Consumer Product Safety Commission: Consumer Education Efforts for Revised Children's Sleepwear Safety Standard

Published by the Government Accountability Office on 1999-06-09.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                  United States General Accounting Office

GAO               Report to Congressional Committees

June 1999
                  CONSUMER PRODUCT
                  SAFETY COMMISSION
                  Consumer Education
                  Efforts for Revised
                  Children’s Sleepwear
                  Safety Standard

      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Health, Education, and
      Human Services Division


      June 9, 1999

      The Honorable Christopher Bond
      The Honorable Barbara A. Mikulski
      Ranking Minority Member
      Subcommittee on Veterans’ Affairs, HUD,
        and Independent Agencies
      Committee on Appropriations
      United States Senate

      The Honorable James T. Walsh
      The Honorable Alan B. Mollohan
      Ranking Minority Member
      Subcommittee on Veterans’ Affairs, HUD,
        and Independent Agencies
      Committee on Appropriations
      House of Representatives

      Reports of children having been severely burned when their pajamas or
      nightgowns caught fire led to the 1972 federal safety standards that
      required all children’s sleepwear to be flame resistant. In 1996, the
      Consumer Product Safety Commission (CPSC) amended the standards to
      permit the marketing of non-flame-resistant cotton garments as sleepwear
      if such garments met prescribed requirements that they be snug fitting.
      Snug-fitting sleepwear is considered safe by CPSC because it reduces the
      possibility of coming in contact with an ignition source and, if it does,
      allows little air to be trapped between the skin and the clothing to fuel
      combustion.1 While CPSC’s decision was praised by some industry and
      consumer advocates as a way to safely expand consumer choice for
      children’s sleepwear, some fire protection groups and other health and
      safety advocates expressed concern that if consumers replaced the
      traditional flame-resistant sleepwear with the snug-fitting cotton
      sleepwear, the number of children injured could increase.

      Because correct size selection is important to the effective use of
      snug-fitting sleepwear—and many parents may not be aware of sleepwear

       Sleepwear is considered snug-fitting under this standard if it follows prescribed measurements to
      ensure that the garment touches a child’s body at seven crucial points: the chest, waist, seat, thigh,
      ankle, wrist, and upper arm. In addition to allowing the sale of snug-fitting non-flame-resistant
      sleepwear, the standards exempt all infant sleepwear sizes 9 months or under from flame-resistant

      Page 1                                   GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

                       standards in general—CPSC undertook efforts to educate consumers on the
                       new standard. CPSC worked with industry groups, such as the American
                       Apparel Manufacturers Association (AAMA), to voluntarily provide in-store
                       point-of-sale information when consumers make their purchase decisions.
                       The fiscal year 1999 appropriations act covering CPSC and its
                       accompanying conference report directed us to examine the type and
                       extent of consumer education that occurred since the revised standard
                       went into effect in January 1997.

                       We examined three voluntary point-of-sale practices that CPSC and others
                       recognize as important for informing consumers about the new standard:

                   •   removable information labels, called hangtags, on sleepwear garments;
                   •   signs or educational brochures to inform consumers about children’s
                       sleepwear safety standards; and
                   •   display of children’s sleepwear separately from other types of children’s

                       This report follows our report on children’s burn injury information,
                       issued April 1999 also in response to the congressional mandate.2 In that
                       report, we concluded that sufficient data are not available to measure
                       changes, if any, in the number of burn injuries associated with children’s
                       sleepwear before and after CPSC amended its standards.3

                       Our findings for this report are based on shopping visits to 70 retail stores
                       in 14 metropolitan areas across the nation. Our methodology did not
                       include an assessment of the extent that the presence or absence of
                       point-of-sale information or practices changed consumer behavior or
                       affected the rate of burn injuries to children. Appendix I describes our
                       scope and methodology in more detail. We did our work between January
                       and June 1999 in accordance with generally accepted government auditing

                       As a result of cooperative efforts among CPSC, children’s sleepwear
Results in Brief       manufacturers, and retailers, progress has been made in making
                       point-of-sale information on sleepwear safety standards available to

                        The Congress directed CPSC to determine by July 1, 1999, whether to revoke, maintain, or modify its
                       earlier decision. At the same time, the Congress directed us to develop information that would help in
                       this deliberation.
                       See Consumer Product Safety Commission: Injury Data Insufficient to Assess the Effect of the
                       Changes to the Children’s Sleepwear Safety Standard (GAO/HEHS-99-64, Apr. 1, 1999).

