01 Childrenswear Safety Manual 2009 - Clothing

Childrenswear Safety Manual 2009 - Clothing

Introduction Welcome to the Marks & Spencer Childrenswear Safety Manual.

Safety is extremely important to us and our customers have high expectations of our ability to trade safely and responsibly. It underpins our core business values (Quality, Value, Service, Innovation & Trust) and we take great pride in selling safe product that meets the highest standards of our business. Marks & Spencer has a large exposure to the consumer and so we must minimise the possible safety risk by minimising the hazard (Hazard X Exposure = Risk). It is therefore essential that all possible steps are taken to eliminate hazards and it is for this purpose that the Childrenswear Safety Manual exists. Understanding and adhering to its content will support the process of producing a safe product and assure continued confidence and trust in the M&S brand. This manual has been designed to give the reader guidance when designing and manufacturing Children’s clothing for Marks & Spencer and is arranged in alphabetical order for convenience. This manual is a ‘living document’ and will be continually updated to remain relevant to the changing needs and expectations of our customer as well as changes or updates in legislation. Please ensure you are always referring to the latest version available on the Quality Standards website. Technologists in our UK Head Office and Regional Offices, are available to support you in interpreting the topics covered in this manual. There will be occasions when product is outside the guidelines of the manual. In this instance advice must be sought, from the M&S Departmental technologist. The technologist will assess the risk using available research, data and services of our independent safety consultant.

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Product Safety Manager It is a condition of supplying Marks & Spencer Childrenswear that our Suppliers designate a senior level person as Product Safety Manager to co-ordinate all aspects of product safety. This person will be the key point of contact for Marks & Spencer for safety related matters. A Product Safety Officer must be employed on each factory site and this person must report directly to the Product Safety Manager. All workers involved in the manufacturing process from development to delivery must have access to adequate training so that they can successfully play their part in delivering safe product. It is the responsibility of the Product Safety Manager to ensure that this is delivered. Product Safety Audit (PSA) The Marks & Spencer Product Safety Audit exists to ensure that procedures operating in each factory can consistently produce the safe product our customer expects and that the Marks & Spencer brand and reputation demands. Before any factory can produce Childrenswear product, the Regional Product Safety Auditor must carry out a PSA and the factory must achieve a grading no less than ‘minimum standard’. Where applicable Corrective Action Plans will be issued and followed up with a visit(s). QMS Childrenswear Product Safety audit report is available on the Quality Standard Website, the path to the document is: Document Library/Quality Systems – Standards Factories will be re-audited by Regional Product Safety Auditor, the frequency of which will be determined by the grade awarded. It is a Marks and Spenser requirement that internal audits are carried out by the factory Product Safety Officer, monthly. A copy of the safety audit form can be found on the Marks & Spencer Quality Standards Website.

Ferrous Free Policy In order that product may be effectively metal detected, it is a requirement that suppliers keep to the M&S policy of using ferrous free metal components so they pass through the metal detector and ensuring the sewing needles are of ferrous content so they are detected for all production.

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Non Adherence to Safety Manual – Our Policy

The safety of our Childrenswear is a core requirement for Garment Makers to conform to. Specifically, all products presented to Childrenswear must be risk and safety assessed, and suitably specified, to avoid any foreseeable risk of danger to the customer. The Childrenswear Safety Manual details the minimum standards of safety that are our Marks and Spencer requirement. These standards to be adhered to for all our products, from first design samples through to production, including those products made for our Outlet Stores. Suppliers who deliver product that fails to perform to the clearly specified guidelines and requirements in this manual risk having non-conforming product rejected: at source, warehouse, RTM’d, or potentially recalled from M&S Stores or customers at their cost. This Merchandise will be destroyed unless it can be re-processed to a safe standard and at a timely requirement to the Departmental needs, no unsafe merchandise will be allowed to be disposed of for re-sale elsewhere. M&S takes the issue of product contamination very seriously – specifically where there is contamination of sharp items which have originated in the factory. In certain instances, these can cause a serious injury or even a fatality to a customer. Our General Merchandise Terms and Conditions – on the Quality Standards Website under Supplier Fines and Recharge Table (All Suppliers) - clearly states that where there is sharp contamination found in product, a fine of £10000 GBP may be applied to the supplier by M&S. We also reserve the right to Bulk RTM the product. In cases where there has been, or potentially could be, serious customer injury which may lead to a fatality, the product may be subject to a nationwide Product Recall. This procedure includes a full recharge of advertising costs in the national papers, as well as charges for the Bulk RTM

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Contents

Category No Non-adherence to our Safety Policy Risk Assessment Legal Documentation Marks and Spencer Internal Standards Test Methods Battery Operated Components 1 Beads 2 Belts 3 Bibs 4 Braces (Separate Braces) 5 Buttons 6 Decorative Feathers 7 Diamantes 8 Direct Embroidery / Fusible Motifs and Badges 9 Dressing up & disguise costumes 10 Elastics 11 Faux Fur pile fabrics & trims. 12 Flammability – All Garments excluding nightwear and Dress up 13 Flammability – Nightwear 14 Flash Flame 15 Float Lengths - Includes socks / tights / gloves / and garments with integral feet. 16 Hoods and Headwear 17 Hooks and Eyes and Hooks and Bars 18 Lace Crochet - open constructions 19 LED Lights (Light Emitting Diode) 20 Liquid Filled Products (e.g. Badges/ Teethers 21 Magnets 22 Metal components - Press fasteners, Stud buttons, Rivets, Eyelets, Strap adjusters 23 Migration of Toxic Elements 24 Natural Materials for Accessories & componentry 25 Necklaces 26 Neck Stretch 27 Neck Ties 28 Plastic bags e.g. over bags intended for sale with the products in M&S stores 29 Pom-Poms / Bobbles / Tassels and Fringing 30 Prints – (transfers, panel prints, all over continuous prints – includes backing materials) 31 Rouleau Loops 32 Safe in the Sun Garments and Hats 33 Scarves 34 Sequins 35 Silica Gel 36 Sleeping Bags 37 Sound Nodules/ Noise Levels 38 Swim Short Mesh Liner Fabric for Boys 39 Toys 40 Waddings and Quilted Waddings including Feather & Down 41 Washed Garments - that use Stones or Sand. 42 Zips 43 APPENDIX Cords and Drawstrings I Risk Assessment & Design Hazard Assessment documentation II Test to Failure (TTF) and Pull Tests III Test to Failure (TTF) - The Maths and graphical illustrations IV In Line Testing V

Risk Assessment Safety, like quality, must be designed, planned and built in to the product. It is sometimes difficult to foresee all the possible modes of failure allowing for all the conditions of use and unforeseeable use. Without a systematic approach to design and manufacture it is likely that some element will be missed resulting in a failure and possible injury to the wearer.

First the Hazards need to be identified

Burn An injury caused by heat, friction, cold, electricity, chemicals or radiation (sun)

• First-degree burns (superficial thickness) are usually limited to redness, minor pain and a white plaque at the site of injury. These burns usually extend only into the epidermis

• Second-degree burns (partial thickness superficial and deep) additionally fill with clear fluid, and have superficial blistering of the skin, and can involve more or less pain depending on level of nerve involvement. Second-degree burns involve the superficial papillary dermis and may also involve the deep (reticular) dermis layer.

• Third-degree burns (full thickness) additionally have charring of the skin, and produce hard, leather-like scabs. Frequently, there is also purple fluid. Nerve endings will have been destroyed in the involved areas.

