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Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile) Safety of toys or apparel or others articles (Mechanical and physical properties) This is EN 71 part-1 specifies requirements and methods of test for mechanical and physical properties of toy s and children wear. The standard applies to toys for children, toys being any product or material designed or clearly intended for use in play by children of less than 14 years of age. It refers to new toys taking into account the period of foreseeable and normal use and when the toys are used as intended or in a foreseeable way, bearing in mind the normal behavior of children. It includes specifics requirements for toys intended for children under 36 months and for children who are too young to sit up unaided. Soft filled toys with simple features intended for holding and cuddling are, for the purposes of this standard, considered as toys intended for children under 36 months. This standard also specifies requirements for packaging, marking and labeling. Torque test If a component can be gripped between thumb and forefinger, apply a torque gradually to the component within a period of 5 s in a clockwise direction until either: a) A rotation of 180º from the original position has been attained b) A torque of 0.34 Nm is reached. Maintain the maximum rotation or required torque for 10 seconds. Permit the test component to return to a relaxed condition. Repeat this procedure in an anticlockwise direction. Projections, part or assemblies that are rigidly mounted on an accessible rod or shaft designed to rotate along with the projections, parts, or assemblies shall be tested with the rod or shaft clamped to prevent rotation. If a component which is attached by a screw thread becomes loosened during application of the required torque is exceded or the part disassembles or it becomes apparent that the part will not disassemble. Requirement: Torque test is done for quality (performance) aspect or Safety aspect (children item). Requirement depands on test method, button or item diameter, item type, zipper size, age range. It also varies buyer to buyer. According to EN 71-1: A rotation of 180º from the original position is also-Pass (For button, bow, cord, drawstring etc.) Passed with 0.34 Nm for 10 seconds But buyers have some special requirement like; 0.45Nm, 0.50 Nm for 10 seconds Tension test When dealing with soft materials, for example, the clamps used to attach the mass or force to the component can cause damage to the component or material to which the component is fixed and compromise the test. If so, the following tests have to be carried out on a new toy or children wear. Apparatus A tensile testing machine or a dead weight arrangement, with means of applying forces up to at least 90 N with an accuracy of 2 N. Clamps and straps Feeler gauge, with a thickness of 0.4 mm±0.02mm and an insertion edge radius of approximately 3mm. Feeler gauge

Safety of Toys or Apparel or others articles

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Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Safety of toys or apparel or others articles (Mechanical and physical properties)

This is EN 71 part-1 specifies requirements and methods of test for mechanical and physical

properties of toy s and children wear. The standard applies to toys for children, toys being any

product or material designed or clearly intended for use in play by children of less than 14 years

of age. It refers to new toys taking into account the period of foreseeable and normal use and

when the toys are used as intended or in a foreseeable way, bearing in mind the normal behavior

of children.

It includes specifics requirements for toys intended for children under 36 months and for children

who are too young to sit up unaided. Soft filled toys with simple features intended for holding

and cuddling are, for the purposes of this standard, considered as toys intended for children

under 36 months. This standard also specifies requirements for packaging, marking and labeling.

Torque test

If a component can be gripped between thumb and forefinger, apply a torque gradually to the

component within a period of 5 s in a clockwise direction until either:

a) A rotation of 180º from the original position has been attained

b) A torque of 0.34 Nm is reached. Maintain the maximum rotation or required torque for 10

seconds. Permit the test component to return to a relaxed condition. Repeat this procedure in

an anticlockwise direction.

Projections, part or assemblies that are rigidly mounted on an accessible rod or shaft designed to

rotate along with the projections, parts, or assemblies shall be tested with the rod or shaft

clamped to prevent rotation.

If a component which is attached by a screw thread becomes loosened during application of the

required torque is exceded or the part disassembles or it becomes apparent that the part will not

disassemble.

Requirement: Torque test is done for quality (performance) aspect or Safety aspect (children

item). Requirement depands on test method, button or item diameter, item type, zipper size, age

range. It also varies buyer to buyer.

According to EN 71-1:

A rotation of 180º from the original position is also-Pass (For button, bow, cord, drawstring etc.)

Passed with 0.34 Nm for 10 seconds

But buyers have some special requirement like; 0.45Nm, 0.50 Nm for 10 seconds

Tension test

When dealing with soft materials, for example, the clamps used to attach the mass or force to the

component can cause damage to the component or material to which the component is fixed and

compromise the test. If so, the following tests have to be carried out on a new toy or children

wear.

Apparatus

A tensile testing machine or a dead weight arrangement,

with means of applying forces up to at least 90 N with an

accuracy of 2 N.

Clamps and straps

Feeler gauge, with a thickness of 0.4 mm±0.02mm and an

insertion edge radius of approximately 3mm.

Feeler gauge

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Dead weight Equipment:

Pull force test machine of a well known brand. It is preferable to use a table machine with the

turning wheel on the side instead of at the top. Internally use the brand SafQ/SafGuard

Test Procedure

Dead weight arrangement

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

If a requirement indicates that torque test and tension test shall be performed, then the tension

test shall follow after the torque test and be performed on the same component of the toy.

Establish if the component to be tested is grippable by inserting the feeler gauge between the

component and the underlying layer or body of the toy at an angle between 0º and 10º from the

toy surface using a force of 10N±1N. If the gauge can be inserted more than 2mm the component

is to be judged as grippable.

If the component is grippable, affix a suitable clamp behind the component, taking care not to

damage the attachment mechanism or the body of the toy. Fasten the toy in the test apparatus and

apply a tensile force to the component to be tested by means of a clamp or by other means.

Apply a force of:

50N±2N when the largest accessible dimension is 6mm or less; or

90N±2N when the largest accessible dimension is greater than 6mm.

Apply the force gradually within a period of 5seconds. Maintain the force for 10 seconds.

Determine whether the component has become detached.

Requirement: Tension test is done for quality (performance) aspect or Safety aspect (children

item/Children safety). Requirement depands on test method, button or item diameter, item type

(metal or plastic), age range. It also varies buyer to buyer. According to EN 71-1:

50N±2N when the largest accessible dimension is 6mm or less; or

90N±2N when the largest accessible dimension is greater than 6mm.