                       Page 2                                  GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

             consumers. We found in our shopping sample that informational
             hangtags—the most prevalent form of consumer education material
             available—were used in about 73 percent of various brand selections of
             snug-fitting garments.

             However, the full range of suggested point-of-sale practices has not been
             widely used. Fewer than 16 percent of the stores we visited displayed
             either consumer education brochures or signs about sleepwear safety
             requirements. Also, about 63 percent of the stores displayed other
             clothing, such as cotton long underwear and loose-fitting cotton T-shirts,
             on racks with sleepwear—a practice that has been shown to cause
             consumer confusion.

             Manufacturers and retailers told us that a primary reason that they had not
             been more aggressive in offering consumer information was the uncertain
             future of the standards. Because the standards that enabled snug-fitting
             sleepwear to be marketed could be revised or revoked, the expenditure of
             additional resources on education efforts relative to this product did not
             make good business sense.

             CPSC was established in 1972 under the Consumer Product Safety Act (P.L.
Background   92-573) to regulate consumer products that pose an unreasonable risk of
             injury, to assist consumers in using products safely, and to promote
             research and investigation into product-related deaths, injuries, and
             illnesses. CPSC has the authority to issue regulations that establish
             performance or labeling standards for consumer products. Although CPSC
             has broad regulatory powers, much of its efforts are carried out using
             nonregulatory methods. CPSC often assists in the development or
             improvement of voluntary efforts to address product hazards such as
             providing safety information to consumers.

             Before CPSC was established, the Department of Commerce implemented a
             specific flammability standard for children’s sleepwear.4 This standard
             required that fabrics used for children’s sleepwear self-extinguish when
             exposed for 3 seconds to a small open flame. The standard did not
             prescribe specific fabrics or require flame-retardant treatments. Some
             fabrics, mostly polyester, generally could meet the requirement without
             treatment; others, mostly cotton, would do so only if treated with a
             flame-retardant chemical. Because of the potential carcinogenic nature of

              Commerce’s 1972 sleepwear standard covered only sizes up to size 6x; in 1975, CPSC extended the
             children’s sleepwear standard to sizes 7 through 14.

             Page 3                                GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

one treatment chemical in use in the 1970s, polyester became the
manufacturers’ fabric of choice in producing children’s sleepwear.

In the 1980s, however, many consumers began to demand natural fibers,
such as cotton, for children’s sleepwear. To meet this demand, retailers
began stocking cotton and cotton-blend long underwear sets that were not
subject to CPSC’s flammability standard for children’s sleepwear.
Sometimes these sets were intermingled with flame-resistant sleepwear on
children’s sleepwear racks. CPSC compliance staff, consumer groups, and
industry sources agreed that, in this environment, enforcing the standard
had become difficult and required a significant amount of agency

In 1991, CPSC began reexamining the children’s sleepwear standard. In
April 1996, two of the three CPSC Commissioners voted to amend the
children’s sleepwear standards to exempt snug-fitting sleepwear and all
infants’ clothing up to size 9 months from the flame-resistant
requirements.5 Snug-fitting sleepwear garments meeting the revised
standards were made widely available to consumers during the fall 1998
selling season.

While the revised standard did not include consumer education
requirements, such as additional permanent garment tags, CPSC recognized
the need for consumer education during deliberations about the new
standards. To address this need, CPSC has issued three press releases and
one video news release to inform consumers about the new sleepwear
standards and to warn consumers against using loose-fitting cotton
garments as sleepwear.6 According to CPSC, its press releases were sent to
over 1,200 media sources and its video release was broadcast over 200
times by local television stations for an estimated audience of 13 million

In voting for the standards, one Commissioner specifically outlined the
importance of providing visible point-of-sale information to remind
consumers of the purpose of the standards, and of separating the displays

 The two Commissioners supporting the amendment contended that the snug-fitting sleepwear would
provide a safe sleepwear alternative for consumers who want cotton garments. The Commissioner
opposed to the amendment argued that the snug-fitting sleepwear could increase injuries if more
consumers use it to replace traditional flame-resistant sleepwear and purchase it in larger sizes to
increase comfort and to allow a child to grow into the garment.
 According to CPSC, loose-fitting T-shirts or other oversized clothes are the most hazardous garments
for children to sleep in because they can easily come in contact with small open flames and, once
ignited, they will burn rapidly.

Page 4                                 GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

                           of complying sleepwear from other clothing to avoid confusion. However,
                           because CPSC has limited funding available for consumer education, it has
                           worked with the apparel industry to promote voluntary point-of-sale

                           In proposing the new standard, CPSC had planned on requiring permanent
Information Hangtags       consumer information labels on garments. However, the apparel industry
Used on Most               was strongly opposed to the mandatory labeling requirement and agreed
Children’s Sleepwear       to use a removable label, such as a hangtag, to provide the point-of-sale
                           information. Thus, the standards were passed with the understanding that
                           the industry would voluntarily undertake an information and education
                           campaign. At the 70 stores that we visited, we found overall that garment
                           hangtags were the most common form of point-of-sale information
                           available to consumers.

                           As the primary trade organization representing about 85 percent of the
                           apparel wholesale industry, AAMA worked with CPSC to design a consumer
                           education hangtag and made it available to manufacturers and importers
                           for use in packaging their products. The AAMA hangtag includes

                       •   artwork to identify garments as sleepwear,
                       •   a statement that explains the importance of fabric and fit in children’s
                           sleepwear and that sleepwear should be flame-resistant or snug-fitting to
                           meet CPSC’s requirements, and
                       •   whether a garment is flame-resistant or should be worn snug-fitting (see
                           fig. 1).

                           Page 5                       GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

Figure 1: Sample of AAMA Garment
Hangtag Design for Snug-Fitting

                                   During our store visits, we specifically examined whether AAMA or other
                                   hangtags containing similar wording were used on the garments marketed
                                   under each brand choice that we encountered.7 At each store, we observed
                                   the sleepwear displays in departments for infants/toddlers, boys, and girls.
                                   We paid particular attention to the presence of hangtags on snug-fitting
                                   garments because of the concern that consumers need to understand the
                                   importance of proper size selection.

                                   Overall, we found that of the 273 brand choices of children’s snug-fitting
                                   sleepwear we identified at the 70 stores that we visited, 199—or about

                                    For analysis purposes, we defined “brand choice” as a distinctly identifiable brand, trademark, or
                                   manufacturer name shown on the inside label or hangtag of the garments. Two or more styles of the
                                   same brand were counted as one brand choice if they were found in the same department in the same
                                   store. However, if the same brand was found, for example, in two different departments or stores, it
                                   would be counted as two brand choices.

                                   Page 6                                 GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

                       73 percent—had information hangtags attached to them. Of these,
                       70 percent used the AAMA-designed hangtag and 30 percent used other
                       types of hangtags. The other types of hangtags vary significantly in their
                       design but generally contain the same basic language used in the AAMA
                       hangtag. We noted that the garments without hangtags were not
                       associated with a specific retail chain. Garments without hangtags
                       generally represented brands that were less prevalent at the stores that we

                       Neither CPSC nor the industry has assessed the extent to which consumers
                       use this information in selecting the proper size of snug-fitting garments.

                       While the information hangtags can be helpful to consumers who read
Store Signs and        them, consumers may not know that they should look for the labels or
Separate Merchandise   hangtags when they shop for children’s sleepwear. Thus, CPSC and industry
Displays Present in    officials agree that in-store signs and brochures are important in
                       supporting point-of-sale information for consumers who are unfamiliar
Few Stores             with the sleepwear safety requirements. However, few of the stores that
                       we visited displayed store signs to alert consumers about the revised
                       sleepwear standards and the importance of examining sleepwear labels or
                       hangtags in making selections. Of the 70 stores that we visited, only 11
                       stores, represented mainly by 2 retail chains, had some store signs on
                       display to inform consumers about the new standards.8 These large signs
                       generally replicated the consumer information contained in the AAMA
                       hangtags. None of the stores we visited had any consumer information
                       brochures on display.

                       CPSC has also noted the importance of having proper designation and
                       separation of sleepwear display from that of other children’s apparel to
                       make it easy for consumers to distinguish sleepwear that meets CPSC
                       standards from other types of clothing, such as children’s playwear or
                       T-shirts, that are not subject to the standards. Again, however, most stores
                       did not designate or separate children’s sleepwear. Over two-thirds of the
                       stores we visited did not display any signs to designate product display
                       racks as sleepwear so consumers can easily identify sleepwear from other
                       garments. In addition, nearly 63 percent of the stores we visited mixed
                       sleepwear with other clothing, such as long underwear or cotton T-shirts,
                       on the same display racks as children’s sleepwear. (See table I.)

                        In one additional chain, we found an indication that signs were present during the fall and winter of
                       1998 but had been removed after the holiday season.

                       Page 7                                  GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

Table 1: Sleepwear Display Practices
in Stores Sampled, March and                                                                     Number of
April 1999                             Display practice                                             stores Percent of total
                                       Stores carrying snug-fitting cotton sleepwear                     67               96
                                       Stores with consumer information signs on display in
                                       one or more children’s apparel departments                        11               16
                                       Stores with signs to designate racks for sleepwear in
                                       one or more children’s apparel departments                        23               33
                                       Stores that mixed other garments with sleepwear in
                                       one or more children’s apparel departments                        44               63

                                       The lack of sleepwear designation and the mixing of sleepwear with other
                                       clothing could confuse consumers because some of the other clothing can
                                       be quite similar to sleepwear in appearance. For example, because of the
                                       lack of sleepwear designation signs, we often had to get help from sales
                                       staff to find the children’s sleepwear on display. In a few instances, we
                                       were directed by the salesperson to garments that resembled cotton
                                       sleepwear, but upon closer examination, we found that the garments had
                                       labels inside that read “not intended for use as sleepwear.”

                                       In early 1997, AAMA developed a consumer information brochure
Consumer Education                     containing clear guidelines to help consumers select safer sleepwear. AAMA
Efforts Hindered by                    officials told us that they had produced a large supply of the brochures
Uncertainty About                      and made them available to retailers and manufacturers; but so far, only
                                       one retailer and two manufacturers have requested the brochures.
Life of Revised                        Because of the small number of brochures requested, AAMA officials said
Standards                              that they probably never reached the consumers. Apparel industry officials
                                       cited the uncertainty surrounding the initial and current likelihood of the
                                       continuation of the new sleepwear standard and product as the main
                                       reasons for their lack of a more aggressive consumer education effort.

