The sizing police of children’s clothes

The big news in children’s wear is that the CPSC has recalled sleepwear from Sage Creek Organics for violations of the federal flammability standard due to sizing. Yes, sizing. The recalled garments don’t meet the “tight-fitting” sizing requirements -which you can find here. [The pdf is easier reading, there’s also an overview of the regulations.]

For the uninitiated, children’s sleepwear sizes are regulated because tighter fitting pajamas reduce the likelihood of burns. But there are a lot of problems associated with regulating sizes; for example, which standards are being used?

A cursory analysis of the CPSC’s sizing standard suggests the agency has followed the ASTM guidelines (D-6192*) in spite of myriad complaints from manufacturers that the CPSC sizing is too small and I’m inclined to agree for several reasons. For one thing, there are many problems with the data set; it’s very old, circa the 1920’s. There is a newer data set (the CS151-50, my entries on it are here and here) which is itself dated but still closer to reflecting the increased girth and height of kids today. Comparisons are difficult but here’s a chart comparing chest girth of the three which explains why I suspect the CPSC is using the ASTM data set. [The regulations published in the Federal Register describe but do not specifically cite a now withdrawn standard (D-5826), saying it was based on an anthropometric survey conducted in 1977 so I’m confused that its results mirror data from the D-6192 (09). ]


sco_children_grading_weight2In the chart at right, I’ve compared weight of three sizes (2-4, I had to limit the sample or I’d be at this all day). This chart is different because the CPSC doesn’t provide weight guidelines but since they’ve followed the ASTM standard, we can guess those weights would apply. I’ve also added data from the Center for Disease Control (2000). You know, the folks who are in charge of this stuff? They weigh and measure kids across the country which is how doctors end up with those handy charts to assure parents their kids are growing normally. You can get the data set to compare for yourself (11 MB pdf download). Anyway, the last line of this chart shows the weights that Sage Creek Organics uses to design their sizing.

The summary conclusion is that Sage Creek is certainly “guilty” of failing to size their products according to CPSC guidelines which are literally, about 90 years old. Albeit guilty, I’m not convinced they’re the ones we should take out behind the shed. Sage Creek has sized well -responsibly even- within the spread shown by the CDC.

There are other problems with regulating sizes like this. Based on weight, there is a large spread of naturally occurring sizes of kids. Obviously CPSC sizes to the 50th percentile but what of the other 50% who are smaller and larger? Sure, parents can buy a size larger or smaller but this introduces other problems, particularly for the rapidly increasing segment of obese kids. For them to find pajamas to fit their girth, the garments will be inordinately long which presents dangers all its own. Say a sleeve dangles and catches fire. Or the kid trips fleeing a burning building because the crotch depth is entirely too long or even trips on his too-long pant legs. The CPSC doesn’t have a standard for plus size kids (plus size activists should be up in arms over this health and safety issue).

So what does all this mean? Well, it means that if you make kid’s clothes, you should stay away from kid’s sleepwear unless you can afford to develop two entirely different sets of patterns, prototypes, fit models etc to cover the range of differing sizes between sleepwear and daily wear. You also risk confusing your customers. Your customers know they buy X size for their kid in your regular clothes but they won’t realize that the sizing of your pajamas will be different because they’re regulated by the government. Knowing how these things go these days, moms will pillory you for sizing inconsistently or being too cheap, you know, trying to save a buck by reducing fabric use in the garments.

And what it means for the CPSC is that they really need to update the regulations to hit the new mean. They also need to add a sizing designation for plus sized kids.

*Re: ASTM D-6192. This is the data set for girls sizes 2-20. There is no data set for boys in this age category. Previously, children’s sizes were grouped together in D-5826 but the standard was withdrawn in 2009.

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  1. Susan Sisk says:

    Thank you for surfacing this issue. As co-chair of the American Society for Testing and Materials (ASTM) Sizing Committee I can shed some light here.

