Children s Sleepwear: Procedures Manual

Transcription

1 Children s Sleepwear: Procedures Manual Version 7 This Manual contains Tween Brands procedures for compliance with the Consumer Product Safety Commission (CPSC) Standards for Children s Sleepwear (16 CFR Parts 1615 and 1616) and the Health Canada Children's Sleepwear Regulations (SOR/ )

2 Table of Contents Section 1 Introduction Procedures Manual Federal Regulations and Too, Inc. s Procedures Junior Sizes Innerwear/Underwear Tight-Fitting Sleepwear ( TFS ) Obligations of Suppliers Testing Requirements Recordkeeping... 5 Section 2 Overview and Definitions Size Ranges Covered by Sleepwear Testing Procedures Flammability Testing Chronology Definitions of Terms... 7 Section 3 Testing and Sampling Procedures Fabric (FPU) Tests Fabrics Subject to Testing Initial Evaluation of Fabric Characteristics FPU Number Assignment FPU Number Disclosure Fabric Sample Selection for Testing FPU Samples Bulk Orders Fabric Testing Procedure Normal sampling Test criteria for the FPU Laundering Tests Remains of Testing Reprocessing or Disposal of Rejected Fabric Production Units and FPU Failures Procedures Reprocessing of FPU Disposal of a Failing FPU Disposal Labeling Tightened Sampling Plan of Subsequent FPUs Prototype Seam and Trim Tests Prototype Testing Prototype Tests Additional Prototype Testing Definitions Prototype Seam Sample Preparation Sample Sets Sewing Thread Position of Seam Prototype Trim Sample Preparation Sample Sets Sewing Thread Position of Trim Graphics Testing Prototype Seams and Prototype Trims Test Method Test Criteria One Test Per Seam or Trim Remains of Testing

3 3.3 Garment Production Testing Production Must Await Acceptable Results FPU/GPU Numbers GPU Production Testing Sampling Plan for Production Testing Garment Sample Preparation by Testing Laboratory Section 4 Labeling of Too, Inc. Sleepwear Labeling Requirements Labeling of FR Treated and Non-Treated Sleepwear Permanent labels Hangtag on garment Section 5 Recordkeeping Appendix A: FPU Criteria Appendix B: Prototype Seam & Trim Criteria Appendix C: GPU Criteria Appendix D: Summary Chart of Tween Brands Test Criteria Appendix E: Tight-fitting Sleepwear Procedures

4 Section 1 Introduction 1.1 Procedures Manual. This Manual provides procedures for Tween Brands suppliers concerning the production, testing, labeling and recordkeeping requirements for children s sleepwear garments manufactured for Tween Brands. This Manual is based on the laws and regulations of the U.S. Consumer Product Safety Commission and Health Canada (See Section 1.2 below), and incorporates additional requirements and standards developed by Tween Brands to assure compliance with children s sleepwear standards. 1.2 Federal Regulations and Tween Brands Procedures. All garments manufactured and sold to Tween Brands for retail sale as children s sleepwear (e.g., pajamas, sleepshirts, nightgowns, robes, loungewear, layettes, and other sleepwear garments) up to size 14 must comply with Tween Brands production procedures, as well as the U.S. Consumer Product Safety Commission (CPSC) regulations applicable to the flammability of children s sleepwear that appear in Title 16 of the Code of Federal Regulations (CFR) under 16 CFR Parts 1615 and 1616 ( Standard for the Flammability of Children s Sleepwear ) and the Health Canada regulations applicable to the flammability of children s sleepwear ( Children's Sleepwear Regulations, SOR/ ). In addition, all apparel, including sleepwear, must meet the general flammability standards found in 16 CFR Part 1610 ( Standard for the Flammability of Clothing Textiles ). This manual should not be relied upon as a substitute for the technical testing requirements set forth in the regulations cited above, and those regulations should be referenced for a complete description of sampling plans, specimen preparation, laundering procedures, equipment preparation and calibration, testing methodology, recordkeeping, and sample retention. 1.3 Junior Sizes. It is the policy of Tween Brands to require sleepwear in Junior sizes (larger than size 14) to meet the children s sleepwear standards and procedures described in this manual. 1.4 Innerwear/Underwear. Garments that are considered innerwear or underwear are not covered by this Procedures Manual. Please refer to the Ascena Children s Testing manual for guidance concerning flammability standards (16 C.F.R. Part 1610), labeling requirements (e.g., This garment not intended to be worn as sleepwear ), and other requirements for these types of garments. 1.5 Tight-Fitting Sleepwear ( TFS ). Garments that meet the definition of tight-fitting sleepwear in 16 C.F.R or 1616 are not subject to the testing and performance standards outlined in this manual. TFS is covered in Appendix E: TFS Procedures Manual outlines the strict measurement, labeling criteria and the requirements set forth in Health Canada s Children's Sleepwear Regulations, SOR/

