Toxic Toy Tactics: Why Testing Makes Sense

Ensuring the safety of children’s products is top of mind for consumers, toy manufacturers, and regulators alike. Recently, the issue has become especially important for one particular segment of the toy manufacturing industry: small business. NSF International’s toy safety expert Ashlee Breitner explains why it’s prudent for manufacturers not to balk at requirements to test their products. Read the full article on Portfolio.com.

ABC Kids Expo

Come check out NSF at the ABC Kids Expo at Booth #5037.

G.C.C. & The Reasonable Testing Program – Recordkeeping: Part 5 of a 5 part series

The fifth element of a reasonable testing program involves maintaining accurate and thorough records that document the different aspects of the reasonable testing program. These documents must be maintained in English at a location within the United States for a period of no less than five (5) years from when the product is no longer produced.  The documents required to be created and maintained are:

• Product Specifications (must be unique for each product and manufacturing site):

1. • Detailed Bill of Materials
   • Visual product identification
   • Unique product SKU
   • Information about their products consumer complaints, warranty returns, insurance claims or payments, product liability lawsuits, reports of production problems, product testing or other critical analyses of products, and the like, if applicable.

• Applicable CPSC Regulations – A complete and thorough list of all applicable laws, regulations, standards and safety rules which apply to the product.

• Certification Testing Outline – A complete list of the individual tests performed on the consumer product.  This outline must contain both the name of the test and the legislation/regulation requiring the testing.  This testing outline should also detail the planned testing frequency and number of samples tested.

• Undue Influence Safeguards – The manufacturer’s policies relating to eliminating undue influence on testing and certification results.

• Testing Reports for all testing conducted on the consumer product – Copies of the actual test reports from all testing completed.

• General Conformity Certificate – The certificate that identifies the product, the manufacture and record keeping information, and all of the applicable CPSC regulations to which the product complies.

• Remedial Action Plan – The plan for investigating and correcting any failing test results.

G.C.C. & The Reasonable Testing Program – Remedial Action Plan : Part 4 of a 5 part series

The fourth element of a reasonable testing program is a remedial action plan.  A remedial action plan would be utilized whenever samples of the consumer product are tested and yield unacceptable or failing test results with respect to any CPSC enforced specification, rule, law or standard.  The remedial action plan should clearly identify what steps should be taken by the manufacturer to investigate and remedy failure.  Remedial action must be taken after any failing test result.

Remedial action can include the following actions:

• Change of manufacturing process or equipment
• Re-working of the products design and/or materials
• Other actions deemed appropriate by the manufacturer to ensure compliance

If the corrective action steps taken involve material changes, design changes, manufacturing process changes, supplier changes, or any other change that differentiates a new/updated consumer product from the failing consumer product, a new product specification must be developed for that product.

Please check back soon for part 5 of the 5 part Reasonable Testing Program Blog Series

G.C.C. & The Reasonable Testing Program – Production Testing Plan: Part 3 of a 5 part series

The third element of a reasonable testing program is creating and documenting a production testing plan.  The production testing plan should clearly describe the tests that are being performed, the frequency of testing, and the number of samples that are tested at each interval. Like other elements of a reasonable testing program, the goal of a production testing plan is to provide a high degree of assurance that all products are safe and comply with applicable standards and regulations.

At the current time there are no published specifications that mandate the frequency of testing, other than that a product needs to be re-tested whenever there a change in materials, design, manufacturing process, suppliers of product materials or manufacturing location.  A Guidance Document from the CPSC encourages verification testing at least once a year.

A Document titled “Guidance Document: Testing and Certification Requirements under the Consumer Product Safety Improvement Act of 2008” provides assistance in answering questions and defining aspects of the Reasonable Testing Program.  The document is available at: CPSIA Guidance Document.

Please check back soon for part 4 of the 5 part Reasonable Testing Program Blog Series

G.C.C. & The Reasonable Testing Program – Certification Tests : Part 2 of a 5 part series

The second element of the reasonable testing program is certification testing.  Manufacturers are required to test their products to prove that they meet all applicable CPSC regulations.  Samples tested for compliance should be identical in both material and design to the manufacturer’s final product.  Sufficient certification testing must be done to demonstrate that products will pass, and continue to pass, testing to applicable standards with a high degree of assurance.  Manufacturers of non-children’s products can elect to test with either a third-party lab or conduct the testing on their own, while manufacturers of children’s products must have products tested by an approved third party conformity assessment body.

It is important to note that additional testing may be required if there are changes in the product’s design, manufacturing process, sourcing of component parts, or materials.

Please check back soon for part 3 of the 5 part Reasonable Testing Program Blog Series

G.C.C. & The Reasonable Testing Program – Product Specifications: Part 1 of a 5 part series

The Consumer Product Safety Commission (CPSC) requires importers and domestic manufacturers of consumer products in the U.S. to provide a General Conformity Certificate (GCC) for each product they sell. The certificate must accompany products throughout their journey from manufacturer to the point of final sale, and be provided to the consumer upon request.  For consumer products not intended for children, the GCC represents a self-certification by the manufacturer or importer that the product complies with all applicable rules, bans, standards or regulations based on a reasonable testing program. The reasonable testing program for consumer products ensures that products meet mandatory CPSC standards with a high degree of assurance.

For children’s products, the GCC is based on third party testing, by an approved lab, for compliance with all applicable rules, bans, standards or regulations.  Though it is not required yet, development and implementation of the reasonable testing program will help importers and manufacturers ensure compliance and continued testing of children’s products to the latest standards, laws and regulations.  The proactive step of establishing and implementing a reasonable testing program is integral in ensuring the safety of the products children are exposed to.  This is the first of a series of five blogs that will take an in-depth look at the establishment of a reasonable testing program.

There are fundamental elements to a “reasonable testing program” as defined by the CPSC.  These elements are:

1. Product specifications
2. Certification tests
3. Production testing plan
4. Remedial action plan
5. Reasonable Testing Program documentation

The CPSC’s explanation of “Product specifications” is documentation which “describes the consumer product and lists the safety rules, standards, etc., with which the product must comply”.   This explanation gives direction, but what should be included?

A thorough product specification would include, but is not limited to:

• A written description of the product including functionality, intended use, age grading and any special product notes
• A bill of materials for the product and sub-assemblies, as applicable, including:

• All trade names and common names of materials used
• Technical drawings of the product
• A list of all known, applicable laws, regulations, standards and safety rules which primarily come from:
  • ASTM F-963 of 2008 – “Standard Consumer Safety Specification for Toy Safety”
  • CPSIA – “Consumer Product Safety Improvement Act of 2008”
  • Additional standards and regulations may apply.  Required testing for specific products will vary depending on the product and the performance characteristics being tested.

It is important to note that product specs are necessary for every different product SKU, as well as for similar products manufactured at different manufacturing facilities.  Updated product specifications are required when there has been a material change in the product or a change in the manufacturing process, which includes changes in component sourcing.