Choking Choking is the mechanical obstruction of the flow of air into the lungs. This can be caused by a foreign object lodged in the mouth or throat thus blocking the airways

Hazard Example - release of a component such a button or stud Note:

Mouthing is an important learning strategy used by all children; infants start mouthing as soon as they can place their hand in their mouth this strategy continues with varied intensity until a child approaches 36 months after this it reduces considerably. This is well understood by child behavioral experts and all safety standards for children’s products contain specific criteria for children in this younger age group. Children’s garments contain many small parts such as buttons and poppers, if detached any one of these could become a serious choking hazard. In an effort to ensure that all products sold to this age group are as safe as possible a specific testing regime has been introduced for this age group to ensure that all products sold are safe. Testing to Failure or destruction is a statistical process designed to identify component defects and provide a consistently safe product

Entrapment A situation where a child is unexpectedly caught up on a garment or part of a garment. Hazard example - chain attached to the belt loops of jeans

Eye Impaction Injury to the eye cased by projectile Hazard example - projectile toy such as bow and arrow

Ingestion The process of taking something into the body by swallowing,

Hazard Example - button cell battery / magnets that could become an ingestion hazard

Inhalation (or Aspiration) The action of drawing in air, other gases or objects into the airway, as in breathing. This could lead to items getting in to the lungs or choking if the item lodges in the airway. Hazard example - A small button or part of a fastener could become an aspiration or inhalation hazard should it detach

Insertion (object into body) Injury caused by child placing small object into their nose or mouth

Hazard example - Detached bead

Over heating Very young children are not capable of regulating their temperature efficiently, which can lead to overheating Overheating may play a role in causing SIDS (Sudden Infant Death Syndrome),

Hazard Example – Sleep bags being too high a Tog Rating

Laceration Cut, scratch or graze Hazard example - Poorly attached fastener with exposed prong / flash on zip fastener

Penile entrapment There are two likely types of penile entrapment:

The foreskin can become caught up in the net fabric that lines boys swimming trunks The foreskin or the skin on the penis can become caught up in the teeth of a zipper on trousers

Pinching Painfully squeezing skin or flesh Hazard Example – caught in a push closure clip or caught in a hinged mechanism

Projection A protruding part that extends out from the garment, or accessory with the ability to cause an injury should the child fall on it. Hazard Example - Some buttons shaped like sharks teeth could become a projection hazard if placed in the neck area of a garment with no fabric / padding beneath when fastened. Restriction of hearing Any product that can constrain hearing

Hazard Example - iPod earphones can make wearer oblivious of approaching traffic Restriction of sight Any product that impedes clear vision Hazard Example – a mask that could limit peripheral vision Skin Irritation A skin allergy is caused by a substance that comes into contact with the skin Hazard Example – Formaldehyde Resin finishes Strangulation Injury caused by constriction of the throat that restricts breathing Hazard example - necklace without a break point, Suffocation Injury caused by the stoppage of breathing or asphyxia resulting from it. External suffocation (not choking or aspiration) Hazard example - flexible impermeable fabric such as hood Rigid hemispherical shape - container Tourniquet Injury to most likely a toe or finger that has caught in a float or loose end causing restriction to the flow of blood, causing potential loss of toe or finger Hazard example - Float on babies’ sock

Toxicity – Chemical A toxic substance is one that can cause harm from through inhalation (by breathing), absorption (by touch) or ingestion (by mouth) Hazard Example – Lead paint Toxicity - Microbiological The absence (or low colony count) of microbial growth would indicate a product was microbiologically clean. Hazard example - There should be no bacteria present a liquid filled badge Toxicity - Pathogen Any agent capable of causing disease. The term pathogen is usually restricted to living agents, which include bacteria, fungi, viruses, yeasts and certain insect larvae. Hazard example - Feathers must be treated in order that they are free from pathogens Tripping Falling by catching the foot on something Hazard Example - overly long dressing gown tie belt

• Marks & Spencer Technologist will then complete the Tech Pack (see appendix) with safety grading for the product (Tech Pack – See Appendix)

• FSV must assess their designs for Safety using the Hazard criteria • Suppliers must complete the ‘Supplier Safety Risk Assessment’ document (See Appendix) for each product – and use as a working document

from initial development through to contract seal. The final version must be uploaded onto contracts.com at contract seal stage. • Should a Product Review Document PRD form be required (see Appendix) this should be completed and submitted on contracts.com

at contract seal stage It is essential to ensure that every aspect of the product is adequately covered by the analysis.

Legal Documentation Childrenswear safety standards are governed by law, legal guidelines and retail best practices. This section sets a list of standards and statutory regulations that apply directly to or which Marks & Spencer has adopted for

application to children’s products and any associated accessories or components. Each supplier must ensure that they have a copy of and are familiar with the documents that relate to their product of supply. British and European Standards are available at http://www.bsi-global.com/en/Standards-and-Publications/ Please ensure you keep up to date with the latest versions. BPA (Baby Products Association) BS (British Standard) BSEN (A British Standard adopted by European Standards) EN (European Standard) (European ‘Norm’) ISO (International Organisation for Standardisation) SI (Standard International) General

• The Consumer Protection Act 1987. • General Product Safety Regulations SI 1803. • BS7907 The Design and Manufacture of Children’s Clothing to promote Mechanical Safety. • Directive 2005/84/EC of The European Parliament and of the council. The Dangerous Substances and Preparations

(Safety) Regulations 2006. • BSEN14682 Safety of Children’s clothing – Cords and Drawstrings. • Phthalate Directive 2005/84/EC • Azo dyes 2002/61/EEC • The Food Imitation (Safety) Regulations 1989 SI 1291.

Buttons • BS4162 British Standard Method of test for buttons.

Feather & Down

• BSEN12935 Feather and Down, Hygiene and Cleanliness Requirements

Hoods • BSEN ISO 9237 Textiles, Determination of the permeability of fabrics to air. • The Children’s Clothing (Hood Cords) Regulations 1976 No 2

Metal Components

• BSEN12472 Method for the simulation of wear and corrosion for the detection of nickel release from coated items. • EN1811 Reference test method for release of nickel from products intended to come into direct and prolonged contact

with the skin. • BSEN71 Part 3 (Migration of elements)

Nightwear

• The Nightwear Safety Regulations 1987. • BS5722 Flammability Performance for fabrics and fabric assemblies used in sleepwear and dressing gowns. • EN14878 Burning behaviour of children’s nightwear specification.

Sleep Bags

• BS8510 Child use and care articles - Safety of children’s sleep bags – Safety requirements and test methods. • BS 5335-1 1991 D.2 and BS 5335-2 2006 with modification laid out in BS 8510:2009 method for determination of

thermal resistance.

Sunsuits / Sun Hats

• BSEN13758 Parts 1&2 Textiles Solar UV protective properties Part 1: Method of test for apparel fabrics Part 2: Classification and marking of apparel.

• BS8466 Hats: protection against solar UVR Method of test and performance requirements / specifications.

Toys / Add -Ons (Including electronic parts in day wear and dress up, dress up accessories, key rings, soft toys)

• BSEN71 Part 1(Mechanical),Part 2 (Flammability), Part 3 (Migration of elements) Safety of Toys, Part 9 (Safety of Toys – Organic chemical compounds) • Toys (Safety) Regulations 1995 SI 204. • BSEN62115 Electric Toys Safety. • Draft Waste Management (Battery and Accumulator) Regulations 2008. • Waste Management (Battery and Accumulator) Directive 2006/66/EC • WEEE Disposal of Waste Electrical and Electronic Equipment. • RoHS Directive on the Restriction of certain Hazardous Substances. • EMC Electromagnetic Compatibility Regulations. • BSEN60825-1 Safety of Laser Products • The Violent Crime Reduction Act 2006 Regulations 2007 • Materials and Articles in contact with food (England) regulations 2005 S.I 898 • BS7272 (Part 1 & 2) Writing and Marking Instruments

Zips

• BS3084 Specification for slide fasteners. • BS7907 Clause 4 – 4.2 & 4.3 Ischemic Injuries

Marks & Spencer Internal Standards This section lists Marks & Spencer internal standards that have been drafted to support the delivery of safe product to our customer. These documents are updated regularly and are available on the Marks & Spencer Quality Standards Web Site.

• Animal Welfare Policy. • C99: Environmental, Chemical and Factory Minimum Standards for Dyeing, Printing, Finishing, Leather tanneries, Spinners &

Laundries of Clothing and Textiles. • Clothing and Home Textiles Test Methods (Colour). • Clothing performance Standards CS1- CS14. • Clothing Test Methods (Physical). • Critical Tolerance Chart Ref 014 • Due Diligence Code of Practice. • Infestation Policy. • Latex Guidelines. • Migration of Toxic Elements • Nickel Guidelines • QMS Factory requirements • QMS factory guidelines • PVC Guidelines. • Suffocation Hazard Assessment – Intertek RAM - see Dept Tech

Test Methods – specifically referred to in this manual • C61 Determination of Phthalates • C64 Determination of PVC • C65 Determination of Alkyl Phenols • FP55 Determination of strength of lace hole eyelet attachments • P5 Durability wash for garments and components • P53 Fibre Retention • P116 Nightwear Flammability • P117 Surface Flash Flame • P122 Strength of Buttons • P131 Pile Retention • P115 Security of Attachment of Accessories to garments (Age 4 years and above) • P115 A Security of attachment of poppers to garments (Age 4 years and above) • P115 B Test to Failure of Attachments of Accessories to garments (bows or other stitched on garment accessory)

(Age Under 4 Years) • P115 C Test to Failure of Attachments of Poppers to garments (Age Under 4 Years)

No Category Potential Hazard

Specification Tech Notes

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Battery Operated Components

• Aspiration • Burn – Chemical • Choking • Ingestion • Inhalation • Insertion • Over heating /Fire • Toxicity - chemical

Age: All Ages • Must comply with BS EN 62115 (2005) Electric Toys Safety.