5 1.6 Obligations of Suppliers. All Tween Brands suppliers involved with children s sleepwear must be familiar with and fully understand the flammability regulations for sleepwear because of the potential impact on business operations. The sleepwear regulations affect all manufacturing stages from fiber procurement through sale of the product, and must be complied with in their entirety. 1.7 Testing Requirements. All Tween Brands suppliers of children s sleepwear must provide test reports for all testing required in this Manual. Tween Brands will not accept any shipments of children s sleepwear in the absence of such reports provided to Tween Brands 1.8 Recordkeeping Section 5 of this Manual outlines the recordkeeping requirements imposed by the CPSC in connection with children s sleepwear flammability testing. Where Tween Brands acts as the importer of record, Ascena Global Sourcing will maintain the necessary records and sample. Where Tween Brands purchases the sleepwear on a landed basis in the U.S., the supplier must assure that the necessary records are being maintained in the U.S. by the importer of record. Where the sleepwear is being manufactured in the U.S., the U.S. manufacturer is required to maintain the necessary records

6 Section 2 Overview and Definitions 2.1 Size Ranges Covered by Sleepwear Testing Procedures Tween Brands requires all sleepwear garments in all sizes, as well as sleepwear garments in all Junior sizes (above size 14) to be subject to the procedures outlined in this manual. Garments which meet the tight-fitting criteria are covered in Appendix E of this manual. 2.2 Flammability Testing Chronology Sleepwear fabric, trim and garments must be tested at various points during the production process and they must meet the rigorous flammability requirements of 16 C.F.R. Parts 1615 and Tween Brands also requires all fabric to be used for its sleepwear to initially meet the general flammability standards of 16 C.F.R. Part Flammability testing must be conducted by an authorized laboratory as specified in the Ascena Quality Program Guidance for Vendors. Flammability testing is to be conducted at the following stages in the production of the sleepwear garment: 1. Fabric in original as finished state under 16 C.F.R. Part 1610 (general apparel flammability standards) 2. Fabric in original as finished state under 16 C.F.R. Parts 1615 and 1616 (children s sleepwear standards) 3. Fabric after 50 launderings under 16 C.F.R. Parts 1615 and 1616 (children s sleepwear standards) 4. Prototype seam development 5. Prototype trim development 6. Final production garment Acceptable test results must be obtained at every stage of development (fabric, prototype seams and trim tests) before proceeding with garment manufacturing

7 2.3 Definitions of Terms Char Length - the distance from the original lower edge of the specimen exposed to the flame to the end of the tear or void in the charred, burned or damaged area. Fabric Production Unit (FPU) - any quantity of finished fabric up to 5000 linear yards which has a specific identity that remains unchanged. Tween Brands requires the designation of a separate FPU for every color and print combination, even where the same fabric construction may be used for different colors and print patterns. Garment Production Unit (GPU) - any quantity of finished garments up to 500 dozen (6000 units) which have a specific identity that remains unchanged throughout the GPU except for size. Tween Brands requires the designation of a separate GPU for each color and print pattern. Sample - A sample consists of a set of five (5) test specimens. Specimen - A specimen consists of a single 3.5 x 10 (8.9 x 25.4 cm) section of fabric. For prototype seam, prototype trim, and garment seam testing, the specimen will include a seam or trim. Test Criteria - The test criteria evaluated in each test will be the average char length and the maximum char length which a sample or specimen may exhibit in order to pass an individual test. Trim - decorative materials such as ribbons, laces, embroidery, or ornaments. But, does not include functional items (e.g., findings) such as zippers, elastic, or individual pieces less than 2 in their longest dimension as long as the aggregate of such pieces does not exceed 20 square inches

8 Section 3 Testing and Sampling Procedures This section describes the various testing and sampling procedures required under 16 C.F.R. Parts 1615 and 1616, as well as any additional Tween Brands requirements. The results of all tests performed in accordance with the regulations and the procedures outlined in this Manual must be evaluated based upon the test criteria (i.e., the acceptable char lengths) outlined in the three Appendices to this Procedures Manual, as follows: Appendix A (Fabric FPU Test Results) Appendix B (Prototype Seam and Trim Test Results) Appendix C (Garment Seam GPU Test Results) For your convenience, Appendix D summarizes Appendices A, B and C and provides a summary chart to assist you in interpreting results obtained on sleepwear tested for Tween Brands, and in deciding when Tween Brands product integrity must be contacted for questionable results. Please note that Tween Brands acceptable char length criteria is somewhat stricter than the char length criteria set forth in the CPSC regulations. Accordingly, the Tween Brands acceptance criteria must be communicated to the laboratory performing the requisite testing. Please also note that while the acceptance criteria imposed by Tween Brands is stricter than the criteria applied by the CPSC in its regulations, the actual testing procedures to be employed by the laboratory must be performed in accordance with the CPSC regulations. The following sections describe the testing requirements for Fabric, Prototype Seams and Prototype Trim, and Garment Seams. Section 3.1: Fabric FPU Testing Section 3.2: Prototype Seam and Trim Testing Section 3.3: Garment GPU Testing - 8 -

