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www.intertek.com 1 © Intertek 2011, All Rights Reserved Safety of Children’s Clothing – Cords and Drawstrings on Children’s Clothing EN14682: 2007 Green. Jing 2014. 7 www.intertek.com 2 © Intertek 2011, All Rights Reserved General Product Safety Directive Directive 2001/95/EC came into force in January 2001, replaces EU GPSD 92/59/EEC The most important requirement is know as the “ General Safety Requirement”: Producers shall place only safe products on the market. Safe Product: Any product which under normal or reasonably foreseeable conditions of use, including duration, and, where applicable, putting into service, installation and maintenance requirements, presents no risk or only the minimum risk compatible with the product’s use and which is with a high level of protection for consumers. EN 14682 is a mandated standard under the GPSD, allows a presumption of conformity with the General Safety Requirement.

Cords and Drawstrings on Children’s Clothing EN14682: 2007

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www.intertek.com1 © Intertek 2011, All Rights Reserved

Safety of Children’s Clothing– Cords and Drawstrings on Children’s Clothing

EN14682: 2007

Green. Jing2014. 7

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General Product Safety Directive

Directive 2001/95/EC came into force in January 2001, replaces EU GPSD 92/59/EEC

The most important requirement is know as the “ General Safety Requirement”:

Producers shall place only safe products on the market.

Safe Product: Any product which under normal or reasonably foreseeable conditions of use, including duration, and, where applicable, putting into service, installation and maintenance requirements, presents no risk or only the minimum risk compatible with the product’s use and which is with a high level of protection for consumers.

EN 14682 is a mandated standard under the GPSD, allows a presumption of conformity with the General Safety Requirement.

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Strangulation, Entrapment, and Tripping

Garments manufactured with cords, drawstrings or loops present a potential risk of strangulation, entrapment or tripping, and national accident statistics indicate relative accidents to children fall into two main groups.

• For children aged 2 to 8 years the risk of entrapment of hood or neck cords in climbing or playground equipment such as sliders, resulting in strangulation, is most common.

• For children aged 10 to 14 years data indicate severe injury or even death caused by entrapment of cords and strings from waists and lower hems of garments in various moving vehicles. Children of this age not only play without supervision, but also are encouraged to become independent and travel to and from school unsupervised. Instances are reported of loops and cords being trapped in doors of buses or trains, etc., while long strings from lower hems of garments can become tangled in bicycle wheels and chains resulting in the rider falling in the path of other road traffic, or simply tripping the wearer. The presence of any rigid toggle or a knot can increase the risk of these accidents.

• In addition elasticated hood or neck cords have resulted in a number of facial injuries.

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Scope & Target

EN 14682: This European Standards specifies requirements for cords and drawstrings on children’s clothing, covering cord, chain, ribbon, string or tape of any textile or non-textile material with or without embellishment, such as a toggle, pom-pom, feather, or bead , including disguise costumes and skiwear, up to the age of 14 year.

Divide into two groups: (EN 14682) Young child: person aged from birth to age 7 years (that is 6 years and 11 months) which includes all children up to and including a height of 134cm.(EN 14682) Older child and young person: person aged from7 years up to 14 years ( that is 13 years and 11 months) which includes all boys of height greater than 134cm up to 182cm and girls of height greater than 134cm up to 176cm.

The aim of this standard is to minimize the risk of accidental entrapment by cords or drawstrings on children’s clothing.

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What is not cover

• Child use and care articles for example bibs, nappies and soother holders;

• Shoes, boots and similar footwear;

• Gloves, hats, bonnets and scarves;

• Neckties designed to be worn with a shirt or blouse;

• Belts and braces;

• Religious clothing and celebratory clothing i.e. ceremonial clothing

• Specialist sportswear generally worn under supervision, i.e. rugby shorts, wet suits and dancewear;

• Theatrical costumes used for theatrical performances;

• Aprons intended to be worn over day wear, for limited periods and under supervision, to protect clothing from soiling during activities such as painting, cooking, or during meal times.

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Considerations for risk assessments (1)

a) The child’s age;

b) Normal behavior and activities of children for their age and stage of development, for example playing in playgrounds, climbing trees, travelling by bus or train, ability to look after themselves, and where relevant, level of supervision;

c) Previous national accident statistics and Rapex weekly report.

http://ec.europa.eu/consumers/dyna/rapex/rapex_archives_en.cfm

d) Children’s clothing sold in the EU is usually sold by height as the primary measurement, sometimes with age as an additional indicator. Clothing for babies (up to around 1 year of age) is generally sold by length of the baby although some countries use the baby’s weight. All chest, waist, and hip measurements are secondary measurements. EN 13402 Size Designation interprets specifications of primary dimension and secondary dimension.

