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CPSC Small Business Office Webinar Series: Cloth Diapers

If you are a Manufacturer or an importer of cloth diapers, although there’s some caveats, There for importers much harder to qualify as a small batch manufacturer, so Mainly focused on domestic manufacturers there, and they will do something that I Hope that you guys find fun which will be interactive audience polling where I’m going to ask you a series of questions and then we’re going to get Feedback, you guys are going to guess the answers and we’ll talk about what the Actual answers are on several questions pertaining to cloth, diapers I’ll talk, About children’s product certificates we’ll actually go through an example of A children’s product certificate specific to cloth diapers and what Information needs to go in what section and then I’ll highlight a children’s Apparel recall example: that is not a cloth diaper, but it is a defect.

Recall Associated with children’s apparel and I’ll talk about why it’s a good example For this product at that time, I’ll hyatt I’ll highlight some of the CPSC business Resources that our office makes available to use Guys, let you know where to find those resources and then finally, we’ll do a Question and answer session at the end of the presentation so first off for Labeling and testing requirements we’ll take a look at labeling cloth, diapers Require tracking information because it’s a children’s product and tracking Information needs to be permanently affixed to the product and the packaging And we get a lot of questions in our office about what it means to have.

Appropriate tracking information on your product and packaging you want to make Sure that four things are covered, the first thing is you want the manufacturer. Or private label er name is it’s being made domestically, it’s being made. Overseas or even you know, to our northern neighbors or seven neighbors in North America then you’re going to want to put the importer name on the product. And the packaging, you also need to make sure that the location and date of Production of the product is included in your tracking information and I will Touch on some frequently asked questions right after this slide, it will kind of Highlight what that means in certain contexts? You want to also include the Third piece of information, which is detailed info on the manufacturing, Process which includes batch overrun number information if you use that in Your manufacturing process can be a very good way to isolate within your Production line where there could be an issue associated with the product and Then finally, the fourth piece of information is any other info.

That’s Going to help a consumer ascertain the source of the product, because that is The purpose of permanent tracking information and one thing that I like to Recommend here is the website for your business, for two reasons: one makes it a Lot easier for a consumer that might be having an issue with a product that They’ve gotten from your company to get in touch with you and then the second Thing is it’s free advertising right if they like the product, they can see the Website and go onto your website order more product straight online, so there Are frequently asked questions section on our website and I’ve got the address.

There CPSC gov forward slash tracking label again. This appears as a hyperlink In the handout on the right-hand side of your screen in the pdf version of this Presentation, it is actually a hyperlink takes you right to the frequently asked Questions slide or the free sorry. The frequently asked questions page on our Website so with that being said, let’s take a look at some of the frequently Asked questions that we get on tracking information that might apply to the Cloth diapers that you might be designing or manufacturing.

So what meets The location of production requirement for permanent tracking information well It’s being made domestically city, state and country of manufacture, so where I’m Physically standing today, it would say the desde Maryland USA and that would Meet the location of production requirement it’s being made in another Country you want to put the province in the country and then what happens if You’re importing a product question we get frequently is: should an importers Name appear on the tracking label instead of the manufacturers and the Answer is yes: if the product is being manufactured outside the United States, The importers name is going to need to take the place of the manufacturers name.

On those four pieces of information on the tracking label, another question that We get very frequently do I need to test the tracking label and certify its Compliance and the answer here is no, however, the way that you decide to mark Your consumer product cannot introduce lead into a children’s product, so you Want to be careful in the material that you choose if you’re going to Permanently affixed a fabric tracking label and then another frequent question: If you’re using disposable packaging does an adhesive label on disposable, Packaging meet the permanently affixed on packaging requirement and the answer Here is maybe, and it depends on how adhesive that label is if this is a Label that is actually going to stay on the disposable packaging such that it Reaches the consumer, then that is a permanently affixed label on packaging.

And would meet the requirements, however, if it’s going to fall right off that Would not meet the requirement for permanently affixing a tracking label on Packaging so let’s take a look at testing requirements and I will try to Highlight some of the questions that we get on cloth diapers, specifically that Kind of confuse it with other different types: Consumer products, because I think it’ll help you guys figure out what applies to The products that you are working with so the first thing is a children’s Product so lead content and accessible components applies, and that is from Congress at 15 USC part 1278, a and the level, therefore, leg, content and Accessible components is 100 ppm for lead and paint and surface coatings and This will be a coating that doesn’t sink or I guess, fully absorb into the Substrate, that standard is 90 ppm or that limit and that’s from our regs at 16 CFR part 1303.

