Category Archives: Juvenile Products

US PIRG “Trouble in Toyland” Report

The Public Interest Research Group publishes an annual report that covers some of the broad strokes of toy safety as well as identifying current hazardous toys and children’s products in the market.  This report was published this past November and it is worth noting that some of the items identified in their report have already been recalled.  They do much more than report on unsafe toys, so check them out.

You can find the report here.  It is very thorough and outlines some of the hazards associated with toys available in the market and those covered in our safety standards.  Prior to the enactment of CPSIA, the standard widely known to cover toys, ASTM F963 was considered a ”voluntary” standard, although many retailers mandated conformance to its requirements.  However there have been loopholes.  Lets say you are an importer, listed as the “importer of record” on your customs documents and distributing goods from your own warehouse, many retailers would not require proof of compliance to safety standards.  This, I would assume, is how we still have hazardous products in the market.  No one has required them to prove conformance to US and Industry requirements, although some major US retailers are in the midst of changing that practice too.

Working in regulatory compliance, I wonder how some guy somewhere determines that it’s wise to allow those products to ship, rather than working with reliable factory sources and testing the product prior to shipment.  Although testing can be expensive, isn’t it cheaper than a recall and the mandatory penalties that the government will levy?  Perhaps they didn’t test the product or its materials at all; trusting that the factory would ship compliant goods. 

There are so many variables in importing toys from abroad that sometimes things get lost in the daily log of duties, but importing safe products shouldn’t be at the bottom of the list.  If for any reason (and not that it is the most important one), the financial strain it is going to cause your company.  Someone like PIRG comes along, tests your product and discovers a ton of lead or phthalates and the CPSC will not only recall your products, but some serious civil penalties will be coming your way!  You will pay more than the product was ever worth in the first place.

No one is exempt and no product quantities are too small to be discovered.  I am sure that these companies think their exposure is limited and no one will find their products….but you are wrong.  Groups like PIRG and forward thinking retailers like Toys R US and Wal-Mart are in the process of changing these practices, to not only protect themselves, but more importantly, children.

Several years ago, a little boy died after swallowing a charm from a pair of Reebok tennis shoes purchased for his sister.  The charm was almost entirely made of lead.  Yet, if you look in the PIRG report, they discovered a charm sold at Claire’s that was over 70% lead!  How can this happen?!  How could someone allow it to happen?

I think the work that PIRG is doing is keeping consumers informed and it adds a layer of policing that will keep these guys on their toes.  Ship unsafe products and someone will find you….


Children’s Toxic Metals Act

In the aftermath of the recent recalls by the CPSC, US Representative Jackie Speier from California’s 12th District is sponsoring a bill (link) that will limit the amount of cadmium, barium and antimony in children’s jewelry.  It’s a good thing right?  It depends who you ask.

For those in the consumer products industry, specifically toys and children’s products, we know the impact that CPSIA has had over the past couple of years and we still feel the sting.  This new bill, titled HR 4428 The Children’s Toxic Metals Act, is still in its infancy stage and has been presented to the House Energy & Commerce Committee.  It could certainly cause waves in the children’s jewelry industry if approved by the committee and sent to the house.  Waves are needed, but not “title” waves.

Don’t get me wrong, there should be regulations in place to prevent unnecessary danger to our kids, but this bill, as it stands is not the answer.  There is no question that elements like lead, cadmium, mercury, chromium, barium and arsenic are dangerous and could be deadly in high dosages and no one wants that.  But, how much is really too much? 

When CPSIA was enacted, it touched all products intended for children.  For example, lead was limited in the brass valve stems on bike tires.  What was never considered, was lead is a necessary element in brass valves, because it fills in all of the little porous holes in the brass, making it air tight; also that the lead wasn’t leachable, meaning that it won’t migrate from the brass; it simply stays in place.  So, unless your child breaks the stem off and eats it, he or she will likely never be exposed to harmful levels of lead.  The intent of CPSIA was a great thing, but the effective dates (virtually over night) were not so great and many companies have only made it this far because the CPSC has offered guidance, opinions and suggestions along the way, making the provisions more manageable.

