5. FLAMMABILITY HAZARD If Children Wear Dangerously

CHILDREN’S SAFETY ISSUES AUGUST 2010

5. FLAMMABILITY

HAZARD

If Children wear dangerously flammable fabrics and they stand by an open flame, such as a heating unit, fireplace, stove, etc., the fabric can ignite and cause serious burns.

DEFINITION

Flammability: Any garment, which fails to meet the CFR (Code of Federal Regulations), listed below: 16 CFR PART 1615- Children’s Sleepwear sizes 0 through 6X 16 CFR PART 1616- Children’s Sleepwear sizes 7 through 14 16 CFR PART 1610- General Wearing Apparel.

To obtain the latest copy of the Federal Code of Regulations contact the NPG QA or visit the CPSC web site at http://www.cpsc.gov

1. Children’s Sleepwear Part 1615 & 1616: Any product of wearing apparel sizes 0-14 for Boys and Girls as listed in the CFR such as nightgowns, pajamas, or similar related items such as robes, intended to be worn primarily for sleeping or activities related to sleeping, except: Diapers and underwear.

2. General Wearing Apparel: Any costume or article of clothing worn or intended to be worn by individuals, excludes footwear.

NORDSTROM POLICY Must meet the performance requirements listed on NPS- 1 and NPS-2 (knits) or NPS-12(wovens)

CHILDREN’S SLEEPWEAR

Children’s Sleepwear must meet stringent flammability testing requirements. The CPSC (Consumer Product Safety Commission) strictly monitors the compliance with this law in the U.S. 16 CFR Part 1615 and Part 1616 refer specifically to these testing requirements. Each requires different testing procedure:

1. Flame-Resistant garments do not continue burning when removed from an ignition source. Examples include inherently flame-resistant Polyesters that do not require chemical treatment or natural fabrics that require chemical treatment. Flame-Resistant garments must be tested according to 16 CFR Part 1615 or Part 1616 specifications.

2. Snug-Fitting garments do not need to be flame resistant because they are made to fit closely against a child’s body. Snug-fitting sleepwear does not ignite easily and, even if ignited, does not burn readily because there is little oxygen to feed a fire. Snug-Fitting garments must be tested according to 16 CFR Part 1610 specifications and does not exceed the maximum dimensions specified in table 1 located at appendix. NOTE: Long Underwear garments not intended as sleepwear must be tested according to 16 CFR Part 1610 specifications. If a garment can be construed as sleepwear, garment should also not exceed the maximum dimensions specified in table 1 located at appendix. Listed below are some of the requirements for Children’s Sleepwear. This list is in no way complete, as the United States Government is continually reviewing the flammability standards for Children’s Sleepwear. NPG Supplier Procedures Manual © 2010 Nordstrom, Inc., all rights reserved. CONFIDENTIAL: These documents contain proprietary, trade secret, and confidential information which are the property of Nordstrom, Inc. These documents and their contents may not be duplicated or disclosed to any other party without express authorization of Nordstrom, Inc. Page 1 of 9

CHILDREN’S SAFETY ISSUES AUGUST 2010

To obtain the latest copy of the Federal Code of Regulations visit the CPSC web site at http://www.cpsc.gov

CHILDREN’S SLEEPWEAR REQUIREMENTS

. Children’s Sleepwear must be tested in accordance with 16 CFR Parts 1615 and 1616. . Children’s Sleepwear flammability testing (16 CFR Part 1615 and Part 1616) is not required if the garment is classified as a “snug-fitting garment” as defined by the sizing charts provided by the CPSC (refer to table 1 located at appendix). . Compliance with 16 CFR 1610 flammability of textiles is required (as in General Wearing Apparel) if the garments meet the “snug-fitting” specifications. . Sizes that span two of the published sizes (i.e., 2-4T) must be manufactured to be less than or equal to the measurements of the smallest size (example. Size 2) to assure a snug-fitting garment (refer to appendix for sizing chart table 1 located at appendix). . Unisex sizing must be manufactured in the smaller size when comparing sizing charts for girls and boys.