                                       AAMA also issued two press releases and developed a press kit, which,
                                       according to officials, was to be used to launch a comprehensive
                                       consumer information campaign targeting general media as well as
                                       parenting and medical magazines. But AAMA officials decided to suspend
                                       this effort initially because of industry concerns about the ability to
                                       successfully produce and market snug-fitting products that met CPSC’s
                                       sizing standards. Soon after the passage of the 1996 amendments, AAMA
                                       and other industry groups expressed concerns that adherence to the
                                       specific measurements required by CPSC’s sizing standards would produce
                                       impractical and unwearable snug-fitting products. As a result, CPSC began
                                       making technical revisions to the standards and, in May 1998, published a

                                       Page 8                            GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

                  notice of proposed rulemaking to change some of the specifications of the
                  garments; final technical changes were published in January 1999. Because
                  of these changes, the new snug-fitting sleepwear garments were not made
                  widely available to consumers until fall 1998. After this initial selling
                  season, AAMA officials said they were very encouraged with the market
                  acceptance of the new products and estimated that, in March 1999, the
                  new snug-fitting products made up about 15 percent of the children’s
                  sleepwear market. Our store visits confirmed that most of the retail stores
                  have begun to market the new snug-fitting sleepwear; 67 of the 70 stores
                  we visited carried at least one brand choice of snug-fitting cotton garment.

                  While the concerns about the initial acceptance of the product have been
                  allayed, the industry has continued to postpone committing additional
                  resources to informing and educating consumers because of its fear that
                  the standards will not be maintained. If the standards are revoked,
                  snug-fitting cotton sleepwear would no longer meet the sleepwear safety
                  standards, and the market for the product would disappear.

                  Our work indicates that while consumers often have some information on
Conclusions       children’s sleepwear safety available at the point-of-sale, it is not to the
                  extent envisioned by CPSC. The effectiveness of this consumer education
                  effort is unknown, however, for at least two reasons. First, neither CPSC
                  nor the industry has assessed whether consumers use this information to
                  select the proper size of snug-fitting garments. Second, there is a lack of
                  data about the extent of recent sleepwear-related burn injuries. The
                  absence of these data prevents an independent determination about
                  whether the new standards pose an increased risk to children and whether
                  a need exists for more consumer information and education or some other
                  strategy to promote sleepwear safety.

                  We provided a draft of this report to CPSC for its review and comment. In
Agency Comments   its response, reprinted as appendix II, CPSC stated that the report provides
                  valuable and helpful information about the extent and type of educational
                  materials available to consumers. It also stated that the results of our
                  survey of retail stores were consistent with information provided by

                  However, CPSC expressed concern about our statement in the conclusions
                  that the effectiveness of the education effort was unknown, in part,

                  Page 9                       GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

    because of the lack of data on the extent of recent sleepwear-related burn
    injuries. CPSC believes this statement to be unfounded, citing three reasons.

•   First, CPSC asserts there are data to support the position that the sleepwear
    amendments have not increased injuries. We do not agree with this
    assertion. In our April 1999 report, we found that data on the actual
    number of injuries are not available, which makes it difficult or impossible
    to observe trends in the number of injuries over time. We also recognized
    that obtaining such data would be difficult and costly. In this report, our
    point is that without such data, it is hard to know whether a more
    extensive education campaign is at least indicated.
•   Second, CPSC commented that the safety of the snug-fitting garments does
    not depend on a consumer education program. We do not believe that
    CPSC’s record or its past actions support this comment. For example, in
    several published alerts to consumers, CPSC and the industry viewed the
    education campaign as important to promote a safer choice of sleepwear.
    In fact, the hangtag wording, developed jointly by CPSC and industry,
    included the phrase “. . . fabric and fit are important safety considerations
    . . . .”
•   Last, CPSC stated that our study was not intended to evaluate the
    effectiveness of consumer education in reducing burn incidents. Our
    report acknowledges that our study was not designed to measure this link.
    Nevertheless, we think it is important to elaborate on this limitation so
    that our overall findings can be viewed in the perspective of consumer
    safety. Therefore, we continue to believe that our conclusions are both
    valid and founded in fact.

    We also provided a copy of our draft report to the AAMA for its review and
    comment. The association’s Director of Government Relations informed
    us that, overall, the association agreed with the presentation of the facts.

    Both CPSC and the AAMA provided technical comments, which we
    incorporated as appropriate.

