Children's Apparel & Accessories – Product Safety Guidelines
HILDREN'S APPAREL & ACCESSORIES
PRODUCT SAFETY GUIDELINES
SAFETY BY DESIGN SAFETY IN USE SAFETY ALWAYS
Children's Apparel & Accessories – Product Safety Guidelines
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Children's Apparel & Accessories – Product Safety Guidelines
Contents
Children's Apparel & Accessories – Product Safety Guidelines
Preface This industry guide is designed to assist
Ultimate responsibility for product safety
manufacturers, importers, suppliers, retailers
remains with the supplier1. Suppliers
and regulators to understand, identify and
must ensure that products are not only
mitigate critical safety hazards associated
safe-by-design, but that they are also
with children's apparel and accessories
manufactured to the same safe levels and
designed, marketed and intended for children
standards as those samples reviewed and
from birth up to and including 14 years of age.
approved during the design and development stages.
This industry guide was developed in consultation with key stakeholders
including industry suppliers, retailers,
This document is a result of the collective
regulators, testing laboratories and
input from various retail organisations
consumer associations.
and their representatives, under the
Risk management principles have been
broader banner of the National Retail
adopted from a variety of existing
Technical Standards Committee. Their
industry standards and frameworks: A
efforts are recognised and appreciated.
process referred to as a "horizontal standards approach". The risk
National Retail Technical
assessment model addresses a variety of
Standards Committee
hazards in a modular approach based on
product features to ensure products are
The National Retail Association's
designed and engineered to a safe
Technical Standards Committee is a group
of quality assurance and product
When designing children's apparel and
compliance specialists who come
accessories, it is essential to take into
together from many of Australia's retail
consideration the behaviours of the
businesses to discuss the challenges of
children, whose need for exploration and
product safety and compliance.
challenge drives them to use products in
The Committee is an important forum for
new and different ways. One common
the development of retail industry policy.
factor children share is that they are
It communicates regularly, on behalf of
unaware of the cause and effect and are
the industry, with government decision-
therefore substantially less cautious than
makers and agencies, including Standards
adults in relation to hazards. Products
Australia, the ACCC, offices of Fair Trading
must therefore be safe for their intended
and Consumer Affairs, the National
use and foreseeable conditions of misuse.
Measurement Institute and others, conveying the issues and concerns of the retail sector.
1 Supplier in this context means: 1) The actual manufacturer for goods manufactured in Australia. 2) For goods imported into Australia, the organisation responsible for importing the products.
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To provide industry guidelines that assist
Aspects of safety covered by existing
manufacturers, importers, suppliers, retailers
legislation are not included within the scope
and regulators to understand, identify and
mitigate critical safety hazards associated with children's apparel and accessories
1. Children's nightwear and limited
daywear: Legislated requirements –
designed, marketed and intended for children
performance and labelling
from birth up to and including 14 years of age.
2. Apparel labelling: Legislated
requirements – care instructions, fibre
content and country of origin
3. Disguise costume: as these types of dress
The requirements of this guide apply to
up's garment are captured in the scope of
Children's apparel and accessories designed,
AS/NZS ISO 8421 Toy safety
marketed and intended for children from
4. Safety frameworks covering products not
birth up to and including 14 years of age. The
typically associated with apparel and accessories (e.g. FSANZ, APVMA, TGA,
guidelines provide a safety assessment
Cosmetics) unless they are referenced in
framework that focusses on the known
some way within certain sections of the
hazards, particularly relating to inhalation and
ingestion, strangulation as well as other
potential physical injuries.
Reference Standards
Assessment of safety requirements applies
Standards referenced during the compilation
initially to children's apparel and accessories
and building of these guidelines includes:
during design and development phases, so items are safe-by-design. The assessment
AS/NZS ISO 8124 Safety of Toys
must not only consider hazards that occur
AS/NZS ISO 31000:2009 Risk
during normal conditions of use, but also
management—Principles and
hazards arising from reasonably foreseeable
conditions of misuse or abuse.
HB 295.1 Product Safety Framework2 BS 7907:2007 Code of practice for the
The requirements of this guide specify
design and manufacture of children's
acceptable criteria and in some cases
clothing to promote mechanical
manufacturing "best practice" for children's
apparel and accessories such as (but not
BS EN 14682:2007 Safety of children's
clothing. Cords and drawstrings on
Metal Trims, Buckles, Rivets & Snaps
children's clothing. Specifications.
Draw Cords and ties Appliqué / Badges / Embroidery Pom, Poms, Tassels, Fringing, Braids &
2 References and extracts produced with permission from SAI Global Ltd under Licence 1207-c121.
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Part 1: Risk Assessment
Modelling
Product Safety – Legal Framework
Compliance with some product safety
The following provides readers with a short
requirements can be established and
overview of the regulatory environment that
confirmed through visual inspections (e.g. the
governs the supply of products and services in
presence of warning labels on baby bath aids),
the Australian marketplace. The framework is
whereas some standards require specialist
more intricate and involved than can be
laboratory testing to verify compliance (e.g.
captured fully within this overview. Readers
measuring the presence of lead and cadmium
are encouraged to seek additional information
in toys). Where laboratory testing is required
as determined by their specific requirements
to validate compliance, copies of test reports
and not to rely exclusively on the information
should be obtained from independent &/or
accredited laboratories.
To assist, a number of important links to
The Australian Competition and Consumer
relevant websites are provided at the end of
Commission or ACCC works closely with
government in the development of
mandatory safety and information standards.
Safety Framework Overview
These standards are often developed by using
The Australian Consumer Law ("ACL")
existing Australian Standards, Industry
commenced on 1 January 2011 and is a
Standards or parts thereof, to regulate that
schedule in the Competition & Consumer Act
products must comply with performance,
2010 ("CCA"). The ACL includes laws that
quality, information, marking &/or labelling
relate to the safety of consumer products and
obligations. It is illegal for businesses to sell
product-related services3. Product safety
products that do not comply with a
relates to how the product performs in
mandatory safety or mandatory information
normal use and also extends to the conditions
of any reasonably foreseeable use (which may
The ACCC has a number of remedies and
include foreseeable misuse).
enforcement options available to deal with
The ACL also includes a combination of
product safety related offences. These include 4
specific safety requirements (mandatory
heavy fines (for corporations and
safety and information standards) and a
individuals), the power to enforce product
general expectation that all products offered
recalls and issue court enforceable
for sale must be inherently and intrinsically
3 Specific product groups (e.g. food, therapeutic goods) are covered by regulations from other government bodies. Please visit the Product Safety Australia Website for further
4 Not an exhaustive list of the options available to the ACCC.
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Product recalls, product bans and
Further information
Mandatory Reporting
The above provides a high level overview of
The product safety legislation also covers
the safety framework in Australia. For further
product bans, recalls and mandatory
details regarding the consumer laws, product
reporting of product/service related injuries
safety and product recalls, it is recommended
that you visit the following websites:
Product bans: products may be
Australian Consumer Law website:
banned on a permanent basis by the
ACCC or on an interim basis where the
Product Safety Australia website:
regulator 5 requires an opportunity to
investigate further. It is illegal to sell products that are covered by either a
Product Safety Recalls Australia
permanent or interim ban.
Product Recalls: where a product
New Zealand Commerce Commission:
represents a significant safety risk for
consumers or does not comply with a mandatory safety or information standard6 and where the product has already been offered and sold to the public, wholesalers and manufacturers may need to withdraw products from sale and conduct a public recall.
Mandatory Reporting: where a
person has suffered death, illness or serious injury7 whilst using a product (or service), upon becoming aware of the incident the supplier8 must submit a report with the ACCC within 48 hours.
5 State or territory based regulators also have the ability to impose interim bans (applicable only in their state or territory) whilst safety investigations proceed.
6 This is a risk based assessment. Products deemed unsafe need not be covered by existing safety standards. Under the ACL safety provisions, products must simply be "safe".
7 Typically, this is where the incident has required the injured party to receive medical &/or clinical attention.
8 A supplier is defined as all participants in the supply chain and includes (but is not limited to) a retailer, dealer, distributor, importer and manufacturer.
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Risk Assessment: The Theory
Risk Assessment Methodology
The risk assessment process is intended to
Risk assessment modelling has been
steer product developers, designers and
extensively captured through a variety of
manufacturers through a series of safety-
Australian and International standards.
gateways to ensure safety is engineered into
The overall process of risk identification, risk
new products at the earliest possible stage of
analysis and risk evaluation is utilised to
a product's lifecycle. By identifying and
achieve a position of "tolerable risk", taking
substantially eliminating potential safety
into consideration design, materials,
hazards during the design and
components and construction. This is an
sample/prototype approval procedures, the
iterative process requiring repeated
risks of safety incidents arising through poor
application until a tolerable level of risk is
design is appreciably minimised.
achieved. (Figure 1 below)
Figure 1 Risk methodology
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Risk Assessment Methodology
Risk Assessment - Assessor
Before commencing the risk assessment, the
The skills required to identify potential
"conditions of use" need to be defined. This
hazards are often acquired after many years
includes an understanding of the expected
of involvement with product development, in
conditions of use as well as the reasonably
assessing and investigating problems, in
foreseeable conditions of misuse. Special
implementing corrective action plans and in
considerations relating to children and infants
updating/creating product
standards/specifications. For this reason, the
Their inability to understand the
safety- feature checklists have been created
consequences of their actions
to assist those who have been less involved in
Their lack of knowledge and
assessments so they can identify hazards and
conduct risk assessments to a high level of
overall consistency and diligence.
Their development and behaviour.
Their likelihood of being injured as
For many organisations though, the concept
compared with adults.
of conducting detailed risk assessments may
Their vulnerability compared with
be daunting. Where an organisation feels that
the skills required to conduct a thorough and
The risk assessment involves consideration for
accurate risk assessments do not exist within
3 key criteria before determining whether a
their organisation, it is recommended that the
"tolerable level of risk" has been achieved:
assistance of professional risk management
Identify the risk - What can
services or product evaluation services are
employed for these purposes.
Analyze the risk - How probable is it?
Evaluate the risk - How severe could the resulting injury be?
If a position of tolerable risk has not been achieved, then the risks need to be treated (i.e. eliminated or reduced) before the risk assessment cycle starts again.
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Risk Assessment Model
The risk assessment modelling contained within these guidelines has drawn upon the principles of "consequence" and "likelihood" used within existing standards.
"Consequence" relates to the severity when an event causes injury or damage. For the purposes of
these guidelines, "consequence" is categorised according to the following table.
