Amended 10/6/09: This entry is somewhat dated in that it was written before the passage of the Consumer Product Safety Improvement Act (CPSIA). Perhaps Esther’s comments below were considered conjecture or hypothesis when they were written but much of what she said has come to pass. If you are not familiar with CPSIA, it is critical to read about it now. Under CPSIA, it is now a crime, punishable by fines and a potential prison sentence, to produce children’s items with drawstrings or ties at the neck, waist, hems etc. Since the law is ambiguous, it’s best to omit this design feature altogether.
Esther Melander, a children’s wear producer, has written a guest entry on drawstrings and child safety in light of some recent recalls. If you produce children’s wear, these issues affect you too. Thanks Esther!
In 1996 the US Consumer Product Safety Commission (CPSC) created guidelines for the use of drawstrings in children’s upper outerwear. The guidelines specifically target drawstrings found in the hoods and waistlines of sweatshirts. They were created after reports of several injuries and even death of children who wore such clothing that became entangled. The guideline applies to clothing sized 2T-16 and is considered voluntary.
CPSC’s drawstring guidelines do not represent a standard or mandatory requirement set by the agency. And, while CPSC does not sanction them as the only method of minimizing drawstring injuries, CPSC believes that these guidelines will help prevent children from strangling by their clothing drawstrings.
Even though the guideline is considered voluntary, it would be in a DE‘s best interest to follow them. In the first two weeks of December 2007, there have been five recalls of children’s clothing with drawstrings!
The latest recalls are representative of the type of drawstring issues that keep showing up. The jacket (below) has a drawstring at the waist (picture does not show it).
The two pants (below) are borderline with the ties at the waistline. They are not technically drawstrings, but they are knotted belts. The belt on the jeans appears to be stitched to the belt loops, but is being recalled because it is a related style to the other.
The problem with the bright pink shirt (below) are the long pink ties are located near the neck.
The hooded striped sweaters have knotted velvet ribbon ties (below).
All of these products were found in major department and chain stores. The irony is all of these stores should know better because these guidelines have been in place for over ten years. The buyers should know. The quality auditors should know. The manufacturers should know. The technical designers should know. And yet, the problem continues to show up. As you can see, there is broad interpretation with the guideline and how it is applied. The original guideline applies to outerwear and the recalled jacket certainly fits. But what about the recalled t-shirt and pants?
The difficulty comes with understanding the difference between an industry standard, voluntary guideline, regulation, and law. For example, the lead levels in painted products began as a guideline and has now morphed into a regulation that can result in severe fines and penalties if not properly followed. The transition began with voluntary recalls by manufacturers and the CPSC. As the public became more aware of the problem and the danger explained, children’s products that contain lead are now under mandatory recall. I believe the drawstring guideline is starting to go down the same path. The pattern right now is in voluntary recalls and public information. As public awareness increases, there will be public pressure to make this guideline a law or regulation. From a public or consumer point of view there is no difference between a voluntary guideline, regulation or law.
What began as a voluntary guideline for drawstrings in upper outer wear for children 2T-16 has resulted in unintended consequences for related products. Any childrenswear designer has to question the use of ties for any age child in any piece of clothing. Potential sources of strangulation or entrapment are everywhere. Consider the common baby bib. Pre-guidelines, bibs were sold with knots on the end of the bias bindings. Now, they are sold without the knots. Yet, it becomes a strangulation issue because the ties could still become caught in a high chair. Do the guidelines cover this too? Sure there are other types of closures, but they pose potential choking hazards. Snaps, buttons, and velcro pieces can come loose if not applied properly. What to do? Feed the baby naked and hose them down afterward?
Other products that can cause concern:
- Bibs with ties made of bias binding, ribbon, or fabric.
- Girls dresses with waist ties made of fabric or trim. The ties may contribute to the design of the dress, but also provide a fitting mechanism.
- Dresses with detached sashes. Some sashes may measure 60-72 inches and are not permanently affixed to the garment.
- Dresses, tops, or pants with added trim that may be loose, especially ribbon dangles.
- Hats with ties made of ribbon or fabric.
- Hats with straps, either attached on both ends or attached on one end with some type of closure on the other.
I am sure blog readers could come up with other examples. When you take safety issues to the extreme, there are all sorts of hidden dangers in clothing. From a realistic and practical design perspective, you can not design a 100% safe product. The pressure is more extreme with children’s clothing. No one wants to unintentionally injure or contribute to the injury of a child. What to do?
I have had employers and DEs ask me (I question myself) about products on the above list. I don’t have an easy answer for them. The first place I turn to is the CPSC website. There are no further guidelines other than the drawstring guideline issued in 1996. The next place to look for industry standards is ASTM. ASTM has the same drawstring standards as the CPSC, but charges you $30 for a licensed copy (read ASTM licensing requirements before purchasing anything from them. You might be surprised at the kind of restrictions you will be under). Another option (not necessarily the best) is to look and see what other companies are doing. How long are their waist ties on dresses, for example? The concern is that even major retailers have trouble following their own internal guidelines (and yes, most of them do have internal guidelines regarding drawstrings). Finally, your company can come up with your own company standard.
I would prefer a voluntary industry standard for the above listed products. I think this is something that can be done. In this endeavor, I am currently working on a letter to send to the CPSC, and possibly ASTM. I will be requesting further clarification on drawstrings and ties in children’s clothing, especially for infants. The drawstring conversation is just beginning. Post any comments or questions you might have about this issue.