But buyers have some special requirement like; 70N for 10 seconds or >100N or >200N

Drop Test

Drop the toy or articles five times through a height of 850 mm ±50 mm on to a 4 mm thick steel

plate, which has a 2mm thick coating of Shore a hardness 75±5 as measured according to EN

ISO 868 or ISO 7619 and which is placed on a non flexible horizontal surface. Prior to release,

orientate the toy in a position that allows the most onerous impact. Finally examine the casing of

toys or articles intended for children too young to sit up unaided has split or cracked. Examine

whether small parts, sharp points, sharp edges or hazardous driving mechanisms have become

accessible.

Requirement: Must durable of metal/plastic materials after drop test. It must remain 100%

function, no cracks or failure.

Impact Test

Place the toy in the most vulnerable position on a plane, horizontal steel surface and drop a

metallic weight with a mass of 1 kg±0.02 kg, distributed over an area of diameter 80 mm±2mm,

through a distance of 100 mm ±2mm onto the toy. Carry out the test once. Examine whether the

casing of toys intended for children too young to sit up unaided has split or cracked. Examine

whether small parts, sharp points, sharp edges or hazardous driving mechanisms have become

accessible.

Compression test

Any accessible area on the surface of a toy that is inaccessible to flat surface contact during the

drop test or tip over test shall be subjected to the compression test. Place the toy on a horizontal

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

rigid surface with the part of the toy to be tested uppermost. Apply a compression force of

110N±5N through a rigid metal disc 30 mm±1.5mm in diameter to the area to be tested. Ensure

that the perimeter of the disc is rounded. Apply the force gradually within a period of 5s.

Maintain the force for 10s. Finally examine the casing of toys intended for children too young to

sit up unaided has split or cracked. Determine whether small parts, sharp points, sharp edges or

hazardous driving mechanisms have become accessible.

If any part of the toys or apparel or other articles has to be removed or disassembled in order to

torque, tension, impact, flexure, Compression, Drop test then accessible sharp point or edge

being tested and shall be placed into the small part cylinder for determining whether an article is

hazardous (choking, aspiration, or ingestion) to children because of small parts.

Requirement: Must durable of materials after compession test. It must remain 100% function,

no cracks or failure.

Sharpness of points

A point tester is applied to an accessible sharp point and it is observed whether or not the point

being tested penetrates a specified distance into the sharp point tester.

Requirement: Shall have no sharp points, other than those required for function.

If any attachment item fails after use and abuse testing need the test, if the red indicator of the

sharp point tester lights off during the test, the point is a no sharp point then –Pass or meets the

standard.

Without this method we can visually observd any garment or articles that it has no sharp point or

broken needle is present or pose to hazard.

Sharpness of edges

A self-adhesive tape is attached to a mandrel which is then rotated for a single 360º revolution

along the accessible edge being tested. The tape is then examined for the length of cut.

Requirement: Shall have no sharp edges, other than those required for function.

If any attachment item fails after use and abuse testing need the test, after remove the tape from

the mandrel without enlarging any cut in the tape or causing any score in the tape to become a

cut. Measure the length of tape that is cut, including any intermittent cuts. Measure the length of

tape which has contacted the edge during the test. Thus calculate the percentage length of the

tape which has been cut during the test. If this is more than 50% of the contact length, the edge is

indentified as sharp.

Length of tape that is cut less than 50% of the contact length, the edge is not indentified as

sharp.then –Pass or meets the standard.

Without this method we can visually observd any garment or articles that it has no sharp edge or

broken metal is present or pose to hazard.

Small parts

Any components or pieces (excluding paper, fabric, yarn, fuzz, elastic, and string) which have

become detached from the article as a result of the use and abuse testing(torque, tension, impact,

compression, drop, flexure) shall be placed into the cylinder, one at a time.

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Place the toy, small parts or component, without compressing and in any orientation, in a

cylinder having dimentions as indicate figure-1

Determine whether the toy, small parts or component fit entirely within the cylinder.

Requirement: Any components or pieces (excluding paper, fabric, yarn, fuzz, elastic, and string)

which have become detached from the article as a result of the use and abuse testing(torque,

tension, impact, compression, drop, flexure) shall be placed into the cylinder, one at a time.

If it fits entirely within the small parts cylinder in any orientation (without being compressed),

then the item must be failed.

Consumer Product Safety Improvement Act (CPSIA)-Children’s Product Safety

According to Consumer Product Safety Improvement Act (CPSIA) A “children’s product”

means a consumer product designed or intended primarily for children 12 years of age or

younger. In determining whether a consumer product is primarily intended for a child 12 years of

age or younger, the following factors will be considered:

• A statement by the manufacturer about the intended use of the product, including a label on the

product if such statement is reasonable.

• Whether the product is represented in its packaging, display, promotion or advertising as

appropriate for use by children 12 years of age or younger.

• Whether the product is commonly recognized by consumers as being intended for use by a

child 12 years of age or younger.

As per U.S Code of Federal Regulations title 16 part 1500.48, 1500.49, 1500.51, 1500.52,

1500.53 and 1501 the hazard of sharp points, sharps edges, impact (b), Bite test (c), flexure (d),

torque (e), tension (f), compression (g) and small parts are assessed both before and after

applicable use and abuse test. In 16 CFR 1500 (a) is the first section which indicate application

of test under different age group. According to CPSIA all children items or article will be

subjected to the tests providing the most stringent requirements. If an article is not age-labeled in

a clear and conspicuous manner or, based on such factors as marketing practices and the

customary patterns of usage of a product by children, is inappropriately age labeled, and is

intended or appropriate for children 96 months of age or less, it will also be subjected to the most

Fig-1 Small part cylinder

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

stringent test requirements. According to Consumer Product Safety Commission guide line a

children item need Torque for small articles 16 CFR part 1500.51-53(e) 0-18 month 2 in-lbs, 18-

36 month 3in-lbs, 36-96 month 4in-lbs. Tension for small articles 16 CFR part 1500.51-53(f),

tension requirement 15 lbs for 10 seconds. If Torque fails no need tension. If the small articles

fail in torque or tension then as per US code of federal regulation title 16 part test Sharp point

(1500.48), Sharp edge (1500.49), Small part (1501), the hazard of Sharp point, Sharp edge,

Small part are assessed both before and after applicable use and abuse tests.

