to ensure functional and non-functional (decorative) cords/ties and drawstrings are
securely attached to children garments, a minimum pull force of 15 lbs is required. Cord / ties
made from metal chain must not be used for children 3 years and under. For children over 3
years, cords / ties / belts made from metal chain must only be non-functional (decorative) and
have a breakaway strength of 25N / 5.6lb to 40N / 9lb. The length of the cord / tie is dependent on
area of attachment. Children’s garments must not be designed to have functional drawstrings,
non-functional (decorative) drawstrings, functional cords / ties or non-functional (decorative) cords
/ ties which emerge from the back of the garment and they must not be tied at the back of the
garment. Sashes, however, are allowed to be tied at the back of the garment. The ends on all
drawstrings and cords / ties must be secured with either, a double turn secured with lockstitch, a
heat seal, laser cut or a plastic sleeve (shoe lace end). If a plastic sleeve is used, it must
withstand a 100N / 22.5lbs pull test. The free ends of all drawstrings and cords/ties must not be
secured with a knot or equivalent i.e. bead, toggle, pom-pom for children’s clothing. Beads must
not be used on functional or non-functional (decorative) drawstring and cords / ties for children 3
years and under. For children over 3 years, beads can be used on drawstring and cords / ties,
except when positioned at the free ends. Functional drawstrings, non-functional (decorative)
drawstrings, functional cords / ties and functional (decorative cords / ties used on the lower edges
of a garment must not hang below the hem of the garment. There are also maximum length
restrictions to consider when using drawstrings and cords/ties on clothing for children.

Functional drawstring Non-functional Functional cord / tie Non-functional

decorative drawstring decorative cord / tie

No functional drawstrings, cords or ties are allowed in any children’s size range in the hood or
neck area of garments. Elastic cords/ties are not permitted in the hood and neck area of
garments. However, non-functional drawstrings and non-functional (decorative) cords/ties are
only allowed on the hood at the base of the front opening. Non-functional drawstrings are to be
securely attached with a bartack 1cm / ½’’ from the exit point.
In case of waist area, functional drawstrings must be secured to the garment with a bartack to
prevent the drawstrings from being pulled out of the garment. This also prevents one end of the
drawstrings from ending up longer than the other and thus becoming an entrapment/catch
hazard. The most common place to secure the drawstring is at the centre back waist.

Non-functional drawstrings should exit through button holes or eyelets at the waist. The cord must
be secured with a bartack no further than 1 cm / ½” from the button hole or eyelet. Non-functional
(decorative) cord/ties should be attached to the outside of the garment with a bartack.
Measurement is taken from the point of attachment.

Lace up ties must be securely attached at exit points for 3 years and under, and at midpoint for all
others.

As per the statistics of European countries, serious accidents involving cords and drawstrings on
children’s clothing fall into two main groups by age of child:
i) Younger Children: Persons aged from birth to age 7 years (that is 6 years and 11 months)
which includes all children up to and including a height of 134 cm ----- Entrapment of hood cords
in playground equipment such as slides, resulting in fatalities.
ii) Older Children and Young Persons: Persons aged from 7 years up to age 14 years (that is up
to 13 years and 11 months) which includes all boys of height greater than 134 cm up to 182 cm
and girls of height greater than 134 cm up to 176 cm -------Entrapment of cords and strings from
the waist and lower hems of garments in moving vehicles such as “bus doors”, ski lifts and
bicycles resulting in severe injuries or death from being dragged along or run over by the vehicle.

Hook and neck area on garments for young children : Garments intended for young children shall
not be designed, manufactured or supplied with drawstrings, functional cords or decorative cords
in the hood or neck area.

Hook and neck area on garments for older children and young persons : When the opening of
the garment is at its largest and the garment is laid flat there shall be no protruding loop. When
the garment opening is at its smallest, that is the size it is intended to fit, the maximum protruding
loop circumference shall be 150 mm. Functional cords shall not be more than 75 mm in length at
either end and shall not be made from elastic cords. Decorative cords shall not be more than 75
mm in length at either end including any attachment such as toggle and shall not be made from
elastic cords. Halter neck style garments shall be constructed with no loose ends in the hood and
neck area.
Waist area of garments : Drawstrings in the waist area shall protrude by a maximum of 140 mm
at each end when the garment is flat on pattern and by no more than 280 mm when closed to the
intended waist size. Functional cords and decorative cords in the waist area shall be a maximum
of 140 mm including any embellishment on decorative cords. Belt loops shall be designed to lie
flat against the garment. Sashes shall be acceptable provided that when untied they do not hang
below the hem of the garment. The length of sash when untied measured from the point where it
is to be tied shall be no more than 360 mm.

