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Safety Manual Clothing 2016
Safety Manual Clothing 2016
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 (Inspiration Innovation Integrity & In Touch) 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.
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 Product Safety Managers and Officers will undergo the Marks & Spencer ‘Certified Auditor Program’ this program involves: training,
witnessed audits and an examination
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.
To ensure that a factory is set up to Marks & Spencer’s safety requirements the Product Safety Manager and Officer should ensure that
the guidelines laid out in the Product Safety Guidelines pack have been implemented
Link - Product Safety Guidelines pack
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:
Link - 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.
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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.
REACH
Every supplier must be familiar and comply with REACH Legislation
A robust process must be in place to respond to any requests especially about chemicals of very high concern within 45 days
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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
Non-adherence to our Safety Policy
Risk Assessment
Legal Documentation
Marks and Spencer Internal Standards
Test Methods
No
1. Aglet (Flugelbinder)
2. Battery Operated Components
3. Beads
4. Bells
5. Belts
6. Bibs
7. Bows
8. Braces (Separate Braces)
9. Buttons
10. Corsages
11. Decorative Feathers
12. Diamantes
13. Direct Embroidery / Fusible Motifs and Badges
14. Dressing up & disguise costumes
15. Dry Cleaning
16. Elastics
17. Faux Fur pile fabrics & trims.
18. Flammability – All Garments excluding nightwear and Dress up
19. Flammability – Nightwear
20. Flash Flame
21. Float Lengths - Includes socks / tights / gloves / and garments with integral feet.
22. Hanger Loops
23. Hoods and Headwear
24. Hooks and Eyes
25. Jewelry
26. Lace Crochet - open constructions
27. LED Lights (Light Emitting Diode)
28. Light Nodules
29. Liquid Filled Products (e.g. Badges/ Teethers
30. Magnets
31. Metal components - Press fasteners, Stud buttons, Rivets, Eyelets, Strap adjusters
32. Migration of Toxic Elements
33. Natural Materials for Accessories & componentry
34. Necklaces
35. Neck Stretch
36. Neck Ties
37. Netting
38. Plastic bags e.g. over bags intended for sale with the products in M&S stores
39. Pom-Poms / Bobbles / Tassels and Fringing
40. Prints – (transfers, panel prints, all over continuous prints – includes backing
materials)
41. Rouleau Loops
42. Safe in the Sun Garments and Hats
43. Scarves
44. Sequins
45. Silica Gel
46. Sleeping Bags
47. Slipper Socks and Slip Resistant Soles
5
48. Sound Nodules/ Noise Levels
49. Swim Short Mesh Liner Fabric for Boys
50. Touch & Close fasteners (e.g. Velcro®)
51. Toys and Dress Up
52. Waddings and Quilted Waddings including Feather & Down
53. Washed Garments - that use Stones or Sand.
54. Zips
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
Kids Pom Pom Construction Guideline VI
SSRA Supplier Safety Risk Assessment Form VII
SSRA Supplier Safety Risk Assessment Form – How to fill in VIII
Firewall Inspection Standards for Floats & Thread Ends IV
6
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-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.
As part of the Risk analysis process each 3D trim should be assessed as a potential choking Hazard, those that are, need to follow our Test to Failure (TTF) and
Pull Test Guidelines, found in the appendix section. Those that are not considered a choking Hazard should still be tested durability P5A for Quality
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
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 SSRA ‘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.
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.
BS EN 16128:2011 Reference test method for release of nickel from products intended to come into direct and prolonged
contact with the skin for Sunglasses & Glasses
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.
89/686/EEC Personal Protective Equipment Directive
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.
ECP : 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
1 Aglet (Flugelbinder) Choking Age: 3 years and Under Definition – a small plastic sheath typically used on the
Permitted - TTF Required end of a shoelace, cord, or drawstring
No Category Potential Hazard Specification Tech Notes
2 Battery Operated Aspiration Age: All Ages Electrical components (including button cell batteries) shall not be
Components Burn – Chemical Must comply with BS EN 62115 (2005) Electric Toys Safety. easily accessible (refer to BS EN 62115 for full details).
