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ICPHSOICPHSO

February, 2010February, 2010

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Toy Safety Certification Program SM

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Development of the TSCPDevelopment of the TSCP

August 2007 – TIA engaged ANSI to coordinate a public-private partnership to develop conformity assessment guidance

February 2008 – Resulting guidance published for public comment

May 2008 – Program approved by TIA Board but still a work in progress

August 2008 – U.S. federal CPSIA signed into law

February 2009 – Phased in TSCP launch begins (GCCs)

March 17, 2009 – Board unanimously reaffirms moving forward

October 1, 2009 – Full launch for participants

November 18, 2009 – First TSCP certified toys

Ongoing – Stakeholder outreach, refining requirements, minimizing testing and auditing redundancies, CPSIA modifications

2010 – Addition of TSCP Mark and consumer outreach

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Improve toy safety by providing a sustainable conformity assessment system to offer reasonable verification that toys meet applicable mandatory U.S. toy safety standards in an efficient and cost-effective way

Help facilitate the U.S. toy industry and its suppliers to meet requirements of the new Consumer Product Safety Improvement Act (CPSIA)

Enhance the confidence of regulators, toy companies, retailers and consumers

TSCP is the toy industry’s solution to fulfill the

requirements of federal law in an effective,

efficient and low-cost manner

Objectives of TSCP

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TSCP Participants and Process

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TSCP FOCUS

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Program Requirements

Applicants are responsible for:

1. Hazard and/or risk assessment for toy design

2. Audit body (verification of ISO Factory process control audits by an independent 9001)

3. Production sample testing by an accredited laboratory to validate that the factory is capable of producing toys that meet U.S. safety standards

Will be verified by ANSI-accredited Certification Bodies

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Why perform Hazard Why perform Hazard Analysis?Analysis?

Standards cannot address all Standards cannot address all hazardshazards

Recommended good design practiceRecommended good design practice Product innovationProduct innovation Consumer innovationConsumer innovation Increasing amount of consumer Increasing amount of consumer

assemblyassembly

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Hazard Analysis will Hazard Analysis will prevent all recallsprevent all recalls

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TheThe Manitoba Manitoba StudyStudy

Based on 2007/2008 research Based on 2007/2008 research from University of Manitobafrom University of Manitoba

Study concluded 61% of Study concluded 61% of recalls due to designrecalls due to design

17 % due to manufacturing17 % due to manufacturing

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Defect ExamplesDefect ExamplesDesignDesign Openings Openings

causing causing entrapmententrapment

Strings Strings causing causing entanglemententanglement

Broken partsBroken parts

ManufacturingManufacturing LeadLead Faulty Faulty

assemblyassembly Substandard Substandard

partsparts

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Who performs hazard Who performs hazard analysisanalysis

Not your GrandmotherNot your Grandmother

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Not the guy in the next Not the guy in the next officeoffice

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Qualifications for Qualifications for performing hazard analysisperforming hazard analysis

Appropriate background – engineer, Appropriate background – engineer, technician, human factors expert, technician, human factors expert, industrial design, consumer service, industrial design, consumer service, doctor, biomedical expert...doctor, biomedical expert...

Experience – familiarity with toys, Experience – familiarity with toys, recalls, safety issues specific to recalls, safety issues specific to childrenchildren

Product designer must not be the Product designer must not be the sole evaluatorsole evaluator

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QualificationsQualifications

Dependant on type of productDependant on type of product More complex product requires More complex product requires

more technical background, more more technical background, more related experiencerelated experience

Factors to consider in determining Factors to consider in determining acceptable qualificationsacceptable qualifications Play patternPlay pattern Complexity of productComplexity of product Previous experience of companyPrevious experience of company

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Qualifications for Qualifications for performing a hazard performing a hazard

analysis differ for these two analysis differ for these two products:products:

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Each Unique Product Each Unique Product requires Hazard Analysisrequires Hazard Analysis

New productsNew products Refresh of existing product involving Refresh of existing product involving

new parts, revised design.new parts, revised design.

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New productsNew products

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Refreshes involving new Refreshes involving new moldsmolds

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Refreshes involving revised Refreshes involving revised designdesign

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Examples of products that Examples of products that are not unique, can are not unique, can

reference existing Hazard reference existing Hazard AnalysisAnalysis

Color or fashion variationsColor or fashion variations New combinations of existing New combinations of existing

componentscomponents

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Color variationsColor variations

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Fashion variationsFashion variations

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Hazard AnalysisHazard Analysis

It is not a compliance reviewIt is not a compliance review Intended to identify issues above Intended to identify issues above

and beyond the scope of compliance and beyond the scope of compliance

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Hazard AnalysisHazard Analysis

Common issues discussed:Common issues discussed: Foreseeable use and misuseForeseeable use and misuse Misassembly of the productMisassembly of the product Pinch pointsPinch points Retention of small partsRetention of small parts Projection/fall-on hazardsProjection/fall-on hazards

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Why submit an Why submit an attestation?attestation?

Hard to assess the Hard to assess the goodness of a Hazard goodness of a Hazard AnalysisAnalysis

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