Comments to CPSC on Drawstrings

On behalf of the American Apparel & Footwear Association (AAFA) and the Retail Industry Leaders Association (RILA), we write you in response to Proposed Rule, “Determination That Children’s Upper Outerwear in Sizes 2T to 12 with Neck or Hood Drawstrings and Children’s Upper Outerwear in Sizes 2T to 16 with Certain Waist or Bottom Drawstrings are a Substantial Product Hazard” (Proposed Drawstring Rule). By way of background, the AAFA is the national trade association representing apparel, footwear and other sewn products companies and their suppliers. RILA’s members include the largest and fastest growing companies in the retail industry--retailers, product manufacturers, and service suppliers--which together account for more than $1.5 trillion in annual sales.