This new bill is different, because jewelry will definitely be placed in the mouth, whether it be a necklace, a ring or a bracelet charm.  So, the chance of exposure is high and with no limits, the risks are even higher.  However, what hasn’t been considered is the percentage of these elements needed to result in negative health effects.  It is easy to say “don’t allow any to be used”, but is it necessary to ban them completely?  More than an educated guess is needed when determining  what the acceptable limits should be.  Right now, the proposal is zero and perhaps that is the right answer, but a much more thought out bill should be proposed; not a 4 page document with very little detail.  Often times, these elements are a technological necessity in manufacturing and there may be no alternatives, even at very low amounts. 

There has to be more science involved to determine “reasonable” limits, as opposed to this anecdotal knee jerk bill creation that could cause more harm than good.  The legislators must also consider the unintended consequences of this bill, like those we continue to feel from CPSIA.  Wouldn’t it be a good idea to get the CPSC  and perhaps the CDC involved at this point and have their experts provide more concrete data before it goes too far?  I think so.  I am not thinking as a selfish manufacturer of children’s goods, but as someone who has felt the sting of a similar situation.  I don’t make jewelry, but I can understand how this could crush that industry if a better plan isn’t proposed.


Strollers…a simple guide for a safe purchase.

So, Kerri and I did our fair share of stroller searching before Lulu arrived and had a few things in mind for our search; storage, ease of use, weight, fashion and compatibility with a baby carrier.  The stroller that we decided on was the Chicco Cortina Travel System.  The stroller folds with a one hand actuated latch and lift handle.  The baby carrier locks automatically when placed in the unfolded stroller and disengages by lifting the handle on the rear of the carrier.  They also have a system called ‘Keyfit’ which allows your baby carrier to lock into a base, installed in your car.  I, (like most guys), hate to admit that I don’t know everything and don’t need instructions, decided it would be best to follow them.  Fortunately, they were clear and I was able to install the Keyfit base in the car, even under the stress of Lulu coming early, it being cold and rainy outside and having a sick (& temperamental) wife in the hospital.

Now, given that I used to work for a test lab and evaluated the safety, reliability and use of strollers (more than I can count), I knew that Chicco made some great products and had not been the subject of any juvenile product recalls in their long history (although there have been several toy recalls).  They have a great track record for safety and designing affordable, fashionable and functional strollers.

We went to Babies ‘R’ Us one Saturday afternoon, drove it around the store and decided it was the perfect stroller for us.  Evaluating the safety of a product like this isn’t easy outside of lab and without the proper equipment is hard to do, but the advantage of shopping at any ‘R’ Us store is their corporate focus on safety.  They have one of the most effective systems in place to test the safety and compliance of the products they sell.  Now, this doesn’t mean that they will never sell products that could be included in a recall, because they do regularly.  However, this has nothing to do with their lack of due diligence.  Keep in mind that many recalls are a reaction to things unforseen and have nothing to do with a companies negligence.

However, here is my quick guide to picking a reliable and safe stroller:

1)  Unfold the stroller and when you place it back in the normal use position, the latches should all engage automatically.  Don’t assume that the floor model has just taken a beating and isn’t locking correctly as a result.  The floor models are usually indicative of the abuse your stroller will endure.  Dont pick a stroller that could fold (and latch closed) while your child is in it.

2)  Check the harness and make sure that it has secure waste and crotch restraints.  The restraint system shouldnt be easy for a child occupant to manipulate.  The restraint system security is your first line of keeping your baby safe.  Also, consider the comfort of the restraint when your child is in the stroller. 

3)  Look for accessibility of your child’s fingers and toes to moving segments, such as springs, access to sliding or rotating parts moving against one another.  Maclaren recalled about one million strollers, because a segment of the folding mechanism was able to pinch or crush fingers.  Their recall likely amputated fingers of children both inside and outside of the stroller.  Think about your toddler standing with his hand on the stroller when you quickly open it.  Is there anything that scares you?

4)  Look for a stroller with brakes that function easily and remain latched when engaged.  Some of you may have witnessed the video of the Australian mother who didn’t actuate the brakes and the stroller rolled from the standing platform into the path of an oncoming train (fortunately the baby survived).  Brake safety is critical to keeping your child out of harms way! 

5)  Stability; sometimes stroller makers are not considering a varying range of children intending to use the stroller, which could result in instability.  Sometimes they don’t consider that adding bags or other objects to the parent tray, handle or the undercarriage can add to instability (I know first hand, because I used to work for a stroller company and it wasn’t Chicco).  Try adding your purse to the handle while the stroller is empty to see how stable it is. 

6)  Look for anything that you feel could be unsafe.  Remember that the safety guys (like me) who are writing these standards are really just average Joe’s and we sometimes find unsafe designs and issues the same as any other parent.  Go with your gut instinct and if you feel a stroller is not fit for your family, don’t buy it.  You have to consider the safety of the kids not only inside of the stroller, but outside too.

The key is thinking about your use patterns and doing everything you can to duplicate those patterns while in the store.  Ask the store associates questions; you’ll be surprised to know that many of them know a lot about safety and the details of products in the store.  Roll the stroller around the store, play with the restraint, fold it/ unfold it, adjust the back rest and do anything you would normally do to decide if that stroller fits your needs.

One last thing; the only thing that Kerri and I dont like about our Chicco is that you have to remove the infant carrier to access the storage compartment underneath.  Our thought was to add springs to the basket, so that the edge can be pressed down to access the goods; we have seen this on Graco stroller before.  Oh well….our overall satisfaction is a 4.5 out of 5.

I hope this is helpful in your stroller search!


Yo Bumbo!

Having had our first baby, Kerri and I were flooded with a ton of incredible gifts from our family and friends, all of which we love and use everyday.  One of those gifts we were able to put to use recently, when we felt Lulu was strong enough to hold her head up on her own; was the Bumbo Baby Seat.

It seems to be a simple product in theory, but working for a consumer products company, I can tell that a lot of thought when into its design.  It’s a one piece formed foam seat, that allows babies 9-22 lbs. (who are able to hold their head up) to sit comfortably in a seated position.  It is slip resistant, soft and pliable and according to Bumbo’s website, is comprised of safe/ non toxic foam.  Given the Bumbo’s relative success and that it’s a one piece item, comprised entirely of the same material, there is probably little to worry about in regards to safety.  Overall rating of this item would be a 4.5 out of 5; the only thing which I don’t like is its limited recommended age (size) range.

Lulu loves her Bumbo, because she’s sitting up like a big girl without mommy or daddy holding her or being confined to her swing.  If there is one of many items I highly recommend everyone with a new baby purchasing, the Bumbo is at the top of the list.  Although they can only be used for a short amount of time, it’s worth the investment. You can buy them online or at your major retail chains for about $40.  A really, cool, simple item; but very useful, comfortable and convenient and your baby will look adorable seated in it; Lulu proves this last declaration below….

Hey Bumbo, perhaps you can include this beautiful baby on your website (wink, wink).   http://www.bumboseat.com/


Safety isn’t easy!

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.


Crib safety @ home

It is critical to all parents that we feel confident in the safety of our children’s cribs.  Below is a simple checklist to follow to make sure that your crib is as safe as possible. 

1)  Make sure that all hardware is functioning, isn’t loose or showing signs of stress or fracture.

2) Be sure that there are no gaps between the side of the mattress and the crib side, large enough to place your fist in with little resistance.  This may be an sign that your mattress is either too small or the crib side has loosened and created a hazardous gap (refer to item 1 above).

3) Try to place a soda can through any openings in the crib sides, no matter their shape.  Large openings present an entrapment and strangulation hazard to small children.

4) Look for any protruding components on the top surface of the crib, which can cause your children’s clothing to become entangled, leading to strangulation.  Any protruding part greater than 1/16″ is cause for concern.

5) Don’t place children in the crib when wearing loose-fitting clothing or shirts with hoods.  If a child stands, becomes entangled and either sits or falls, the clothing could lead to strangulation.

6) Choose playpens whose mesh openings are very small; preferably 1/4″ or smaller according to the CPSC.  The buttons on children’s clothing can pass through the mesh holes and entangle them, leading to possible strangulation.

7)  Don’t place stuffed animals, comforters, or thick bumper pads inside of the crib when occupied by children 12 months or younger.  They can suffocate on soft filled products while sleeping.  Only use a fitted crib sheet designed specifically for cribs.  All crib mattresses and the cribs interior dimensions are standard size, for the best fit.

8)  Use a sleeper in place of blankets, but if blankets are necessary, follow the CPSC’s recommendation, by tucking the blanket underneath of mattresses end and only pulling the blanket to the chest or midsection of the baby.

9)  Avoid cribs with decorative cutouts in the end panels.  Cutouts of certain shape and size can cause standing children to become entrapped and lead to strangulation.

10)  When a child is able to pull themselves to a standing position, always place the cribs mattress support in the lowest possible position, to prevent children from climbing or falling out.


A rash of crib recalls

Recently, there have been a number of crib recalls in the United States, because of faulty or mis-assembled hardware of the cribs drop side.  Children can roll into the space created by the faulty drop side and the mattress, become entrapped, suffocate or strangle. 

It is first important to understand the difference between a drop side and stationary side crib.  A drop side crib, has a side rail, that when pressed, lifted or otherwise manipulated, will lower for easy access to the child occupant.  A stationary crib has four sides that simply don’t move up or down. 

In drop side cribs, there are various designs which often rely on a metal or plastic (most times plastic) component attached to the side rail, to move up and down on a guide that is attached to the end panel of the crib.  Most of the recall’s resulted in failure of either one or both of the guide components.  It could have been that the crib side or the component was installed incorrectly, accurate assembly instructions were not provided or perhaps the guide simply wasn’t strong enough to withstand the normal up and down movement.  Plastic will at some point fail to function normally, become brittle and break, if under constant stress, because of poor design or improper assembly.

As a result of reported injuries and deaths, the ASTM committee which oversees the safety standard development of cribs has recently approved a revision that precludes (or prohibits) cribs with a drop side rail or related hardware from complying with the ASTM standard.  It is important to remember that ASTM is considered a “voluntary” standard for most consumer products, except for toys, which are mandated under federal law.  Cribs are not banned from sale in the US if they use a drop side, nor does the CPSC have any enforcement authority to prevent the import of such cribs.  However, most major retail chains in the US, including Babies ‘R’ Us, Wal-mart, Target and Sears/ Kmart require that all products, especially toys and juvenile products, meet applicable ASTM standards before being sold in their stores.

It is unlikely that cribs with drop sides will be sold at major retail stores in the near future.  This is a precautionary measure on the part of the crib industry, manufacturers and retailers, rather than waiting for another child to die before offering safety alternatives.  The recalls don’t mean that all cribs with a drop side rail are unsafe.  In fact, most cribs with these drop sides are safe, but parents should check to make sure that the hardware is tight, not fractured or showing signs of stress or damage and installed correctly; if not, you should stop using the crib immediately.  Most major manufacturers have assembly instructions available on their websites, so it is a good idea to check the assembly and current condition of your crib regularly.  If you do find damage to the assembly hardware, contact the manufacturer and explain the issue; they will jump at the opportunity to send you a kit to correct the issue.

Crib safety is one of the most important things in any household with small children and a manufacturer’s instructions and warnings for use should always be strictly adhered to.  I will be later adding information about crib safety on this site.  In the meantime, please check the CPSC website for current recalls http://www.cpsc.gov/, see if your crib is listed in any of the bulletins, then follow the instructions at the bottom of each notice.


I am a super safety dad

I am a quality & compliance engineer for a small, but incredible toy company, so I thought I would use this blog as an avenue for sharing some of what I know to help those who wouldn’t mind a little guidance or simply need help determining if a toy is ok for their children to play with, what makes a crib unsafe and anywhere in between.

I have worked in consumer product safety for many years now and it isn’t just a job to me; it is something I am passionate about and apply to my personal life.  I find myself wandering down toy aisles at the store or folding and unfolding strollers to see how well they work, even when I am not in the market for them. 

I am a new dad, with my first child, a 3 month old baby girl at home.  Although I work in toy safety and love kids, I was never sure if I would love having one of my own.  I know now that I was meant to be a dad!  Having this new little bundle of love in our home, makes what I do for a living even more important.  It gives what I do true meaning and purpose, so I thought I would share with anyone who wants to listen about what I do, how it may apply to the products in your home and what you may want to do to further protect your children.

There has been a ton of  buzz over the past few years regarding toy safety and much of it is misinterpreted by media outlets and consumer groups.  There have been and still are hazardous toys and children’s products in the market, but not all toys are unsafe.

I am hoping to post daily with examples, pictures, demonstrations, my favorite things, those super safe (and not so safe) products and the occasional shout out, so keep your eyes open.  Hopefully this information will help you determine what products in your home may not be good for your kids in various age groups, the benefits of paying a little extra (and sometimes less) and hopefully simplify all of the laws and regulations for children’s goods.


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