Consequence (for an injury)
Injury Outcome & Treatment
Permanent Disability or Death
Extensive injuries requiring hospitalisation or substantial treatment by a registered physician
Moderate
Injuries requiring minor treatment by a registered physician but not requiring hospitalisation
First Aid Treatment
No Injuries. Mild discomfort or irritation
"Likelihood" relates to the chances or probability of an event occurring. "Likelihood" within the
design and development processes relates to the expected or anticipated rate of failure. For the
purposes of these guidelines, "Likelihood" is categorised according to the following table.
Likelihood
Expected frequency of fault/failure
Description
Almost certain
All Garments/Products
1 per 10 Garments/Products
Possible
1 per 100 Garments/Products
Unlikely
1 per 1000 Garments/Products
1 per 10,000+ Garments/Products
The "risk rating" is then determined based on the combination of consequence and likelihood
according to the following table.
Likelihood
Consequence
Moderate
Almost certain
Possible
Unlikely
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The "Recommended Actions" are then determined based upon the risk rating. The higher the risk
rating, the greater the effort required to alter the design and to re-engineer the product to minimise
or eliminate the identified risk.
Recommended Actions
High Risk
To mitigate the known/anticipated HIGH risks and to achieve a position of "tolerable risk", actions should include: Eliminate/remove the identified hazard, Modify, re-design or re-engineer the product, Introduce cautionary labelling & warnings (if appropriate9) Do not proceed with development of the product
To mitigate the known/anticipated MEDIUM risks and to achieve a position of "tolerable
risk", actions should include: Eliminate/remove the identified hazard, Modify, re-design or re-engineer the product, Introduce cautionary labelling & warnings (if appropriate)
To mitigate the known/anticipated LOW risks and to achieve a position of "tolerable risk", actions should include: Modify, re-design or re-engineer the product, Introduce cautionary labelling & warnings (if appropriate)
Minimising production risks
The primary purpose of conducting risk assessments during a product's design and development phases is to incorporate safety into the product from its origins. This is the single most effective strategy for eliminating product safety risks.
It should also be noted that, regardless of design, safety hazards may also arise within the production process. Risk may arise through:
Contamination from equipment (e.g. broken needles) Self-contamination (e.g. buttons or press-studs loose in garments) Deviation from specification (e.g. trims not attached securely) Raw materials variability (e.g. fabric properties differ from approved fabric)
The use of production and post-production quality checks are required to ensure that quality and safety are not only engineered into products from the outset, but to ensure that safety transcends through the entire end-to-end process. Production and post-production quality checks may include the following10:
Audits of factories to establish quality capabilities Quality inspections of manufactured goods to confirm items are as-approved Quality & safety checks of goods as they are being produced (i.e. in the production line) Laboratory testing to validate that production items meet specified requirements Production samples being submitted to the retailer/importer for approval prior to shipping
9 Refer to section entitled "Cautionary Labels & Warnings" for guidance regarding appropriateness of labels/warnings.
10 The scope of this document does not allow coverage of these stages in detail.
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Risk Assessment: The Practical Application
The following section explains the process steps through which the risk assessment model is applied during the product design and development stages.
The Hazards
There are 4 main classes of hazards associated with children's apparel and accessories:
Choking & Ingestion hazards
Sharp Edges and Points hazards
Strangulation and Entrapment hazards
Chemical Toxicity hazards
Other Sources of Hazards
Detailed explanations of the hazards are provided in the "Hazards" section of this document.
Product Features
A risk assessment template has been created for each of the features commonly associated with apparel and accessory products:
Applique, Badges, Embroidery
Gifts with Purchase (GWP)
Beads & Jewel Trims
Metal Trims, Buckles, Rivets & Snaps
Bows, Fabric Loops, Hanger Loops,
Decorative and 3D Motifs
Pom Poms, Tassels, Fringing, Braids &
Diamantes, Glued & Heat-sealed
Drawstrings, Functional Ties,
Zips - Slide Fasteners & Pullers
Decorative Ties & Sashes
The detailed risk assessment templates are provided in the "Features" section of this document
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Cautionary Labels & Warnings
The appropriateness of cautionary labels and warnings needs to be considered in context of the hazards and the conditions under which the warnings will impact upon the user. By example, it is not appropriate to place small parts warnings for attachments on garments where garments themselves are intended for children younger than 36 months of age.
The following points should be considered to determine the adequacy and appropriateness of proposed warning labels and instructions.
Is it reasonable to expect that by providing
Are warnings permanently attached to
the warnings there will be an impact on
the product? If so, will the instructions
the conditions of use and upon reducing
remain legible and visible throughout the
safety risks? If not effective in reducing
expected life of the product?
risk, then the use of warning labels may
Is the message written in a way that is
not be appropriate.
easily understood? Are major callouts
Do warnings explain the danger/hazard
(e.g. CAUTION or WARNING11) stated in
for users? Do warnings explain the safe
uppercase? Are graphics and images used
conditions of use? Both?
to more clearly communicate the safety
Are warnings intended to provide
cautions that influence the purchase
Do the safety warnings or instructions
decision? Are warnings prominent and
breach mandatory standards or could
visible at point of sale?
they be deemed misleading to
Are warnings intended to provide advice
and instructions regarding conditions of use? Should they be prominent and visible during use? Are they prominent and visible during use?
11 "WARNING" indicates a hazardous situation which may result in death or serious injury. "CAUTION" indicates a hazardous situation that could result in minor or moderate injury. (ANSI Z535.5 Definitions)
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Documentation & Record Keeping
It is recommended that accurate records are retained in order to:
Demonstrate due diligence: Shows that there is structure and a defined process.
Provide traceability: An auditable trail is valuable to demonstrate due-process to either
internal or external parties.
Capture "Corrective Action Plans" (CAP's): CAP's are used as a reference to ensure
required changes and improvements have been actioned.
Confirm Management Accountability: The documents should be signed or authorised by an
appropriately qualified and authorised company delegate.
Records should be readily accessible to support any investigations into alleged product failure or reported safety incidents. It is recommended that record retention times should:
1. Cover the period during which products are available for sale to customers, plus
2. Cover an additional period that represents the anticipated lifespan of the product in use.
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Hazards are defined as the potential source of harm. For children's apparel and accessories, the most prevalent hazards have been identified. For each, an overview is provided for the nature of the hazard and how it presents dangers for children.
The key hazards are:
Chemical Toxicity
Choking & Ingestion
Sharp Edges & Points
Strangulation & Entrapment
Other Sources of Hazards
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Chemical Toxicity
Hazard Overview
Chemicals, toxins, impurities and contaminants are the hidden hazards in textile production, as these are invisible, often odourless and generally difficult to detect and understand. Research into the effects of certain chemicals and the determination of what levels should be considered hazardous is ongoing. There inconsistent regulations internationally regarding acceptable limits and whether negative consequences outweigh the utility of certain chemicals, especially in view of substitution with less studied substances. Therefore standards currently vary between regions. The more stringent regulations and bans are in place in Europe and North America.
Generally young children are more vulnerable to chemical hazards. Their bodies, internal organs and major physiological systems are still developing. Metabolic, immunological, hormonal and reproductive systems are immature and more vulnerable to toxins. Innate behaviour such as sucking and frequent hand to mouth contact means they ingest substances present in their immediate surroundings.
The following section aims to provide guidance on the common uses of chemicals in the supply chain. With awareness regarding substances having the potential to be harmful to humans or an adverse impact on the environment, avoiding them in the production of children's clothing should be easier.
The following classifications can be made:
toxic substances that remain in textiles and can affect or transfer to the wearer
substances that affect workers during production
bio-accumulative substances with potentially long term effects on the environment
The Regulatory Environment
In Australia: For consumer goods, there are few chemical restrictions or guidelines. Heavy metal restrictions are found within the mandatory standard for toys and as part of import regulations. The ACCC provides some guidance on the Product Safety Australia website: By example:
Formaldehyde limits for clothing,
Diethylhexyl phthalate (DEHP) in children's plastic products, and
Azo dyes which reduce to aromatic amines.
Responsibility for the use of chemicals in Australia is overseen by the National Industrial Chemicals Notification and Assessment Scheme (NICNAS). The NICNAS mission is to aid in the protection of the Australian people and the environment by assessing the risks of industrial chemicals and providing information to promote their safe use.
The regulated environment in Europe and USA differs considerably from Australia.
In Europe, the REACH system (Registration, Evaluation, Authorisation and Restriction of Chemical
substances) makes industry responsible for assessing and managing the risks posed by chemicals and
providing appropriate safety information to their users. This is a more expansive and engaged
framework than exists in Australia
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In the USA, there is a general requirement that children's products comply with testing and certification requirements as prescribed by their Consumer Product Safety Improvement Act.
International Best Practices
Harmful substances throughout the supply chain can be avoided by putting a number of risk management tools in place, such as:
Assessing manufacturer compliance and accreditation before placing orders
Engaging suppliers to undertake steps to ensure conformance
Conducting regular product testing
The OEKO-TEX® Standard 100 is an independent testing and certification system for textile raw materials, intermediate and end products at all stages of production. Manufacturers that carry OEKO-TEX accreditation are committed to minimising risk through chemical hazards, by avoiding their use.
The Apparel and Footwear International RSL12 Management (AFIRM) Working Group has developed a Supplier RSL Toolkit which is a collection of resources to help the global apparel/footwear supply chain understand and reduce the use and impact of harmful substances.
ZDHC (Zero Discharge of Hazardous Chemicals) group members made a shared commitment to help lead the industry towards zero discharge of hazardous chemicals by 2020. The group of brands ZDHC developed and published a Joint roadmap that go in detail specific projects and actions that can be taken along with other brands to the apparel and footwear industry to the goal of ZDHC.
Harmful Chemicals List
The attached table is a compilation of information gathered from various international sources. The list represents the collective state-of-knowledge on health effects associated with chemicals. The list is intended for use during discussions with potential suppliers of products. The expectation being that suppliers provide commitments that:
They are aware of these various requirements and
The use of such chemicals should be avoided in production.
Due Diligence Requirements
The science and research in the area of chemical hazards is very dynamic and complex. This document is intended to provide some guidance and insight into chemical safety. This document is not an exhaustive review of chemical hazards and is unlikely to capture the most recent developments and regulations.
For this reason, it is recommended that risk assessments include a review and understanding of the current regulations, industry best practice and any emerging issues associated with chemicals used for children's products.
12 RSL = Restricted Substances List
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Harmful Chemicals List
Chemical
Potential Harm
Acceptable Limits
ALKYL PHENYL
Used in dyeing/finishing as
No specific regulation in
ETHOXYLATES (APEO's)
detergents, wetting agents
and emulsifying agents.
Regulated Internationally.
ALLERGENIC DISPERSE
Skin irritations.
Dyeing of synthetic fibres
No specific regulation in
(e.g. polyester, acetate,
nylon) or "plastic" parts (e.g.
Regulated Internationally.