Lower hems of garments which hang below the waist : Drawstrings, decorative cords or
functional cords including any toggle on the lower edges of garments where the lower edge is
situated below the hip shall not hang below the lower edge of the garment and should be totally
inside the garment. If they are external to the garment, the drawstring or cord shall lie flat against
the garment, when the garment is tightened or fastened. There shall be no protruding
drawstrings, functional cords or decorative cords on the bottom hem of coats, trousers or skirts,
which are designed to finish at the ankle.

Sleeves : Drawstrings, functional cords and decorative cords at the lower edge of long sleeved
garments shall be totally on the inside of the garment, when the garment is fastened. However,
they are acceptable on short sleeved garments provided the sleeve finishes above the elbow and
the maximum protruding length is 140 mm measured laid flat on pattern.

Other parts of the garment : In all the other areas of the garment, not previously addressed, the
drawstrings or functional and decorative cords shall protrude by no more than 140 mm when the
garment is open to its largest.

Based on the case studies, two types of hazards are recognized in regard to the use of
drawstrings in children’s garments:
a) the potential strangulation hazard primarily associated with hood and neck drawstrings, and
b) the potential vehicular dragging hazard primarily associated with waist and bottom drawstrings.

7. Toggles

In order to ensure toggles are securely attached to children’s garment, a minimum pull force of 15
lbs is required. Wood, cork, leather, mother of pearl (shell), glass or other non-durable toggles
must not be used on children’s clothing. Toggles must only be used on functional drawstrings,
non-functional (decorative) drawstrings, functional cords / ties or non-functional (decorative) cords
/ ties that have no free ends. In addition, free ends cannot be knotted together to form a
continuous loop. Positioning of toggles on children’s clothing is to be seriously viewed in order to
prevent injury and discomfort during wear. For instance, toggles positioned at the knee area are
not acceptable.

Decorative purpose: Pig nose (cord lock) and spring loaded toggles can be used on children’s
clothing as a decorative application. The cord and toggle must sit flush to the garment and must
be securely contained within the loop of the cord so it cannot be removed from the garment. The
cord must be securely bartacked no more than 1 cm / 3/8” from the eyelet or button hole.

Functional purpose: Pig nose (cord lock) and spring loaded toggles can sometimes be used on
children’s clothing as a functional application. The loop circumference can not extend more than
7.5 cm (3”) when cord is cinched to the body and must fully retract inside waistband when the
garment is fully extended. The toggle can not be attached to a continuous drawstring.

8. Fixed Bows

In order to ensure fixed bows are securely attached to garments a minimum pull force
requirement of 15 lbs must be achieved for children’s 3 years and under. Fixed bows must be
tested for colour fastness to water. Bows must be secured at the centre with a bartack.
The tail ends of the bow must be secured with either a double turn secured with a lockstitch, a
heat seal or laser cut. Fixed bows can be used on all areas of a garment. However, there are
maximum length restrictions to consider for the loop and tail lengths of bows when used on
children’s clothing. For instance, in the hood area, loop (4 cm) and tail (2.5 cm) differs from waist
area wherein accepted values are 7.5 cm and 7.5 cm, respectively.

9. Buttons

Wood / cork / leather / mother of pearl (shell) / glass or other non-durable buttons must not be
used on children’s clothing. Buttons can not have rough or sharp edges and must be free from
rust and contamination. They should not contain toxic elements, objectionable surface coating,
and must comply with the European Nickel Directive (94 / 27 / EC). With a view to ensure buttons
are securely attached to the garment, a minimum pull force of 20 lbs is required for children 3
years and under. Two piece multi-component buttons and fabric covered buttons must not be
used on children clothing 3 years and under.

All buttons must be attached using a lockstitch attach machine. Two hole buttons must have 14-
16 stitches and four hole buttons must have 24-26 stitches. Four hole buttons must be stitched
through each hole and only core spun polyester sewing thread to be used when attaching
buttons. Bobbin thread should be a different colour than the needle thread, which enables easy
verification of the lockstitch application. For buttons that require a harsh wash, it is recommended
that buttons are attached after washing to avoid damage to either the button or garment.

10. Pom-Poms and Fringe

Traditional pom-poms and fringe made from hand knitting / sweater yarns and those constructed
with metal components are not permitted for children 3 years and under. Stuffed pom-poms made
from fabric are acceptable. The filling must be new and completely enclosed inside a lining. In
order to ensure secure attachment to garments, a minimum pull force of 15 lbs is required. Pom-
poms and / or fringe must not be attached to the end of a drawstring, cord or tie with free ends.

