Guidance

PRISM: Narrative style risk assessment – non-compliant cords and drawstrings identified in clothing intended for children

Published 10 October 2024

Applies to England, Scotland and Wales

1) The product

The product is a summer garment set comprising of shorts and a top with decorative cords designed to tie into a bow. The decorative cord on the top ties across the front of the neck to create a bow, the intended age of the garments is for children under 3 years of age. The cord is 342mm in length which is prohibited within the relevant standard EN 14682:2014 and covered under General Product Safety Regulations 2005.

In accordance with the standard, garments intended for young children shall not be designed, manufactured, or supplied with drawstrings or functional cords in the head, neck or upper chest area. In addition, decorative cords shall not be permitted anywhere on the hood or at the back of the neck. In other parts of neck and upper chest areas, decorative cords shall have free ends no longer than 7.5cm, shall have no knots, toggles or three-dimensional embellishments and shall not be positioned so they can tie across the throat.

Very young children are especially vulnerable to strangulation because their heads weigh proportionately more than their bodies compared to adults and their muscle control isn’t fully developed, which makes it harder for them to free themselves if they get tangled up. ^{[footnote 1]} In addition, their windpipes are smaller in diameter and softer than those of adults and older children. This means their airways become blocked and they suffocate more quickly when their necks are under pressure. ^{[footnote 2]}

Some babies start climbing or walking before they can crawl; they can shuffle on their bottoms to grab things that parents think are out of reach. ^{[footnote 3]} In addition, young children up until the age of three may still have at least one period of sleep during the day, ^{[footnote 4]} the younger the child the increase in frequency of these nap times. In most cases, the outfit the child is wearing during the day is not changed prior to these day-time naps. It is foreseeable that one of the cords from the child’s clothing gets entangled or looped around the child’s neck. It is reported that some children under 3 years have been strangled by cords, this could be a blind cord, a ribbon attached to a cot bumper, a string trailing into the cot, or the decorative cord from the top which they are wearing.

Note: As this is a worked example further product details are not provided here, but would normally include:

• manufacturer/brand
• model
• batch numbers and any other coding
• quantities supplied and over what time period
• how the matter came to the attention of the market surveillance authority (e.g. complaint, intelligence or ports and borders work)
• details of any reported incidents or injuries
• photographs of the product and packaging that, where possible, capture the hazard and identify the product

2) The hazard

The hazard under assessment is that the decorative cord attached to the top the young child is wearing becomes entangled around the child’s neck whilst taking part in usual behaviour and activities of children for their age and stage of development. For example, unsupervised sleeping whilst wearing the product and, playing on a play mat, in a bouncer or at a playground. In older children, cords and drawstrings can lead to injury or death if they get caught in items such as playground equipment, escalators, automatic doors, car or bus doors, ski-lifts or in the spokes of bicycle wheels, therefore the age of intended user is important as this may have an influence on their behaviour and level of supervision during such activities.

Drawstring and cord-related casualties are rare but devastating, especially when they occur in environments that most parents consider to be safe. In 2019, clothing, textiles and fashion items were the third most notified products on Rapex ^{[footnote 5]} and 63% of these notifications were for drawstrings or cords in children’s clothing.

Over the past 23 years, the US Consumer product Safety Commission (CPSC) has received reports of 27 deaths and 70 non-fatal incidents involving the entanglement of children’s clothing drawstrings, ^{[footnote 6]} and in China they have reported 192 clothing related incidents since before 2017. ^{[footnote 7]} There are insufficient data sources in the UK that relate specifically to clothing related incidents, however it is worth noting that population sizes within China and US significantly outweigh that of the UK, therefore if a ratio was to be applied the number of clothing related incidents within the UK should be significantly less than that reported in the aforementioned countries. It is also worth noting that clothing with long cords and/or drawstrings within the UK has been prohibited since 1976 which may influence the numbers of reported incidents, however when these are present within clothing there is evidence that these can have devastating consequences which can be preventable.