AROMATIC
Used in some adhesives,
No specific regulation in
print formulations, solvent
(ORGANIC SOLVENTS)
scouring and spot cleaning.
Not regulated Internationally.
Used for dyeing & printing of
No specific regulations in
textile & leather products.
Australia but ACCC Product
Safety guidelines are available. Regulated Internationally.
Wide range of applications:
No specific regulation in
Stabilisers in plastics (e.g
Regulated Internationally.
Coating of metallic
Pigments used in dyes,
prints, plastics.
CHROMIUM &
Wide range of applications:
No specific regulation in
CHROMIUM VI
Dyestuffs and finishing
Regulated Internationally.
Chrome plating,
Leather tanning, dyes and
DIMETHYL FUMARATE
Skin irritation.
A mould/moisture inhibitor
No specific regulation in
used in silica sachets or in
wood & fur products.
Regulated Internationally.
FLAME RETARDANTS
Depends on exact
Flame inhibitors.
No specific regulation in
Regulated Internationally.
harmful to the environment
Fixing and cross linking agent No specific regulations in
Volatile gaseous
for dyeing, crease/wrinkle
Australia, but ACCC Product
finishes and printing.
Safety guidelines are
Products for tanning /
Regulated Internationally.
softening leather.
Bio-accumulative, Accessories and accessories
No specific regulation in
made of metals or alloys.
Regulated Internationally.
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Chemical
Potential Harm
Acceptable Limits
Variety of pigments used in paints, prints, plastics.
Bio-accumulative, Used as a preservative.
No specific regulation in
Occurs as contaminant during Regulated Internationally.
certain processes.
Skin irritations.
Shiny metals parts and
No specific regulation in
Regulated Internationally.
ORGANOTIN
Depends on exact Antifungal and antibacterial
No specific regulation in
COMPOUNDS
agent for textile and leather
Regulated Internationally.
Resins and polymers in prints, coatings, plastic parts.
PESTICIDES /
Bio-accumulative
Used by growers and
No specific regulation in
processors of cotton,
cellulosic fabrics, wool and
Regulated Internationally.
other keratin fabrics.
Skin irritation.
Most textiles & leather
No specific regulation in
Australia. Not regulated Internationally.
PHENOLS:
ORGANIC SOLVENTS
No specific regulation in
Fungicides used for textile
(cotton, viscose) and leather
Regulated Internationally.
TETRACHLOROPHENOL
(TeCP)
PHTHALATES
Softening agent for
An ACCC permanent ban is in
force for use of Diethylhexyl
phthalate (DEHP) in children's
Plastisol prints & fabric
plastic products.
Regulated Internationally.
Flame retardant for
No specific regulation in
DIPHENYL ETHER
sleepwear, protective
Regulated Internationally.
SAND BLASTING
Linked to a fatal
Mostly denim processing.
Not regulated, but
internationally accepted as
banned practice.
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Choking & Ingestion
Hazard Overview
One of the most prevalent and potentially dangerous hazards for young children is small parts or pieces that break-away or pull-away from garments or accessories. Once these small pieces become accessible to young children, they often find their way into children's mouths, upon which they present a choking or ingestion hazard13.
Detached small parts can arise through a number of circumstances:
"Normal" use: Where attachments or parts of items create small parts through the conditions of
use. By example: Bows at the neckline being plucked or sucked; Toggles on drawstring being sucked/chewed;
Washing treatments: Garments and accessories are placed under physical duress whenever
laundered. Any weaknesses in methods of attaching components can be exposed through the laundering process. By example: Diamantes glued to fabrics that become loose once washed.
Fitting or removing a garment: Attachments such as buttons or snaps that are placed under
stress whenever used, have the potential to separate and thereby create a small part.
Risks are greater for the very young. It is generally recognised that children under the age of three are most susceptible to severe outcomes from small part being swallowed. At young ages, the gag-reflex (i.e. the ability to cough to remove a blockage) has not adequately developed. If small parts are swallowed they can create a blockage that then becomes fatal.
Unfortunately, children are often reluctant to confess to their actions. This can make it difficult to establish the circumstances leading to them feeling unwell or having a reaction to something they have swallowed.
The most effective means by which hazards can be eliminated is to prevent
them from occurring in the first case.
13 Such items may also be inserted into nose or ears. Whilst medical assistance may be required for removal, there is less likelihood of resulting injury or harm.
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Test Methods & References
Laboratory Test Methods
AS/NZS ISO 8124.1 Safety of Toys Part 1: Safety aspects related to mechanical and physical properties. This toy standard provides test methods for the assessment of Small Parts (section 4.4). The tests involve subjecting toys to "abuse tests" (i.e. drop, twist and pull tests). Parts that are liberated during the abuse tests are assessed whether they fit entirely into a truncated cylinder of very specific dimensions. Parts fitting entirely into the cylinder are defined as a "small part". The specific abuse tests involve the following:
Drop test (clause 5.24.2): Based on the product's intended age group, products are dropped
from a height onto a specified hard surface for a number of drop cycles.
Age group
Drop Height (cm) No of cycles
Under 18 months
Over 18 months, up to 96 months
Torque (twist) test (clause 5.24.5): The item is clamped, a specified torque/twist is applied. The
test stops when the maximum torque (0.45 ± 0.02 Nm) is reached or when 180o rotation has been reached.
Tension Test (clause 5.24.6): A clamp is applied. A pulling force of 70 ± 2 N is applied evenly over
a period of 5 s and held for 10 s. The part being tested is pulled upwards & sidewards.
Physical Assessment
It is not practical to subject every garment, accessory, trim and attachment to a laboratory for independent testing. It is recommended therefore that in the first instance, designers, developer & technicians apply internal assessments. Such assessment should replicate, to a large extent, the abuse tests that would be conducted by laboratories (i.e. drop, pull & twist pieces to see whether parts remain attached). Should any pieces become dislodged, assess whether they fit into the standard truncated cylinder14. As performance can be affected by laundering, consideration should be given to conducting this assessment on both an unwashed and a washed sample. If the internal assessment identifies a potential small part risk or if there is an element of doubt, then:
submit a sample for independent laboratory testing, or
remove, re-design or re-engineer this aspect of the product
14 Note: Truncated cylinders are available from international laboratories at negligible cost.
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Other Considerations
"Conditions of Use" Considerations
The location of trims or embellishments on garments can influence the risk assessment. If the potential small part is placed so it can easily find its way into the mouth (e.g. on a sleeve end or on a collar tip) then it is more likely to be mouthed or sucked by a child. The same components attached at lower risk zones where they cannot be easily mouthed (e.g. back of a garment, waist of pants) will logically be less risky.
Post-Production Evaluation
It is necessary to verify that the quality and safety standards approved during the pre-production assessment of prototype samples are fully replicated and transferred into production. Choking & ingestion hazards can be introduced through variations during the production/manufacturing process (e.g. through materials variation, assembly variances, etc.) that could not have been detected during assessment of prototype samples.
The following is recommended:
Upon completion of production, the finished goods should be subjected to a final inspection.
The inspection should be conducted by independent inspectors (i.e. not the factory's QC Team) and be conducted according to a recognised statistical sample plan. The inspection should apply the "tactile assessment" standards to confirm that the performance of bulk goods does not deviate from the approved sample.
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Sharp Edges & Points
Hazard Overview
Safety risks arise for children when buttons, trims and attachments create sharp edges or sharp points. These create potential:
Penetration risks
Piercing risks, or
Slicing risks
These risks can present themselves during:
Regular use (e.g. a sharp corner edge on a buckle that causes a slicing risk when arms pass
across the edge)
Fitting or removing a garment (e.g. a star-shaped button on a front placket that creates a
sharp point risk when removing the garment over the head)
Risks are greater for the very young who are unable to communicate their discomfort or take action to remove/eliminate the risk (e.g. consider a zipper on a grow suit with sharp teeth that cause scratching and abrasions around the neckline, compared to the same zip issue for an older child's track top). Sharp points and edges should be identified through a risk assessment during the product development and approval stages, then eliminated through re-design, re-engineering or re-processing. Sharp edges and points can also arise via contamination during the production process (e.g. Broken needles, pins or staples). It is important that post-production quality controls are implemented to identify and rectify any risks introduced through the production process. Sharp edges and sharp points are often associated with the following:
Badges, brooches or decorative pins.
Beads, diamantes, sequins,
Buttons, studs, rivets
Zips, zip teeth, zip pullers
Contamination: Often metallic (e.g. broken needles, pins) but could also be non-metallic
(e.g. nylon Kimble residues)
NB: Either the item itself or the way it is attached may create the sharp edge or sharp point (e.g. a metallic badge that is attached by a safety-pin mechanism)
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Test Methods & References
Laboratory Test Methods
AS/NZS ISO 8124.1 Safety of Toys Part 1: Safety aspects related to mechanical and physical properties. This toy standard provides test method for the assessment of sharp edges (section 5.8) and for sharp points (section 5.9). Attachments that are abrasive, sharp-to-touch or likely to be uncomfortable for young children would not necessarily be identified as "sharp" if relying on testing according to the toy standard. It is therefore recommended that a tactile assessment be conducted to identify sharp edges and points rather than relying on more formal laboratory testing15.
Physical (Tactile) Assessment
Existing laboratory test methods do not provide a practical method by which sharp edges and points
can be identified. A more practical "tactile" risk assessment is required. The risk assessment involves
running hands and fingers across all surfaces for which a potential sharp edge or point could arise.
Wherever the tactile assessment identifies moderate-to-significant sharp, rough or abrasive
surfaces, then this should be deemed a point of failure. The product should be rejected with the
identified risk then being eliminated through re-design, re-engineering or re-processing – For all age
groups.
Where the tactile assessment identifies a low level of sharp, rough or abrasive surfaces, then this
should be deemed a point of failure for products suitable for "Ages up to 3 years". The product
should be rejected with the identified risk then being eliminated through re-design, re-engineering
or re-processing. For all other age groups, re-design, re-engineering or re-processing should be
considered.
Where there are Nil sharp, rough or abrasive surfaces, the product should be approved.
Other Considerations
"Conditions of Use" Considerations
In addition to the tactile assessment, consideration should be given to the "Conditions of Use". An attachment may be considered low-to-moderate risk from a sharp edge or sharp point perspective, but then be positioned on a garment in such a way that it increases the likelihood of the sharp edge or point causing an injury. (e.g. A tooth-shaped toggle/button at the neckline of a hooded jacket. Whilst the toggle may not be overly "sharp", because it passes across the face and eyes when removed overhead, this creates a higher risk through conditions of use.)
15 After checking with international laboratories, no other relevant standards or test methods could be identified
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Post-Production Evaluation
It is necessary to verify that the quality and safety standards approved during the pre-production assessment of prototype samples are fully replicated and transferred into production. In particular, for sharp edges and sharp points, risks may be introduced through the production process that would not have been present during assessment of prototype samples (eg. Broken needles). The following is recommended:
1) Upon completion of production, the finished goods should be subjected to a final inspection.