(BS EN 50088 was withdrawn 01/01/2008 and will no longer be accepted).

• Certification of compliance to EN71 pt1where applicable • For use in Toys - Refer to the M&S Electronic Toys Standard on the

Quality Standards Website. • Certification of compliance to EMC requirements. • For use in Toys - Comply with the WEEE Directive. • For use in Toys - Components to be RoHS compliant. • Comply with New Directive 2006/66/EC for Batteries &

Accumulators and waste batteries & accumulators. • For Clothing - P5 Durability wash to be submitted at technical

evaluation stage in garment or panel form. Age: Under 4 Years • Allowed in this age group provided they are inaccessible

• Electrical components (including button cell batteries) shall not

be easily accessible (refer to BS EN 62115 for full details). • Battery operated components must be enclosed in a sealed unit

prior to attachment to the garment footwear or accessory • Directive 2006/66/EC for batteries & accumulators (including

button cells) – all batteries shall be marked with the Standard Battery logo (the crossed out wheelie bin) and where appropriate with the chemical symbol for the heavy metal concerned below it; if it contains more than 0.0005% Mercury (Hg), 0.002% Cadmium (Cd) or 0.004% Lead (Pb) by weight (Note: due to size restrictions button cell markings may be applied to the product label or packaging).

Battery logo Heavy metals Battery logo’s

• Refer to “Battery Directive 2006-66-EC Marking Requirements

and Warnings” on the M&S Quality Standards Website for full marking requirements and standard battery warnings (located under the Home folder).

• Standard disposal statement “DISPOSAL - This product contains batteries and electronics that may be harmful to the environment; they should not be discarded with normal household waste but taken to your local collection centre for recycling.”

No.

Category Potential Hazard Specification Tech Notes

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Beads

• Choking hazard • Ingestion • Inhalation • Insertion • Laceration • Toxicity-chemical

Age: All Ages • Beads must not have sharp, rough edges, burrs or ‘flash’ from the

molding process. • Shaped beads such as flower or star shapes must have smooth edges

and no sharp points • Coatings on beads must conform to ‘Migration of Toxic Elements’

section • P5 - Durability wash is required. Age: Under 4 years • Size/Type of bead must be agreed with the relevant technologist • Beads must be enclosed with a suitable fabric e.g. mesh so the beads

can not come out should they become loose. Or • Beads are permitted if they are not accessible e.g. threaded onto a

non open ended strap. In this case the strap should pass TTF to ensure it remains in place and the beads do not become loose. (Please refer to TTF/Pull test appendix)

Hand applied Beads: Thread: • Monofilament thread may not be used because of potential

laceration. How to Attach: • The needle must pass through the bead a minimum of three

times. • If beads are applied singly, double knot off after each bead. • If beads are attached in a group – knot off every third bead.

At Start: • Double knot two strands of thread together, stitch through fabric

to form a small stitch before applying bead. To finish: • Stitch through and double stitch, finish and knot. • Thread length - start and finish to be 3mm to 5mm.

For Quality : • Float length – maximum of 1cm • Thread end - after cutting 0.5cm to 1cm.

If applied to neck area – ensure neck stretch is checked. Please refer to Neck Stretch section.

No. Category Potential Hazard Specification Method of attachment

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Belts

• Choking • Entrapment • Laceration • Skin Irritation • Toxicity-chemical • Tripping

Age: All Ages • Please refer to TTF/Pull test appendix

Metal Components: • Must be non ferrous • To avoid rusting, metal components must be made of brass, or stainless

steel – specification reference 316L (a common type of surgical quality stainless steel), or Zamac ( zinc, aluminum, magnesium and copper alloy)

• Refer to Migration of Toxic Elements section Buckles, Keepers, Prongs, D Rings & Clasps

• Must be free from rough or sharp edges. • Prongs must be compatible to buckle size. ( see Figure 1)

Eyelets • Only rolled finish eyelets are permitted. Ensure that the eyelet is

correct depth suitable to the material to which it is applied. • Ensure the eyelet rolls at the back of the material. • Star clench back not permitted due to sharp edges.

Eyelets are not permitted on elastic belts. Studs • Star clench back not permitted due to sharp edges. • Studs are not permitted on elastic belts.

Age: Under 4 Years • Metal D rings / buckles must be fully welded into one piece. (see

Figure 2) • TTF (P115b) must be carried out on all small parts, e.g. prongs, studs • Where belt keepers are used they must be permanently attached by

stitching. Staples are not acceptable. Age: Over 4 Years • P115 must be carried out on all small parts, e.g. prongs, studs

PLEASE REFER to TTF / Pull Test Appendix Eyelets • Where pull test / TTF cannot be carried out , use Eyelet

attachment strength test, reference: M&S FP55, BS 5131:515D

XFigure 2

Figure 1 Prong should not extend past buckle edge

No. Category Potential Hazard Specification Tech Notes

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Bibs

• Laceration • Strangulation • Suffocation

Age: All ages • No side or back neck ties permitted. • Closing method must not be a continuous loop. • Closing method - To be joined either by press fastener, or touch and

close fastening e.g. Velcro®. • Plastic backed bibs must be tested to ensure they are not a Conforming

material* – Suffocation Hazard assessment- Intertek RAM may be specified by the technologist.

• P5 to be carried out on any plastic backed bibs to ensure they do not become brittle and break up, or disintegrate in wash /wear

• The construction of the closure must avoid irritation to the skin. • ‘*Conforming material’ – a material that seals round the mouth /

nose and inhibits or prevents breathing • Suffocation Hazard assessment - Intertek RAM may be required.

This can only be carried at ITS Chicago USA. In this case please, refer to department technologist for advice.


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Braces (Separate Braces)

• Entrapment • Laceration • Strangulation • Toxicity - chemical

Age: All Ages • Webbing must be woven to desired width. • Elastic must be latex free • Must be free of rough edges. • For metal component of braces please refer to Migration of Toxic

Elements • Please refer to TTF / Pull Test Appendix Age: Under 4 Years • Braces are not allowed under 4 years • Any D rings must be fully welded into one piece (see figure 2 Belts

section)

• Webbing must be securely stitched over D rings • ‘Rabbit ears’ must be bar tacked. • Must carry swing ticket warning ‘Not suitable for under 36

months’ For all label references please refer to the CLA website

No Category Potential Hazard Specification Tech Notes

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Buttons ( relating to any buttons that can be sewn onto a garment / product using thread)

• Choking • Ingestion • Inhalation • Insertion • Laceration • Projection • Toxicity-chemical

Age: All Ages • Buttons must withstand P122 • Machine Lockstitch only CHAIN STITCHING IS

NOT PERMITTED. • Must be free of injection mould ‘flash’ or rough

edges. • Buttons must not resemble food. • Do not attach spare buttons on Childrenswear. • Glass buttons not permitted. • PLEASE REFER to TTF / Pull Test Appendix Age: Under 4 Years • No Buttons to be attached to uneven surfaces. • No two part / *composite buttons permitted. (see

Figure 1) • “Pig nose” covered buttons are acceptable provided

they are fabric covered and have metal casings as holes, or where stitching secures all parts of the button to the garment (example, fig. 2)

• Toggle buttons (see figure 3) must be risk assessed for shape, catchments, and attachment hazard at design briefing stage.

• Hand stitch buttons NOT PERMITTED Age: 4 Years and Above • If used composite buttons must be clamped or glued

with epoxy resin adhesive, and withstand P5 Durability and P122 test requirements.

• Hand stitched buttons are permitted if they pass P115

• Please remember if you are applying the same button over different levels of thickness on the same garment, a TTF / Pull test will need to be submitted for each thickness. ( for example, a four layer placket and a two layer pocket) Fig. 1

Fig. 2

Fig. 3

*Composite: A button made up from more than one part. • To aid in security of attachment, whipping and heat sealing can be used on all

heavyweight fabrics / garments e.g. coats. • Any buttons/ toggles attached using cord or tape must be secured using bar

tacking. • Cut cords must be covered with a triangular piece of fabric (Sprat head) that are

sewn over the cord and stitched to the product. Sprat Head Diagram (these can also be fabric patches)

• Buttons made from polyester are preferred • It is recommended to avoid materials such as Acrylic, Polycarbonate and

polypropylene which are relatively weak and do not usually pass P122 test requirements.