It is intended for use by children that by reason of their functional purpose necessarily present

the hazard of sharp points and that do not have any non-functional sharp points.

Articles, intended for use by children that by reason of their functional purpose necessarily

present the hazard of sharp metal or glass edges and that do not have any non-functional sharp

metal or glass edges are exempt from this section. Examples of these are children's ice skates and

children's cutlery.

Small parts these requirements applies to all articles intended for use by children under 3 years

(36 months) of age which presents a choking, aspiration, or ingestion hazard because of small

parts that are introduced into interstate commerce after the effective date. Small parts – all

articles intended for use by children under 3 years (36months) of age which can totally place into

the small parts cylinder without any compressing it.

Impact Test

Except as Large and bulky toys of this section, toys or other articles having a weight 3 lbs or 4

lbs or 10 lbs shall be subject to this test.

Impact medium: The impact medium shall consist of a 1⁄8-inch (0.3-centimeter) nominal

thickness of type IV vinyl-composition tile, composition 1- asbestos free, as specified by

paragraphs 1.2 and 3.1.4 of Interim Amendment- 1(YD), dated November 14, 1979, to the

Federal Specification entitled Tile, Floor: Asphalt, Rubber, Vinyl, Vinyl-Asbestos, SS-T-312B,

dated October 10, 1974,1 over at least a 2.5-inch (6.4-centimeter) thickness of concrete. The

impact area shall be at least 3 square feet (0.3 square meter) for all age group. The Commission

recognizes that this specified impact medium is the equivalent of, and will yield the same impact

test results as, a surface covered with vinyl-asbestos tile meeting the requirements of Federal

Specification SS-T- 312A.

Method No Age group Weight of Sample No. of

drops

Drop Height

16 CFR 1500.51 0-18 months Less than 3lbs±0.01lb 10 4.5 feets±0.5 inch

16 CFR 1500.52 18-36 months Less than 4lbs±0.01lb 4 3.0 feets±0.5 inch

16 CFR 1500.53 36-96 months Less than 10lbs±0.01lb 4 3.0 feets±0.5 inch

Testing procedure (16 CFR 1500.51): Except Large and bulky toys, the toys or other articles

shall be dropped 10 times from a height of 4.5 feet ±0.5 inch (1.37 meters) onto the impact

medium described above. The toy shall be dropped in random orientation. After each drop, the

test sample shall be allowed to come to rest and shall be examined and evaluated before

continuing.

Testing procedure (16 CFR 1500.52): Except Large and bulky toys, the toys or other articles

shall be dropped four times from a height of 3 feet ±0.5 inch (0.92 meter) or onto the impact

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

medium described above. The toy shall be dropped in random orientation. After each drop, the

test sample shall be allowed to come to rest and shall be examined and evaluated before

continuing.

Testing procedure (16 CFR 1500.53): Except Large and bulky toys, the toys or other articles

shall be dropped four times from a height of 3 feet ±0.5 inch (0.92 meter) or onto the impact

medium described above. The toy shall be dropped in random orientation. After each drop, the

test sample shall be allowed to come to rest and shall be examined and evaluated before

continuing.

Requirement:

Bite test

Children 0-36 months

A toy (or component or any accessible portion thereof) that has an external dimension of 1.25

inches ±0.05 inch (3.18 centimeters) or less and a design configuration that would permit a child

to insert a portion into the mouth in any orientation up to a biting thickness of 1.25 inches ±0.05

inch (3.18 centimeters), for a penetration of at least 0.25 inch (0.635 centimeter), shall be subject

to this test.

Children over 36 but not over 96 months

A toy (or component) that is a mouth toy shall be subject to this test.

Test equipment: (for children 0- not over 96 months) Contact mechanism. The contact

mechanism shall be two metal strips or plates each measuring 0.25 inch ±0.002 inch (0.635

centimeter) high and each having a contact edge radius of 0.020 inch ±0.002 inch (0.05

centimeter), for at least a 150-degree cross-sectional arc. Loading device; the loading device

shall be a scale or force gauge having an accuracy of±0.5 pound (±225 grams).

Testing procedure: The test article shall be placed in the contact mechanism in any reasonable

position for a penetration of 0.25 to 0.5 inch (0.64 to 1.27 centimeters), which position utilizes

less than 180 degrees of the arc of the contact mechanism, for use by children 18 months of age

or less a test load increasing to 25 pounds ±0.5 pound (11.35 kilograms) shall be evenly applied

within 5 seconds. For 18 months to 36 months a test load increasing to 50 pounds ±0.5 pound

(22.74 kilograms) shall be evenly applied within 5 seconds. For children over 36 but not over 96

Months a test load increasing to 100 pounds ±0.5 pound (45.50 kilograms) shall be evenly

applied within 5 seconds. This load shall be maintained for an additional 10 seconds.

Requirement: Requirement depands on test method, or item type (metal or plastic), age range.

No detachment, breakage, cracks or failure after bite test.

Flexure test

This test shall be applied to each component of a toy containing metal wire(s), or for retention of

form if the component can be bent through a 60-degree arc by a maximum force of 15

pounds±0.5 pound (6.80 kilograms) applied perpendicularly to the major axis of the component

at a point 2 inches±0.05 inch (5 centimeters) from the intersection of the component with the

main body of the toy or at the end of the component if the component is less than 2 inches±0.05

inch (5 centimeters) long.

Testing procedure: The toy shall be secured in a vise equipped with vise shields that are

fabricated from 13- gauge cold-rolled steel or other similar material and that have a 0.375-inch

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

(0.95-centimeter) inside radius. The component shall then be bent through a 60-degree arc by a

force applied at a point on the component 2 inches±0.05 inch (5 centimeters) from the

intersection of the component with the main body of the toy or applied at the end of the

component if the component is less than 2 inches (5 centimeters) long. The component shall then

be bent in the reverse direction through a 120-degree arc. This process shall be repeated for 30

cycles at a rate of one cycle per two seconds with a 60-second rest period occurring after each 10

cycles. Two 120- degree arc bends shall constitute one cycle.

Requirement: Requirement depands on test method, component type, age range. No detachment

under a load of 16 lbs, (120 arc for 30 cycles at a rate of 1 cycles per 2 seconds, with a 60

seconds after each 10 cycles) but it also varies buyer to buyer.