Choking (BS EN 50088 was withdrawn 01/01/2008 and will no longer be Battery operated components must be enclosed in a sealed unit
Ingestion accepted). prior to attachment to the garment footwear or accessory
Inhalation Certification of compliance to EN71 pt1where applicable Directive 2006/66/EC for batteries & accumulators (including
Insertion For use in Toys - Refer to the M&S Electronic Toys Standard on the button cells) – all batteries shall be marked with the Standard
Over heating /Fire Quality Standards Website. Battery logo (the crossed out wheelie bin) and where appropriate
Toxicity - chemical Certification of compliance to EMC requirements. with the chemical symbol for the heavy metal concerned below it;
For use in Toys - Comply with the WEEE Directive. if it contains more than 0.0005% Mercury (Hg), 0.002% Cadmium
For use in Toys - Components to be RoHS compliant. (Cd) or 0.004% Lead (Pb) by weight (Note: due to size restrictions
Comply with New Directive 2006/66/EC for Batteries & Accumulators button cell markings may be applied to the product label or
and waste batteries & accumulators. packaging).
For Clothing - P5A Durability wash to be submitted at technical Battery logo Heavy metals Battery logo’s
evaluation stage in garment or panel form.
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.
X
PLEASE REFER to TTF / Pull Test Appendix
8 Braces Entrapment Age: All Ages Webbing must be securely stitched over D rings
(Separate Braces) Laceration Webbing must be woven to desired width. ‘Rabbit ears’ must be bar tacked.
Strangulation Elastic must be latex free Must carry swing ticket warning ‘Not suitable for under 36
Toxicity - chemical Must be free of rough edges. months’ For all label references please refer to the CLA website
For metal component of braces please refer to Migration of Toxic
Elements
Please refer to TTF / Pull Test Appendix
9 Buttons Choking Age: All Ages Please remember if you are applying the same button over
Ingestion Buttons must withstand P122 different levels of thickness on the same garment, a TTF / Pull test will need to be
( relating to any Inhalation Machine Lockstitch only CHAIN STITCHING IS NOT submitted for each thickness. ( for example, a four layer placket and a two layer pocket)
buttons that can be Insertion PERMITTED. Fig. 1
sewn onto a garment / Laceration Must be free of injection mould ‘flash’ or rough
product using thread) Projection edges.
Toxicity-chemical Buttons must not resemble food.
No Latex Rubber buttons to be used
Do not attach spare buttons on Childrenswear.
Glass buttons not permitted. Fig. 2
PLEASE REFER to TTF / Pull Test Appendix
10 Corsages Choking All Ages Machine attach were possible for quality
Insertion
All corsages must pass D Wash P5A
Labeling
All Ages
Additional Care codes required
wash inside out
iron on reverse
No. Category Potential Hazard Specification Tech Notes
13 Direct Embroidery / Choking Age: All Ages Consider irritation e.g. knees, elbows etc.
Fusible Motifs and Ingestion Soft interlining to be used on all embroideries which are in direct Special attention must be paid to flocking to ensure that safety
Badges Irritation in wear. contact with the skin to avoid irritation in wear, (this depends on the standards are met, formaldehyde free etc.
Laceration location of the embroidery and should be discussed at development Design motifs on stretch fabric must be designed with breaks
Tourniquet stage with department technologist ) in the pattern. This will avoid the breaking of thread when
Toxicity Please refer to the Appendix - Firewall Inspection Standards for Floats worn by the customer.
Toxicity - chemical & Thread Ends Ensure any adhesives comply with ECP.
For quality we specify thread ends/ loops on embroidery should not To reduce sharpness of motif edges it is recommended to laser
exceed 1cm. cut or fold.
Novelty motives / badges – please refer to section on Liquid
Flocked, PU Printed or Welded Motifs applied by a high frequency Filled Products
welding French Knots are not considered to be a choking hazard – they
The welded edges must be continuous, all contours to be as should be assessed for durability P5A for quality purposes
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.
Soft plastic badges must comply with ECP
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.
