Danger to human health or safety assessment for children’s upper outerwear with drawstrings

Last updated: July 4, 2023

Table 3 was first published in July 2020 to consolidate information for regulated parties in an effort to increase openness and transparency regarding Health Canada's evaluation of products that pose a danger to human health or safety. While this entry was added to Table 3 upon initial posting of the table in July 2020, the danger to human health or safety was previously communicated by Health Canada to regulated parties. This assessment does not present new decisions, and is being published for clarity on the decisions made previously.

Legislative background

The purpose of Canada Consumer Product Safety Act (CCPSA) is to protect the public by addressing or preventing dangers to human health or safety that are posed by consumer products in Canada, including those that circulate within Canada and those that are imported. Any person who manufactures, imports, advertises, sells or tests a consumer product must comply with all applicable requirements of the CCPSA and its regulations. Paragraphs 7(a) and 8(a) of the CCPSA prohibit the manufacture, importation, advertisement or sale of any consumer product that is a "danger to human health or safety". The CCPSA defines the term as follows:

Danger to human health or safety means any unreasonable hazard — existing or potential — that is posed by a consumer product during or as a result of its normal or foreseeable use and that may reasonably be expected to cause the death of an individual exposed to it or have an adverse effect on that individual's health — including an injury — whether or not the death or adverse effect occurs immediately after the exposure to the hazard, and includes any exposure to a consumer product that may reasonably be expected to have a chronic adverse effect on human health.

Definitions

Children's upper outerwear

Upper body clothing, such as jackets and sweatshirts, generally intended to be worn over other clothing. This definition includes one-piece snowsuits and lightweight upper outerwear appropriate for use in warmer climates.

This definition does not include upper body clothing typically worn against the body, such as underwear, sleepwear, swimwear, swimwear cover-ups, shirts, t-shirts, dresses or hats.

Drawstring

A non-retractable cord, ribbon or tape of any material that passes through a channel, loop(s), eyelet(s) or something similar and functions to pull together parts of upper outerwear to adjust the size of the opening or provide for closure. A drawstring may be a single strand, a loop or other configuration.

This definition does not include belts or decorative cords (i.e., non-functional (ornamental) cords that cannot be used for closure).

Free ends
The loose ends of a drawstring outside the drawstring channel, loop(s), eyelet(s) or something similar.

Scope of affected products

Children's upper outerwear with drawstrings

Includes:

Excludes:

Hazards of concern

Children's upper outerwear with drawstrings can catch on playground equipment, fences or other objects and result in strangulation, or in the case of a moving vehicle, in a child being dragged.

IncidentsFootnote 1

Health Canada is aware of 16 reports of incidents that occurred in Canada between 1988 and 2010 involving children's upper outerwear with drawstrings. Of the 16 reports, three reported a death. Health Canada is aware of 25 reports of incidents that occurred in Canada between June 20, 2011, and December 31, 2022, involving drawstrings. Of these, ten reports were related to drawstrings on children's upper outerwear. Of the ten reports, none reported a strangulation.

Health Canada is aware of 38 reports of incidents and 18 reports of deaths between January 1985 and September 2009 involving children's upper outerwear with drawstrings in the United States. These reports involved children between 18 months and 10 years of age. Health Canada is aware of 8 reports in the United States of incidents that occurred between April 1, 2011, and June 30, 2020, involving children's upper outerwear with drawstrings. Of the eight reports, none reported a strangulation. The US data is from the Consumer Product Safety Commission's (CPSC) publicly available database: https://www.saferproducts.gov/PublicSearch.

Danger to human health or safety assessment

Based on the danger to human health or safety considerations and details discussed in the following sections, Health Canada believes that certain children's upper outerwear with drawstrings that do not conform to the applicable criteria set out in ASTM F1816-18 – Standard Safety Specification for Drawstrings on Children's Upper Outerwear, with modifications, or the equivalent, likely pose a danger to human health or safety.

Health Canada recognizes that there may be other possible health or safety concerns with the use of these or similar products. Industry should review their products for all potential hazards and respond appropriately to make sure they are safe for consumers. The Consumer Product Safety Program of Health Canada operates as a post-market regulatory regime, meaning that there is no pre-market review or approval of consumer products by Health Canada.

Health Canada may update this assessment as warranted.

