Investigation Guildelines

INVESTIGATION GUIDELINE

Appendix 23A
11/23/1999
CHILDREN'S WEARING APPAREL
I.

INTRODUCTION

A. Background
Currently there are two flammability standards in effect
for children's sleepwear, one for sizes 0 through 6X, the
other for sizes 7 through 14. Both standards require that
test specimens must self-extinguish when exposed to a small
open-flame ignition source. Both standards also require
manufacturers of sleepwear garments to perform prototype
tests on specimens of fabric, seams, and trim with
acceptable results before beginning production of sleepwear
garments. Additionally, both standards require
manufacturers of sleepwear fabrics and garments to select
samples from production and to obtain passing results from
flammability testing of those samples before introducing
those fabrics or garments into interstate commerce. The
standard does not apply to shoes, gloves, and hats.
CPSC amended the sleepwear flammability standards in 1996.
As a result, infant garments sized nine months or smaller
and tight fitting sleepwear garments for older children are
now exempt from the flammability standards.
CPSC has experienced difficulties in enforcing the
sleepwear flammability standards. The marketplace has
changed substantially since the original children’s
sleepwear standards went into effect. Today, some children
are sleeping in T-shirts or clothing marketed as playwear
or underwear. A precise definition as to what qualifies as
sleepwear has contributed to the difficulty in the
enforcement of sleepwear standards.
Although the standards specifically apply to sleepwear
garments, ignition incidents of all types of clothing for
children under age 15 should be investigated. Clothing
ignition cases, as well as cases in which clothing melted
or smoldered are of interest. Determining whether the
garment fit the victim loosely or tightly is crucial.

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INVESTIGATION GUIDELINE
B. Study Purpose
The purpose of this data collection is to obtain
information about clothing fire and burn injuries to
children younger than age 15. Of particular interest is
clothing being worn as sleepwear. The data will be used to
gather information regarding the impact of the amended
standards and to learn more about the range of children’s
clothing involved in fires.
C. Product Description
This guideline applies to incidents involving the ignition,
melting, or smoldering of all wearing apparel items worn by
children under 15 years of age, excluding shoes, gloves,
and hats.
D. Specific Items of Interest
1) Description of the garment(s) involved including
material, labeling, age, manufacturer, and if the
garment was used for sleeping. Especially of interest
are incidents in which articles of clothing marketed as
daywear, such as T-shirts, sweatsuits, leggings, and
underwear, are being used as sleepwear.
2) Description of the fit of the garment(s) on the victim.
Whether or not the garment fit the victim snugly (worn
fitting tightly against the child’s body) or if it was
loose fitting (a roomier fit; not close against the
child’s skin).
3) Description of how the garment burned and the extent of
the injuries to the victim. Indicate whether there was
ignition or only melting or smoldering.
4) Collect the entire garment(s) or as much of it as
possible.
E. Headquarters Contacts
Debra Ascone, EPHA
(301) 504-7403
Marilyn Borsari, CRC (301) 504-7619
Margaret Neily, ESFS (301) 504-7530

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[email protected]
[email protected]
[email protected]

INVESTIGATION GUIDELINE
II.

INSTRUCTIONS FOR COLLECTING SPECIFIC INFORMATION

A. Synopsis
Describe the ignition, smoldering, or melting incident, the
age of victim, and the injuries incurred. Describe the
garment the victim was wearing and the manner in which it
burned.
For computer data retrieval, please use the following key
words as appropriate: sleepwear, snug fit, loose fit,
daywear, pajamas, long sleeved, short sleeved, blanket
sleeper, T-shirt, underpants, robe, dress, blouse, shirt,
sweatshirt, sweatpants, leggings, long underwear,
nightgown, jeans, sweater.
B. Data Record Sheet
The data record sheet is provided as a check-list for onsite investigations to ensure that all the required
elements are covered by the investigator. The incident
environment narrative is important since the data record
sheet is not all-inclusive.
C. Telephone Questionnaire
If the garment is not available for collection, conduct a
telephone interview using the telephone questionnaire.
Again, the narrative portion of the telephone questionnaire
in which the incident environment is described in detail is
important since the questions in the questionnaire are not
all-inclusive.
D. Description of Incident Environment
Pre-Incident
Describe the environment in which the incident occurred.
Describe the garment(s) that smoldered, ignited, or melted
in the incident. Report how frequently the garment involved
in the incident was worn for sleeping. Report the size of
the garment and the approximate height and weight of the
victim at the time of the incident. Describe the fit of the
garment on the victim. Specify the age of the child at the
time of the incident (if the child is less that 2 years
old, please record the age in months).