    The revised sizing standards were based on several studies including CDC, NHANES, body scan data and anthropometric data which more accurately represent today’s population and growth patterns by age and gender. The scope of the sizing standard is specified on the cover page of the document to alert the user that the body measurements do not supersede any regulatory requirements:

    “1.6 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.”

    The CPSC established finished garment measurements for flame retardant sleepwear in the 80’s and while not stated, these specifications do require a significant percentage of fabric stretch in order to fit, especially at the sleeve and leg openings. It is critical to note that CPSC specified garment measurements – not body measurements. Over the last 30 years manufacturers have complied with CPSC sizing, labeling and testing protocol in order to be compliant with sleepwear regulations. Therefore sleepwear categories are generally managed separately from playwear by manufacturers.
    For a history of the CPSC regulations and the apparel industry here is a link showing the complexity of the issue:

    A couple of additional points for clarity – the Center for Disease Control (CDC) gathers, analyzes and distributes data on specific measurements which are taken by doctors and reported to the CDC. This data represents critical growth patterns in childhood development, but not the traditional chest, waist, hip, inseam etc as we rely on for apparel manufacturing.

    The Boys ASTM charts have not yet been published, but have been balloted and approved and should be available later this year, and reflect similar changes.

    Agreed, a review of the CPSC regulations would be appropriate, in the meantime Mom needs to rely on the size charts printed on all children’s sleepwear to determine the best fit for her child.

  2. Eric H says:

    Susan, these are fine points, but the average Mom is not going to know, or even have an interest in, the esoteric minutiae of sleepwear sizing. They will probably go by the sizing used by the manufacturer (and probably factor in some growth, according to the commentary in the Federal Register). The manufacturer bases its sizing on its target demographic. CPSC’s standard is based on a demographic that doesn’t represent their market. See the disconnect?

    The manufacturer could try using that old data (if that is what CPSC is using), but then their clothes would routinely fit excessively tight. Then Mom doesn’t buy that brand anymore. Then that company leaves the market. Then a new company fills the void with a radical idea: fit real clothes to real kids! And so the cycle repeats.

    The problem is the sizing that CPSC is using, not what Mom’s are using or what manufacturers are using or especially not the more recent data ASTM is producing. Childhood obesity exploded in the last decade or so (see this BBC article, for example), so even a 10 or 20 year old study is no longer representative.

  3. Laura says:

    I am so glad the CPSC was not involved in children’s sleepwear when I was growing up.

    Sleepwear should be large and flowing.

    CPSC has gotten a little crazed. Basing regulations on reported accidents and injuries only tells part of the story.

  4. Barb Taylorr says:

    Fascinating, and wow am I glad I don’t work in kid’s sleepwear. Here’s a hypothetical question though. Would a manufacturer be expempt from the CPSC requirements if they put an obvious tag and label on their garments that said “Not intended for use as sleepwear” ??

  5. Kathleen says:

    The scope of the sizing standard is specified on the cover page of the document to alert the user that the body measurements do not supersede any regulatory requirements:

    Perhaps my intent was taken out of context; CPSC implementation of CPSIA is an oozing sore amongst producers in the market and has been discussed here at length. I also did not suggest (or intend to imply) ASTM standards superseded CPSC sleepwear regulations. I also do not imply that ASTM, members of committee D-13 (I’m also a member) nor the specified ASTM standard itself was in any responsible for the guidelines established by the CPSC.

    That the specified measures reflect garment dimensions rather than body landmarks makes the sleepwear standard even more unreasonable. I thank you for the distinction tho; the wording of the regulations is awkward at best. I also know CDC doesn’t survey anthropometric landmarks; for this reason I used body weight in the second chart. Body weight is correlated to girth measures and very commonly used in the development of clothing patterns -particularly for children who are height and weight proportionate.

    That knit fabrics (for all intents and purposes) must be used to meet the sleepwear regulations presents another difficulty in that not all children can tolerate them (particularly with respect to certain kinds of ribbed cuffs etc) due to tactile defensiveness. The thread looping pulls on body hairs (a condition worsened by tight fitting garments) resulting in a situation that many autistic children and adults find intolerable.