    We are sending copies of this report to Ann Brown, Chairman, CPSC;
    Thomas H. Moore, Commissioner, CPSC; Mary Sheila Gall, Commissioner,
    CPSC; and appropriate congressional committees. We will also make copies
    available to others upon request. If you or your staff have any questions
    about this report, please contact me at (202) 512-7118 or Frank Pasquier,

    Page 10                       GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

Assistant Director, at (206)-287-4861. Major contributors to this report
include Sophia Ku and Matt Byer.

Kathryn G. Allen
Associate Director, Health Financing
  and Public Health Issues

Page 11                      GAO/HEHS-99-123 Children’s Sleepwear Safety Standard

Letter                                                                                            1

Appendix I                                                                                       14

Scope and
Appendix II                                                                                      17

Comments From the
Consumer Product
Safety Commission
Tables              Table 1: Sleepwear Display Practices in Stores Sampled, March                 8
                      and April 1999
                    Table I.1: Details on Retail Stores Visited by GAO in                        15
                      March/April 1999 to Observe Point-of-Sale Practices for
                      Children’s Sleepwear

Figure              Figure 1: Sample of AAMA Garment Hangtag Design for                           6
                      Snug-Fitting Sleepwear


                    AAMA      American Apparel Manufacturers Association
                    CPSC      Consumer Product Safety Commission

                    Page 12                     GAO/HEHS-99-123 Children’s Sleepwear Safety Standard
Page 13   GAO/HEHS-99-123 Children’s Sleepwear Safety Standard
Appendix I

Scope and Methodology

                 To select stores to visit, we first identified national and regional discount,
                 department, and children’s apparel specialty stores having large sales
                 volume, using data published in 1998 by the National Retail Federation. We
                 categorized these retailers into three groups based on volume of sales:

             •   large-volume discount or department stores,
             •   other discount or department stores, and
             •   children’s apparel specialty stores.

                 In each of 14 metropolitan areas in which GAO has field offices, we
                 judgmentally selected 5 stores to visit that included a mixture of all
                 categories. The 70 stores that we visited consisted of 23 separate retail
                 chains. We visited the stores in March and April 1999. Table I.1 shows the
                 details on the stores we visited in each category by location.

                 Page 14                       GAO/HEHS-99-123 Children’s Sleepwear Safety Standard
                                        Appendix I
                                        Scope and Methodology