Exemptions

. Diapers and Underwear . Infant Garments – As defined by CFR1615.1(C) – a garment which 1- is sized for a child that is 9 months or younger. . if a one piece garment, does not exceed 64.8 cm (25.75 inches) in length; if a two piece garment, has no piece exceeding 40 cm (15.75 inches) in length . “Tight Fitting Garments” (Measurement requirements for Tight Fitting Garments are at the end of this section)

If you are producing Children’s Sleepwear, you must contact NPG Product Integrity Department for further review of our testing program and procedures. Our record keeping and testing requirements are quite extensive. Following is a list of the testing requirements and agent/Supplier agreements. We expect all Suppliers to be familiar with and adhere to all requirements under the Flammable Fabrics Act.

To obtain the latest copy of the Federal Code of Regulations contact the NPG QA or visit the CPSC web site at http://www.cpsc.gov

LABELING REQUIREMENTS

In some cases, special labeling is required on Children’s garments to let the consumer know how the particular article of clothing is to be used. The following are guidelines for labeling related to the flammability properties of Children’s garments. These guidelines, as with any of the information included in this manual, are subject to change as the laws and regulations of the U.S. government change.

Tight-Fitting Sleepwear Hang-tag and Permanent Label:

1. Tight-fitting sleepwear Hang-tag; unpackaged garments: (sizes 0-6X & 7-14) . Must bear a label stating, “For child’s safety, garment should fit snugly. This garment is not flame resistant. Loose-fitting garment is more likely to catch fire”. . Must measure 1.5 ” x 6.25” and have text in 18 point Ariel or Helvetica font which is enclosed in a text box that measures 1” x 5.75”; . Must have a yellow background, which meets the specifications for Standard Safety Yellow as described in American National Standard ANSI Z535.1-1998 or referenced Pantone color chip-108C. The text must be in black lettering. NPG Supplier Procedures Manual © 2010 Nordstrom, Inc., all rights reserved. CONFIDENTIAL: These documents contain proprietary, trade secret, and confidential information which are the property of Nordstrom, Inc. These documents and their contents may not be duplicated or disclosed to any other party without express authorization of Nordstrom, Inc. Page 2 of 9

CHILDREN’S SAFETY ISSUES AUGUST 2010

. Must have the one side displaying only this message, and a reverse side which may display sizing information but must otherwise be blank; . Must Not have text obscured by a hole provided for attaching it to the garment . Must be prominently displayed on the garment. 1.5” FOR CHILD’S SAFETY, GARMENT SHOULD FIT SNUGLY. THIS GARMENT IS NOT FLAME RESISTANT. LOOSE-FITTING GARMENT IS MORE LIKELY TO CATCH FIRE. (Example)

6.25”

2. Tight-fitting sleepwear Hang-tag; packaged garments: (sizes 0-6X & 7-14) . Must bear a label stating, “For child’s safety, garment should fit snugly. This garment is not flame resistant. Loose-fitting garment is more likely to catch fire”. . Must have a text box that measures .75” x 3.75” and text in 11 point Arial or Helvetica. . Must have a yellow background, which meets the specifications for Standard Safety Yellow as described in American National Standard ANSI Z535.1-1998 or referenced Pantone color chip108C. The text must be in black lettering. . Must be prominently, conspicuously, and legibly labeled with the required message. . The label may be adhesive

FOR CHILD’S SAFETY, GARMENT SHOULD FIT SNUGLY. .75” THIS GARMENT IS NOT FLAME RESISTANT. LOOSE-FITTING GARMENT IS MORE LIKELY TO CATCH FIRE.

