1. Childrens Upper Outerwear with Drawstrings

Definitions

Neck area: means the area one inch above and below the seam between the body of a garment and the collar or hood.

Upper outerwear: means clothing, such as jackets and sweatshirts, which is generally intended to be worn over other garments.

Childs Outer Garment: An outer garment (raincoat, overcoat, anorak or other outer garment for use as outer wear) having a measurement not exceeding 44 cm (17.32 in.) across the chest when the finished garment is laid out as flat as possible without distorting its natural two-dimensional shape and buttoned or otherwise fastened as it is designed to be in normal wear.

Drawstring: Cord, chain, ribbon, string or tape of any textile or non-textile material that passes through a channel, loop(s) or eyelets(s) or similar, to adjust the size of the opening, or part of the garment or to fasten the garment itself. The ASTM definition specifies that a drawstring is a non-retractable cord. The drawstrings usually pull the clothing tight to prevent air and/or water (rain or snow) seepage. The tightening systems (non-exhaustive list) can be found on the following garment parts,

Upper neck hem

Hood hem

Jacket or trouser waist-tightener

Trouser or leg gaiter

Glove wrist tightener, etc

Different kinds of hoods and collars may require more drawstrings and locks.

Decorative Cord: Cord, chain, ribbon, string or tape of any textile or non-textile material with or without embellishment, such as toggle, pom-pom, feather or bead, of fixed length and not intended to be used to adjust the size of the opening or to fasten the garment itself.

Functional Cord: Cord, chain, ribbon, string or tape of any textile or non-textile material with or without embellishment, such as toggle, pom-pom, feather or bead, of fixed length, which is used to adjust the size of the opening, or part of the garment or to fasten the garment itself.

Hood: A loose, pliable covering for the head, either detachable or permanently attached to upper outerwear.

Loop: Cord or narrow strip of fabric curved in shape, which may be fixed or adjustable in length, where both ends are attached to the garment.

Sash: Drawstring, decorative or functional cord of textile material of not less than 30 mm (~1 inch) in width worn around the waist of a garment and tied into a bow.

Toggle: Wooden, plastic, metal or otherwise composed piece attached to, or present on, a drawstring for decorative purposes or to prevent the drawstring from being drawn through its channel.

Introduction

Drawstrings on childrens apparel can be hazardous and have led to deaths and injuries. Therefore several countries have taken measures through standards or safety advisories to reduce the risk of marketing and sale of garments with drawstrings that can be hazardous or even fatal to children. However, many retailers and manufacturers sell apparel in multiple countries and variations in drawstring requirements among various countries can be confusing. One set of requirements that cover their needs for selling in the United States (US), Canada and European Union (EU) would be ideal. Drawstrings on childrens apparel can be hazardous and have led to deaths and injuries. Drawstrings can catch on playground equipment, cribs, bus doors, etc. and potentially strangle a child. Therefore Canada, the United States and the European Union have all issued standards or guidelines to minimize the risk of accidental entrapment by drawstrings or cords.

Death and Injuries that can be caused by Childrens Upper

Outerwear with Drawstrings

Waist drawstrings can become

Hood and neck drawstrings can become

entangled in a bus door

entangled on playground equipment,

cribs, and other common items.

Managing loops/cords by cutting

it short and separating them

Country: United States of America (USA)Guidelines for Drawstrings on Childrens Upper OuterwearThe U.S. Consumer Product Safety Commission (CPSC) is an independent federal regulatory agency that was created in 1972 by Congress in the Consumer Product Safety Act. The CPSC issued a voluntary guideline (US Consumer Product Safety Commission Guidelines for Drawstrings on Childrens Outerwear) and ASTM issued a standard (ASTM F1816-97, Standard Safety Specification for Drawstrings on Childrens Upper Outerwear) in 1997.