16 Elastics Entrapment Age: All Ages Elastics can reduce blood flow if designed too tight. Ensure
Pinching Must be latex free conformance to relaxed and extended garment measurements
Skin Irritation Where used in nightwear, must conform with relevant flammability stated on the size chart
Tourniquet legislation 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 ECP.
No. Category Potential Hazard Specification Technical Notes
17 Faux Fur pile fabrics & Perceived choking Age: All Ages Under 4 years - Boa construction must be used as it is more
trims. and aspiration Real animal fur is not permitted. secure
Inhalation 4 Years and above - Sliver knit constructions are permitted
Printed furs (e.g. discharge tips) - solvent-free printing systems should
where agreed with the Departmental Technologist and must be
be used wherever possible and the finished product must comply with
polished to remove loose fibre.
ECP requirements.
Loose pile can also be improved by back coating or heat
Where cellulosic and cellulosic rich faux furs are used these should be bonding the fabric – the coating used must meet ECP
tested to surface Flash Flame P117 requirements and be latex free
18 Flammability – All Burns Age: All Ages Please refer to the Childrenswear label position on the Quality
Garments excluding Labeling Standards Website
nightwear and Dress All Kids’ Daywear Clothing must have a Fire Warning (FW) label as Please also refer to Kids clothing Flammability Labeling Policy
up part of the front of the permanent sewn in care label – please note for products and exceptions.
product exceptions in the appendix Pram shoes, bootees & slippers must carry the FW wording.
The ‘FW’ wording to read, ‘KEEP AWAY FROM FIRE’ (Upper Case
10 point red lettering).
21 Float Lengths Laceration Age: Babywear The Age Splits are in line with Departmental age breaks
Includes socks / Ripping off Baby bootees and garments with integral feet, all over-runs of seams must be at
tights / gloves / finger and toe the back of the foot Float:
nails A thread, which is attached at both ends & lies on the
and garments
Tourniquet & Internal Design Standards surface of a fabric, forming a loop
with integral feet.
restriction of Floats must be pulled flat to measure
blood circulation Age: Under 24 months
Hosiery – Babies 0 to Age 24 months Thread End:
Floats and Thread Ends
Floats Leg Float Foot Thread Thread An untrimmed thread end, attached at one side.
Ends Leg Ends Foot Products must be examined inside and out to ensure no
Design Standards 1.0cm 1.0cm 2.5cm 2.5cm threads or floats are left inside.
Coverage of floats – where technically possible – for
Toe Seam – to be 1.0cm max example in mittens, it is recommended to line the side of the
product where the floats are exposed, to minimise the risk
Knitted Gloves – Babies 0 to Age 36 months of catchment in wear
Floats and Thread Ends Floats Thread Ends
In knitwear & specifically jacquard designs, floats above the
Design Standards specified tolerance must be discussed with the
1.0cm 2.5cm
departmental technologist to eliminate risk.
Refer to beads, direct motifs and sequins for sewing float
Cut & Sew items with enclosed feet or Hands – Babies 0 to Age 24 months guidelines.
Floats and Thread Ends Floats Thread Ends
Design Standards 1.0cm 1.0cm Knitwear
Colour changes on stripe panel may result in vertical loops at
Knitwear – Babies 0 to Age 24 months the panel’s edge. If these are longer than the specified float
Floats – Main Floats - Thread Ends length, they must be trimmed in line with Marks and
Floats and Long Ends Body Sleeves & Legs Spencer’s quality requirements.
Design Standards 2.0cm 1.0cm 1.0cm Consider gauge and tension when designing critical areas
e.g. Cuffs
Age: 24 months and Above
Hosiery – Children – Age 24 months Upwards
Floats Leg Float Foot Thread Thread
Floats and Thread Ends Ends Ends Foot
Leg
Design Standards 2.5cm 2.5cm 3.0cm 3.0cm
Cut & Sew items with enclosed feet or Hands – Children - Age 24 months
Upwards
Floats and Thread Ends Floats Thread Ends
Design Standards 1.0cm 1.0cm
See Appendix - Firewall Inspection Standards for Floats & Thread Ends
No. Category Potential Hazard Specification Tech Notes
Dress Up Headwear:
Refer to Dress Up section for flammability requirements EN 71 part 2
27 LED Lights (Light Damage to eyesight Age: All Ages Valid Certification required verifying Class 1.
Emitting Diode) Obtain specification from supplier to confirm the class of LED; this It is good practice to ensure that LED’s are tested in position
determines the strength of the beam to prevent any potential damage within the product to take account of any lenses, covers or filters
to eyes (Only Class 1 LED’s are permitted in children’s clothes, shoes or which may affect the strength of light emitted.
toys. Warning text in respect of LED’s is not required for Class 1.
Test to BS EN 60825 pt1. Safety of Laser Products.
Refer to the front section of this manual for generic standard
requirements.
28 Light Nodules Damage to eyesight In Addition to section 26: LED lights (light emitting Diode) D wash P5A to be submitted at contract seals stage
Product to be CE marked for EMC
Age: All Ages
Must comply with Electro Magnetic Compatibility (EMC) regs. As the Nodule will have to be applied after metal detection – the
Refer also to ‘Battery Operated Components’ section in this document factory floor will need to be set up to ensure no other metal
for compatibility & labeling contamination is introduced to this area – See ‘Factory Safety
Guidelines’ in Supplier Exchange
Age: Under 4 years
Allowed in this age group provided they are permanently attached and
are inaccessible
No. Category Potential Hazard Specification Tech Notes
29 Liquid Filled Choking Age: All Ages Please refer to TTF / Pull Test Appendix
Products (e.g. Laceration New reports required if composition of contents change. Safety data sheet must be completed and submitted prior to
Badges/ Teethers) Toxicity - Toxicological assessment on liquid formulation required. The contract seal.
Microbiological assessment must not show any Hazard. MSDS (Material Safety Data Sheet) to be uploaded onto
Water treatment plant to be audited to ensure microbiologically safe Contracts.COM (CMS) and retained in product technical file.
by a qualified microbiologist. Random checks on each process batch required.
Audit process and controls documentation to be recorded and Checks on purification system to be performed and recorded daily.
retained by the factory i.e. checks on purification. Min 3yrs planned maintenance to be in place for purification
Batch microbiological testing required frequency to be agreed with system.
M&S department technologist and is dependant on batch size/ Toxicity test on liquid to be completed on an annual basis.
quantities. The security of enclosure to which liquid is contained should be
CAS/ EINECIS number/ listing to be recorded in technical file. designed to prevent possible leakage and avoid potential customer
All liquid filled products must be traceable to batch production complaints over perceived hazard of ingestion (consider seam
records. strength/ edge sharpness/ product integrity).
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.
No. Category Potential Hazard Specification Tech Notes
31 Metal components - Choking Age: All Ages PLEASE REFER to TTF / Pull Test Appendix
Press fasteners Ingestion PRODUCT REQUIREMENTS: REFER TO INLINE TESTING PROCEDURES
Stud buttons, Inhalation For metal fasteners and eyelets the gauge of the brass strip must be
Rivets, Insertion minimum 0.37mm on the drawn barrel. Figure 1:
Eyelets, Laceration Prong fasteners – rings must be made from brass, and a minimum strip FRONT BACK
Strap adjusters.
Projection thickness of 0.5mm. This reduces the risk of the prongs cracking.
Hooks & Bars Toxicity - chemical The use of aluminum nails is only acceptable on certain products where
brass is not applicable – please discuss with dept Tech
Steel must not be used as it can rust.
Refer to Migration of Toxic Elements section
X
Must be free of rough edges. Prongs bent back can be
Roll setting eyelets (as opposed to split setting eyelets) must be used on sharp. Not acceptable
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 MACHINERY:
allowance. Machine operators must be trained and certified by the
Knitted fabrics; use prong fasteners to prevent laddering. Post fasteners component supplier.
must not be used on knitted fabrics. Manufacturer’s compatible dies must be used.