Torque test This is 16 CFR 1500.50-53 specific test methods for graspable components that are attached to or

a part of children’s garments as well as the reasonably foreseeable damage or abuse to which the

articles (Graspable components - a component can be grasped by thumb and forefinger or teeth)

may be subjected.

Apparatus and Equipment

Torque Meter with accuracy of ± 0.23 kgf.cm

Screw Clamp

Safety Information

Laboratory coat as necessary

Goggle as necessary

Method

The test shall be applied to a previously untested sample.

The amount of torque shall be determined from below table.

Age Grade (months) Torque Force

0 to 18 2 0.2 in.lbf

18 to 36 3 0.2 in.lbf

36 to 96 4 0.2 in.lbf

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

If an article is marked, labeled, advertised, or otherwise intended for children of ages

spanning more than one of these age groups, the article will be subjected to the tests

providing the most stringent requirements. If an article is not age-labeled in a clear and

conspicuous manner or, based on such factors as marketing practices and the customary

patterns of usage of a product by children, is inappropriately age-labeled, and is intended or

appropriate for children 96 months of age or less, it will also be subjected to the most

stringent test requirements.

Determine the graspable components of the product

Use suitable clamp to fasten the object or component and then the torque gauge firmly

without destructing the integrity of the component.

The torque is applied about the major axis of the component evenly within a period of 5

seconds in a clockwise direction until either a rotation of 180 degrees from the original

position has been attained or the required torque exceeded.

The maximum rotation or required torque is maintained for an additional 10 seconds.

Remove the torque and the component permitted to return to a relaxed condition.

Repeat steps on above in counter-clockwise direction starting from the point at the relaxed

condition of the component.

For a component that is attached by the manufacturer or by the manufacturer’s instructions,

becomes loosen during the application of the required torque, continue to apply the torque

until either the required torque is reached or the part disassembles.

If this part disassembles and exposes an accessible component that can be grasped as above,

repeat the torque test on that component.

Reporting Criteria

Report the broken part, if any.

Determine and report the hazard such as sharp edges, sharp points and small parts according to

16 CFR 1500.48, 49 and 1501, if any.

Requirement: Torque test is done for quality (performance) aspect or Safety aspect (children

item). Requirement depands on test method, button or item diameter, item type, Zipper size, age

range. It also varies buyer to buyer.

A rotation of 180º from the original position is also-Pass (For button, bow, cord, drawstring etc.)

According to 16 CFR 1500 (51-53):

Age Grade (months) Torque Force

0 to 18 Passed with 2 0.2 in.lbf for 10 seconds

18 to 36 Passed with 3 0.2 in.lbf for 10 seconds

36 to 96 Passed with 4 0.2 in.lbf for 10 seconds

But buyers have some special requirement like; 4.4 in-lbs or 4.6 in-lbs for 10 seconds

Tension test

This is 16 CFR 1500.50-53 specific test methods for simulating normal use of textile garment

and other articles intended for use by children as well as the reasonably foreseeable damage or

abuse to which the articles (Graspable components - a component can be grasped by thumb and

forefinger or teeth) may be subjected.

Apparatus and Equipment

Dial Push-Pull Gauge / Digital Force Gauge accuracy of ± 0.5lbf

Tension Test Clamp/ Seam Clamps

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Safety Information

Laboratory coat as necessary

Goggle as necessary

Method

The test shall be conducted with the test sample used in the torque test.

The amount of force shall be determined from below table.

Age Grade (months) Tension Force

0 to 18 10 0.5 lbf

18 to 36 15 0.5 lbf

36 to 96 15 0.5 lbf

If an article is marked, labeled, advertised, or otherwise intended for children of ages

spanning more than one of these age groups, the article will be subjected to the tests

providing the most stringent requirements. If an article is not age-labeled in a clear and

conspicuous manner or, based on such factors as marketing practices and the customary

patterns of usage of a product by children, is inappropriately age-labeled, and is intended

or appropriate for children 96 months of age or less, it will also be subjected to the most

stringent test requirements.

Determine the graspable components of the product or the components that the tension test

is applied subsequent to the torque test.

Choose and attach the appropriate tension test clamp to the component to be tested such

that the structural integrity of the bond between the main body and the component is

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

unaffected.

Apply evenly the force within a period of 5 seconds, parallel to the major axis of the test

component, until the required force is reached, and then maintain for additional 10

seconds.

Remove the tension test clamp.

Repeat steps on above for the force is applied at 90 degrees to the major axis of the

component. The perpendicular direction shall be chosen in the most unfavourable

condition.

Whenever possible, the force is applied with a push action. If the push action cannot be

achieved, a pull action for applying the force can be used.

The direction of the perpendicular force must remain unchanged even the tested

component is bent during the test.

Reporting Criteria

Report the broken part, if any.

Determine and report the hazard such as sharp edges, sharp points and small parts according

to 16 CFR 1500.48, 49 and 1501, if any.

Requirement: Tension test is done for quality (performance) aspect or Safety aspect (children

item/Children safety). Requirement depands on test method, button or item diameter, item type

(metal or plastic), age range. It also varies buyer to buyer. According to 16 CFR 1500 (51-53):

Age Grade (months) Tension Force

0 to 18 Passed with 10 0.5 lbf for 10 sec

18 to 36 Passed with 15 0.5 lbf for 10 sec

36 to 96 Passed with 15 0.5 lbf for 10 sec

But buyers have some special requirement like; 16 lbs or 17 lbs or 21 lbs for 10 seconds

72. Compression test

Application: Any area on the surface of a toy that is accessible to a child and inaccessible to flat-

surface contact during the impact test shall be subject to this test.

Test apparatus: The loading device shall be a rigid metal disc 1.125 inches ±0.015 inch (2.86

centimeters) in diameter and 0.375 inch (0.95 centimeter) in thickness. The perimeter of the disc

shall be rounded to a radius of 1⁄32 inch (0.08 centimeter) to eliminate irregular edges. The disc

shall be attached to an appropriate compression scale having an accuracy of ±0.5 pound (±225

grams).

Testing procedure: The disc shall be positioned so that the contact surface is parallel to the

surface under test. A direct force of 25 pounds ±0.5 pound (11.4 kilograms) shall be evenly

applied within 5 seconds through the disc. This load shall be maintained for an additional 10

seconds. During the test the toy is to rest on a flat, hard surface in any convenient position.

Requirement: Must durable of materials after compession test. It must remain 100% function,

no cracks or failure.

Sharp Point Test

This is ASTM F963-Clause 4.9, which refer to 16 CFR 1500.48 test procedure of Accessible

points. A point tester is applied to an accessible sharp point and it is observed whether or not the

point being tested penetrates a specified distance into the sharp point tester. For any accessible

portion of the test sample (which intended for use by children under 8 years of age) before and

after subjecting the test sample to the use and abuse tests of 16 CFR 1500.51/52/53. (Excluding

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

the bite test-paragraph (c) of each section). The following children’s articles are exempt from

this 1500.48: Articles, intended for use by children that by reason of their functional purpose

necessarily present the hazard of sharp points and that do not have any non-functional sharp

points. (e.g. ball-point pen). As received need to assess that No needle left in garments. Trims

must be anti-magnet.

Apparatus and Equipment:

Sharp Point Tester

Safety Information:

Laboratory coat as necessary

Goggle as necessary

Place the sharp point tester on a horizontal plane and loosen the lock ring of the tester.

Rotate the gaging cap clockwise until the red indicator just lights on.

To determine a calibration reference mark by turning the gaging cap counter-clockwise until the

indicator lights just off.

Lock Ring

Gaging Cap Red Indicator

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Rotate the lock ring counter-clockwise until it just touches the gaging cap. (Note: make sure that

the mark on the lock ring aligns with one of the marks on the gaging cap)

Rotate the gaging cap counter-clockwise until an equivalent of five divisions has passed the

calibration reference mark.

Lock the gaging cap in this position by rotating the lock ring counter-clockwise until it locks the

gaging cap.

Calibration reference mark

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Inspect visually or by touching it to find if there is any accessible point which might be a sharp

point.

Insert the test point into the gaging slot.

Place the sharp point tester under its body weight of 1 pound at a vertical position.

Gaging Slot

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Test point should be maintained steadily during the test.

Do not add on an external force on the tester during the test.

Observe if the red indicator lights on.

Reporting Criteria:

If the red indicator of the sharp point tester lights on during the test, the point is a

sharp point.

Requirement: Shall have no sharp points, other than those required for function.

According to 16 CFR this test applies to children up to 8 years. No mechanical hazards or safety

hazards. Any graspable component or decorative item in clothing shall not present any other

mechanical hazards such as pinching, scissoring, bruising, lacerating, crushing, breaking or

amputating. If any attachment item fails after use and abuse testing need the test, if the red

indicator of the sharp point tester lights off during the test, the point is a no sharp point then –

Pass or meets the standard.

Without this method we can visually observd any garment or articles that it has no sharp point or

broken needle is present or pose to hazard.

Sharp Edge Test

This is ASTM F963-Clause 4.7, which refer to 16 CFR 1500.49 test procedure of Accessible

edges. A self-adhesive tape is attached to a mandrel which is then rotated for a single 360º

revolution along the accessible edge being tested. The tape is then examined for the length of cut.

For any accessible portion of the test sample (which intended for use by children under 8 years

of age) before and after subjecting the test sample to the use and abuse tests of 16 CFR

1500.51/52/53 (excluding the bite test-paragraph (c) of each section). The following children’s

articles are exempt from the 16 CFR 1500.49: Articles, intended for use by children that by

reason of their functional purpose necessarily present the hazard of sharp metal or glass edges

and that do not have any non-functional sharp metal or glass edges are exempt from this section.

Examples of these are children's ice skates and children's cutlery.

Apparatus and Equipment:

Sharp edges tester

Single layer of polytetrafluoroethylene (TFE) tape

Scissor

Ruler or Calliper

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Figure 1: Sharp edges tester

Reagents, Standards and Consumables:

Single layer of polytetrafluoroethylene (TFE) tape

Safety Information:

Laboratory coat as necessary

Goggle as necessary

Method:

For any accessible edges, inspect visually or by touching it to find if there is any point which

might be a sharp edges.

Wrap the mandrel with a single layer of TFE tape,

The ends of the tape shall be either butted or overlapped not more than 0.10 inch (2.5mm),

Apply the mandrel, at the approximate center of the tape, and apply upward force to the toys

so that the red line stays in between the two black lines of the force indication window.

Part of the test sample may need to be removed to allow the sharp edge testing device to test

an edge that is accessible. Such dismantling of the test sample could affect the rigidity of the

edge in question. The sharp edge test shall be performed with the edge supported so that its

stiffness approximates but is not greater than the edge stiffness in the assembled sample.

The mandrel shall be placed so that its axis is at 90 degrees ±5 degrees to the line of a

straight test edge or 90 degrees ±5 degrees to a tangent at the point of contact. (see figure 3)

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

1-any suitable device, portable or non-portable, to apply a known force and rotation to the

mandrel

2-(6±0.5) N applied to the mandrel axis

3-single warp of self-adhesive tape

4-(90±5)ᵒ (test edge relationship to mandrel)

5-variable angel to seek worst case situation

6-during the test the mandrel rotates one full revolution

Figure: 2 Principle of sharp edge test

Orient the edge so that the edge is most likely to cut the tape.

Maintain the force constant (1.35 ± 0.11 pounds) so that the white line still stays in between

the red lines and press the red button on the handle of the sharp edge tester. The mandrel will

begin to rotate 360 degrees,

Figure: 3 - The Red line stays in between the black lines

Hold the sample firmly. Prevent linear motion of the mandrel along the line of the edge.

Repeat the test if the linear motion affects the testing results.

Release the mandrel from the edge and remove the tape without enlarging any cut or causing

any score to become a cut.

Measure the length of the tape that is cut,

Reporting Criteria:

A cut in the tape with a length of not less than ½ inch (13mm) identifies an edge as sharp edge.

Requirement: Shall have no sharp edges, other than those required for function.

According to 16 CFR this test applies to children up to 8 years. If any attachment item fails after

use and abuse testing need the test, if a cut in the tape with a length of less than ½ inch (13mm)

then –Pass or meets the standard.

Without this method we can visually observd any garment or articles that it has no sharp edge or

broken metal is present or pose to hazard.

Small Parts Test This is ASTM F963- Clause 4.6, which refer to 16 CFR 1501 specified test procedure of Small

objects. These requirements applies to all articles intended for use by children under 3 years (36

Red line

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

months) of age which presents a choking, aspiration, or ingestion hazard because of small parts

that are introduced into interstate commerce after the effective date.

The factors describe below are relevant in determining which articles are intended for use by

children under 3 years (36 months) of age.

The manufacture’s stated intent (such as on a label) if it is a reasonable one;

The advertising, promotion, and marketing of the article;

The article is commonly recognized as being intended for children under 3 years.

The requirements do not apply to toys or articles which are solely intended for use by children 3

years of age or older. In addition, it does not apply to all articles to which children under 3 years

of are might have access simply because of presence in a household.

The following articles are exempt from these regulations 1501.4:

Balloons;

Books and other articles made of paper;

Writing materials such as crayons, chalk pencils, and pens;

Children’s clothing and accessories, such as shoe lace holders and buttons;

Grooming, feeding, and hygiene products, such as diaper pins and clips, barrettes,

toothbrushes, drinking glasses, dishes and eating utensils;

Phonograph records’ modelling clay and similar products’

Fingerpaints, watercolors, and other paint sets;

Apparatus and Equipment

Small parts cylinder

Small parts cylinder

Method

No toy shall be small enough to fit entirely within a cylinder with the dimensions shown in Figure-

1, when its fail tension and torque test.

Place the article, without compressing it and in any orientation, into the cylinder.

Determine whether the article fits entirely within the cylinder.

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Reporting Criteria

If the article fits entirely within the cylinder, in any orientation, it fails to comply with the test

procedure. (Test any detached components of the article the same way.)

If the article does not fit entirely within the cylinder, subject it to the appropriate “use and abuse”

tests of 16 CFR 1500.51 and 1500.52 (excluding the bite tests of 1500.51(c) and 1500.52 (c)). Any

components or pieces (excluding paper, fabric, yarn, fuzz, elastic, and string) which have become

detached from the article as a result of the use and abuse testing shall be placed into the cylinder,

one at a time. If any such components or pieces fit entirely within the cylinder, in any orientation

and without being compressed, the article fails to comply with the test procedure.

Requirement: For all decorative and functional items intended for children 36 months (3 years)

of age. If the item fails after use and abuse testing or appearance after laundering requirement, it

will then be tested as a small part. If it fits entirely within the small parts cylinder in any

orientation (without being compressed), then the item must be failed.

Drop test

This is VF Asia In House -VFAIHTM010 specified Test Method which determines the durability

of metal/plastic materials in garments when subjected to drop.

Sample preparation

Take 4 specimens. Retain one specimen as a control and use others for testing.

Method

Sample to be dropped from 100cm in height vertically for 3 times.

Results

Visually assess the specimen to determine if there are any cracks or failure.

Review all 3 specimens and report the worst rated sample.

It must remain 100% function, no cracks or failure.

Report

Report the test condition.

Report the visual assessment of material and be specific about the failure as compared to the

control.

Figure-1 Small Part cylinder

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Requirement: Must durable of metal/plastic materials after drop test. It must remain 100%

function, no cracks or failure.

Pom Pom test

This is ASTM F963 specific test method which ensures safety and security of pompom in

garments. Pompom is a Ball created either from cut lengths of thread or yarn fastened at the

centre, or from a piece of fabric filled with wadding. Pompoms can be secured directly to a

garment or attached by means of a cord.

In child garments pompom consider as a toys. Any toy with a projection, part, or assembly that a

child can grasp with at least the thumb and forefinger or the teeth shall be subject to this test.

Pompoms are subjected to the torque test. The amount of torque shall be determined from Table-

1, according to the age group for which the toy is intended. The loading device used in the test

shall be a torque gauge, torque wrench, or other appropriate device having an accuracy of ±0.2

in.lbf (±0.02 Nm).

Determine the graspable components of the product

Use suitable clamp to fasten the object or component and then the torque gauge firmly

without destructing the integrity of the component.

The torque is applied about the major axis of the component evenly within a period of 5

seconds in a clockwise direction until either a rotation of 180 degrees from the original

position has been attained or the required torque exceeded.

The maximum rotation or required torque is maintained for an additional 10 seconds.

Remove the torque and the component permitted to return to a relaxed condition.

Repeat steps on above in counter-clockwise direction starting from the point at the relaxed

condition of the component.

For a component that is attached by the manufacturer or by the manufacturer’s instructions,

becomes loosen during the application of the required torque, continue to apply the torque

until either the required torque is reached or the part disassembles.

If this part disassembles and exposes an accessible component that can be grasped as above,

repeat the torque test on that component.

Pompom has a possibility to rotate 180ᵒ.

Pompoms are subjected the tension test by tension tester. The clamps used to grip the material to

be tested shall have jaws to which 3⁄4-in. (19-mm) diameter washers are attached. One clamp

shall be attached to the pompom and a second clamp used to grip the base material. A force of 15

lbf (67 N) shall be applied evenly within 5 s and maintained for an additional 10 s.

Table-1 Test requirement for Use and Abuse Tests

Age Grade (months) Tension Force Torque Force

0 to 18 10 0.5 in.lbf 2 0.2 in.lbf

18 to 36 15 0.5 in.lbf 3 0.2 in.lbf

36 to 96 15 0.5 in.lbf 4 0.2 in.lbf

These requirements are intended to address choking hazards associated with pompoms on toys

intended for children under three years of age that detach during tension test. Pompoms detached

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

during tension must not pass entirely through the 1.75-in. (44.5-mm) test fixture (see Fig) under

their own weight. Any components, pieces, or individual strands of the pompom that are

liberated during the torque and tension tests should not be subject to this test. Test the pompoms

by putting the free ends of fiber into the gauge.

Requirement: Requirement varies buyer to buyer

Pompom must pass torque and tension test as required. If fail torque and tension not pass

entirely the test fixture to address choking hazards.

Some buyer set a measurement of pompom. Small measure-no smaller than 1.5 inches

diameter.

