In this lesson, we'll be learning about mechanical ciphers, which are ciphertext generated using actual machines. Now, these became really popular around the early 1900s, early 1800s, kind of at the edge of the industrial revolution, where machining these metal parts that are required to make these devices was really something that was feasible for a lot of people. But we'll see that using machines to make ciphertext is nothing new. It's nothing unique about the 1900s. People have been doing this really since the dawn of cryptography. We've already seen the ciphertext wheel created by Alberti back in the 1400s. And then there's also this device called the PsyTale, first mentioned by some Greek poet back in the seventh century BC as a way to perform a transposition cipher. You can see the little strap that gets wrapped around a specific block of unknown shape and known length.  And then you had to have the same matching block in order to decipher it on your end. So using tools, using machines to perform an encryption is certainly nothing new in history. But we'll see that this is the first time here in the 1900s where it really starts to advance cryptography to an entirely new level that had not been seen before. Now, one key player in the move to a more mechanical encryption machine was Boris Hagelin, who is a Swedish businessman and inventor who invented these machines that required no electricity. We just call them purely mechanical. And Boris was really one of the first people to make millions of dollars. Historians think he is the first person to make over a million dollars from doing some cryptography work as a private citizen. He was the person who sold the patent to some machines that we'll see in just a moment to the US government during the World War II, and then later to businesses and other governments around the world for performing this more modern mechanized encryption. He started working at a Swedish company, which he eventually were to take over and change the name of that to Crypto AG. And they moved to Switzerland at the start of World War II due to the political conflict going on at the time. Now, an interesting historical piece about Crypto AG is that the CIA, so the US government, secretly bought this company in 1970. That was part of an operation called Operation Rubicon. And what they did is after they owned the company is that they would continue selling machines to all of these governments and diplomats, but they would have a secret backdoor in them so they could read all of the messages that were being sent. This was just discovered recently, so I definitely encourage you to read a little bit more about Operation Rubicon. Really interesting historical components there. The first machine we're gonna take a look at is the C-36 Cypher machine, shown here on the screen. You can see this is a pretty small machine. You can tell kind of by the size of the key lock there, relatively how big it is. So it was meant to be almost small enough to fit into your pocket. We'll see a video of one of these working in just a moment. But the key components on a machine like this are that we have a wheel on the left that will set the plain text on, see a little horizontal metal bar that will point to your plain text letter. There's a rotating lever on the right-hand side that you'll spin to encrypt your message. These wheels that we can see popping through the slots here on the top of the case indicate the current position of the enciphering components. Those only turn once, and they all turn once after each letter that's encrypted. And after your plain text letter is encrypted, it gets printed on this piece of tape over here. There'd normally be a spool of all of this paper tape tucked away inside the machine's casing. Taking off the lid, we can see all of the mechanical pieces. So we have all these gears and wheels. These wheels here are what control the possible length of the period of the key stream. So kind of like how we saw with Visionaire, a short keyword has a very short period when we kind of repeat that over and over. The goal of using these wheels is to take out some of that characterization of the repetition in our key stream and provide more randomness. And by choosing wheels that have 25 and then 23 and then 21, 19, and 17 different positions on them, the instances are all relatively prime with each other. They're least common multiple, meaning when they'll sync back up and have the exact same readout is 3,900,000, 225. So you have to go a long message in order to start reusing your key stream, which is what the point was. Up at the top, we have the cylinder with 25 bars across it. Each bar has the location of what's called a lug. Those are those little metal objects protruding out. And those lugs as they rotate around have the possibility of catching with one of these pins that are on the wheel, which we'll see in just a moment, in order to spin our ciphertext wheel into its final position. That ciphertext wheel is over here on the left. You can see it has kind of a rubber stamp for each of the ciphertext possible letters, and that's how it prints onto the machine. So let's zoom in here on this cage or cylinder of bars. So there are 25 bars here, and we can see the different positions across the bar for those lugs to go. Now, each one of those lugs could line up with a particular wheel, wheel one, two, three, four, or five. And as that lug rotates around, and all of these bars will rotate around for every single letter, as it passes by one of the wheels, if that wheel was set into an active position, and we'll talk what that means in just a second, then the ciphertext wheel will turn one time for that bar. So there's possibilities here, that is as this bar wheels all the way around for to encrypt a letter, it could move your ciphertext wheel 25 spots. Once for each of the bars. But what we'll see is that more common is that it's not going to be exactly 25, it's going to be some number smaller than 25, because not all of the five wheels will always be in the active position. So let's see what determines whether or not one of the five wheels is in an active position. On the zoomed in view of the wheels, you can see that each of them is coated with these pins that can be adjusted so they're sticking out to the left side of the wheel or the right side of the wheel. On the furthest left wheel, you can see a row of inactive pins that are being pointed out where they're being pushed in so they appear flat with the wheel. But if you look where the called out arrow is pointing for the active pin, you can see a small little rectangle protruding from the right hand side of the wheel. Now remember these wheels each turn one spot after each letter is encrypted. So these pins are going to be moving around and around, sometimes with the pin now in the active position and some now with an inactive position. And I believe that those positions are determined about what pin is at the bottom of the wheel. Now when a pin is active, what that means is that the lugs will actually spin our ciphertext wheel for that any lugs that line up with that wheel. And if a pin is inactive, so pushed in, then as the bars go around, none of the lugs that correspond with the inactive pin wheel will actually cause the ciphertext wheel to rotate. So again, if all five pins on the wheels were active, then we'd have 25 spins plus one, that always spins one time, for the one rotation of our bars. But because not all of the pins are usually lined up for in the active position, sometimes we'll get less than 25. Usually we'll get less than 25 spins of the ciphertext wheel. Now there is a slight improvement of this machine as it was sold to the US. The US modified the patent from Boris Hagelin and added a sixth wheel and a 25th, 26th, 27th bar on the rotating cylinder. You could also move around where the lugs are. So this just added some security to the machine, but the principle is the same. It did extend out the period, so how long it took for our keys to start rotating, the key stream to start repeating itself. So a little over 100 million characters could go by before we had the exact same configuration of the key stream. Now we actually have a video of this one in use here. So as you watch it, you can see the case goes up. And then the person here in the video will set the plain text letter on the left hand side using that dial. And then spins that cage of bars all the way around. And you can see that all of the wheels turn after each letter that gets encrypted. And as active and inactive pins decide that as those bars were by, how many spots that ciphertext wheel gets rotated. And then once it's done, it actually prints it out. Now because this is that M209B, not the original machine we were looking at, we can see that it can move the ciphertext wheel up to 28 different rotations. And then yeah, when it's done, it prints it out to the tape for easy reading to be transmitted over the radio or the telegraph or maybe more modern days, you would send that in a message like a text message. So how secure were these ciphertext machines? Well, we were able to figure out after the World War II, which is when these were primarily used by US troops, that only about 10% of the American traffic that was sent over the M206B was actually discovered or decrypted successfully by the German army. 6% of that was from actual crypt analysis. So breaking the message and then 4% was more from espionage, they were able to capture some keys and then just decrypt the messages that way. Normally these messages, if they were intercepted and broken by crypt analysis, it would take between seven to 10 days for them to actually be able to recover that message, which for tactical messages like on the battlefield is usually too long for them to be actually useful when you're done. Although there are some reports that towards the end of the war, the German army and secret recovery unit were able to start breaking these messages in just a matter of a few hours, maybe four to six hours. And that would pose a little bit more threat, but again, if the messages you're sending are really just real-time messages, knowing what they said four hours later, not that big of a deal. So now that we've seen how the mechanical version of this works, let's actually take a look at