Parents rightfully expect toys to be safe when we make a purchase and the majority of the time, they are. However, what isn’t known is what someone like me, my colleagues and factories has to do to make sure our products are safe. It may be more complex than you think.
First, we typically start with a concept; someone’s idea of the next greatest thing to hit the toy industry; we’ll use a battery operated, talking teddy bear as an example (not so great, I know). This is when I first lay the foundation for my opinion, by asking questions like; “what is the cover material?”, “how is it expected to perform?”, “does it fly?” These questions give me an idea of how play patterns translate into safe or unsafe use.
From there, engineering is completed and prototypes created, which further brings the bear to life. I can then provide more detailed direction for safety and regulatory compliance by first appropriately age grading the item using the CPSC guidelines and dissecting the bear precisely determines how it operates mechanically. I would also specify how the battery compartment should be designed, so that the batteries are never accessible and prevent them from being reversed which leads to possible overheating. No detail is overlooked and I have to consider all possible and unforeseen abuses of the bear, to truly know how safe it will be.
There are very important basics to safety and regulatory compliance that I am leaving out, like the prohibition of small parts, sharp points or sharp edges in some toys. In the case of the bear, it would be appropriate for children of any age, so none of these hazards are acceptable. Determining the current or future presence of these hazards requires a series of tests that are specified in the Code of Federal Regulations (CFR). They include a drop test, from various heights & frequency, torque forces for all components that a child can grasp, followed by a tension test (or tensile force). Last, a compression test that simulates a child stepping on the product.
There are many more tests that have to be completed before I give this bear final approval, including determining if it meets all of the applicable requirements in ASTM F963, the toy industry standard that has recently been adopted into federal law. There are way too many tests to detail here, but they include among other things; potential pinching and crushing hazards, seam strength testing and the bear’s flammability. This standard also cites state laws, which require that the product be labeled, the stuffing meet cleanliness minimums, which prohibit bacteria, human hair, rocks, metal fragments or any other contaminants.
Because Teddy is a toy, he has to meet very stringent chemical limits; the most recognizable being the lead content in paints. This law has been around for over 30 years, but recently, with the enactment of a new Federal Act, called Consumer Product Safety Improvement Act or CPSIA, the limits have been reduced to 0.009% or 90 parts per million (ppm).
Paints also have limitations for other chemical elements, typically referred to as the “soluble heavy metals content”, which limits the permissible amounts of barium, cadmium, selenium, mercury, chromium, lead, antimony and arsenic. This test considers and simulates human digestion, so the limits are slightly different than the lead content noted above.
Children’s products, including toys also have a maximum lead limit in their accessible substrates as well. Using our bear as an example, his fur, plastic nose and the vinyl pads on his feet are covered under the terms of CPSIA and required to comply. This limit is 0.03% (300ppm), until possibly it is further reduced in 2011.
The next and most controversial chemicals with mandatory limits in toys are called phthalates; plasticizers, typically used to soften plastics and sometimes paint. There are six phthalates which according to some studies are known to be carcinogenic and are each limited to 0.1% (1000ppm) in CPSIA. The limits apply to all components of a product, even if they are not accessible. For example, our bear has wires deep inside of his guts leading from the battery compartment to the motor moving his mouth. Those wires, under normal circumstances would not be accessible by children, but nonetheless are now required to meet these limits. The controversy is whether or not phthalates are truly hazardous and if their accessibility should be considered. For the time being, we have no choice and have to comply while those details are discussed in Congress.
I’m not done. There are state laws that limit the amount of certain elements in the packaging of the toy. Because the bear uses batteries, there could possibly be Federal Communication Commission performance measures for unintentional radiation. There are warning statements & country of origin markings, required on the packaging; all requiring specific placement and size. A label is required on the bear that declares its filling material content and a registration number that identifies the manufacturer of this stuffed toy.
Keep in mind that all of this has to be outlined and a production management plan detailed with the factory before we even near mass production. Not to mention that factories are required by many retailers & US Customs to meet specific ethical, labor and security standards before our Teddy is produced.
Last, confirmation that Teddy passes all of the above requirements! We typically pay a CPSC approved 3rd party test lab to conduct product testing, audit our factory and provide a report that shows compliance with all of the laws. These reports I keep in my files and supplied to the retail customer, customs & the CPSC, when requested.
A lot of coordination, detailed work and long hours are spent preparing to launch a new product. Although this is the 30,000 foot view of what is involved in safety & compliance, every detail requires hours of preparing documents, research, meetings, emails, phone calls and frequent travel. I have racked up over 150,000 miles of air travel over the past several years, so United Airlines loves me….well, except at O’Hare. In the end, the satisfaction is worth every minute, mile and bad Chinese breakfast I eat.