The inspection should be conducted by independent inspectors (i.e. not the factory's QC Team) and be conducted according to a recognised statistical sample plan.
2) For medium-high risk categories, finished goods should also be passed through a metal
detector to ensure that any broken needle points or other metallic foreign matter such as pins or staples are identified, isolated and the contamination removed.
3) A broken needle control system requires sewing machine operators to submit all pieces of
broken needles to a supervisor before a replacement needle is provided. Such a process should form part of a factory's standard control mechanisms, regardless of whether the factory uses metal detection devices.
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Strangulation & Entrapment
Hazard Overview
Strangulation and entrapment hazards arise through the use of cords, bows or ties used functionally or as decoration on garments. Long ties and cords have the potential to either wrap around necks or, for ties used in hoods (for example), to tighten around necks and cause strangulation. Globally, there are reports of very serious injuries and deaths occurring when knots, toggles or cord-ends become snagged or caught into moving parts or closing doors. Ties and cords with bulky cord-ends are particularly susceptible to being entrapped, especially when their length and positioning on garments allows them to hang, drape or swing away from the body. To address the variety of hazards that arise from the use of cords and ties, consideration should be given to the following:
Eliminating functional ties & cords, especially for the younger age groups
Limiting the length of both functional and non-functional ties and cords
Securing functional ties so they are unable to be removed. As an example: Bar tack the draw
cord at the centre back of a hood so it will not slide out through the channel.
Remove all knots, toggles, aglets etc. from the ends of draw cords to minimise potential
entrapment hazards (NB: Also removes potential choking and ingestion hazards)
Cords and ties around the neckline are high risk zones for strangulation hazards. Long ties
and cords at the extremities (wrists, ankles) or on waistbands of jackets are high risk zones for entrapment hazards.
The most effective means by which hazards can be eliminated is to restrict the
design & use of cords and ties: Especially in higher risk zones and for younger
age groups.
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Test Methods & References
Laboratory Test Methods
There are no specific laboratory test methods to assess or measure strangulation and entrapment hazards. Note: For cords or ties that contain an end-cap or toggle, refer to "Ingestion & Choking Hazards" for relevant test methods.
Physical Assessment
The risks introduced through the use of draw cords and ties are most appropriately identified through a physical assessment. The physical assessment will involve:
Measuring lengths of cords/ties in the relaxed state and, for functional ties, in tightened
Ensuring that drawcords are secured by stitching at the centre back of garments to prevent
them from being removed and becoming a hazard: Especially for young children's products and for hoods (for all ages).
Non-functional (decorative) treatments are used wherever possible: Especially for products
intended for very young children.
Cords and ties do not use end-treatments that create potential entrapment hazards:
Especially for cords and ties that have the potential to swing or drape away from the body.
OTHER CONSIDERATIONS
"Conditions of Use" Considerations
The location and design of cords and ties on garments can influence the risk assessment. High risk zones for strangulation are cords and ties around/near the neckline. High risk zones for entrapment are around the waists or limb extremities (ankles, wrists), especially if cords and ties can drape or swing away from the body.
Post-Production Evaluation
It is necessary to verify that the quality and safety standards approved during the pre-production assessment of prototype samples are fully replicated and transferred into production. Strangulation and entrapment hazards can be introduced through variations during the production/manufacturing process (e.g. through materials variation, assembly variances, etc.) that could not have been detected during assessment of prototype samples.
The following is recommended:
Upon completion of production, the finished goods should be subjected to a final inspection.
The inspection should be conducted by independent inspectors (i.e. not the factory's QC Team) and be conducted according to a recognised statistical sample plan. The inspection should apply the "physical assessment" standards to confirm that the performance of bulk goods does not deviate from the approved sample.
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Other Sources of Hazards
Hazard Overview
The hazards identified as being the most significant and relevant for children's apparel and accessories have been covered in detail in other sections. It is worth noting however that there are numerous other hazards which do not present risks generally for children's apparel or accessories. These hazards are listed below as an additional source of reference for risk-assessments.
Burn hazards: Hazards with the potential to cause injury by heat, friction, chemicals or solar
radiation. Flammability hazards for children's nightwear are covered by a mandatory standard
(AS/NZS 1249). Sun protective fabrics can be tested and assessed according to the standard
AS/NZS 4399.
Eye impact hazards: Hazards arising from projectiles (e.g. objects shot or fired, usually from a
toy). The toy standard (AS/NZS ISO 8124.1) contains test requirements for projectiles.
Insertion hazards: Hazards arising from children placing small objects into body openings (e.g.
ears, nose, but not the mouth). Small parts create the risk, similar to choking and ingestion
hazards. The toy standard (AS/NZS ISO 8124.1) provides methods to assess small parts.
Pinching hazards: Hazards arising from closing mechanisms that can pinch or squeeze the skin.
(e.g. Alligator clips on suspenders, overalls or hair accessories)
Projection hazards: Hazards arising from pieces or components of garments/products which
protrude in a way that could cause them to push-into or penetrate the body. (e.g. long or
elongated buttons or toggles)
Tripping hazards: Hazards arising from parts of garments that can float/sit on or near the feet
(e.g. long belts on robes, draw-cords at/near ankles on pants)
Other hazards which are even less likely to be associated with children's apparel and accessory products (such as electrical hazards, sound/noise hazards) are not covered by this document.
The most effective means by which hazards can be identified and eliminated is
to conduct comprehensive risk assessments at the design and development
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Test Methods & References
Laboratory Test Methods
Where available, test methods are named within the above definitions.
Physical Assessment
The most effective method of identifying these types of potential hazards is to conduct a physical
examination. The assessment should aim to identify all potential sources of hazard of the types
outlined above. As there are few test methods to assist with making approval decisions, it is
suggested that potential hazards are assessed by a qualified risk-assessment practitioner. In the
absence of such a practitioner, it is recommended that the risk be assessed by a panel or within a
group to ensure there is agreement (i.e. agreement on the level of "tolerable risk"). The review
process and outcomes should be documented.
Other Considerations
Post-Production Evaluation
It is necessary to verify that the quality and safety standards approved during the pre-production
assessment of prototype samples are fully replicated and transferred into production.
A variety of hazards can be introduced through variations during the production/manufacturing
process (e.g. through materials variation, assembly variances, etc.) that could not have been
detected during assessment of prototype samples.
The following is recommended:
Upon completion of production, the finished goods should be subjected to a final inspection.
The inspection should be conducted by independent inspectors (i.e. not the factory's QC Team) and be conducted according to a recognised statistical sample plan. The inspection should apply the "physical assessment" standards to confirm that the performance of bulk goods does not deviate from the approved sample.
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Part 2: RISK ASSESSMENT WORKSHEETS
Risk Assessment worksheets are provided for the most common garment / accessory trims and treatments that have the potential to cause harm. The worksheets are the practical tools and guides to be used during the risk assessment. For each trim / treatment, guidance is provided for the design of safe products. Where such trims / treatments are then used in garments, methods for identifying risks and testing performance is outlined.
Risk assessment worksheets are provided for the following trims and treatments:
2.1 Applique, Badges, Embroidery
2.2 Beads & Jewel Trims
2.3 Bows, Fabric Loops, Hanger Loops, Decorative 3D Motives
2.5 Diamantes, Glued & Heat-sealed Decorations
2.6 Drawcords, Functional Ties, Decorative Ties & Sashes
2.7 Gifts with Purchase (GWP)
2.8 Metal Trims, Buckles, Rivets & Snaps
2.11 Pom, Poms, Tassels, Fringing, Braids & Plaits
2.13 Zips – Slide Fasteners & Pullers
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2.1: Applique, Badges, Embroidery
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations for the design
The following is recommended:
and manufacture of children's clothing in relation to
Applique/badges and embroidery should remain attached under the allocated care instruction, and throughout the life
the use of Applique/badges and embroidery to
promote safety and minimise risks.
Applique/badges and embroidery stitching is to be neat and securely sewn. Stitch type, density and tension should be
Applique/badges and embroidery, though commonly
controlled to ensure complete enclosure and to avoid potential finger probing, detachment and loop forming. There
used on all forms of apparel, have the potential to
should be adequate knotting off to avoid any unravelling.
create safety hazards: Especially for small children.
Long loops and threads on internal or external areas of product should be trimmed off.
Applique/badges and embroidery that are poorly
The reverse side of an embroidery/applique/badge stitching area should be nonabrasive: Especially if likely to be in
attached to garments where they can become
direct contact with the skin. A suitable backing/fusing material may be required to provide a layer of protection.
detached or where long threads are easily accessible,
A suitable backing/fusing material may be required to conceal long float threads, knots or stitching. The backing should
pose a safety risk to young children.
completely conceal the stitched area. The backing or fusing material should be securely attached.
Sharp or pointy edges that can scratch or pierce a
Backing paper used during the embroidery process should be completely removed.
child's skin can arise through poor quality appliques or
Heat-applied or glued items (Appliques, Badges, Backing Fabric, Fusing and Interlining) should be securely attached.
badges and/or inferior finishing techniques.
Follow the manufacturer's application instructions to ensure effective adhesion.
Coatings and materials of appliques/badges,
The application processes must be consistent throughout production. Ensure that the attachment methods and critical
ingredients used within liquid fillings of badges, should
quality points are adequately controlled to deliver consistency and reproducibility.
not contain chemicals with known health impacts.
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2.1: Applique, Badges, Embroidery
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary
Further Testing / Assessment
Assessment
2nd Level
Conduct "Further Testing"
Assessment
≥3 and ≤ 7
>7 and ≤14
if risks are identified
Choking & Ingestion
Applique/badges and
embroidery may become
and any backing or fusing
Pull & twist on
Required for heat
Required for age
material used must be
applique/badges to assess
applied badges or
securely attached.
ease with which it detaches
when preliminary
assessment fails
Visual review of stitching
or has cause for
Delamination
Visual review and pull & twist to assess ease with which it detaches.