how the mathematics of the system works in order to insightful the message. So at first we'll start with our plain text like normal and we'll convert that to a numerical value. Notice this particular system uses two for B instead of one for B like we've seen, but mathematically this will be equivalent. And then we'll use the machine to generate our key numbers, which is essentially our running key for this message. Now remember, these key numbers are just determined by the unique configuration of the wheels, the pins, the bars, and the lugs that are set right before we encrypt this message. So a key number of 15 means that there must be a certain number of pins in the right spot so that when all of those bars go by, we get 15 rotations of the ciphertext wheel from where it started, which is the plain text. So if we take our key value and subtract off the plain text value, we'll get our ciphertext value, which will correspond to a ciphertext letter printed to the machine. At their core, and this is very important, these mechanical ciphers are not very different from the vision air ciphers that we've seen in the past. The only difference between this and the vision air is that we're using this mechanical machine to create the key stream of numbers using those wheels, pins, lugs, and bars instead of just using a keyword that we repeat over and over or using a primer keyword in the auto key. Because we're using the machine, we get a much more predictable randomness, which is what we're hoping for. Predictable randomness might sound like an oxymoron, but what I mean by that is that we know we're gonna have the right amount of randomness to secure our message every time as opposed to leaving it up to chance of choosing the right keyword or things like that. The other benefit of using a machine over our vision air cipher is that the machine at the time was really a much faster way to implement this, plus the operator didn't need to know anything about modular arithmetic or mathematics. You could teach them to set up the wheels, the pins, the lugs, and all of that, and then all they had to do was set the letter, turn the crank, and look at what got printed. Now for a while, this was the only way for us to do this type of mechanical encryption, but as electronics started to grow in popularity and sophistication, we started to be able to see these rotor systems, as opposed to the pinwheel systems, which were the purely mechanical ones. These rotor systems were electromechanical, meaning it was a mix of mechanical operation and electrical signals being passed. The most notable one was invented by Arthur Scherbius, who was a German electrical engineer, and he created the Enigma machine, which was very popular by the German military during World War II, but you'll see that this was actually invented much earlier than that. The German Navy actually adopted this in 1926. World War II wasn't starting for at least almost another 10, 15 years down the way. Now this system was housed in this wooden box, and you'll see it had a lot of similar components to the older systems, the purely mechanical systems that Hagelin produced. It's got some wheels up at the top, but the big difference here is instead of setting your plain text letter with a wheel, you can type it like a keyboard. And then these plug board here would swap around some electrical signals that pressing the keys on the keyboards would generate. They would eventually pass through some wireings that are contained inside of these wheels that rotate after each letter. And then the cipher text letter, instead of being printed, gets lit up on this upper half of the keyboard. Opening up the case, we can see that these wheels look very similar to the wheels inside of the Hagelin machines. The big difference is that they contain wiring on the inside. So we can see kind of an exploded view here of each of these wheels, is that an electrical signal gets passed from the right hand side to the left hand side, but it doesn't go straight across the wheel. There's a kind of secret wiring pattern that connects the two halves of the wheel. And when you put them, three of them together, you see we've got a pretty complicated system here. Let's run through it. So we're gonna start by pressing letter Q on the keyboard, which closes some electrical circuit that's powered by a battery. We follow that signal through the system, through an initial kind of stationary wheel called the sticker. And then it enters the wheel number one on the right hand side, and we can see that in red. And if we follow that red signal, it goes from the right hand side of wheel one, out the left hand side of wheel one, and then into the right hand side of wheel two, and out the left hand side, and so on. And then it hits this reflector, which passes the electrical signal back through the wheels in the opposite order. So now we're following the blue lines. So the left hand side of wheel three to the right hand side of wheel three, into the left hand side of wheel two, and so on. Until it comes back out of the wheel system. And then it goes through the sticker, which again is kind of the stationary thing, but that's where the plug board comes in. We can now swap electrical signals from one output to the other. So those plug board that we saw earlier will swap the signal. It should have gone past through the wire that connects to the bulb W. But the swap board is gonna swap it to the signal that goes to the bulb for E, which will now light up. So our Q became an E as ciphertext. However, after we press that button, things kind of reset and we press the next button, all the wheels, well not all, but one of the wheels will rotate, which would potentially also trigger a second wheel and so on. These wheels keep rotating around, not all at the same time. So that's a big difference from the mechanical machine. These go one at a time, almost like the car odometer spins them around until they light up our ciphertext. In order to set up the machine, there was a lot of configuration options, and this is what lends itself to a very secure system, is that there's five wheels, but you only ever use three at a time. So you pick three out of the five, the other two go in on this little wooden box for safe storage. Each wheel can then also have some configuration options. You can change where in the wheel that it trips over the wheel to its adjacent side to spin the one like say in the middle. You can change a little setting on the right hand side wheel to determine when it flips over the one in the middle. So a lot of configuration options there. You can have to plug in all of these plugs. Normally the German military used 10 plugs, so you would swap 10 pairs of letters on using the plug board. And that really lends to a lot of security. Like you can see that number, a total number of configuration options which are the keys. So how do we get to that big number? Well as I mentioned, you have to choose three wheels from the five available, so that's 60 choices there. Two of those wheels can have that ring set up to change the wiring or when the next wheel flips over. That's 676 options there. Then you have to decide where does each wheel start in this configuration? Are you lining them up kind of like 0, 0, 0, or is it 17, 5, 22? There's a lot of different ways you can just set the wheels into the machine before you get started. In fact, over 17,000 of those. So just the choices you have to put your wheels in the machine is over 700 million choices, just to put those wheels in there. And then the plug board adds an incredible amount of complexity to the machine. In fact, over 150 trillion different ways you can plug in those 10 cables. That's kind of crazy. And since you have those choices are independent of each other, the ways that you put the wheels in don't impact the ways that you set up the plug board. The total number of keys we obtain is just the product of those two numbers. So that is a huge possibility that we have here for the key space, which is what made it so difficult for the Allied Forces to crack signals from this machine. Now these are not the only two rotor machines that are out there or mechanical machines. All of these kind of machine type ciphers were very popular starting from about the 1920s, 1930s all the way up until the 1970s or so. Here's a couple other examples in case you wanted to look them up. The two that we looked at were really just kind of field cipher machines, meaning they were meant to be used in the field of battle. But there are much more complicated ones that were used at kind of bases like the Cigaba, the Type X, so the Rens, the Nima, and the Stolba. These are a lot more complicated and therefore a lot more heavy so they didn't really make the trip out into the battlefield, hard to carry around. But check these out, they all use a lot of the same principles of trying to generate a really long pseudo-random key stream that could be used to encrypt messages. And they all have the little quirks and pluses and minuses. But ultimately we reached the end of an era. The last really well-known rotation machine was the HX63. It employed nine rotors, really complicated circuitry within the wheels, keyboard, all of that. But as we see is as we get to the 1960s and 70s, computing power really started to take off. And doing this stuff in software by programming a computer became much more efficient and faster than using these mechanical rotating wheels. But it also started to allow other mathematical operations and complexity to the encryption that a mechanical system just couldn't provide. It seems like the last known message that was sent by one of these rotor machines was in 1983 by the Canadian government. And since then they've really gone out of style. So that's it for our mechanical ciphers. I hope that you realize that the biggest takeaway is that these machines just allow the everyday user to implement a really high tech security, but it's really not mathematically different than the vision air cipher. For every character in the plain text, we need to find a way to generate a pseudo random character in our key stream that can be created both by the message creator and the message decoder. The machines allow a nice predictable, long period key stream to be generated by both sides of the equation.