Table I.1: Details on Retail Stores
Visited by GAO in March/April 1999 to                              Number of
Observe Point-Of-Sale Practices for     Store type              stores visited Locations
Children’s Sleepwear                    Major discount or department store chain
                                        J.C. Penney                           Sacramento, Calif.; Daly City, Calif;
                                                                              Westminster, Colo.; Tucker, Ga.; Lombard, Ill.;
                                                                              Hyattsville, Md.; Clackamas, Oreg.; Dallas,
                                                                           10 Tex.; Hampton, Va.; Tukwila, Wash.
                                        Kmart                                 Fairview Heights, Ill.; Shawnee, Kans.;
                                                                            4 Somerville, Mass.; Laurel, Md.
                                        Sears                                 Santa Monica, Calif.; Tucker, Ga.; Cambridge,
                                                                            4 Mass.; Virginia Beach, Va.
                                        Target                                Sacramento, Calif.; Colma, Calif.; Manhattan
                                                                              Beach, Calif.; Broomfield, Colo.; Lombard, Ill.;
                                                                            7 Shawnee, Kans.; Clackamas, Oreg.
                                        Wal-Mart                            3 O’Fallon, Ill.; Plano, Tex.; Bremerton, Wash.
                                        Other discount or department store chain
                                        Bloomingdale’s                      1 Los Angeles, Calif.
                                        Bon Marche                          1 Silverdale, Wash.
                                        Dillard’s                           1 Dallas, Tex.
                                        Filene’s                            1 Boston, Mass.
                                        Foley’s                             1 Westminster, Colo.
                                        Hecht’s                             2 Hyattsville, Md.; Hampton, Va.
                                        Lord & Taylor                       3 Atlanta, Ga.; St. Louis, Mo.; Dallas, Tex.
                                        Macy’s                                Sacramento, Calif.; San Francisco, Calif.;
                                                                            3 Boston, Mass.
                                        Marshalls                           2 Merriam, Kans.; Hampton, Va.
                                        Meier & Frank                       1 Portland, Oreg.
                                        Mervyn’s                              Los Angeles, Calif.; Westminster, Colo.;
                                                                            3 Tukwila, Wash.
                                        Montgomery Ward                       Lombard, Ill.; Overland Park, Kans.;
                                                                            3 Baltimore, Md.
                                        Nordstrom                             Sacramento, Calif.; San Francisco, Calif.;
                                                                            4 Oakbrook, Ill.; Portland, Oreg.
                                        Rich’s                              1 Atlanta, Ga.
                                        T.J. Maxx                           1 Fairview Heights, Ill.
                                        Children’s apparel
                                        Babies”R”Us                         1 Virginia Beach, Va.
                                        Baby Gap, GapKids                     Sacramento, Calif.; Los Angeles, Calif.;
                                                                              Boulder, Colo.; Atlanta, Ga.; Cambridge,
                                                                              Mass.; St. Louis, Mo.; Portland, Oreg.; Dallas,
                                                                            9 Tex; Seatac, Wash.
                                        Kids”R”Us                             Colma, Calif.; Lombard, Ill.; Overland Park,
                                                                            4 Kans.; Laurel, Md.

                                        Page 15                        GAO/HEHS-99-123 Children’s Sleepwear Safety Standard
    Appendix I
    Scope and Methodology

    For each store, we visited up to three separate departments:

•   infants (sizes 9 to 24 months) or toddler boys and girls (sizes 2 to 4) or
•   boys (sizes 4 to 14), and
•   girls (sizes 4 to 14).

    We approached each store visit as if we were “shopping” for children’s
    sleepwear and observed whether there was available information, such as
    signs, labels, and hangtags, that (1) differentiated the new snug-fitting
    products from the traditional flame-resistant sleepwear and (2) informed
    consumers about the snug-fitting requirements of the new products. We
    also tried to assess how difficult it was to differentiate the sleepwear from
    other garments not intended as sleepwear, such as cotton long underwear
    or sweatshirts, by noting whether the sleepwear racks were plainly
    marked and whether the sleepwear was displayed separately or mixed in
    with nonsleepwear.

    During our store visits, we specifically examined whether AAMA or other
    hangtags (containing similar wording) were available on the garments
    marketed under each brand choice that we encountered. For analysis
    purposes, we defined “brand choice” as a distinctly identifiable brand,
    trademark, or manufacturer name shown on the inside label or hangtag of
    the garments. We considered each department within each store as a
    separate observation. As a result, the same brand was counted as a
    separate “brand choice” each time that it was carried by the department

    Although the results from the 70 stores we visited are not statistically
    projectable to all retail outlets in the country, we believe our findings are
    typical of situations that many shoppers would encounter in making
    decisions about buying children’s sleepwear. We chose a variety of stores,
    focusing mainly on chains that carry children’s apparel with the greatest
    sales volume under the assumption that these stores represent the retail
    environment that a large proportion of consumers experience when
    shopping for children’s sleepwear. Several of these chains also have stores
    located in less populated, nonmetropolitan areas.

    Page 16                       GAO/HEHS-99-123 Children’s Sleepwear Safety Standard
Appendix II

Comments From the Consumer Product
Safety Commission

              Page 17   GAO/HEHS-99-123 Children’s Sleepwear Safety Standard
           Appendix II
           Comments From the Consumer Product
           Safety Commission

(108397)   Page 18                       GAO/HEHS-99-123 Children’s Sleepwear Safety Standard
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