Consumer Product Safety Commission: Consumer Education Efforts for
Revised Children's Sleepwear Safety Standard (Letter Report, 06/09/99,
GAO/HEHS-99-123).

Pursuant to a legislative requirement, GAO examined the type and extent
of consumer education that occurred since the revised children's
sleepwear safety standard went into effect in January 1997, focusing on
three voluntary point-of-sale practices that the Consumer Product Safety
Commission (CPSC) and others recognize as important for informing
consumers about the new standard.

GAO noted that: (1) as a result of cooperative efforts among CPSC,
children's sleepwear manufacturers, and retailers, progress has been
made in making point-of-sale information on sleepwear safety standards
available to consumers; (2) GAO found in the shopping sample that
informational hangtags--the most prevalent form of consumer education
material available--were used in about 73 percent of various brand
selection of snug-fitting garments; (3) however, the full range of
suggested point-of-sale practices has not been widely used; (4) fewer
than 16 percent of the stores GAO visited displayed either consumer
education brochures or signs about sleepwear safety requirements; (5)
also, about 63 percent of the stores displayed other clothing, such as
cotton long underwear and loose-fitting cotton T-shirts, on racks with
sleepwear--a practice that has been shown to cause consumer confusion;
(6) manufacturers and retailers told GAO that a primary reason that they
had not been more aggressive in offering consumer information was the
uncertain future of the standards; and (7) because the standards that
enabled snug-fitting sleepwear to be marketed could be revised or
revoked, the expenditure of additional resources on education efforts
relative to this product did not make good business sense.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  HEHS-99-123
     TITLE:  Consumer Product Safety Commission: Consumer Education
	     Efforts for Revised Children's Sleepwear Safety
	     Standard
      DATE:  06/09/99
   SUBJECT:  Safety regulation
	     Consumer protection
	     Children
	     Product safety
	     Clothing industry
	     Consumer education
	     Statistical data
	     Safety standards

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Cover
================================================================ COVER

Report to Congressional Committees

June 1999

CONSUMER PRODUCT SAFETY COMMISSION
- CONSUMER EDUCATION EFFORTS FOR
REVISED CHILDREN'S SLEEPWEAR
SAFETY STANDARD

GAO/HEHS-99-123

Children's Sleepwear Safety Standard

(108397)

Abbreviations
=============================================================== ABBREV

  AAMA - American Apparel Manufacturers Association
  CPSC - Consumer Product Safety Commission

Letter
=============================================================== LETTER

B-282019

June 9, 1999

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

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

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

Because correct size selection is important to the effective use of
snug-fitting sleepwear--and many parents may not be aware of
sleepwear standards in general--CPSC undertook efforts to educate
consumers on the new standard.  CPSC worked with industry groups,
such as the American Apparel Manufacturers Association (AAMA), to
voluntarily provide in-store point-of-sale information when consumers
make their purchase decisions.  The fiscal year 1999 appropriations
act covering CPSC and its accompanying conference report directed us
to examine the type and extent of consumer education that occurred
since the revised standard went into effect in January 1997. 

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

  -- removable information labels, called hangtags, on sleepwear
     garments;

  -- signs or educational brochures to inform consumers about
     children's sleepwear safety standards; and

  -- display of children's sleepwear separately from other types of
     children's apparel. 

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

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

--------------------
\1 Sleepwear is considered snug-fitting under this standard if it
follows prescribed measurements to ensure that the garment touches a
child's body at seven crucial points:  the chest, waist, seat, thigh,
ankle, wrist, and upper arm.  In addition to allowing the sale of
snug-fitting non-flame-resistant sleepwear, the standards exempt all
infant sleepwear sizes 9 months or under from flame-resistant
requirements. 

\2 The Congress directed CPSC to determine by July 1, 1999, whether
to revoke, maintain, or modify its earlier decision.  At the same
time, the Congress directed us to develop information that would help
in this deliberation. 