In 2024, the revenue in the Children’s Apparel market in the United Kingdom will amount to £10.37bn. ^{[footnote 8]}

3) Who could be harmed?

This product in particular is intended for very young children due to its design and size. There is evidence that cords and drawstrings within clothing pose a risk of severe injury or death, and the scenario is that this product could be worn by a very young child which could cause risks throughout the products lifetime.

In the following scenario we are considering a strangulation hazard. Children below the age of 3 years are particularly vulnerable to this type of hazard, but it is still present and there is evidence of occurrence in children over the age of 3 years. The Child Accident Prevention Trust states that it can take just 15 seconds for a toddler to lose consciousness if they get tangled in a blind cord, and there is no reason identified for this to be any different with a cord or drawstring on children’s clothing. Death can occur in just two or three minutes. ^{[footnote 1]}

According to the NHS each year 40,000 under-5s are admitted to hospital following accidents, and lots of these accidents are preventable, this also highlights that even with adult supervision children are at risk of injury or death. ^{[footnote 9]}

4) Harm scenario

The scenario details how the child is wearing the top whilst placed in a reduced supervision environment in which the caregiver may assume safe, for example a playpen, highchair, bouncer, car seat or push chair. The decorative cords on the top become entangled around the child’s neck. Whilst children within this age category are generally under close carer supervision, this scenario details that carers do not notice in time as the carer assumes the child is safe within their environment.

It is foreseeable that the child cannot break away from the source of entrapment as this product is intended for the age category under 3 years, it is designed for a very young child who may not have the strength or developed the skills to free themselves. The steps leading to the level 4 harm are as follows:

Step 1: A young child is wearing the top with decorative cords in a low supervision context, such as in a playpen, highchair, bouncer, car seat or push chair.

Step 2: The decorative cord attached to the top becomes entangled around the child’s neck.

Step 3: The child cannot free themselves from the source of entrapment, and the parents or carers do not notice in time to act.

Step 4: A level 4 injury occurs.

5) Severity of harm

Strangulation accidents are rare, and most people don’t always think it is possible for their child to strangle themselves. It is reported that early intervention to release the hazard can prevent fatality, ^{[footnote 10]} the most commonly occurred injuries are within the neck area such as bruising, swelling and burns from the material. However, there is evidence that there are a growing number of cases of children catching themselves on blind cords or other loops, which can be fatal ^{[footnote 11]} particularly when intervention is too late to release the cords in time.

6) Probability of harm

The following probabilities can be estimated using the available data and knowledge of human behaviour:

Step 1: A young child under 3 years is wearing a top with decorative cords in a low supervision context.

The summer garment set is designed for children under 3 years due to the size and age recommended for the garments. Children of this age are also encouraged to have regular periods of sleep during the day. Based on best judgement, a conservative probability of 0.02 is given to the likelihood of a child under 3 years wearing the garment whilst placed in a cot to sleep based on a common-qualitative event.

Probability: 0.02

Step 2: The decorative cord attached to the top becomes entangled around the child’s neck.

There is evidence that cords and drawstrings within clothing pose a risk of severe injury or death, this product could be worn in a number of scenarios by a very vulnerable child which could cause risks throughout the products lifetime. This probability is also informed by the nature of the material, for this example, a probability of 0.01 is given.

Probability: 0.01

Step 3: The child cannot free themselves from the source of entrapment, and the parents or carers do not notice in time.

The nature of the material of the cord, the length of the cord and behaviour of wearer may impact on the probability scoring. This could be determined from data presented within a test report or a feel of the cords during a visual inspection. Young children are especially vulnerable to strangulation because their heads weigh proportionately more than their bodies compared to adults and their muscle control isn’t fully developed, which makes it harder for them to free themselves if they get tangled up, plus, their windpipes are smaller and less rigid than those of adults and older children. This means they suffocate far more quickly when their necks are constricted, plus this is silent harm.

Based on best judgement, a conservative probability of 0.1 is given.

Probability: 0.1

Step 4: A level 4 injury occurs. The child is strangled leading to death or brain damage.

Asphyxia (which includes choking, strangling and suffocation) is the second most common cause of accidental child death in the UK, after road traffic accidents. The probability is calculated to be 0.1.

Probability: 0.1

Compound probability = 0.02 x 0.01 x 0.1 x 0.1 = 0.0000020

7) Level of risk

The steps to harm are summarised in the table below.

Steps	Probability
1: A young child under 3 years is wearing a top with decorative cords. The child is placed down for a nap during the day.	0.02
2: The decorative cord attached to the top becomes entangled around the child’s neck.	0.01
3: The child cannot free themselves from the source of entrapment, and the parents or carers do not notice in time	0.1
4: A level 4 injury occurs. The child is strangled leading to death or brain damage.	0.1

The compound probability is the sum of the probabilities at each step, which equates to 0.0000020 (or 1 in 500,000). For a level 4 injury, this is a medium-risk outcome (see PRISM guidance Table 3 in Part 1, section 2.2(vii)).

8) Uncertainty

There is a medium level of uncertainty in relation to this assessment. This injury scenario takes into consideration consumer behaviour, even though some behaviours can be predicted it is challenging to directly attribute human behaviour to this specific product. Although data is available to support some of the steps there is still a level of uncertainty and judgement used, particularly for steps 1, 3, and 4 where subjective probabilities have been applied. The harm scenario is largely based on predicting the behaviour of young children and of adult caregivers, both of which come with uncertainty.

Sensitivity analysis

The probability associated with step four is an area of uncertainty. Whilst reports indicate that this probability is proportionate, there is limited injury data from hospitals to validate the claims these reports make. The outcome of the risk assessment is somewhat sensitive to changes in these probabilities, which would need increasing by a factor of 10 or more to move the risk level outcome from medium to high. Multiple steps would need to be increased by a factor of 10 or more to increase the risk level to serious.

9) Risk evaluation

This product poses a medium risk of a level 4 injury. The subjects primarily at risk in this scenario are children under 3 years of age. The public has a low tolerability of non-compliant products that can cause avoidable injury to children, particularly very young children. This includes the risk from cords on blinds which has utility, and an effective means of mitigating the risk with cord breaks and tie backs. Decorative cords and drawstrings on clothing do not offer utility other than a decorative quality, and are not considered necessary on children’s clothing, therefore it is considered there will be a very low tolerance of harm from cords in children’s clothing. The highly distressing nature of the potential injury and the circumstances in which it can arise are such that there is potential for psychological impact on the parent or carer, the child’s family, and anyone involved in dealing with the incident.

In addition, the nature of the risk in this case is low probability and high severity, and such risks tend towards low tolerability, compared to high probability and low severity. It is unlikely that a product presenting these hazards left in the hands of consumers would be considered tolerable. This low-level risk is therefore considered intolerable, and action will be required to reduce the risk to a tolerable level.

10) Footnotes

1. Strangulation – Child Accident Prevention Trust ↩ ↩²

2. Pediatric airway – University of Wisconsin School of Medicine and Public Health ↩

3. Child development milestones – NHS Cambridgeshire Community Services ↩

4. Naps (for parents) – Neymours Children’s Health ↩

5. Safety Gate (RAPEX) is a European system for the rapid exchange of information on dangerous non-food products. ↩

6. Questions and answer on cords and drawstrings – Europa ↩

7. An analysis of children’s clothing-related injuries cases reported by the media in mainland of China from 2003 to 2017 – National Library of Medicine ↩

8. Children’s Apparel – Statista ↩

9. Accidents and injuries – Keeping your child safe in the home – Royal College of Paediatrics and Child Health ↩

10. Paediatric hanging and strangulation injuries: A 10-year retrospective description of clinical factors and outcomes – National Library of Medicine ↩

11. Strangulation and Asphyxiation – RoSPA ↩