Sharp Edges & Points
Applique or badges may have
Applique and badges should
Tactile review for sharp or
sharp edges due to the:
be free from sharp edges
stitching threads cutting
through the material
finish applied ( heat sealing
Badges attached to garments
Pins used for the purpose of
Visual Assessment
attaching badges or brooches
Required for age
to garments should have a
Recommend an alternate
design or component
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2.1: Applique, Badges, Embroidery
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary
Further Testing / Assessment
Assessment
2nd Level
Conduct "Further Testing"
Assessment
≥3 and ≤ 7
>7 and ≤14
if risks are identified
Sharp Edges & Points
Badges that are shaped
Badges should not create a
Tactile review for sharp or
intentionally by design or
sharp or pointy edge.
manufactured with sharp or
Chemical Toxicity
The material, coatings or the
Badges should not contain
Consult supplier to confirm
substance contained within the
any of the known irritants:
that no coatings or materials
filling of badges may contain
as listed in AS/NZ ISO
contain chemicals known to
chemicals that are hazardous
8124.3 Migration of
cause skin irritations or
there is a cause
there is a cause
there is a cause
when in oral or skin contact.
certain elements
health problems.
as listed/recognised as
health risks (refer to
"Hazards: Chemical
Find alternate source of
"Hazards:
Toxicity")
materials, coatings etc. when
verification cannot be
Toxicity"
section for further info.
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2.2: Beads & Jewel Trims
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations for the design
The following is recommended:
and manufacture of children's clothing in relation to
Beading & Jewel trims should remain attached under the allocated care instruction, and throughout the life of the
the use of beads and jewel trims to promote safety
and minimise risks.
Claws of jewels should be avoided for young age groups. When used, claws should be fully clamped to ensure that they
Beads & Jewel trims, though commonly used for all
remain enclosed.
forms of apparel, have the potential to create safety
Beading and jewel trims made from glass, ceramic, natural materials such as wood & shell are not recommended
hazards: Especially for small children.
because they can crack and break easily when bitten by young children.
Beads & jewel trims that are poorly attached to
Machine lock stitching is the recommended form of attachment.
garments or that easily break can become a "small
Hand stitched beads should be back-stitched and knotted off securely to avoid detachment.
part" that is easily mouthed and swallowed by young
Long loops and threads on internal or external areas of product should be trimmed.
A suitable backing material may be required to conceal long float threads, knots or stitching and to fully secure a bead or
Sharp or pointy edges that can scratch or pierce a
jewel trim from detaching. For example, backing fabrics may be required for reinforcement in instances where the base
child's skin can arise through poor quality or badly
fabric is light weight.
attached beading or jewel trims.
Consideration should be given to the positioning of beads and jewels that pass across the face when a garment is
Coatings and materials used for beads or jewels may
contain chemicals that are hazardous for children who are known to frequently mouth such items.
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2.2: Beads & Jewel Trims
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion Beads/Jewel trims may become
Beads & Jewel trims must be
Pull & twist on bead or jewel
Required for all
Required for age
securely attached.
to assess ease with which it
Jewels should be fully secure
that are >3mm
Sharp Edges &
Beads or jewel trims may crack,
Beads or jewels must not
Tactile review for sharp,
break or have burrs
create sharp or pointy edges
pointy edges & burrs
if they crack or break during
Beads or jewels should not have burrs
Jewels that are shaped
No part of a jewel should
Tactile review for sharp or
intentionally by design or
have a sharp or pointy edge.
manufactured with sharp or
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2.2: Beads & Jewel Trims
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
if risks are identified
2nd Level
Assessment
≥3 and ≤ 7
>7 and ≤14
Chemical Toxicity
Beads or jewel trim materials or
Beads & jewel trims should
Consult supplier to confirm
coatings may contain chemicals
not contain any of the known
that no coatings or materials
that are hazardous when in oral
contain chemicals known to
assessment when there is a cause
cause skin irritations or
there is a cause
there is a cause
as listed in AS/NZ ISO
health problems.
Materials used for beads and
8124.3 Migration of
jewels may cause irritations
certain elements
as listed/recognised as
when in contact with the skin
potential health risks by
Find alternate source of
"Hazards:
reputable bodies (refer
materials, coatings etc. when
to "Hazards: Chemical Toxicity")
verification cannot be
Toxicity" section
for further info.
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2.3: Bows, Fabric Loops, Hanger Loops, Decorative & 3D Motifs
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations for the design
The following is recommended:
and manufacture of children's clothing in relation to
Bows, fabric loops, decorative and 3D motifs should remain attached under the allocated care instruction and throughout
the use of bows and similar attachments to promote
the life of the product.
safety and minimise risks.
Bows and fabric loops should be securely constructed and stitched down so that they do not unravel
Bows, Fabric Loops, Hanger Loops, Decorative and 3D
Bow ends and ribbon trims to be adequately sealed, or, single/ double turned and stitched down or bar tacked to prevent
Motifs, though commonly used for all forms of
apparel, have the potential to create safety hazards:
Wired ribbon is not recommended because it poses a risk of injury to the child if the wire protrudes from the fabric.
Especially for small children.
Heat sealed ends or laser cut fabrics should not have sharp edges
Those that are poorly attached to garments or that
If machine stitching, machine lock stitching is the recommended form of attachment
easily detach or separate can become a "small part" that is easily mouthed and swallowed by young
Hand stitched bows, fabric loops or motifs are not recommended for children up to 3. For hand stitched items above this age group, ensure that the trim is backstitched and secured thoroughly with stitching knotted off adequately to avoid
Sharp or pointy edges that can scratch or pierce a
To maximise the strength of attachment when hand stitching it is recommended that multiple threads are not passed
child's skin can arise through use of inappropriate
through the eye of the needle
components (e.g. wire ribbon).
Long loops & threads on internal or external area of product should be trimmed off
Entrapment, Entanglement, or strangulation can occur
A suitable backing material may be required to conceal long float threads, knots or stitching. Backing fabrics are
if loop sizes are not limited and controlled.
recommended in instances where the base fabric is lightweight & reinforcement may be necessary to assist in securing attachment
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2.3: Bows, Fabric loops, Hanger Loops, Decorative & 3D Motifs
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion Trims become detached by:
Bows, loops etc. must be
Pull & twist on trim to assess
Required for all
Required for all
securely attached
ease with which it detaches
Glued Trims become detached
Glue Trims must remain
Pull & twist on trim to assess
due to delamination or glue
securely attached.
ease with which it detaches
Glue Trims not recommended
Sharp Edges &
Risk of injury due to sharp edge/
Bows, tapes etc. should be
Tactile review for sharp or
free from sharp edges
Recommend an alternate
design or component.
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2.3: Bows, Fabric loops, Hanger Loops, Decorative & 3D Motifs
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing" if
2nd Level
risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Strangulation &
Bows and Fabric Loops that are
Fabric loops and bows should
Assess the feature for free
Entrapment
be engineered so that any
Draw cord and function ties risk assessment work sheet
Pose entrapment hazard of free ends should not fall
Conduct risk assessment:
for testing requirements
within the high risk zones as
Risk zone diagrams
Cut off blood flow to
set out in the Draw cord and
Functional ties risk
Be caught on obstacles
assessment worksheet within the related diagram and images section
Hanger loops that are not
For childrens' products, it is
Ensure appropriate Warnings
removed prior to wearing can:
important to provide
have been applied to hanger
Pose entrapment hazard of adequate warnings about the
loops (i.e. to advise removal
hazard and advice regarding
of hanger loops)
Cut off blood flow to
Be caught on obstacles
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National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
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14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
Buttons, though commonly used for all forms of
The following is recommended:
apparel, have the potential to create safety hazards:
Buttons should remain attached under the allocated care instruction, and throughout the life of the product.
Especially for small children.
Avoid using buttons that resemble food: Especially for ages under 3.
Buttons that are poorly attached to garments or that
The method of providing/attaching spare buttons should also be risk assessed.
easily break or separate can become a "small part" that is easily mouthed and swallowed by young
Avoid using fusing to support button attachment: Especially for ages under 3.
Avoid using furry or pile fabrics to cover buttons: Especially for ages under 3.
Sharp or pointy edges that can scratch or pierce a
Special consideration should be given to the shape and profile of buttons that pass across the face when a garment is
child's skin can arise through poor design (e.g. star
shapes) or when buttons break too easily.
Coatings and materials used for buttons may contain chemicals that are hazardous for children who are known to frequently mouth such items.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.4: Buttons
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion Buttons become detached by:
Buttons must be securely
Pull & twist button to assess
Required up to 5
ease with which it detaches
Multi-component button
Multi-component and
Manipulate buttons to assess
separating into pieces
assembled buttons must not
ease with which parts
separate under any
for transitional
circumstances of use
Sharp Edges &
Buttons crack or break
Buttons must not create
Tactile review for sharp or
sharp or pointy edges if they
pointy edges: Bend & stress
crack or break during use
button to assess ease of
Buttons are designed or
No part of a button should
Tactile review for sharp or
manufactured with sharp or
create a sharp or pointy edge
Chemical Toxicity
Button materials or coatings
Buttons should not contain
Consult supplier to confirm
contain chemicals known to
any of the known irritants:
that no coatings or materials
cause skin irritation or health
as listed in AS/NZ ISO
contain chemicals known to
8124.3 Migration of
cause skin irritations or
there is a cause
there is a cause
there is a cause
certain elements
as listed/recognised as
health risks by other
Find alternate source of
reputable bodies (refer
materials, coatings etc. when
Refer to Hazard
to "Hazards: Chemical
verification cannot be
- Chemical
Toxicity")
Toxicity section for further info.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.5: Diamantes, Glued & Heat-sealed Decorations
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
Glued/heat-sealed decorations, commonly used for all
The following is recommended:
forms of apparel, have the potential to create safety
Diamantes and other glued/heat sealed decorations should remain attached under the allocated care instruction, and
hazards: Especially for small children.
throughout the life of the product.
Glued/heat-sealed decorations that are poorly
Avoid using glued/heat-sealed decorations that resemble toys / food: Especially for ages under 3.
attached to garments can peel away become
Special consideration should be given to the appropriate attachment method for uneven surfaces such as velour, piles,
detached, creating a "small part" that could easily be
flocked prints, ribs, brushed and printed fabrics that may compromise their attachment.
mouthed and swallowed by young children.
Avoid glued/heat-sealed decorations made from glass as they crack and break easily
Sharp or pointy edges as a result or poor design
Avoid glued/heat-sealed decorations with sharp, rough or burred edges which may cause injuries
choices, can scratch or pierce a child's skin (e.g. star shapes).
Maximum adhesion to be obtained using the most suitable application process, it must be consistent throughout entire
Coatings and materials used for glued/heat-sealed
It is recommended that cold, gentle machine/hand wash care is suitable for most glued on decorations.
decorations may contain chemicals that are hazardousl for children who are known to frequently mouth such items.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.5: Diamantes, Glued & Heat-sealed Decorations
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion Decorations may become
Decorations must be securely
Pick/pull-at decorations to
Required for all
Required for age
assess ease with which it
decorations that
If detached in use or during
Poor attachment
laundering, the size of pieces
Perform wash/durability
should be assessed based on
tests: 3 x wash/dry cycles as
per allocated care instruction
Sharp Edges &
Decorations that are shaped
Decorations must have
Tactile review for sharp and
intentionally by design or
smooth and rounded
manufactured with sharp or
Decorations may crack, break or have burrs.
Chemical Toxicity
Glued/heat-sealed decorations
Glued/heat-sealed
Consult supplier to confirm
may contain chemicals, solvents
decorations should not
that no coatings or materials
known to cause skin irritation or
contain any of the known
contain chemicals known to
cause skin irritations or
there is a cause
there is a cause
there is a cause
as listed in AS/NZ ISO
8124.3 Migration of
certain elements
Find alternate source of
as listed/recognised as
materials, coating etc. when
potential health risks by
verification cannot be
reputable bodies (refer
to "Hazards: Chemical Toxicity")
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.6: Drawcords, Functional Ties, Decorative Ties & Sashes
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations for the design
The following is recommended:
and manufacture of children's clothing in relation to
Drawstrings should be sewn or securely attached to the garment at their midpoint so they cannot be pulled through.
the use of drawcords, functional and decorative ties.
Toggles and knots at the ends of drawcords, functional ties and decorative ties are not recommended as they can
Drawcords, functional ties, decorative ties and sashes
create a "hook" or stopper that may get caught in small spaces, or may become detached causing a choking hazard to
though commonly used for all forms of apparel, have
young children. Other alternatives for finishing ends such as sealed ends should be considered.
the potential to create safety hazards for children of all
Decorative items when attached to drawcords and ties can pose a choking hazard for young children. Due care in
reviewing these accessories should be considered. Refer to the relevant Risk Assessment Worksheet within the
ages which include entrapment, strangulation,
entanglement and tripping hazards. These can lead to
Functional ties and decorative ties should not be made from elastic. Due to the extensibility of elastic, there is risk of
serious injury or death.
injury to children of all ages.
Dangers arise through normal children's behaviour and
Avoid using drawcords, functional ties and decorative ties around hood/neck area, below the elbow and below the
activities, often under minimal supervision: Such as
knee as these pose a high risk of entrapment and tripping hazard to children. Refer to the High risk zone and medium
playing in playgrounds, climbing trees and travelling by
bus, train or bicycle. Such activities create risks such as
When designing a garment with a sash or tied-belt the width should be no less than 30 mm.
entrapment, strangulation, entanglement and tripping.
When halter neck and shoulder ties are tied up their loose ends should be restricted to minimise the risk of
entrapment hazards. Please note that these types of ties have a low risk associated with strangulation.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.6: Drawcords, Functional Ties, Decorative Ties & Sashes
Related Diagrams & Images
RISK ZONE DIAGRAMS
MEASURING DIAGRAMS
How to measure:
1) Relax the opening (i.e. not stretched or gathered)
High Risk
Medium Risk
2) Extend the cord without contracting the opening
Shoulder to elbow
3) Measure the length from eyelet, exit point or point of attachment.
Head & neckline
Waist to knee on shorts, dresses &
Elbow to wrist
Waist to hem of tops & dresses Knee to ankle
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.6: Drawcords, Functional Ties, Decorative Ties & Sashes
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Strangulation
Drawcords, functional ties
Drawcords and functional ties
Proceed to "Further testing"
High risk zone:
High risk zone:
Entrapment
and sashes
should be engineered to
Conduct risk assessment:
Not recommended. If used,
create risks of
Tripping
minimise risks by:
Refer to risk zone diagrams
cord or functional
draw cord and functional ties
Adopting lower-risk non-
tie on a relaxed
on a relaxed garment should
Entanglement
functional options
not exceed 14cm from the
Being designed for quick
point of protrusion.
Use of tabs that are
High risk zone: Determined by
adjustable in high risk
Medium risk zone:
Medium risk zone:
the position on a garment/ body.
Not recommended.
Refer to the risk zone diagrams.
Avoid using functional
If used: Drawcord and
Drawcord and functional ties
ties and drawcords
functional ties on a
on a relaxed garment
Medium risk zone: Determined
around high risk zones
relaxed garment:
1) should not exceed 14 cm
by the position on a garment/
Reducing length of "free
1) should not exceed
from the point of
body. Refer to risk zone
14 cm from the point
Preventing easy removal
2) should remain outside
of protrusion, and
Refer to Design
2) should remain
the high risk zones.
outside the high risk
Sashes and tied-belts: During
A sash or tied-belt when
No part of the untied sash No part of the untied sash or
the design stage, careful
untied should not hang below
assessment. Refer
or tied-belt should fall
tied-belt should fall within
consideration should be given
the hem of the garment.
within the high risk zones. the high risk zones.
to the application and
attachment of the sash/tied -
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.6: Drawcords, Functional Ties, Decorative Ties & Sashes
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
if risks are identified
2nd Level
Assessment
≥3 and ≤ 7
>7 and ≤14
Entrapment
Decorative ties create risks of Decorative ties should be
Proceed to "Further testing"
High risk zone:
High risk zone:
Tripping
engineered to minimise risks
Conduct risk assessment:
Not recommended.
Refer to risk zone diagrams.
decorative ties.
If used, Free ends should not
exceed 14 cm from the point of
Avoid using decorative
ties around high risk
Medium risk zone:
Medium risk zone:
High risk zone: Determined by
Refer to Design
Not recommended.
1) Free ends should not
the position on a garment/ body,
exceed 14 cm from the
refer to the High risk zone
1) Free ends should not
point of attachment, and
exceed 14 cm from
2) Free ends should remain
outside the high risk
Medium risk zone: Determined
2) Free ends should
by the position on a garment/
remain outside the
body, refer to medium risk zone
high risk zones.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.7: Gifts with Purchase (GWP)
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations on how to risk
The following is recommended:
assess "Gifts with Purchase" that often accompany
Avoid GWP's that resemble food
children's apparel. These can be any variety of items, from toys, toy-like packaging, costume jewellery, hair
Ensure GWP's comply with applicable mandatory safety standards and regulations.
accessories etc.
Traditional risk assessments focus on the safety of the product itself.
GWP's must be assessed for their age appropriateness and meet relevant standards (i.e. AS/NZS ISO 8124 Toy Standard).
If GWP's are attached to a garment at point of sale, the method of attachment itself (such as long ties or sharp pins) needs to be risk assessed to ensure it does not pose any danger to children,
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.7: Gifts with Purchase (GWP)
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion GWP may be very small and
Small components must be
Check size of the GWP.
could be ingested easily.
attached in a manner that
guarantees they cannot
Inspect/examine: Identify the
create small parts
GWP may have small
become detached.
presence of any componentry
are not suitable
that could become a
for this age group. Provide safety
GWP items must not be able
potential choking hazard.
break, separate and should
be constructed in such a way that small components do
not pose a risk.
Twist-ties, strings, pins or Kimble
Where deemed appropriate,
Inspect/examine: Identify the
may be used to attach GWP.
provide adequate warnings
presence of any packaging
about the potential hazard
related componentry that
and advice regarding safe
could become a potential
Test as per AS/NZS ISO 8124.1
Sharp Edges &
GWP or components that could
Tactile review of all packaging
No item should have a sharp
contain sharp/pointy edges that
components for sharp or
can cause scratch or laceration
Seek alternative
Seek alternative
GWP could be attached with pins
No item should have a sharp
or mechanisms having
Review multiple pieces to
sharp/pointy edges that can
ensure consistency.
cause scratch or laceration injuries.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.7: Gifts with Purchase (GWP)
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
if risks are identified
2nd Level
Assessment
≥3 and ≤ 7
>7 and ≤14
Chemical Toxicity
Materials used for GWP may
Materials used for GWP
Consult supplier to confirm
Avoid use at all
Avoid use at all
Avoid use at all
contain chemicals known to
should not contain any
that no coatings or materials
cause irritation.
known chemicals to cause
contain chemicals known to
skin irritations or sensitivities.
cause skin irritations or
Find alternate source of
materials, coatings etc. when
Refer to Hazard
verification cannot be
- Chemical
Toxicity section for further info.
Strangulation &
Twist-ties, strings, pins or Kimble
Avoid the use of long strings
Inspect/examine: Identify the
If appropriate :
If appropriate :
Entrapment
may be used to attach GWP. Long
or ties. Provide adequate
presence of any long strings
Length to be kept
strings or ties could wrap around
warnings about the hazard
or ties that could create a
neck, fingers etc. and cause
and advice regarding safe
hazard in the hands of a child.
strangulation or ligature
constriction (ischaemic) risks.
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National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
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14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.8: Metal Trims, Buckles, Rivets & Snaps
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations for the design
The following is recommended:
and manufacture of children's clothing in relation to
the use of metal trims, buckles, rivets and snaps to
Metal trims, buckles, rivets & snap fasteners should remain attached under the allocated care instruction, and
promote safety and minimise risks.
throughout the life of the product
Metal trims, buckles, rivets & snaps, though commonly
Metal trims, buckles, rivets & snap fasteners should be stitched using adequate stitch tension, density and
used on all forms of children's clothing have the
formation to prevent detachment. Reinforced treatments should be considered for light-weight fabrics.
potential to create safety hazards: Especially for small
Backing material may be required as reinforcement when attaching components to light weight fabrics. The backing
material must also be securely attached.
Metal trims, buckles, rivets & snaps that are poorly
Metal chain lengths/belts and positioning should be considered to reduce the risk of being caught on other objects.
attached to garments or are poorly constructed can
become a safety risk for young children.
Prongs on buckles should not protrude beyond the rim of the buckle. Buckle rims should be indented to allow the prong to lay flush.
Sharp or pointy edges that can scratch or pierce a
child's skin can arise through poor quality or
The size & type of the snap fastener should be suited to the fabric weight and thickness. Validate suitability through
construction of metal trims, buckles, rivets or snaps.
the snap supplier.