\3 See Consumer Product Safety Commission:  Injury Data Insufficient
to Assess the Effect of the Changes to the Children's Sleepwear
Safety Standard (GAO/HEHS-99-64, Apr.  1, 1999). 

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

As a result of cooperative efforts among CPSC, children's sleepwear
manufacturers, and retailers, progress has been made in making
point-of-sale information on sleepwear safety standards available to
consumers.  We found in our shopping sample that informational
hangtags--the most prevalent form of consumer education material
available--were used in about 73 percent of various brand selections
of snug-fitting garments. 

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

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

   BACKGROUND
------------------------------------------------------------ Letter :2

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

Before CPSC was established, the Department of Commerce implemented a
specific flammability standard for children's sleepwear.\4 This
standard required that fabrics used for children's sleepwear
self-extinguish when exposed for 3 seconds to a small open flame. 
The standard did not prescribe specific fabrics or require
flame-retardant treatments.  Some fabrics, mostly polyester,
generally could meet the requirement without treatment; others,
mostly cotton, would do so only if treated with a flame-retardant
chemical.  Because of the potential carcinogenic nature of one
treatment chemical in use in the 1970s, polyester became the
manufacturers' fabric of choice in producing children's sleepwear. 

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

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

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

In voting for the standards, one Commissioner specifically outlined
the importance of providing visible point-of-sale information to
remind consumers of the purpose of the standards, and of separating
the displays of complying sleepwear from other clothing to avoid
confusion.  However, because CPSC has limited funding available for
consumer education, it has worked with the apparel industry to
promote voluntary point-of-sale information. 

--------------------
\4 Commerce's 1972 sleepwear standard covered only sizes up to size
6x; in 1975, CPSC extended the children's sleepwear standard to sizes
7 through 14. 

\5 The two Commissioners supporting the amendment contended that the
snug-fitting sleepwear would provide a safe sleepwear alternative for
consumers who want cotton garments.  The Commissioner opposed to the
amendment argued that the snug-fitting sleepwear could increase
injuries if more consumers use it to replace traditional
flame-resistant sleepwear and purchase it in larger sizes to increase
comfort and to allow a child to grow into the garment. 

\6 According to CPSC, loose-fitting T-shirts or other oversized
clothes are the most hazardous garments for children to sleep in
because they can easily come in contact with small open flames and,
once ignited, they will burn rapidly. 

   INFORMATION HANGTAGS USED ON
   MOST CHILDREN'S SLEEPWEAR
------------------------------------------------------------ Letter :3

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

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

  -- artwork to identify garments as sleepwear,

  -- a statement that explains the importance of fabric and fit in
     children's sleepwear and that sleepwear should be
     flame-resistant or snug-fitting to meet CPSC's requirements, and

  -- whether a garment is flame-resistant or should be worn
     snug-fitting (see fig.  1). 

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

   (See figure in printed
   edition.)

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

Overall, we found that of the 273 brand choices of children's
snug-fitting sleepwear we identified at the 70 stores that we
visited, 199--or about 73 percent--had information hangtags attached
to them.  Of these, 70 percent used the AAMA-designed hangtag and 30
percent used other types of hangtags.  The other types of hangtags
vary significantly in their design but generally contain the same
basic language used in the AAMA hangtag.  We noted that the garments
without hangtags were not associated with a specific retail chain. 
Garments without hangtags generally represented brands that were less
prevalent at the stores that we visited. 

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

--------------------
\7 For analysis purposes, we defined "brand choice" as a distinctly
identifiable brand, trademark, or manufacturer name shown on the
inside label or hangtag of the garments.  Two or more styles of the
same brand were counted as one brand choice if they were found in the
same department in the same store.  However, if the same brand was
found, for example, in two different departments or stores, it would
be counted as two brand choices. 

   STORE SIGNS AND SEPARATE
   MERCHANDISE DISPLAYS PRESENT IN
   FEW STORES
------------------------------------------------------------ Letter :4

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

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

                          Table 1
          
           Sleepwear Display Practices in Stores
               Sampled, March and April 1999

                                     Number of  Percent of
Display practice                        stores       total
----------------------------------  ----------  ----------
Stores carrying snug-fitting                67          96
 cotton sleepwear
Stores with consumer information            11          16
 signs on display in one or more
 children's apparel departments
Stores with signs to designate              23          33
 racks for sleepwear in one or
 more children's apparel
 departments
Stores that mixed other garments            44          63
 with sleepwear in one or more
 children's apparel departments
----------------------------------------------------------
The lack of sleepwear designation and the mixing of sleepwear with
other clothing could confuse consumers because some of the other
clothing can be quite similar to sleepwear in appearance.  For
example, because of the lack of sleepwear designation signs, we often
had to get help from sales staff to find the children's sleepwear on
display.  In a few instances, we were directed by the salesperson to
garments that resembled cotton sleepwear, but upon closer
examination, we found that the garments had labels inside that read
"not intended for use as sleepwear.

--------------------
\8 In one additional chain, we found an indication that signs were
present during the fall and winter of 1998 but had been removed after
the holiday season. 

   CONSUMER EDUCATION EFFORTS
   HINDERED BY UNCERTAINTY ABOUT
   LIFE OF REVISED STANDARDS
------------------------------------------------------------ Letter :5

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

AAMA also issued two press releases and developed a press kit, which,
according to officials, was to be used to launch a comprehensive
consumer information campaign targeting general media as well as
parenting and medical magazines.  But AAMA officials decided to
suspend this effort initially because of industry concerns about the
ability to successfully produce and market snug-fitting products that
met CPSC's sizing standards.  Soon after the passage of the 1996
amendments, AAMA and other industry groups expressed concerns that
adherence to the specific measurements required by CPSC's sizing
standards would produce impractical and unwearable snug-fitting
products.  As a result, CPSC began making technical revisions to the
standards and, in May 1998, published a notice of proposed rulemaking
to change some of the specifications of the garments; final technical
changes were published in January 1999.  Because of these changes,
the new snug-fitting sleepwear garments were not made widely
available to consumers until fall 1998.  After this initial selling
season, AAMA officials said they were very encouraged with the market
acceptance of the new products and estimated that, in March 1999, the
new snug-fitting products made up about 15 percent of the children's
sleepwear market.  Our store visits confirmed that most of the retail
stores have begun to market the new snug-fitting sleepwear; 67 of the
70 stores we visited carried at least one brand choice of
snug-fitting cotton garment. 

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

   CONCLUSIONS
------------------------------------------------------------ Letter :6

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

   AGENCY COMMENTS
------------------------------------------------------------ Letter :7

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

However, CPSC expressed concern about our statement in the
conclusions that the effectiveness of the education effort was
unknown, in part, because of the lack of data on the extent of recent
sleepwear-related burn injuries.  CPSC believes this statement to be
unfounded, citing three reasons. 

  -- First, CPSC asserts there are data to support the position that
     the sleepwear amendments have not increased injuries.  We do not
     agree with this assertion.  In our April 1999 report, we found
     that data on the actual number of injuries are not available,
     which makes it difficult or impossible to observe trends in the
     number of injuries over time.  We also recognized that obtaining
     such data would be difficult and costly.  In this report, our
     point is that without such data, it is hard to know whether a
     more extensive education campaign is at least indicated. 

  -- Second, CPSC commented that the safety of the snug-fitting
     garments does not depend on a consumer education program.  We do
     not believe that CPSC's record or its past actions support this
     comment.  For example, in several published alerts to consumers,
     CPSC and the industry viewed the education campaign as important
     to promote a safer choice of sleepwear.  In fact, the hangtag
     wording, developed jointly by CPSC and industry, included the
     phrase .  .  .  fabric and fit are important safety
     considerations .  .  .  .

  -- Last, CPSC stated that our study was not intended to evaluate
     the effectiveness of consumer education in reducing burn
     incidents.  Our report acknowledges that our study was not
     designed to measure this link.  Nevertheless, we think it is
     important to elaborate on this limitation so that our overall
     findings can be viewed in the perspective of consumer safety. 
     Therefore, we continue to believe that our conclusions are both
     valid and founded in fact. 