The risk assessment is in relation to the aim of this European Standard which is to minimize the risk of accidental entrapment in moving vehicles or strangulation by cords and strings on children’s clothing, taking into account:

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e) Decorative design features: e.g. bows, half belts, tabs, straps etc. are all features that shall be subjected to a risk assessment to establish that they do not present a hazard to the wearer of the garment

f) Functional loops used on the inside of garments for display and hanging purposes shall be subjected to a risk assessment to establish that they do not present a hazard to the wearer of the garment.

Considerations for risk assessments (2)

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Body Zone

A hood and neck area B chest an waist area

C below hip D back area

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Measurement

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Some Definitions (1)

Definition is very important to define which kind of cord Definition is very important to define which kind of cord should be, which is premise to assess the risk.should be, which is premise to assess the risk.

Drawstring: cord, chain ribbon, string or tape of any textile or non-textile material with or without embellishment, such as a toggle, pom-pom, feather, or bead which Passes through a channel, loop(s) or eyelet(s) or similar, to adjust the size of the opening, or part of the garment or to fasten the garment itself.

Note 1 the protruding length of the drawstring may increase whenclosure is effected.

Note 2 For some garments a drawstring may be a loop with a tightening device rather than

Functional Cord: cord, chain ribbon, string or tape of any textile or non-textile material with or without embellishment, such as a toggle, pom-pom, feather, or bead of fixed length, which is used to adjust the size of the opening, or part of the garment or to fasten the garment itself.

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Some Definitions (2)

Decorative Cord: non-functional cord, chain ribbon, string or tape of any textile or non-textile material with or without embellishment, such as a toggle, pom-pom, feather, or bead of fixed lengthwhich is not intended to be used to adjust the size of the garment opening or fasten the garment itself.

Shoulder Strap: functional cord joining the front and back of a garment top together, which is close fitting and passes over the shoulder.

Adjusting Tab: small strip of fabric not less than 20mm in width intended to adjust the size of opening on a garment for example at the ankle or sleeve cuff.

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Some Definitions (3)

Halter Neck Cord: functional cord worn round the back of the neck holding the garment ( for example dress, blouse or bikini) top leaving the shoulder and back bare.

Tied Belt or Sash: drawstring, decorative or functional cord or piece of textile material of not less than 30mm width tied round the waist area of a garment.

Loop: cord or narrow strip of fabric curved in shape, which may be fixed or adjustable in length, where both ends are attached to the garment.

Fixed loops: protrude from the garment

Flat loops: do not protrude from the garment.

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Requiements (1)

3.1 General

3.1.1 The free ends of drawstrings, functional cords and tied belts or sashes shall have no three-dimensional embellishments or knot and shall be secured to prevent fraying, for example by heat sealing or bar tacking. The ends may be doubled or folded provided no hazard of entrapment is created.

3.1.2 Toggles shall only be used on drawstrings with no free ends or decorative cords.

3.1.3 Where drawstrings are permitted, they shall be attached to the garment, for example using a bar tack, in at least one point positioned equidistant from the exit points.

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3.1.4 Fixed loops, for example to fasten, shall be no more than 75mm in circumference. Flat loops for example for belt loops, shall be no more than 75mm in length, between the fixed points of attachment to the garment.

3.1.5 Zip pullers including any embellishment shall be no longer than 75mm in length from zip slider and shall not hang below the lower edge of garments designed to finish at the ankle.

Requirements (2)

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3.2 Hood and neck area on garments for young children

3.2.1 Garments intended for young children shall not be designed, manufactured or supplied with drawstrings, functional cords or decorative cords in the hood or neck area.

3.2.2 Adjusting tabs are permissible provided that the length is no more than 75mm.

3.2.3 Shoulder straps are permissible provided they are constructed from one continuous length of material or cord attached at front and back of the garment. Decorative cords attached to a shoulder strap shall not have free ends longer than 75mm and fixed loops shall be no more than 75mm in circumference.