In addition to the CPSC/ASTM guidelines, the states of New York and Wisconsin have implemented mandatory laws. Wisconsins standard applies to a broader range of sizes (0-16) than the CPSC/ASTM and New York (2T-12). Additionally, the New York requirements for waist and bottom drawstrings apply to all childrens clothing, as opposed to only childrens upper outerwear for CPSC/ASTM and Wisconsin.

CPSC recommends that parents or caregivers completely remove the hood and neck drawstrings from all childrens upper outerwear, including jackets and sweatshirts, sized 2T to 12.

CPSC recommends that consumers purchase childrens upper outerwear that has alternative closures, such as snaps, buttons, Velcro, and elastic.

\ CanadaCanadas advisory notice (Potential Strangulation from Drawstrings on Childrens Outerwear) mirrors the ASTM standard (ASTM F1816-97).

When selling apparel in throughout the US and CanadaCanada has adopted ASTM F1816-97. However, Wisconsins drawstring requirements are more stringent than that of the CPSC/ASTM and New York in most areas. Most notably, Wisconsins requirements apply to a wider size range (0-16). However, New Yorks requirements for the waist or bottom apply to all childrens clothing (not just childrens upper outerwear as in the PSC/ASTM and Wisconsin requirements).

Therefore, it is recommended that a combination to include the most stringent of requirements be followed, as below:

Country: European Nations (EN)In France, investigations have shown that garment drawstrings can cause two types of accidents, i.e.,

The strangulation of young children when a drawstring is caught in community equipment (playgrounds)

Eye injuries or dental fractures to secondary school children when their hanging, elastic, hard-tipped drawstrings on their hoods are pulled

The European Commission instituted a standard (EN 14682: 2004, Safety of Childrens Clothing Cords and Drawstrings on Childrens Clothing-Specifications) which limits the use of drawstrings in childrens apparel. This standard was adopted as a national standard by member states in June 2005.

The standard was published in the Official Journal of the European Union (OJEU) 2006/C171/04 of 22 July 2006. As a result, clothing in compliance with the safety requirements prescribed by this standard are now presumed to be in compliance with the general safety requirement of the General Product Safety Directive (GPSD), 2001/95/EC of the European Parliament and of the Council of 3 December 2001 on general product safety.

Publication in the OJEU, does not make it a legal requirement that clothing must comply. However, the General Product Safety Directive is a legal requirement implemented in European countries and having articles that comply with harmonized standards such as EN 14682 is a way of demonstrating that the product is safe for aspects covered by the standard.

Therefore, if a product does not comply with EN 14682, the seller could be prosecuted for not complying with the requirements of GPSD as this would be considered to be a relevant standard. In other words, if a product does not comply with EN 14682, the seller cannot be prosecuted for noncompliance to EN 14682 per se but could be prosecuted for not complying with the requirements of GPSD as this would be considered to be a relevant standard and requirements of EN 14682 is a means to ensure a safe product.Country: United Kingdom (UK) In Great Britain, the SI 1976 No. 2 regulation on childrens clothing (hood drawstrings) bans drawstrings in the fabric hem of the hoods on garments where chest size is smaller than 44 centimeters. The British 1997 standard BS 1907 referring to this regulation,

Forbids drawstrings or decorative ribbons longer than 14 centimeters on clothing for children under 3, and prohibits hard buckle tips longer than 5 centimeters. Apparel must not have strings either decorative items or drawstrings - hanging out of garment back.

Sets down exact string measurements according to location of the drawstring on a garment. Drawstrings cannot exceed 14 centimeters at the waist when the garment is fully loosened. Bottom-half drawstrings cannot be longer than 8 centimeters.

Recommends spring clips and wide vents. The standard forbids the use of any aglet likely to increase entrapment (knots or duffel-coat toggle-fastenings, for instance). Standard neck fastenings like the ones adults wear are not appropriate for children under 5. The fastenings must be easily detachable in case of entrapment. Neck fastenings must be removable (hence the recommendation for Velcro or snap fastenings).