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

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

---------------------------------------------------------- Letter :7.1

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

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

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

SCOPE AND METHODOLOGY
=========================================================== Appendix I

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

  -- large-volume discount or department stores,

  -- other discount or department stores, and

  -- children's apparel specialty stores. 

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

                         Table I.1
          
          Details on Retail Stores Visited by GAO
           in March/April 1999 to Observe Point-
              of-Sale Practices for Children's
                         Sleepwear

                 Number of
                    stores
Store type         visited  Locations
--------------  ----------  ------------------------------
Major discount or department store chain
----------------------------------------------------------
J.C. Penney             10  Sacramento, Calif.; Daly City,
                             Calif; Westminster, Colo.;
                             Tucker, Ga.; Lombard, Ill.;
                             Hyattsville, Md.; Clackamas,
                             Oreg.; Dallas, Tex.; Hampton,
                             Va.; Tukwila, Wash.
Kmart                    4  Fairview Heights, Ill.;
                             Shawnee, Kans.; Somerville,
                             Mass.; Laurel, Md.
Sears                    4  Santa Monica, Calif.; Tucker,
                             Ga.; Cambridge, Mass.;
                             Virginia Beach, Va.
Target                   7  Sacramento, Calif.; Colma,
                             Calif.; Manhattan Beach,
                             Calif.; Broomfield, Colo.;
                             Lombard, Ill.; Shawnee,
                             Kans.; Clackamas, Oreg.
Wal-Mart                 3  O'Fallon, Ill.; Plano, Tex.;
                             Bremerton, Wash.

Other discount or department store chain
----------------------------------------------------------
Bloomingdale's           1  Los Angeles, Calif.
Bon Marche               1  Silverdale, Wash.
Dillard's                1  Dallas, Tex.
Filene's                 1  Boston, Mass.
Foley's                  1  Westminster, Colo.
Hecht's                  2  Hyattsville, Md.; Hampton, Va.
Lord & Taylor            3  Atlanta, Ga.; St. Louis, Mo.;
                             Dallas, Tex.
Macy's                   3  Sacramento, Calif.; San
                             Francisco, Calif.; Boston,
                             Mass.
Marshalls                2  Merriam, Kans.; Hampton, Va.
Meier & Frank            1  Portland, Oreg.
Mervyn's                 3  Los Angeles, Calif.;
                             Westminster, Colo.; Tukwila,
                             Wash.
Montgomery               3  Lombard, Ill.; Overland Park,
 Ward                        Kans.; Baltimore, Md.
Nordstrom                4  Sacramento, Calif.; San
                             Francisco, Calif.; Oakbrook,
                             Ill.; Portland, Oreg.
Rich's                   1  Atlanta, Ga.
T.J. Maxx                1  Fairview Heights, Ill.

Children's apparel
----------------------------------------------------------
Babies"R"Us              1  Virginia Beach, Va.
Baby Gap,                9  Sacramento, Calif.; Los
 GapKids                     Angeles, Calif.; Boulder,
                             Colo.; Atlanta, Ga.;
                             Cambridge, Mass.; St. Louis,
                             Mo.; Portland, Oreg.; Dallas,
                             Tex; Seatac, Wash.
Kids"R"Us                4  Colma, Calif.; Lombard, Ill.;
                             Overland Park, Kans.; Laurel,
                             Md.
----------------------------------------------------------
For each store, we visited up to three separate departments: 

  -- infants (sizes 9 to 24 months) or toddler boys and girls (sizes
     2 to 4) or both,

  -- boys (sizes 4 to 14), and

  -- girls (sizes 4 to 14). 

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

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

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

(See figure in printed edition.)Appendix II
COMMENTS FROM THE CONSUMER PRODUCT
SAFETY COMMISSION
=========================================================== Appendix I

(See figure in printed edition.)

*** End of document. ***