Technical Assessment (Safety of Children’s Clothing – Cords and Drawstrings on

Children’s Clothing)

For European Market

Safety of Children’s Clothing – Cords and Drawstrings on Children’s Clothing

This is BS EN 14682: 2014 specific test methods used to minimize the

risk of accidental entrapment by cord or drawstring on childrens

clothing. The standards or specifications to consider cords and

drawstring in clothing intended for children up to age 14 years.

Specimen is classified as garments for young children (person aged

from birth to age 6 years 11 months, including all children up to and

including a height of 134 cm) 7-14 years for older children and young

persons.

According to this method they divided a body in four zones.

Zone A-Hood and neck area on garments for young children

Zone B-Waist area on garments, internal and external to the garment

Zone C-Lower hem of garments which hang below the crotch

Zone D-Back area

The European standard does not apply to the following:

Fig-Test Fixture for Small Balls

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Child use and care articles, for example bibs, nappies and soother holders;

Shoes, boots and similar footwear;

Gloves, hats, bonnets and scarves;

Neckties designed to be worn with a shirt or blouse;

Belts, with the exception of tied belts which are within scope;

Braces;

Religious clothing;

Celebratory clothing such as that worn at civil or religious ceremonies, national or regional

festivals provided this worn for limited periods and under supervision;

Specialist sportswear and activity wear generally worn for limited periods and under

supervision, for example rugby shorts, wet suits, and dancewear, except where those

garments are commonly worn as day wear or night wear;

Theatrical costumes used for theatrical performance;

Aprons intended to be worn over day wear, for limited periods and under supervision, tp

protect clothing from soiling during activities such as painting, cooking, or during meal

times;

Bags and purses.

Requirements based on standard

Basically they have some findings that ensure the children item or clothing is safe and hazard

free based on the zone.

General

The free ends of drawstrings, functional cords, and tied belts or sashes shall have no knots or

three dimensional embellishments and shall be secured to prevent fraying, for example by

heat sealing or bar tacking. The ends may be doubled or folded provided no hazard of

entrapment is created. Knots and three-dimensional embellishments along the length of the

free ends are not permitted.

Toggles shall only be used on drawstrings with no free ends or decorative cords.

Where drawstrings are permitted, they shall be attached to the garment, for example using a

bar tack, in at least one point positioned equidistant from the exit points.

Fixed loops, which protrude from the garment, for example to fasten, or loops on fixed bows,

shall be no more than 7.5 cm in circumference. Flat loops which do not protrude (for

example: belt loop) from the garments, for example belt loops, shall be no more than 7.5 cm

in length, between the fixed points of attachment to the garment. Note: Functional hanger

loops and other loops inside garment are permitted if a risk assessment shows that they are

not a hazard to the wearer.

Zip pullers including any embellishment shall be no longer than 7.5 cm in length from zip

slider.

Zip pullers with or without embellishment shall not hang below the lower edge of garments

designed to finish at the ankle.

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Head, neck and upper chest area on garments for young children (Zone A)-From birth to

age 7yrs/Up to height of 134cm

Garments intended for young children shall not be designed, manufactured or supplied with

drawstrings, or functional cords in the head, neck or upper chest area.

Decorative cords shall not be permitted anywhere on the hood or at the back of the neck.

In other parts of neck and upper chest areas, decorative cords shall have free ends no longer

than 7.5 cm, shall have no knots, toggles or three dimensional embellishments and shall not

be positioned so they can tie across the throat. Decorative cords shall not be made from

elastic cords.

Adjusting tabs are permissible provided that the length is no more than 7.5 cm, and shall

have no button, toggle, buckle on the free end which may present an entrapment hazard.

Shoulder straps shall be constructed such that, when worn, there shall be no free ends

external to the garment. Shoulder straps may be permanently fixed to front and back, or

attached to permit adjustment of strap length by for example button, press fasteners, provided

the free end is inside the garment. The use of a clip or fastening of two cords is acceptable,

provided these do not result in free ends of cords when garment is worn.

Where a mechanism, for example ring and slider, is used to adjust the length of the shoulder

strap, the strap including the loop shall lie flat to the body when worn.

Decorative cords attached to a shoulder strap shall not have free ends longer than 7.5 cm and

fixed loops shall be no more than 7.5 cm in circumference.

Halter neck-style garments shall be constructed with no free ends in the neck and throat.

The use of a clip or fastening of two cords is acceptable, provided these do not result in free

ends of cords when garment is worn.

Where a mechanism, for example ring and slider, is used to adjust the length of the halter

neck, the strap including the loop shall lie flat to the body when worn.

Head, neck and upper chest area on garments for older children and young persons (Zone

A)-From age 7 up to age 14/Boys of height greater than 134cm up to 182cm/Girls of height

greater than 134cm up to 176cm

Drawstrings shall not have free ends.

Drawstrings with no free ends shall have no protruding loop when the garment is open to its

largest and laid flat. When the garment opening is at its smallest, i.e. the size it is intended to

fit, the maximum protruding loop circumference shall be 15 cm

Where toggles are used for adjustment of drawstrings with no free ends, the toggle shall be

fixed to the garment.

Functional cords shall be not more than 7.5 cm in length. Functional cords shall not be made

from elastic cords.

Decorative cords shall not be more than 7.5 cm in length including any attachment or three

dimensional embellishments. Decorative cords shall not be made from elastic cords.

Adjusting tabs are permissible provided that the length is no more than 7.5 cm, and shall

have no button, toggle, buckle on the free end which may present an entrapment hazard.

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Shoulder straps are permissible provided any free ends are no longer than 14 cm from the

point at which they are to be tied and fixed loops are no more than 7.5 cm in circumference.

Where a mechanism, for example ring and slider, is used to adjust the length of the shoulder

strap, the strap including the loop shall lie flat to the body when worn.

Halter neck-style garments shall be constructed with no free ends at the neck and throat. The

use of a clip or fastening of two cords is acceptable, provided these do not result in free ends

of cords when garment is worn.

Where a mechanism, for example ring and slider, is used to adjust the length of the halter

neck strap, the strap including the loop shall lie flat to the body when worn.