Hello, and welcome to this session in which I explain the concept of metadata. It's very important to understand what is data first. Data is information that has been gathered and recorded for analysis and interpretation purposes. And data comes in various forms. It can be numbers, text, images, sounds, video files, etc. And we are bombarded with various types of data in the real world. Now, what is metadata? Metadata is a data that provides information about other data. Now, hold on a second. This is practically circular. So metadata is a data that provides information about the data. What does that mean? Well, let's take a look at this image here. Okay, for example, metadata for an image might include the date it was taken, the camera used and the dimension of the image. So believe it or not, my cousin found this image or somehow he was able to get his hand on this image. Now this image is it's all what we know is it was taken April 77. That's all what we know. And this individual here looks like my one of my brothers, I have two brothers that's basically they were close in age. We did not know. So we know the date, we know the time, but we did not know who's in which one of my brothers in this image, why, because we did not have enough metadata. We have that I believe this is either the type of the camera or the type of the film that was used to take the picture. So that's all what we know. Now, so in a broader sense, it can be thought as data about the data, providing more information that makes it easier to find something, manage something, use data and provide context and easier for comparison and analysis. Now the good news is now we know it's April of 1977. We know either the type of the film or type of the camera, the good news is on the back. There was a description, although the description was not complete. We know this was my oldest brother. So that much we know, but we didn't know who the baby was. Was it me? It can be me because I was not born before April of 77. So the point is, if you have this data on the description on the back, we will be able to know the cipher exactly when, who and the location, the location was not taken. So we guessed where the location is. So that's basically metadata about this picture. Before we proceed any further, I have a public announcement about my company, farhatlectures.com. Farhat Accounting Lectures is a supplemental educational tool that's going to help you with your CPA exam preparation, as well as your accounting courses. My CPA material is aligned with your CPA review course, such as Becker, Roger, Wiley, Gleam, Miles. My accounting courses are aligned with your accounting courses, broken down by chapter and topics. My resources consist of lectures, multiple choice questions, true, false questions, as well as exercises. Go ahead, start your free trial today, no obligation, no credit card required. Now we could have metadata about emails. We could have metadata in Excel sheet. For example, in Excel sheet, you could have an about tab before you have other tabs, for example, sales, purchases, so on and so forth. And in this about tab, you can explain what's in the data. In an email, when you send an email, well, you're going to have the most important part of the email is the email itself, the content of the email. But you could have many metadata in the email that has nothing to do with the message itself. For example, the sender's email address is considered a metadata. The recipient is a metadata. They have nothing to do with the message itself. So metadata refers to information about an email message that's not part of the actual content of the message. You could have a subject line, time and date of sending and receiving, size of the email, maybe the server, so on and so forth. Not part of the message itself. So the message itself is the data, but you have information about that data. Because if you look at the message, if you don't know who the sender, who's the recipient, what's the subject line, you may not be able to decipher it. So the metadata gives you information about the data. Now from an accounting perspective, because again, here we are accountant, maybe you're listening to this for the CPA exam or for the CMA exam. An accounting metadata can be used to describe and provide information about the financial data and the transaction that we use in the system. So what could be some examples of metadata that can be used in the accounting field? Well, transaction date, the date that the transaction took place, such as the purchase of a sale. Description of the transaction. What's the purpose of the transaction? Office supplies, salary payment, so on and so forth. The amount is the metadata about the numbers, the monetary value of the transaction. The account information. We have to have account information about the account that we are using. Are we debiting? Are we crediting this account? The classification of the account. Is it an expense? Is it a revenue? Is it an asset? Is it a liability? Now bear in mind, all this metadata is stored in the financial software, in the financial accounting software, or in the financial databases. And it can be used to organize all this financial data and to produce financial statements and reports. So this is how we use the metadata for all of this to be able to ask the system to pull an income statement. We already know that what goes on the income statements is revenue and expenses. The metadata tells the system we are looking at revenues and expenses. Now we could have many revenues, many expenses, but the metadata is revenue and expense. And the classification of it is part of the income statement. So by providing information about financial transaction, metadata can help accountant and finance professional to understand the context of the data and make informed decision. Now we could have many types of metadata and uses in many fields, not only in accounting. We could have descriptive metadata, for example, title, author date. For example, this could be used in a library setting. We could have structural metadata like file format and size. We could have administrative metadata like rights management access control for certain files, technical metadata resolution, color depth. And as I mentioned, it's used in many fields, library, information science, digital asset, contact management and systems, so on and so forth. What should you do now? Whether you are studying for your CPA exam or CMA exam, go to Farhat Lectures and maybe look at additional MCQs. That's gonna help you understand this topic. So you can answer any questions whether you are a CPA candidate or a CMA candidate on the exam day. Good luck everyone, study hard and stay safe.


The police command in Nassarwa State has raided a kidnapper's hideout at Kiguna village in Lafayette, the state capital, and arrested six suspects. The commissioner of police in the state, Meaqi Muhammad Baba, made the disclosure at a news briefing while presenting the command's achievements. About all one for five hours, police operative attached to Qashin division, while on routine patrol. They arrested a group of suspected criminals at the Auta Balafi, where they are trying to throw their broken down operative evakers. Primarily, we are gesturing whether the criminal gangs of 12 members carry out their operation using a Volkswagen Charon and a Toyota Sienna, and go about what they used to go about, breaking into people's houses and shops, attacked drivers of broken down vehicles.


Well hello YouTube. I am here today with the honor and pleasure of being the first recipient of Bosnian Bill's box of locks to travel that travels around the United States. I think there's another one too. I don't know who's getting it. So I'm going to open it up and I may or may not pick something from it but we'll see this time. I'm not going to sit it on my lap but I'm going to have it here on the table so that you can actually see what the heck I'm doing. So this came in the mail this morning and it's ahead of schedule I think. This one to the post office. So let's just make sure it's got a good view. Good focus. Excellent. Now what I'm going to do is I'm going to set the box on the floor. So there's a box within a box. Okay, it even has my name on it. So let's see what we got in here. This is packaged very securely. So securely I'm not even sure how to get it up.  I'm on frame here. Let me move this down so we can see a little bit better. I mean you just need to see. I mean look at this thing. It's like I can't even tell you how many. There's probably two dozen locks in there. I'd get the scale up but I can tell you it's more than 10 pounds and that's the capacity of the scale. So we'll come over here. Let's see what we got in here. So we have a, whoa, a whole bunch of stuff. One of the newer master locks, the key, the craftsman lock which looks suspiciously like an Elko. Burn this in even more. Got the wide angle on here. So there we go. Have a firm lock which looks suspiciously Chinese but I don't know. Never know. Made in China, sure enough. Bad locks. Aha. American lock. Siri 7260. So this is a, this is a, there we go. This is a an ace type lock. There you go. Great view of that. No key for that one. We'll see about that. Okay. A public storage lock made in Germany. So that's probably an abyss there. Oh my goodness. I've been wanting one of these for a long time and it doesn't have a combination. Hmm. That could make it more difficult. This is an S&G, which model is this? This is an 8088. This is one of their combination padlocks. I think there's an 8087 or 8077 as well. This is government issue or was into the US on it. I don't know if this is the actual government version or the civilian version.  A Yale. Made in the United States. Nice spring action on that. We have a quick set. We'll screw this. Bell. Quick set. Really? Maybe it's pinned strangely. No, it doesn't feel strange. Quick set lock. Okay. This takes more than 30 seconds.  He says he takes more than 30 seconds to open it. There it is. That one's down. Put a little, just a little mark on it so I don't do it again. So quick set lock open. Excellent.  There's another quick set lock. This one is brass shinier. Looks like it came from a deadbolt type of system. So let's see if, almost had it. I'm just focused on these open. Probably get that thing in too deep. Okay, this one's putting it more of a fight. I was joking with Bell that he probably, well we'll do that later. He probably got credit from his wife for getting rid of locks. I want to run over time here. All right, a beautiful Yale. This is an older one. Eaton, it says on it. GG. No idea what that means. And wow. Looks like it has a 22223. Yeah. Looks like it, look at the, look at the bidding on that thing. That's going to be fun. I'm not even sure. Wow, I think it has a direct code on it as well. All right, we have one of these little master combination locks. These are fun. Oh, and it's open, which is good. You can set your own combination. We have a completely anonymous looking rim mortise cylinder. We have the Brinks combination, high security, safe, or lock box, or the Cofergarde clay, if you're French, and I'm not going to try to pronounce the Spanish. So we saw Bill bypass that one. And a best padlock with no control key, but with an operating key. Very nice, shiny. It's a removable cylinder. That's cool because you can pick it to control or to open. We have an inbox, Hermax. Hermax. This is a disc detainer lock. This looks like it might actually be respectable. Where is this made? Made in China. All right, so I'm not sure if I'm going to try to open it the bill way, or maybe a nicer way, but it does claim to be a medium security lock. We have a water brewery lock with a chain, but no US set, but no key on that one. And a cute little bag that says Citadel, Citadel on it, inside of which there is a... Oh, I've seen one of the... I think I destroyed one of these once. It's an ACE type motorcycle security device. So if I remember correctly, you stick this in and... Well, I don't know what you do actually. There we go. It opens up like that. So I think you put that through your rotor or something on your motorcycle and keeps people from stealing it. So we'll see how effective the security of that thing is there. So that should be fun. I'm going to put it back in its little case because it's kind of cute. All right. Well, I don't know how much time I've got, but why don't I try to pick something else here? Maybe something non-trivial. And we'll see if the camera times out.  The keyway is pretty tight in there. You can see it's... And it's got a little sort of guard thing on it that's not going to work. So that might work. Nope. I really don't want to have to come from the bottom on this one. I'm desperately trying to find something that will take the top, but there's just no... There's nothing to grab on to. So we're going to have to go bottom of the keyway on this despite the lack of room. I'm going to guess there's at least about 300 spools in here based on the flopping us. And now we'll see. We're still running. Yes. We'll see what we got in here. So good god, man. I need a thinner pick. But this one hasn't broken yet. So we're looking for a false set with any luck. Get in there, baby. Now, my problem is going to be that if there's a very low-cut pin that I may not have enough room to get under it because of the very restrictive keyway we have here. I can't remember if Bill picked this one on camera or not. Am I still rolling? Yeah.


I would like to introduce Carolyn Carlin from my office, the Office of Compliance. She's a compliance officer in my division. She handles all the plantable fabric stuff, specifically sleepwear and general wearing apparel. And she has been the main reason we've been having a lot of recalls because she's out there. She's a sleuth on the internet. And she finds products and brings them in and we test them and she loves to do the recall. So that's Carolyn Carlin. And then next to Carolyn is Paige Whitson and Paige is a textile technologist at the laboratory and she is the person doing all the testing. So I'm going to turn the podium over to them and they're going to bring you up in technology and we're going to play, have some fun, sorry, not play a game. All right, so before we start with this interactive PowerPoint slide, there's a lot, thank you, I wanted to reach out and just mention Jonathan's email. We have an email guy up here who is able to keep a listing of all the FAQs. So if there's any questions that you don't raise a hand or you don't want to say it out loud, you can just email him at J-K-E-N-T, is that right? Okay, at C-P-S-C dot gov, all right? So being the millennials we are, we wanted something fun and active. I'm going to just state that the questions can be tricky, but you all should know the right answer, right, yeah? Okay, well Paige is going to explain the process, but you are going to need a cell phone. Everyone has one of those, right? All right, so there is an email sent out last night to people who registered online and also in your folders, there is the address to type in to access the questions for this section. So if you want to pull that out, you either get it through email or type it in from your handout in your folder. That would be great. You can get started, right? Majority, good to go. Or anyone having technical issues? We're going to go with the first question. All right, so which garment is considered sleepwear? There's also a video in the back for those. Yeah, there you go, you got it. All right, so garment one is 100% cotton woven two-piece set that is paired with a diaper bloomer. The fabric weighs about five ounces per square yard. Garment number two is 100% woven garment with lettuce-like edge trimming and a pink ribbon at the neckline. The fabric is a lighter weight. Which one is considered to be sleepwear? Oh, we can just wait and see what people. Has everyone voted? All right, so now the correct answer is garment number two. Garment number two. Garment number two. This is known as a traditional sleepwear nightgown. Question number two. Which garment silhouette appears to be traditional sleepwear? Garment number one has buttons and a Peter Pan collar. It also has piping around the wrist and the ankle. Garment number two is 100% cotton. Oh, that's the people I'm talking about. I just got to keep it up for the webinar, I think it's because the answer is number one. Traditional sleepwear is loose-fitting sleepwear. The second garment is considered to be tight-fitting sleepwear. Next question, which garment appears to be tight-fitting? Garment one has lettuce-edging trimming with a ribbon at the top, the neckline. And garment number two has rib-knit. All right, I'll stop talking. The answer is number two. All right, can tight-fitting children's sleepwear garments have a hood? Oh, I cannot. Tight-fitting garments cannot have any type of trim, embellishment, or decor that is more than 1 fourth of an inch from the point of attachment. And a hood is a good 8 inches, 9 inches, maybe even a foot. Next question, what type of children's sleepwear requires a hang tag? It's tight-fitting garments. Tight-fitting garments are required to have a garment hang tag. It is the yellow safety hang tag that you see a lot in the stores. Is an FPU or GPU number required on traditionally styled children's sleepwear garments? There is, yes, they do require FPU or GPU number on traditional sleepwear. Both aren't required as long as you have one. Normally, this is printed on the side seam label inside the garment. Are there mandatory labeling requirements for children's sleepwear? Yes, there are, mandatory labeling requirements. This should have been first. But yes, tight-fitting has to have the two labeling requirements, neck label and hang tag. And the traditional styled sleepwear has to have the FPU or GPU number. So when is a sleepwear garment subject to the thylate requirements or limits? The answer is size for children, three and under. Mary spoke about this when she talked about the CP-SIA requirements. If your tight-fitting children's sleepwear garments are sold directly to consumers, I can't. OK, if your tight-fitting children's sleepwear garments are sold directly to consumers in a properly labeled package, do they also require a hang tag? The answer is no, they do not require the yellow hang tag if the bag is properly labeled. Now, speaking at a retailer standpoint, if you are selling your tight-fitting garments, I know some stores have them actually stacked, and consumers can just go and grab like fast retailer, that is not required to have a hang tag since you will be placing the actual hang tag wording and the same coloring on the actual package. That is fine. Are certain fabrics composed of specific fibers exempt from testing requirements for children's sleepwear? No, there is no specific fiber exemption for children's sleepwear. Is there a hang tag requirement that states a garment is flame-resistant or flame-retardant? No, there is no hang tag that you need that states that the garment is flame-resistant or flame-retardant. Which item below would be defined as trim under the standards and requires testing? Great question. Everyone's thinking. The answer is screen print. All the other trim tights are considered functional trim and do not need to be tested. Would a sleepwear garment size 6 to 12 months require testing under the sleepwear standard? The answer is yes. It would still need to be required since the sizing goes over the nine-month limit for infant garments. Can tight-fitting sleepwear garments be offered exclusively in small, medium, and large sizes? No, they need to have additional sizing numbers in addition to small, medium, and large sizes. Yes, compliance staff advises that numerical numbers be used as specific, as specified in the tight-fitting garments chart within the standards. When and if there is a size range on the garment, compliance staff will only measure the garment to the smaller size that you label. Do tight-fitting children's sleepwear garments require a measurement by a CPSC accepted accredited third party laboratory? No, they do not need to be tested or measured by a accredited third party laboratory. For those who answered yes, you will be learning today how to do it on your own. Yes, that's all the questions we have. OK, good morning. We're ready to resume and get back on track for our agenda. Good morning. I'm Allison Tenney. I've been at the commission for almost 17 years. My current position is division director and the directorate for laboratory sciences. I have a couple of my staff here today, so I do want to thank them for all the support. But we're going to start our session with the regulation requirements and testing. I'm going to introduce Linda Fanzler. She's going to moderate this session. She's a senior textile technologist in the division of engineering and the directorate for laboratory sciences. She is part of my staff, and she's been with the commission for 31 years. She is a recognized expert in textile flammability and the regulations under the Flammable Fabrics Act. So with that, I'm going to turn it over to Linda Fanzler. So we're going to be talking about the testing requirements. So as everyone, I'm sure, knows by now, there are two mandatory sleepwear standards for children. And they're broken into two size ranges, the smaller size 0 to 6x and the larger size 7 to 14. And the standards were developed by NIST in the early 70s to protect children from small flame sources. So as I said, the intent is to protect children. We want to reduce the risk of injury or potential death from contact from small flame ignition sources. Small flames would be like matches, candles, and lighters. These standards are not intended to protect against large flame fires, such as a whole house fire. We found that the test method is a very good predictor of the flammability performance of a garment. Passing specimens will self-extinguish. We found that many polyester fabrics will self-extinguish and meet the requirements, flammability requirements. Cotton and cotton blends do not, I'll repeat, do not meet the flammability requirements of the children's sleepwear standards unless they are treated with a chemical treatment. The standards have been amended periodically over the years. Some of the amendments include sampling plans, the elimination of the residual flame time, how we test trim in a horizontal direction, the laundering procedures to include an updated of the standard detergent, to then also the tight fitting and the infant garments. And we've talked a little bit about those two already today. And I'll just briefly go over those again. So tight fitting garments are exempt from the children's sleepwear standards in sizes larger than nine months up to size 14. The garments cannot exceed maximum dimensions specified for each size. And you can see the chart right in the standards. There's the labeling rule which we've talked about, the hang tag and the permanent label on the garment. And the infant garments are sized nine months or smaller. Although these are exempt from the children's sleepwear requirements, they must meet the flammability requirements found in the general clothing textile standard. That's 16 CFR part 1610. And now we're gonna show a very short video and keep in mind that at our lab when we do the testing, we do a compliance test that is more similar to a garment production test. We get actual garments in to test. Hi, my name is Linda Fanzler. I've worked at the commission for 31 years, the last 21 in the product safety laboratory. Right now I'm performing a children's sleepwear compliance test. When we receive official samples of children's sleepwear, we test them according to the standards for the flammability of children's sleepwear found at 16 CFR part 1615 and 1616. These regulations help protect children from potential burn injuries. Unfortunately, we frequently find violations. Most of the time we already know that the suspect fabrics will burn rapidly and should not be used to make children's sleepwear garments. Oftentimes they're untreated cotton. We know from experience these fabrics will not pass our regulation. However, we still see them in children's sleepwear products on the market. Now I will show a portion of the testing procedure required for children's sleepwear. Once the garments are received, we evaluate the fabric and seams. We use templates similar to this to prepare the proper specimen size for testing. In this example, we'll be evaluating a garment, fabric and seam. It is important that the sewing thread used to sew the garment seams is also flame resistant and is not coated with a flammable lubricant sometimes used in the sewing process. We mount the specimen in the holder so that the flame can be applied to the seam first. We anchor the fabric so it lays flat and we use clips to assemble the specimen holder. Once the specimens are mounted in the test frames, the test specimens go into the oven at 105 degrees Celsius for 30 minutes. They are removed after 30 minutes and go into our desiccators for another 30 minutes to cool down. After conditioning the specimens according to the test protocol, the specimen is placed in the test cabinet. I will remove the specimen from the desiccator and show you an example of a flame resistant cotton fabric and how a compliant specimen performs. The holder is suspended in the cabinet and the flame will be applied from the side and directed to the bottom edge of the specimen for three seconds. As you can see, nothing happened. That's because this was not a regular piece of cotton fabric. This fabric is flame resistant which causes the flames to self extinguish or go out once the flame from the test chamber is removed. An untreated cotton fabric would have burned the entire length of the specimen to illustrate the difference between regular and flame resistant cotton fabric. I'll show you a specimen that is 100% cotton. Again, the specimen is placed in the test apparatus and the flame is applied for three seconds. You can see that once the flame is removed the specimen continues to burn with large flames. Additionally, once the flames go out none of the specimen remains. A garment made of this fabric would burn readily when exposed to an open flame. A child would not necessarily have the time to react to prevent injuries. Here at the CPSC we take our job seriously and we know that you are a partner that shares our commitment to safety. We wanna give you the tools to deliver safe products in the marketplace. Thank you. So that was just a very quick summary of how we tested the lab and Carrie I believe is gonna come up, sorry, Paige is gonna talk about tight fitting. Oh, testing, I'm sorry. All right, I'm here to talk about, go into a little more detail about the specifics of testing that we do. Here's a brief overview of what we consider sleepwear once again, nightgowns, pajamas, robes, loungewear. We all consider sleepwear and will be tested. Once again, the sizes are there. For the test method we typically do the fabric, seams, trim, and of the final garter, sorry, this is for you guys. You need to test the fabric, seams and trim and the final garment to get your FPUs and GPUs as well as prototypes for seams and trims. Each test sample that you do must consist of five specimens. The testing must be done in original state and after 50 laundering if the sample passes in the original state. And the test samples are required to be retained once again for your record keeping. So the first thing we're gonna talk about is the fabric production unit. This thing is up to 5,000 linear yards of finished fabric for normal sampling. There are other types of sampling plans is reduced and tightened. We won't go into much detail about those, but those are available for various testing plans. Finished fabric is considered dyed. Any finishes are applied. That is the finished fabric except for slicing. Typically you do not wanna test an undyed fabric and then dye it later because it can definitely change the flammability properties of that fabric. Different colors and prints can be combined in an FPU, but you can only do different colors or different prints. You cannot have both different colors and prints within the same FPU. The samples need to be taken at the beginning and the end of the FPU. So within that 5,000 linear yards, you need to take samples from the beginning of end of that 5,000 yards. To include different colors or different patterns, additional testing needs to be done is shown that they show similar testing or flammability properties. And at this charlain they're not significantly different. All initial FPUs are done in the finished state and once again, original state and after laundering. If the FPU has not been tested to 50 laundering, the GPU must be tested to 50 laundering. If you do, yeah, yeah. I believe that you may know that a little more detailed. A little more detailed. So the question is whether you test, could you repeat that? Sure. And could you hold it for a second? Can Jonathan give you the, thank you. Okay, if I am trying to combine three different colorways, so I have red, blue and green. And basically I can combine them if three samples from each of the colors have been tested and don't show significantly different charlinks. So when I'm testing the red and then I'm gonna test the blue and then I'm gonna test the green and I'm testing three samples of each, is that correct? Yes. Okay, so for those, for the first sample of those three samples for a specific color, do I need to do both original and after 50 laundering for only the first of the three samples of each color or for all three samples of each color? I'm gonna let Mary take that one. Okay, so what you're doing with the three samples is you're identifying whether or not they have different charlinks, whether or not they have similar flammability characteristics. So once you establish that, then the 50 laundering can be done on one of those three colors and it'll be equivalent for all three colors. You just have to know what you're doing, you have to know what you're doing, you have to know that the samples that you're testing are have similar or identical characteristics. So then you're good for the 50 laundering is after you make that assessment that they're the same, then you can do the 50 laundering and that'll apply to the other two colors and you can combine them in an FPU. Okay. I am gonna add that this is just speaking about knits. You can't construct, you can't add different construction mixes because I see a lot of confused faces and we are gonna have a testing panel and Luann gets in depth on GPU and FPU testing. Just for one quick clarification, there was three specimens and not three samples, correct? Three samples, five specimens of each sample. So 15 specimens per color. Is that too many? It's three specimens, right? Three specimens, three samples. Three samples. I'm sorry. I just wanna be sure we're all clear because I know there's a lot of information going around. So I have the same fabrication and I'm making it in red, blue and green. And so I'm going to test three samples, 15 specimens of the red and in the original. And then I'm gonna do the same thing for the blue and the same thing for the green. And then I'm gonna go back to the red and I'm gonna launder it 50 times and I'm gonna test three samples. Yeah, test the same ones that I did from the same fabrics. And if it passes the 50 launderings, then I can make the assumption that the blue and the green will pass 50 launderings because it's basically the same fabrication. And then I can, in subsequent FPUs, I can combine all three colors, the production amount of all three colors into one FPU. Yes. Is that correct? Yes. Great. Yeah, and you still have to follow the FPU numbers and everything else, yes. Thank you. Okay. Good question. Okay, so now we're gonna move on to prototyping. This is done pre-production. It's done on the seams and the trim of your garment or your future garment. Each seam should be tested and evaluated, which leads, you can lead, you have to do each construction. So it can lead to a numerous amount of different seam types and constructions, as well as trim types in their construction. The prototype must be the same as the orientation that it's gonna be on the garment, so either vertical or horizontal. Functional trim is exempted. So that was some of the things that we mentioned in the questions. Spaghetti straps are considered functionals. Zippers are considered functionals. Small decals are not considered trim that needs to be tested. Anytime you consider a change or you're gonna make a change in the garment design, you need to do a new prototype testing for that. So now the garment production unit, the GPU is finished garment up to 500 dozen or 6,000 units that have specific identity and it remains unchanged throughout the unit, except for size, trim, findings, and print patterns. The production testing performed on the GPU is done on seams only. Different solid colors or different print patterns on the same fabric may be included in the same GPU, as long as three or more samples from each solid color or print pattern are tested somewhere to the FPU. You cannot combine solid colors and print patterns and you cannot combine nits and woven in the same GPU. This is also similar where you can't combine, they're both nits, but maybe one's a fleece and one's a plain knit or a plain knit. So that is the saying they cannot be combined in the same GPU. Samples need to be taken randomly from the GPU population. Typically, you need at least five samples for testing. 15 specimens are needed and separated into three sample sets. No more than five can be taken from a single garment. All specimens from a single garment must be included in the same sample set. So you can't have five from one and then like an extra six from the same garment that you put into a different sample set. So these are for rejected products and FPU or prototype that fails needs to be reworked to improve the flammability performances after a rework is done on the FPU. You would go to the tightened sampling plan that I mentioned earlier. These can all be found in the regulation also in your test manuals. After a rework is done on a prototype that it failed has to be retested a failing or rejected GPU that has been offered for sale must be reported under section 15 that we mentioned earlier. If the product cannot be reworked it needs to be rejected and marked that it did not pass the standards and records must be kept and must be properly marked that it does not pass our standards. Now we're gonna go into some of the more nitty gritty of the test method. So here's kind of an overview. The size of the specimen, they need to be conditioned. Each specimen is placed in a vertical metal holder. The gas flame must be three centimeters and the char length must be measured at the end after afterglow and flame has finished. Here are examples of our weight and the fabric weight must be measured beforehand to know the type of weight you need to use to test the char length at the end of testing. Cutting the sample size is about three and a half inches by 10 inches. You need to take samples from both the warp and filling direction or vertical and horizontal for the test. Samples are mounted. The bottom edge must be in line with the edge of the metal holder so it hits the flame at the right height. The size of the specimen must be clamped. And here are the conditioning requirements I've mentioned 105 degrees Celsius for 30 minutes and placed in the desiccated cool for no less than 30 minutes, but it cannot exceed 60 minutes. In your test cabinet, you'll have a marker to indicate the flame height and the flame, you just need to make sure that the flame is consistent and remains at 3.8 centimeters. So the samples are removed from the desiccator after the 30 minutes and suspended vertically in the test cabinet. Flame is applied for three seconds to the bottom edge of the fabric. And if you have seams, the seam edge must be facing the inside or towards the flame. Once the specimen has burned to completion, remove it, you will use the weight that you, from the fabric weight that you calculated earlier and hook the weight onto one edge of the fabric and tear it to get the full char length. And then you will measure from that edge to the bottom edge of your specimen. There's a picture of measuring from the bottom edge of the fabric to the top of the char length. The average char length of the five specimens cannot exceed 17 centimeters or seven inches. And no individual specimen can have a full length burn, which is 10 inches. Here is our laundering requirements. They are also found in our test manual and in the regulation. And now I will turn it over to Carrie to go over a little bit more of what is sleepwear. Okay, so now we're gonna speak on how the Office of Compliance evaluates and determines children's sleepwear garments. And if everyone wants to take out their lab manual, we're going to actually go over the tight fitting garments and you can actually walk step through step with me. There's a little bit more information on here. Now everything's gonna fit on the PowerPoint slide. All right, so as stated previously during the interactive questions, there are no fiber exemptions under the children's sleepwear standard. However, we do have the following exemptions. Diapers and underwear are not considered sleepwear. They have to comply with 1610, which is the general wearing apparel. Infant garments are also exempt from the sleepwear standard for flammability as long as they are sized nine months and under. There's also a length requirement. So if those are exceeded, either one piece or two piece, there is an actual factor that they could actually be considered to be sleepwear. Tight fitting garments also do not need to meet the flammability requirements unless they do not actually meet the tight fitting specifications. If they do not meet the tight fitting measurements, then they will be tested to flammability and they will fail because most of the time they're 100% cotton. The CPSC staff considers several factors when determining whether a garment is sleepwear and does not only consider the manufacturer's marketing, marketing terms and designations. Factors include the nature of the garment and its suitability for sleeping or active related to sleeping or activities related and the type of fabric, decorative features and print patterns that are used. How the garment will be purchased and used by children for sleeping and activities related, which also brings us to the category of loungewear. In the 1990s, a category of products called loungewear was introduced into the children's market. The CPSC staff used children's loungewear or other similar garments marketed as comfortwear or sometimes the new word is playwear. As garments worn primarily for sleep related activities. Therefore, loungewear must comply with the children's sleepwear standards. A letter of guidance, which Mary did mention was sent to the industry and I believe 1996, it was sent out again in 2008 and I recently sent it out again in 2015, February. So the document is called the sleepwear policy and loungewear position letter. If you need it, you can email me and I will send it directly to you. So here pictured, we have traditional sleepwear garments. We have seen loungewear, which are the first two top and bottom, the pantsets. These are usually actually sold solo, usually called playwear or loungewear. The middle pink garment is a two piece set that was actually sold as tight fitting. However, as I stated, if it exceeds the measurement dimensions, it is going to be placed into the traditional sleepwear category. And the other two garments were sized six to 12 months and nine to 24 months. And that is why those two were also considered sleepwear. Here we have some recent sleepwear that has been recalled. We have two robes, the loungewear boxers, two piece sets that were not within the limits for tight fitting measurements and also a garment that failed trim on that screen print on the dark navy outfit. So to summarize what exactly is required for children's sleepwear garments, children's sleepwear garments must meet the flammability requirements and also the or and or the tight fitting. A CPC, like Mary said, a children's product certificate is required for all children's products. This includes every single garment of sleepwear. The lead content, lead surface coding and tracking labels are all also required under the CPSIA and also the Thylate requirements. But with that summary, we do have some time for additional questions if anyone has any. Was it going to be labeled, which one? Well, you could take them A and B. So if a robe is labeled bathrobe or in a catalog is featured shown as a child is next to a bathtub. Sleepwear. Yeah, is it sleepwear? That's lounging, it's related.  That is going to be under the category loungewear, sleepwear. Traditional sleepwear. Correct. Swimsuit cover-ups are a little trickier perhaps if they're shown with a child wearing a swimsuit next to a pool. They're allowed. We're just having an issue with the actual designers. There is a cervical to knee measurement that is required to be met if you're going to make spa cover-ups or beach pool, whatever you wanna call them. They need to meet the cervical to knee measurement and I will be bringing that up in the tight fitting guidelines. But yeah, they have to be above the knee. Right, so that if they exceed the correct length to consider them pool or spa, it's a measuring issue. It's a measuring and also that's just one aspect, like marketing, distribution, you're merchandising. If you're gonna put it next to the robes that kids are gonna be using for bath time, I'm gonna take that into consideration. Okay, good. A lot of aspects. Yes. I'm Cindy, hi here. Hi. I'm Cindy from H&M. I have a question about long johns. I mean, you would think of them as underwear, but if they meet the tight fitting measurements like it would be like a long pajama bottom, it could be a separate pajama bottom. If they were labeled with the yellow hang tag, could they be sold as pajamas if they meet the tight fitting measurements for a pajama bottom? Or if they don't and they're considered by CPSC as underwear, do you label them something like not to be used to sleepwear? How do you treat those? How do you look at those? Okay, long johns. Everyone calls them long johns or union suits. Something like that. Yeah, they're considered to be underwear. We do see them as underwear. Until you put that tag that says not considered to be sleepwear, that's a red flag to CPSC staff. We advise that you do not use those. Don't use them. We advise against that, yes. Because when you're putting a tag on a garment, you're gonna make the consumer think, oh, well maybe I can use it for sleepwear. You know, that's how the commission sees it. Sleeping bunnies. Does that change whether it's underwear or sleepwear? Depends on how you're gonna market it. Where are you gonna place it in your store? How are you gonna merchandise it? If I put it with all the other long johns? You have an actual long john category, then that's an underwear area, right? Yes. Then it's still considered underwear. It'd still be considered daywear, yes. Okay, thank you. Could you elaborate a little bit more on what you consider to be a multi-layer fabric? And if it's something that is attached all the way through and then you test it as one piece, or would a multi-layer fabric be something that, say you have a gown, that there's an attachment, everything's attached to the waist, but there's two pieces that free-flow at the bottom. Do you test that as a multi-layer fabric, or are those two separate fabrics? Do we test them if they're free-flowing as two separate fabrics? Even though they're attached at the waist. Okay, thank you. I just wanna clarify what you said. If something is thermal underwear, we should not be putting something on there that says do not use for, not intended for sleep. Correct. The same thing with the beach robe, we shouldn't do that either. Correct. Okay. Thanks, I think it's a very simple question. When you're testing screen printing, how do you do that? Just according to the regular trim, you cut it out. Like if it's on the fabric and it's been screen printed, you cut it out and sample it. Not familiar with the testing for screen printing as trim. Linda or Paige? Yeah, we would take the layout and we would put it over the screen print and cut it out and make sure that the bottom edge, the flame would impinge on that screen print. And then I guess a follow-up would be if of course the screen print was less than two inches and narrow, would you then not test it under the narrow fabric exemption for trim? Yeah, if it's under the two inch, if it covers less than the two inches then it would not need to be tested. Thank you. Carolyn, can you please elaborate on accessories that may be sold with sleepwear? And just slippers, sleep masks, things like that. Correct. Tutus, capes. Tues. Okay, sleepwear. Very often we've seen some combinations sold as combination sets. Tutus? Tutu, that is an actual garment. I don't find that to be an accessory. You're actually wearing that. So if it's gonna be sold. Because it becomes, I have not seen those. I mean, usually we advise that anything sold with sleepwear should be able to meet the flammability requirements. A tutu to me still, you're wearing it. I don't find that to be an accessory. It's actually around your waist. It's not like a slipper. So I would say that that should meet the flammability requirements. What about that? Excuse me, sorry. Which flammability requirement? Well, it can't be tight fitting. It's more than one fourth of a trim. It would definitely be flammability. So it would be the 16, 15, 16, 16 test as opposed to 16, 10. Correct. Okay. And you said hats, such as like newborn hats, like hats with the layout sets, stuff like that. That's an accessory. Anything else? All the way in the back. Hi, I just wanted to go back to Ellen's question about sleep masks. Would that also be considered an accessory? That's an accessory. Okay, so we wouldn't have to meet any testing requirements with that. Actually, 16, 10 sleep masks are under 16, 10. Okay, thank you. Want to go to lunch or do you want to go right into tight fitting? Lunch? Oh. Yeah? Okay. So you need those lab manuals? For sure. Now we're going to get into tight fitting sleepwear, specifically. So tight fitting garments are exempt from testing to the sleeper requirements under flammability. They do need to meet obviously the tight fitting specifications. There is a size chart in every CFR. You can also email me and I will send you a chart. And if Doug is so nice, he can give you a little index card. So here we have actual garments that are tight fitting. Tight fitting garments can be shorts. They can be short sleeves. They can be a mix. You can have any type of long sleeve or short or pant cross. They can all mix match. Here we have some recall tight fitting sleepwear. These were all recalled due to multiple exceeding amounts of measurements. Like the, like we usually say, there are, there's a minimum tolerance within the tight fitting measurements, but we usually really look at the wrist, upper arm and the tops waist. Places where there's points of buyer access. And it's usually around the child's arm, their waist. And these also had labeling issues and they also had sleepwear policy issues. The tight fitting garments require two types of labeling. They require a neck label and a hang tag label. And for those garments, as I said, those sold in packages have to have a warning label on the outside of the package. This goes in depth of what the actual neck labels can look like, should look like, sorry. So the neck label must be at least five points and font. We even pick out the font for you. When it has to be in all capital letters, it needs to be directly under the size limit. And the hang tag has its specific font and size as well. It also needs to have that black box. This catches the consumer's eye. Now if you, ooh, sorry. Now if you wanna turn to page, I believe it's 51 in the lab book. This is where we start. We're gonna start with measuring the chest. So before you start measuring your garment, you need to have a flat surface. You also need to make sure that you are making the garment smooth, but you don't want to, you know, when you put down the garment, you don't wanna stretch it out. You're not gonna help your case by stretching out the garment before you measure it. It needs to be in a relaxed state. The chest measurement is taken from armpit seam to armpit seam.  Measuring the waist of the top is to be taken at the hemline from point C to point D. When a one-piece garment, it can be a little bit tricky, but you need to measure at the most narrow part between the chest and the seat. I usually look around the belly button area. The measuring the upper arm, this is where I see a lot of violations, is the upper arm measurement. I do understand that tight fitting garments are tight fitting, but that is the purpose. And you cannot exceed in the upper arm measurement. So for the upper arm measurement, you're gonna use a straight edge to form a line from the waist through the armpit to the shoulder of the garment. From this point on the shoulder, you're gonna measure down the arm sleeve using the appropriate value for the size of the garment. From this point, you're gonna measure across the sleeve, perpendicular to the top edge of the sleeve. Measuring the wrist or cuff. The wrist measurement is from point E to F, which is in the end, which is the end of the opening. For a short sleeve top, you must use a roller to check if the sleeve is tapering from the top of the shoulder to the end of the opening. I get a lot of questions of what the definition of tapering means. It means the garment's getting smaller. The actual opening is going to a close. The pant is to be measured at a relaxed state from side to side at the very top of the pant. Please note that for the tight fitting garments, you cannot have a trim that exceeds more than one fourth of an inch. That means no ribbon, no drawstring. Nothing can be present at the elastic, or sorry, elastic waist pant. There is no elastic. It cannot be present at the center front of the pant, if that makes sense. The measuring the seat of the pant or short is to be taken by folding the front of the pant in half. You have to find the bottom of the crotch. So you're gonna mark the point above the crotch by four inches exactly, and you're gonna do it perpendicular to the bottom of the crotch, which you see here. I hope you can see J and K. If not, it's in your lap manuals a little bit darker. And then you're gonna measure from the point L through K to M. So it's basically going up and then over and over. That L to M is your actual measuring point. That is your data. To measure the thigh, you're gonna measure one inch down the inseam from the bottom of the crotch, which is J to N. And you're gonna measure from this point across the pant leg, which is N to O. When measuring the ankle, for pants that extend to the ankle, you're gonna measure across the width of the end of the pant leg, which here is P to Q. For short or capri pants that do not extend to the ankle, the pant leg may not exceed the maximum width for the thigh and must diminish in width gradually as it approaches the ankle. Tapering. The tight fitting garments cannot have any trims, decor, or embellishments that exceed one fourth of an inch from the point of attachment. This includes lace, appliques, drawstrings, ribbons, raised buttons. And here is a picture of a trim being measured. So even those little baby tags or side seam labels that a lot of companies like to put on for social media purposes, branding purposes, those have to meet the one fourth inch rule as well. Lettuce edging. We get a lot of questions about lettuce edging even though I do not see it ever being sold. This edge finish should be measured in scalloped. The scalloped, sorry, the scalloped edges should not extend more than obviously one fourth of an inch. And you can use a stand roller on the end, perpendicular to the garment against the scalloped edges. For a two-piece set, a set may consist of a combination of a piece that meets the tight fitting requirements and a piece that meets the flammability requirements of the children's sleepwear standards. Both pieces must taper to the waist, the top tapers from the chest to the waist, and the bottom tapers from the seat to the waist. For tight fitting tops, tops with front fasteners must have the lowest fastener within six inches of the bottom of that piece. For boat neck style tops and envelope shoulders that are not, sorry, boat neck style tops and envelope shoves are not prohibited as long as the measurements do not exceed those as in the standards. Any questions on tight fitting? He's coming, he's coming. Does the CPSC have a preference whether we use inches or millimeters to measure? I mean, there's both in here, but- As long as your garment meets those measurements, that's why we have both available. Usually for companies overseas, they have to obviously comply with our standards too and they don't use inches, so that's why we have it. But no, as long as they meet, and if you're using a lab, if you want to have it in centimeters or inches, that's fine. It does not matter, there's no preference. I actually am the lab.  All the way in the back, John. Hi, I'm Mike Diablo from SGI. Have you found that the retail community has requested longer lengths on cotton garments because they don't feel that the CPSC garments are long enough? No. I have not gotten that question. Yeah, we have. Yeah, like top lengths. So kids are getting taller? Or they don't feel that the spec is long enough because when they put them on the garments, maybe the kid is a little bigger, a little smaller, the belly's hanging out, they want them a little longer. So I just wanted to know if you've gotten any feedback from that. I have not. Hasn't reached my office yet. Yeah, I'd be interested as H&M. Do they do anything like that? Cindy? Yeah, we have several retailers that are asking for that now. I've gotten questions on the sizing standards that are in the tight fitting requirements. And because the rule was written in 1996, kids' sizes have changed quite a bit. And we've been asked to take a look at the sizing that's in the tight fitting requirements. We don't have a project to do it right now, but we are aware that people are asking the question about the tight fitting sizing that's in the standard. Wait, wait, wait a second, wait. One thing that I hear is that people are just buying larger sizes. So even though it says buy it to fit snug, that it's intended to be one small, I know a lot of people just buy it bigger. So that could be also to compensate for the length as well. And we don't recommend that people do that. I realize that, but I think that's what's actually happening in a lot of cases. There's only so much we can control. Does the CPSC offer any kind of guidance document on how many items should be for tight fitting sleepwear? How many items should be measured across a batch size to have confidence that your whole batch is tight fitting? You mean quality control? Yes. Yeah, I would say this would be personal because we don't really have a statement stating that you have to test or measure every four garments. We just advise that you're doing quality control perposing, you actually have a team or the factory or you're using a lab and you're making sure. Because we do, I mean those recalls, that was an issue. They gave their correct dimensions to the factory. They weren't followed. That comes back on the firm. So yeah, you do need to have a certain team, someone or multiple people measuring throughout the entire process. That's the only way you're gonna know that they're being followed. When the rule was first written, we recommended that manufacturers measure at least 10 garments in a size. That gave you a pretty good range for the tolerance within that size. Is that per style or just? Yeah, so you're still ongoing testing. You mean each measurement dimension needs to be tested per size, yes. For the baby sizes, where there's the exemption up to nine months. When you're measuring a baby size, there's that maximum dimension in the length. How would you measure it when there's a foot? It's a footy style. When you get to that foot part, do you have to, do you go to the ankle? Do you flatten out that foot? Are there any? You're talking about the elastic seam? Yeah, you measure the heel. Yeah, when it's a footy style, that maximum length, how do you? You're not measuring it to the toe, if that's what you're asking. You're gonna measure it at the ankle. Measure it to the ankle. To the heel, to the heel of the foot. Okay, so you flip it over, you measure it on the back, and you measure it to the heel. Okay, so the heel and the ankle might be a different seam, though. Yeah, that's, there's either elastic or there's an actual seam. Right. So if you're doing it to the heel, the ankle would be the elastic seam. Does that make sense? Yeah, well, I mean, it might be different for style, like you're saying. Yes. Okay. You can always send me a picture, send me a video. All right, okay. That would be great. Thank you. Everyone's hungry now. Okay, just a thank you to the panel. Thank you to Carolyn Carlin, Paige Whitson and Linda Fanzler for the very informative session on testing type fitting and the laboratory requirements. Also want to thank Jonathan Kent for fielding the questions and taking in questions. If you do need to send in questions by email, it is jkent. J-K-E-N-T at cpsc.gov. So we will look at those later at the Q&A session. So we will get back on track. We will go to lunch and return at one o'clock p.m. sharp. But because we have covered some afternoon sessions, that does mean that we will conclude our seminar a little bit earlier than expected. So hopefully that makes everyone happy. There's a lunch place here in the building. There's a shuttle van outside of the building that makes a loop around Bethesda and goes to Bethesda Row. There's the website on the handout that was in your folder with some other restaurant ideas and places close by in Bethesda. It's also walkable. It's a decent walk, but it's certainly doable. Please feel free to ask any CPSC staff if you want some recommendations or ideas or directions. We have a couple of exciting sessions coming up this afternoon, so I don't want you to miss those. So one p.m. sharp. We will have our panel on testing. We have representatives from independent laboratories here to share their stories with you. And we also have what to expect when you're inspected with some other CPSC staff. And then we will field any questions and answers to ensure that you have your chance to ask questions and learn something new from today's seminar. So have a great lunch. I will see everyone at one p.m. Thanks.