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INVESTIGATION GUIDELINE

Incident
Determine the source of ignition (or melting or smoldering)
and describe in detail how it occurred (e.g., dropped a
match in lap, ignited sleeve on stove burner, etc.). Report
the involvement of any flammable liquids, including a
description of the type, approximate amount, and how it was
involved.
Record the time of the incident.
witnessed the incident.

Determine if anyone

Post-Incident
Indicate how the fire was extinguished. Determine if the
fire department arrived. If the fire department was
involved, obtain the fire department’s report.
Describe the medical care administered as a result of the
incident. Report the type and extent of injury, treatment
and long term prognosis for the victim.
E. Description of Injured Child and Product Interaction
Note what part of the garment ignited, smoldered, or melted
first. Describe how the garment burned (e.g., surface
flash; melted and dripped on the victim; etc.). If multiple
garments were involved, determine the order that the
garments ignited (e.g., pants then shirt; shirt then Tshirt; etc.).
Describe the actions of the victim upon discovering that
the clothing was on fire (e.g., dropped and rolled, ran to
another location, tried to pat flames out, tried to remove
clothing, etc.).
Determine if the victim was under the influence of alcohol,
medication, or any other drugs at the time of the incident.
Determine if the victim suffered from any physical
infirmities that may have contributed to the cause of the
incident or hindered quick reaction to the burning
clothing.

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INVESTIGATION GUIDELINE
F. Description of Product
Describe in detail the garments that smoldered, melted, or
ignited in the incident. Identify the material that the
garment was made of and the source used to make that
determination. Determine if the fabric was a knit or a
woven textile. Describe the extent of the damage to the
garment.
Report the wording of any labels on the garment(s),
including fiber content, care instructions, size, FTC
registration numbers (RNS and WPLS), etc. Indicate the
manufacturer, age, and laundering history of the garment.
Indicate when and where the garment was purchased.
Provide as specific information as possible about the fit
of the garment on the child involved in the incident (snug
or loose). For example, knit pajamas that are manufactured
to fit snugly (i.e. tight against a child’s body) may be
loose fitting if several sizes too large for the child who
is actually wearing them.
G. Product Safety Standards
The Commission administers two mandatory standards, issued
under section 4 of the Flammable Fabrics Act, 15 U.S.C.
1193, that prescribe flammability tests for children’s
sleepwear garments and fabrics intended for use in
children’s sleepwear. The first, issued in 1971 by the
Department of Commerce, covers children’s sleepwear in
sizes 0 through 6X (16 CFR Part 1615). After responsibility
for administration and enforcement of the FFA was
transferred to CPSC, the Commission issued a flammability
standard for children’s sleepwear in sizes 7 through 14 (16
CFR Part 1616). The amendment to exempt infant sleepwear in
sizes 9 months or smaller and tight fitting sleepwear from
the standard was issued on September 9, 1996 (16 CFR Part
47634).
The standard for the flammability of clothing textiles, CFR
1610, details the flammability standard for general wearing
apparel.

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INVESTIGATION GUIDELINE
III. INSTRUCTIONS FOR PHOTOGRAPHING AND/OR DIAGRAMMING
INCIDENT SCENE AND FACTORS RELATED TO THE INCIDENT
SEQUENCE
Include a photograph, or diagram of the garment, indicating
where ignition, melting or smoldering first occurred and/or
what part of the garment was sampled. If photographs are
taken, please include a view of any labeling present on the
garment. Indicate the body surface injured in the incident
on the body diagram at the end of the data record sheet.
IV.

INSTRUCTIONS FOR OBTAINING SAMPLES AND DOCUMENTS
RELATED TO INVESTIGATION

Obtain a copy of the fire incident report, casualty
reports, and any other fire department investigative
reports of the incident. Obtain copies of any insurance or
engineering report on fire cause and circumstances
involved. Obtain a summary of medical records if an injury
or death occurred.
Attempt to collect the entire garment or as large a sample
as possible, in order to provide enough fabric for testing.
Indicate from what part of the garment the sample was
obtained.
Contact Marilyn Borsari if it is possible to purchase new
garments identical to the item(s) of clothing that burned.
Mail the sample and a copy of the accompanying Sample
Collection Report (form 166) to the sample custodian, to
the attention of Debra Ascone, EPHA. On the sample
collection form, please specify the investigation task
number.

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INVESTIGATION GUIDELINE

CHILDREN'S WEARING APPAREL
Data Record Sheet

Task Number: ____________________
Incident Date: __________________

1. What was the age and the approximate height and weight
of the child when the incident occurred?
______years ______ months; age (in months if age < 2 years)
______height
______weight
2. What was the extent of the injury (how serious were the
burns suffered, how much body surface area was burned,
etc.)?_____________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
3. Was the victim hospitalized?____________________________
4. What did the victim do upon discovering that the
clothing had ignited?
______ran to another location
______tried to pat flames out
______tried to remove clothing
______dropped and rolled
______other (specify)______________________________________
5. Did the victim suffer from any sort of physical
infirmity that may have contributed to the incident or
reduced reaction time?
g
______yes (specify)________________________________________
______no
6. Was the victim under the influence of medication or any
other drugs at the time of the incident?
______yes (specify)________________________________________
______no

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INVESTIGATION GUIDELINE
7. What type of garment ignited/smoldered/melted?
______infant wear
______sleeper
______playwear
______underwear (undershirt, onesies – snap under
the crotch to stay in place)
______diaper
______other (specify)____________________________
______blanket sleeper
______T-shirt
______daywear
______underwear
______pants
______jeans
______underpants
______robe
______dress
______blouse
______shirt
______sweater
______sweatshirt
______sweatpants
______leggings
______long underwear
______printed/decorated
______undecorated
______nightgown
______pajama top
______short sleeves
______long sleeves
______pajama bottom
______short bottoms
______long bottoms
______other (specify)________________________
8. How frequently did the victim sleep in this garment?
______usually
______sometimes
______never
______unknown
9. What was the garment made of?
______100 percent cotton
______cotton blend
______synthetic
______other (specify)______________________________
______unknown

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INVESTIGATION GUIDELINE

10. How did you determine what the garment was made of?
______from the tag
______from memory of victim or bystander
______from general knowledge of fabrics
______other (specify)___________________________
Report wording of tag if available:________________________
___________________________________________________________
11. Was the fabric knit or woven?
______knit (fabric formed by interlooping yarns)
______woven (fabric formed by interlacing two yarns)
______unknown
12. How would you describe the fit of the garment?
______snug fitting
______loose fitting
(give short explanation of the fit) ______________________
___________________________________________________________
13. What was the size of the garment? ______unknown
___________________________________________________________
14. Who was the manufacturer of the garment? ______unknown
___________________________________________________________
15. How old was the garment?
______first time wearing it
______at most one year old
______more than one year old
______unknown
16. When and where was the garment purchased? ______unknown
___________________________________________________________
17. Had the garment been laundered or dry cleaned prior to
the incident?
______yes
______laundered (approximate number of times)
______dry cleaned (approximate number of times)
______no
______unknown
18. What part of the garment ignited first (e.g., sleeve of
a shirt, hem of a dress)? ______unknown
___________________________________________________________
___________________________________________________________

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INVESTIGATION GUIDELINE
19. How did the garment burn?
______surface flash
______rapidly spreading fire
______melted and dripped
______smoldered
______other (specify)______________________________________
20. What was the source of ignition?
______stove (cooking) burner; if so, what type of stove?
______gas
______wood-burning
______electric
______space heater; if so, what type of space heater?
______electric
______kerosene
______gas
______wood-burning
______other (specify) ___________________
______match
______cigarette
______lighter
______fireplace
______candle
______other; (specify)___________________
21. Were any flammable liquids involved (e.g., gasoline or
lighter fluid)?
______yes (specify kind and amount)________________________
_________________________________________________
______no
______unknown
22. At what time did the incident occur? (Give approximate
hour, including a.m. or p.m.) ______unknown
___________________________________________________________
23. Where did the incident occur?
______kitchen
______living room/family room
______dining room
______bathroom
______bedroom
______other (specify)______________________________________
24. Did anyone witness the incident?
______yes (age and relationship)___________________________
______no

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INVESTIGATION GUIDELINE
25. How was the fire extinguished?
✔
______water
✔
______fire
extinguisher
✔
g
______other
(specify)______________________________________
______________________________________________________
g
26. Did the fire department arrive?
✔
______yes
✔
______no
27. Was a sample collected?
Sample number_______________________________________
g

Diagram the Body Surface Injured

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INVESTIGATION GUIDELINE

Telephone Questionnaire
Children's Wearing Apparel
Task Number: ____________________
Incident Date: __________________
1. Please tell me how the accident happened and what injury
the victim received. ____________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________

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INVESTIGATION GUIDELINE
I WOULD LIKE TO VERIFY WITH YOU THE FOLLOWING INFORMATION
ABOUT THE INCIDENT. IF I ASK YOU SOMETHING THAT YOU HAVE
ALREADY TOLD ME, PLEASE CONFIRM IT ONCE MORE.

2. What was the age and the approximate height and weight
of the child when the incident occurred?
______years ______months; age (in months if age < 2 years)
______height
______weight
3. What was the extent of the injury (how serious were the
burns suffered, how much body surface area was burned,
etc.)? ____________________________________________________
___________________________________________________________
___________________________________________________________
___________________________________________________________
4. Was the victim hospitalized? ___________________________
5. What did the victim do upon discovering that the
clothing had ignited?
______ran to another location
______tried to pat flames out
______tried to remove clothing
______dropped and rolled
______other (specify)______________________________________
___________________________________________________________
6. Did the victim suffer from any sort of medical condition
that may have contributed to the incident or reduced
reaction time?
______yes (specify)________________________________________
______no
7. Was the victim under the influence of medication or any
other drugs at the time of the incident?
______yes (specify)________________________________________
______no
8. How frequently did the victim use this garment for
sleeping?
______usually
______sometimes
______never
______unknown

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INVESTIGATION GUIDELINE
NOW I WOULD LIKE TO ASK ABOUT THE CLOTHING THAT PRODUCED
THE INJURY.

9. What type of garment ignited/smoldered/melted?
______infant wear
______sleeper
______playwear
______underwear (undershirt, onesies – snap under
the crotch to stay in place)
______diaper
______other
______blanket sleepers
______T-shirt
______daywear
______underwear
______pants
______jeans
______underpants
______robe
______dress
______blouse
______shirt
______sweater
______sweatshirt
______sweatpants
______leggings
______long underwear
______printed/decorated
______undecorated
______nightgown
______pajama top
______short sleeves
______long sleeves
______pajama bottom
______short bottoms
______long bottoms
______other (specify)________________________
10. What was the garment made of?
______100 percent cotton
______cotton blend
______synthetic
______other (specify)______________________________
______unknown

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INVESTIGATION GUIDELINE
INTERVIEWER: IF THE ANSWER TO QUESTION 10 IS “UNKNOWN,”
SKIP TO QUESTION 12.

11. How did you determine what the garment was made of?
______from the tag
______from memory of victim or bystander
______from general knowledge of fabrics
______other (specify)
Report wording of tag if available:________________________
___________________________________________________________
___________________________________________________________
12. Was the fabric knit or woven?
______knit (fabric formed by interlooping yarns)
______woven (fabric formed by interlacing two yarns)
______unknown
13. How would you describe the fit of the garment?
______snug fitting
______loose fitting
(give short explanation of the fit)________________________
___________________________________________________________
14. What was the size? __________________________
______unknown
15. Who was the manufacturer?______________________________
______unknown
16. How old was the garment?
______first time wearing it
______at most one year old
______more than one year old
______unknown
17. When and where was the garment purchased? _____________
___________________________________________________________
______unknown
18. Had the garment been laundered or dry cleaned prior to
the incident?
______yes
______laundered (approximate number of times)
______dry cleaned (approximate number of times)
______no
______unknown

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INVESTIGATION GUIDELINE

19. What part of the garment ignited first (e.g., sleeve of
a shirt, hem of a dress)?__________________________________
___________________________________________________________
___________________________________________________________
20. How did the garment burn?
______surface flash
______rapidly spreading fire
______melted and dripped
______smoldered
______other (specify)______________________________________

NOW I WOULD LIKE TO ASK ABOUT THE SOURCE OF THE FIRE.

21. What was the source of ignition?
______stove (cooking) burner; if so, what type of stove?
______gas
______wood-burning
______electric
______space heater; if so, what type of space heater?
______electric
______kerosene
______gas
______wood-burning
______other (specify) ___________________
______match
______cigarette
______lighter
______fireplace
______candle
______other (specify)___________________
22. Were any flammable liquids involved (e.g., gasoline or
lighter fluid)?
______yes (specify kind and amount)________________________
_________________________________________________
______no
______unknown
23. At what time did the incident occur? (Give approximate
hour, including a.m. or p.m.) _____________________________
___________________________________________________________
______unknown

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INVESTIGATION GUIDELINE
24. Where did the incident occur?
______kitchen
______living room
______dining room
______bathroom
______bedroom
______other (specify)______________________________________
25. Did anyone witness the incident?
______yes (age and relationship)___________________________
______no
26. How was the fire extinguished?
______water
______fire extinguisher
______other (specify)______________________________________
27. Did the fire department arrive?
______yes
______no
INTERVIEWER: THANK PERSON AND END INTERVIEW.
Diagram the Body Surface Injured

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