(Example) 3.75”

3. Tight-fitting sleepwear permanent label- all garments: (sizes 0-6X & 7-14) . Must bear a label stating, “Wear Snug-Fitting, Not Flame Resistant”. . Text must be printed on the front of the sizing label located on the center back of the garment and must be immediately below the size designation. . Text must be a minimum of 5 point Sans Serif font in all capital letters. . Must be set apart from other label text by a line border. . Text must be contrast with the background color of the label. . Must not be covered by any other label or tag.

WEAR SNUGFITTING

NOT FLAME RESISTENT

(Example)

Flame resistant sleepwear

Flame resistant (made from fibers that are naturally flame resistant and fabrics that chemically treated with flame retardant finish) require having the following information permanently labeled.

1. Fabric Production Unit (FPU) identification number . The fabric production unit identification shall appear in letters at least 0.4 centimeters (one-sixth of an inch) in height against a contrasting background on each label that relates to such fabric. 2. Garment Production Unit (GPU) identification number

NPG Supplier Procedures Manual © 2010 Nordstrom, Inc., all rights reserved. CONFIDENTIAL: These documents contain proprietary, trade secret, and confidential information which are the property of Nordstrom, Inc. These documents and their contents may not be duplicated or disclosed to any other party without express authorization of Nordstrom, Inc. Page 3 of 9

CHILDREN’S SAFETY ISSUES AUGUST 2010

. Each garment subject to the Standard shall bear a label with minimum dimensions of 1.3 centimeters (0.5 inch) by 1.9 centimeters (0.75 inch) containing the appropriate garment production unit identification for that garment in letters which are clear, conspicuous, and legible and in a color which contrasts with the background of the label.

REQUIRED FLAMMABILITY TESTING FOR CHILDREN’S SLEEPWEAR

In order to be in compliance with the Flammable Fabrics Act and Children’s Sleepwear Standards, as well as the Children’s Sleepwear Flammability testing requirements under the Code of Federal Regulations 16 CFR Part 1615 and Part 1616, the Supplier will be required to perform the following outlined steps.

1. Fabric Testing . Submit to one of the NPG approved test labs, four yards of each print identified by purchase order number which designates the month the item was shipped (this will act as the Fabric Production Unit # - or F.P.U. #). . Purchase order number to be no greater than 5,000 linear yards. If greater than 5,000 linear yards, you must designate a different purchase order number. . For styles that are continuous production (i.e., same print coverage), a five-yard cut will be submitted in order to perform the “after 50 launderings” performance criteria as directed by the regulations. The one-time 50 laundering criteria will be sufficient as long as no changes occur (print coverage, finish treatments, fabric structure, etc.). If no changes occur, this one-time washing sample is effective for one year. . Submit all prints or as many as possible at the same time to reduce cost of testing (color is based per wash load, not per print/pattern). . First and Last Fabric Production Unit (for production under 5,000 linear yards). Submit one full-yard width of first yardage and one full-yard width of last yardage for a singular print if the fabric lot is made up of only one roll. For lots with more than one roll, select one sample from the beginning of the first fabric roll and the end of the last roll in the fabric lot. This must be completed for every 5,000-yard increment.

2. Prototype Seam Testing . Submit two sets of one-continuous-yard seams of each type, which appears in the garment (i.e., join seams, ruffles, lace, etc.). Hems or edge bindings are exempt. . Any appliqués longer than two inches in any direction or an aggregate of 20 square inches must be tested as a prototype seam.

3. Production Garment Testing . Six garments randomly selected of each style in the largest size, properly identified as to purchase order. . One sample from each size range to be stored by the testing lab for 5 years as original in case reproduction of test results is necessary at a later date. . No purchase order number shall exceed 6,000 pieces. Anything over 6,000 pieces must be assigned a new purchase order number.

RECORD KEEPING REQUIREMENTS FOR CHILDREN’S SLEEPWEAR

1. Fabric . Written reports certifying the fabric have been tested and swatched with proper fabric. Test must reflect and make reference to purchase order number (s). . Remains of tested specimen should be included. Also, sufficient fabric must be included to reproduce the written test if necessary at Nordstrom approved lab. . Keep documents for a period of five years. NPG Supplier Procedures Manual © 2010 Nordstrom, Inc., all rights reserved. CONFIDENTIAL: These documents contain proprietary, trade secret, and confidential information which are the property of Nordstrom, Inc. These documents and their contents may not be duplicated or disclosed to any other party without express authorization of Nordstrom, Inc. Page 4 of 9

CHILDREN’S SAFETY ISSUES AUGUST 2010

2. Prototype Seams . Written report on all prototype seams identified as to the purchase order number with a swatch for identification and the tested remains of specimens and additional seam specimens to reproduce the written test if necessary at Nordstrom approved lab. . Keep documents for a period of five years.

3. Production Garments / Seams . Written report on all garments/seams identified as to the purchase order number with a swatch for identification and the tested remains of specimens as well as one untested garment in each size range to reproduce the testing if necessary at Nordstrom approved lab. . Documents are stored for 5 years at the third party Test Lab Partners.

Agent/Supplier by acceptance of this manual, hereby confirms his/her understanding of the above Children’s Sleepwear testing and record keeping requirements, and verifies that agent/Supplier will comply with all applicable sections of 16 CFR 1615/1616 as regulated by the U.S. Consumer Product Safety Commission. Agent/Supplier is required to sign additional confirmation document listed in the appendix of this manual.

NORDSTROM POLICY

GENERAL WEARING APPAREL

Children’s general wearing apparel must meet the flammability testing requirements. The Consumer Product Safety Commission (“CPSC”) strictly monitors the compliance with this law in the U.S. The United States Code of Federal Regulations, 16 CFR Part 1610, refer specifically to these testing requirements. The following are examples related to the flammability properties of Children’s general wearing garments. These examples, as with any of the information included in this manual, are subject to change as the laws and regulations of the U.S. government change.

. Any general wearing garment considered other than Children’s Sleepwear . Any Infant garments which are sized for a child that is nine (9) months or younger as defined by CFR 1615.1, including Children’s Sleepwear. . Any Children’s Sleepwear garment classified as “Snug Fitting” (to assure a measurement of snug-fitting garment, refer to appendix for sizing chart table 1 located at appendix.) . All long underwear garments not intended as sleepwear. . Beach Cover-ups 1. Must be marketed for use at the beach or swimming pool. Hem must be at least 2 inches above the knee unbelted. No shrinkage compensation allowed. 2. Beach cover-ups must have a permanently attached label located at the center back of the garment stating “For beach and pool use only- do not use as a bathrobe. Does not comply with flammability standards applicable for sleepwear.” Note this tag has no CPSC regulations. Please contact NPG Quality Assurance for specifications.

FOR BEACH AND POOL USE ONLY- DO NOT USE AS A BATHROBE. DOES NOT COMPLY WITH FLAMMABILITY STANDARDS APPLICABLE FOR SLEEPWEAR (Example)

CHILDREN’S SAFETY ISSUES AUGUST 2010

3. Must be sold at least 2 fixtures (approximately 10’) away from Children’s sleepwear. 4. Must meet the performance requirements for general wearing flammability 16 CFR 1610.

The General Wearing Apparel must meet the performance requirements for flammability listed in NPS-1 (located at appendix). Nordstrom only accepts class 1, normal flammability as stated in 16 CFR PART 1610.