Specifies that nightwear for children under 3 should not have hoods because they obstruct the childs line of view and hearing. Clothing with hoods must be designed to avoid said inconveniences. Hoods should preferably come off at the slightest pressure.

Hood Cords for Childrens Clothing, SI 1976 No. 40 of Ireland is very similar to UK regulations. Therefore, products distributed in the UK/Ireland must comply with this requirement in addition to the requirements of EN 14682.

Country: FinlandFinland has no regulations. However on November 18, 1998, the National Consumer Association (NCA) issued a press release calling for a ban on the import of childrens apparel with drawstrings around the neck. Several children suffered near suffocation due to drawstrings.

The NCA drew on the example of Great Britain and, in agreement with Finnish manufacturers, called for safer childrens apparel by pointing to the fact that Finnish suppliers were already selling articles with other fastenings (Velcro, elastic bands, and so on) for older children. Some day-care centers have already acted on this and asked parents to cut off the drawstring on very young childrens garments. Manufacturers seem to be aware of the hazards and have designed the appropriate clothing.

Regulations when selling in throughout the US, Canada and the EU

Certain parts of the EU requirements are more stringent than the US/Wisconsin/NY requirements:

All size ranges (ages up to 14) are regulated.

Drawstrings hanging below the hip, cannot hang below the lower edge of the garment.

Drawstrings cannot protrude from the bottom hem of coats, trousers or skirts that are designed to finish at the ankle.

The standard also specifies drawstring requirements for sleeves and other parts of the garment.

For hood and neck areas, EU standard covers all ages up to 14 years whereas US requirements covers up to 12 years. (Note: Age is used as an approximation as the measurement guidelines represent a retailer's average customer. In the smaller sizes (up to size 8), the size translates to approximate age.For US sizing, size 10/12 is generally for ages 9-10, 14/16 is generally ages 11-12 and size 18 is generally 13-14 years. However, certain portions of the US (including New York and Wisconsin) requirements are more stringent:

Only 3 inches of the drawstring are allowed to extend outside the drawstring channel, as opposed to 5.5 inches (140 mm) for the EU in the waist area.

For hood and neck areas, the EU allows loop drawstrings for ages 7-14 whereas US does not allow any drawstring for sizes 2T-12-CPSC/NY (approximate age 10) and 0-16-WI (approximate age 12).

However, the UK national legislation does not allow drawstrings and cords (ties) for hood and neck areas in childrens outer wear with chest measurement not exceeding 44 cm (approximately up to 13 years of age).

Therefore, it is recommended to follow one separate specification for US/Canada and one for the EU. Drawstrings specifications for childrens apparel are specified in the following two (2) charts.A research report published in November 1999 entitled "Choking Risks to Children" evaluated the effectiveness of the small parts cylinder test in preventing choking accidents to children under four from small toys or parts Garments.

The Garment should not have any accessories exceeding the size mentioned below.

AUSTRALIA AND NEW ZEALAND

CHOKING HAZARD INHALATION AND INGESTION.

This is a hazard caused by a component or failure of a component, which if inhaled or ingested by a child can create an obstruction in the airway, or poses a risk of perforation in the esophagus.

Toy Standard AS/NZS ISO 8124.1:2002)

Small Parts

Small parts include non-porous material smaller than 3cm diameter.

Small parts must be secure and not able to be removed from the garment.

Known Examples:

Buttons, studs, eyelets, toggles.

Trims beads / sequins / pompoms / animal eyes or noses.

Buckles / zip pullers.

Battery case for sound box.

Filling in toys.

Decorative motifs, eg: butterflies; flowers.

. TOGGLES

_ Must securely attached

_ Must pass bite test (as per AS1647.2).

_ Prohibited around neck area (3 yrs and under).

_ Cord must be securely attached at both ends preventing toggle from falling off or pulled off.