In Line checking: Pinch settings and machine sign off must be obtained from the
Check the machine has set up in accordance with the pinch testing and component supplier.
this should be done every two hours TTF/ P115a must be passed before production starts.
Pull Tests to be carried out every two hours
A manual check must be carried out on every garment to confirm that Where possible Fully Automatic Machinery is preferred
the popper prongs have all been pierced into the base fabric – and none Manually operated machinery which solely is reliant on the
are left protruding (See Figure 1) operator’s foot or hand pressure is not acceptable.
All garments with feet / pockets or other areas where poppers could be Semi automatic manually foot or hand operated machinery
found need to be turned inside out to check that no loose objects are allowed provided that it incorporates a non return ratchet
trapped inside. 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.
No. Category Potential Hazard Specification Technical notes
Rhinestone is enclosed in
metal and held by metal
ridge
Figure 3:
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.
No. Category Potential Hazard Specification Tech Notes
32 Migration of Toxic Toxicity - Chemical Age: All Ages < Less than
Elements
Migration of Toxic Elements: Metal componentry - Test as EN71 part 3 and apply our standards
Fabrics ,Tanneries, Print Houses and Laundries Chrome in all Leather products
Must comply to M&S ECP requirements Chrome is present in most tanned leathers
Chrome vi is banned
Toys Chrome iii is permitted
Must comply to EN71 part 3 & 9
Silica Gel has been shown to occasionally contain DMF. Silica Gel
Metal componentry sachets are prohibited in any kidswear products.
Must comply to the following levels:
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 ECP
34 Necklaces Laceration Age: Under 3 years Oval jump rings are preferred with split at the top
Not permitted
Diag:
Age: 3 years and above
Necklaces must have loose jump rings (split rings).
Break Strength min 25N to max 40N
X
For quality purposes break strength should be higher than 25N
No. Category Potential Hazard Specification Tech Notes
35 Neck Stretch General Distress The following requirements are to be adhered to: Perspex templates are available to test samples and end of line
Laceration Age Minimum neck Stretch – contact RO
5lb 48cm
6lb 6oz 50cm
New Born - 24months 56cm
24m -10years 58cm
10yrs - 14yrs 60cm
over 14 years 62cm
No. Category Potential Hazard Specification Method of attachment
37 Netting Toxicity – Chemical Netting commonly has Formaldehyde added to create the stiffness Formaldehyde Free – must ensure that Formaldehyde has never
been added. It is not acceptable to wash off and claim as
Age: Under 3 years. Formaldehyde Free
All Ages: Underwear Nightwear & Dress Up
Ensure that Formaldehyde Free is specified
38 Plastic bags e.g. Suffocation Thickness of permanent polyester bags to be greater than 38.0 Appropriate warnings to be applied depending on end use.
over bags intended microns. Please refer to GM Terms & Conditions for transit packaging
for sale with the Bags made of flexible plastic with an opening perimeter of greater including overbags.
product in M&S than 350mm must not have a drawstring or cord as a means of closing
Stores New products which require plastic bag packaging when in store
should be developed in consultation with the departmental
technologist & packaging developer.
No. Category Potential Hazard Specification Tech Notes
39 Pom-Poms / Bobbles Choking Please refer to Cords & Drawstring appendix PLEASE REFER to TTF / Pull Test Appendix
/ Tassels and Entrapment • Please refer to TTF / Pull Test Appendix
Fringing Ingestion • All types of Pom Poms must be risk assessed for entrapment and Figure 1 Figure.2
Inhalation strangulation
Insertion
Strangulation Age: Under 12 months
Tourniquet Pom Poms are NOT permitted with the exception of Hats where the Pom
Tripping Poms MUST to be assessed and agreed with the departmental
Technologist & The Safety Consultant. These must be a minimum of 60mm
diameter
40 Prints – (transfers, Choking hazard – prints Age: All Ages Test for Qualitative determination of PVC - C64 – QUALITATIVE
panel prints, all over peeling off All inks and backing materials should be PVC free where (BELSTEIN TEST) then/or FTIR for confirmation (Fourier
continuous prints – Toxicity - Chemical technically and commercially viable – any exceptions to be Transform Infa-Red Spectroscopy)
includes backing discussed with Departmental Technologist at development stage. Test for determination of Phthalates - C61 Solvent Extraction
materials) and GCMS (Gas Chromatography/Mass Spectrometry)
Phthalates & APEO’s are not permitted according to ECP.
Durability test on transfer prints should be carried out during
Print house and all printing inks and binders used need to production to ensure there is no peeling or cracking on the
conform to M&S ECP requirements surface.
Some printing methods can leave a residue of formaldehyde on Transfer prints applied to pile fabrics i.e. Velour should be
the fabric. Ultra-low formaldehyde binders should always be assessed to P5A at product development stage
used. P5A & C15 must be tested before contract seal and uploaded on
No Formaldehyde is permitted in Babywear or Intimate apparel to contracts.com for contract seal sign off
43 Scarves Entrapment Under 18 Months The maximum lengths must include any tassels or attachments
Strangulation No traditional Scarves Permitted at the end of the scarf.
Tassels should not exceed 14cm
A Safe Scarf – that can not be tied around the neck and is fastened Pockets are allowed on scarves as long as a risk assessment
with Velcro ®is permitted at the following lengths: has been carried out. Only patch pockets should be applied
6-12 Months reduce the entrapment risk.
A Safe Scarf construction permitted with max length 60cm
12 – 18 Months Safe Scarf Construction:
A Safe Scarf construction permitted with max length 70cm Touch and close fastenings, e.g. Velcro®, attached on underside of
Touch and close fastening edges should be rounded off to eliminate scarf
sharp edges and corners.
Over 18 Months
The following Maximum Length requirements are to be adhered to:
18 Months 4 Years 80cm
4-6 Years 95cm
6-8 Years 110cm
8-10 Years 125cm
10-12 Years 140cm
12-14 Years 155cm
44 Sequins Aspiration Age: All Ages P5A – Durability wash must be carried out before contract seal
Choking, Sequins must not have sharp, rough edges or burrs (fishtails). and uploaded on to contracts.com for contract seal sign off
Ingestion Must be free of mould ‘flash’ No Spare sequins to be supplied with the garment
Inhalation Sequins must be Phthalate and APEO free e.g. made of Polyester
Insertion Machine attach Sequins:
Laceration Age: Under 12 Months Thread: Monofilament of a minimum of 80denier may be used
Skin Irritation. All Ages: Underwear & Nightwear to keep lustre of the sequin, but if used must be used in
Toxicity - Chemical Monofilament yarns Not permitted combination with a fusing backing to avoid direct contact with
skin.
Age: Under 4 years Use of Monofilament Risk Assessment should be carried out
Machine attach only Stitching must be secure to ensure that none of the
Maximum Diameter 5mm monofilament comes unraveled by carrying out a ‘D’ wash at
Sequins must be round, flat and with smooth edges, and have a centre first production and carried out weekly during production.
punched hole. These records must be kept.
Strip sequins on a string not allowed Stitch Type: Lockstitch
Special Occasion Dresses Attachment:
Hand Attached sequins have been allowed for special occasion wear Age: Under 4 Years - 4 double stitch formation passing through
only. The sequins must be fully encased with an organza or mesh to the centre of the sequin
catch any sequins that have potential of coming off. Age: 4 Years and Above – Any stitch formation permitted
Age: 4 years and Above Hand Attach Sequins – Age 4 years and Above
Hand applied sequins are permissible if application guidelines are Thread: Embroidery/General sewing thread ticket 120.