3.2.4 Halter neck-style garments shall be constructed with no free ends in the hood and neck area.

Requirements (3)

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3.2.5 Stitched or otherwise attached embellishments, for example bows, shall not have free ends longer than 75mm. Any loops shall be not greater than 75mm in circumference.

3.3 Hood and neck area on garments for older children and young persons

3.3.1 Drawstrings shall not have free ends. When the garment opening is at its largest and the garment is laid flat there shall be no protruding loop. When the garment opening is at its smallest, i.e. the size it is intended to fit, maximum protruding loop circumference shall be 150mm.

Requirements (4)

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3.3.2 Functional cords and adjusting tabs shall be not more than 75mm in length.

Functional cords shall not be made from elastic cords, except for shoulder straps and halter necks.

3.3.3 Decorative cords shall not be more than 75mm in length at either end including any attachment such as a toggle.

Decorative cords shall not be made from elastic cords.

3.3.4 Shoulder straps are permissible provided any free ends are no longer than 140mm from the point at which they are to be tied and fixed loops are no more than 75mm in circumference. (not mentioned)

Requirements (5)

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3.3.5 Halter neck-style garments shall be constructed with no loose ends in the hood and neck area.

3.4 Waist area of garments, internal and external to the garment

3.4.1 Free ends of drawstrings in the waist area shall protrude by a maximum of 140mm at each end when the garment is opened to its largest and laid flat, and by no more than 280mm when closed to the intended size. Drawstrings with no free ends shall have a loop with a maximum circumference of 280mm when closed to the intended size.

3.4.2 Functional cords, decorative cords and adjusting tabs in the waist area shall be a maximum of 140mm including any embellishment on decorative cords.

Requirements (6)

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3.4.3 For young children, tied belts or sashes intended to be tied at the back of the garment are permissible provided that when untied and measured from the point where they are to be tied, they shall be no more than 360mm in length and, when untied, do not hang below the hem of the garment.

3.4.4 For older children and young person, tied belts or sashes intended to be tied at the back of the garment are permissible provided that, when untied and measured from the point where they are to be tied they shall be no more than 360mm in length.

Requirements (7)

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3.4.5 For both age groups, tied belts or sashes intended to be tied at the front of the garment shall be acceptable provided that when untied they shall be no more than 360mm in length measured from the point where they are to be tied.

3.5 Lower hems of garments which hang below the crotch

3.5.1 Drawstrings, decorative cords or functional cords including any toggle on the lower edges of garments where the lower edge is situated below the crotch shall not hang below the lower edge of the garment.

3.5.2 Drawstrings or cords at the lower edges of garments shall lie flat against the garment, when the garment.

Requirements (8)

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3.5.3 In garments that are designed to finish at the ankle (coats, trousers or skirts), the drawstrings, functional cords and decorative cords at the bottom hem shall be totally on the inside of the garment.

Stirrups at the hem of trousers are permissible.

3.5.4 Adjusting tabs are acceptable provided that they are no longer than 140mm in length and shall not hang below the hem of the garment.

Requirements (9)

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3.6 Back area

3.6.1 Children’s garments shall not be designed to have drawstrings, decorative cords or functional cords that emerge from the back of the garment or to be tied at the back.

3.6.2 Tied belts or sashes are permissible.

3.7 Sleeves

3.7.1 Drawstrings, functional cords and decorative cords at the lower edge of long sleeved garments shall be totally on the inside of the garment, when the garment is fastened.

Requirements (10)

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3.7.2 For younger children, drawstrings, functional cords and decorative cords are permissible on short sleeved garments provided the sleeve finishes above the elbow and the maximum protruding length is 75mm measured when the sleeve is open to its largest and laid flat.

3.7.3 For older children and young persons, drawstrings, functional cords and decorative cords are permissible on short sleeved garments provided the sleeve finishes above the elbow and the maximum protruding length is 140mm measured when the sleeve is open to its largest and laid flat.

Requirements (11)

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3.7.4 For both age groups, adjusting tabs are permissible on sleeves provided that they are no longer than 100mm in length and when open shall not hang below the hem of the garment.

3.8 Other parts of the garment

In all other areas of the garment, not previously addressed, the drawstring or functional and decorative cords shall protrude by no more than 140mm when the garment is open to its largest and laid flat.

Requirements (12)

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3.2 Questions concerning terms and definitions

What is a three dimension (3D) embellishment?