    The primary objection I have to the sleepwear fit standard is that it is dated in several respects. Primary is that it does not reflect changes in childhood obesity. The ASTM standard has been updated with plus size guidelines so it stands to reason that the sleepwear regulation should follow suit. That the sleepwear regulations don’t reflect the current sizing needs of children in the US, can lead to safety hazards all its own.

    Laura: extensive studies have shown that loose fitting sleepwear contributes to higher incidence of burn injuries. While it may not be as comfortable, tight fitting sleepwear prevents fabric ignition because it eliminates a cushion of air on both sides of the fabric.

    Esther had some interesting comments on the subject, I hope she’ll post them here.

    Barb: the issue of avoiding CPSC/CPSIA requirements is another controversy. The CPSC has tried to address the issue in terms of appropriate marketing. For example, the obvious tag/label is but one part of it. A producer should also take great pains to avoid any implication in their marketing that the product could be used in ways other than how it is intended to be used. For example, a tag is useless for CPSC compliance purposes if the manufacturer uses photos of the child sleeping in the garments etc.

  6. Susan Sisk says:

    Kathleen thank you for your added points, this is certainly a complex issue!
    I would like to add for the clarity of all readers that this category requires great diligence on the part of the manufacturer and we are in agreement that the legislation has not caught up with the needs of the consumer.
    That said, it is important to note that no brand is at a commercial disadvantage in the application of labeling or sizing requirements. For 30 years all sleepwear brands sold in the US have been equally required by law to meet these regulations. Any products found to be in violation are recalled by the CPSC resulting in financial losses for the company and negative media coverage for the brand. No one wants to see a child or a company hurt due to sleepwear!
    My suggestion those unfamiliar with this market is to know and understand the CPSC and FTC labeling regulations and have the full support of your corporate legal staff, quality assurance department and product development teams before entering this product category.

  7. celeste says:

    Answering as a mom here – The tight fitting pajamas, I usually have to buy a size, to 2 sizes larger to get them to even fit, and I have average size children. It did take buying and returning items, to learn that lesson, but now I automatically just buy them bigger.

    And, thats all the kids are going to let me write……….

  8. Esther says:

    My comments in the forum echos Celeste. Several parents have complained and questioned why sleepwear is practically skin tight. They buy sleepwear in larger sizes or have them wear adult sized t-shirts, completely defeating the purpose of the requirement in the first place. But the larger problem is that there is an assumed cause and effect relationship which is implied by the requirement which is plain wrong. Many assume that the sleepwear standard was enacted because sleepwear was in and of itself a cause of the burn injury. The truth is that apparel MAY contribute to the SEVERITY of the burn injury due the amount of air trapped between the skin and the clothing. Wearing tight fitting clothing does not prevent a burn injury at all as the source of the flame is outside of the act of actually wearing the clothing – that is unless sleepwear manufacturers are selling self-combustible clothing. I do not mean to imply that safety is not a concern, but the regulations do need to be reevaluated with consideration for actual injury statistics related to the fit of the clothing and the source of the burn. IOW, perhaps we need to look elsewhere in preventing burn injuries.

    In general, I advise designers to stay away from sleepwear.

  9. Susan Sisk,

    From your last paragraphs I deduce that you believe that only large corporations are equipped to take the risk of producing sleepwear for children. That’s clear enough.

    How do you address concerns that plus-sized children wearing extra-long clothes designed for thin children are placed at increased, not decreased, risk of injury?

  10. Lesley says:

    This is SUCH a pet peeve of mine, not as a manufacturer (since I do not do sleepwear) but as a parent! My kids are on the slim size yet I have to buy up 2 sizes AND cut off the wrist and ankle bands because my kids are sensitive to those tight pressure points. NOBODY likes to sleep with tight clothing. Otherwise I simply buy non-sleepwear for them to sleep in so they can be comfortable. Seriously misguided regulation by the CPSC in all, since any data will show that most fire-related deaths occur from smoke inhalation rather than having your pajamas char you up in a fireball. Duh!