9 3.1 Fabric (FPU) Tests Fabrics Subject to Testing. All fabrics must be evaluated and must meet Tween Brands acceptance criteria for children s sleepwear. Tween Brands requires a separate FPU designated for the following: - Any new fabrications or styles - Any new fibers, yarns, or fabrics - Any new yarn suppliers (even for existing fabrics already tested) - Any new colors or prints Initial Evaluation of Fabric Characteristics. All fabrics considered for use in children s sleepwear must be tested to determine if the fabric meets the flammability requirements without the use of a flameretardant (FR) finish. If the fabric does not meet these criteria, further development is needed to determine an appropriate FR finish. Once the necessary flame resistance characteristics are met, the fabric must be analyzed and a fabric specification developed. (See Section 1.7 concerning fabric specifications). In addition to the above, general flammability testing under 16 CFR Part 1610 must be performed and results of such testing should be made available to quality assurance upon request FPU Number Assignment. The fabric mill must assign a separate FPU number to each FPU quantity of production fabric as defined in Section 2.3. The actual yardage for each FPU, as well as the sequence of the rolls within each FPU, must be recorded in master records maintained by the fabric mill, as well as in records maintained by the U.S. importer of record. As noted above, separate FPU numbers must be assigned for each color/print pattern FPU Number Disclosure. The FPU number must be securely attached to fabric that is shipped and the number must appear on the following: - Cutting tickets - Fabric shipping documents - Mill production records - Test samples - Test reports - Garment shipping and customs documents - Inspection documents Fabric Sample Selection for Testing - 9 -

10 FPU Samples. The fabric mill must cut the following fabric for testing: -Four (4) yards from the beginning of the first fabric "piece" (defined as a fabric roll or bolt) of each FPU; and -Four (4) yards from the end of the last "piece" of each FPU Each of these four-yard segments should be cut into half creating two equal segments, which must be identified with the FPU number and the location within the FPU (e.g., beginning and end). A two-yard segment from the beginning and a two-yard segment from the end of the goods must be forwarded to the authorized laboratory for testing. A completed test request form must accompany the samples to the authorized laboratory. The remaining two-yard segments from the beginning and end of the fabric piece must be forwarded to the U.S. importer of record for recordkeeping. All samples cut from the FPU unit pieces must be clearly marked in sequence. This sequence needs to be highlighted on the following records: - Cutting tickets - Fabric shipping documents - Mill production records - Test samples - Test reports - Garment shipping and customs documents - Inspection documents The two-yard samples sent to the authorized laboratory should have a sufficient amount of fabric to perform a retest if one is necessary. However, if an FPU fails and it is decided to salvage pieces from the FPU, additional sampling will be required. See Section

11 Bulk Orders. All commercial FPU s sent for certification testing must be bulk piece goods, which are finished on bulk equipment. Fabrics produced on pilot equipment or in small quantities can be tested, but this data can only be used for product development purposes and cannot be used to certify an FPU Fabric Testing Procedure Normal sampling Test criteria for the FPU Single layer fabrics. From the two-yard segment provided, the test laboratory will prepare four (4) sample sets of five (5) specimens in each sample set. Each specimen cut will measure 3.5 x 10 from the two yard segment provided. For each sample set, two specimens are cut from one fabric direction (e.g., warp or fill), and the other three specimens are from the other fabric direction. Two of the sample sets will be prepared from the fabric as received (as finished), one from the beginning of the FPU and the other from the end of the FPU. The two remaining sample sets will be prepared from the fabric after it has been washed and dried 50 times. Again, one sample set is from the beginning of the FPU and the other is from the end of the FPU. Multi-layer fabric constructions should be tested according to detailed requirements of 16 CFR (b) 8. Tween Brands quality assurance must be consulted before testing any multi-layer fabrics. If an FPU meets the Tween Brands criteria stated in Appendix A, go to section 3.2. If an FPU does not meet this criteria, Tween Brands quality assurance must be notified immediately. If Tween Brands approves a plan to reprocess and retest the fabric, please refer to Section

12 Laundering Tests. For each new fabric color / new design, a test is required after 50 wash and dry cycles. The two-yard sample from the beginning and end of the FPU should be sufficient for this testing. If this initial 50 wash / dry test of the new fabric FPU passes, and the fabric has not been flame retardant (FR) treated, then no further tests after washing/drying will be required for the subsequent FPU s within a given GPU. The subsequent FPU s still must be tested in original state. NOTE: FR (Flame Retardant) Treated Yarn or Fabric. If the yarn or fabric is treated with a flame retardant finish (e.g., a chemical additive or reactant is applied to the yarn or fabric), then every FPU consisting of that FR treated fabric must be tested in both original state and after 50 wash/dry cycles. Exception for Specialty Yarns: If a fabric is made from a specialty yarn that was created with FR characteristics as part of the formation of the yarn itself (but not involving a chemical applied or added to the yarn after formation), then only the first FPU will have to be tested after laundering. This will apply when the fabric, in one color is utilized for multiple styles within a season. The first FPU will require testing after laundering. Assuming test results are satisfactory and the fabric for all styles was produced at one time, subsequent FPU s do not require testing after laundering. However, the additional FPU reports must reference the original test report containing the after laundering results. Tween Brands must be informed in advance if any specialty yarn will be used so that it can determine whether or not the fabric will be exempt from the requirement to test every FPU after laundering Remains of Testing. All test remains for a given test are to be collected by the testing laboratory and packaged in an envelope. The envelope must be packaged in an airtight manner and identified by test and FPU number and forwarded to quality assurance at the U.S. importer of record for storage with the master records Reprocessing or Disposal of Rejected Fabric Production Units and Subsequent Testing Requirements The procedures outlined below may only be performed with the approval of quality assurance at Tween Brands FPU Failures. FPU s which fail 16 CFR Parts 1615 and 1616 may be reprocessed, re-tested and certified for use,

