2013 Toy Safety Standard ASTM F963, 2013 Safety Academy

This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.

2013 CPSC Safety AcademySeattle, WA

The BasicsThe Basics

• ASTM F963 was adopted – and subsequently updated – as mandatory rule by CPSC, as required in the Consumer Product Safety Improvement Act of 2008 (CPSIA)– Copyright still owned by ASTM-International –

copies must be purchased at www.astm.org– Read-only copies available for viewing online

when ASTM proposes revisions to CPSC

• F963 is one of the key requirements for children’s toys but other requirements also apply. (E.g. lead content, lead in paint, banned phthalates, small parts, hazardous substances….)

History of the StandardHistory of the Standard

• First version developed by toy industry and published by the National Bureau of Standards – 1976

• First version of ASTM F 963 developed by the American Society for Testing and Materials (ASTM) –1986

• ASTM F 963- 07e1 adopted as a mandatory standard by the CPSIA – 2008

• Most recent version (ASTM F 963-11) became effective June 12, 2012

ASTM F 963 - OverviewASTM F 963 - Overview

• Subcommittee members from industry, consumer groups, government

• Requirements based on injury analysis• Covers toys for children under 14 years• Scope excludes products addressed by

other standards• More than 40 sections of requirements• Annexes contain information and

rationale

Scope OverviewScope Overview

• Addresses thermal, electrical, and mechanical hazards of toys, packaging, and toy chests

• Sections for prevention of choking, lacerations, strangulation, impalement, suffocation, falls, burns, poisoning, eye injuries, etc.

• Age Grading: Advice for matching toys to children of certain ages

The Standard ItselfThe Standard Itself

• List of other federal rules for toys• Definitions• Requirements• Test methods• Guidelines

Where are we now? Where are we now? September 2013

• 2011 version added:– Lead requirements aligned with CPSIA– Heavy elements (8) in substrate

• Compositing Procedure for Total Heavy Metal Analysis

– Cadmium requirements– Bath toy projections– Seat overload testing– Acoustics testing aligned with international

standard– Elastic tether toys testing– New figures

Mandatory Standard Revision Mandatory Standard Revision ProcessProcess

• ASTM F963 revisions sent to CPSC for review

• CPSC may reject revisions within 90 days• Unless rejected, changes become

mandatory 180 days after proposal• CPSC rejected removal of toy chest section

from ASTM F963-08, so ASTM F963-07e1 toy chest requirements remain in use with current mandatory version, ASTM F963-11

Partial List of Requirements Partial List of Requirements ASTM F963

• Sound-Producing Toys • Battery-Operated Toys• Small Objects • Stuffed and Beanbag-type

Toys• Projections • Marbles and Balls• Folding Mechanisms and

Hinges• Hemispheric-Shaped Objects• Cords and Elastics in Toys• Yo-Yo Elastic Tether Toys• Bath Toy Projections

• Wheels, Tires, and Axles• Magnets• Pacifiers• Balloons• Projectile Toys• Certain Toys with Spherical

Ends• Rattles• Teethers and Teething Toys• Squeeze Toys • Toxicology: Heavy Elements

in Paint and Substrate

9

Third Party Testing RequiredThird Party Testing Required

Except in the following circumstances:

• Sections that address requirements for labeling, instructional literature, or producer’s markings;

• Sections that involve assessments that are conducted by the unaided eye and without any sort of tool or device.

• Sections that pertain to the manufacturing process and thus, cannot be evaluated meaningfully by a test of the finished product (e.g., the purified water provision at section 4.3.6.1); and

• Sections that address food and cosmetics;

How To Apply the Standard?How To Apply the Standard?

• Age grading:– matches the attributes of the toy to the capabilities of the

child; and– is used to determine the appropriate tests to which a

product must comply.

• The Commission considers:– the manufacturer’s labeling on the product, if it is

reasonable;– whether the product is advertised, promoted, and

marketed for that age child;– whether the product is recognized commonly by

consumers as being intended for that age child; and– Age Determination Guidelines – September 2002.

ExamplesExamples

• Not All Sections of F963 Apply to Every Toy

• Some Sections of F963 Require Third Party Testing, Some Sections Do NOT require Third Party Testing

• Clear Examples– Robert von Goeben, Co-Founder, Green

Toys

ExamplesExamples

• “Gray Area” Examples– Testing Laboratory: Pratik Ichhaporia,

PhD, Intertek Consumer Goods

www.intertek.com14 © Intertek 2013,

All Rights Reserved

o Classification

General use vs. Children’s products

Children’s products vs. children’s toys

o Applicability of toy safety standard sections

Interpretations

Children’s Product?

Toys?

Toy Safety Standard: Applicability of Requirements

Section 4.36 Hemispheric Shaped objects

4.18.1 Accessible Clearances for Moveable Segments

www.intertek.com18 © Intertek 2013,

All Rights Reserved

TIA Interpretation’s committee

Revision to standard to clarify gray areas

F15.22 Sub-committee on going work

Magnets

Projectiles

Certain other requirements including emerging hazards

Standard Revision

Where are we going?Where are we going?

New Issues and Emerging Hazards• Nancy Cowles, KIDS in Danger• Working groups:– Batteries in toys (Lithium batteries, fire prevention)– Magnets in toys (Magnet strength, flux index, labeling)– Projectile toys (Kinetic energy, improvised projectiles)– Impaction hazards (Nail-shaped hazards)– Emerging hazards (Projection hazards)– Toy Chests

Thank YouThank You

Panelists:

Robert von Goeben Co-Founder, Green [email protected]

Nancy CowlesKIDS in [email protected]

Pratik Ichhaporia, PhDIntertek Consumer [email protected]

m

Moderator:

Neal S. Cohen Small Business Ombudsman, [email protected]

Twitter @CPSCSmallBiz

www.slideshare.net/USCPSC

www.cpsc.gov/Toysafety

www.cpsc.gov/GettingStarted

www.cpsc.gov/SmallBiz

Safety & Compliance in aHyper-Growth Eco Company

Robert von GoebenPresident & Co-Founder, Green Toys Inc.

[email protected]

© 2010 Green Toys Inc. CONFIDENTIAL – DO NOT DISTRIBUTE

Green ToysGreen Toys

Market Leader in Socially Responsible and Environmentally Friendly

Children’s Products

Solid in over 5,000 retail locations in USAPottery Barn, Whole Foods, Amazon, CostPlus,

Nordstrom's, Barnes & Noble, etc.Export products to 97 countriesAverage annual revenue growth 70%






Corporate Goals 2007Corporate Goals 2007

1. Find “quantifiably green” plastic material• Afterlife (biodegradable, recyclable)• Proven environmental stats (greenhouse gas

reductions, energy savings)

2. Made in SF Bay Area of USA• Find local manufacturers

3. Safe materials and processes• Find reliable trusted supplier• Work in absence of testing procedures• Find trusted labs


High-Density PolyethyleneHigh-Density PolyethyleneSafety

#2 one of the safest plastics availableNo BPA, phthalates, PVC, etc.

Wide AvailabilityCurb-side collectedAvailable in California

Good MarketingFamilies understandClose the education loopGood connotation

CHALLENGE: Manufacturability


Our key to compliance: simplicityOur key to compliance: simplicityLimited raw materials

ResinColorant

Limited suppliersGT knows all sub-suppliersAll in USA

Simple productsNo batteriesNo electronicsNo glues, screws, metal, paints, surface coatings, decals


Challenge 1: Recycled Resin Challenge 1: Recycled Resin

1. Less material certifications

2. Inconsistent feedstock

3. “Cottage industry” suppliers


Solution: Lot testingSolution: Lot testing

Lots manufactured and quarantined

Independent 3rd party

Chemical testing

Release upon compliance


Challenge: ManufacturingChallenge: Manufacturing

No screws

No metal at all

No glue

No paint


Challenge: Made in USA

Challenge: Made in USA


Initial and annual testingInitial and annual testing


Product SafetyProduct Safety

Rigorous US-based testing programRaw Materials

Lot testing of recycled resin

StandardASDTM F963EN71ISO8124

AdditionalFDA Food ContactBPAPVC


Corporate GoalsCorporate Goals

1. Find green material

2. Made USA

3. Safe materials and processes

Robert von GoebenPresident & Co-Founder, Green Toys Inc.

[email protected]

04/12/23

Toy Safety: The Consumer Perspective

Presented by:

© 2013 Kids In Danger, Inc.

Nancy Cowles, Executive Director

Nonprofit organization dedicated to protecting children by improving children’s product safety.

© 2013 Kids In Danger, Inc. 39

Founded by parentsLinda Ginzel and BoazKeysar after the deathof their son, Danny.

Toy Safety

40© 2013 Kids In Danger, Inc.

a. Shared toy boxb. Supervisionc. Age gradingd. Real world use

Choking


Hazard Highlight:

Build-A-Bear recalls “Sully”Character stuffed animal.

Basic Beat BB201 standard eggShaker recalled.

Detachable metal conductor pin onlight-up toy frogs and ducks.


Hazard Highlight:Lead

Recall of "Soldier Bear”Toy sets due to leadPoisoning hazard.

Various Thomas & FriendsWooden Railway Toys containlead-based paint.

“Dinosaur Epoch”toy dinosaursrecalled by XtremeToy Zone.

Magnets


Hazard Highlight:

Kenny died after swallowing loose magnets that fell out of a magnetic toy. He was 21 months old.

Toys R Us recalls BuckyballsHigh-power magnet sets.

Magnetix Building Sets are atop recall item.

Hazard Highlights:


Toxins

Spin Master “Bindeez”or “Aquadots” contain apharmacologically activesedative pro drug.

Plush toys are found to be treated with Chlorinated Tris, a carcinogenic flame retardant. Not recalled.

Emerging Hazards:


Water Balz Water-absorbing polymer beadsSold As:Water Balz, Growing Skulls, Growing Spider, H2O Orbs “Despicable Me,” Cosmo Beads, and Fabulous Flowers toys

Emerging Hazards:


Water Balz Water-absorbing polymer beadsAlso non-toy marketing


Lingering Hazards:Eyeball ToyThe plastic eyeball containskerosene, which if broken,presents a chemical hazardto children. Mike’s Story

A toy ball filled with adangerous liquid injured5-year-old Mike when itcracked and leaked fluidinto his eye.

Solutions

• Testing• Standards• Learning from past



Kids In Danger116 W Illinois StreetSuite 4EChicago IL 60654Phone: 312-595-0649Fax: 312-595-0939Email: [email protected]

www.KidsInDanger.org

Facebook:

www.facebook.com/KidsInDanger

Facebook:

www.facebook.com/KidsInDanger

Twitter:

www.twitter.com/KidsInDanger

@KidsInDanger

Twitter:

www.twitter.com/KidsInDanger

@KidsInDanger

Thank YouThank You

Panelists:

Robert von Goeben Co-Founder, Green [email protected]

Nancy CowlesKIDS in [email protected]

Pratik Ichhaporia, PhDIntertek Consumer [email protected]

m

Moderator:

Neal S. Cohen Small Business Ombudsman, [email protected]

Twitter @CPSCSmallBiz

www.slideshare.net/USCPSC

www.cpsc.gov/Toysafety

www.cpsc.gov/GettingStarted

www.cpsc.gov/SmallBiz

2013 Toy Safety Standard ASTM F963, 2013 Safety Academy

Business

matching toys

green toys

sections of f963

standard itselfthe standard

cpsc f963

version of astm f

lead requirements

mechanical hazards of