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Is Santa Claus Covered Under CPSIA, REACH, China GB or ASTM?


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In this topical guest article, Gary Barraco of ecVision puts a seasonal spin on the serious matter of supply chain transparency and compliance… with a little help from ol’ Saint Nick.

Twas the night before Christmas and all through the house… You have everything in place for a wonderful morning of holiday gift-giving and memories to be made.

The stockings were hung by the chimney with care… So you settle down with a mug of warm cocoa, light the log in the fireplace, and unwind from the hustle and bustle of the holiday.

When out on the lawn there arose such a clatter… I thought, “Uh, oh. What is that noise out there? Kids messing around with my 6 foot inflatable Abominable Snowman? Someone on their way home from a party?”

I sprang from [my recliner] to see what was the matter…
When I parted the curtains, I thought I was seeing things. Someone was parked in the driveway. It looked like some sort of antique sled and, really, there are animals harnessed to it.

As I drew in my head, and was turning around, Down the chimney St. Nicholas came with a bound…
Whoa! Hold on, this can’t be real. First of all, I have a nice toasty fire roaring in the colonial-sized fireplace. If someone is really coming down the chimney, this isn’t going to turn out so well. Should I call 911 now? Burglars disguised like the Jolly Old Fellow? This is going to be interesting.

He was dressed all in fur, from his head to his foot…
Just then, I see a burly man slide down the chimney as I rub my eyes wondering what is in the hot cocoa I am drinking or if I had watched too many Harry Potter movies recently. As he comes down, I see sparks flying when his boots hit the logs. If he hurries, he can make it unscathed, but with all of this magical stuff going on, maybe he has a fireproof suit anyway.

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Just then, I awoke abruptly. I had nodded asleep and this was all just a bad dream…or was it. The combination of the comforting setting along with the discussions I had earlier in the week with the Chief Supply Chain Risk Officer at work contributed to the bizarre scenario. But the hallucination got me to think about the regulatory directives from government agencies all around the world.

For instance, the United States Federal Government requires clothing and textiles intended to be used for clothing to have “Normal Flammability” as tested with 16 CFR 1610 (ASTM D 1230 Standard Test Method for Flammability of Apparel Textiles); quite a mouthful of jargon, I know. The means in which testing labs conduct this type of analysis is similar to the way Santa came down the chimney – the fabric is mounted at a 45° angle from ignition source and the rate of burn is measured.

Some exemptions apply:

  • Certain hats
  • Glove
  • Footwear
  • Interlining fabric
  • Plain surface fabrics, regardless of fiber content, weighing 2.6 oz/yd2 or more
  • Fabric made entirely with these fibers, or blends of these fibers:
    • acrylic
    • nylon
    • polyester
    • modacrylic
    • olefin
    • wool

How much of Santa’s garb would have been covered under this test protocol? According to the description of his outfit, a plush Santa Suit that features a zipper front red velveteen Santa jacket with extra wide faux fur trim and matching Santa pants with pockets. The jacket and pants come accessorized with a lined Santa hat with plush faux fur cuff, a wide belt with silver buckle, white fabric gloves, and black faux leather boot tops. Santa wig, beard, glasses, and hand bell sold separately. There are so many components that need to be tested before making this a “safe” uniform for Santa.

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In an effort to increase margins while offering customers more choice, many retailers have turned to lower priced imports. This strategy enables retailers to better manage purchasing costs but often comes with hidden costs – returns, recalls and most importantly, the potential loss of consumer confidence. With the abundance of products manufactured overseas, reduced quality control is inevitable. Everyday around the world, manufacturers, brands and retailers turn to expert testing labs with questions.

“Can we make it better, faster, more efficient and maintain the tough regulatory standards mandated by all levels and regions of government? How do we strike the balance between quality, profitability and compliance?”
Experienced retailers know that working with an experienced lab – not just for test execution, but also as an advisory team, provides a higher level of control across the supply chain. In today’s highly competitive environment, this type of relationship can offer a unique advantage to balance an efficient supply chain with increased product quality.

To assist retailers in effectively managing their suppliers, ecVision has built a data bridge through integration to many of the major testing and auditing labs. The 3rd party companies offer a complete suite of supply chain management services designed to help organizations strengthen their business operations, resulting in:

  • Reduced quality problems
  • Reduced customer complaints due to lack of quality, safety and usability
  • Increased verification of legal requirements and laws
  • Increased customer satisfaction through higher product quality, safety and performance

These experts offer a host of global services that inspect and verify product quality and performance for suppliers located around the world, before products are even shipped to the distribution network. This provides retailers with independent third-party verification that the products they sell are compliant not only with global safety requirements, but also with their own performance specifications. Through the integration of technology with ecVision Suite’s Best Practices, this area of the production process just became simplified.

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After the sparks fall and the smoke dissipates I come to realize that it was all just a dream after all. The image of Saint Nicholas making his entrance through the chimney had me wondering what it is that keeps him unharmed in the presence of a large blazing fire. Having been lost in the thought of government regulatory directives for fire and safety, it’s possible to believe that Santa’s suit had in fact been tested under the 16 CFR Part 1610 for flammability. It’s critical that materials used in apparel comply with the standards within regulation prior to resale, therefore taking precaution whether at work or home can simply reduce putting both yourself and another’s life in danger. That said I believe now it is time to put out the fire and go to bed

As I doze off once again, I have a stronger conviction that prevention is better than damage control. I will turn to the experts for help to manage the supply chain risks for my company by checking and testing for any issues, defects or hazardous chemicals before it enters the market or begin operations; avoiding recalls, brand reputation damage, health issues and even fatalities.

About the Author:
Gary Barraco is Senior Director of Product Marketing for ecVision. ecVision®, the leader in supply chain collaboration solutions for retailers and brands, is an integration partner with many of the world’s foremost product testing company with labs around the world. Together these organizations exchange data through ecVision’s cloud-based supply chain collaboration platform enabling users to seamlessly build, request and receive testing data through a single solution.
The partnership provides ecVision customers with added value when they are looking to complete product safety testing with the network of labs. The integration streamlines collaboration between development, sourcing, quality assurance and compliance teams for brands and manufacturers on products that require testing under CPSC, REACH, CA Prop 65 and other state or country regulations. ecVision users have the ability to request and store product safety tests requests and results completed by TÜV SÜD and its agents within the ecVision platform.
With direct integration to each provider, the product safety testing processes are simplified with ‘behind-the-scenes’ data push & pull. This partnership creates a more efficient means of initiating product testing requests, allows brands to maintain accurate product safety results and lower their risk across their supply chain through stronger reporting capabilities.

Ben Hanson Ben Hanson is one of WhichPLM’s top contributors. Ben has worked for magazines, newspapers, local government agencies, multi-million pound conservation projects, museums and creative publications before his eventual migration to the Retail, Footwear and Apparel industry.Having previously served as WhichPLM’s Editor, Ben knows the WhichPLM style, and has been responsible for many of our on-the-ground reports and interviews over the last few years. With a background in literature, marketing and communications, Ben has more than a decade’s worth of experience, and is now viewed as one of the industry’s best-known writers.