No. Category Potential Hazard Specification Technical Notes

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Decorative Feathers

• Choking • Ingestion • Inhalation • Insertion • Laceration • Projection • Skin irritation • Toxicity – Pathogen

• See Kidswear Dress-up performance standard Age: Under 4 Years • Decorative feathers are not allowed under 4 years

Feathers • Feathers must be thoroughly washed and suitably processed to

the British hygiene and cleanliness requirements E.g. steam cleaned.

• Please refer to the Animal welfare policy on quality standard website


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Diamantes

• Choking • Inhalation • Ingestion • Insertion • Laceration • Toxicity -chemical

Age: All Ages • Diamante attachment to fabric type to be assessed at product

development stage. • Assess security using the P5 durability wash. • Diamantes are to be inspected for cracks, chips & blackened

edges prior to application • Diamantes must not have sharp, rough edges or burrs • Shaped diamantes such as stars must have smooth edges • Both ultra sonic & heat transfer methods of attachment are

acceptable • Big diamantes i.e. larger than 5mm must be sewn on (see

sequin/ bead section for sewing attachment guidelines) and meet P115 requirements.

• Acrylic stones should not be used as they do not react well to heat application.

Age: Under 4 Years • Diamantes can be used in this age group. Minimum size to be

used 2mm maximum size 3mm. • Diamantes attached to woven fabric, to be discussed with the

department technologist.

• Diamantes should not be attached directly over prints as this affects

the bonding of the diamante to the fabric. • Diamantes must not be attached on uneven surfaces, such as seams. • Nail head Diamantes – can also be called Rhinestones or Rhinestuds these can be made of metal and can be used • Coloured Diamantes are not as durable due to the films and backing

used. Please ensure they are tested independently of the clear diamantes if you are using both on the same garment.

• Diamantes need to be attached after industrial garment washing. • No spare diamantes to be supplied with the garment Labeling All Ages • Additional Care codes required • wash inside out • iron on reverse Age 4 Years and above • if the diamantes used are not as allowed for under 4 years category

then an additional disclaimer Label: K8A 483G stitched into the side seam adjacent to the care label.


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Direct Embroidery / Fusible Motifs and Badges

• Choking • Ingestion • Irritation in wear. • Laceration • Tourniquet • Toxicity • Toxicity - chemical

Age: All Ages • Soft interlining to be used on all embroideries which are in direct

contact with the skin to avoid irritation in wear. ( this depends on the location of the embroidery and should be discussed at development stage with department technologist )

• Thread ends can potentially become a tourniquet risk if over 2.5cm. For quality we specify thread ends/ loops on embroidery should not exceed 1cm.

Flocked, PU Printed or Welded Motifs applied by a high frequency welding

• The welded edges must be continuous, all contours to be as round as possible, and edge lines as wide as possible- to increase adhesion. These motif types are not dry-cleanable

Motifs/ Badges • Must not be applied by adhesive alone, and must be stitched all

round to ensure security of attachment. Badges • All edges must be sealed to prevent fraying. • Soft plastic badges must have groove line to allow for stitching.

Nightwear Kid’s nightwear containing embroideries, fusible motifs, and badges must comply with relevant nightwear regulations. • Direct embroidery motifs, embroidered fabrics, and fusible motifs

and backing fabric must all comply with the relevant flammability requirements

• Synthetic fibre threads must be used. • Backing fabric on direct embroidery must apply to the relevant

nightwear regulations e.g.100% polyester. Age: Under 4 years • Fusible motifs or badges should not be hand sewn on for this age

group as this could pose a choking hazard. • Welded motifs can be used – must pass P5 Durability test

• Consider irritation e.g. knees, elbows etc. • Special attention must be paid to flocking to ensure that safety

standards are met, formaldehyde free etc. • Design motifs on stretch fabric must be designed with breaks

in the pattern. This will avoid the breaking of thread when worn by the customer.

• Ensure any adhesives comply with C99. • To reduce sharpness of motif edges it is recommended to laser

cut or fold. • Novelty motives / badges – please refer to section on Liquid

Filled Products


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Dressing up & disguise costumes

• ALL RISKS

Age: All Ages • Refer to the Dress Up Performance standard – KDU standard • Refer to the Home safety manual where relevant for toys accessories

& add-ons • All product must be compliant to relevant parts of EN71 & must be

CE labeled • DHA must be carried out for all dress-up products by department /

qualified supplier technologist • Please refer to TTF / Pull Test Appendix Age: 3 Years and Under Any potential detachable items must meet TTF P115B requirements.

• Trousers with integral feet must include a slip resistant sole-

test method FP06. • Formaldehyde finishes are not permitted PU COATED

FABRICS should be durability tested to ensure they do not deteriorate or peel.

No. Category Potential Hazard Specification

Tech Notes

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Elastics

• Entrapment • Pinching • Skin Irritation • Tourniquet

Age: All Ages • Must be latex free • Where used in nightwear, must conform with relevant flammability

legislation

• Elastics can reduce blood flow if designed too tight. Ensure

conformance to relaxed and extended garment measurements stated on the size chart

• Where elastic is used in garment necklines it must meet minimum neck stretch measurements refer to 014 Critical Tolerances Chart to be found in appendix.

• Must be compliant with formaldehyde restricted levels specified in C99.


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Faux Fur pile fabrics & trims.

• Perceived choking

and aspiration • Inhalation

Age: All Ages • Real animal fur is not permitted.

• Printed furs (e.g. discharge tips) - solvent-free printing systems should be used wherever possible and the finished product must comply with C99 requirements.

• Where cellulosic and cellulosic rich faux furs are used these should be tested to surface Flash Flame P117

Age: Under 12 Months • Toys - Pile length to be maximum 3mm • Garments - Pile length maximum 18mm. Age: 12 months to 4 Years • Trims – Pile length 25mm • Garments - Pile length maximum 20mm. Age: 4 Years and Above • No restrictions on pile length.

• Under 4 years - Boa construction must be used as it is more

secure • 4 Years and above - Sliver knit constructions are permitted

where agreed with the Departmental Technologist and must be polished to remove loose fibre.

• Loose pile can also be improved by back coating or heat bonding the fabric – the coating used must meet C99 requirements and be latex free

Development • Pile retention to be discussed & agreed with Department

Technologist. P5 durability wash to be submitted in garment or panel form or 5 x label wash with negligible loss of pile

• Note: Methods P131 Pile Retention, & P53 Fibre Shedding may be used as guides if required

• Repeated label washes can be carried out in house Labeling

• Our animal welfare policy for clothing states that- For clothing - Synthetic materials made to look like animal products should be clearly labeled as such to avoid unnecessary offence or confusion.

To comply with this any product containing faux fur must be labeled as such on the care label using Z 305 Code


13

Flammability – All Garments excluding nightwear and Dress up

• Burns

Age: All Ages Labeling

All Kids’ Daywear Clothing must have a Fire Warning (FW) label as part of the front of the permanent sewn in care label – please note product exceptions in the appendix

• The ‘FW’ wording to read, ‘KEEP AWAY FROM FIRE’ (Upper

Case 10 point red lettering). • Flash flame testing may be required on certain products please refer

to flash flame section

• Please refer to the Childrenswear label position on the Quality

Standards Website • Please also refer to Kids clothing Flammability Labeling Policy

for products and exceptions. • Pram shoes, bootees & slippers must carry the FW wording.


14

Flammability - Nightwear

• Burns

Age: Age 3 months and Above: • PYJAMAS, ALL IN ONES AND WALK-IN SLEEPERS – must meet the

requirements of EN14878 minimum Class B • NIGHTDRESSES – must meet the requirements of BS5722, as

specified in clauses 3.1.1 and 3.2.1. • DRESSING GOWNS AND BATHROBES (except those made of

100% cotton terry toweling) - must meet the requirements of BS5722, as specified in clauses 3.1.1 and 3.2.1.

• Bathrobes Made of 100% Cotton Terry Towelling – must meet the

requirements of EN14878 Minimum Class A • Refer to the requirements for Flash Flame – M&S test method P117

• Flammability performance relates to both the individual base

fabric and as assembled as a complete garment. Please refer to Nightwear Flammability Appendix VI doc. for specific testing details

• Please also refer to Appendix for specific labeling requirements by product type including fire warnings

• Where stricter flammability requirements exist for nightdresses, dressing gowns etc, all components including threads, trimmings labels etc will be required to meet the flammability performance.

• Specific design restrictions are also detailed in the nightwear appendix. BS5722 and EN14878

• Flame retardant finishes are not permitted unless they comply with C99, Toxicology of flame retardant as specified in EN14878 and will perform for the life of the garment.

• 100% Cotton terry toweling bathrobes can not be sold as nightwear


15

Flash Flame

• Burns

Age: All Ages FABRICS WHERE ‘FLASH FLAME’ TEST APPLIES • Products made from 100% cellulosic or cellulosic rich fabric / yarns

(over 55% content) with a raised hairy surface should be assessed using test method M&S reference P117.

• Refer to Garment Safety standards S4 • Refer also to specific nightwear flammability requirements • Where cellulosic and cellulosic rich faux furs are used as

trims, these should also be tested

No

Category Potential Hazard Specification Tech Notes

16

Float Lengths Includes socks / tights / gloves / and garments with integral feet.

• Laceration • Ripping off

finger and toe nails

• Tourniquet & restriction of blood circulation

Age: Babywear • Baby bootees and garments with integral feet, all over-runs of seams must be at

the back of the foot Age: Under 3 years Hosiery – Babies 0 to Age 3

Floats and Long Ends Floats Leg Float Foot Long Ends Toe Seam Design Standards 1.0cm 1.0cm 2.5cm 1.0cm Manufacturing tolerance Nil Nil Nil Nil

Gloves – Babies 0 to Age 3

Floats and Long Ends Floats Long Ends Design Standards 1.0cm 2.5cm Manufacturing tolerance Nil Nil

Knitwear – Babies 0 to Age 3

Floats and Long Ends Floats – Main

Body Floats - Sleeves

& Legs Design Standards 2.0cm 1.0cm Manufacturing tolerance Nil Nil

Age: 3 years and Above Hosiery – Children – Age 3 Upwards

Floats and Long Ends Floats Leg Float Foot Long Ends Toe Seam Design Standards 2.5cm 2.5cm 3.0cm 1.0cm Manufacturing tolerance 1.5cm Nil 1.0cm Nil

Gloves – Children – Age 3 Upwards

Floats and Long Ends Floats Long Ends Design Standards 2.5cm 3.0cm Manufacturing tolerance Nil 1.0cml

Knitwear – Children – Age 3 Upwards

Floats and Long Ends Floats – Main

Body Floats - Sleeves

& Legs Design Standards 2.5cm 2.5cm Manufacturing tolerance 1.5cm Nil

Float: • A thread, which is attached at both ends & lies on the

surface of a fabric, forming a loop Long End: • An untrimmed thread end, attached at one side. • Products must be examined inside and out to ensure no

threads or floats are left inside. • Coverage of floats – where technically possible – for

example in mittens, it is recommended to line the side of the product where the floats are exposed, to minimise the risk of catchment in wear

• In knitwear & specifically jacquard designs, floats above the specified tolerance must be discussed with the departmental technologist to eliminate risk.

• Refer to beads, direct motifs and sequins for sewing float guidelines.

Knitwear • Colour changes on stripe panel may result in vertical loops

at the panel’s edge. If these are longer than the specified float length, they must be trimmed in line with Marks and Spencer’s quality requirements.


17

Hoods and Headwear

• Burns • Entrapment • Strangulation • Suffocation • Restriction of hearing • Restriction of sight

Age: All Ages Hoods & Headwear • Please refer to Cords & Drawstrings section and Appendix • Wadded hoods must be assessed for flammability P142. • Hoods should be designed to minimise the risk of entrapment. • Headwear should be designed to minimise any restriction of hearing

or vision by the wearer. Hat / Cap Functional Ties • A quick release mechanism such as a press fastening or touch and

close fastening such as Velcro® is required for under-chin closures. Hat / Cap Decorative Ties • Strings from hat area need to be individually Risk Assessed as a

potential strangulation hazard if long enough to tie. Dress Up Headwear: • Refer to Dress Up section for flammability requirements EN 71 part 2 Age: 12 Months and Under Daywear Hoods • Rain coats for infants with hoods must be assessed on a case by case

basis for suffocation. • Hoods must be assessed for Air Permeability Either (1) Air

permeability BSEN IS0 9327 and achieve result of greater than 10 litres of air, submitted at technical evaluation stage. Or (2) Suffocation Hazard Assessment – Intertek RAM Test Method

Age: 3 years and Under Nightwear Hoods: • Hoods are not permitted on garments designed for sleeping.

• Construction of any closures must avoid irritation to the skin. • When designing Baby Headwear ensure consideration is

taken of softness of babies’ heads • Increasing the thickness and bending stiffness of the hood

material can reduce the suffocation hazard. • Linings can help reduce the risk of the fabric conforming to

the face and therefore resulting suffocation • Plastic inserts to stiffen the peak, should have round corners

for comfort. • Suffocation Hazard Assessment test may be required. This

can only be carried at ITS Chicago USA. In this case please, refer to department technologist for advice.


18

Hooks and Eyes and Hooks and Bars

• Choking • Ingestion • Inhalation • Insertion • Laceration • Toxicity - chemical

Age: All Ages • Please refer to TTF / Pull Test Appendix Age: Under 4 years • Hooks and Eyes and Hooks and Bars are not permitted.

No. Category

Potential Hazard Specification Tech Notes

19

Lace crochet open constructions

• Entrapment • Laceration • Tourniquet • Toxicity -chemical

Age: All Ages All Laces & Crochet • Monofilament yarns not permitted Nightwear • Lace on any nightwear must comply with relevant Nightwear

(Safety) Regulations. See ‘Flammability – Nightwear’ section of this document.

(Note: Cellulosics generally do not meet the regulations.) Age: 12 Months and Under • Due to the size of Babies fingers Crochet and lace stitch

knitwear hole size to be Under 7.0mm or over 12mm in diameter

• Lace containing metalised fibres e.g. lurex® can be an irritant when in

direct contact with the skin ensure a soft version is used and it is checked through wearer trial

• Free and released Formaldehyde must meet C99 standards C18 B & C • Rigid Laces can affect stretch when applied to knitted fabrics - Ensure

Neck stretch is checked and cuff movement is assessed

No. Category


20

LED Lights (Light Emitting Diode)

• Damage to eyesight

Age: All Ages • Obtain specification from supplier to confirm the class of LED; this

determines the strength of the beam to prevent any potential damage to eyes (Only Class 1 LED’s are permitted in children’s clothes, shoes or toys.

• Test to BS EN 60825 pt1. Safety of Laser Products. • Refer to the front section of this manual for generic standard

requirements.

• Valid Certification required verifying Class 1. • It is good practice to ensure that LED’s are tested in position

within the product to take account of any lenses, covers or filters which may affect the strength of light emitted.

• Warning text in respect of LED’s is not required for Class 1.

No. Category


21

Liquid Filled Products (e.g. Badges/ Teethers)

• Choking • Laceration • Toxicity -

Microbiological

Age: All Ages • New reports required if composition of contents change. • Toxicological assessment on liquid formulation required. The

assessment must not show any Hazard. • Water treatment plant to be audited to ensure microbiologically

safe by a qualified microbiologist. • Audit process and controls documentation to be recorded and

retained by the factory i.e. checks on purification. • Batch microbiological testing required frequency to be agreed with

M&S department technologist and is dependant on batch size/ quantities.

• CAS/ EINECIS number/ listing to be recorded in technical file. • All liquid filled products must be traceable to batch production

records. • Factory cleanliness is key to prevent cross contamination of the

liquid and must be demonstrated to M&S Regional Office Technology team.

Age: Under 4 Years Acceptable if passes: • Bite and tear test ASTM F963 -03. • If smaller than the 1.5 gauge, must pass TTF P115B.

• Please refer to TTF / Pull Test Appendix • Safety data sheet must be completed and submitted prior to

contract seal. • MSDS (Material Safety Data Sheet) to be uploaded onto

Contracts.COM (CMS) and retained in product technical file. • Random checks on each process batch required. • Checks on purification system to be performed and recorded

daily. • Min 3yrs planned maintenance to be in place for purification

system. • Toxicity test on liquid to be completed on an annual basis. • The security of enclosure to which liquid is contained should be

designed to prevent possible leakage and avoid potential customer complaints over perceived hazard of ingestion (consider seam strength/ edge sharpness/ product integrity).

No. Category


22

Magnets

• Aspiration/ Inhalation • Choking • Ingestion • Insertion

CLOTHING FOOTWEAR & ACCESSORIES • Magnets are NOT permitted TOYS / NON CLOTHING ADD ONS Age: All Ages • No loose Neodymium or similar strong magnets are to be used which

can fit entirely within the small parts cylinder as specified under EN71 pt1.

• Magnets must be completely enclosed or embedded within the toy or garment.

• Must be designed to avoid the heart/ chest area when worn. • Suitable in-line production checks should be agreed to check security

of attachment. Records to be recorded and made available upon request.

• Magnets retained by glue or ultra-sonic welding are not allowed unless retained by a secondary method.

• Torque and tension, drop and impact tests required as per EN71 pt1. Please note: amendments to EN71 due 2009 will include requirements for magnets which will need to be adhered to.

• TTF testing required. Age: Under 4 Years • Magnets not permitted. • Children’s Shoes containing magnets are excluded from the above rule

provided an appropriate risk assessment has been completed by a qualified person.

• Magnets have become increasingly powerful and now pose a

higher risk of serious accidents than in the past. When more than one magnet is swallowed, the magnets can attract each other and may cause intestinal perforation, infection or blockage, which can be fatal. Inhalation of magnets can also cause serious injuries, and aspiration into the lungs requires immediate surgery.

• A strong magnet can affect the performance of a pacemaker or a defibrillator, so strength must be determined as the minimum required for functionality and agreed with department technologist at development stage.

• Determine the strength, or Gauss (G), of the magnet, and ensure it is kept to a minimum.

• Note that the strength of a magnetic field is measured in units of Gauss (G).

• Ensure warning placed on garment giving caregivers awareness of potential hazard to consumers with pacemakers or defibrillators.

• Enclosed magnet warning “Warning: Magnets have been safely enclosed within this product. In the event of the product becoming damaged and the magnets being released, ensure that the product and magnets are disposed of safely to avoid potential serious injury.”

No. Category Potential Hazard Specification Technical notes

23 Metal components - Press fasteners Stud buttons, Rivets, Eyelets, Strap adjusters.

• Choking • Ingestion • Inhalation • Insertion • Laceration • Projection • Toxicity - chemical

Age: All Ages PRODUCT REQUIREMENTS:

• For metal fasteners and eyelets the gauge of the brass strip must be minimum 0.37mm on the drawn barrel.

• Prong fasteners – rings must be made from brass, and a minimum strip thickness of 0.5mm. This reduces the risk of the prongs cracking.

• Steel must not be used as it can rust. • Refer to Migration of Toxic Elements section • Must be free of rough edges. • Roll setting eyelets (as opposed to split setting eyelets) must be used on

all products. • When sourcing components refer to approved component list.

APPLICATION: • For stud buttons, woven fabrics should be pre-punched, and knitted

fabrics should be ‘bodge’ (this avoids the separation of yarns) pierced to ensure successful application.

• Must not be applied to uneven surfaces. E.g. half on half off the seam allowance.

• Knitted fabrics; use prong fasteners to prevent laddering. Post fasteners must not be used on knitted fabrics.

In Line checking: • Check the machine has set up in accordance with the pinch testing and

this should be done every two hours • Pull Tests to be carried out every two hours • A manual check must be carried out on every garment to confirm that

the popper prongs have all been pierced into the base fabric – and none are left protruding (See Figure 1)

• All garments with feet / pockets or other areas where poppers could be found need to be turned inside out to check that no loose objects are trapped inside.

• PLEASE REFER to TTF / Pull Test Appendix • REFER TO INLINE TESTING PROCEDURES Figure 1:

MACHINERY: • Machine operators must be trained and certified by the

component supplier. • Manufacturer’s compatible dies must be used. • Pinch settings and machine sign off must be obtained from the

component supplier. • TTF/ P115a must be passed before production starts. Where possible Fully Automatic Machinery is preferred • Manually operated machinery which solely is reliant on the

operator’s foot or hand pressure is not acceptable. • Semi automatic manually foot or hand operated machinery

allowed provided that it incorporates a non return ratchet mechanism. This ensures the required level of pressure is applied. It must be regulated to ensure machine stops if pressure falls below required level for operation.

• Fully automatic machinery is allowed provided that it is regulated to ensure machine stops if pressure falls below required level for operation.

FRONT BACK

XProngs bent back can be sharp. Not acceptable

No. Category Potential Hazard Specification Technical notes

23

(Cont) Metal components - Press fasteners Stud buttons, Rivets, Eyelets, Strap adjusters

(Cont) • Choking • Ingestion • Inhalation • Insertion • Laceration • Projection • Toxicity - chemical

Age: Under 4 Years • Rhinestones only permitted if fully encased in component (See Figure

2) • Rivets must be chosen that can be tested for TFF P115C. Any

exceptions to this must be agreed by the department Technologist prior to purchase.

• Brace clips and strap adjusters for straps must be one piece welded (See figure 3)

Figure 2: Figure 3:

Fully welded, one piece metal. Application notes: Some fabrics may need reinforcing to attach metal components securely. For example, knitted fabrics require woven bias cut interlining to stabilise the base.

Rhinestone is enclosed in metal and held by metal ridge

No. Category

Potential Hazard


24 Migration of Toxic Elements

• Toxicity - Chemical

Age: All Ages Migration of Toxic Elements: Fabrics ,Tanneries, Print Houses and Laundries

• Must comply to M&S C99 requirements

Toys • Must comply to EN71 part 3 & 9

Metal componentry • Must comply to the following levels:

Antimony ( Sb) < 60ppm Arsenic (AS) < 25ppm Barium (Ba) < 500ppm Cadmium (Cd) < 50ppm Chromium (Cr) < 25ppm Lead (Pb) < 10ppm Mercury (Hg) < 40ppm Selenium (Se) < 400ppm

Nickel Free • All our metal componentry, regardless of contact with the skin, must

be specified Nickel Free and must pass EN 1811 Nickel requirements Leather • Must comply to C99 Dimethyl Fumarate (DMF) • This is a fungicide used to prevent mold forming in leather • DMF is banned from use in all Kidswear products

• < Less than • Metal componentry - Test as EN71 and apply our standards • Chrome in all Leather products

Chrome is present in most tanned leathers Chrome vi is banned Chrome iii is permitted

• Silica Gel has been shown to occasionally contain DMF. Silica Gel sachets are prohibited in any kidswear products.

No. Category

Potential Hazard


25 Natural Materials for Accessories & componentry

• Laceration

Age: Under 4 years • Natural products can vary in strength and can split.

Due to the nature of these products the following raw materials Must Not be used:

Wood Coconut Mother of Pearl Shells

Age: 4 years and above • Discuss material with Dept Technologist prior to purchase.

No. Category

Potential Hazard


26 Necklaces • Laceration

Age: Under 3 years • Not permitted

Age: 3 years and above • Necklaces must have loose jump rings (split rings). • Break Strength max 2.5N

• Oval jump rings are preferred with split at the top Diag:

• For quality purposes break strength should be higher than

2.0N

X

No. Category

Potential Hazard


27 Neck Stretch • General Distress • Laceration

• The following requirements are to be adhered to: Age Minimum neck

stretch 0- 24months 56cm 14m -10years 58cm 10yrs - 14yrs 60cm over 14 years 62cm

• Perspex templates are available to test samples and end of line – contact RO

No. Category Potential Hazard Specification Method of attachment

28 Neck Ties • Strangulation Age: 5 Years and Under • Conventional neck ties are not suitable for children under the age of

5 years. • Clip on, or touch and close fastenings, e.g. Velcro®, to be used for

neckties for children 5 years or under. (as Figure 1b) • Touch and close fastenings should be quick release to aid this the

hook side should be cut shorter than the loop side. • A low strength touch and close fastening is recommended. • Touch and close fastening edges should be rounded off to eliminate

sharp edges and corners. Age: Over 5 Years • Traditional neck ties permitted (as Figure 1a) Garments should be labeled ‘Not suitable for under 5 years’

Figure 1:

Touch and close fastener required at centre back neck One piece tie

a) b)

No. Category Potential Hazard Specification

Tech Notes

29

Plastic bags e.g. over bags intended for sale with the product in M&S Stores

• Suffocation • Thickness of permanent polyester bags to be greater than 38.0 microns.