13 provided the tightened sampling plan is used and test results are acceptable. Otherwise, the FPU can not be used in the manufacturing of children s sleepwear. The FPU will be held in a secure area until the fabric can be reprocessed to meet the testing requirements of 16 CFR Parts 1615 and 1616, used in non-sleepwear apparel or sold. (See Section for labeling requirements) Procedures. If the FPU is re-tested, the FPU must be cut into multiple pieces and tested in numerous locations. See 16 CFR 1615 and c (4) i - iv for procedures and acceptance criteria Reprocessing of FPU Disposal of a Failing FPU An FPU may possibly be reprocessed to improve its flammability characteristics. If so, reprocessing procedures and results of re-testing under a tightened sampling plan (e.g. beginning, middle, end) must be documented and submitted to quality assurance for record keeping. If the fabric is reprocessed, all records must be marked clearly as REPROCESSED including: * Cutting tickets * Fabric shipping documents * Mill production records * Test samples * Test reports * Garment shipping and customs documents * Inspection documents All yardage in the F.P.U unit must be accounted for if the fabric is reprocessed Disposal. If a failed FPU is destroyed or resold for other apparel use, a written plan for the disposition of these goods, along with all documentation concerning disposal, must be forwarded to the U.S. importer of record for recordkeeping. All yardage in the FPU unit must be accounted for prior to the disposal of any failed fabric

14 Labeling. An F.P.U that does not meet the requirements of 16 CFR Parts 1615 and 1616 must be labeled as follows: REJECTED FPU. THIS FPU DOES NOT MEET THE REQUIREMENTS OF 16 CFR 1615/1616. DO NOT USE IN CHILDREN S SLEEPWEAR Tightened Sampling Plan of Subsequent FPU s Any subsequent FPU s that are identical to the original failed FPU must be put into a tightened sampling plan after a failure is obtained. The tightened sampling plan requires that an additional sample (5 specimens) be taken from the middle of each FPU, increasing the number of specimens tested per FPU from 10 specimens to 15 specimens. Follow the procedures and criteria cited in 16 CFR 1615 and (c) 3. The fabric style, regardless of color or print, must stay on the tightened sampling plan until five (5) subsequent FPU s pass, after which the style can be moved back into a normal sampling plan. If a fabric has to remain on the tightened sampling plan for 15 consecutive units due to repeated failures, then this fabric must be discontinued. The cause of the failure must be identified and the quality of the fabric must be improved before it can be returned to production

15 3.2. Prototype Seam and Trim Tests Prototype Testing Prototype Tests Prototype testing includes testing of proposed seam constructions and garment trims (excluding findings) before garment production begins so as to confirm that a proposed seam or trim is suitable for use in children s sleepwear. Actual production fabric, trims & thread should be used to construct the sample specimens. Each color and print shall be tested. Prototype testing is only required for the first FPU of each GPU, or series of GPU s, when color, print, garment style, etc. are identical Additional Prototype Testing. If there are changes in factory manufacturing practices, or if a new type of thread is used, or if there are changes in the garment construction, additional prototype seam and trim testing shall be required Definitions Seam - the place where two panels of fabrics used in garment are joined typically by stitching. Edge finishes such as hems and bindings are not considered seams. Trim - means decorative materials such as ribbons, laces, embroidery, or ornaments. It does not include functional items (e.g., findings) such as zippers, elastic, skin tight rib knit at wrists, or ankles or individual pieces less than 2 in their longest dimension unless the total area of such pieces exceeds 20 square inches. Functional items - such as buttons, zippers and elastic (also called findings). Seams used to attach findings do not have to be tested Prototype Seam Sample Preparation Sample Sets. Each sample set consists of 5 specimens (3.5 wide x 10 long). Make 3 sample sets (15 specimens) for each type of seam that will be used in the garment (e.g., reinforced seam, 3-thread overlock stitch seam, etc.). A duplicate set of seam samples must be forwarded to the U.S. importer of record for recordkeeping

16 Sewing Thread. Use the specific sewing thread that will be used in commercial production of the garments Position of Seam. The seam should be positioned in the center of the specimen Prototype Trim Sample Preparation Sample Sets. Each sample set consists of 5 specimens (3.5 wide x 10 long). Make 3 sample sets (15 specimens) for each type of trim that will be used in the garment (e.g., flat trim, piping, etc.). A duplicate sample set must be forwarded to the importer of record for recordkeeping Sewing Thread. Use the specific sewing thread that will be used in commercial production of the garments Position of Trim. If the trim used in a vertical position on the garment, it should be positioned in the center of the fabric specimen. This includes all sleeve and neckline trim. If trim is only used in a horizontal position on the garment, it should be attached to the bottom edge of the fabric for testing. This includes prototype testing of trims for use as waist drawstrings. If more than 1 row of trim is used in the garment, then the specimens must be prepared with the same trim placement (same number of rows of trims & spacing) as the production garment Graphics. Prototype testing must include testing of all graphics in order to confirm suitability of use Testing Prototype Seams and Prototype Trims Test Method. The method used for prototype seam or trim testing is the same as testing of the fabric, except that 15 specimens are tested (i.e., 3 sample sets of 5 specimens) Test Criteria. If a proto seam or trim meets the Tween Brands criteria stated in Appendix B, go to Section Garment Testing. If a proto seam or proto trim fails to meet the criteria listed in Appendix B, the seams can be reworked to find the optimum seam construction to pass the flammability test. However, if no seam constructions are found to provide a passing result for this FPU or fabric style, garments cannot be made from this FPU. Refer to section for disposal of the FPU