Coatings and materials used for metal trims, buckles,
Snap fasteners should not be applied over seams or on uneven fabric thickness to minimise risk of detachment.
rivets or snaps may contain chemicals that are
Appropriate machine settings in manufacturing must be used to accommodate fabric thickness.
hazardous for children due to known irritants through
After production: It is highly recommended that products are inspected for any detached, loose or broken snap
oral or skin contact.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.8: Metal Trims, Buckles, Rivets & Snaps
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion Metal trims, buckles, rivets or
Metal trims, buckles, rivets &
Pull & twist on metal trim &
Required for all
Required for age
may become detached by:
snaps must be securely
buckle to assess ease with
which it detaches
buckles, rivets &
Multicomponent metal trims,
Multicomponent and
Manipulate all components
Required for age
buckles, rivets & snaps. Parts may
assembled metal trims,
to assess ease with which any
buckles, rivets and snaps
must not separate under any
circumstances of use
Sharp Edges &
Metal trims, buckles, rivets snaps
The construction of Metal
Tactile review for sharp,
and all their components may be
trims, buckles, rivets and
pointy edges, & burrs
sharp, break or have burrs
snaps should have smooth
surfaces to reduce risk of
scratching. Metal trims, buckles, rivets, snaps & all components must not create sharp or pointy edges if they break during use. Beads or jewels should not have burrs
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.8: Metal Trims, Buckles, Rivets & Snaps
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
if risks are identified
2nd Level
Assessment
≥3 and ≤ 7
>7 and ≤14
Chemical Toxicity
Metal trims, buckles, rivets &
Metal trims, buckles, rivets &
Consult supplier to confirm
snaps can be made from
snaps should not contain any
that no coatings or materials
materials or coatings that contain
of the known irritants:
contain chemicals known to
chemicals that are hazardous
as listed in AS/NZ ISO
cause skin irritations or
there is cause for
there is cause for
there is cause for
when in oral contact
8124.3 Migration of
health problems.
certain elements as
listed/recognised as
Materials used may also cause
Find alternate source of
health risks by other
irritations when in contact with
reputable bodies (refer
materials, coatings etc. when
to "Hazards: Chemical
verification cannot be
Toxicity")
Toxicity section
for further info.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
THIS PAGE
LEFT BLANK
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
Traditional risk assessments focus on the safety of
The following is recommended:
known product features, such as buttons, zippers,
A novelty item should remain attached under the allocated care instruction and throughout the life of the product.
prints and common decorations etc.
As the complexity and variety of design options is limitless in this space: Only a general safety overview is provided
However new trends and technological advances are
in these guidelines.
constantly emerging. Examples are such features as magnetic closures, battery operated trims, draw
The true value of conducting a "comprehensive risk assessment" is demonstrated for novelty items.
strings functioning as head-sets etc. These novelties also have to be assessed for their safety and age appropriateness.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.9: Novelties
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion Items that are small, can be
All items must be securely
Inspect/examine: Identify the
Avoid use at all
dismantled into smaller parts, or
attached and contained
presence of any componentry part hazards as
can become loose or detached.
adequately so they pose no
that could become a
risk to the wearer.
potential choking hazard.
AS/NZS ISO 8124.1 70 N Pull Test
Sharp Edges &
Items that are shaped
Where such items are used,
Tactile review of all
intentionally by design by design
they should not contain
components for sharp or
such items. Seek
such items. Seek
or manufactured with sharp or
edges that sharp or pointy.
pointy edges. Inconsistent
manufacturing or weak material
Review multiple pieces to
that can break etc. can also pose
ensure consistency. Ensure
materials used are durable over the lifetime of the garment.
Chemical Toxicity
Materials used for novelty trims
Chemicals known to cause
Consult supplier to confirm
and features may contain
skin irritations or sensitivities
that no components contain
chemicals known to cause
should not be used for any
chemicals known to cause
component in the
skin irritations or health
there is a cause
there is a cause
there is a cause
manufacture of children's
apparel. Avoid chemicals:
as listed in AS/NZ ISO
Find alternate source of
8124.3 Migration of
materials, coatings etc. when
Refer to Hazard
certain elements
verification cannot be
- Chemical
as listed/recognised by
Toxicity section
other reputable bodies
for further info.
(refer to "Hazards: Chemical Toxicity")
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations on how to risk
The following is recommended:
assess the packaging, labelling and methods of
At no time should plastic bags have a drawstring or cord that constricts/closes the end of a bag
securing swing tags, button bags and other accessories to products.
Use non recycled materials for plastic bags to avoid chemical contamination.
Novelty packaging (i.e. ‘gift with purchase ‘ that looks and functions like a toy) needs to meet relevant standards
Traditional risk assessments focus on the safety of the product itself.
The packaging, labelling and methods of securing swing tags, button-bags and other accessories to products can ALSO introduce hazards. However, these hazards may not fall within the scope of the traditional risk assessment of the product and could therefore be inadvertently overlooked.
Packaging within the scope of this section does not include in-transit packaging that is discarded prior to purchase.
14/4/2015 V2.0
National Retail Technical Standards Committee
Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
2.10: Packaging
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary
Further Testing / Assessment
Assessment
2nd Level
Conduct "Further Testing"
Assessment
≥3 and ≤ 7
>7 and ≤14
if risks are identified
Choking & Ingestion Twist-ties, staples etc. may be
Where appropriate, there
Inspect/examine: Identify
Identify small part
used to attach components,
should be adequate warnings
the presence of any
accessories or packaging to each
about the potential hazard
packaging related
and advice regarding safe
componentry that could
providing safety
providing safety
become a potential choking
providing safety
disposal advice.
disposal advice.
warnings & disposal advice.
Plastic bags used for packaging
Use "thick" bags that:
Inspect/Examine against
can present a suffocation risk for
1) Are too small to fit over
the safety requirement
thickness > 38
thickness > 38
children if placed over their
2) Have holes or
perforations that allow
2) Meets criteria
2) Meets criteria
Meets criteria for
3) Contain warnings that
the bag is not a toy
of opening size,
of opening size,
opening size, air
holes and warning
Sharp Edges &
Packaging may use staples, twist
No items should contain
Tactile review of all
ties or components that could
sharp or pointy edges.
packaging components for
such items. Seek
such items. Seek
contain sharp/pointy edges that
sharp or pointy edges.
can cause scratch or laceration
Review multiple pieces to
ensure consistency.
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2.10: Packaging
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
if risks are identified
2nd Level
Assessment
≥3 and ≤ 7
>7 and ≤14
Chemical Toxicity
Materials used for packaging, and
Volatile chemicals may pass
Review/assess declarations
Avoid use at all
Avoid use at all
Avoid use at all
prints used on packaging, may
from package to product.
contain chemicals known to
Chemicals known to cause
cause irritation.
skin irritations or sensitivities
Consult supplier to confirm
should not be used for
with declarations that the
packaging (boxes, bags) or
materials contain no
printing onto packaging.
chemicals known to cause
skin irritations or health
Refer to Hazard
- Chemical
Toxicity section
Find alternate source of
for further info.
materials when verification cannot be obtained
Strangulation &
Long strings or ties could wrap
Avoid the use of long strings
Inspect/examine: Identify the
Entrapment
around neck, fingers etc. and
or ties. Provide adequate
presence of any long strings
Length to be kept
cause strangulation or ligature
warnings about the hazard
or ties that could create a
constriction (ischaemic) risks.
and advice regarding safe
hazard in the hands of a child.
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2.11: Pom Poms, Tassels, Fringing, Braids & Plaits
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations for the design
The following is recommended:
and manufacture of children's clothing in relation to
Pom Poms, Tassels, Fringing, Braids and Plaits should remain attached under the allocated care instruction and
the use of Pom Poms, Tassels, Fringing, Braids and
throughout the life of the product.
Plaits to promote safety and minimise risks.
Machine stitching is recommended. Lock stitching is the recommended form of attachment.
Pom Poms, Tassels, Fringing, Braids and Plaits, though
Hand stitched pom poms, tassels, fringing, braids or plaits should be backstitched and secured thoroughly with
commonly used for all forms of apparel, have the
stitching knotted-off adequately to avoid detachment.
potential to create safety hazards: Especially for small
To maximise the strength of attachment when hand stitching it is recommended that multiple threads are not
passed through the eye of the needle.
Those that are poorly attached to garments or that
Long loops & threads on internal or external area of product should be trimmed off.
easily break or separate can become a "small part" that is easily mouthed and swallowed by young children.
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2.11: Pom Poms, Tassels, Fringing, Braids & Plaits
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion Pom-poms and Tassels become
Pom-poms and tassels must
Pull & twist on trim to assess
be securely attached.
ease with which it detaches
Glued Trims become detached
Glue Trims must remain
Pull & twist on trim to assess
due to delamination or glue
securely attached.
ease with which it detaches
Glue trims are not
recommended for age< 3.
Pom-poms, Tassels, Braids
All trims must be
Assess the trim to ensure
or plaits unravel and detach
securely constructed
yarns are not easily
due to poor construction
and stitched down so
that the yarns do not
Recommend alternative
constructions if yarns easily unravel
Strangulation &
Long strings/lengths that attach
When a Pom-pom, plait or
Assess the trim to determine
Entrapment
pom-poms create risks of being:
tassel is used in conjunction
if it forms part of a drawcord,
with a functional or
decorative ties or adjusting
decorative cord they should
be considered with reference
If yes, refer to the relevant
to the guidelines on draw
section within this document.
cords, decorative ties & functional ties as set out within this document.
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Children's Apparel & Accessories – Part 2: Risk Assessment Worksheets
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
This section provides recommendations for the design
The following is recommended:
and manufacture of children's clothing in relation to
Sequin trims should remain attached under the allocated care instruction, and throughout the life of the product
the use of sequins to promote safety and minimise risks.
Machine stitching is preferred. Lock stitching is the recommended form of attachment
Hand stitched Sequins should be back-stitched and secured thoroughly with stitching knotted off adequately to
Sequin trims, though commonly used for all forms of
avoid detachment.
apparel, have the potential to create safety hazards: Especially for small children.
Long loops and threads on internal or external areas of product should be trimmed off.
A suitable backing material may be required to conceal long float threads, knots or stitching and to fully secure the
Sequin trims that are poorly attached to garments or
sequin from detaching. For example, backing fabrics may be required for reinforcement in instances where the
that easily break can become a "small part" that is
base fabric is light weight.
easily mouthed and swallowed by young children.
Backing fabric or fusing must be secure to ensure that they are not removed easily.
Sharp or pointy edges that can scratch or pierce a
Sequins used in conjunction with ties or cords should be considered with reference to the guidelines on Drawstring,
child's skin can arise through poor quality or badly
Functional Cords & Decorative ties as set out within this document.
attached sequins.
Consideration should be given to the positioning of sequins that pass across the face when a garment is removed.
Coatings and materials used for sequins may contain
Consideration should be given to the positioning of sequins at armhole, leg and neck openings for comfort &
chemicals that are hazardous for children who are
known to frequently mouth such items.
Glued sequins, please refer to the Diamantes, Glued and heat sealed decorations feature section.
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2.12: Sequins
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Sharp Edges &
Sequins may crack, break or have
Sequins must not create
Tactile review for sharp,
sharp or pointy edges if they
pointy edges & burrs
crack or break during use.
Sequin edges should not have burrs or sharp edges
Sequins that are shaped
No part of a sequin should
Tactile review for sharp or
intentionally by design or
have a sharp or pointy edge.
manufactured with sharp or
Materials used for sequins or the
No part of a sequin should be
Tactile review for rough and
manner with which sequins are
rough, abrasive &
abrasive surfaces: Especially
attached can be rough, abrasive
uncomfortable to the skin.,
for surfaces that sit in contact
& uncomfortable to the skin.
Choking & Ingestion Sequins may become detached
Sequins must be securely
Pull & twist on sequin to
Required for age
assess ease with which it
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2.12: Sequins
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Chemical Toxicity
Sequins can be made from
Sequins should not contain
Consult supplier to confirm
materials or coatings that contain
should not contain any of the
that no coatings or materials
chemicals that are hazardous
known irritants:
contain chemicals known to
when in oral contact
as listed in AS/NZ ISO
cause skin irritations or
there is cause for
there is cause for
there is cause for
8124.3 Migration of
health problems.
Materials used may also cause
certain elements
irritations when in contact with
as listed/recognised as
Find alternate source of
health risks by other
materials, coatings etc. when
reputable bodies (refer
verification cannot be
to "Hazards: Chemical
Toxicity")
Toxicity section for further info.
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2.13: Zips, Slide Fasteners & Pullers
GUIDELINES FOR USE: Use this worksheet to facilitate a risk assessment for products containing buttons:
1. Consider the recommendations contained within the "Design Considerations" text box. 2. Assess each of the potential hazards by first understanding the "Functional Requirements", then conducting the "Preliminary Assessment" (as required). 3. Proceed to "Further Testing" where the "Preliminary Assessment" is inconclusive or to obtain independent safety and performance evaluations
DESIGN CONSIDERATIONS:
Slide fasteners, though commonly used for all forms of
The following is recommended:
apparel, have the potential to create safety hazards:
Slide fasteners/Pullers should remain attached under the allocated care instruction, and throughout the life of the
Especially for young children.
Poor quality components of zippers can easily break or
Avoid using zip pullers that resemble food for children under the age of 3 years.
become, a detached "small part" that is easily
Where zippers come in contact with the skin, a zipper guard or facing is recommended.
mouthed and swallowed by young children.
It is recommended that the zip puller is attached to the slider so that it cannot be pulled free by using a twisting or
Sharp or pointy edges can scratch or pierce a child's
skin can arise through poor quality componentry or
It is preferred that the zip pullers are constructed as part of the main body of the zip slider.
poor design choice.
Zip pullers made from rubber or other natural material such as wood are not recommended because they can crack
Coatings and materials used for slide fasteners may
and break easily.
contain chemicals that are hazardous for children who are known to frequently mouth such items.
Ensure channel stoppers are fully effective in preventing the zip slider from detaching and becoming a small part.
Metal top stoppers on slide fasteners must be firmly clamped.
Top and bottom stops should prevent zipper slider/zipper head from detachment
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2.13: Zips, Slide Fasteners & Pullers
Functional Requirements
Assessment and Testing Requirements
Safety Requirements
Preliminary Assessment
Further Testing / Assessment
Conduct "Further Testing"
2nd Level
if risks are identified
Assessment
≥3 and ≤ 7
>7 and ≤14
Choking & Ingestion Sliders component may come
Sliders must be securely
Pull & twist on puller and/or
attached and must not
slider to assess ease with
detach from the zipper.
which it detaches
Poor weak quality
Sharp Edges &
Sliders /pullers can crack or break
Must have smooth and
Tactile review for sharp or
resulting in laceration to the skin.
rounded edges to reduce the
pointy edges and burrs
Stoppers may have sharp burrs
risk of scratching.
caused by faults in the mould.
Chemical Toxicity
Slide fasteners /pullers materials
Slide fasteners/pullers should
Consult supplier to confirm
or coatings may contain
not contain any of the known
that no coatings or materials
chemicals known to cause skin
contain chemicals known to
irritation or health problems
as listed in AS/NZ ISO
cause skin irritations or
there is a cause
there is a cause
there is a cause
8124.3 Migration of
certain elements
as listed/recognised by
Find alternate source of
other reputable bodies
materials when verification
(refer to "Hazards:
cannot be obtained.
Chemical Toxicity")
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Appendix A: Definitions
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Children's Apparel & Accessories
The following definitions should be used within the context of safety assessment for children's apparel and accessories.
Accredited laboratory
A laboratory that has been assessed and
A patch made from different types of material
accredited by an independent accreditation
that is either a) permanently attached with
body such as NATA in Australia or HOKLAS in
adhesive or stitching or b) is detachable (e.g. a
Hong Kong.
badge with a pin).
An item which is used to supplement, decorate
A small, often round piece of material, such as
or contribute to the wearer's main outfit (e.g.
glass, plastic, or wood, that is pierced for
headwear, scarf, gloves, brooch)
grouping, stringing, threading and attachment.
Small plastic capping used to secure the ends of small cords to prevent fraying (e.g. as used
A decorative band created from interlacing
for shoe laces)
strips or strands of textile material.
Channel Stopper
Items of clothing that are worn to protect,
A device attached to the top or bottom of a zip
wrap, or beautify the body.
to prevent the zip puller from detaching when pulled to the upper/lower limits.
Chemical Toxicity
A decoration made by cutting pieces of one material and applying them to the surface of
An adverse reaction to residual chemicals
that may be toxic.
Backing material
1) A substrate (typically paper) used with
A supplier's ability to meet and demonstrate
embroidery to provide structural
conformance to the applicable requirements
stability for fabrics during the
and test procedures.
embroidery process.
Choking Hazard
2) Small pieces of material used to
reinforce attachment of trims to
The mechanical obstruction of the flow of air
prevent them pulling through or
to the lungs.
damaging the main fabric.
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Decorative Tie
A non-functional or decorative cord, ribbon or
A layer of fabric which is adhered by heat and
tie of fixed length which is not intended to be
pressure to the reverse side of a fabric,
used to adjust the size of a garment opening
typically to provide stability and shape to the
or to fasten the garment itself.
main fabric. Refer Backing Material.
Hanger loops
A small, glittering ornament, such as a
Fabric strips or ribbons sewn to garments near
rhinestone or a sequin, applied to (usually
the shoulder, neck or waist area that is looped
adhered to) fabric or a garment.
onto hangers to prevent garments from falling off when hung.
Draw cord / Drawstring
Harm
A cord or ribbon running through a channel or loop to adjust the size of the opening or to
Physical injury or damage to the health of the
fasten a garment.
Ornamental designs created on fabric surfaces
Potential source of harm to the wearer of the
using hand or machine needlework and
stitching
Hook & Loop
A fastening system consisting of two pile-
A situation where a garment, part of a
fabric tapes which are sealed by pressing the
garment or component of an accessory is
pile sides of the two tapes together. Velcro is a
unexpectedly caught, trapped or snagged.
brand name of such a system.
Horizontal standards approach
An attached fabric/textile trim with an
The use of safety and performance standards
unsecured end that is able to sit or hang
created for specific product types to conduct a
loosely from its point of attachment.
product risk assessment on an unrelated product (e.g. the application of AS/NZS ISO
Functional cord
8124.1 toy standard to identify a small part on
See drawcord
a fashion accessory).
Functional Tie
Independent laboratory
A cord of ribbon of fixed length that is used to
An independent laboratory is one that has no
adjust the size of the opening or to fasten a
ownership or affiliation with the companies
for which testing services are provided.
Informative reference
A reference document cited in the guidelines that provides instructions and information for guidance.
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Quick release
Taking something in by swallowing.
A component or device used on drawcords and drawstrings that has been designed to release
rapidly when light force is applied (e.g. as
Damage to the body caused by (acute)
commonly used for lanyards).
exchanges with environmental energy that are
Risk
beyond the body's resilience.
A combination of the probability of occurrence
of a hazard and the severity of the harm,
The placing of a small object into the nose, ear
which that hazard could be expected to cause.
or mouth.
Risk assessment
The overall process of risk identification, risk
Refer Fusing.
analysis and risk evaluation utilised to achieve "tolerable risk", taking into consideration
design, materials, components and construction. This is an iterative process
A cut, scratch or graze.
requiring repeated application until a
Normative reference
tolerable level of risk is achieved.
A reference document cited in the guidelines
that is a necessary and integral element for
Small metallic trim, which is comprised of two
application of the guidelines.
parts, one part is attached to the outer side of
Panel review
the garment by a tack which passes through the fabric from the reverse side. This is
A process by which risk assessment decisions
typically used on the pockets of denim jeans.
are referred to a panel or group of engaged stakeholders to arrive at a decision relating to
product safety.
Safety is achieved by reducing risk to a
Press Fastener
tolerable level, referred to in this document as tolerable risk.
A fastening device that consists of a male component and a female component,
Sash or Tied Belt
attached to different parts of a garment. The
A wider decorative or functional tie that is not
garment is fastened when the two
encased and is tied around the waist area of a
components are aligned and pressed together.
These devices can be attached to a garment mechanically or can be sewn on. They include
studs and snaps.
A small shiny ornamental disk, often sewn onto fabrics as decoration
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Slide fastener
Tolerable risk
Refer Zip Slider
An acceptance that there are residual safety risks associated with a product's design or
Snaps (Snap-fasteners)
function that are approved given the
Refer to Press Fasteners
utility/benefits provided.
Touch and Close Fastener
Refer to Press Fasteners
Refer to Hook and Loop
Stoppage of breathing or asphyxia.
A registered trademark for a hook and loop
fastener system. Refer to Hook & Loop
Vertical Standard
Injury caused by constriction of the throat that restricts breathing.
A Standard or Guideline specifically written for one range or product type.
Zip slider
Designer, manufacturer or distributor of a product. (Consideration of anyone in the
The device that moves up and down to
supply chain)
open/close the zip.
Tab
Zip puller
A small flap or strip of material/fabric used to
The tab that is held to move the zip slider up
hold or fasten a part of a garment/accessory.
and down.
Tactile review
A process of feeling, rubbing and pressing against components to assess whether there are any sharp or pointy edges that could cause irritation, aggravation or injury.
1) A short rod of wood or plastic sewn to
one side of a coat or other garment, that is pushed through a hole or loop on the other side to join or close a garment.
2) An attachment to the end of a cord or
tie intended to improve appearance of the cord end, to protect the cord end or to restrict cord ends from being pulled into a hem or casing.
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Source: http://www.nra.net.au/wp-content/uploads/2015/06/Children-s-Apparel-Accessories-Product-Safety-Guidelines-Apr-2015-.pdf
St Kizito Hospital Matany Moroto Diocese-Karamoja P.O. Box 46, Moroto - UGANDA- Annual Analytical Report Financial Year 2011/12 St Kizito Hospital Matany 31st December 2012 Endorsement of Report This annual analytical report for St. Kizito Hospital Matany covering the period from
Current Learning in Palliative care Helping patients with symptoms other than pain 1: Constipation Introductory level Aim of this worksheet Produced by St. Oswald's Hospice To learn how to assess and manage constipation How to use this worksheet You can work through this worksheet by yourself, or with a tutor.