• Bags made of flexible plastic with an opening perimeter of greater than 350mm must not have a drawstring or cord as a means of closing

• New products which require plastic bag packaging when in store should be developed in consultation with the departmental technologist & packaging developer.

• Appropriate warnings to be applied depending on end use. • Please refer to GM Terms & Conditions for transit packaging

including overbags.

No. Category Potential Hazard

Specification

Tech Notes

30

Pom-Poms / Bobbles / Tassels and Fringing

• Choking • Entrapment • Ingestion • Inhalation • Insertion • Strangulation • Tourniquet

Please refer to Cords & Drawstring appendix • Please refer to TTF / Pull Test Appendix • All types of Pom Poms must be risk assessed for entrapment and strangulation Traditional Pom Poms (see figure 1) Age: Over 4 Years • Traditional Pom Poms are allowed Age: Under 4 Years • No Traditional Pom Poms Other Pom Poms -Stuffed (figure 2) / Fabric Strips Age: All Ages • Fringing length to be agreed with Departmental Technologist to individually Risk Assess –but Note length should never exceed 14cm. Age: Under 4 Years • Small soft decorative pom-poms (as Figure 2 not traditional type as figure1) directly attached, are allowed, provided P115B requirements are met. • Large Stuffed Pom Poms / bobbles on a string must: (1) If soft and squashable meet 50cc plush criteria, or (2) If round and hard meet the 44.0mm gauge. And therefore not require TTF Testing for Safety Tassels and Fringing Age: Under 4 Years • Like Pom-Poms, threads can be removed if pulled. These products are

only suitable for use if it is possible to produce them with threads that are not removable and they meet the requirements of P115B.

• PLEASE REFER to TTF / Pull Test Appendix Figure 1 Figure.2

• When used, pom-poms must be attached by means of a 4

hole lockstitch button sew attach, and thread ends must not be able to be pulled out.

• Pom Poms can be lock stitched at the centre position during construction for extra security

• The attachment of Pom Poms, tassels etc must not cause a potential entrapment hazard, for example when attached as an embellishment to a decorative or functional cord. Please refer to BS EN14682

•


Specification

Technical Notes

31 Prints – (transfers, panel prints, all over continuous prints – includes backing materials)

• Choking hazard – prints peeling off

• Toxicity - Chemical

Age: All Ages

• All inks and backing materials should be PVC free where technically and commercially viable – any exceptions to be discussed with Departmental Technologist at development stage.

• Phthalates & APEO’s are not permitted according to C99.

• Print house and all printing inks and binders used need to conform to M&S C99 requirements

• Some printing methods can leave a residue of formaldehyde on the fabric. Ultra-low formaldehyde binders should always be used.

• No Formaldehyde is permitted in Babywear or Intimate apparel

• Solvent-free printing systems should be used wherever possible and no residual solvent must remain on the garment

• Plastisol prints covering a large area of the garment can cause issues with flammability - refer to Flammability of nightwear section for more details

• Transfer prints should be applied according to the manufacturers recommendations and transfer press calibrated and checked regularly to ensure optimum fusing conditions

• Test for Qualitative determination of PVC - C64 – QUALITATIVE (BELSTEIN TEST) then/or FTIR for confirmation (Fourier Transform Infa-Red Spectroscopy)

• Test for determination of Phthalates - C61 Solvent Extraction and GCMS (Gas Chromatography/Mass Spectrometry)

• Durability test on transfer prints should be carried out during production to ensure there is no peeling or cracking on the surface.

• Transfer prints applied to pile fabrics i.e. Velour should be assessed to P5 at product development stage


Specification

Tech Notes

32

Rouleau Loops

• Entrapment • Tourniquet

Age: All Ages Rouleau Loops • To avoid entrapment, the loop should have an opening length

measured as circumference. Maximum – 7cm.

No.

Product category

Potential Hazard

Specification

Tech Notes

33 Safe in the Sun Garments and Hats

• Burn Age: All Ages • Garment styling: Garments for the top half of the body must fit from

the nape of the neck down to at least the hip level, and the arms covered to 3/4 of the upper arm below the elbow. Bottoms must cover from waist to sit below knee bone.

Testing

• Fabrics and garments needs to comply with BS EN 13758 parts 1&2. Hats need to comply with BS 8466 (2006).

• At development stage all prints and colour ways need to be tested to BSEN13758 part 1 and comply with BSEN13758 part 2. I.e. to pass the fabric results must show UVPF values larger than 40, and the average UV-A transmission to be less than 5%.

• At bulk garment stage every stroke number must be tested independently to ensure compliance with BSEN 13758:2.

Labeling

• All safe in the sun product must have permanent wording on the care label for the garment AND hat, even if sold together.

• Suit care labels need to have the reference; 'conforms to EN13758-2 2003 UPF40+' in addition to 'KEEP AWAY FROM FIRE' and care code ref TC16 B.

• Hat care labels must have the reference; 'this hat conforms to BS8466' in addition to 'KEEP AWAY FROM FIRE' and care code ref TC16 B.

No. Category

Potential Hazard


34

Scarves

• Entrapment • Strangulation

Under 18 Months • No traditional Scarves Permitted • A Safe Scarf – that can not be tied around the neck and is fastened

with Velcro ®is permitted at the following lengths: 6-12 Months A Safe Scarf construction permitted with max length 45cm 12 – 18 Months A Safe Scarf construction permitted with max length 50cm

• Touch and close fastening edges should be rounded off to eliminate sharp edges and corners.

Over 18 Months • The following Maximum Length requirements are to be adhered to:

18 Months 4 Years 60cm 4-6 Years 90cm 6-8 Years 100cm 8-10 Years 125cm 10-12 Years 140cm 12-14 Years 155cm

• The maximum lengths must include any tassels or

attachments at the end of the scarf. • Tassels should not exceed 14cm • Pockets are allowed on scarves as long as a risk assessment

has been carried out. Only patch pockets should be applied reduce the entrapment risk.


35

Sequins • Aspiration • Choking, • Ingestion • Inhalation • Insertion • Laceration • Skin Irritation. • Toxicity - Chemical

Age: All Ages • Sequins must not have sharp, rough edges or burrs. • Must be free of mould ‘flash’ • Sequins must be Phthalate and APEO free e.g. made of Polyester Age: Under 4 years • Machine attach only • Maximum Diameter 5mm • Sequins must be round, flat and with smooth edges, and have a

centre punched hole. • Strip sequins on a string not allowed Age: 4 years and Above • Hand applied sequins are permissible if application guidelines are

followed. • Shaped sequins such as stars, must have smooth edges • Strips of sequins to be attached by lockstitch machine – bar tack start

and finish.

• P5 – Durability wash must be carried out before contract seal. • No Spare sequins to be supplied with the garment Machine attach Sequins: • Thread: Monofilament of a minimum of 80denier may be used

to keep lustre of the sequin, but if used must be used in combination with a fusing backing to avoid direct contact with skin.

• Stitching must be secure to ensure that none of the monofilament comes unraveled by carrying out a ‘D’ wash at first production and carried out weekly during production. These records must be kept.

• Stitch Type: Lockstitch Attachment: Age: Under 4 Years - 4 double stitch formation passing through the centre of the sequin Age: 4 Years and Above – Any stitch formation permitted

Hand Attach Sequins – Age 4 years and Above • Thread: Embroidery/General sewing thread ticket 120. • If applied singly, double knot off after each sequin • If attached in a group - knot off every third sequin • ‘’Knot off’’ – knot thread and cut off At Start: • Double knot 2 strands of thread together, stitch through fabric

to form a small stitch prior to applying bead. • To finish: • Stitch through and double stitch finish and knot • Thread length start and finish to be 3mm to 5mm. • Float length – maximum of 1cm, length after cutting 0.5cm to

1cm. Strips of Sequins: • The stitch run where possible, must start and finish in a seam True Knitwear • Must be attached with Embroidery / general sewing thread.

(as monofilament will cut the yarn) • If applied to neck area – neck stretch must be unaffected.