We’ve got the two types of lead testing that could apply to your Cloth diapers, depending on how they’re constructed the third thing is: Flammability testing and there is a general wearing apparel flammability Standard which is our reg 16 10 and there’s one for vinyl plastic film, much Less applicable on cloth diapers, although we do get some questions on Accessible diaper diaper inserts that might involve a vinyl plastic filament At 1611, but apparel flammability standards do apply most likely.

It’s Going to be 16 10 that applies to your cloth, diapers in terms of testing Procedure and a note here – and you know this – is here because a lot of questions Come into our office related to whether or not cloth diapers are considered Children’s sleepwear, the answer is they’re not and the reason that we get That question is because children’s sleepwear, as many of you know, is subject To a more stringent flammability standard, also in our regulations, which Is 16 CFR, 16, 15 and 16 16 for our agency does not consider cloth diapers as Children’s sleepwear and the fourth bullet here is also based on a question.

That we frequently get is whether or not cloth diapers need to be tested for Phthalates, as many of you know, toys and child care articles that facilitate Sleeping and eating are subject to phthalates limits and the phthalates There can exceed more than 0.1 percent. There are six types of phthalates that Either are temporarily banned pending a final rule from the Commission are Permanently banned in precise components, however, this does not Apply to cloth diapers, they are not considered a child care article that Facilitate sleeping and eating and they’re, certainly not a children’s toy So no phthalates testing is required on cloth diapers.

Once you have met all of Your testing requirements, you want to make sure that you properly certify that You’ve met these requirements and you do that through creating a children’s Product certificate and we’ll go through an example of that and hopefully you’ll Find that useful I’ll also refer you to some resources on our website in terms Of obligations of who needs to create a children’s product certificate, it is Importers and domestic manufacturers that are responsible for making sure That a CPC has been created and is in place to cover the cloth diapers that They may be importing or manufacturing all right.

Let’s take a little harder. Look at each of the testing requirements because there could be, depending on the Type of material or the way that you are constructing your cloth diapers there Could be ways that you would be able to avoid testing in certain instances. So The first requirement that was on that bulleted list from the fly before was Led content testing from 15 USC 1278 – a you remember the limit.

There is 100 ppm And accessible components, however, keep in mind that there is a pretty extensive List of materials that we know after years and years of testing within our Agency that are not going to exceed the lead limit as long as they’re in an Untreated on adulterated State and those materials, I’ve highlighted some here and I’ll go through those are in 16 CFR, 1500 point nine one and again that’s a Hyperlink right to that regulation that is available on the PDF handout on the Right-Hand side of your screen, the reason I wanted to hyperlink the Regulation for you, if not so, you can go and read, regulations which I know Non-Lawyers find really exhausting and no fun it’s because I’ve done my best Here to highlight each of the materials that I think may apply to your cloth.

Diapers, but that regulation has a pretty extensive list, the contents of which I Could not list – or I guess I could list, but it might be a little bit exhaustive. For our purposes today, okay, so if you are using a textile That’s not on this list, check the regulation and see if it’s there, because If so, you might be able to avoid total leg content testing under twelve. Seventy Eight a so: what are the materials? The first one is a wood paper and similar Materials made from wood we’ve had some questions about cloth diapers.

I guess There are some innovations in the way of textiles that are being created from Wood and paper derived products, so those would fall under that exemption or Likely would you’re welcome to reach out to us with specific questions on Textiles that you might have and then, if we internally need to get a decision. From our experts within our agency, we’re happy to do that. But wood paper and similar materials made from wood are listed in 1500 point Nine one as not requiring total lead content testing now the second bullet Here is CMYK process printing inks, and why is this important Cmyk process printing ink fully absorb into the substrate, so they are listed as From not requiring total egg content testing and then natural, fibers diet or Undyed, including, but not limited to and again, I’ve had tried to highlight here a Lot of the materials we get questions on, but there’s a much more extensive list.

Online cotton linen hemp, bamboo file, silk and sheep’s wool and died or undyed States as long as they are untreated and then manufacturing our manufactured Fibers also died or undyed, including, but not limited to rayon yfl acetate. Triacetate rubber polyester nylon, acrylic motor acrylic and spandex Additionally, I’ve added this is based on agency guidance that we’ve received Internally from our staff that velcro and applix, which are two materials that Are frequently used in cloth diapers would be considered textiles that fall Under 1500 point nine one, it would not require total leg content testing.

Also Important to remember here, there are other components on your cloth: diapers Besides the fabric that you make them up, and you Should think of the products that you are creating kind of like a puzzle with A bunch of different pieces and you need to look at each of the pieces and see Whether or not different types of testing would apply based on how the Pieces come together so for zipper, snaps and other fasteners.

That would be made. Of like a metal or a poly resin, you want to make sure that those comply with the Total lead limit on substrate and then polyurethane laminate or pull we get Questions about frequently on cloth diapers would not require testing if It’s inaccessible, however, it’s not on the list at 1500. Point nine one! So if it is accessible, it would require total egg content testing. Colorants may be a source of lead, so you want to think about how your coloring And dyeing your textiles that you’re, using and depending on the types of inks And colorants that you’re using to do so, they could be a first LED that would Require total egg content testing and again testing labs can very frequently Help you determine whether or not lead content testing would be needed.

You’re Also welcome to reach out to our office, and we can forward internally to the Experts here at the agency to help you figure out whether or not testing would Apply for lead in paint and surface coatings. This is the second bullet point. On that four bullet point list that we talked about for testing requirements. It’s a straight from our reg. You remember for paint and surface coating. The limit is 90 ppm.

Unfortunately, on paint and surface coatings, there’s no Exceptions and exemptions, like we just talked about for total egg content. However, thing to remember here is that if you don’t have paint or a surface Coating, this is not going to apply to you, but what does it mean to be a Surface coating well surface coating is something that’s Applied to a substrate that does not absorb into the substrate meaning it’s Sitting on the surface, so examples that we see here that require ledge and paint And surface coatings testing in a cloth, diaper context or frequently screen Printed fabrics and then painted zippers and snaps and with painted zippers and Snaps remember they can, with the puzzle, piece method that they’re going to need.

Total lead content testing for whatever the zipper and snap is made of And then lead in paints and surface coatings testing for the paint. That’s Sitting on top of that snap, all right, the third requirement is flammability. Testing in flammability testing on general wearing apparel is in our Regulations, part 1610. That applies to all textiles that are used for adult and Children’s wearing apparel and cloth diapers are children’s wearing apparel This just of note, this flammability testing section does not apply to Certain types of hats, gloves, footwear and inner lining fabrics and then for Children’s sleepwear that’s got to meet a more stringent standard, so I just Wanted to highlight that, for those of you that might be making other type of Apparel items and wondering whether or not the flammability testing of 16:10 Will apply to those items, so a vinyl plastic film is the other flammability Testing requirement and again very frequently, input applies here because Vinyl plastic film really is a disposable diapers material.

It would be Unsupported vinyl plastic film that could be transparent, translucent and Opaque but it needs to be uncovered or exposed in wearing apparel to require Flammability testing to 16-11 from thymes and vinyl cloth, diaper inserts. If Those are exposed, this would apply but again very limited circumstances. I just Wanted to bring it to your attention, though, so for flammability, there are Some exemptions for flammability testing and those can be found in our regulation.

Section 16, 10.1, section D and the fabrics that do not require flammability Testing are broken into two main categories. The first one is plain: Surface fabrics that exceed a certain weight, and that way it is eighty eight Point two grams per square meter or two point: six: ounces per square yard; Regardless of fiber content, so that’s the first type of fabric that would be a Type of textile that could be exempted from Ability testing and in the second group, our plane and resurface fabrics that are Made of six materials or any combination of them, regardless of weight and those Materials are acrylic, Mota, acrylic, nylon, olefin, polyester and wool.

So I you know: Point to take away from the flammability testing exemptions and the list of Materials that we aren’t going to exceed the lead content, our total leg content, Is when sourcing materials, if you would like to try to limit your obligation to Test, because that can sometimes you know, add to the expense associated with there. It always adds to the expense associated with getting a product to market.

Then, if You are creative and sourcing, your materials, and you check fifteen hundred Point nine one: four total leg content exceptions list and you check the Flammability exemptions list and you managed to pick textiles that fall under Both and you can avoid testing in certain circumstances. So flammability testing – I just wanted to highlight some of the things associated With it and how it works, because we do that some questions about what does it? Mean to be different classes of fabric, and it’s you know under flammability, Testing, so what flammability testing standards do? Is they classify the Flammability of a textile into three classes and that’s class, one: two: three And it’s based on two main things, which is the average burn time over several Specimens or the speed that there that they burn and in the surface Characteristics of the fabric and class: three textiles are considered.