• A three dimensional embellishment is any decorative item attached to a cord that is thicker than the cord itself.

• Thin materials such as plastic sleeving (bootlace ends) which are not thicker than the cord itself are not considered three dimensional embellishments.

• Generally, thin textile materials which are not thicker than the cords itself will not create a hazard.

Action: To be clarified in the revision of EN 14682.

PD CEN TR 16446: 2012 Guidance Document

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3.3 Questions concerning requirements

3.3.1 How should decorations near the end of the decorative cords or functional cord be considered?

• The three-dimensional embellishment at any point of the cord may present a hazard of entrapment and therefore a full risk assessment should be carried out.

Action: No action required.

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3.3 Questions concerning requirements

3.3.2 Elastic cords with free ends are not permitted in hood andneck area. What is the rationale?

• Elastic cords with free ends or protruding loops may snap back into the face if pulled, resulting in eye, facial or neck injury especially if a toggle is present.

Action: Annex C “ Rationale” in revised EN 14682 to be improved.

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3.3 Questions concerning requirements

3.3.3 Are hood extensions used to fasten a hood considered as adjusting tabs and therefore subject to requirements of subclauses 3.2.2 and 3.4.2?

• No, the hood extension as illustrated in Figure 1 is integral to the hood and does not present any more risk than the hood itself.

Action: No action required.

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3.3 Questions concerning requirements

3.3.4 Shoulder straps and halter neck styles are kinds of functional cords. May these be made of elastic materials?

• Yes. Shoulder straps which have no free ends will never have ends which can “ snap” back on the wearer’s face. Those straps with free ends will not be long enough to present a hazard.

Action: No action required.

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3.3 Questions concerning requirements

3.3.5 Is it acceptable for bikinis with no free ends to use a halter neck clasp?

• Yes. The closing mechanism at the end of the cord (halter neck garment) should not be considered as an entrapment hazard because the cord sits close to the body.

Action: No action required.

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3.3 Questions concerning requirements

3.3.6 Is it acceptable to have shoulder straps or halter neck straps which may be adjusted by means of a ring slider mechanism?

• Yes. provided the loop is flat and close to the body. As the loop is adjustable it will be of variable length.

Action: To be addressed in the revision of EN 14682.

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3.3 Questions concerning requirements

3.3.7 Dungarees have shoulder straps. Is it acceptable for theseto be detachable and adjustable?

• Yes, provided the free ends of the straps are inside the garment

• The reason the clarification document states that the free ends should be on the inside is that they do not want long strips of fabric hanging outside the garment from adjustment of shoulder strap.

Action: No action required to current standard.

*** Textile technical note*** TTN-CDEN-001-13During the seminar, we agreed that the following types of designs would be classed as shoulder straps and would not be classed as having a free end.

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3.3 Questions concerning requirements

3.3.8 How should tabs on the shoulder of a garment be considered?

• Tabs on the shoulder, even if decorative, should meet the same requirements as adjusting tabs.

Action: No action required.

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3.3 Questions concerning requirements

3.3.9 Are adjusting tabs on backs and tops of hoods acceptable? These do not appear to be mentioned in EN 14682: 2007?

• Yes. Adjusting tabs are permissible provided that the length is no more than 75mm.

Action: To be addressed in the revision of EN 14682.

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3.3 Questions concerning requirements

3.3.10 Are loops for fastening garments such as a duffel coat acceptable?

• Yes. provided the protruding fixed loops are a maximum of 75mm in circumference.

Action: No action required.

3.3.11 Is the cord to which a toggle button is attached on duffel coat a functional cord?

• No it is a fixed loop.

Action: No action required.

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3.3 Questions concerning requirements

3.3.12 When assessing a sash or tied belt, what is the correct method for assessing the length?

• With the belt or sash in place, lay the garment flat on the table with opening closed, cross the sash or tied belt as if to tie in a knot. Straighten the free ends of the sash or tied belt, and measure the length of the free ends.

• If the sash or tied belt is not permanently attached to the garment, adjust the lengths of the free ends to be uniform, thenmeasure.

• If the sash or tied belt is permanently attached and the free ends are not equal in length, the longest end shall be measured.

Action: Improved measurement method to be added to the revision of EN 14682, Annex D.

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3.3 Questions concerning requirements

3.3.13 Is a scarf tied around the waist of a garment acceptable?

• If the width of the scarf is greater than 30mm, it should be considered as a sash or tied belt. If the width of the scarf is less than 30mm, it should be considered as a cord or, if threaded through belt loops, as a drawstring and meet the relevant requirements.