Danger to human health or safety considerations

Considerations for a product to pose a potential danger to human health or safety are outlined in Health Canada's Industry Guidance - "Danger to Human Health or Safety" Posed by Consumer Products. The main considerations assessed are:

  1. Unreasonable hazard
  2. Existing or potential hazard
  3. Normal or foreseeable use
  4. May reasonably be expected to cause
    1. Death
    2. Adverse effect on health

1. Unreasonable hazard

The consideration of unreasonable hazard includes the following components.

a. Inherent hazard

Drawstrings are used to adjust the tightness of the waist or hood on children's upper outerwear. Two hazards have been identified with drawstrings: the potential strangulation hazard associated primarily with hood and neck area drawstrings of upper outerwear; the potential vehicular dragging hazard associated primarily with waist and bottom drawstrings of upper outerwear.

b. Severity of hazard

Strangulation may quickly result in loss of consciousness, permanent brain damage due to lack of oxygen, or death. Vehicular dragging by a moving vehicle may result in severe and permanent injuries or death.

c. Intended and foreseeable users

The intended users of children's upper outerwear with drawstrings are children. Children may be particularly vulnerable to the strangulation and vehicular dragging hazards posed by children's upper outerwear with drawstrings due to their increased likelihood of playing on playground equipment, such as slides, and being passengers on school buses.

d. Obviousness of hazard

It is likely not obvious to children or their caregivers that children's upper outerwear with drawstrings could pose a strangulation and vehicular dragging hazard.

e. Social utility

Drawstrings are used to adjust the tightness of the waist or hood on children's upper outerwear. Drawstrings may also have decorative value.

f. Available alternatives

Children's upper outerwear is available with alternative closures such as snaps, buttons, hook-and-loop fasteners, and elastic. Alternatives to hoods also include hats.

g. Consensus-based safety standards or government regulations

One consensus-based safety standard for children's upper outerwear with drawstrings is ASTM F1816-18 – Standard Safety Specification for Drawstrings on Children's Upper Outerwear. This standard sets out criteria that address the strangulation and vehicular dragging hazards, including:

Drawstrings at the waist and bottom of children's upper outerwear in sizes 2T to 16, or the equivalent sizes, should:

Children's upper outerwear in sizes 2T to 12, or the equivalent sizes, should:

These criteria, with the following modification, may be sufficient to mitigate the risk of strangulation and vehicular dragging:

Children's upper outerwear in sizes newborn to 12, or the equivalent sizes, should:

This expanded scope addresses the concern that children younger than two years of age may also be at risk of strangulation from drawstrings in the hood and neck area of children's upper outerwear.

There are products available in the Canadian marketplace that appear to conform to the applicable criteria outlined above.

2. Existing or potential hazard

Incident reports from Canada and the United States indicate the presence of the existing or potential strangulation and vehicular dragging hazards. Children's upper outerwear with drawstrings can catch on playground equipment, fences, other objects or moving vehicles resulting in injuries and death.

3. Normal or foreseeable use (including foreseeable misuse)

It is foreseeable for children to play on playground equipment or climb fences or other objects while wearing upper outerwear. Children's upper outerwear with drawstrings, especially those with attachments at the free ends, can catch on playground equipment, fences or other objects and result in strangulation. Reported incidents have included children's upper outerwear with drawstrings catching on playground slides.

It is foreseeable for children wearing upper outerwear to be passengers on school buses and other vehicles. Children's upper outerwear with drawstrings can catch on a vehicle and result in a child being dragged when the vehicle moves. Reported incidents have included children's upper outerwear with drawstrings catching on the closed doors of a moving school bus and children being dragged and being run over by the bus.

4. May reasonably be expected to cause

a. Death

Drawstrings, particularly in the neck area of children's upper outerwear, can become entangled on an object such as a play structure and can strangle a child. Strangulation may reasonably be expected to cause death due to a lack of oxygen being delivered to the brain. Drawstrings on children's upper outerwear can become entangled in a moving vehicle, such as a door or a rail. Being dragged by a moving vehicle may reasonably be expected to cause death.

Health Canada is aware of three reports of death in Canada involving children's upper outerwear with drawstrings, between 1998 and 2010.

It is therefore reasonable to expect that children's upper outerwear with drawstrings that do not conform to the applicable criteria outlined above to address the strangulation and vehicular dragging hazards may cause death.

b. Adverse effect on health

The circumstances that may reasonably be expected to cause death may also reasonably be expected to cause adverse effects on health, including:

Health Canada is aware of 13 reports of non-fatal injury in Canada involving children's upper outerwear with drawstrings, between 1998 and 2010.

It is therefore reasonable to expect that children's upper outerwear with drawstrings that do not conform to the applicable criteria outlined above to address the strangulation and vehicular dragging hazards may cause an adverse effect on human health.

If you require additional information regarding this Danger to Human Health or Safety Assessment, please contact a Health Canada Consumer Product Safety Office via email (hc.ccpsa-lcspc.sc@canada.ca) or telephone at 1-866-662-0666 (toll-free within Canada and the United States).

Footnotes

Footnote 1

Health Canada receives reports on an ongoing basis and does not validate details of every report it receives. Incident report numbers are based on the data available at the time of publication.

Return to footnote 1 referrer

Page details

Date modified: