INDITEX Safe To Wear en

TABLE OF CONTENTS
TABLE OF CONTENTS
I. DEFINITION OF THE STANDARD........................................................................ 87
II. CHILDRENS GARMENT SAFETY....................................................................... 88
1. Cords and Drawstrings.................................................................................. 88
2. Separable Small Parts................................................................................... 89
3. Non-Separable Small Parts (1/2)................................................................... 90
5. Sharp Points (1/2)......................................................................................... 92
6. Sharp Edges (2/2).......................................................................................... 93
III. LEGALLY REGULATED PARAMETRES............................................................... 94
ANNEX I: REQUIREMENTS OF THE UNE-EN 14682 STANDARD.............................. 97
1. Generalities.................................................................................................... 97
2. Hood and Neck Area in Young Childrens Garments....................................... 98
3. Hood and Neck Area in Clothing for Older Children and Youths..................... 98
4. Waist Area of the Garments........................................................................... 99
5. Lower Edges of the Garments that Hang Below the Waist............................. 99
6. Sleeves........................................................................................................ 100
7. Other Parts of the Garment.......................................................................... 100
ANNEX II: MEASUREMENTS . ............................................................................ 101
1. Measurement of cords with the end loose.................................................. 101
2. Measurement of a cord with no loose end.................................................. 101
ANNEX III: AREAS / ZONES OF THE BODY........................................................... 102
ANNEX IV: EXAMPLES OF CORDS AND DRAWSTRINGS....................................... 103
ANNEX V: SMALL PARTS CYLINDER.EN 71-1..................................................... 112
ANNEX VI: TENSION TEST. EN 71-1.................................................................... 113
ANNEX VII: TORQUE TEST. EN 71-1.................................................................... 114
ANNEX VIII: SHARP POINTS. EN 71-1................................................................. 115
ANNEX IX: SHARP EDGES. EN 71-1................................................................... 116
IV. BIBLIOGRAPHY............................................................................................. 117
This Referece Manual is a free translation from the Spanish Version.
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I. DEFINITION OF THE STANDARD.

The Safe to Wear Standard (hereinafter STW) is defined as a Product Safety Standard and it has been develo
ped by Inditex in accordance with the following safety regulations:
- UNE-EN 71-1:1988 Safety of Toys. Mechanical and physical properties.
- UNE-EN 14682-2004 Safety of Childrens Clothing. Cords and Drawstrings on Childrens Clothing. Specifi
cations.
- BS 7907:1997 Code of Practice of the Design and Manufacture of Childrens Clothing to Promote Mechani
cal Safety.
- PNE 40902 (Spain) Seguridad de prendas de beb. Propiedades fsicas y mecnicas.
- CPSIA (United States) Consumer Product Safety Improvement Act of 2008.
- CPSC (United States) Flammable Fabrics Act (16 CFR II, Subchapter D)
- CPSC (United States) Flammability of Clothing Textiles (16 CFR II, Subchapter D, Part 1610)
- CPSC (United States) Flammability of Childrens Sleepwear (16 CFR II, Subchapter D, Part 1615 & 1616)
- Regulations (SOR/87-443) (Canada) Hazardous Products (Childrens Sleepwear) Regulations (SOR/87-443)
- UK Regulation The Nightwear (Safety) Regulations 1985, S.I. 2043 & Amendment 1987, S.I. 286, Childrens
Nightwears - Garments for Childrens Over 3 Months & Under 13 Year of Age, Babies Garments Exclusively
for Babies Under 3 Months Must Contain A Permanent Label Showing Wheather or not They Meet Flamma
bility Standard.
- Swedish Regulation Guidelines on Fire Properties of Apparel Textile (Flammability), Product Safety Act (SFS
1988 : 1604)
- Australian Flammability Regulation Childrens Nightclothes Having Reducing Fire Hazard.
- Netherland Regulation: Netherland Mandatory Fire Safety Requirements.
- EN 14878: Flamability to be Performed for Children Nightwear.
- ASTM F963: Small Parts Attachments (Sharp Edges & Sharp Points)
- M16 CFR 150 Remoral of Small Parts Accessories (Torque & Tension Test)
- ASTM F1816 Drawstring and Cords.
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II. CHILDRENS GARMENT SAFETY.

1. Cords and Drawstrings.
Products to control
Cords and drawstrings.
Standard
UNE-EN 146821.
Potential Mechanical Hazards
Strangulation and Entrapment.
Objective
Minimise the risk of accidental entanglement by cords and drawstrings on childrens clothing1.
Application / Age
Garments intended for minors between 0-14 years of age.
Controls
UNE-EN 14682:20042.
Best practices
Conduct obligatory visual inspections, and in accordance with the standard of garments / models - quali
ty intended for children under 3 years of age that contain cords and drawstrings.
Conduct visual inspections in accordance with the standard of garments / models - quality intended for
minors between the ages of 3 and 14 years of age, ONLY if the failure rate in products intended for children
under 3 years of age is not acceptable.
Recommendations
Make manufacturers and distributors of childrens clothing aware of the content and scope of the standard.
The scope of - UNE-EN 14682:2004 - is restricted to cords and drawstrings for childrens clothing, including costumes and ski
garments, up to the age of 14. The following articles are excluded from this group: (1) care articles (diapers and dummy fasteners);
(2) shoes, boots and similar footwear; (3) gloves, hats and scarves; (4) ties designed to be worn with a shirt or blouse; (5) belts and
straps; (6) religious garments; (7) sportswear of specialists and sportswear that is worn during limited periods of time and under
supervision (rugby suits, suits for aquatic activities and dance clothing, except when these garments are normally used as day or
night clothes) and (8) costumes used in theatre performances.
UNE-EN 14682:2004 specifies basic design requisites included in Annex I of this Guide.
88
2. Separable Small Parts.
Products to control
Separable Small Parts3.
Standard
EN 71-1.
Small Parts/Choking Hazards.
Objective
Avoid choking caused by young children sucking and partly swallowing ties, ribbons and similar items.
Application / Age
Garments intended for children under 3 years of age and /or children up to 98 cm in height.
Test Method
EN 71-1 (Small Parts cylinder)4
Test Requirement
Small parts shall not fit entirely in the cylinder.
3
4
Separable Small Parts: Any component attached permanenty to the garment (i.e. stickers and accessories, mainly)
See Test Method Summary in Annex V of this Guide.
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3. Non-Separable Small Parts (1/2)
Products to control
Non-Separable Small Parts5.
Standard
EN 71-1.
Injuries from detached objects.
Objective
Avoid injuries from detached objects because of tension forces (buttons, popper fastener parts or zipper
puller become detached from the garment)
Application / Age
A garment with a projection, part or assembly that a child can grasp with at least the thumb and forefinger or
the teeth shall be subject to this test (i.e. zipper pullers, pompons and tassels, mainly).
Minors between 0-3 years of age and/or children up to 98 cm in height.
Test Method
EN 71-1 (Tension Test)6
Test Requirement
50 N when the largest accessible dimension is 6 mm or less.

90 N when the largest accessible dimension is greater than 6 mm.
Non separable Small Parts: Any component attached permanently to the garment. A breakdown is mainly as follows:
Sewn buttons.
Pressure fasteners (studs, snaps and rivets, among others).
Clasps with catches.
Buckles.
Hooks.
Zippers.
Other general adornments.
See Test Method Summary in Annex VI of this Guide.
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Products to control
Non-separable Small Parts7.
Standard
EN 71-1.
Objective
Avoid injuries from detached objects because of torque forces (buttons, popper fastener parts or zipper
pullers become detached from the garment)
Application / Age
Test Method
EN 71-1 (Torque Test)8
Test Requirement
0.45 Nm ( 4.0 lb.inch)
Non-separable Small Parts: Any component attached permanently to the garment. A breakdown is mainly as follows:
Sewn buttons.
Buckles.
Hooks.
Zippers.
See Test Method Summary in Annex VII of this Guide.
91
5. Sharp Points (1/2)
Products to control
Sharp Objects9.
Standard
EN 71-1.
Injuries from sharp objects.
Objective
Avoid injuries from sharp points found on buttons, zips, decorative features or deteriorated components.
Application / Age
Safety pins, straight pins, decorative ornamental pins, broken needles, exposed prongs of snaps/studs/
nuets/rhinestones and zipper parts, mainly.
Test Method
EN 71-1 (Sharp Points )10
Test Requirement
Maximum penetration, 0.5 mm.
Sharp Objects: objects with points or edges that are or may be shown and they may have probability of causing insuries from
cutting or puncture.
10 See Test Method Summary in Annex VIII of this Guide.
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6. Sharp Edges (2/2)
Products to control
Sharp Objects11.
Standard
EN 71-1.
Objective
Avoid injuries from sharp edges found on buttons, zips, decorative features or deteriorated components.
Application / Age
nuets/ rhinestones, zipper parts.
Minors between 0-3 years of age and or children up to 98 cm in height.
Test Method
EN 71-1 (Sharp Edges)12
Test Requirement
Maximum at length, 50%.
11 Sharp Objects: objects with points or edges that are or may be shown and may have probability of causing insuries from cutting or
puncture.
12 See Test Method Summary in Annex IX of this Guide.
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III. LEGALLY REGULATED PARAMETERS.
III. LEGALLY REGULATED PARAMETERS

Flammability
1. What is it?
The ability of a material or product to burn with a flame under specified test conditions.
2. Where is it required?
Nightwear Requirements
It is required in all: i) baby clothing; ii) Childrens Nightwear, iii) Childrens Sleepwear, iv) adult nightwear and
v) Home Textiles.
General Apparel Requirements
It is required in all general apparel (adult & children) with the following exception gloves, footwear, interli
ning fabrics and garments made from: i) in Plain surface fabrics, regardless of fiber type, weighing 2.6 oz/
yd2 (85g/m2) or greater are exempt from the regulation and ii) in Apparel manufactured with these fibers
(Acrylics, Modacrylics, Nylon, Polyester, Wool and Olefins, mainly) or blends of these fibers, regardless of
weight, are exempt from the regulation.
3. How are they regulated?
CPSC (United States) Flammable Fabrics Act (16 CFR II, Subchapter D)
CPSC (United States) Flammability of Clothing Textiles (16 CFR II, Subchapter D, Part 1610)
CPSC (United States) Flammability of Childrens Sleepwear (16 CFR II, Subchapter D, Part 1615 & 1616)
Regulations (SOR/87-443) (Canada) Hazardous Products (Childrens Sleepwear) Regulations (SOR/87-443)
UK Regulation The Nightwear (Safety) Regulations 1985, S.I. 2043 & Amendment 1987, S.I. 286 , Childrens
for Babies Under 3 Months Must Contain a Permanent Label Showing Wheather or not They Meet Flamma
bility Standard.
Swedish Regulation Guidelines on Fire Properties of Apparel Textile (Flammability), Product Safety Act (SFS
1988 : 1604)
Australian Flammability Regulation Childrens Nightclothes Having Reducing Fire Hazard.
Netherland Regulation: Netherland Mandatory Fire Safety Requirements.
Norway FOR 1984-02-13 nR 427 Forskrifter om forbud mot svaert brannbare tekstiler 13-02- 1984 Directi
ve on prohibition of highly flammable textiles.
Swiss regulation: Swiss Ordinance 817.043.1
4. How is it analyzed?
It is analyzed by:
i) 16CFR1610 (ASTM D1230) for General Apparel Requirements; and
ii) BS5438:1989 with BS5722:1991, BS EN ISO 6940:2004 and BS ISO 1103:2007, for Childrens Nightwear
Requirements.
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5. Which are the acceptable limits?

Childrens Nightwear Requirements
Pyjamas
CATEGORY OF INTENDED WEARER
PERFORMANCE REQUIREMENTS
Birth up to (6 months) height 68cm
Meet Netherland Mandatory fire safety requirements: when tested to EN 1103

17 seconds to 520 mm.
Surface flash must be less than 520 mm.
Over 68cm (6 months) and up to height:

Girls 176cm (14 years)
Boys 182cm (14 years)

Night Dresses, Dressing Gowns, Bath Robes (not cotton terry towelling) and similar garments
Birth up to 3 months

Over 3 months and up to height 68cm (6 months)
Meet UK regulations, BS 5722: when tested to BS 5438

300mm trip thread severed in not less than 25s, and
600mm trip thread severed in not less than 50s.


Bath Robes made of cotton terry towelling only

Birth up to 3 months1

Over 3 months and up to 6 months



All baby garments

None
Babies garments: Garments exclusively for babies under 3 months and having a chest measurement not exceeding 53 centime
tres (approx 21)
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Adults Nightwear Requirements

Adults (older than 14 years old)


COUNTRY
TESTING METHOD
REQUIREMENTS
USA
CFR 16
Part 1610
Average flame spread time ( tp ) > 3.5 s for plain surface fabrics.
Average flame spread time ( tp ) > 4 s and no base burn for raised surface fabrics.
CANADA
CAN/CGSB 4.2
NO. 27.5
NETHERLANDS
ASTM D1230
Average time of flame spread ( tp )> 4 s.
SWITZERLAND
EN 1103
Maximum flame spread velocity ( vp ), 90 mm/s and no surface flash.

Maximum flame spread velocity ( vp ), 120 mm/s for cellulosic fabrics with fabric weight less than 80 g/m2.
SWEDEN
ASTM D1230
NORWAY
ASTM D1230
Average time of flame spread ( tp )> 7 s for garments intended for children up to 170 cm
Average time of flame spread ( tp )> 5 s for garments intended for adults.
6. How can it be avoided?

By producing non flammable clothings.
Definitions:
Flammability: The ability of a material or product to burn with a flame under specified test conditions.
Ignitability: The measure of the ease with which a material, product or component can be ignited so as to
flame or progressively smoulder.
Flame retardance: The property of a material whereby flaming combustion is slowed, terminated or pre
vented. Flame retardance may be the property of either the materials used or may be applied after the fabric
has been produced.
Flame resistance: The ability of a material to withstand ignition (term deprecated)
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ANNEX I: REQUIREMENTS OF THE UNE-EN 14682 STANDARD.

1. Generalities.
1. The ends of the drawstrings, functional cords1 and the sashes2 must not be tied and must be protected to
avoid fraying (thermal bonding and stitched). The hem or fold of the end is permitted as long as it does not create
a risk of entanglement.
2. Baubles3 may only be used in drawstrings that do not have loose ends or decorative cords4 (see figure IV.1,
Annex IV: Samples of cords and drawstrings)
3. Childrens clothing must be designed in such a way that they do not have drawstrings, decorative or functional
cords that protrude from the back part of the garment or that are fastened to the back (except the sashes) (see
figure III.2, zone D, Annex III: Areas/zones of the body) (see figure IV.2, Annex IV: Examples of cords and draws
trings)
4. In case of being permitted, the cords must be fastened (using a stitch in at least one point equidistant from the
exit points. See figure IV.3, Annex IV: Examples of cords and drawstrings)
5. Fixed loops that protrude from the garment, for example, in order to tie it, must have a circumference that does
not exceed 75 mm. Flat loops that do not stick out from the garment (ribbons/loops of the straps) must have
a length measured between the fixed points of the accessory to the garment less than or equal to 75 mm (see
figure IV.4, Annex IV: Examples of cords and drawstrings)
6. Zipper pulls, including any adornment, must have a length less than or equal to 75 mm measured from the
body of the pull and, in addition, must not extend beyond the lowest edge of the clothing designed to end at the
ankle (see figure IV.5, Annex IV: Examples of cords and drawstrings)
7. All the measurements must be made according to Annex II: Measurements.
1
2
3
4
Functional cord: band, chain, ribbon, drawstring or strip of any textile material with or without embellishments such as baubles,
pom-poms, feathers or beads, of a fixed length that is used to adjust the size of the opening or part of the garment or to hang the
garment.
Sash: drawstring, decorative or functional cord of a textile material of not less than 30 mm in width that is worn around the waist
of a garment or joined by a ribbon.
Bauble: Piece of wood, plastic, metal or of any other material fastened or placed on a drawstring, functional cord or decorative
cord.
Decorative cord: non-functional band, chain, ribbon, drawstring or strip of any textile or non-textile material with or without embe
llishments, such as baubles, pom-poms, feathers or beads, of a fixed length and not used to adjust the size of the opening of the
garment or to hang it.
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2. Hood and neck area in young childrens garments5.

1. Clothing for young children must not be designed, manufactured or supplied with drawstrings, functional1 or
decorative4 cords in the hood or in the neck area.
2. The tab fastener6 is permitted as long as the length is not over 75 mm.
3. Straps7 are permitted as long as they are made of a continuous material or cords tied in the front and back part
of the garment. Decorative cords tied to the straps must not have loose ends that are longer than 75 mm and the
fixed loops must not have a circumference larger than 75 mm (see figure IV.7, Annex IV: Examples of cords and
drawstrings)
4. Garments with cords around the neck must be designed without loose ends in the hood and neck area (see
5. Adornments sewn or connected in another way, for example ribbons8, must not have loose ends longer than 75
mm. No ribbon/loop may have a circumference larger than 75 mm. (See figure IV.9, Annex IV: Examples of cords
and drawstrings)
3. Hood and neck area in clothing for older children and youths.
1. Drawstrings must not have loose ends.
- When the garment is opened as far as possible and laid flat, no ribbon should protrude. When the opening
is at the minimum, that is, that which corresponds to the size for which it is intended to be adjusted, the
maximum circumference of the loop will be 150 mm. (See figure IV.10, Annex IV: Examples of cords and
drawstrings)
2. Decorative cords must not have a length over 75 mm in the ends including any fastening element, such as, for
example, a bauble3. The decorative cords should not be fabricated with elastic cords.
3. Functional cords and tab fasteners must not have a length over 75 mm on each end. Functional cords should
not be fabricated with elastic cords10, except straps and cords in the neck area.
4. Garments with a cord around the neck must be fabricated without loose ends in the hood and neck area.
5. Straps are permitted as long as the loose ends are not over 140 mm, measured from the point in which they
are tied and the fixed loops must not have a circumference over 75 mm (see figure IV.7, Annex IV: Examples of
cords and drawstrings)
garment.
3 Bauble: Piece of wood, plastic, metal or of any other material fastened or placed on a drawstring, functional cord or decorative
cord.
4 Decorative cord: non-functional band, chain, ribbon, drawstring or strip of any textile or non-textile material with or without embe
5 Young child: a person from the time of birth until he reaches 7 years of age (that is, 6 years and 11 months); also included in this
category are children whose height is less than or equal to 134 cm.
6 Tab fastener: small strip of fabric not less than 20 mm in width used to adjust the size of the opening of a garment (ankles or
sleeve cuffs)
7 Straps: functional cord that joins the front and back parts of the upper part of a garment that clings to the body and passes over
the shoulder.
8 Ribbon: A cord or narrow strip of curved material, with a fixed or adjustable length, in which the two ends are fastened to the
garment.
9 Older children and youths: person from 7 years of age up to 14 (13 years and 11 months), also including all the boys with height
of 134 cm up to 182 cm and girls with height of 134 cm up to 176 cm.
10 Elastic cord: drawstrings that contain rubber threads or are of elastodiene polymer, elastane or similar materials, which have high
elasticity and complete or almost complete recovery.
1
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4. Waist area of the garments (figure 1, zone b, annex III; area/zones of the body)
1. Cords in the waist area may protrude a maximum of 140 mm on each end when the garment is lying flat accor
ding to the design and must not exceed 280 mm when it is closed or adapted to the corresponding waist size.
Cords without loose ends must have a loop/ribbon with a maximum circumference of 280 mm when they are
adapted to the corresponding waist size (see figure IV.15, Annex IV: Examples of cords and drawstrings)
2. Functional1 and decorative4 cords and tab fasteners in the waist area may have a maximum length of 140 mm
including any adornment on the decorative cords.
3. Young children5: Sashes2 designed to be tied in the back of the garments are permitted, as long as when they
are untied they do not exceed 360 mm, measured from the tying point and, in addition, when they are untied they
must not hang below the hem of the garment (see figure IV.16, Annex IV: Examples of cords and drawstrings)
4. Older children and youths9: Sashes designed to be tied in the back of the garments are permitted as long as
when they are untied they do not exceed 360 mm, measured from the tying point (see figure IV.16, Annex IV:
Examples of cords and drawstrings)
5. Sashes designed to be tied in the front of the garment are permitted as long as when they are untied they do
not exceed 360 mm, measured from the tying point (see figure IV.17, Annex IV: Examples of cords and draws
trings)
5. Lower edges of the garments that hang below the waist (figure III.1, zone c, annex III; areas/zones of
the body)
1. The drawstrings, decorative or functional cords that may include any bauble3 on the lower edge of the gar
ments in which the lower edge is situated below the hips, must not hang below the lower edge of the garment
and they must be situated completely within the garment (see figure IV.11, Annex IV). When they are on the
outside of the clothing, cords or drawstrings must lie flat against the garment when it is adjusted or fastened (see
2. There must not be any drawstrings, functional or decorative cords extending below the lower edge of coats,
pants or skirts designed to end at the ankle (stirrups are acceptable on the edge of the pants)
3. The tab fasteners6 are acceptable if their length is no more than 140 mm and, in addition, they must not hang
below the garment (see figure IV.12, Annex IV: Examples of cords and drawstrings)
1
2
3
4
5
6
9
garment.
Bauble: piece of wood, plastic, metal or of any other material fastened or placed on a drawstring, functional cord or decorative
cord.
Young child: a person from the time of birth until he reaches 7 years of age (that is, 6 years and 11 months); also included in this
Tab fastener: small strip of fabric not less than 20 mm in width used to adjust the size of the opening of a garment (ankles or
sleeve cuffs)
Older children and youths: person from 7 years of age up to 14 (13 years and 11 months), also including all the boys with height
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6. Sleeves.
1. When the sleeve is fitted, the drawstrings, functional1 and decorative cords4 on the lower edge of the longsleeved garments must be completely situated in the interior of the garment (see figure IV.13, Annex IV: Examples
of cords and drawstrings)
2. Young children5: drawstrings, functional and decorative cords are permitted in short-sleeved garments whene
ver the sleeves end above the elbow and when the maximum length that protrudes is 75 mm, measured when the
sleeve is flat on the model (see figure IV.14, Annex IV: Examples of cords and drawstrings)
3. Older children and youths9: drawstrings, functional and decorative cords are permitted in short sleeved gar
ments when the sleeves end above the elbow and their maximum length is not over 140 mm, measured when it is
flat on the model (see figure IV.14, Annex IV: Examples of cords and drawstrings)
4. The tab fasteners6 are permitted on sleeves as long as they do not exceed 100 mm and, in addition, when they
are open they do not extend below the hem of the garment (see figure IV.6, Annex IV: Examples of cords and
drawstrings)
7. Other parts of the garment.

1. In other areas of the garment not mentioned above, drawstrings or functional and decorative cords must not
protrude more than 140 mm, when the garment is completely open (maximum)
1
4
5
6
9
garment.
sleeve cuffs)
100
ANNEX II: MEASUREMENTS.

All the measurements must be made with cords or loops in a relaxed state.
1. Measurement of cords with the end loose.

LEGEND
1. Cord - straight (one loose end)
2. Garment.
3. Length of the cord (in mm)
2. Measurement of a cord with no loose ends.

LEGEND
1. Bauble.
2. Cord - with no loose end.
3. Garment.
4. Length of the loop (in mm)
5. Fixed ends - both fixed or inside the garment.
101
ANNEX III: AREAS/ZONES OF THE BODY.
Key
A= hood and neck area.
B= chest and waist area.
C= under the hips.
D= back area.
102
ANNEX IV: EXAMPLES OF CORDS AND DRAWSTRINGS.
103
104
105
Key
2= Case 2 of hood and neck area for young children, max. 75 mm.
= Case 5. Hood and neck area for all her children and youths, max. 140 mm.
106
107
108
Key
1= case 2 of sleeves: young children max. 75 mm.
case 3 of sleeves: older children max. 140 mm.
109
110
Width of the belt 30 mm.

Length of the belt from where it is tied 360 mm.
111
ANNEX V: SMALL PARTS CYLINDER. EN 71-1.

1. Test Method.
EN 71-1.
2. Test Equipment.
Cylinder according to EN 71-1.
3. Test Procedure.
To place the Separable Small Part, without compressing and in any orientation, in a cylinder that has the
dimensions shown in figure V.1.
4. Test Requirement.
To verify if the Separable Small Part doesnt fit entirely in the cylinder.
112
ANNEX VI: TENSION TEST. EN 71-1.

1. Test Method.
EN 71-1.
2. Test Equipment.
Clamps.
Loading device.
3. Test Procedure (for grippable component)

Affix a suitable clamp behind the component.
Fasten the garment in the apparatus and apply force to the component.
Apply the force gradually within a period of 5 s.
Maintain the force for 10 s.
4. Grippable Definition.
Test equipment:
Feeler gauge.
Source: SGS International.
Test procedure:
Inserting the feeler gauge between the component and the underlying layer at an angle between 0o and
10o from the small part surface using a force 10N.
If the gauge can be inserted more than 2 mm, the component shall be considered as grippable.
50 N, when the largest accessible dimension is 6 mm or less.
90 N, when the largest accessible dimension is greater than 6 mm.
6. Application.
Any projection of a garment that the child can grasp with at least the thumb and forefinger or the teeth shall
be subject to this test.
This test is to be conducted on the same garment that has been subjected to the torque test (i.e. Zipper
pullers, buttons, hook & loop, D rings, pompoms, tassels, bows, rosettes, appliques, hasp/slider and other
decorative components, mainly)
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ANNEX VII: TORQUE TEST. EN 71-1.

1. Test Method.
EN 71-1.
2. Test Equipment.
Torque Gauge
3. Test Procedures.
A torque of specified force shall be applied evenly within a period of 5 seconds in a clockwise direction or
until a rotation of 180 degrees from the original position.
The torque or maximum rotation shall be maintained for an additional 10 seconds. The torque shall then be
removed and the test component permitted to return to a relaxed condition. This procedure shall then be
repeated in a counterclockwise direction.
4. Test requirements.
0.45 Nm (4.0 lb.inch)
114
ANNEX VIII: SHARP POINTS. EN 71-1.

1. Test Equipment.
Sharp Point Tester.
2. Test Procedure.
Insert the point into the cap slot.
Apply a force of 4.5 N to depress the spring.
3. Test Requirements.
The point is consider as sharp point if the point penetrates a distance of 0.5 mm or more into the gauging
slot, causing the indicator lamp to light.
4. Application.
Safety pins, straight pins, decorative ornamental pins, broken needles, exposed prongs of snaps / studs /
rivets / rhinestones and zipper parts, mainly.
115
ANNEX IX: SHARP EDGES. EN 71-1.

1. Test Equipment.
Sharp Edge Tester.
2. Test Procedure.
Wrap one layer of standard self-adhesive tape around the full circumference of the mandrel.
Apply a force of 6 N to the mandrel and rotate the mandrel 360o about its axis against the edge.
Remove the tape without enlarging any cut or causing any score to become a cut.
If the cut in the tape with a length of more than 50%, the edge tested is considered to be a sharp edge.
4. Applications.
rivets/rhinestones and zipper parts, mainly.
116
IV. BIBLIOGRAPHY.
IV. BIBLIOGRAPHY1.
- ASTM Standard F 1816-97. Standard safety specification for drawstrings on childrens upper outerwear.
- BS 7907: 1997 Code of practice for the design and manufacture of childrens clothing to promote mechanical
safety.
- Budavari, E. & Eiben O., 1982. Evaluation of School Furniture with regard to Students Body Measurements,
Ergonomia, 15.2, 70-77.
- CEN/BTWG/117 N11 Draft for Comment Child Safety - Guidelines for its Inclusion in Standards.
- CEN/TR 1338 7:2004 CEN Child Use and Care Articles - General and Common Safety Guidelines.
- CEN Guidelines M/293.
- CHILDATA published by the DTI, UK, 1995.
- DIN 33402: Body Dimensions of People; Values, June 1981.
- XP G30-105 (2002) Scurit des vtement denfants Cordons ou Liens de serrage.
- EN 71-1: 2001 Safety of Toys: Part 1 Mechanical and Physical Properties.
- Home Accident Surveillance System Annual Report. Accident Data and Safety Research: Home, Garden and
Leisure UK Department of Trade and Industry Consumer Affairs and Policy Directorate.
- ISO/IEC Guide 50:2002 Safety Aspects- Guidelines for Child Safety.
- Joubert, D., 1982, Le salon international de la mode enfantine, Filiere Maille, Sept-Oct. 20.
- Ostyn, M., Simons, J., Beunen, G., Renson, R. & Van Gerven, D., 1980, Somatic And Motor Development of
Belgian Secondary Schoolboys - Norms and Standards, Leuven University Press, Belgium.
- Pheasant, S. T., 1986, Bodyspace: Anthropometric Ergonomics and Design, Taylor and Francis, London, UK.
- Sihvola Seija (2000) A Health Dialogue in the School Entrance Health Examination, Acta Universitatis Tamperen
sis 751: Tampere.
- Stakes (1998) Lasten ja nuorten hyvinvointi ja terveys Suomessa, Statistical Report 13/1998, 129.
- Steenbekkers, LPA, 1993, Child Development, Design Implications & Accident Prevention. No. 1 in Physical
Ergonomics Series, TU Delft (Delft University of Technology) Netherlands.
- UK legislation: Childrens Clothing (Hood Cords) Regulations 1976.
- Waaler, P.E. 1983, Anthropometric Studies in Norwegian Children, Acta Paediatrica Scandinavica, Supplement
308, 2-38.
Bibliography source: EN 14682:2006.
117
2010
2010
Reference Manual Coordination:
Technical coordinator:
Javier Chrcoles Blzquez.
Director of Corporate Responsibility Department. Inditex.
Scientific coordinator:
Hctor Alonso Fernndez.

Product Health and Safety Manager.
Corporate Responsibility Department. Inditex.
www.inditex.com
Scientific Advisors:
F. Javier Sardina Lpez

Professor of Organic Chemistry and Coordinator for Management
and Research Promotion.
University of Santiago de Compostela.
Rafael Cela Torrijos
Professor of Analytical Chemistry.
University of Santiago de Compostela.
Design and Layout:
NEO
Aknowledgements:
This Reference Manual has been revised by Drs. F. Javier Sardina

and Rafael Cela, professors of Chemistry of the University of San
tiago de Compostela (USC) Inditex wishes to thank them and the
USC for their contributions, suggestions and corrections during the
preparation of this Reference Manual.
of the text:
Corporate Responsibility Department. Inditex

Neither the reproduction of this Reference Manual, nor its electronic
treatment, nor its transmission in any form or by any means, whether
electronic, mechanic, photocopy, by registry or any other means are
allowed without the previous written permission from the Copyright
owners.
TABLE OF CONTENTS
TABLE OF CONTENTS
I. METAL DETECTING POLICY............................................................................. 125

1. Definition and Scope.................................................................................... 125
2. Commitments of the External Suppliers and Manufacturers....................... 126
3. Commitments of the Packing, Trim and Accessory Suppliers...................... 127
II. METAL DETECTING PRODUCTION GUIDELINE.................................................. 128
1. Training........................................................................................................ 128
2. Commitments.............................................................................................. 129
3. Scope........................................................................................................... 130
4. Tools............................................................................................................. 132
III. ANNEX I....................................................................................................... 134
1. Factory Metal Detecting Report................................................................... 134
IV. ANNEX II...................................................................................................... 134
Commitment to Comply with the Inditex groups Safe to Wear 2010
Product Safety Standard.................................................................................. 134
123
I. METAL DETECTING POLICY
I. METAL DETECTING POLICY.

1. Definition and Scope.
The Metal Detection Policy (here in after the Policy) is a mandatory procedure designed by Inditex to ensure that
all the products supplied by any External Manufacturers and Suppliers and their Subcontractors to Inditex do not
contain any needle, pin, staple or any metallic item (from any stage of the production process) that may cause
any injury if inadvertently left in the product.
The Policy has been designed to protect not only the Health and the Safety of Inditexs Consumers, its Reputa
tion as well as the External Suppliers and Manufacturers and their Subcontractors, but also the Health and Safety
of the workforce involved in any stage of the Inditex s Supply Chain.
The Policy implies that:
It is a mandatory requirement since its approval and its non-compliance or violation can therefore not be
tolerated and will lead to penalties starting from form fines tile cancellation of all orders.
When External Manufacturers and Suppliers and their subcontractors be not the manufacturer, they must
ensure that any products supplied to Inditex will be in accordance with the Policy.
All Inditex apparel items should be 100% ferrous free.
125
2. Commitments of the External Suppliers and Manufacturers.

The External Manufacturer and Suppliers and their Subcontractors commit themselves:
Ferrous Detection Test:
To manufacture their products using packing material, trims and accessories containing metallic compo
nents be made only of non-ferrous metal. Consequently, all metal accessories should pass the ferrous
detection check with maximum diameter 1.00 mm from any direction.
To check all incoming trims and accessories at least on a random basis in order to identify eventual metallic
contamination at an early stage. Consequently, Inditexs External Manufactures and Suppliers Top Manage
ment will be immediately informed of any trims or accessories identified after the ferrous detection process.
To pass a metal detection test with maximum Diameter 1.00mm from any direction before carrying out the
Final Inspection in all products manufactured to Inditex.
To ensure that the metal detection machine is maintained properly and set according to the standard.
At manufacturing level:
To make all machine workers/operators aware of the relevance and importance of the Policy and its imple
mentation.
To nominate fully responsible trained workers to keep the control of all new machine needles for embroidery,
hosiery, knitting and sewing, mainly.
To ensure that all sewing needles in the possession of the machine workers/operators are controlled at any
time during the manufacturing process.
To nominate fully responsible trained workers to monitor the adequate implementation of the Policy and
deal with contaminated products.
Action to be taken with contaminated products:
To destruct the product affected by it and to eliminate any possibility of its future use.
To record product contaminated in a formal file.
To keep the mentioned files available for inspections anytime when either Inditex or its External Quality Con
trol and Health and Safety Team require.
To check again new samples of previous contaminated products to ensure their conformity with the Policy
and its requirements once the contaminated product situation has been corrected.
126
3. Commitment of the Packing, Trim and Accessory Suppliers.

The Packaging, Trims and Accessory External Suppliers must ensure that all packing material, trims and
accessories are metal (ferrous) free and have successfully passed a metal detection process prior to the
beginning of the manufacturing process.
This process must to be recorded and all its documents must be available upon request from either Inditex
or its External Quality Control and Health and Safety Team.
127
II. PRODUCTION GUIDELINE
II. METAL DETECTING PRODUCTION GUIDELINE.

1. Training.
1.1. General.
External Manufacturers and Suppliers and their Subcontractors are responsible for conducting and docu
menting regular Quality Control & Health and Safety Audits at production units to ensure the compliance
with this Guideline.
1.2. Scope.
External Manufacturers and Suppliers and their Subcontractors should nominate a fully responsible trained
worker/operator to conduct Quality Control and Health and Safety Audits on a regular basis.
worker/operator to conduct needle distribution at factory level.
External Manufacturers and Suppliers and their Subcontractors should train all their workers and operators
on proper needle control and the contents of this Guide. The mentioned training program should include the
following topics:
- Machine cleaning.
- Needle exchange.
- Needle breakage.
- Swift tag gun needles used for attaching hangtags.
External Manufacturers and Suppliers should keep a record of the mentioned training courses given to their
workers/operators.
128
2. Commitments.
External Manufacturers and Suppliers and their Subcontractors should control the use of staples, metal
paper clips and pins, mainly.
External Manufacturers and Suppliers and their Subcontractors should train fully responsible specialists/
mechanics to conduct and document scheduled needle changes. Additionally, the quantity of needles
should be verified and recorded each time .
External Manufacturers and Suppliers and their Subcontractors should have metal disposal boxes available
on each floor/line to keep, control and isolate safely metal parts found or exchanged needles.
External Manufacturers and Suppliers and their Subcontractors should control:
- Uncontrolled spare needles.
- Uncontrolled metal tools from a tool board.

- Unfixed scissors, timmers and seam openers from the machine.
- Unused tools to be located on the tool board at all times.
129
3. Scope.
3.1. Cutting Area.
Markers must be fused onto fabric in order to avoid the use of pins or stuck with tape onto the upper layer.
Metal clamps can be used but the number of clamps per cutting table must be checked after every shift.
The quantity of the pins must be recorded when pins are used for striped and checked fabric.
Supplier of above mentioned fabrics/padding must have a metal detection process.
3.2. Embroider Area.
This Area must follow a strict needle control policy.
All panels with embroideries must pass metal detection before they go to into sewing line (either Done by
External Subcontractor or Manufacturer itself)
Daily broken needle report must be kept.
3.3. Sewing Area.
3.3.1. Needle Replacement Procedure.
New needles must be stored in a locked place operated by a nominated fully responsible trained worker/
operator.
No other needles except the sewing machine needles should be allowed at the machine.
New needles must only be handed out to the operators by the nominated fully responsible trained worker/
operator.
New needles must only be handed out in exchange of damage needle or all the parts of the broken needles.
All broken needles parts must be taped on to the Broken Needle Report.
Machine drawers must be checked regularly by the line supervisor and machine tools must be kept in a
secure place and accounted for at the end of each day.
Mechanics must not leave any needles on the machine.
Screwdrivers and machine tools must be kept in a secure place and be accounted for at the end of each
day.
3.3.2. Broken Needle/ Part Not Found.
In case not all parts of the broken needle were to be found the following procedure needs to be implemented:
Request of thorough search of garment panels and work area. If not all parts of the needle found, the opera
tor must inform the supervisor.
Carry on a supervisor control of all garment panel within the area of 2.5 meters around the machine in a
transparent plastic bag and check for broken needle through the metal detector. If the needle parts cannot
be found during this checking, this parcel should be checked by the metal detector one more time.
If the broken part of the needle can not be found after 2 times of needle detection checking the production
should only continue by formal authorization ofthe manager.
To document all actions taken in a proper file.
130
3.3.3. Broken Needle Report.

The Broken Needle Report is a spreadsheet which includes the following columns:
Section
MC type
Needle size
Seam operation
Style/order
Action
An individual sheet should be issued for each needle type to easily identify incomplete broken needles.
The column for the needles parts should be of the same width as the length of the needle.
The broken needles on one page should match the pacing unit of the needle for easy book-keeping.
Old broken needle reports must be properly disposed in order to prevent any person from harm.
The Broken Needle Report must be analyzed in a regular basis to gain important information which can
prevent problems. This issue should mainly include:

1. Type of fabric, where incidence of needle breakage is high.
2. Kind of machine/operation where incidence of needle breakage is high.
3. Size of needle with high incident of breakage.
4. Does the needle always break into several pieces?
5. What style/product has a high incidence of needle breakage?

The Broken Needle Reports must be kept for a period of at least five years.
3.3.4. Packing Area (Metal Detection Area)
The metal detection process must be carried on in an isolated area of the warehouse with restricted access.
The area must be free of any metal contamination or high power supply cable that might affect the sensitivi
ty of testing.
All packed and sealed garments must be tested by the metal detector once at a time.
Records of the metal detection process must be kept on a record sheet.
All garments which have passed the metal detection process must be immediately packed in the delivery
carton. The carton must be sealed and signed with a sticker stating metal free.
Delivery cartons must not be stapled and need to be free of metal.
131
4. Tools.
4.1. Metal Detector.
Only nominated fully responsible trained workers will be allowed to handle and operate the metal detectors.
Trained workers operating the metal detectors should be metal free (i.e. watch and ring, mainly)
Metal detectors must be calibrated at least once a year by the metal detectors engineer. This process
should be documented.
Metal detectors need to follow the standard ferrous diameter 1.0 mm. and all of them must react against
with the mentioned standard at the weakest sensitive points.
External Manufacturers and Suppliers must ensure that the sensitivity points of the metal detectors in use
are checked and calibrated at least once a month. This process must be documented.
Metal detectors must be calibrated to react at these nine points against the standard of ferrous diameter 1.0
mm. This process should be documented. Adjustments to be done if necessary.
External Suppliers and Manufacturers must detect every garment in horizontal and vertical direction with the
metal detector. Different ways of metal detector machine set ups are possible to ensures that the conveyer
type is used1. If garment fails to pass the metal detection process it must be kept in a separate box until
further checking. This box must be locked and have a slit to deposit the contaminated garment2.
Lastly, if an unreasonable amount of garments fails the metal detection process the factory must locate the
source of the detection and inform the respective persons immediately.
4.2. Documentation.
External Manufacturer and Suppliers and their Subcontractors must document the metal detection process
on 'Factory Metal Detecting Report' (See Annex 1)
Records need to be kept at least 5 years and need to be available upon request by either Inditex or its Ex
ternal Quality Control and Health and Safety Team.
Broken Needle Report must be maintained by fully responsible trained workers/operators.
Accurate records of needle issued to production lines must be kept and checked regulary (needle stock
control sheet) by fully responsible trained worker/operator.
1 The
metal detector must have an automatic stop when metal is detected.
2 Only
132
the mentioned earlier must then be documented in a report.
4.3. Compliance Assessment.

Lastly, Inditex will assign an External Quality Health & Safety Team Control Team to audit each factory based
on a regular basis.
Example of two-way needle detection by two sets of single gate needle detector. Source: SGS Internacional
133
III. ANNEX
III. Annex I.
1. Factory Metal Detecting Report.
Vendor Name:
Audit Date:
Factory Name:
Factory Location:
Style #:
Season:
Color #:
PO Qty.:
PO # :
Shipped Qty.:
Info
Detector Type:
Conveyor
Table Top
Hand Held
1.0mm
1.0mm
1.0mm
Yes
No
Brand Name:
Model#:
Intensively:
Remarks:
Test passed
We, here confirm that we have inspected the above mentioned Style / Quality by metal detector and have sorted out any metal contaminated
product from shipment.
Factorys Representative:
Factorys QA Manager:
Signature:
Signature:
Date:
Date:
134
ANNEX II:
Commitment to
comply with the
Inditex groups
Safe to Wear
2010 product
safety standard
COMMITMENT TO COMPLY WITH THE INDITEX GROUPS SAFE TO WEAR 2010 PRODUCT
SAFETY STANDARD.
I hereby confirm that:
1) We have received the Safe To Wear Metal Detecting Policy & Vendor Guideline 2010 product safety Stan
dard (hereinafter, STW), we have read it and thoroughly understand its implications;
2) We acknowledge that compliance with the STW-Vendor Guideline is a contractual obligation and undertake,
accordingly, to meet the STW-Vendor Guideline requirements in all orders1 involving production, marketing
or distribution placed by any of the formats of the Inditex Group effective as of April 15th 2010.
3) We acknowledge that compliance with the STW-Metal Detecting Policy is a contractual obligation and un
dertake, accordingly, to meet the STW-Metal Detecting Policy in all orders2 involving production, marketing
or distribution placed by any of the formats of the Inditex Group effective as of 1st April.
4) We undertake to disclose and formally demand STW implications to the whole of the production line.
5) We acknowledge that as of April 15th 2010, the Inditex Group:
Reserves the right to check: i) compliance with STW regarding any good supplied, by any method,
at any time, and/or at any stage of the production, marketing or distribution processes, and ii) the
appropriate disclosure of STW.
Reserves the right to cancel any order for any good where non compliance with STW regarding any
test and/or inspection carried out pursuant to the printout has been established.
Reserves the right to return any orders already delivered where non compliance with STW regarding
any test and/or inspection carried out pursuant to the printout has been established.

Reserves the right to cancel or destroy, or to order destruction of the goods subject to the cance
lled order, subject to the fact that the cancellation of the relevant order shall entail the non existence
of the obligation to pay any sum whatsoever for the goods failing to comply with STW.
Holds the Supplier as solely responsible for any and all damages caused by the goods failing to
comply with STW;
and last,
6) We acknowledge that approval of a sample and any subsequent repetition of goods by the INDITEX
Group do not release us from our liability, for the entire production, marketing and distribution processes.
The scope of the requirements laid down in STW-Vendor Guideline is as follows: i) goods for babies and toddlers aged 0-3: Re
quirements included in chapters II and III; ii) goods for children aged 3-14: Requirements included in chapters II.1 and III; and, iii)
goods for adults : Requirements included in chapter III
The scope of the requirements laid down in STW-Metal Detecting Guideline exclusively covers goods for babies and toddlers aged
0-3.
137
TABLE OF CONTENTS
TABLE OF CONTENTS
I. DEFINITION OF THE STANDARD........................................................................ 87
II. CHILDRENS GARMENT SAFETY....................................................................... 88
1. Cords and Drawstrings.................................................................................. 88
2. Separable Small Parts................................................................................... 89
5. Sharp Points (1/2)......................................................................................... 92
6. Sharp Edges (2/2).......................................................................................... 93
III. LEGALLY REGULATED PARAMETRES............................................................... 94
ANNEX I: REQUIREMENTS OF THE UNE-EN 14682 STANDARD.............................. 97
1. Generalities.................................................................................................... 97
2. Hood and Neck Area in Young Childrens Garments....................................... 98
3. Hood and Neck Area in Clothing for Older Children and Youths..................... 98
4. Waist Area of the Garments........................................................................... 99
5. Lower Edges of the Garments that Hang Below the Waist............................. 99
6. Sleeves........................................................................................................ 100
7. Other Parts of the Garment.......................................................................... 100
ANNEX II: MEASUREMENTS .............................................................................. 101
1. Measurement of cords with the end loose.................................................. 101
2. Measurement of a cord with no loose end.................................................. 101
ANNEX III: AREAS / ZONES OF THE BODY........................................................... 102
ANNEX IV: EXAMPLES OF CORDS AND DRAWSTRINGS....................................... 103
ANNEX V: SMALL PARTS CYLINDER.EN 71-1..................................................... 112
ANNEX VI: TENSION TEST. EN 71-1.................................................................... 113
ANNEX VII: TORQUE TEST. EN 71-1.................................................................... 114
ANNEX VIII: SHARP POINTS. EN 71-1................................................................. 115
ANNEX IX: SHARP EDGES. EN 71-1................................................................... 116
IV. BIBLIOGRAPHY............................................................................................. 117
85

The Safe to Wear Standard (hereinafter STW) is defined as a Product Safety Standard and it has been developed by Inditex in accordance with the following safety regulations:
- UNE-EN 71-1:1988 Safety of Toys. Mechanical and physical properties.
- UNE-EN 14682-2004 Safety of Childrens Clothing. Cords and Drawstrings on Childrens Clothing. Specifications.
- BS 7907:1997 Code of Practice of the Design and Manufacture of Childrens Clothing to Promote Mechanical Safety.
- PNE 40902 (Spain) Seguridad de prendas de beb. Propiedades fsicas y mecnicas.
- CPSIA (United States) Consumer Product Safety Improvement Act of 2008.
- CPSC (United States) Flammable Fabrics Act (16 CFR II, Subchapter D)
- CPSC (United States) Flammability of Clothing Textiles (16 CFR II, Subchapter D, Part 1610)
- CPSC (United States) Flammability of Childrens Sleepwear (16 CFR II, Subchapter D, Part 1615 & 1616)
- Regulations (SOR/87-443) (Canada) Hazardous Products (Childrens Sleepwear) Regulations (SOR/87-443)
- UK Regulation The Nightwear (Safety) Regulations 1985, S.I. 2043 & Amendment 1987, S.I. 286, Childrens
for Babies Under 3 Months Must Contain A Permanent Label Showing Wheather or not They Meet Flammability Standard.
- Swedish Regulation Guidelines on Fire Properties of Apparel Textile (Flammability), Product Safety Act (SFS
1988 : 1604)
- Australian Flammability Regulation Childrens Nightclothes Having Reducing Fire Hazard.
- Netherland Regulation: Netherland Mandatory Fire Safety Requirements.
- EN 14878: Flamability to be Performed for Children Nightwear.
- ASTM F963: Small Parts Attachments (Sharp Edges & Sharp Points)
- M16 CFR 150 Remoral of Small Parts Accessories (Torque & Tension Test)
- ASTM F1816 Drawstring and Cords.
87

1. Cords and Drawstrings.
Products to control
Cords and drawstrings.
Standard
UNE-EN 146821.
Strangulation and Entrapment.
Objective
Minimise the risk of accidental entanglement by cords and drawstrings on childrens clothing1.
Application / Age
Garments intended for minors between 0-14 years of age.
Controls
UNE-EN 14682:20042.
Best practices
Conduct obligatory visual inspections, and in accordance with the standard of garments / models - quality intended for children under 3 years of age that contain cords and drawstrings.
Conduct visual inspections in accordance with the standard of garments / models - quality intended for
minors between the ages of 3 and 14 years of age, ONLY if the failure rate in products intended for children
under 3 years of age is not acceptable.
Recommendations
Make manufacturers and distributors of childrens clothing aware of the content and scope of the standard.
The scope of - UNE-EN 14682:2004 - is restricted to cords and drawstrings for childrens clothing, including costumes and ski
garments, up to the age of 14. The following articles are excluded from this group: (1) care articles (diapers and dummy fasteners);
(2) shoes, boots and similar footwear; (3) gloves, hats and scarves; (4) ties designed to be worn with a shirt or blouse; (5) belts and
straps; (6) religious garments; (7) sportswear of specialists and sportswear that is worn during limited periods of time and under
supervision (rugby suits, suits for aquatic activities and dance clothing, except when these garments are normally used as day or
night clothes) and (8) costumes used in theatre performances.
UNE-EN 14682:2004 specifies basic design requisites included in Annex I of this Guide.
88
2. Separable Small Parts.
Products to control
Separable Small Parts3.
Standard
EN 71-1.
Small Parts/Choking Hazards.
Objective
Avoid choking caused by young children sucking and partly swallowing ties, ribbons and similar items.
Application / Age
Garments intended for children under 3 years of age and /or children up to 98 cm in height.
Test Method
EN 71-1 (Small Parts cylinder)4
Test Requirement
Small parts shall not fit entirely in the cylinder.
3
4
Separable Small Parts: Any component attached permanenty to the garment (i.e. stickers and accessories, mainly)
See Test Method Summary in Annex V of this Guide.
89
Products to control
Non-Separable Small Parts5.
Standard
EN 71-1.
Objective
Avoid injuries from detached objects because of tension forces (buttons, popper fastener parts or zipper
puller become detached from the garment)
Application / Age
Test Method
EN 71-1 (Tension Test)6
Test Requirement
50 N when the largest accessible dimension is 6 mm or less.

90 N when the largest accessible dimension is greater than 6 mm.
Non separable Small Parts: Any component attached permanently to the garment. A breakdown is mainly as follows:
Sewn buttons.
Buckles.
Hooks.
Zippers.
See Test Method Summary in Annex VI of this Guide.
90
Products to control
Non-separable Small Parts7.
Standard
EN 71-1.
Objective
Avoid injuries from detached objects because of torque forces (buttons, popper fastener parts or zipper
pullers become detached from the garment)
Application / Age
Test Method
EN 71-1 (Torque Test)8
Test Requirement
0.45 Nm ( 4.0 lb.inch)
Non-separable Small Parts: Any component attached permanently to the garment. A breakdown is mainly as follows:
Sewn buttons.
Buckles.
Hooks.
Zippers.
See Test Method Summary in Annex VII of this Guide.
91
5. Sharp Points (1/2)
Products to control
Sharp Objects9.
Standard
EN 71-1.
Objective
Avoid injuries from sharp points found on buttons, zips, decorative features or deteriorated components.
Application / Age
nuets/rhinestones and zipper parts, mainly.
Test Method
EN 71-1 (Sharp Points )10
Test Requirement
Maximum penetration, 0.5 mm.
Sharp Objects: objects with points or edges that are or may be shown and they may have probability of causing insuries from
cutting or puncture.
10 See Test Method Summary in Annex VIII of this Guide.
92
6. Sharp Edges (2/2)
Products to control
Sharp Objects11.
Standard
EN 71-1.
Objective
Avoid injuries from sharp edges found on buttons, zips, decorative features or deteriorated components.
Application / Age
nuets/ rhinestones, zipper parts.
Minors between 0-3 years of age and or children up to 98 cm in height.
Test Method
EN 71-1 (Sharp Edges)12
Test Requirement
Maximum at length, 50%.
11 Sharp Objects: objects with points or edges that are or may be shown and may have probability of causing insuries from cutting or
puncture.
12 See Test Method Summary in Annex IX of this Guide.
93
III. LEGALLY REGULATED PARAMETERS

Flammability
1. What is it?
The ability of a material or product to burn with a flame under specified test conditions.
2. Where is it required?
Nightwear Requirements
It is required in all: i) baby clothing; ii) Childrens Nightwear, iii) Childrens Sleepwear, iv) adult nightwear and
v) Home Textiles.
It is required in all general apparel (adult & children) with the following exception gloves, footwear, interlining fabrics and garments made from: i) in Plain surface fabrics, regardless of fiber type, weighing 2.6 oz/
yd2 (85g/m2) or greater are exempt from the regulation and ii) in Apparel manufactured with these fibers
(Acrylics, Modacrylics, Nylon, Polyester, Wool and Olefins, mainly) or blends of these fibers, regardless of
weight, are exempt from the regulation.
3. How are they regulated?
CPSC (United States) Flammable Fabrics Act (16 CFR II, Subchapter D)
CPSC (United States) Flammability of Clothing Textiles (16 CFR II, Subchapter D, Part 1610)
CPSC (United States) Flammability of Childrens Sleepwear (16 CFR II, Subchapter D, Part 1615 & 1616)
Regulations (SOR/87-443) (Canada) Hazardous Products (Childrens Sleepwear) Regulations (SOR/87-443)
UK Regulation The Nightwear (Safety) Regulations 1985, S.I. 2043 & Amendment 1987, S.I. 286 , Childrens
for Babies Under 3 Months Must Contain a Permanent Label Showing Wheather or not They Meet Flammability Standard.
Swedish Regulation Guidelines on Fire Properties of Apparel Textile (Flammability), Product Safety Act (SFS
1988 : 1604)
Australian Flammability Regulation Childrens Nightclothes Having Reducing Fire Hazard.
Netherland Regulation: Netherland Mandatory Fire Safety Requirements.
Norway FOR 1984-02-13 nR 427 Forskrifter om forbud mot svaert brannbare tekstiler 13-02- 1984 Directive on prohibition of highly flammable textiles.
Swiss regulation: Swiss Ordinance 817.043.1
4. How is it analyzed?
It is analyzed by:
i) 16CFR1610 (ASTM D1230) for General Apparel Requirements; and
ii) BS5438:1989 with BS5722:1991, BS EN ISO 6940:2004 and BS ISO 1103:2007, for Childrens Nightwear
Requirements.
94
5. Which are the acceptable limits?

Childrens Nightwear Requirements
Pyjamas
Birth up to (6 months) height 68cm



Night Dresses, Dressing Gowns, Bath Robes (not cotton terry towelling) and similar garments
Birth up to 3 months

Over 3 months and up to height 68cm (6 months)



Bath Robes made of cotton terry towelling only


Over 3 months and up to 6 months



All baby garments

None
Babies garments: Garments exclusively for babies under 3 months and having a chest measurement not exceeding 53 centimetres (approx 21)
95
Adults Nightwear Requirements

Adults (older than 14 years old)


COUNTRY
TESTING METHOD
REQUIREMENTS
USA
CFR 16
Part 1610
CANADA
CAN/CGSB 4.2
NO. 27.5
NETHERLANDS
ASTM D1230
SWITZERLAND
EN 1103
Maximum flame spread velocity ( vp ), 90 mm/s and no surface flash.

Maximum flame spread velocity ( vp ), 120 mm/s for cellulosic fabrics with fabric weight less than 80 g/m2.
SWEDEN
ASTM D1230
NORWAY
ASTM D1230
Average time of flame spread ( tp )> 7 s for garments intended for children up to 170 cm
Average time of flame spread ( tp )> 5 s for garments intended for adults.
6. How can it be avoided?

By producing non flammable clothings.
Definitions:
Flammability: The ability of a material or product to burn with a flame under specified test conditions.
Ignitability: The measure of the ease with which a material, product or component can be ignited so as to
flame or progressively smoulder.
Flame retardance: The property of a material whereby flaming combustion is slowed, terminated or prevented. Flame retardance may be the property of either the materials used or may be applied after the fabric
has been produced.
Flame resistance: The ability of a material to withstand ignition (term deprecated)
96

1. Generalities.
1. The ends of the drawstrings, functional cords1 and the sashes2 must not be tied and must be protected to
avoid fraying (thermal bonding and stitched). The hem or fold of the end is permitted as long as it does not create
a risk of entanglement.
2. Baubles3 may only be used in drawstrings that do not have loose ends or decorative cords4 (see figure IV.1,
Annex IV: Samples of cords and drawstrings)
3. Childrens clothing must be designed in such a way that they do not have drawstrings, decorative or functional
cords that protrude from the back part of the garment or that are fastened to the back (except the sashes) (see
figure III.2, zone D, Annex III: Areas/zones of the body) (see figure IV.2, Annex IV: Examples of cords and drawstrings)
4. In case of being permitted, the cords must be fastened (using a stitch in at least one point equidistant from the
exit points. See figure IV.3, Annex IV: Examples of cords and drawstrings)
5. Fixed loops that protrude from the garment, for example, in order to tie it, must have a circumference that does
not exceed 75 mm. Flat loops that do not stick out from the garment (ribbons/loops of the straps) must have
a length measured between the fixed points of the accessory to the garment less than or equal to 75 mm (see
6. Zipper pulls, including any adornment, must have a length less than or equal to 75 mm measured from the
body of the pull and, in addition, must not extend beyond the lowest edge of the clothing designed to end at the
ankle (see figure IV.5, Annex IV: Examples of cords and drawstrings)
7. All the measurements must be made according to Annex II: Measurements.
1
2
3
4
garment.
Bauble: Piece of wood, plastic, metal or of any other material fastened or placed on a drawstring, functional cord or decorative
cord.
Decorative cord: non-functional band, chain, ribbon, drawstring or strip of any textile or non-textile material with or without embellishments, such as baubles, pom-poms, feathers or beads, of a fixed length and not used to adjust the size of the opening of the
97
2. Hood and neck area in young childrens garments5.

1. Clothing for young children must not be designed, manufactured or supplied with drawstrings, functional1 or
decorative4 cords in the hood or in the neck area.
2. The tab fastener6 is permitted as long as the length is not over 75 mm.
3. Straps7 are permitted as long as they are made of a continuous material or cords tied in the front and back part
of the garment. Decorative cords tied to the straps must not have loose ends that are longer than 75 mm and the
fixed loops must not have a circumference larger than 75 mm (see figure IV.7, Annex IV: Examples of cords and
drawstrings)
4. Garments with cords around the neck must be designed without loose ends in the hood and neck area (see
5. Adornments sewn or connected in another way, for example ribbons8, must not have loose ends longer than 75
mm. No ribbon/loop may have a circumference larger than 75 mm. (See figure IV.9, Annex IV: Examples of cords
and drawstrings)
3. Hood and neck area in clothing for older children and youths.
1. Drawstrings must not have loose ends.
- When the garment is opened as far as possible and laid flat, no ribbon should protrude. When the opening
is at the minimum, that is, that which corresponds to the size for which it is intended to be adjusted, the
maximum circumference of the loop will be 150 mm. (See figure IV.10, Annex IV: Examples of cords and
drawstrings)
2. Decorative cords must not have a length over 75 mm in the ends including any fastening element, such as, for
example, a bauble3. The decorative cords should not be fabricated with elastic cords.
3. Functional cords and tab fasteners must not have a length over 75 mm on each end. Functional cords should
not be fabricated with elastic cords10, except straps and cords in the neck area.
4. Garments with a cord around the neck must be fabricated without loose ends in the hood and neck area.
5. Straps are permitted as long as the loose ends are not over 140 mm, measured from the point in which they
are tied and the fixed loops must not have a circumference over 75 mm (see figure IV.7, Annex IV: Examples of
cords and drawstrings)
garment.
3 Bauble: Piece of wood, plastic, metal or of any other material fastened or placed on a drawstring, functional cord or decorative
cord.
4 Decorative cord: non-functional band, chain, ribbon, drawstring or strip of any textile or non-textile material with or without embellishments, such as baubles, pom-poms, feathers or beads, of a fixed length and not used to adjust the size of the opening of the
5 Young child: a person from the time of birth until he reaches 7 years of age (that is, 6 years and 11 months); also included in this
6 Tab fastener: small strip of fabric not less than 20 mm in width used to adjust the size of the opening of a garment (ankles or
sleeve cuffs)
7 Straps: functional cord that joins the front and back parts of the upper part of a garment that clings to the body and passes over
the shoulder.
8 Ribbon: A cord or narrow strip of curved material, with a fixed or adjustable length, in which the two ends are fastened to the
garment.
9 Older children and youths: person from 7 years of age up to 14 (13 years and 11 months), also including all the boys with height
10 Elastic cord: drawstrings that contain rubber threads or are of elastodiene polymer, elastane or similar materials, which have high
elasticity and complete or almost complete recovery.
1
98
4. Waist area of the garments (figure 1, zone b, annex III; area/zones of the body)
1. Cords in the waist area may protrude a maximum of 140 mm on each end when the garment is lying flat according to the design and must not exceed 280 mm when it is closed or adapted to the corresponding waist size.
Cords without loose ends must have a loop/ribbon with a maximum circumference of 280 mm when they are
adapted to the corresponding waist size (see figure IV.15, Annex IV: Examples of cords and drawstrings)
2. Functional1 and decorative4 cords and tab fasteners in the waist area may have a maximum length of 140 mm
including any adornment on the decorative cords.
3. Young children5: Sashes2 designed to be tied in the back of the garments are permitted, as long as when they
are untied they do not exceed 360 mm, measured from the tying point and, in addition, when they are untied they
must not hang below the hem of the garment (see figure IV.16, Annex IV: Examples of cords and drawstrings)
4. Older children and youths9: Sashes designed to be tied in the back of the garments are permitted as long as
when they are untied they do not exceed 360 mm, measured from the tying point (see figure IV.16, Annex IV:
Examples of cords and drawstrings)
5. Sashes designed to be tied in the front of the garment are permitted as long as when they are untied they do
not exceed 360 mm, measured from the tying point (see figure IV.17, Annex IV: Examples of cords and drawstrings)
5. Lower edges of the garments that hang below the waist (figure III.1, zone c, annex III; areas/zones of
the body)
1. The drawstrings, decorative or functional cords that may include any bauble3 on the lower edge of the garments in which the lower edge is situated below the hips, must not hang below the lower edge of the garment
and they must be situated completely within the garment (see figure IV.11, Annex IV). When they are on the
outside of the clothing, cords or drawstrings must lie flat against the garment when it is adjusted or fastened (see
2. There must not be any drawstrings, functional or decorative cords extending below the lower edge of coats,
pants or skirts designed to end at the ankle (stirrups are acceptable on the edge of the pants)
3. The tab fasteners6 are acceptable if their length is no more than 140 mm and, in addition, they must not hang
below the garment (see figure IV.12, Annex IV: Examples of cords and drawstrings)
1
2
3
4
5
6
9
garment.
Bauble: piece of wood, plastic, metal or of any other material fastened or placed on a drawstring, functional cord or decorative
cord.
sleeve cuffs)
99
6. Sleeves.
1. When the sleeve is fitted, the drawstrings, functional1 and decorative cords4 on the lower edge of the longsleeved garments must be completely situated in the interior of the garment (see figure IV.13, Annex IV: Examples
of cords and drawstrings)
2. Young children5: drawstrings, functional and decorative cords are permitted in short-sleeved garments whenever the sleeves end above the elbow and when the maximum length that protrudes is 75 mm, measured when the
sleeve is flat on the model (see figure IV.14, Annex IV: Examples of cords and drawstrings)
3. Older children and youths9: drawstrings, functional and decorative cords are permitted in short sleeved garments when the sleeves end above the elbow and their maximum length is not over 140 mm, measured when it is
flat on the model (see figure IV.14, Annex IV: Examples of cords and drawstrings)
4. The tab fasteners6 are permitted on sleeves as long as they do not exceed 100 mm and, in addition, when they
are open they do not extend below the hem of the garment (see figure IV.6, Annex IV: Examples of cords and
drawstrings)
7. Other parts of the garment.

1. In other areas of the garment not mentioned above, drawstrings or functional and decorative cords must not
protrude more than 140 mm, when the garment is completely open (maximum)
1
4
5
6
9
garment.
sleeve cuffs)
100

All the measurements must be made with cords or loops in a relaxed state.
1. Measurement of cords with the end loose.

LEGEND
1. Cord - straight (one loose end)
2. Garment.
3. Length of the cord (in mm)
2. Measurement of a cord with no loose ends.

LEGEND
1. Bauble.
2. Cord - with no loose end.
3. Garment.
4. Length of the loop (in mm)
5. Fixed ends - both fixed or inside the garment.
101
Key
A= hood and neck area.
B= chest and waist area.
C= under the hips.
D= back area.
102
103
104
105
Key
2= Case 2 of hood and neck area for young children, max. 75 mm.
= Case 5. Hood and neck area for all her children and youths, max. 140 mm.
106
107
108
Key
1= case 2 of sleeves: young children max. 75 mm.
case 3 of sleeves: older children max. 140 mm.
109
110
Width of the belt 30 mm.

Length of the belt from where it is tied 360 mm.
111

1. Test Method.
EN 71-1.
2. Test Equipment.
Cylinder according to EN 71-1.
3. Test Procedure.
To place the Separable Small Part, without compressing and in any orientation, in a cylinder that has the
dimensions shown in figure V.1.
To verify if the Separable Small Part doesnt fit entirely in the cylinder.
112

1. Test Method.
EN 71-1.
2. Test Equipment.
Clamps.
Loading device.
3. Test Procedure (for grippable component)

Affix a suitable clamp behind the component.
Fasten the garment in the apparatus and apply force to the component.
Apply the force gradually within a period of 5 s.
Maintain the force for 10 s.
4. Grippable Definition.
Test equipment:
Feeler gauge.
Test procedure:
Inserting the feeler gauge between the component and the underlying layer at an angle between 0o and
10o from the small part surface using a force 10N.
If the gauge can be inserted more than 2 mm, the component shall be considered as grippable.
50 N, when the largest accessible dimension is 6 mm or less.
90 N, when the largest accessible dimension is greater than 6 mm.
6. Application.
Any projection of a garment that the child can grasp with at least the thumb and forefinger or the teeth shall
be subject to this test.
This test is to be conducted on the same garment that has been subjected to the torque test (i.e. Zipper
pullers, buttons, hook & loop, D rings, pompoms, tassels, bows, rosettes, appliques, hasp/slider and other
decorative components, mainly)
113

1. Test Method.
EN 71-1.
2. Test Equipment.
Torque Gauge.
3. Test Procedure.
A torque of specified force shall be applied evenly within a period of 5 seconds in a clockwise direction or
until a rotation of 180 degrees from the original position.
The torque or maximum rotation shall be maintained for an additional 10 seconds. The torque shall then be
removed and the test component permitted to return to a relaxed condition. This procedure shall then be
repeated in a counterclockwise direction.
0,45 Mn (4.0 lb. inch)
114

1. Test Equipment.
Sharp Point Tester.
2. Test Procedure.
Insert the point into the cap slot.
Apply a force of 4.5 N to depress the spring.
The point is consider as sharp point if the point penetrates a distance of 0.5 mm or more into the gauging
slot, causing the indicator lamp to light.
4. Application.
Safety pins, straight pins, decorative ornamental pins, broken needles, exposed prongs of snaps / studs /
rivets / rhinestones and zipper parts, mainly.
115

1. Test Equipment.
Sharp Edge Tester.
2. Test Procedure.
Wrap one layer of standard self-adhesive tape around the full circumference of the mandrel.
Apply a force of 6 N to the mandrel and rotate the mandrel 360o about its axis against the edge.
Remove the tape without enlarging any cut or causing any score to become a cut.
If the cut in the tape with a length of more than 50%, the edge tested is considered to be a sharp edge.
4. Applications.
rivets/rhinestones and zipper parts, mainly.
116
IV. BIBLIOGRAPHY.
IV. BIBLIOGRAPHY1.
- ASTM Standard F 1816-97. Standard safety specification for drawstrings on childrens upper outerwear.
- BS 7907: 1997 Code of practice for the design and manufacture of childrens clothing to promote mechanical
safety.
- Budavari, E. & Eiben O., 1982. Evaluation of School Furniture with regard to Students Body Measurements,
Ergonomia, 15.2, 70-77.
- CEN/BTWG/117 N11 Draft for Comment Child Safety - Guidelines for its Inclusion in Standards.
- CEN/TR 1338 7:2004 CEN Child Use and Care Articles - General and Common Safety Guidelines.
- CEN Guidelines M/293.
- CHILDATA published by the DTI, UK, 1995.
- DIN 33402: Body Dimensions of People; Values, June 1981.
- XP G30-105 (2002) Scurit des vtement denfants Cordons ou Liens de serrage.
- EN 71-1: 2001 Safety of Toys: Part 1 Mechanical and Physical Properties.
- Home Accident Surveillance System Annual Report. Accident Data and Safety Research: Home, Garden and
Leisure UK Department of Trade and Industry Consumer Affairs and Policy Directorate.
- ISO/IEC Guide 50:2002 Safety Aspects- Guidelines for Child Safety.
- Joubert, D., 1982, Le salon international de la mode enfantine, Filiere Maille, Sept-Oct. 20.
- Ostyn, M., Simons, J., Beunen, G., Renson, R. & Van Gerven, D., 1980, Somatic And Motor Development of
Belgian Secondary Schoolboys - Norms and Standards, Leuven University Press, Belgium.
- Pheasant, S. T., 1986, Bodyspace: Anthropometric Ergonomics and Design, Taylor and Francis, London, UK.
- Sihvola Seija (2000) A Health Dialogue in the School Entrance Health Examination, Acta Universitatis Tamperensis 751: Tampere.
- Stakes (1998) Lasten ja nuorten hyvinvointi ja terveys Suomessa, Statistical Report 13/1998, 129.
- Steenbekkers, LPA, 1993, Child Development, Design Implications & Accident Prevention. No. 1 in Physical
Ergonomics Series, TU Delft (Delft University of Technology) Netherlands.
- UK legislation: Childrens Clothing (Hood Cords) Regulations 1976.
- Waaler, P.E. 1983, Anthropometric Studies in Norwegian Children, Acta Paediatrica Scandinavica, Supplement
308, 2-38.
Bibliography source: EN 14682:2006.
117
TABLE OF CONTENTS
TABLE OF CONTENTS
I. METAL DETECTING POLICY............................................................................. 125

1. Definition and Scope.................................................................................... 125
2. Commitments of the External Suppliers and Manufacturers....................... 126
3. Commitments of the Packing, Trim and Accessory Suppliers...................... 127
II. METAL DETECTING PRODUCTION GUIDELINE.................................................. 128
1. Training........................................................................................................ 128
2. Commitments.............................................................................................. 129
3. Scope........................................................................................................... 130
4. Tools............................................................................................................. 132
III. ANNEX I
1. Factory Metal Detecting Report................................................................... 137
IV. ANNEX II
Commitment to Comply with the Inditex groups Safe to Wear Product Safety
Standard.......................................................................................................... 141
123
I. METAL DETECTING POLICY.

1. Definition and Scope.
The Metal Detection Policy (here in after the Policy) is a mandatory procedure designed by Inditex to ensure that
all the products supplied by any External Manufacturers and Suppliers and their Subcontractors to Inditex do not
contain any needle, pin, staple or any metallic item (from any stage of the production process) that may cause
any injury if inadvertently left in the product.
The Policy has been designed to protect not only the Health and the Safety of Inditexs Consumers, its Reputation as well as the External Suppliers and Manufacturers and their Subcontractors, but also the Health and Safety
of the workforce involved in any stage of the Inditex s Supply Chain.
The Policy implies that:
It is a mandatory requirement since its approval and its non-compliance or violation can therefore not be
tolerated and will lead to penalties starting from form fines tile cancellation of all orders.
When External Manufacturers and Suppliers and their subcontractors be not the manufacturer, they must
ensure that any products supplied to Inditex will be in accordance with the Policy.
All Inditex apparel items should be 100% ferrous free.
125
2. Commitments of the External Suppliers and Manufacturers.

The External Manufacturer and Suppliers and their Subcontractors commit themselves:
Ferrous Detection Test:
To manufacture their products using packing material, trims and accessories containing metallic components be made only of non-ferrous metal. Consequently, all metal accessories should pass the ferrous
detection check with maximum diameter 1.00 mm from any direction.
To check all incoming trims and accessories at least on a random basis in order to identify eventual metallic
contamination at an early stage. Consequently, Inditexs External Manufactures and Suppliers Top Management will be immediately informed of any trims or accessories identified after the ferrous detection process.
To pass a metal detection test with maximum Diameter 1.00mm from any direction before carrying out the
Final Inspection in all products manufactured to Inditex.
To ensure that the metal detection machine is maintained properly and set according to the standard.
At manufacturing level:
To make all machine workers/operators aware of the relevance and importance of the Policy and its implementation.
To nominate fully responsible trained workers to keep the control of all new machine needles for embroidery,
hosiery, knitting and sewing, mainly.
To ensure that all sewing needles in the possession of the machine workers/operators are controlled at any
time during the manufacturing process.
To nominate fully responsible trained workers to monitor the adequate implementation of the Policy and
deal with contaminated products.
Action to be taken with contaminated products:
To destruct the product affected by it and to eliminate any possibility of its future use.
To record product contaminated in a formal file.
To keep the mentioned files available for inspections anytime when either Inditex or its External Quality Control and Health and Safety Team require.
To check again new samples of previous contaminated products to ensure their conformity with the Policy
and its requirements once the contaminated product situation has been corrected.
126
3. Commitment of the Packing, Trim and Accessory Suppliers.

The Packaging, Trims and Accessory External Suppliers must ensure that all packing material, trims and
accessories are metal (ferrous) free and have successfully passed a metal detection process prior to the
beginning of the manufacturing process.
This process must to be recorded and all its documents must be available upon request from either Inditex
or its External Quality Control and Health and Safety Team.
127
II. METAL DETECTING PRODUCTION GUIDELINE.

1. Training.
1.1. General.
External Manufacturers and Suppliers and their Subcontractors are responsible for conducting and documenting regular Quality Control & Health and Safety Audits at production units to ensure the compliance
with this Guideline.
1.2. Scope.
worker/operator to conduct Quality Control and Health and Safety Audits on a regular basis.
worker/operator to conduct needle distribution at factory level.
External Manufacturers and Suppliers and their Subcontractors should train all their workers and operators
on proper needle control and the contents of this Guide. The mentioned training program should include the
following topics:

- Machine cleaning.
- Needle exchange.
- Needle breakage.
- Swift tag gun needles used for attaching hangtags.

External Manufacturers and Suppliers should keep a record of the mentioned training courses given to their
workers/operators.
128
2. Commitments.
External Manufacturers and Suppliers and their Subcontractors should control the use of staples, metal
paper clips and pins, mainly.
External Manufacturers and Suppliers and their Subcontractors should train fully responsible specialists/
mechanics to conduct and document scheduled needle changes. Additionally, the quantity of needles
should be verified and recorded each time .
External Manufacturers and Suppliers and their Subcontractors should have metal disposal boxes available
on each floor/line to keep, control and isolate safely metal parts found or exchanged needles.
External Manufacturers and Suppliers and their Subcontractors should control:

- Uncontrolled spare needles.
- Uncontrolled metal tools from a tool board.
- Unfixed scissors, timmers and seam openers from the machine.
- Unused tools to be located on the tool board at all times.
129
3. Scope.
3.1. Cutting Area.
Markers must be fused onto fabric in order to avoid the use of pins or stuck with tape onto the upper layer.
Metal clamps can be used but the number of clamps per cutting table must be checked after every shift.
The quantity of the pins must be recorded when pins are used for striped and checked fabric.
Supplier of above mentioned fabrics/padding must have a metal detection process.
3.2. Embroider Area.
This Area must follow a strict needle control policy.
All panels with embroideries must pass metal detection before they go to into sewing line (either Done by
External Subcontractor or Manufacturer itself)
Daily broken needle report must be kept.
3.3. Sewing Area.
3.3.1. Needle Replacement Procedure.
New needles must be stored in a locked place operated by a nominated fully responsible trained worker/
operator.
No other needles except the sewing machine needles should be allowed at the machine.
New needles must only be handed out to the operators by the nominated fully responsible trained worker/
operator.
New needles must only be handed out in exchange of damage needle or all the parts of the broken needles.
All broken needles parts must be taped on to the Broken Needle Report.
Machine drawers must be checked regularly by the line supervisor and machine tools must be kept in a
secure place and accounted for at the end of each day.
Mechanics must not leave any needles on the machine.
Screwdrivers and machine tools must be kept in a secure place and be accounted for at the end of each
day.
3.3.2. Broken Needle/ Part Not Found.
In case not all parts of the broken needle were to be found the following procedure needs to be implemented:
Request of thorough search of garment panels and work area. If not all parts of the needle found, the operator must inform the supervisor.
Carry on a supervisor control of all garment panel within the area of 2.5 meters around the machine in a
transparent plastic bag and check for broken needle through the metal detector. If the needle parts cannot
be found during this checking, this parcel should be checked by the metal detector one more time.
If the broken part of the needle can not be found after 2 times of needle detection checking the production
should only continue by formal authorization ofthe manager.
To document all actions taken in a proper file.
130
3.3.3. Broken Needle Report.

The Broken Needle Report is a spreadsheet which includes the following columns:
Section
MC type
Needle size
Seam operation
Style/order
Action
An individual sheet should be issued for each needle type to easily identify incomplete broken needles.
The column for the needles parts should be of the same width as the length of the needle.
The broken needles on one page should match the pacing unit of the needle for easy book-keeping.
Old broken needle reports must be properly disposed in order to prevent any person from harm.
The Broken Needle Report must be analyzed in a regular basis to gain important information which can
prevent problems. This issue should mainly include:

1. Type of fabric, where incidence of needle breakage is high.
2. Kind of machine/operation where incidence of needle breakage is high.
3. Size of needle with high incident of breakage.
4. Does the needle always break into several pieces?
5. What style/product has a high incidence of needle breakage?

The Broken Needle Reports must be kept for a period of at least five years.
3.3.4. Packing Area (Metal Detection Area)
The metal detection process must be carried on in an isolated area of the warehouse with restricted access.
The area must be free of any metal contamination or high power supply cable that might affect the sensitivity of testing.
All packed and sealed garments must be tested by the metal detector once at a time.
Records of the metal detection process must be kept on a record sheet.
All garments which have passed the metal detection process must be immediately packed in the delivery
carton. The carton must be sealed and signed with a sticker stating metal free.
Delivery cartons must not be stapled and need to be free of metal.
131
4. Tools.
4.1. Metal Detector.
Only nominated fully responsible trained workers will be allowed to handle and operate the metal detectors.
Trained workers operating the metal detectors should be metal free (i.e. watch and ring, mainly)
Metal detectors must be calibrated at least once a year by the metal detectors engineer. This process
should be documented.
Metal detectors need to follow the standard ferrous diameter 1.0 mm. and all of them must react against
with the mentioned standard at the weakest sensitive points.
External Manufacturers and Suppliers must ensure that the sensitivity points of the metal detectors in use
are checked and calibrated at least once a month. This process must be documented.
Metal detectors must be calibrated to react at these nine points against the standard of ferrous diameter 1.0
mm. This process should be documented. Adjustments to be done if necessary.
External Suppliers and Manufacturers must detect every garment in horizontal and vertical direction with the
metal detector. Different ways of metal detector machine set ups are possible to ensures that the conveyer
type is used1. If garment fails to pass the metal detection process it must be kept in a separate box until
further checking. This box must be locked and have a slit to deposit the contaminated garment2.
Lastly, if an unreasonable amount of garments fails the metal detection process the factory must locate the
source of the detection and inform the respective persons immediately.
4.2. Documentation.
External Manufacturer and Suppliers and their Subcontractors must document the metal detection process
on 'Factory Metal Detecting Report' (See Annex 1)
Records need to be kept at least 5 years and need to be available upon request by either Inditex or its External Quality Control and Health and Safety Team.
Broken Needle Report must be maintained by fully responsible trained workers/operators.
Accurate records of needle issued to production lines must be kept and checked regulary (needle stock
control sheet) by fully responsible trained worker/operator.
1 The
metal detector must have an automatic stop when metal is detected.
2 Only
132
the mentioned earlier must then be documented in a report.
4.3. Compliance Assessment.

Lastly, Inditex will assign an External Quality Health & Safety Team Control Team to audit each factory based
on a regular basis.
Example of two-way needle detection by two sets of single gate needle detector. Source: SGS Internacional
133
ANNEX I:
Factory Metal
Detecting Report
III. ANNEX
III. Annex I.
1. Factory Metal Detecting Report.
Vendor Name:
Audit Date:
Factory Name:
Factory Location:
Style #:
Season:
Color #:
PO Qty.:
PO # :
Shipped Qty.:
Info
Detector Type:
Conveyor
Table Top
Hand Held
1.0mm
1.0mm
1.0mm
Yes
No
Brand Name:
Model#:
Intensively:
Remarks:
Test passed
We, here confirm that we have inspected the above mentioned Style / Quality by metal detector and have sorted out any metal contaminated
product from shipment.
Factorys Representative:
Factorys QA Manager:
Signature:
Signature:
Date:
Date:
137
ANNEX II:
Commitment to
comply with the
Inditex groups
Safe to Wear
product safety
standard
COMMITMENT TO COMPLY WITH THE INDITEX GROUPS SAFE TO WEAR PRODUCT

SAFETY STANDARD.
I hereby confirm that:
1) We have received the Safe To Wear Metal Detecting Policy & Vendor Guideline product safety Standard
(hereinafter, STW), we have read it and thoroughly understand its implications;
2) We acknowledge that compliance with the STW-Vendor Guideline is a contractual obligation and undertake,
accordingly, to meet the STW-Vendor Guideline requirements in all orders1 involving production, marketing
or distribution placed by any of the formats of the Inditex Group.
3) We acknowledge that compliance with the STW-Metal Detecting Policy is a contractual obligation and undertake, accordingly, to meet the STW-Metal Detecting Policy in all orders2 involving production, marketing
or distribution placed by any of the formats of the Inditex Group.
4) We undertake to disclose and formally demand STW implications to the whole of the production line.
5) The Inditex Group:
Reserves the right to check: i) compliance with STW regarding any good supplied, by any method,
at any time, and/or at any stage of the production, marketing or distribution processes, and ii) the
appropriate disclosure of STW.
Reserves the right to cancel any order for any good where non compliance with STW regarding any
test and/or inspection carried out pursuant to the printout has been established.
Reserves the right to return any orders already delivered where non compliance with STW regarding
any test and/or inspection carried out pursuant to the printout has been established.
Reserves the right to cancel or destroy, or to order destruction of the goods subject to the cancelled order, subject to the fact that the cancellation of the relevant order shall entail the non existence
of the obligation to pay any sum whatsoever for the goods failing to comply with STW.
Holds the Supplier as solely responsible for any and all damages caused by the goods failing to
comply with STW;
and last,
6) We acknowledge that approval of a sample and any subsequent repetition of goods by the INDITEX
Group do not release us from our liability, for the entire production, marketing and distribution processes.
The scope of the requirements laid down in STW-Vendor Guideline is as follows: i) goods for babies and toddlers aged 0-3: Requirements included in chapters II and III; ii) goods for children aged 3-14: Requirements included in chapters II.1 and III; and, iii)
goods for adults : Requirements included in chapter III
The scope of the requirements laid down in STW-Metal Detecting Guideline exclusively covers goods for babies and toddlers aged
0-3.
141
Code of Conduct
for External
Manufacturers
and Suppliers
TABLE OF CONTENTS
TABLE OF CONTENTS
I. CODE OF CONDUCT FOR EXTERNAL MANUFACTURERS AND SUPPLIERS.......... 149

II. ANNEX I:
Commitment to Comply with the Code of Conduct for external
manufacturers and suppliers.......................................................................... 153
The Code is a free translation from the Spanish Version.
147
I. CODE OF CONDUCT FOR EXTERNAL MANUFACTURERS AND SUPPLIERS
CODE OF CONDUCT
149
I. CODE OF CONDUCT FOR EXTERNAL MANUFACTURERS AND SUPPLIERS
150
ANNEX I:
Commitment to
Comply with the
Code of Conduct
for external
manufacturers
and suppliers
II. ANNEX I
COMMITMENT TO COMPLY WITH THE CODE OF CONDUCT FOR EXTERNAL

MANUFACTURERS AND SUPPLIERS.
I hereby confirm, in order to guarantee effectiveness in the establishment and fulfilment of the Code that:
1) We have full knowledge and comply with all the relevant laws (local, national and international) in the countries where we operate.
2) We fully understand the Code and compromise to comply with it.
3) We agree to inform all our subcontractors about the contents of the Code, and to enforce their compliance
with it.
4) The Code requirements are in no way contradictory to the law.
5) The Group itself or other independent parties appointed by it are entitled to carry out inspections at our facilities without giving previous notice, as well as at our subcontractors facilities. Likewise, we undertake to
give, with no delay, all the necessary information in order to verify that we comply with each and every point
of the Code.
6) The following points are relevant for those Suppliers using animal products such as skin, leather, shell,
bone, horn, amongst others:
All animal products used in those articles supplied to the Group shall come from animals reared in
farms to obtain meat.
Under no circumstance do we use or shall we use any skin, leather or product coming from animals
slaughtered exclusively to commercialize their skin, shell, horn or bone.
We undertake to treat all animals involved in such activities ethically and sensibly.
7) In the event that we or our subcontractors do not pass the initial inspection, we undertake to take appropriate measures in order to correct all the revealed failures and to keep on operating with the Group.
8) We assume that an immediate cancellation of all pending orders could arise from failure to comply with
these principles.
9) I hereby undertake to provide you with the list of subcontractors (suppliers) that carry out operations concerning the Groups products and with whom we work. In addition, I undertake to communicate you any
amendment that might be introduced to the said list.
153

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TABLE OF CONTENTS

This Referece Manual is a free translation from the Spanish Version.

I. DEFINITION OF THE STANDARD.

I. DEFINITION OF THE STANDARD.

This Referece Manual is a free translation from the Spanish Version.

II. CHILDRENS GARMENT SAFETY.

II. CHILDRENS GARMENT SAFETY.

Cords and drawstrings.

Potential Mechanical Hazards

Strangulation and Entrapment.

Garments intended for minors between 0-14 years of age.

This Referece Manual is a free translation from the Spanish Version.

II. CHILDRENS GARMENT SAFETY.

2. Separable Small Parts.

Separable Small Parts3.

Potential Mechanical Hazards

Small Parts/Choking Hazards.

EN 71-1 (Small Parts cylinder)4

Small parts shall not fit entirely in the cylinder.

This Referece Manual is a free translation from the Spanish Version.

II. CHILDRENS GARMENT SAFETY.

3. Non-Separable Small Parts (1/2)

Non-Separable Small Parts5.

Potential Mechanical Hazards

Injuries from detached objects.

EN 71-1 (Tension Test)6

50 N when the largest accessible dimension is 6 mm or less.

This Referece Manual is a free translation from the Spanish Version.

II. CHILDRENS GARMENT SAFETY.

4. Non-Separable Small Parts (2/2)

Non-separable Small Parts7.

Potential Mechanical Hazards

Injuries from detached objects.

EN 71-1 (Torque Test)8

0.45 Nm ( 4.0 lb.inch)

This Referece Manual is a free translation from the Spanish Version.

II. CHILDRENS GARMENT SAFETY.

5. Sharp Points (1/2)

Potential Mechanical Hazards

Injuries from sharp objects.

EN 71-1 (Sharp Points )10

Maximum penetration, 0.5 mm.

This Referece Manual is a free translation from the Spanish Version.

II. CHILDRENS GARMENT SAFETY.

6. Sharp Edges (2/2)

Potential Mechanical Hazards

Injuries from sharp objects.

EN 71-1 (Sharp Edges)12

Maximum at length, 50%.

This Referece Manual is a free translation from the Spanish Version.

III. LEGALLY REGULATED PARAMETERS.

III. LEGALLY REGULATED PARAMETERS

This Referece Manual is a free translation from the Spanish Version.

III. LEGALLY REGULATED PARAMETERS.

5. Which are the acceptable limits?

Birth up to (6 months) height 68cm

Meet Netherland Mandatory fire safety requirements: when tested to EN 1103

Over 68cm (6 months) and up to height:

Meet Netherland Mandatory fire safety requirements: when tested to EN 1103

Meet Netherland Mandatory fire safety requirements: when tested to EN 1103

Over 3 months and up to height 68cm (6 months)

Meet UK regulations, BS 5722: when tested to BS 5438

Over 68cm (6 months) and up to height: