A Case Study: Review of Flammability Product Testing, the Similarities and Differences Ellen Roaldi Bureau Veritas Consumer Products Services

Transcription

1 A Case Study: Review of Flammability Product Testing, the Similarities and Differences Ellen Roaldi Bureau Veritas Consumer Products Services September 22, 2016

2 Agenda Methods Analysis Applicability Requirements Exemptions Exceptions Differences Similarities Recalls Conclusions 2

3 Question

4 Question What is the required Flammability if marketing across borders? Can we test to one method and satisfy compliance of multiple countries? Consider the following Scarf Shirt Sweater Pant Sock Underwear Boot 4

5 Method Analysis

6 Applicability General Apparel Application US Canada Adult and Children s - which covers and protects head,neck or face and gloves (>14 ) Adult and Children s - all consumer products made of textile fibres Finland Netherlands Adult - No known Children s costume - apparel Adult - all clothing Children s - all clothing China EU Adult - No known Children s - Textile products worn by infants Children between ages 3-14 Adult - No known Children s - Industry practicecostume Norway Sweden Adult - all clothing Children s - all clothing Adult - all clothing Children s - all clothing 6

7 Requirements Acceptance Criteria US - Apparel Class 1: Plain surface : > or = to 3.5 sec. or more Raised Fiber: Burn time is > than 7.0 sec. or burn time is 0-7 sec with no base burns (may exhibit surface flash only) Canada - Textile Products Plain surface : > to 3.5 sec. or more Raised Fiber: May exhibit ignition or fusion of its base fibres and must be greater than 4 seconds. China Textile Fabrics Average burning time 7.0 s or average burning time is 0 to 7 seconds with no base burn, charring and melting. Exhibit rapid surface flash only. 7

8 Requirements EU Children s Costumes Up to 30mm/minute burn rate at a 45 degree slope Finland Textiles Report time to ignite if 21sec or less/ Individual burn Netherlands - Apparel For raised fiber surface the number of specimens as received which ignited charred or melted. /The flame spread of 127 mm must be no less than 4 seconds. Norway Apparel and fabrics For raised fiber surface the number of specimens as received which ignited charred or melted. Report option tested to (A or B for DC )Prohibition of law includes: 1) Children's apparel in sizes up to and including 170 cm and has a flame spread of 7.0 seconds 2) Other apparel and fabrics suitable for apparel having a flame spread of 5.0 seconds or less Sweden Apparel For raised fiber surface the number of specimens as received which ignited charred or melted. Report option tested to (A or B for DC) Textiles are acceptable if the time of flame spread > than 5.0 sec.(textiles are unacceptable if the time of flame spread is less than or equal 5s) Textiles with a flame retardant shall pass the requirement after 2 washing in addition to as received. Textiles with a raised fiber surface shall meet after 1 wash. 8

9 Differences Exemptions From Flammability Testing US -Plain surface weighing >2.6 oz.sq. yd or more / Plain or Raised Surface made from nylon, polyester, acrylic, modacrylic, olefin, and wool. Canada - None China - Wool, nylon, polyester, acrylic, modified acrylic, polyamide, polypropylene are not tested. Exempt if plain surface and over 90 g/m2 EU - None Finland - None Netherlands - Smooth fabric (plain surface) weighing more than 88 gms./ m2 and/or all fabric made from nylon, olefin, polyester, acrylic, modacrylic, and wool. Norway - None Sweden - None 9

10 Differences Product exceptions - US, Netherlands and Norway US hats, gloves, footwear and interlining fabrics Netherlands swimwear, hosiery, underwear and baby clothes (smaller than size 80). Norway Does not apply to children's apparel in sizes up to and including 170 cm or less. It does not apply to export items or production intended for export. 10

11 Differences Method Differences: Example US - 16 CFR 1610 CN - CAN/CGSB 4.2, No China - GB18401 (references 16 CFR 1610) Finland - Nordtest 029 (similar to 16 CFR 1610) Netherlands - ASTM D1230 (most recent version) Norway - ASTM D EU EN Part 2 Sweden - ASTM D

12 Differences Refurbishing (Washing and drying / DC) US / China / Netherlands follows 1DC Perchlorethylene) and (AATCC using MW(120 o F), NC, TD Cotton Sturdy Canada 1 DC ( professional ) and then follows care on product or ( NORMAL 10 REGULAR setting) with TD with exhaust temperature of 66 C ± 5 C ( DELICATES ) Finland 1DC Perchlorethylene) and (AATCC using MW(120 F), NC, TD Cotton Sturdy Norway/ Sweden coin operated DC or Commercial DC, then follow AATCC 135 per care label, if no label info then MWW (120 F and TD Normal or PP). Detergent (Per specified method) US / China / Netherlands specify AATCC 124 WOB Canada allows Tide Finland / Norway / Sweden specify AATCC124 EU- NA Equipment (Flammability tester) US / China /Netherlands / Canada/Finland /Norway / Sweden - 45 angle chamber EU - Flammability chamber and candle specified in the 16CFR

13 Differences Conditioning Temperature and Time (Minutes) Norway and Sweden: 105 C±3 C (221 F±5 F) for 15 minutes US, China, Findland and Netherlands: 105 C±3 C (221 F±5 F) for 30 minutes Canada: 105 C±3 C (221 F±5 F) for 1 hour Flame Impingement (Time) All countries except Finland: 1 second point of impingement Finland: 20 seconds Time in Dessicator (Time) US, Finland, Netherlands, Norway, Sweden: 15 Minutes China: 45 Minutes Canada:1 Hour 13

14 Similarities Small scale ignition All cover wearing apparel (But definition of apparel can differ) Testing to representative of finished production Gas supply Impingement time Recalls US and Canada joint recalls 14

15 Recall Analysis

16 Recalls Based on Violation notices: US: For all products regulated by the CPSC, the Commission issues a Letter of Advice (LOA) when there is a violation of a mandatory standard. It advises the company of the violation and of the nature of the necessary corrective action (to correct future production (CFP); to stop sale and CFP; or to recall, stop sale, and CFP). Canada and EU: Based on recall data. April 2014 to present US CANADA EU Total # garments sold 35, ,486 unknown 20,

17 Conclusion 1. It is necessary to understand all of the regulation details for applicability or exceptions. 2. It is not possible to test once for a global approach. 3. Testing is required per the countries code. 4. Different versions of the same method have different parameters of testing, therefore you must consider the year it was written. 5. Recalls / LOA s have an even greater impact than before. In addition, globally they are being enforced and there are now joint recalls between US and CN. 17

18 - Copyright Bureau Veritas

19 Contact Information For more information, you can reach me at the following: Ellen Roaldi (716)