To obtain the latest copy of the Federal Code of Regulations contact the NPG QA or visit the CPSC web site at http://www.cpsc.gov

Party Responsible (For all Flammability Testing; Children’s Sleepwear, Beachwear, Snug- Fitting, Fabric, Seams, Garments) . Nordstrom Product Group Kids Brand and/or Technical Design Team are responsible for Design and Spec Pack that conforms to Nordstrom Policies. . Supplier is responsible for meeting Federal Code of Regulations 16 CFR Part 1615/1616 and Part 1610 flammability testing and ensuring that products have been tested for flammability at an accredited lab, using a reasonable and representative sampling. . Supplier/Agent is responsible for submitting testing to the Nordstrom-approved lab along with proper submit information (i.e., purchase order numbers, style number, construction details, finish, etc.) . Third-party Nordstrom approved lab, at the direction of Nordstrom will keep remains of tested samples for five years. . Agent QC/Direct Supplier is responsible for auditing in-line and final inspections making sure the garments conform to Nordstrom’s policies, and there is a passing test report, prior to shipment. . Nordstrom Product Group, Product Integrity is responsible for keeping testing documents for 5 years.

CHILDREN’S SAFETY ISSUES AUGUST 2010

Maximum Dimension Sizing Chart For Tight Fitting Children’s Sleepwear (sizes 0-6x) Chest Waist Seat Upper Arm Thigh Wrist Ankle

Size 9-12 months Maximum Dimensions: Centimeters 48.3 48.3 48.3 14.3 26.7 10.5 13 Inches 19 19 19 5 5/8 10 1/2 4 1/8 5 1/8

Size 12-18 months Maximum Dimensions: Centimeters 49.5 49.5 50.8 14.9 28.3 10.5 13.1 Inches 19 1/2 19 1/2 20 5 7/8 11 1/8 4 1/8 5 1/8

Size 18-24 months Maximum Dimensions: Centimeters 52.1 50.8 53.3 15.6 29.5 11 13.6 Inches 20 1/2 20 21 6 1/8 11 5/8 4 1/4 5 3/8

Size 2 Maximum Dimensions: Centimeters 52.1 50.8 53.3 15.6 29.8 11.4 14 Inches 20 1/2 20 21 6 1/8 11 3/4 4 1/2 5 1/2

Size 3 Maximum Dimensions: Centimeters 53.3 52.1 56 16.2 31.4 11.7 14.9 Inches 21 20 1/2 22 6 3/8 12 3/8 4 5/8 5 7/8

Size 4 Maximum Dimensions: Centimeters 56 53.3 58.4 16.8 33 12.1 15.9 Inches 22 21 23 6 5/8 13 4 3/4 6 1/4

Size 5 Maximum Dimensions: Centimeters 58.4 54.6 61 17.5 34.6 12.4 16.8 Inches 23 21 1/2 24 6 7/8 13 5/8 4 7/8 6 5/8

Size 6 Maximum Dimensions: Centimeters 61 55.9 63.5 18.1 36.2 12.7 17.8 Inches 24 22 25 7 1/8 14 1/4 5 7

Size 6X Maximum Dimensions: Centimeters 62.9 57.2 65.4 18.7 37.8 13 18.7 Inches 24 3/4 22 1/2 25 3/4 7 3/8 14 7/8 5 1/8 7 3/8

Note: Maximum dimensions are calculated by placing the garment on a horizontal, flat surface with the outer surface of the garment exposed, measuring the distance between the points specified below; and multiplying that value by two: . Chest - measure distance from arm pit to arm pit. . Waist - on one-piece garment, measure at the narrowest location between arm pits and crotch. On two-piece garment, measure width at the bottom of the upper piece, and the top of the lower piece. . Seat - on one-piece garment, measure at widest location between waist and crotch. On two-piece garment, take this measurement on lower piece only. . Upper Arm - measure at a line perpendicular to the sleeve. Extending from the outer edge of the sleeve to the arm pit. . Wrist - Measure the width of the end of the sleeve, if intended to extend to the wrist . Ankle - Measure the width of the of the leg, if intended to extend to the ankle

CHILDREN’S SAFETY ISSUES AUGUST 2010

Maximum Dimension Sizing Chart For Tight Fitting Children’s Sleepwear (sizes 7-14) Chest Waist Seat Upper Arm Thigh Wrist Ankle