17 One Test Per Seam or Trim. The proto seam and proto trim tests do not have to be repeated for subsequent FPU s or GPU s if the fabric, garment seams and trim construction are identical in terms of color, print and style. This applies to reorders of styles which have been previously tested with satisfactory results as long as there are no changes in trim, color, materials, design. The report number for the original seam/trim prototype testing must be referenced on all GPU reports of the re-order Remains of Testing. All test remains for a given tests are to be collected by the testing laboratory and packaged in an envelope. The envelope must be identified by test and FPU numbers, along with the prototype design. The envelope must be maintained at the Ascena Global Sourcing overseas office in an airtight bag or the U.S. importer of record s office

18 3.3 Garment Production Testing Production Must Await Acceptable Results. Garment production can begin when there are acceptable test results for each FPU, and for prototype seam and prototype trim constructions. Each Garment Production Unit (GPU) can include only one color/print pattern. The garment manufacturer and the importer of record must maintain a record of GPU designations in their records FPU/GPU Numbers. When fabric panels are cut and bundled, the appropriate FPU & GPU numbers must be stated on the bundle ticket for each set of garments being produced. All residual fabric pieces left over during production must be clearly marked with the appropriate FPU number GPU Production Testing Sampling Plan for Production Testing. For each GPU, randomly pull seven (7) garments (individual garments or sets) for testing and recordkeeping purposes. These should be pulled from various points during the production. If a GPU includes several FPU s, samples should be pulled from each FPU. Record the approximate production unit that each garment represents (e.g., unit 21 out of 6000 units) on test request forms and on garment labels. Five (5) garments should be sent to the laboratory for testing and two (2) garments (sizes 5-14 only) to the importer of record for recordkeeping Garment Sample Preparation by Testing Laboratory Cut three sample sets from the randomly selected garments. A total of 15 specimens containing seams positioned in the center of the specimen will be necessary. Very Important: A maximum of five specimens, or one sample set, can be cut from one garment. All specimens from a single garment must be in the same test sample set. The specimens should be cut from the longest seams in order to get the 10 length needed for the test specimen. If the largest size garment does not contain 10 seams, cut a specimen of 3 ½ wide by the maximum available seam length, with the seam in the center and extending the entire specimen length. Test using the same procedure as for fabric and proto seam testing

19 If the production garment test meets the Tween Brands criteria stated in Appendix C, the garments in that GPU may be shipped and released for sale. If the production garment test fails, then the entire GPU must be disposed of. All rejected garments must not be retested, used, or promoted for use in children s sleepwear unless they have undergone some form of re-work to improve flammability and these garments obtain passing test results. In the event of a fail/pass Tween Brands will validate the GPU upon arrival to the Distribution Center. All test remains for a given set of GPU tests are to be collected by the testing laboratory and packaged in an envelope. The envelope must be enclosed in an airtight bag and identified by test and GPU number and forwarded to the importer of record for recordkeeping

20 Section 4 Labeling of Sleepwear 4.1 Labeling Requirements. Garments must follow Tween Brands labeling practices for compliance with the U.S. labeling rules and regulations under the Textile Fiber Products Identification Act (16 C.F.R. Part 303), the Care Labeling Rule (16 C.F.R. Part 423), the Consumer Product Safety Improvement Act (CPSIA, Title I, 103), and any applicable labeling requirements under the sleepwear flammability standards in 16 C.F.R. Parts 1615 and 1616, as well as Canadian labeling requirements (including but not limited to the requirements under the Hazardous Products Act (R.S.C., 1985, c. H-3) and related regulations). 4.2 Labeling of FR (Inherent) or Non-Treated Sleepwear Permanent labels (heat transfer or satin) - Two labels shall appear in the garment as follows: Brand, Content, Care label FPU, GPU and Tracking label Two piece sets should have labels in both pieces. See label page in Tech Package for placement. A. Brand/Content/Care Label* Brand Identification Country of Origin Fiber Content Statement - Flame Resistant Size Registered Number (RN) Care Instructions (including any warning statements about treatments to be avoided) Factory ID * Note: The information on the Brand/Content/Care Label cannot be covered or obscured in any other way by any other label. B. FPU, GPU and Tracking Label Minimum dimensions ½ x ¾ FPU/GPU numbers in letters at least 1/6 high and easily readable. Permanently attached to be easily seen by the consumer. Must remain legible for the life of the garment. If on the care label, FPU/GPU numbers must be separated from the other information by a 1.0 space

21 Tracking Label information consists of style number, factory ID number, month/year of production - printed on back Hangtag on garment A. Registered Brand Name B. Statement This garment meets Consumer Product Safety Commission requirements for children s sleepwear

