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Toy Safety Testing

Applied Technical Services, LLC recently attended Toy Fair 2010 in NYC. We were among the 1,100 exhibitors and over 25,000 attendees. We were present as an exhibitor, addressing concerns and detailing reasonable testing strategies with regards to Toy Safety Testing and CPSIA regulations for Children’s Toys & Childcare Articles.

While attending Toy Fair, we also attended the Safety – TSCP Legislative Update. The informative session addressed the primary concerns in Children’s Toys & Childcare Articles, with the key focus for 2010 being on the following areas: choking hazards, magnets, sharp points, strangulation hazards, and toxic chemicals (i.e. lead, cadmium, antimony, etc.).

In our prior newsletter, we touched upon toxic chemicals, highlighting the risks of cadmium. We would like to dedicate this newsletter to the other four items of primary concern as stated in the Legislative Update:

  • Choking Hazards
  • Magnets
  • Sharp Points
  • Strangulation Hazards

As a CPSC accredited full service testing lab, we provide our clients with certified compliance in accordance with ASTM and CPSC regulations. We have the capability to assist our customers with testing their items to the applicable toy safety standards. In speaking with our customers, we find that additional assistance with regards to physical and mechanical hazards is needed, and we can provide the necessary guidance to ensure that your products are safe for your customers. The current details and requirements for the CPSC focus area are as follows:

  • Fabrics Exemptions are only for fabrics made entirely or in combinations of acrylic, modacrylic, nylon, olefin, polyester, or wool.
  • Children’s Sleepwear – this applies to children’s sleepwear which is regulated in 16 CFR 1615 and 1616.

In researching labs to test and certify your items, it is important to work with a lab that is accredited to perform flammability testing to ASTM F963-08. Additionally, you may want to ensure that they have the ability to test to European flammability requirements for toys, which is EN 71 Part 2.

Choking Hazards:

  • What is involved? This is also referred to as “small part testing”. Testing is conducted on the item to see if the item is considered a small part, or if during normal play, small parts may be created or developed.
  • Who is required to test? Your item shall be tested for small parts if it is age-graded for 3 years & under or if the toy is attractive to younger children. It is not sufficient enough to simply label your item to circumvent this testing requirement. If the toy has “play value” for children younger than 3 years of age, then it needs to be tested for small parts. The CPSC sets forth guidelines for proper age grading of toys.
  • Label Requirements: If the item contains small parts, then it shall be labeled with the appropriate warning labels.

Strangulation Hazards:

  • What is involved? We test the cords, strings, and elastic bands attached to toys and children’s consumer goods to determine if they present themselves as potential strangulation hazard.
  • Who is required to test? If a loop of sufficient size can be made out of the cords, strings, and elastic bands attached to toys, then it must be checked to qualify it as a strangulation hazard. Some examples are: self retracting pull cords, strings on pull toys, strings and lines for flying devices, strings on hooded sweatshirts, and cords on storage bags.
  • Design change: Required for those items that show to be a potential strangulation hazard (if marketed for children under 18 months or 36 months – depending on the toy type).

Magnet Hazards:

  • What is involved? New test requirements exist with the approval of ASTM F963-08 with regards to magnets in toys. The size restriction requirement for small parts is also a requirement for any magnets. This may be critical as rare earth magnets have a high flux density (magnetic strength). This may cause the magnets to adhere more firmly to metal surfaces and other magnets and ultimately may overcome the adhesive strength or compromise the material holding the magnet in the toy. Magnets with a flux density greater than 50 is considered hazardous and can become fatal when more than one is ingested, as it may cause binding in the gastrointestinal tract of children.
  • Who is required to test? Any toy with magnets in its design that are intended for children under 14 years of age needs to undergo the required testing; this even applies to magnets that are embedded in the toy.
  • Label Requirements: If a toy is labeled for “Under 14 years” and contains magnets, then it shall undergo the “Magnet Test” to determine if it contains hazardous magnets.

Sharp Points/Sharp Edges

  • What is involved? Testing is conducted to determine if sharp points or sharp edges exist or may be created during normal play.
  • Who is required to test? Toys that are marketed or labeled for children under 8 years of age.
  • Label Requirements: If it is determined that the item has or can develop sharp points or sharp edges, then it should be marketed for 8 & older, or a re-design may be in order.

Hopefully this information provides you with clarification concerning testing in these four focus areas with regards to the Mechanical/Physical Hazards of toys. Keep in mind that we offer a variety of testing beyond the areas mentioned above.

Accredited Lab Services

We are an American Association for Laboratory Accreditation (A2LA) accredited lab with the capability to test not only the above outlined areas, but a wide range of other children’s consumer goods. For example we have the ability to test bunk beds, full size and non-full size cribs, baby walkers & bouncers, balls & marbles, dive sticks, rattles, pacifiers, sound producing toys, squeeze toys, stuffed toys, pom-poms, projectile toys, and determine proper age grading.

As always, it is best to test your item when you are in the design phase or to test prototypes. This provides assurance that your item is not putting a child at risk and helps avoid recalls. As a CPSC accredited lab partner, we hope to be a part of your “reasonable testing program” to ensure full compliance and safety.

Compliance Commentary

Wisconsin became the third US state, after Minnesota and Connecticut, to introduce legislation restricting the use of Bisphenol A (BPA) in baby bottles and “sippy” cups. Senate Bill 271, the BPA-Free Kids Act, bans the manufacture or sale of new baby bottles or cups for children aged three years or younger that contain BPA. Similar legislation is being considered by the state of Pennsylvania, which in January held hearings on House Bill 221. This legislation would prohibit the manufacture, sale or distribution of certain child care articles containing BPA.

ATS Updates

  • Authorized by Toy Industry Association to serve as an approved and accredited testing lab for the Toy Industry Association’s (TIA) Toy Safety Certification Program (TSCP).
  • Membership acceptance to American Home Furnishings Alliance. We are a listed lab with AHFA to assist those with testing in the furniture industry. A special thanks to our customers that referred us.
  • Recent A2LA Audit – Scope Expansion to include relevant items in ASTM F963.

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