Dangerously flammable and are not suitable for use in clothing, because They rapidly and intensively burn, so this is just a picture of a sample being Prepped at our testing lab and for flammability testing, you want to have And again, this is all in 1610 and the testing procedure is outlined there You’ll want to have a 2 by 6 inch specimen, and you can see that attach to The late their eyes held at a 45 degree, Angle: here’s a 16 millimeter flame, a one-second ignition.

The ignition has to Take place on the surface, the burn time is recorded, there’s a prescribed sample. Prep on you know what you need to do before you put the sample on the plate. And begin the burning process and then what you do afterwards and then Refurbishing is required and refurbishing is laundering. The textile And whatever way is going to be prescribed for whoever’s going to wear It so again very complex, the flammability testing procedure and it’s Outlined in 16 CFR, 1610, four other things to keep in mind on children’s Clothing, small parts, sometimes cloth diapers, have small potential small parts.

In them – and you can see some examples of small parts – the toggle which I frankly Have not seen on cloth diapers but could certainly exist, and then you see buttons. Which I have seen on cloth diapers, so a cloth diaper examples, so things to keep In mind with things like those toggles or those buttons, are that children’s Clothing and accessories are exempted from the small parts regulations. Many of You know small parts does apply to children’s toys if they’re intended for Children under the age of three and many children’s products is intended for Children under the age of three certainly cloth.

Diapers are, however, a Children’s clothing and accessories are exempted from a small parts rags, but you Need to make sure those things are secure. And I’ll talk about a recall example on children’s apparel and highlight why That’s important but suffice to say for now that, if buttons or toggles start Falling off of your cloth diapers, because they’re, poorly constructed or They’re not properly attached, then our agency to take a look at that based on a Report or our own internal investigation and determine that that could be a Product hazard, so if you are using toggles or buttons any kind of fastener That might be affixed to your cloth diapers.

You want to make sure that those Are very secure and don’t have the ability to be pulled off all right for once touch on the small Batch manufacturer registration benefits because many people attending may Qualify as a small batch manufacturer and one of the questions we frequently Get is what are the benefits if I register so at the outset. I just want to Say registration is not required at all by your agency.

However, if you do Register there are certain benefits, so let’s talk about those and we’ll first Start with what it takes to qualify as a small batch manufacturer, the Qualifications in this calendar year, you must meet two requirements and that’s a Gross revenue requirement and a limit on the amount of manufactured products that Fall under your registration in a calendar year so for gross revenue last Calendar year you cannot have exceeded right under 1.

1 million and that figures On your screen and you cannot have manufactured more than 7,500 units of The covered product that qualifies you as a small batch manufacturer so in the Context of cloth diapers, what are the benefits of registering and small batch Manufacturer the benefit is that registered eligible small batch Manufacturers may be able to avoid third-party testing at independent CPSC Excepted labs for specific tests on children’s products in one example is The flammability test for a general wearing apparel in 16 CFR part 1610, now Registered eligible small batch manufacturers can conduct first party Testing or manufacturer testing.

In this context, however, you must make sure that You are strictly meeting the requirements of 16:10 and its sample. Prep and testing procedures, which are extensive if you are interested in this If you have specific questions, please feel free to reach out to us and we’re Happy to seek guidance with the groups within our agency to have much more Expertise on this than I do, you can find out more information on the benefits of Small batch manufacturer registering on our website at CPSC gov forward, slash Small batch and again, it appears as a hyperlink on your screen.

It’s a Hyperlink in the handout on the right hand, side of your screen in the PDF Version of the of this document all right, I love charts As many people who know me know, so I just wanted to give you guys a chart if You are a manufacturer of cloth, diapers that you could have handy and it would Be an easy reference for you, so things to keep in mind here. I’ve got the for Potential types of testing that we talked about at the outset and then I’ve Got three columns.

The first one is: is third-party CPSC accepted lab testing? Required for each of these types of tests and we’ll talk about that by test In just a second, the second of the columns on the right hand, side is, can Written assurances from our supplier be relied upon by a registered small-batch Manufacturer so for those of you attending today that are registered Small batch manufacturers or you are eligible to register and you are Considering whether or not you should register this will let you know the Benefits associated with that and then finally could a domestic manufacturer Rely on timely component part testing from a supplier to avoid retesting for Each of these types of tests, so let’s take a look at the left-hand side and Look at each of the types of testing and then we’ll look at we’ll go right across Each of the columns so first one a total egg content which applies to accessible Parts usually total egg content applies to the textiles that you use for your Cloth diapers, it would also include polyurethane laminate and then the snaps And zippers that you use the substrate there, be it metal or poly resin.

