Abstract
In 1996, the U.S. Consumer Product Safety Commission (CPSC) amended the children’s sleepwear flammability standards to exempt sleepwear sized for infants aged 9 months or younger and tight-fitting sleepwear for older children. These amendments were adopted after CPSC concluded that they would provide consumers a wider selection of children’s sleepwear without diminishing the protection provided by the standards. They were also issued in response to an apparent preference for untreated cotton garments by many parents and difficulties in enforcing the pre-amendment standards. Nevertheless, the amendments were controversial. Some interested parties opposed them because they believed the exemptions would substantially reduce the level of safety for children. The amendments were also subjected to congressional scrutiny; in 1999, after they had gone into effect, Congress required that the Commission consider revoking them. To address these concerns, in cooperation with the American Burn Association and Shriners Hospitals for Children, the CPSC initiated a national study of child clothing-related burn injuries treated in burn center hospitals. From 2003 through 2005, the CPSC collected information on 475 such injuries. This study evaluates the burn center data to help determine the safety effects of the amendments to the sleepwear standards. The results provide no evidence of increased risk of burn injury associated with the exemptions from the sleepwear standards.
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Notes
The standard for sleepwear in sizes 0 through 6X became effective in 1972 and is codified at 16 Code of Federal Regulations (CFR) part 1615; the standard for sizes 7 through 14 became effective in 1975 and is codified at 16 CFR part 1616. Sleepwear sizes reflect the ages of the children for which they are intended. Sizes 0 to 6X are generally intended for children up to age six, and sizes 7 through 14 are generally intended for children ages seven through fourteen.
The requirements are codified at 16 CFR 1615.3 and 1616.3.
Children’s sleepwear is defined by the standard as any product of wearing apparel in the sizes covered by the standard, such as nightgowns, pajamas, or similar or related items, such as robes, intended to be worn primarily for sleeping or activities related to sleeping, except diapers and underwear. The term item means any product of children’s sleepwear or any fabric or related material intended or promoted for use in children’s sleepwear (16 CFR 1615.1 and 1616.2). According to Commission policy statements intended to clarify the scope of the standard, relevant factors for determining whether a product of wearing apparel is intended to be worn primarily for sleeping or activities related to sleeping (or whether a fabric or related material is intended or promoted for use in children’s sleepwear) include: the nature of the product (or fabric) and its suitability for use by children for sleeping or activities related to sleeping; the manner in which the product (or fabric) is distributed and promoted; and the likelihood that the product (or fabric) will be used by children primarily for sleeping or activities related to sleeping (16 CFR 1615.64 and 1616.65).
Sleepwear is considered tight fitting if it follows prescribed measurements and is fitted snugly on a child’s body at seven points, including wrist, upper arm, chest, waist, seat, thigh, and ankle.
In July 2004, the General Accounting Office’s legal name was changed to the Government Accountability Office.
Based on burn injuries reported through NEISS, a stratified national probability sample of U.S. hospital emergency departments (Schroeder & Ault 2001), CPSC staff estimated an average of about 90 sleepwear-related burn injuries treated in U.S. hospital emergency departments annually (Morris 1999; CPSC 1999).
A snapsuit is a shirt designed for infants that extends past the waist and has snaps or buttons that allow it to be closed over the crotch, with enough extra room to accommodate or cover a diaper.
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Acknowledgements
We want to thank Debra Ascone, formerly with the CPSC’s Directorate for Epidemiology, for the important role she played in the planning and early data collection phases of this project. We also thank Laura Noble, a CPSC program manager who was in charge of liaison with the burn center hospitals and who conducted the initial review of the injury reports as they were received from the hospitals.
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The views expressed in this article are those of the authors. It has not been reviewed or approved by, and may not necessarily reflect the views of, the Commission. Because this article was written in the authors’ official capacities, it is in the public domain and may be freely copied.
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Rodgers, G.B., Adair, P.K. Exemptions to the Children’s Sleepwear Flammability Standards: A Description of Policy Considerations and an Evaluation of the Effects on Burn Injuries to Children. J Consum Policy 32, 59–71 (2009). https://doi.org/10.1007/s10603-009-9092-y
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DOI: https://doi.org/10.1007/s10603-009-9092-y