Action: No action required.

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3.3 Questions concerning requirements

3.3.14 Is it acceptable for free ends of a sash to be shaped?

• Yes, provided the ends do not present additional bulk which might lead to an entrapment hazard. When assessing the length of the sash, the measurement should be taken to the longest point of the shaped sash ends.

Action: No action required.

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3.3 Questions concerning requirements

3.3.15 Are the cords on the sides of a pinafore dress to be considered as sashes or functional cords?

There are two cords on both sides of the dress to tie the front and back of dress together at the waist. The cords are more than 30mm wide.

• As the cords are wider than 30mm and are tied at the waist they are considered as a sash.

• The requirements of sashes and tied belts to be tied at the front apply to those tied at the side.

Action: To be clarified in the revision of EN 14682

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3.3 Questions concerning requirements

3.3.16 Are sashes or tied belts sewn to the garment from the side seam acceptable?

• Yes, provided the sashes meet the requirements for sashes and tied belts.

Action: No action required.

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3.3 Questions concerning requirements

3.3.17 How should cords designed to be tied on the side of the body, such as on bikini pants, to be considered?

• The functional cords (or tied belts) should be evaluated in the same way as functional cord or tied belts on the front of the garment.

• Cords which emerge from the side, but are designed to be tied at the back should meet the requirements of EN 14682: 2007, subclause 3.6

Action: No action required.

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3.3 Questions concerning requirements

3.3.18 Where a garment has a cord at the waist, how is the acceptable length measured?

• The cord should be measured from the last exit point on the garment, or the last loop, to the end of the cord

Action: To be clarified in the revision of EN 14682.

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3.3 Questions concerning requirements

3.3.19 For board shorts with four eyelets, is the exit point measured from the exit point of the eyelet or from the garment?

• From a risk point of view, the hazard is when the garment is on the body, it is therefore recommended that the measurement is taken from the last exit point.

Action: No action required.

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3.3 Questions concerning requirements

3.3.20 Is it acceptable to have a fringe on the garment?

• Fringes are not considered in EN 14682:2007 and a separate risk assessment is required.

Action: To be addressed in the revision of EN 14682.

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3.3 Questions concerning requirements

3.3.21 Where cords are at lower hems of garment, and it is not obvious if this is below the crotch, how should these be assessed. It is not clear from subclause 4.5

• Where it is not obvious if the garment will hand below the crotch, the more stringent requirements of subclause 4.5 shoud apply.

Action: To be addressed in the revision of EN 14682.

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3.3 Questions concerning requirements

3.3.22 Are strings at the hems of capri(3/4 length) trousers acceptable?

• Yes if the strings do not hang below the lower hem of the trouser, see EN 14682: 2007 subclauses 3.5.1, 3.5.2 and 3.1

Action: No action required.

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3.3 Questions concerning requirements

3.3.23 EN 14682 subclause 3.7 describes how to assess cords on long sleeve garments and on short sleeve garments. How are cords on 3/4 length sleeves to be assessed?

• The garment sleeves are not the hazard, the cords hanging from the sleeve are the hazard. The hazard will depend on the length of the cords and the location on the sleeve. EN 14682 provides specifications for short sleeves and long sleeved garments. If the cords are below the elbow, these should be considered as for long sleeved garments; if the cords are above the elbow, consider as short sleeve garments.

Action: To be included in an informative annex in the revision of EN 14682.

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3.3 Questions concerning requirements

3.3.24 Are hanging loops (for display purposes in store) acceptable?

• Where hanging loops do not meet the requirements of fixed loops EN 14682, a risk assessment should be done, Hanging loops on the inside of the garment are satisfactory provided they present no protrusion or additional hazard in wear. It may be necessary to make them removable or easily detachable. Other functional loop internal to the garment should be considered similarly.

Action: No action required.

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Drawstring & Cords Safety –frequent cases recalled analysis

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Drawstring & Cords Safety –frequent cases recalled analysis

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Drawstring & Cords Safety –frequent cases recalled analysis

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Drawstring & Cords Safety –frequent cases recalled analysis

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Drawstring & Cords Safety –frequent cases recalled analysis

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Other recalled cases due to drawstring & Cords

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Case Discussion

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THANK YOU!

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