No. Category Potential Risk Specification Tech Notes

36

Silica Gel

• Choking • Toxicity - Chemical

Silica Gel is banned in Kidswear

• Silica Gel is primarily used in moisture re-movement in transit

No. Category Potential Risk Specification Tech Notes

37

Sleep Bags - for use in a cot

• Entrapment • Flammability • Over Heating

• Flammability must conform to BS EN 14878 • M&S max Tog requirement Tog 3.5 tested to BS 5335 as defined in

BS 8510 • To ensure no Entrapment of body into the bag

Up to 6 months - neck opening must be between 280 – 320mm 6 months upwards - neck opening must be 355 – 395mm

• Dimensional Stability – Length and width change must not exceed +/- 5% when tested to care label instructions

• Label requirements - compliance to BS 8510:2009 must be displayed on the permanent care label

• Specific Instruction need to be displayed on the Swing Ticket this must be signed off by the Departmental Technologist

No.

Category

Potential Hazard

Specification

Tech Notes

38

Sound Nodules/ Noise Levels

• Damage to hearing

Age: All Ages • Must comply with acoustic requirements in EN71 part 1. • Must comply with Electro Magnetic Compatibility (EMC) regs. • Refer also to ‘Battery Operated Components’ section in this

document for compatibility & labeling Age: Under 4 years • Allowed in this age group provided they are permanently attached

and are inaccessible

• Certification of compliance to EN71 part 1 (clause 4.20 Acoustics).

• Use an appropriate warning: “Do not place close to the ear, misuse may damage hearing”.

• D wash to be submitted at contract seals stage • Product to be CE marked for EMC


39 Swim Short Mesh Liner Fabric for Boys

• Entrapment • Laceration

Age: All Ages

• Holes in mesh need to be smaller than 1.5mm in diameter to avoid entrapment of skin.

• Mesh fabric to be soft handle. Agreement of handle should be gained from the M+S Departmental Fabric Technologist.

• Avoiding skin entrapment is a new requirement into BS 7907


40 Toys • ALL Age: All Ages • Must comply with EN 71 parts 1 to 11 as required. • Must comply with all other relevant standards – see this document. • Refer to relevant Toy Standards in Home Safety Manual on Quality

Standards website. • Consult with relevant M&S Technologist for any add on

products, give-always, soft toys, key rings or other child appealing items.

• Please refer to TTF / Pull Test Appendix Pens Writing and Marking Instruments • Sufficient ventilation must be allowed in pen tops ,closures

and caps to avoid asphyxiation refer to BS 7272 part 1&2

• Ensure appropriate warnings as specified in EN71 parts 1,2,3 inc. age specific warnings.

• Refer to M&S approved standard warnings for toys • Note: EN71 testing requirements are different for under 3’s

and over 3’s age group. Ensure testing is performed appropriate to the intended age group. If the item is intended for over 3’s but you feel it may appeal to under 3’s then test to under 3’s as a precaution and consult with relevant toy technologist.

• Note: M&S small parts criteria differs from those specified in EN71, refer to Toy standards in the Homeware Safety Manual. Small parts must meet M&S gauge criteria unless agreed with M&S toy Technologist in exceptional circumstances.

Labeling • All Toys must be tested to the relevant sections of EN71

and CE labelled in accordance with EN71 part 6

• Those Toys not suitable for Under 3 Years must carry an additional warning to state this

No.

Category

Potential Hazard

Specification

Tech Notes

41 Waddings and Quilted Waddings Inc Feather & Down

• Laceration • Projection • Suffocation • Toxicity – Chemical • Toxicity - Pathogen.

(Refer to animal infestation policy.

Age: All Ages • Synthetic Wadding must be made from 100% low melt polyester.

This includes silicon finished polyester balls. • Resin treated waddings not permitted. • Nightwear garments must comply with Nightwear (Safety)

Regulations. 1985. Age: 12 months and under • Feather and Down are not to be used in this age group due to

potential over heating Wadded Hoods • Garments with wadded hoods for infants must be assessed on a case

by case basis for suffocation. • Hoods must be assessed for Air Permeability Either (1) Air

permeability BSENISO 9327 and achieve result of greater than 10 litres of air, submitted at technical evaluation stage.

Or (2) Suffocation Hazard Assessment – Intertek RAM Test Method Age: Under 4 years • No quill to be used in any Feather and Down

Testing • Waddings in Nightwear – to be assessed and evaluated for tog

rating BS 4745 at development stage. • Baby sleep bags – see section 37 • C18 B & C: Determination of free and released

Formaldehyde, submitted at technical evaluation stage. • Migration of fibre from wadding must pass P5 test. • To prevent fibre migration; wadding can be heat bonded,

outer fabrics can be chintzed on the inner surface or a scrim can be used on the wadding.

• Seams must have sufficient bite in order to reduce seam failure and the exposure of fillings.

• We recommend that Silicon finished Polyester Balls are double bagged to prevent migration.

• Suffocation Hazard Assessment test may be required. This can only be carried at ITS Chicago USA. In this case please, refer to department technologist for advice.

Feathers and Down • Feather and down must be thoroughly washed and suitably

processed to the British hygiene and cleanliness requirements E.g. steam cleaned. Also to be double bagged to prevent migration.

• Please refer to the Animal welfare policy for down wadding on quality standard website

No.

Category

Potential Hazard

Specification

Tech Notes

42 Washed Garments - that use Stones or Sand.

• Choking hazard • Ingestion • Inhalation • Insertion

Age: All Ages • Sand must be free from aluminum chips to ensure that metal

detection is possible. • Where there are attached components TTF must be tested after

garment washing • If mock ups are used to test componentry , they must be washed Age: Under 4 Years • Sand or Stones not permitted on garments with any pockets or areas

where stones/Sand can be entrapped.

All ages • Apply all componentry after washing. • Adequate rinse cycles must be used to remove/neutralise

residual chemicals including wash chemicals and enzymes. • Ensure for all chemicals used C99 is adhered to. Ensure Safety

data sheets are available. 4 Years and Above • Where stones and sand are used all pockets must be tacked

closed before washing, and all garments 100% inspected for loose stones and/or sand.

No Category Potential Hazard Specification Technical notes

43

Zips

• Choking • Inhalation • Injection • Insertion • Laceration • Penile entrapment • Toxicity - chemical

Age: All Ages • Zip supplier must be informed that it is an M&S Kidswear order • Must be free of rough edges. • Decorative pullers should be risk assessed, and where appropriate a design hazard assessment

conducted. • Polyester zip tapes should be used for greater strength. • Zip puller length – refer to Cords and Drawstring appendix Zips must be manufactured to set lengths. Continuous rolls of nylon coil zips not acceptable. • Please refer to TTF / Pull Test Appendix

Top and bottom stops • Must not be claw type. Fig 2 (see technical notes) • D Stops, and injection molded or welded top stops, must be used. • Cut coil ends must not protrude above the top stop. • Open end zips must have a top stop to retain the slider. Age: Under 4 years • Metal Zips not allowed. • No metal top stops • Bottom stop can be metal provided they are ‘H’ type • Sliders and pullers can be metal, provided they meet the criteria in ‘ALL’ section above. • Plastic molded zips preferred. • Coil zips only allowed when zip will not be in direct contact with the body. • Zip guards to be used to avoid entrapment when zipper is directly in contact with skin –

especially in the neck area • Ideally Zip puller should be Direct Attachment (one-piece) Pullers. Any Indirect Attachment

(two-piece) Pullers MUST be TTF tested and Zip supplier to confirm suitability for M&S Kidswear production before order placed

• TTF (P115b) on zip puller submitted at contract seal stages - this test is carried out by the zip manufacturer.

• Material or add-on pullers TTF (P115b) required, this is to be carried out by the garment manufacturer. This is in addition to the zip puller TTF above.

• Wadded fabric zip pullers need to be double bagged and assessed by the departmental technologist at development stage.

BOYS FLY OPENINGS Age: 5 Years and Under • Functioning zips on boys fly openings are not allowed. • Mock openings with an elasticated waistband, press stud, or button fly’s should be used as

alternatives. (Code of practice requirement BS7907) Age: 6 Years and Above • When allowed, zips can be made of metal however zips with plastic elements reduce the risk of

entrapment. • Where metal zips are used for ages 6 years and above, they must be designed with an inner flap

at least 2.0cm wide, and secured by stitching across the base of the fly opening.

Figure 1

• Claw type top and bottom stops. Claw stop must be replaced by an H block bottom stop.

Figure 2 • Testing: Zip manufacturer to carry out CS13 test on each type of zip supplied. (BS 3804:2006) Figure 2

Metal

Coil

Plastic molded

01 Childrenswear Safety Manual 2009 - Clothing

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