So third Party CPSC accepted lab testing required no on total egg content. Can you rely on Written assurances, if you’re a registered small batch manufacturer – yes So what is the written assurance from your supplier is something on their Letterhead, that’s certifying to you that the products that they’re supplying us Complies with our Legg content limit of 100 ppm, so that is this should be a Distinct in your mind, from a testing report, but again that is only eligible Registered small batch manufacturers that can utilize written assurances Until the LED content and then on the also on the right hand, side for total Egg content domestic manufacturer can lie on component part testing from a Supplier on total leg, content for their textiles order, snaps and zippers for LED And paint and surface coatings you’ll see that it’s the flip of the leg.

Content above it, you do need third-party CPSC accepted lab testing. So if you have Things like painted snaps or zippers, or screen printing you’re going to need to Have that lab tested by a CPSC, accepted testing lab and we’ll talk about how to Find those in just a second, you cannot rely on a written assurance that the Lead and paint and surface coating does not exceed our 90 ppm limit if you’re a Registered small batch manufacturer.

But if you get a testing report that is on The component part, be it the painted snap or zipper that is from your Supplier, that’s certifying to you that it’s passed, the 90 ppm LED in painting Surface coatings limit you can rely on that component. Part testing for Flammability on general wearing apparel under 16 10. That does not require Third-Party CPSC accepted lab testing. However, you can, as a registered small Batch manufacturer rely on a written assurance that the textile that they’re Supplying us passes the apparel flammability testing and you can also, as A domestic manufacturer rely on timely component part testing and what, if it Means to be time like timely component part testing, we’ll talk about that in a Second, but it’s usually a testing report, that’s within the past a year and that You make sure test your actual product component and then finally for vinyl.

Plastic cell flammability testing, as it might apply to diaper and parts that are Exposed in some way again very isolated application of 16:11 in flammability Testing here you do not have to have that CPSC accepted third-party lab Tested and you do have the ability to rely on written assurances if you are an Eligible registered small batch manufacturer and you can also rely on Timely component part testing from your supplier of the vinyl plastic film, so We just talked about all the testing requirements.

How do you find testing lab If you are required to use a CPSC excepted lab, you’ve got to find that Cpsc accepted lab via our website, and I’ve got the site linked there. That is Available on your handout at cpsc.Gov forward, slash lab search, you have the Ability to narrow your search by region or by country and by scope, meaning the Type of product testing that you need – and there is a lab search demo – article Available on our website and I’ve got the hyperlink in your handout.

We are Working on the lab search page and we’re trying to make it a little more user, Friendly in the meantime, if you have questions, feel free to reach out to us, We’re happy to help you find a CPSC accepted testing lab for your cloth. Diapers and the lab search demo, article can also probably help you figure out. How to best use that website, if you you know, are doing this after hours or at a Time when will or myself are not available to help you on the phone, so Testing frequency there is a periodic testing rule.

One of the questions that We hear a lot is: how often do I have to get my cloth diapers tested? Well, the Main answer is that a vast majority of manufacturers and importers need to make Sure that they’re testing their products once per year – and that applies, that is The default, however, if you have a production testing plan and if you’ve Got questions about that we can talk to you more in depth about what that means.

You do have the ability, with a production testing plan in place to test Every two years and I’ll caveat that in just a second about material changes, Every three years requires that you have a testing lab accredited under that ISO. Standard very, very, very few manufacturers are going to qualify for Every three year testing and the takeaway here, the vast majority – it’s Going to be once per year, so our testing requirements, what is the proper Procedure, manufacturers and importers need to submit the samples to the Testing lab and we get questions on that – we’ll talk about that a little bit later.

In the webinar, the CPSC accept a testing lab receives Your samples perform the applicable testing and then They provide you, the testing results, our recommendation to lower your cost. You Want to find one lab that can do all the testing that you need to have done. Labs Are accredited or accepted by the CPSC on a test by test basis, so they may not. Be able to perform all the testing that you might need to have done on your Product, so when looking for a testing lab, you want to make sure that they are Accepted by us, especially in the case of children’s products, that they can test, Or conduct all the testing that you need to have done in your cloth, diapers and For importers, the testing needs to be completed before entry at the port or You distribute them in commerce, and you need to have proof of that ready to be Provided and I’ll talk about that, a little bit more depth in just a second So I said I would caveat the testing requirements a second ago when I talked About every two years, with a production testing plant or once per year for the Vast majority of manufacturers that changes, if you make a material change to The design of your product, and what does it mean to be a material change? We get a Lot of questions on that, and truly that is a case-by-case basis, question that You know, I can’t give you a broad answer on, but if you do have questions on Whether or not some things a material change, please feel free to reach out to Myself and we’ll in our office and what we can get guidance internally on Whether or not what you’ve done is considered a material change that would Necessitate retesting the affective component part or the entire product.