  11. martin says:

    In the 90s one company got around some of the regulations (FR) by marketing (and labeling, mentioned above) their pajamas ‘lounge wear’. Photographs of children (and non obese children at that) standing around as though in deep conversation.

  12. Eric H says:

    Susan, I’m still a little confused. On the one hand, you seem to be posting here as a representative of ASTM, which is not a government agency or policy advocacy group. ASTM publishes standards, period, and you have even quoted from a standard to illustrate the separation between ASTM’s work and federal regulations. On the other hand, you offer accounts of the history and development of the regulations, you defend CPSC and their interpretation, and you offer regulatory compliance advice as if you were a member of a policy advocacy group. Is this ASTM’s position? If so, it seems like a conflict of interest to defend a regulatory agency which uses standards which, if you want to check your compliance, must then be purchased from ASTM.

    Allison, I reached a similar conclusion before I got to the last paragraph. It is only true that “no brand is at a commercial disadvantage in the application of labeling or sizing requirements” if they all have equal access to legal, technical, lobbying, and marketing services so that they can go head-to-head with CPSC over the interpretation of the law. Those services contribute to overhead costs. Higher overhead costs are an advantage to manufacturers with larger market share because they can spread them out over a wider offering.

    We are not advocates here of laziness or defenders of Innocence by Aura of Good Intentions theory. Bigger does not equal Better. Read this, for example. But neither are we defenders of bad laws or unreasonable interpretations of those laws.

  13. Dori T says:

    This forum is priceless and I am glad to have stumbled upon it.
    Being new to childrenswear, I will shy away from sleepwear until I have a grasp on such regulations.
    What is a good resource for brushing up on other childrenswear regulations?

  14. Christina says:

    As a mother with more than an ounce of common sense, I completely agree with Lesley on the ridiculousness of thinking that tight sleepwear prevents the deaths of sleeping children. While tight-fitting clothing *might* prevent an *awake* child from death directly caused by burning alive, the risk while sleeping is smoke inhalation. In order for flames to immediately kill a human being, the fire must start on your body, or very, very close by. I have never heard of a child starting fire while asleep, though perhaps a sleep walker could do so (the primary risk to sleepwalkers is falling, to the best of my knowledge.)

    Preventing child-fire-deaths requires 1. smoke detectors to alert to fires, 2. teaching children to leave the building that is on fire immediately, and not hide under the bed or in the closet, which is their instinct, 3. never allowing a child to be near a fireplace, candle, space heater, stove, matches, lighters, cigarettes, or any other source of high temperatures and/or flame. You could perhaps prevent a few deaths by requiring children to wear play-clothes that are flame-resistant or retardant, because most of the time when a child or his/her clothing catches on fire, it is a fire that they set themselves. But petroleum-based fabrics melt when exposed to heat, and those are the government-preferred child sleepwear materials. Melted plastic is much worse than cotton or rayon ashes. Pure, tightly-woven, wool fabric is self-extinguishing in most environments suitable to human life, but good luck getting a child to wear that wool! Good luck shoving a writhing, stubborn child into too-small pajamas. There is also some research that suggests that fire-retardant chemicals cause some cases of SIDS. So there is no good way to prevent a sleeping child’s pajamas from catching on fire.

    The essay “A Modest Proposal” would suggest that the easiest way to prevent the children from being burned alive is to eat them before that can happen. This is a very economical solution to world hunger, global overpopulation, the greenhouse effect, and the guilt you feel when seeing on TV that a sleeping child’s clothing somewhere, sometime spontaneously combusted, according to a chain email that is making rounds. If you think that “A Modest Proposal” is a good idea, Jonathan Swift might want to start by eating you, because you would make a good “roast.”

    Yes, I am full of snark. Snark is a dish best served cold, like shoulders.

  15. I think the sleepwear concern originated with the observation that children who catch fire in their pyjamas are most likely to do so when awake and playing. Therefore measures to prevent children from catching fire in their pyjamas must be targeted to playing children. Pyjamas are skin-tight so that they aren’t accidentally dragged through flame, as a child twirling in a frilly nightie in front of the fireplace might do.

    It’s possible the original observation is even more general than that: perhaps most children who catch fire are awake and playing in their pyjamas, therefore pyjamas should be difficult to light. But I’m having trouble finding an original source for it for some reason.

    The first interpretation is difficult to understand: if children are generally most likely to catch fire when awake and playing, why target sleepwear for fire prevention?

    The second interpretation is easier, but I can’t source it. If children are most likely to catch fire when awake and playing in their pyjamas, I can imagine the reason being early risers playing quietly unsupervised in the house while the parents try to get some sleep, or children playing alone in their rooms before they settle for the night. In that case parents want to be sure that the children couldn’t possibly have access to matches or lighters, but from a public safety perspective we know that many children live in houses with smokers or fireplaces and do have such access. Therefore we want to be sure they will have trouble lighting themselves on fire.

    I haven’t seen any reasoning that spontaneous combustion of children sleeping quietly in their cribs is of concern.

    *** *** ***
    Obviously there are serious problems with the current sleepwear regulations. But to argue effectively against them we need to understand the arguments for them.

  16. Willie says:

    As a mom and a grandmom, there is possibly nothing that makes me crazier than the sleepwear regulations!

    My children could NOT tolerate the nasty polyesters that were (and still are in large part) supposed to keep them from getting burns. Within 5 minutes of falling asleep they woke up screaming and drenched. I quickly learned to ignore all those rules and make my children’s sleepwear. I do the same for my grandchildren, while their mom gets the cotton knit tight-fitting. I make them warm flannels for cold weather and light weight cottons for summer.

    I take into account that little girls nighties should not reach all the way to their ankles (to reduce tripping), but mostly I concentrate on COMFORT. Getting good sleep is very important to their overall health.

    My children and grandchildren are not allowed to sleep in ANYTHING other than 100% cotton, preferably organic. It’s about time the regulators realize that the regs do not apply to half our society. We have never had a kerozene heater in our home. And we do not use space heaters. Other than the kitchen, it is almost impossible for them to be anywhere near flames of any sort. And nothing could be less healthful than sentencing them to sleep in flame retardant fabrics.

    Should all of you who sit on these regulating boards have ANY influence at all, it would truly be nice to see decent, healthful sleepwear for kids–even in Target and Walmart, where it’s polyester. I feel very sorry for people who cannot to shop elsewhere.

    And on the size issue: organic cotton, tight fitting sleepwear almost all shrink. Hannah Anderson’s don’t shrink much, but for Costco ones, our 5-year old is about to go into size 10!!! (She’s tallish and has long legs, but she’s very “normal” for her age.) “Pre-shrunk” seems to mean very little these days.

  17. Willie says:

    I do want to add that I understand many children sleep in hazardous environments. And many parents cannot provide less hazardous environments (although they could ALL quit smoking, NOW).

    Those families have my heartfelt concern and compassion.

  18. W says:

    1. Sizing cannot be set by regulation it just does not work in a free market economy. My girlfriend is Russian and I can confirm the communists already tried it and it didn’t work for them either. The EU keeps trying for it but even they realize it isn’t practical from a free market perspective.

    2. Sleepwear that is too tight (I am one of those sensitive people who cannot stand to be wrapped in anything tight) cancer causing flame retardants, etc. are not the answer. Keeping children away from flames is the answer (Formerly known as PARENTING).

    3. Sizing that is too tight forcing children or adults to choose loose fitting apparel of another type completely defeats the purpose. Tell parents that tight fitting is better and let them choose the appropriate sleepwear for their own child. Somewhat tighter on a lot of children is better than adult t’s etc. on the same children.

    5. For myself I’ll thank the government to keep its nose out of my sleepwear choices and I’ll sleep naked. I suppose for my children the only choice will be to sleep in a tightly wrapped, wet, wool blanket…..

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