Size 7 BOYS Maximum Dimensions: Centimeters 63.5 58.4 66 18.7 37.2 13.0 18.7 Inches 25 23 26 7 3/8 14 5/8 5 1/8 7 3/8

Size 7 GIRLS Maximum Dimensions: Centimeters 63.5 58.4 67.3 18.7 38.7 13.0 18.7 Inches 25 23 26 ½ 7 3/8 15 1/4 5 1/8 7 3/8

Size 8 BOYS Maximum Dimensions: Centimeters 66 59.7 67.3 19.4 38.4 13.3 19.1 Inches 26 23 ½ 26 ½ 7 5/8 15 1/8 5 ¼ 7 ½

Size 8 GIRLS Maximum Dimensions: Centimeters 66 59.7 71.1 19.4 41.3 13.3 19.1 Inches 26 23 ½ 28 7 5/8 16 ¼ 5 ¼ 7 ½

Size 9 BOYS Maximum Dimensions: Centimeters 68.6 61.0 69.2 20 39.7 13.7 19.4 Inches 27 24 27 ¼ 7 7/8 15 5/8 5 3/8 7 5/8

Size 9 GIRLS Maximum Dimensions: Centimeters 68.6 61.0 73.7 20 42.6 13.7 19.4 Inches 27 24 29 7 7/8 16 ¾ 5 3/8 7 5/8

Size 10 BOYS Maximum Dimensions: Centimeters 71.1 62.2 71.1 20.6 41.0 14 19.7 Inches 28 24 ½ 28 8 1/8 16 1/8 5 ½ 7 ¾

Size 10 GIRLS Maximum Dimensions: Centimeters 71.1 62.2 76.2 20.6 43.8 14 19.7 Inches 28 24 ½ 30 8 1/8 17 ¼ 5 ½ 7 ¾

Size 11 BOYS Maximum Dimensions: Centimeters 73.7 63.5 73.7 21 42.2 14.3 20 Inches 29 25 29 8 ¼ 16 5/8 5 5/8 7 7/8

Size 11 GIRLS Maximum Dimensions: Centimeters 73.7 63.5 78.7 21 45.1 14.3 20 Inches 29 25 31 8 ¼ 17 ¾ 5 5/8 7 7/8

Size 12 BOYS Maximum Dimensions: Centimeters 76.2 64.8 76.2 21.6 43.5 14.6 20.3 Inches 30 25 ½ 30 8 ½ 17 1/8 5 ¾ 8

CHILDREN’S SAFETY ISSUES AUGUST 2010

Maximum Dimension Sizing Chart For Tight Fitting Children’s Sleepwear (7-14 continued) Chest Waist Seat Upper Arm Thigh Wrist Ankle

Size 12 GIRLS Maximum Dimensions: Centimeters 76.2 64.8 81.3 21.6 46.7 14.6 20.3 Inches 30 25 ½ 32 8 ½ 18 ½ 5 ¾ 8

Size 13 BOYS Maximum Dimensions: Centimeters 78.7 66 78.7 22.2 44.8 14.9 20.6 Inches 31 26 31 8 ¾ 17 5/8 5 7/8 8 1/8

Size 13 GIRLS Maximum Dimensions: Centimeters 78.7 66 83.8 22.2 47.6 14.9 20.6 Inches 31 26 33 8 ¾ 18 ¾ 5 7/8 8 1/8

Size 14 BOYS Maximum Dimensions: Centimeters 81.3 67.3 81.3 22.9 46 15.2 21 Inches 32 26 ½ 32 9 18 1/8 6 8 ¼

Size 14 GIRLS Maximum Dimensions: Centimeters 81.3 67.3 86.4 22.9 49.5 15.2 21 Inches 32 26 ½ 34 9 19 ½ 6 8 ¼

For more information about sizing and ruling see the CPSC web site at www.cpsc.gov