You Do have the option to do either one in most circumstances, but again it’s Case-By-Case so we’re happy to help you if you believe that you might have a Material change on the design of your cloth diapers. That could mean that you Need to test more frequently than that 12-month window, Once that retesting on the component, part of the entire product has happened. After our material change, you need to make sure that you issue a new Children’s product certificate and who’s responsible for children’s product Certificates, manufacturers or importers are responsible for making sure that a Cps or a CPC is available based on passing test results all right, so I hope Everybody is ready to go and excited about interactive audience, polling, we’re Going to see how well you’ve all been paying attention and I’m going to you Know hopefully, you guys are going to get all the answers right, but let’s just see How we do so, I’m going to go ahead and put the first question up and that Question hopefully, is appearing on your screen and it is do reusable pocket.

Diapers have to bear a permanent tracking label, and these are questions. Based on ones that we get quite frequently in our office, so let’s see as A group how we do you all right and it looks like everybody Has voted so I’m going to go ahead and close the results and, let’s share and See what we as a group thought the results were on whether or not reusable Pocket diapers need to bear a permanent tracking label and it looks like by and Large we thought the answer was yes.

So, let’s see if we were right and good news, We we are correct, so here’s what you guys need to keep in mind if we’re Talking about reusable pocket diapers that are sold in a set, then the answer Is yes, the reusable pocket diapers need permanent tracking information on them? So great job, everybody – that was just our warm-up question, so Let’s see how we do on the second question again, these are based on real Questions that we receive from manufacturers and importers of cloth Diapers each day, so the question here is which lead limit applies to accessible Polyurethane laminate and cloth diapers would it be.

The 100 ppm lead limit that Applies to substrate lead or the 90 ppm lead limit for paint and surface Coatings, you all right now give you guys just a few More seconds it looks like there is an overwhelming response. All right, I’m Going to close the poll and let’s see what we as a group, thought the answer: Was on which lead limit applies to accessible polyurethane, laminate and Cloth diapers and it looks like the group pretty overwhelmingly thinks that The answer is 100 ppm, which applies to total, lead content and substrates.

Let’s See if you guys were right – and the answer is 100 ppm for lead and substrate So the large majority of you guys were correct: okay, well, you’re and you’re. Doing great so far, so let’s see how you do on our third question about cloth. Diapers also frequently received from members of the public all right, the Question here are cloth diapers, consider children’s sleepwear subject to the more Stringent children’s sleepwear flammability standard when people are Answering very quickly that’s a good indicator because we get so many Questions here, because young children sleep frequently in cloth diapers, so we Get questions about whether or not it’s considered children’s sleepwear, so Everybody voted so quickly that I would go ahead and close the poll and then We’ll take a look at the results and see what we thought as a group on whether or Not cloth diapers fall under the children’s sleepwear flammability Testing standards – and it looks like I haven’t – been able to stump you guys so Far because a huge majority, 85 % of you said that the answer was no.

Let’s take a Look and see if that, if you guys are right and the answer is no cloth – diapers Are considered general wearing apparel, so they are not subject to the more Stringent children’s sleepwear flammability standards they are instead Subject to the general wearing flammability standards of 1610 All right, I got another question queued up for you guys, let’s see how you do on This one and the question here is our cloth diaper subject to salads testing.

Thank you to everybody, who’s Participating you guys you’re on the ball and I’m reading the participation Percentages go off the charts all right, so I’m going to go ahead and close. The Poll here and let’s see what the group thought in terms of whether or not cloth Diapers would be subject to phthalates testing and, as a group, you Overwhelmingly thought that the answer was no, that cloth diapers would not be Subject to phthalates testing, let’s see if you were correct, you are correct.

The Answer is no phthalates. Testing applies only to children’s toys. In child care articles that facilitate sleeping and eating, our agency has put Out guidance and it’s available on our website, I’m happy to point you to those Resources that children childcare articles that facilitate sleeping and Eating would include something like a baby, bib, sippy cups and utensils and Children’s sleepwear as well all right, let’s see how you do on the Fifth question that I’ve got queued up for you and the question here is our Disposable diaper liners subject to the same testing requirements as cloth.