Chest and waist area

Garments worn from waist down without shoulder straps, braces, or sleeves, such as trousers,

shorts, skirts, briefs, bikini bottoms, shall not have:

a) Free ends of drawstrings longer than 20 cm at each end when the garment is in a relaxed

natural state.

b) Protruding loops on drawstrings with no free ends, when the garment is open to its largest and

laid flat. Where toggles are used for adjustment of drawstrings with no free ends, the toggles

shall be fixed to the garment.

c) Functional cords longer than 20 cm.

d) Decorative cords longer than 14 cm including any embellishment.

Garments other than those listed in 3.4.1 such as shirts, coats, dresses, and dungarees shall

not have:

a) Free ends of drawstrings longer than 14 cm at each end when the garment is open to its largest

and laid flat.

b) Protruding loops on drawstrings with no free ends when the garment is open to its largest and

laid flat. Where toggles are used for adjustment of drawstrings with no free ends, the toggles

shall be fixed to the garment.

c) Functional cords longer than 14 cm

d) Decorative cords longer than 14 cm including any embellishment.

For all garments, adjusting tabs in the waist area shall be a maximum of 14 cm

For young children, tied belts or sashes intended to be tied at the back of the garment are

permissible provided that when untied and measured from the point where they are to be tied,

they shall be no more than 36 cm in length. When untied, they shall not hang below the hem

of the garment.

For older children and young persons, tied belts or sashes intended to be tied at the back of

the garment are permissible provided that, when untied and measured from the point where

they are to be tied they shall be no more than 36 cm in length.

For both age groups, tied belts or sashes intended to be tied at the front or at the side of the

garment shall be acceptable provided that when untied they shall be no more than 36 cm in

length measured from the point where they are to be tied.

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Lower edge of garments which hang below the crotch (Zone C)-(where it is unclear if the

lower edge of the garment is below crotch)

Drawstrings, functional cords or decorative cords including any toggle shall not hang below

the lower edge of the garment.

Drawstrings, functional cords or decorative cords at the lower edges of garments shall lie flat

against the garment, when the garment is tightened or fastened.

In garments that are designed to finish at the ankle such as trousers, skirts and coats, the

drawstrings, functional cords and decorative cords at the lower edge shall not be outside the

garment. Note: stirrups at the hem of trousers are permissible.

Adjusting tabs shall be no longer than 14 cm, shall not hang below the lower edge of the

garment and shall have no button, toggle , buckle on the free end which may present an

entrapment hazard.

Back area (Zone D)

Children’s garments shall not be designed to have drawstrings or functional cords that

emerge from the back of the garment or to be tied at the back.

Decorative cords shall not be more than 7.5 cm in length and shall have no knot, toggle or

three dimensional embellishments.

Adjusting tabs shall be no longer than 7.5 cm, shall not hang below the lower edge of the

garment and shall have no button, toggle, buckle on the free end which may present an

entrapment hazard.

Tied belts or sashes are permissible.

Sleeves

Drawstrings, functional cords and decorative cords at the lower edge of long sleeves shall not

be outside the garment, when the garment is fastened.

Drawstrings, functional cords and decorative cords positioned below the elbow on long

sleeves, shall not hang below the lower edge and free ends shall be no longer than 7.5 cm

For young children, drawstrings, functional cords and decorative cords are permissible on

short sleeves provided the sleeve finishes above the elbow and the maximum protruding

length is 7.5 cm measured when the sleeve is open to its largest and laid flat.

For older children and young persons, drawstring, functional cords and decorative cords are

permissible on short sleeves provided the sleeve finishes above the elbow and the maximum

protruding length is 14 cm measured when the sleeve is open to its largest and laid flat.

For both age groups, adjusting tabs are permissible on sleeves provided that they are no

longer than 10 cm in length and when open shall not hang below the edge of the sleeve.

Other parts of the garment

In all other areas of the garment, not previously addressed, the drawstring or functional and

decorative cords shall protrude by no more than 14 cm when the garment is open to its largest

and laid flat.

There is an individual risk assessment (Annex E) is carried out on any garments in order to

ensure that it does not present a hazard to the wearer.

Mechanical Safety AzMiR LaTiF (MSc. Engr. Textile)

Annex E

The risk assessment is in relation to the aim of this European standard which is related to the

introduction: to minimize the risk of accidental entrapment in moving vehicles or strangulation

by cord and string on children’s clothing.

Decorative design features, e.g. bows, half belts, tabs, straps etc. are all features that shall be

subjected to a risk assessment to establish that they do not present a hazard to the wearer of the

garment.

Functional loops used on the inside of garments for display and hanging purposes shall be

subjected to a risk assessment to establish that they do not present a hazard to the wearer of the

garments. Other hazards from clothing will require separate consideration.

For American and Canadian Market

ASTM F 1816 Visual Appearance test for drawstrings also cover CPSC Guideline/Health

Canada Advisory Visual/Actual measurement based on New York state law 391.d and

American Wisconsin state law ATCP 139

Safety Specification for drawstrings on children’s upper outerwear

This is ASTM F 1816 specific test method for drawstrings on children’s upper outerwear.

Knot, toggle and other decorative or functional attachments on the ends of long, loose drawstring

can catch and snag on other objects. Two hazards associated with such drawstring on children’s

upper outerwear have been identified: the potential strangulation hazard associated primarily

with hood and neck area drawstrings of outerwear; the potential vehicular dragging hazard

associated primarily with waist and bottom drawstring of upper outerwear. This consumer safety

specification is intended to reduce the risk of drawstring on children’s upper outwear accessing

and getting snagged in various entrapment areas.

The type of clothing covered by this specification is girls and boys clothing, such as jackets and

sweatshirt, generally intended to be worn on the exterior of other clothing.

The sizes covered by this specification are sizes 2T to 12 or neck/hood drawstring and sizes 2T

to 16 for waist/bottom drawstrings.

Upper outerwears with fully retractable drawstrings are exempt.

Requirement

There shall be no drawstrings in the hood and neck area of children’s upper outerwear sizes

2T (toddler) to 12 years

Drawstrings at the waist and bottom area of children’s upper outwear sizes 2T (toddler) to 16

years

Not exceed 3 inches (75 mm) in the length outside the drawstring channel when the garment

is expanded to its fullest width.

Have no toggles, knot, or other attachments at the free ends and

Be bartacked, if the drawstring is one continuous string cannot not pulled out