TRIMS

ZIPS

Glass prohibited

Zip pull to pass bite test (as per AS1647.2)

Plastic zips are recommended for age 3 years and under, unless harsh wash item.

Zips must be Burr free

Nylon Zip not to have excess teeth beyond top stop

FASTENERS

Ties to be kept to a minimum length, to be fit for purpose, eg: enough length to tie a bow, if relevant to product.

Ribbon ends to be heat-sealed or bar tacked.

Rope to be securely knotted at ends.

Mock ties preferred in lieu of draw cord.

Ties in hood & hat to be secured Prohibited for newborn.

Chin ties to be open-ended (not looped).

Elastic relaxed measurement to meet minimum size requirements to prevent lack of circulation.

Soft quality elastic preferred for newborn and sleepwear.

Binding ends to be knotted or bar tacked.

Elastic Cord to be secured at opening to be non-functional, loop to be no more than 2.5cm

Non-stretch cord preferred

Velcro to be positioned to avoid contact with skin, Corners to be rounded, Use soft quality Velcro

FLOATING / LOOSE THREADS:

Goods contain no floating threads in the toe or finger area for infants up to 12 months of age.

The goods contain no loose and or floating threads longer than 1cm on the inside or outside of the remaining article for infants up to 18 months and 2.5cm over 18 months.

Terry toweling: Looped yarn to break at 3cm when pulled by hand not to be able to be continuously pulled to form a loop.

Loose or Untrimmed Threads in Feet, Hands or Crotch : PROHIBITED

BELTS

Chain Belt Sold with Garment: Prohibited for 3yrs and under.

Prohibited for 3yrs and under : Prohibited for 3yrs and under.

Informal Comparison Between Various U.S. Drawstring Standards

ASTM Standard (F 1816-97)1 Wisconsin Law (ATCP 139) 2 New York (A10866) (Amendment to A01865 from 2002).

How implemented Voluntary national standard

Already implemented. State regulation.

Effective Date: January 1, 2000. State law.

Effective upon enactment.

Neck area prohibitions No drawstrings in the hood and neck area of certain childrens clothing.

Only childrens upper outerwear.

Sizes 2t to 12.

No drawstrings in the hood and neck area of all childrens clothing.

All childrens clothing.

Sizes 0 to 16.

No drawstrings in the hood and neck opening of certain childrens clothing.

All childrens clothing.

Sizes 0 to 12.

Waist/bottom prohibitions Drawstrings at waist and bottom of certain childrens clothing subject to limitations.

Only childrens upper outerwear.

Sizes 2t to 16

Drawstrings may not extend more than 3 inches (75mm) past channel when garment is expanded to fullest width.

No toggles, knots, or other attachments at free ends.

Bartacked if drawstring is one continuous string.

Drawstrings at waist and bottom of certain childrens clothing subject to limitations.

Only childrens upper outerwear.

Sizes 0 to 16

Drawstrings may not extend more than 3 inches past channel when garment is expanded to fullest width.

No toggles, knots, or other attachments at free ends.

Drawstring is sewn to garment at midpoint of channel so it cannot be pulled out of channel.

Drawstrings at waist and bottom of all childrens clothing subject to limitations.

All childrens clothing.

Sizes 2t to 16

Drawstrings may not extend more than 3 inches past channel when garment is expanded to fullest width.

No toggles, knots, or other attachments at free ends.

Attached to garment at midpoint of drawstring.

Exemptions Upper outerwear with fully retractable drawstrings. None. None

Definitions Definitions cover the terms: bartack, bottom of upper outerwear, drawstring, hood, neck area, neck opening, toggle, upper outerwear, and waist. Definitions cover the terms: neck area, upper outerwear.3 These terms are modeled after ASTM definitions. Definitions cover the terms: sell at retail, drawstring, tie, hood, neck opening, toggle, and aglet.

Note: Ties are not considered drawstrings and aglets are not considered toggles.