 Welcome! In this video, we will be introducing 16 CFR Part 1610, the standard for the flammability of clothing textiles. Flammability testing requirements are regulated under the Flammable Fabrics Act, also known as the FFA, and includes standards for clothing textiles, final plastic film used in clothing, children's sleepwear, carpets and rugs, mattresses, mattress pads and mattress sets, and upholstered furniture. The FFA prohibits the manufacturer, sale, distribution, and importation of any product or fabric that fails to conform to the applicable flammability standards. Today, we will be focusing on 16 CFR Part 1610, the standard for the flammability of clothing textiles. 16 CFR Part 1610 is commonly referred to as the general wearing apparel standard. The purpose of the standard is to keep the most dangerously flammable textile products out of the marketplace. This standard applies to all wearing apparel, except the following items listed under section 1610.1c. Hats that do not cover the neck, face, or shoulders. Gloves that are 14 inches or shorter and are not attached to a garment. Footwear that does not consist in a hole or in part of hosiery and is not attached to a garment. And inner lining fabrics when they are intended or sold for use as a layer between an outer shell and an inner lining. Additionally, children's sleepwear garments that do not meet the definitions of either infant garments or tight-fitting garments are subject to 16 CFR Part 1615 or 1616. The criteria to be defined as an infant garment or tight-fitting garment are based on sizing and measurement guidelines. See section 1615.1 or 1616.2 for more info. Fabrics that meet a specific exemption from the standard do not require testing. For the first exemption, plain surface fabrics weighing 2.6 ounces per square yard or more do not need to be tested regardless of fiber content. Weighing the fabric does not need to be conducted by lab and you can measure the weight yourself or check to see if this info is provided on the fabric roll you are using to construct the garment. For the second exemption, plain and raised surface fabrics made entirely of acrylic, mod-acrylic, nylon, olefin, polyester, wool, or a combination of these fibers regardless of weight are exempt from testing. Fabrics that contain any other fibers other than the six specified would not meet this exemption. Reminder, the first exemption could potentially apply to textiles with any combination of fiber content if they are plain surface and meet their weight requirement. Also, please note that regardless of fiber content, there are any chemical coatings placed onto the fabric and the fabric may no longer be exempt from testing due to the risk of finishes and coatings altering the flammability characteristics of the fabric. Coatings can include resins, plastics, melamine, or oil finishes and can change the way the fabric burns. It's important for manufacturers and importers to check the coatings applied to their textiles to ensure compliance with the standard. To help determine whether your fabrics meet a specific exemption, you should identify the fabric type, weight, and specifications including whether the fabric is plain surface or raised surface. A plain surface fabric is any textile fabric that does not have an intentionally raised fiber or yarn surface, such as pile, nap, or tuft. Whether the product has an intentionally raised surface is determined by the manufacturing process. For example, if the manufacturing process involves brushing the fabrics, then it is likely considered a raised surface fabric. Examples of plain surface fabrics typically include Oxford, Chambray, Searsucker, Jersey Cotton, and Spandex. Please note that these are common examples of plain surface fabrics. However, the manufacturing process determines whether it is a plain or raised surface fabric, so these fabrics may not always be considered plain surface. Some natural fibers, like wool, can be considered a plain surface fabric if they do not go through an additional process. A raised surface fabric is any textile fabric that has an intentionally raised fiber or yarn surface, such as a pile, nap, or tuft. Examples of raised surface fabrics typically include terrycloth, fleece, velvet, chenille, corduroy, velour, plush polyester, and flannel. Flannel and micro polyester are the most common raised surface fabrics. An example of a manufacturing process that intentionally raises the fibers would be the fabric going through an agitator that cuts and brushes the fibers on the top surface. As you've learned, the classification as a plain surface or raised surface fabric depends on the manufacturing process. If you are unsure of whether your fabric is plain surface or raised surface, please feel free to reach out to the CPSC's Small Business Ombudsman team for help. Narrow fabrics and loose fibrous materials manufactured less than 2 inches in width in either direction shall not be tested. This includes certain neck ties, bow ties, and belts. If a 2 by 6 inch specimen cannot be cut due to the nature of the item, do not conduct a test. This includes items like hula skirts and fringe. Only uncovered or exposed parts of wearing apparel shall be tested under the standard. An uncovered or exposed part is defined as a part of wearing apparel that might be opened to flame or other means of ignition during normal wear. The outer surface of an undergarment is considered to be uncovered or exposed. Examples of uncovered or exposed parts of wearing apparel include linings with exposed areas such as full front zipper jackets, sweatshirts with exposed raised fiber surfaces on the inside and capable of being worn, napped side out, unlined hoods, and rolled cuffs. For garments with exposed linings like these jackets, both the exposed inside lining and outside fabric need to be tested, unless they meet an exemption. Please note that the exemptions do not apply if only the outside fabric meets an exemption. For example, if you have a plain surface fabric that meets an exemption on the outside, but you have an exposed raised surface fabric lining that does not meet an exemption, then you will need to test the exposed lining. Raise surface fabrics can catch fire more quickly than plain surface fabrics. The inner fabric on garments that are intended or advertised to be reversible are considered exposed parts and must be tested on one or both sides of the garment if it does not meet a specific exemption. This also applies to any fabrics that are intended or