Diapers, I will give you guys just a few more Seconds to get your answer in before we close the poll all right, I’m Going to go ahead and close the poll and let’s see what we as a group, thought on Whether or not disposable, diaper liners were subject to the same testing. Requirements as cloth diapers looks like the large majority of you, Guys thought that the answer is no, that there are different requirements, that Apply to disposable, diaper liners, let’s see if you were right and you guys were correct.

The answer is No, that diaper liners as with cloth diapers, need to meet lead content. Requirements so in that way, disposable, diaper, liners and cloth diapers are the Same in lead content requirements, however, on flammability they are Different disposable, diaper liners that are completely unexposed to the outside Do not require flammability testing and that’s per our regulation. 16 CFR. 16. 1034.

So it was a bit tricky because that’s information that I didn’t provide, but You guys already knew the answer. So, let’s see how you do on question number. 6 – and the question here is – are cloth diapers, subject to the small parts ban, Because they are intended for children under age 3. Alright I’ll give you guys just a few More seconds to get your answers in because this is trending not in a Decisive fashion, all right, I’m going to go ahead and close the poll and, let’s See what we as a group thought the answer was on whether or not cloth Diapers are subject to small parts banned because they’re intended for Children under 3, you can see the group it trends towards yes, but we’re close to Evenly split we’re 6040 on our percentages, let’s see if the folks that Selected, yes, we’re correct, and the answer here is actually no cloth.

Diapers Are exempt from small parts testing and the small parts banned under 16 CFR? 1501. Point 3 D, however, because children’s clothing and apparel, which cloth diapers Are do not require small parts testing and therefore there’s no small parts ban. On them, however, please keep in mind – and this is the caveat from earlier – that all Snaps and buttons still need to be secured on those cloth diapers because You don’t want to be in a recall situation based on a product defect, so As a group we’re doing great, we’ve got one more question and I’m going to go.

Ahead and queue up for you guys, that is a little bit more specific. That again is Based on the types of questions that we have received from you know, fellow Manufacturers and importers of cloth diapers all right and the question that You guys are taking a look at is a manufacturer of cloth diapers, where the Diapers are made entirely of bamboo fiber and velcro. Do Bislett testing need To be conducted on those diapers, alright, I’m going to give you guys just A few more moments to get your question, I mean your your answers to the question.

Then all right, I’m going to go ahead and close the poll because it looks like Everybody’s participated, so let’s see what we as a group thought the answer. Was then we’ll see whether or not we were right? So 72 % thought the answer was No, that cloth diapers made entirely of bamboo, fiber and velcro would not Require lead content testing. So let’s see whether or not you guys were correct. And the majority of you were correct, those cloth diapers would not require Led content testing and that’s pursuant to the list that we discussed earlier Which is in 16 CFR 1500 point nine, one specifically D: seven that lists Unadulterated and untreated bamboo, fiber and velcro is included by our agency.

Interpretation at fifteen hundred point nine one and the list of materials that Do not require total leg content testing based on years and testing by our agency. Some things that we know will pass and will not exceed the substrate lead. Content level of 100 ppm, so thank you. Everybody for participating in the poll. Let’s take a look at children’s product certificates and what would go on a Children’s product certificate that covers cloth diapers, there are seven Pieces of information that need to be on a children’s product certificate, we’ll Go through each one caveat here: this is for demonstrative purposes only so it Might not include everything that applies to your cloth, diaper based on Design, some of the things that are included here may not apply based on the Design of your cloth diaper so we’re just using it for an example in number One you need to describe the product covered by the certificate, so that’s Going to be a full description, as best you can of the cloth diapers that you’re Manufacturing or importing and number two you’re going to cite to each CPSC Safety rules to which you are certifying compliance and I’ve listed out there, the Four things that could apply that we’ve covered today, which is the two To lead testing, then the two different types of flammability testing: again Keeping in mind vinyl plastic film only applies to uncovered and exposed vinyl Plastic film large majority are going to fall right under 1610 for clothing.

Textile flammability testing number three: you need to make sure that you Include your importer or domestic manufacturer contact information number Four is the contact info for the person that maintains your testing records very Frequently that individual might not be within your organization might be Somebody outside to include as much contact info as you possibly can. To help our import staff in our compliance staff take a look at these Certificates and get in touch with the right people for testing records.