followed. If applied singly, double knot off after each sequin
Shaped sequins such as stars, must have smooth edges If attached in a group - knot off every third sequin
Strips of sequins to be attached by lockstitch machine – bar tack start ‘’Knot off’’ – knot thread and cut off
and finish. At Start:
Double knot 2 strands of thread together, stitch through fabric
to form a small stitch prior to applying sequin
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
45 Silica Gel Choking Silica Gel is banned in Kidswear Silica Gel is primarily used in moisture re-movement in transit
Toxicity - Chemical
No. Category Potential Risk Specification Tech Notes
46 Sleep Bags - for use Entrapment Flammability must conform to BS EN 14878 Specific Instruction need to be displayed on the Swing Ticket this
in a cot Flammability M&S max Tog requirement Tog 3.5 tested to BS 5335 as defined in BS must be signed off by the Departmental Technologist
Over Heating 8510 Tog Report to be checked before Care Label and Swing Ticket
To ensure no Entrapment of body into the bag ordering and loaded on to contracts.com at contract seal
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
Popper Release
Break force to be tested for every: type of popper, size & different Report to be conducted and passed before popper purchase and
material layers applied through submitted at contract seal
Break Force Test Method
Unsnapping of poppers ASTM D4846 peel method – popper opening
force before & after 100 open and closes.
TTF Pass required using Lower Spec limit of 1kg & Z = 4
Ring poppers to be used
Do not use Cap Poppers as these have a stronger Break force
No. Category Potential Hazard Specification Tech Notes
47 Slippers Socks & Tripping Age: All Ages CE Marking: Products that have a play element like a
Slip resistant soles Must comply with this slip test and abrasion resistance test M&S FP06 rattle or squeeze component should be CE marked
(Satra TM 144 2007)
48 Sound Nodules/ Damage to hearing Age: All Ages Certification of compliance to EN71 part 1 (clause 4.20
Noise Levels Must comply with acoustic requirements in EN71 part 1. Acoustics).
Must comply with Electro Magnetic Compatibility (EMC) regs. Use an appropriate warning: “Do not place close to the ear,
Refer also to ‘Battery Operated Components’ section in this document misuse may damage hearing”.
for compatibility & labeling D wash P5A to be submitted at contract seals stage
Product to be CE marked for EMC
Age: Under 4 years As the Nodule will have to be applied after metal detection –
Allowed in this age group provided they are permanently attached and the factory floor will need to be set up to ensure no other
are inaccessible metal contamination is introduced to this area – See ‘Factory
Safety Guidelines’ in Supplier Exchange
No. Category Potential Hazard Specification Technical Notes
49 Swim Short Mesh Entrapment Age: All Ages Avoiding skin entrapment is a new requirement into BS 7907
Liner Fabric for Laceration Holes in mesh need to be smaller than 1.5mm in diameter to avoid
Boys entrapment of skin.
Mesh fabric to be soft handle. Agreement of handle should be gained
from the M+S Departmental Fabric Technologist.
No. Category Potential Hazard Specification Technical Notes
Toys & Dress UP All Age: All Ages Ensure appropriate warnings as specified in EN71 parts 1,2,3 inc.
51
Must comply with the EU Toy Safety Directive 2009/48/EC age specific warnings.
Must comply with EN 71 parts 1 to 11 as required. Refer to M&S approved standard warnings for toys
Must comply with all other relevant standards – see this document. Note: EN71 testing requirements are different for under 3’s and
Refer to relevant Toy Standards in Home Safety Manual on Quality over 3’s age group. Ensure testing is performed appropriate to
Standards website. the intended age group. If the item is intended for over 3’s but
Consult with relevant M&S Technologist for any add on you feel it may appeal to under 3’s then test to under 3’s as a
products, give-always, soft toys, key rings or other child precaution and consult with relevant toy technologist.
appealing items. Note: M&S small parts criteria differs from those specified in
EN71, refer to Toy standards in the Homeware Safety Manual.
Please refer to TTF / Pull Test Appendix
Small parts must meet M&S gauge criteria unless agreed with
M&S toy Technologist in exceptional circumstances.
Pens Writing and Marking Instruments
Sufficient ventilation must be allowed in pen tops ,closures and Labelling
caps to avoid asphyxiation refer to BS 7272 part 1&2 All Toys must be tested to the relevant sections of EN71 and
CE labelled in accordance with EN71 part 6
Dress Up
Those Toys not suitable for Under 3 Years must carry an
Please also refer to Kids Dress Up Safety and Performance additional warning to state this
Standards on Quality standards Website
No. Category Potential Hazard Specification Tech Notes