advertised with rolled cuffs. Part 1610 specifies testing procedures to determine the flammability of textiles used in apparel as one of three classes of flammability. Two by six inch specimens must be tested to determine the class and hazard rating. Class 1 textiles are plain surface and raised surface fabrics that exhibit normal flammability and are acceptable for use in wearing apparel. Class 2 textiles are raised surface fabrics that exhibit intermediate flammability and should be used with caution for wearing apparel. This class is not applicable to plain surface fabrics. Class 3 textiles are plain surface and raised surface fabrics that are dangerously flammable and cannot be used in wearing apparel. There are additional requirements based on whether the garments are intended for adults or children. Adult wearing apparel does not need to be tested at a third party CPSC accepted lab. Adult wearing apparel is required to have a general certificate of conformity, also known as a GCC. Manufacturers and importers of general use products for which consumer product safety roles apply, such as adult wearing apparel, must certify an written GCC based on testing or reasonable testing program that the products comply with 16 CFR Part 1610. The commission issued enforcement discretion guidance related to adult apparel and GCCs. The CPSC will not pursue compliance or enforcement actions against firms that fail to issue a GCC for adult wearing apparel that is exempt from testing pursuant to section 1610.1D. Adults in general use wearing apparel that is tested will need to have a GCC. Children's wearing apparel that is subject to Part 1610 includes general wearing apparel and children's sleepwear that meets the definition of infant garment or tight fitting, as described in 16 CFR Parts 1615 or 1616. Testing that needs to be conducted on children's wearing apparel must be performed at a CPSC accepted laboratory. You can find the lab at cpsc.gov slash labsearch. However, if you are a qualifying small batch manufacturer, you may be eligible for third-party testing relief. Part 1610 falls under Group B requirements, which means that you may be able to certify compliance in alternate ways beyond third-party testing your product at a CPSC accepted lab. Such alternatives include first-party testing, which is performed in-house by the domestic manufacturer or importer, testing by a non-CPSC accepted lab, or by receiving a written assurance of compliance from your producer or supplier. You can find out more information about whether you qualify as a small batch manufacturer and how to register at cpsc.gov slash small batch. Once manufacturers and importers of children's wearing apparel have received any applicable passing test results for their products and gathered any additional compliance documentation, they must issue a children's product certificate, also known as a CPC. To learn about how to create a CPC, please watch CPSC's three-part education series for CPCs by visiting CPSC's business education playlist at youtube.com slash USCPSC. Although not part of the requirements for Part 1610, there are other common requirements that may apply to children's wearing apparel. Children's products and their packaging are required to have tracking labels. The tracking label is a distinguishing permanent mark that is affixed to the product and its packaging to the extent practicable and provides certain identifying information that is ascertainable, including the manufacturer, importer, and or private labeler, date and location of production, and batch code or cohort information that helps identify the specific source of the product. To learn more about the tracking label requirement, please watch CPSC's tracking label requirement video by visiting CPSC's business education playlist at youtube.com slash USCPSC. Children's products are also subject to the total lead content requirements of 15 USC section 1278A. Generally, all accessible components of a children's product must be tested to demonstrate compliance with the lead content limit of 100 parts per million. If the products have any metal or plastic components such as buttons, snaps, or zippers, they likely will need to be tested for total lead content at a third-party CPSC-accepted lab. However, please note the commission issued a series of lead testing determinations under 16 CFR section 1500.91 for certain materials, including dyed and undyed textiles that are not treated or adulterated. For more information, visit cpsc.gov slash lead. If the children's clothing contains any painted component parts, then lead and paint requirements under 16 CFR part 1303 apply. Such articles must not contain a concentration of lead greater than 90 parts per million in paint or any similar surface coatings and must always be tested at a third-party CPSC-accepted lab. Additionally, if there are any screen printing inks used on the garments, then they may need to be tested to either the total lead content or lead and paint requirements. The applicability of the tests depend on the types of inks used and the process for applying the inks. For more information, please visit cpsc.gov slash lead and paint. Congress permanently banned children's toys and childcare articles that facilitate sleeping, feeding, sucking, or teething in children ages three and younger that contain eight specified phthalates and amounts greater than 0.1%. Phthalates are chemicals used in plastics and plasticized components, such as buttons, snaps, or zippers. A common example of a garment subject to both the requirements of part 1610 and the phthalates rule are children's bibs. For more information, visit cpsc.gov slash phthalates. If you're new to product safety or need help, CPSC's Regulatory Robot is an online tool that will walk you through a series of questions to discover the likely applicable requirements in place for your consumer product. You can access the regulatory robot at business.cpsc.gov. We also recommend that you check out product safety recalls at cpsc.gov slash recalls. We hope you learned a lot about flammability requirements for clothing textiles in this overview of 16 CFR Part 1610. If you have any questions about wearing apparel requirements or any other requirements involving your consumer products, please contact the small business ombudsman by visiting cpsc.gov slash smallbiz. Submitting an inquiry through our contact form at cpsc.gov slash sbo-contact, calling toll-free at 888-531-9070 or emailing us at sbo-cpsc.gov. Thanks for watching!