A Case Study: Review of Flammability Product Testing, the ... · Review of Flammability Product...

A Case Study: Review of Flammability Product Testing,

the Similarities and Differences

Ellen Roaldi

Bureau Veritas Consumer Products Services

September 22, 2016

2 Bureau Veritas Consumer Product Services

Agenda

►Methods Analysis

Applicability

Requirements

Exemptions

Exceptions

Differences

Similarities

►Recalls

►Conclusions

Question


• Scarf

• Shirt

• Sweater

• Pant

• Sock

• Underwear

• Boot

Question

What is the required Flammability if marketing across borders? Can we test to one method and satisfy compliance of multiple countries?

Consider the following…

Method Analysis


US

General Apparel Application

EU

China

► Adult and Children’s - which covers and protects head ,neck or face and gloves (>14”)

► Adult - No known

► Children’s - Industry practice-costume


► Children’s - Textile products worn by infants Children between ages 3-14

Canada ► Adult and Children’s - all

consumer products made of textile fibres


► Children’s costume - apparel

► Adult - all clothing

► Children’s - all clothing





Applicability

Finland

Norway

Sweden

Netherlands


Requirements

► Acceptance Criteria

US - Apparel

• Class 1: Plain surface : > or = to 3.5 sec. or more

• Raised Fiber: Burn time is > than 7.0 sec. or burn time is 0-7 sec with no base burns (may exhibit surface flash only)

Canada - Textile Products

• Plain surface : > to 3.5 sec. or more

• Raised Fiber: May exhibit ignition or fusion of its base fibres and must be greater than 4 seconds.

China – Textile Fabrics

• Average burning time ≥ 7.0 s or average burning time is 0 to 7 seconds with no base burn, charring and melting. Exhibit rapid surface flash only.


EU – Children’s Costumes

• Up to 30mm/minute burn rate at a 45 degree slope

Finland – Textiles

• Report time to ignite if 21sec or less/ Individual burn

Netherlands - Apparel

• For raised fiber surface the number of specimens as received which ignited charred or melted. /The flame spread of 127 mm must be no less than 4 seconds.

Norway – Apparel and fabrics

• For raised fiber surface the number of specimens as received which ignited charred or melted. Report option tested to (A or B for DC )Prohibition of law includes:

• 1) Children's apparel in sizes up to and including 170 cm and has a flame spread of 7.0 seconds

• 2) Other apparel and fabrics suitable for apparel having a flame spread of 5.0 seconds or less

Sweden – Apparel

• For raised fiber surface the number of specimens as received which ignited charred or melted. Report option tested to (A or B for DC) • Textiles are acceptable if the time of flame spread > than 5.0 sec.(textiles are unacceptable if

the time of flame spread is less than or equal 5s)

• Textiles with a flame retardant shall pass the requirement after 2 washing in addition to as received.

• Textiles with a raised fiber surface shall meet after 1 wash.

Requirements


Differences

►Exemptions From Flammability Testing

US -Plain surface weighing >2.6 oz.sq. yd or more / Plain or Raised Surface

made from nylon, polyester, acrylic , modacrylic, olefin, and wool.

Canada - None

China - Wool, nylon, polyester, acrylic, modified acrylic, polyamide , polypropylene are not tested. Exempt if plain surface and over 90 g/m2

EU - None

Finland - None

Netherlands - Smooth fabric (plain surface) weighing more than 88 gms./ m2 and/or all fabric made from nylon, olefin, polyester, acrylic , modacrylic, and wool.

Norway - None

Sweden - None


Differences

► Product exceptions - US, Netherlands and Norway

US

hats, gloves,

footwear and

interlining fabrics

Netherlands

swimwear, hosiery,

underwear and baby clothes (smaller than

size 80).

Norway Does not apply

to children's apparel in sizes

up to and including 170 cm or less . It does

not apply to export items or

production intended for

export.


► Method Differences:

Example

US - 16 CFR 1610 Finland - Nordtest 029 – (similar

to 16 CFR 1610)

CN - CAN/CGSB 4.2, No. 27.5 Netherlands - ASTM D1230

(most recent version)

China - GB18401 (references

16 CFR 1610)

Norway - ASTM D1230-81

EU – EN Part 2 Sweden - ASTM D1230-83

Differences


(Washing and drying / DC) Refurbishing • US / China / Netherlands follows 1DC Perchlorethylene) and (AATCC 124 -2006 using MW(120oF), NC, TD Cotton Sturdy • Canada 1 DC ( professional ) and then follows care on product or (“NORMAL 10 REGULAR” setting) with TD with exhaust temperature of 66°C ± 5°C (“DELICATES”) • Finland 1DC Perchlorethylene) and (AATCC 124 -2006 using MW(120°F), NC, TD Cotton Sturdy • Norway/ Sweden coin operated DC or Commercial DC, then follow AATCC 135 per care label, if no label info then MWW (120 °F and TD Normal or PP).

(Per specified method) Detergent • US / China / Netherlands specify AATCC 124 WOB

• Canada allows Tide

• Finland / Norway / Sweden specify AATCC124

• EU- NA

(Flammability tester) Equipment • US / China /Netherlands / Canada/Finland /Norway / Sweden - 45 ° angle chamber

• EU - Flammability chamber and candle specified in the 16CFR 1500.44

Differences


(Minutes)

Conditioning Temperature and Time

• Norway and Sweden: 105°C±3°C (221°F±5°F) for 15 minutes

• US, China , Findland and Netherlands: 105°C±3°C (221°F±5°F) for 30 minutes

• Canada: 105°C±3°C (221°F±5°F) for 1 hour

(Time) Flame Impingement

• All countries except Finland: 1 second point of impingement

• Finland: 20 seconds

(Time) Time in Dessicator

• US, Finland, Netherlands, Norway, Sweden: 15 Minutes

• China: 45 Minutes

• Canada:1 Hour

Differences


Similarities

►Small scale ignition

►All cover wearing apparel (But definition of apparel can differ)

►Testing to representative of finished production

►Gas supply

►Impingement time

►Recalls

►US and Canada joint recalls

Recall Analysis


Recalls

Based on Violation notices: US: For all products regulated by the CPSC, the Commission issues a Letter of Advice (LOA) when there is a violation of a mandatory standard. It advises the company of the violation and of the nature of the necessary corrective action (to correct future production (CFP); to stop sale and CFP; or to recall, stop sale, and CFP).

Canada and EU: Based on recall data.

US CANADA EU Total

April 2014 to

present

11 1 0 12

2013 0 3 0 3

2012 0 3 1 4

# garments

sold

35,940 + 20,486 unknown 20,486 +


1. It is necessary to understand all of the regulation details for applicability or exceptions.

2. It is not possible to test once for a global approach.

3. Testing is required per the countries code.

4. Different versions of the same method have different parameters of testing, therefore you must consider the year it was written.

5. Recalls / LOA’s have an even greater impact than before. In addition, globally they are being enforced and there are now joint recalls between US and CN.

Conclusion


Contact Information

For more information, you can reach me at the following:

Ellen Roaldi

(716) 505-3670

[email protected]

mailto:[email protected]

A Case Study: Review of Flammability Product Testing, the ... · Review of Flammability Product...

Documents

Transcript of A Case Study: Review of Flammability Product Testing, the ... · Review of Flammability Product...