22 Section 5 Recordkeeping 5.1 All testing and manufacturing records, including all requisite samples and remains of testing, must be kept for a minimum of 3 years from the time the garments are shipped to Tween Brands. All records shall be maintained until instructed by Product Integrity and Tween Brands legal counsel that the records can be destroyed and samples can be disposed of. 5.2 No goods can be released for shipment without having a passing test report on file with Tween Brands quality assurance. 5.3 The U.S. importer of record (or U.S. manufacturer if made in the U.S.) must hold a copy of the following information: A record of all children s sleepwear produced for Tween Brands Documentation as to what flammability test method the garment(s) are certified to A record of all items listed below. There must be a mechanism to trace the flow of FPU s and GPU s warehousing, cutting records, and shipping documents. These records must be logged into Children s Sleepwear Database. A B C D E F G H I J K L M N O P Tween Brands purchase order Fabric Manufacturer and location Fabric specification fiber content, construction, finishes, etc. FPU numbers with actual yardage, piece sizes, and order of the pieces within the FPU Garment Manufacturer and location Country of origin of garment Garment specification fiber content, thread type, seam construction, etc. Yield yardage (e.g., fabric yardage/dozen garments) GPU and # of units per GPU Manufacturer identification and style number for trims, threads, and findings Types of seams Units (sizes of projected and actual shipped) Shipment date Test report numbers and results Samples on hand (e.g. fabric, proto seams & trim, garments, residual burn specimens for all flammability tests) Record of sampling plans (e.g., unit designations [45/6000] and type of sampling - normal, reduced, tightened)

23 5.3.4 Test Reports. Copies of all test reports for fabric(fpu), prototype seam, prototype trim, and garment (GPU) testing. If an FPU is reprocessed, or if a prototype seam or prototype trim is reworked, detailed records of any retesting must be maintained Disposal Records. If applicable, records concerning the details of any disposal for rejected FPU s and GPU s must be maintained Samples The U.S. importer of record (or U.S. manufacturer if made in the USA) must hold physical samples of the items listed below. These samples must be kept clean and undisturbed in the company s office or other designated storage facility. Also, a 4 by 4 swatch of the fabric from each FPU tested should be attached to the test report or scanned into electronic records. A B C D E Two 2-yard samples from beginning and end of each FPU tested. A set of fifteen (15) specimens for each prototype seam construction for each GPU tested. A set of fifteen (15) specimens for each prototype trim construction for each GPU test record. Two (2) finished garments for each GPU test record. Residual specimens from all flammability tests. Sample sets should be grouped and these sets should be placed in an envelope and marked with the appropriate test number, FPU, seam or trim type and GPU designation

24 Appendix A Tween Brands Fabric Test (FPU) Criteria a) Sample Sets. If one or both of the sample sets have average char lengths greater than 4.0 but less than or equal to 5.5, discuss with product integrity. If the average char length for one or both sets is greater than 5.5, reject the FPU. b) Individual Specimens. If one or more of the 10 individual specimens has an individual char length of greater than 6.0, but less than or equal to 9.5, discuss with product integrity. If two or more specimens have char lengths greater than 9.5, reject the FPU. c) Additional Testing. If only one individual specimen from the 10 selected specimens has a char length greater than 9.5, select five additional specimens from the piece in which the failure occurred. If this additional sample passes the Sample Set criteria listed above in (a), and has no individual specimens where the char length exceeds 6.0, accept the FPU. If this additional sample fails the Sample Set criteria in (a), or has one or more individual char lengths greater than 6.0, discuss with product integrity. d) Accept FPU. If both samples meet the average char length criterion of being less than or equal to 4.0 and there are no individual specimens with a char length greater than 6.0, accept the FPU. See Appendix D for Decision Support Summary

25 Appendix B Tween Brands Prototype Seam & Trim Test Criteria a) Sample Sets. If one or more of the three sample sets have average char lengths greater than 5.0 but less than or equal to 6.5, discuss with product integrity. If any of the three sample sets have average char lengths greater than 6.5, reject the prototype design. b) Individual Specimens: Discuss. If two or more of the 15 individual specimens have char lengths greater than 7.0 but less than or equal to 8.0 or if one individual char is equal to 10.0, discuss with product integrity. c) Individual Specimens: Reject. If three individual specimens from the 15 selected specimens have individual char lengths greater than 8.0 or if two individual chars are equal to 10, reject the prototype design d) Retesting. If an error in prototype construction is suspected, prepare three more sample sets and retest. Upon retesting, reject the prototype unit if it fails to pass the requirements outlined above in (c) the second time. If these additional sample sets pass (e) and have no individual specimens where the char length is greater than 7.0, accept the prototype unit. If the additional sample sets fail (e) but are within the parameters in (a) and (b), discuss with product integrity. e) Accept Prototype. If all three sample sets meet the average char length criterion of being less than or equal to 5.0 and there are no specimens, or only one specimen, with an individual char length greater than 7.0, accept the proto design. See Appendix D for Decision Support Summary

26 Appendix C Tween Brands Garment Test (GPU) Criteria a) Sample Sets. If one or more of the three sample sets have average char lengths greater than 5.0 but less than or equal to 6.0, discuss with product integrity. If the average char length is greater than 6.0, reject the GPU. b) Individual Specimens: Discuss. If three or more of the 15 individual specimens have individual char lengths greater than 7.0 but less than or equal to 8.0, or if one individual char is equal to 10.0, discuss with product integrity. c) Individual Specimens: Reject. If four or more of the 15 have individual char lengths greater than 8.0 or if two individual chars are equal to 10.0, reject the GPU. d) Accept GPU. If all three sample sets meet the average char length requirement of being less than or equal to 5.0 and there are no specimens, or no more than two specimens, with individual char lengths greater than 7.0, accept the GPU. e) Seam Selection. If 10 seams are not available, and smaller specimens are utilized (at least 3 1/2 wide by the maximum available seam length, with the seam in the center and extending the entire length), if all 3 sample sets have average char lengths less than 6.0, and there are no more than two individual specimens with full length burns, accept the GPU. See Appendix D for Decision Support Summary

27 Appendix D Summary Chart of Tween Brands Children s Sleepwear Flammability Test Criteria Decision FPU Test Results Sample Sets Individual Specimens Proto Seam & Trim Test Results GPU Test Results Sample Sets Individual Specimens Sample Sets Individual Specimens REJECT One (1) or more average char sample sets greater than 5.5 Two (2) or more individual char specimens greater than 9.5 One (1) or more average char sample sets greater than 6.5 Three (3) or more individual char specimens greater than 8.0 or if two (2) individual char specimens equal to 10 One (1) or more average char sample sets greater than 6.0 Four (4) or more individual char specimens greater than 8.0 or if two (2) individual char specimens equal to 10 CONTACT TWB product integrity * One (1) or more average char sample sets greater than 4.0 and less than or equal to 5.5 One (1) or more One (1) or more individual char average char specimens greater sample sets than 6.0 and less greater than 5.0 than or equal to and less than or 9.5 equal to 6.5 Two (2) or more individual char specimens greater than 7.0 and less than or equal to 8.0 or if one (1) individual char specimen equal to 10 One (1) or more average char sample sets greater than 5.0 and less than or equal to 6.0 Three (3) or more individual char specimens greater than 7.0 and less than or equal to 8.0 or if one (1) individual char specimen equal to 10 ACCEPTABLE All average char sample sets less than or equal to 4.0 Zero (0) individual char specimen greater than 6.0 All average char sample sets less than or equal to 5.0 One (1) or fewer individual chars greater than 7.0 All average char sample sets less than or equal to 5.0 Two (2) or fewer individual chars greater than 7.0 All children s sleepwear products must meet the requirements published in 16 CFR 1616 \See Operating Procedures and Appendices A-C for further details *Contacts: By policy, results in the middle yellow range must be reviewed on a case by case basis by product integrity at Tween Brands

28 Appendix E Tween Brands Tight-fitting Sleepwear Procedures Children s Tight-Fitting Sleepwear (TFS): Procedures Manual This Manual contains Tween Brands procedures for compliance with the Tight- Fitting Sleepwear ( TFS ) within the Consumer Product Safety Commission Standards for the Flammability of Children s Sleepwear (16 CFR Parts 1615 and 1616) and the Health Canada Children's Sleepwear Regulations (SOR/ )

29 Section 1. Introduction 1.1. Procedures Manual. This document provides procedures for Tween Brands suppliers relative to the measurement, labeling and testing for sleepwear, meeting the tight-fitting sleepwear criteria Federal Regulations and Tween Brands Procedures. All garments intended for sale as children s sleepwear (e.g., pajamas, sleep shirts, nightgowns, robes, loungewear, layettes, and other sleepwear garments) up to size 14 must comply with Tween Brands production procedures as well as U.S. and Canadian government requirements, which are enforced by The U.S. Consumer Product Safety Commission (CPSC) and Health Canada. The CPSC regulations applicable to the flammability of children s sleepwear appear in Title 16 Code of Federal Regulations (CFR) Part 1615 Standard for the Flammability of Children s Sleepwear: Sizes 0 Through 6X and 16 CFR Part 1616 Standard for the Flammability of Children s Sleepwear: Sizes 7 Through 14, and Health Canada s regulations appear in the Children's Sleepwear Regulations, SOR/ In addition, all apparel, including sleepwear, must meet the general flammability standards found in 16 CFR Part 1610 Standard for the Flammability of Clothing Textiles. This manual should not be relied upon as a substitute for the technical testing requirements set forth in the regulations cited above, and those regulations should be referenced for a complete description of sampling plans, specimen preparation, laundering procedures, equipment preparation and calibration, testing methodology, recordkeeping, and sample retention Tight-Fitting Sleepwear ( TFS ). Garments that meet the definition of tightfitting sleepwear in 16 CFR Part 1615 or 1616 and/or Health Canada s Children s Sleepwear Regulations, SOR/ are required to meet specific U.S. points of measure and Canadian flammability requirements. This TFS Procedures Manual outlines the strict measurement, labeling and flammability criteria for TFS Junior Sizes. Tight-fitting sleepwear garments in Junior sizes (above size 14) do not have to meet any TFS criteria Innerwear/Underwear. This Procedures Manual does not cover garments that are considered innerwear or underwear. Please refer to the Tween Brands General Wearing Apparel manual for guidance concerning these types of garments Obligations of Suppliers. All Tween Brands suppliers involved with children s sleepwear must be familiar with and fully understand the flammability regulations for sleepwear because of the potential impact on business operations. The sleepwear regulations affect all manufacturing stages from fiber procurement through sale of the product, and must be complied with in their entirety

30 Section 2. Tight-Fitting Children s Sleepwear Requirements 2.1. Size Requirements Garments sizes 5-14 must meet the strict measurement criteria of 16 CFR Parts 1615 and 1616 in order to qualify for the sleepwear flammability testing exemption. Garments qualifying as tight-fitting shall not exceed the maximum dimensions specified in the tables below for the seven key locations. Maximum measurements for both the CPSC (inclusive of all tolerances) and Tween Brands are listed in the below tables. Measurement points are described more fully below the tables Maximum Dimensions for Tight-Fitting Sleepwear Table 1: Girl s Tight-Fitting Sleepwear- CPSC Maximum Dimensions for (Sizes 5 to 14) (Includes Tolerance) Girl s Size cm inches Chest Waist Seat Upper Arm* / / / / / / / / / / / / / / / Thigh Wrist Ankle * Distance G to H / / / / / / / / / / / / / / / / / / / / / / / / / / ¾ ½ / ¾ / / / /8-30 -

31 Table 2: Girl s Tight-Fitting Sleepwear Tween Brands Maximum Dimensions for (Sizes 5 to 14) (Includes Tolerance) Girl s Size inches Chest Waist Seat Upper Arm* Thigh Wrist Ankle * Distance G to H /8 21 3/8 23 7/8 6 ¾ 13 ½ 4 ¾ 6 ½ 3 ¾ /8 21 7/8 24 7/ /8 4 7/8 6 7/ /8 22 7/8 26 3/8 7 ¼ 15 1/8 5 7 ¼ 4 ½ /8 23 3/8 27 7/8 7 ½ 16 1/8 5 1/8 7 3/8 4 5/ /8 24 3/8 29 7/ /8 5 3/8 7 5/8 4 7/ /8 25 3/8 31 7/8 8 3/8 18 3/8 5 5/8 7 7/8 5 1/ /8 26 3/8 33 7/8 8 7/8 19 3/8 5 7/8 8 1/8 5 5/8 Boy s Size cm inches Table 3: Boy s Tight-Fitting Sleepwear- CPSC Maximum Dimensions for (Sizes 5 to 14) (Includes Tolerance) Chest Waist Seat Upper Arm* / / / / / / / / / / / / / / / / Thigh Wrist Ankle * Distance G to H / / / / / / / / / / / / / / / / / / / / / / / / / / ¾ ½ / ¾ / / / /8-31 -

32 Boy s Size inches Table 4: Boy s Tight-Fitting Sleepwear Tween Brands Maximum Dimensions for (Sizes 5 to 14) (Includes Tolerance) Chest Waist Seat Upper Arm* Thigh Wrist Ankle * Distance G to H /8 21 3/8 23 7/8 6 ¾ 13 ½ 4 ¾ 6 ½ 3 ¾ /8 21 7/8 24 7/ /8 4 7/8 6 7/ /8 22 7/8 25 7/8 7 ¼ 14 1/2 5 7 ¼ 4 ½ /8 23 3/8 26 3/8 7 ½ /8 7 3/8 4 5/ /8 24 3/8 27 7/ /8 7 5/8 4 7/ /8 25 3/8 29 7/8 8 3/ /8 7 7/8 5 1/ /8 26 3/8 31 7/8 8 7/ /8 8 1/8 5 5/8 (iii) *The above Tween Brands Table is based on Maximum allowable dimensions. The technical designer will provide specific measurements that fit into the above dimensions and provide allowable tolerances on all points of measurement on a styleby-style basis

33 2.3 How To Measure the Maximum Dimensions for Tight-fitting Sleepwear The seven key garment measurement locations are chest, waist, seat, upper arm, wrist, thigh and ankle. The maximum dimension of the measurement must include all garment tolerances, because the CPSC does not allow any actual garment measurements to exceed these maximum dimensions. Listed below are the CPSC definitions of these key measurements with instructions on how to determine the proper measurement (please refer to Diagram 1 below): Chest - Measure distance from armpit to armpit (A to B) as seen in Diagram 1. Waist - For a one-piece garment, measure at the narrowest location between armpits and crotch (C to D). For a two-piece garment, measure the width at both the bottom/sweep of the upper piece (C to D), as in Diagram 1, and the top of the lower piece (C to D). Wrist - Measure the width of the end of the sleeve (E to F), if intended to extend to the wrist, as in Diagram 1. Upper Arm - Draw a straight line from waist/sweep D through arm pit B to G. Measure down the sleeve fold from G to H. Refer to the last column labeled as " * Distance G to H" to determine distances for each size in Table 1. Measure the upper arm of the garment (perpendicular to the fold) from H to I in Diagram 1. Seat - Fold the front of the pant in half to find the bottom of the crotch at J as in Diagram 1. The crotch seam and inseam intersect at J. Mark point K on the crotch seam 4 inches above and perpendicular to the bottom of the crotch. Unfold the garment as in Diagram 1. Measure the seat from L to M through K as shown. Thigh - measure from the bottom of the crotch (J) one (1) inch down the inseam to N as in Diagram 1. Unfold the garment and measure the thigh from the inseam at N to O as shown in Diagram 1. Ankle - measure the width of the end of the leg (P to Q), if intended to extend to the ankle, as in Diagram 1. Measure each distance as described above and multiply each measurement by 2. Compare this number to the corresponding maximum allowable measurement in Table 2, Tween Brands Maximum Dimensions for Tight- Fitting Sleepwear Sizes