Number Five, the date in place of manufacture of the goods that this certificate is Covering in this case, your cloth, diapers number six, the location of testing and The date is test on which the certification is based. However, if you Are relying on a regulation, the two of which we have discussed today, have to do With total lead content testing the list of materials that would not require Total leg content testing at fifteen hundred point nine one or flammability Testing exemptions in sixteen ten point, one D, if you are relying on those to not Have to test your product, you want to make sure that those citations are Listed out in number, six and six should parallel to in terms of the sections on Your certificate be as specific as you can in fifteen hundred point nine one And sixteen ten point, one D on which portion of those exempted or accepted Materials, you are relying on, so you know if it’s the weight of the fabric put the Weight of the fabric, if it’s the content of the fabric, put the content of the Fabric in number six, the number seven is the contact info of the testing lab that You use and again you want to provide as much information as you can and, lastly, I’ve got the asterisk at the top to remind you that if you are a registered Small batch manufacturer, you want to make sure to include your registration.

Number on your children’s product certificate all right, important things: To remember in children’s products certificates all children’s products, Require them that includes cloth, diapers manufacturers and importers have to be The ones that are certifying in their CPC that the product is very important. Our manufacturing complies and CPSC gov /c PC is our website for children’s Product certificates – and there are two samples on our website, which is Hyperlink in the handout on the right hand, side of your screen and those Samples are for children’s clothing, which you can absolutely use for your Cloth diapers or for a children’s toy, if that’s something that you’re also Manufacturing and the children’s product certificates three main things to Remember here those certificates need to accompany each shipment and there are Different ways of doing that I’ll talk about electronic certificates in just a Second, a copy of the certificate needs to be furnished to each distributor or Retailer of the product that you’re working with you do not have a Requirement to provide it to the ultimate consumer, a copy of the Certificate also needs to be available to our Commission, our representatives of Our agency or Customs and Border Protection upon request and then finally Electronic certificates, our Commission has ruled that electronic certificates Are absolutely fine, but those must be completed or it created the certificate.

Needs to be created no later than the time of shipment or first distribution, Within the United States, so it’s not an after-the-fact thing where you can go in And create a certificate after the fact all right. Lastly, I’m just going to Highlight a recall example, which is not on cloth diapers, but it is on children’s Apparel for a defect because this could apply to cough diapers, many cloth, Diapers have snaps just like this.

One Vita is at the bottom and you can see in Terms of units there were four hundred and seventy nine thousand of these Onesie fold, the recalled date here is August 2015, and the problem was that the Snaps weren’t sufficiently affixed to the onesie, so they came off and they Were a small part that posed a choking hazard so even though important to Remember even though small parts, the small parts band or the small parts Testing does not apply to children’s apparel.

You cannot have a product defect. Like this, where the snaps are coming off of the product, so you want to make That you fully secure the snaps or closure items to the cloth diapers that You are manufacturing all right: some Consumer Product Safety, Commission, Business resources: I’ve got my contact information up. There, you’ve got my email Address the telephone number: that’s there, 301 five! Oh four: seven! Nine! Four! Five is our business line.

I arranged that both myself and my colleague wills Desk and we answer as long as we are sitting at our desk and not at a meeting On another call, we do have a Twitter feed if you would like to follow us on Twitter, we post information about things like this webinar or speaking. Engagements that we have around tables that might be taking place and that We’re going to take part in so if you want to stay in touch with a small Business office: that’s the way to do that.

I’ve got the lab search page on the Left-Hand side, which we discussed earlier, is useful for helping you find a Testing lab again we’re happy to help you do that the desktop reference guide Which is useful and have all different types of consumer products and the Testing and labeling requirements that apply to them. The link is there and then The regulatory robot, which is an interactive bot that helps you figure, Out what requirements apply to your product, based on asking you a series of Interactive questions and generating a customized report at the end, all right, a Few last things to point out and then I’ll take a few last questions at the End, we have an agency YouTube blog now and there is a playlist.

That’s Specific for our webinar series, just like the one we’ve conducted here today – This is the third in our series, so the previous two are available on CPSC Webinar series playlist online and again that link is in the PDF handout on the Right hand, side of your screen and then, if you want to stay up to date on the Things that we here at the small business Ombudsman’s office are working On be it webinars or other things that might be going on with the Commission, we Try to do a nice job at the end of each month to issue a newsletter so that you Can keep track of Commission activities that you might be able to submit a Public comment on and to sign up for that monthly newsletter.

You can do so at Cpsc gov forward slash email, you enter email address and you’ll want to make Sure that you click small business Ombudsman updates Alright, well with that, it looks like time is up. I want to make sure that we End on time, so I thank you. Everyone for attendance and I’ll see everybody next Month, thank you.


 

By Jimmy Dagger

Find out my interests on my awesome blog!

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