11. Decorative trims and embellishments

Appliqué and Embroidery: Appliqué can be edge stitched or stitched at the centre. In case of
centre stitched, it must be lockstitch attached and should withstand a minimum pull force of 15
lbs.

Applique – edge stitched Applique – centre stitched

Embroidery is to be backed with interlining if the reverse is scratchy and comes in direct contact
with the skin. In backing is utilized it must be permanently attached so it cannot pose a potential
choking hazard.
Bead : Individual beads can be stitched by hand for 4 years and above by using core spun
polyester. Those must be securely attached with double thread and the end of thread is to be
knotted.

Maximum thread end of 1 cm (3/8”) and minimum 0.5 cm (3/16”) are acceptable but floats over 1
cm (3/8”) are not acceptable. Beads should not contain toxicity or any undesirable surface
coating. There should not be any loss in colour, loss of bead and peeling or delamination after
wash or drycleaning.

Sequins: Individual sequins can be attached in one part of garment (1 year and above) or all over
the garment (4 years and above) by hand. Those must be securely attached with double thread
and the end of thread is to be knotted. Sequins can also be attached by machine, individually (1
year and above) or in a row (4 years and above).
They must be lockstitch attached and secured. In both hand and machine attachment, maximum
thread end of 1 cm (3/8”) and minimum 0.5 cm (3/16”) are acceptable but floats over 1 cm (3/8”)
are not acceptable. Sequins should not contain toxicity or any undesirable surface coating. There
should not be any loss in colour, loss of sequin and peeling or delamination after wash or
drycleaning.

Jewel : A jewel is considered to be greater than 5 mm. If less than 5 mm, it is considered a bead.
Individual jewels can be attached to the garment by hand for children’s garment of 4 years and
above. Jewels must have attachment holes at each side. It is attached by stitching at least three
times at either side.

Those must be attached with double thread and the end of thread is to be knotted. Maximum
thread end of 1 cm (3/8”) and minimum 0.5 cm (3/16”) are acceptable but floats over 1 cm (3/8”)
are not acceptable. Jewel should withstand a minimum pull force of 15 lbs. Jewels should not
contain toxicity or any undesirable surface coating. There should not be any loss in colour, loss of
sequin and peeling or delamination after wash or drycleaning.
Heat Transfer Diamante (Rhinstone) and Stud guidelines :
Those are suitable for 4 years and above. Right temperature, time and pressure are to be
maintained to secure attachment.

They should not contain toxicity or any undesirable surface coating. There should not be any loss
in colour, loss of diamante (rhinestone) or metal stud and peeling or delamination after wash or
drycleaning.

General Wearing Apparel Flammability Requirements

All children’s wearing apparel must comply with any and all State and/or Federal guidelines,
regulations, and laws, including but not limited to reasonable and representative testing as
required under CFR Title 16, Part 1610, and must be classified as Class 1: Normal Flammability.

Figure of the instrument :

Children’s Sleepwear / Loungewear Flammability Requirements

All children’s sleepwear sized 0-18 must comply with any and all State and/or Federal guidelines,
regulations, and laws, including but not limited to CFR Title 16, Part 1615 and 1616. if the
packaging or any printed design on a children’s garment suggests sleeping, it will be considered
sleepwear, and must pass testing to comply with the requirements set forth in CFR Title 16, Part
1615 and 1616. Loungewear is considered sleepwear, and therefore must follow the same
requirements as sleepwear. CPSC is the final authority for determining what loungewear is.
Federal Flammability requirements for children’s sleepwear are outlined as follows:

Sleepwear for infants 9M and younger are exempt from the Children’s Sleepwear Flammability
requirements if the following two conditions are true :

1. The sleepwear is a one piece garment that is not longer than 64.8 cm (25 ¾ inches), or a
two piece garment with no piece longer than 40 cm (15 ¾ inches).
2. The sleepwear includes a label stating the age (in months) of the children for whom it is
intended.

Even though the sleepwear for infants under 9M is exempt from the children’s sleepwear
regulations, the sleepwear must still meet the general wearing apparel flammability requirements.

Children’s sleepwear sized above 9M and up to 6X and size 7 to 18 must meet the flammability
requirements of 16 CFR 1615, Standard for the Flammability of Children’s Sleepwear Sizes 0-6X
and 16 CFR 1616, Standard for the Flammability of Children’s Sleepwear Sizes 7 through 14,
respectively.

Although tight fitting garments are exempt from the flammability requirements of 16 CFR 1615 &
1616, they must meet the sizing and labeling requirements specified in 16 CFR 1615 & 1616 and
meet Class I Normal Flammability under 16 CFR 1610 for general Wearing Apparel.