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Safer Toys, By Design

Building safety into toys from their start

By Susan DeRagon and Jill Hurley -- Gifts and Dec, 1/1/2010 12:00:00 AM

While the Consumer Product Safety Improvement Act was created to improve product safety, toys can be in compliance with regulations and still harm, or have the potential to harm, children. The Consumer Product Safety Commission (CPSC) states that regulations are the minimum requirements; in the case of toys, more must be done to ensure safety.

A design hazard and human factors analysis can help manufacturers integrate safety into toy design. While there are various ways to assess and design for safety, all include the basic human factors precept of determining what, if any, risks are inherent in the foreseeable use and/or foreseeable misuse of the product, and then addressing those risks.

Age concerns

The first step in a human factors analysis of toys is to determine age appropriateness. This is done through a process of studying and analyzing the physical, perceptual, and cognitive ability of children, as well as static and functional anthropometry. Resources for age determination include, but are not limited to, CPSC's Age Determination Guidelines; ASTM F963-08 Annex A1; and CHILDATA: The Handbook of Child Measurements and Capabilities.

Once appropriate age is determined, the next step is to identify potential hazards. Resources include U.S. and international standards, both mandatory and voluntary, a review of incident data on similar product, use of a hazard checklist, conducting a behavioral task analysis and/or performing your own research.

International standards provide insight into additional factors important to assessing safety. Other countries have standards that are more stringent than, or are not included in, the U.S. regulations. For example, Canada's Hazardous Products (Toys) Regulations C.R.C., c. 931, includes a dead weight test for hard attachments on stuffed toys such as plastic eyes and noses, and also applies a weight of 1 pound to determine if a component is considered a hazardous small part. Voluntary or industry consensus standards, such as Underwriters Laboratories, include requirements that may not be mandatory but can help address the safety of a product.

Incident data review, which is based on injuries that occurred during use and/or misuse of similar product, can provide a wealth of valuable information in assessing potential risks. Sometimes the product was used as intended but resulted in an unforeseen injury; other times the product may have been used in ways that were unintended, or by an unintended user (that is, someone older or younger than the appropriate age). The CPSC has a number of different databases that provide injury and fatality information, available through Freedom of Information Act (FOIA) requests. These include:

National Electronic Injury Surveillance System (NEISS). This database represents injuries reported to participating hospital Emergency Rooms nationwide. NEISS offers a description of what happened along with age, gender, part of the body injured, and diagnosis. This information can be found online at www.cpsc.gov/library/neiss.html.
Injury and Potential Injury (IPII). The "Reported Incidents" contained in this database are obtained when people contact the CPSC to report a dangerous product, or through media reports.
In-Depth Investigation reports. IDIs are conducted as a follow-up investigation to Reported Incidents or NEISS reports.
Fatality reports. The CPSC purchases Death Certificate reports from all 50 states, and also receives fatality reports from Medical Examiners and Coroner's offices (MECAPS).

Additional data sources include professional journals such as Human Factors & Ergonomic Society, Journal of American Medical Association, and Pediatrics, as well as National Institute of Health (NIH) publications, PubMed (www.pubmed.gov), and both CPSC and international recall sites.

The hazard checklist is a primary feature of ISO Guide 50, Guidelines for Child Safety. At STR, we have developed our own Hazard Pattern Checklist for toys based on the types of hazards found in the incident data discussed above, and with a severity classification for each type of hazard. A checklist provides a reliable methodology for evaluating the product and every potential hazard. A hazard checklist is not static—incident data must be monitored to identify emerging hazards and to update the checklist.

A behavioral task analysis assesses the potential hazards associated with product use, including product assembly, use, cleaning, troubleshooting, disassembly and storage. The analysis considers how the product is intended to be used, any other possible uses of the product, any instructions or artwork included with the product and where the product is used.

Lastly, independent research, such as behavioral observations of children using the toy, focus groups with parents, or survey research with parents, can help assesses potential concerns with the toy design. STR has a relationship with a local child care facility, for example, which is an invaluable resource for determining children's interests in certain toys and their abilities to use different features.

Once the potential design hazards have been identified, and the risks of each hazard assessed, the toy manufacturer must quantify the hazard(s). Helpful tools include Failure Mode and Effect Analysis methodology and Europe's Risk Assessment Guidelines, which incorporate risk level ratings based in part on the severity of the potential injury and the likelihood of its occurrence.

The best solution for hazard prevention is to design the hazard out of the product. If the potential hazard cannot be designed out, then there should be a guard or shield against the hazard. This must be done effectively and consistently. The last—and least effective—defense is to warn against the hazard.

While it is not possible to predict all the ways in which a child may creatively use a product, a design hazard and human factors analysis can help to reduce potential hazards and ensure that the product not only complies with all regulatory requirements, but that is also safe.

Author Information

Susan DeRagon is Associate Director of Toy and Premiums and Jill Hurley is Project Leader of the Human Factors Department at Enfield, CT-based Specialized Technology Resources (STR), which provides testing, audit, accreditation, and responsible sourcing services for the toy and premium industry. They can be reached at susan.deragon@STRQuality.com and jill.hurley@STRQuality.com, respectively.

Safety Spotlight: Recalled Products

EduShape, Deer Park, N.Y., recalled 40 sets of Snap Beads (pictured) because the tip of the snap bead peg could break off under repetitive pressure, posing a choking hazard to small children.
Simon & Schuster, New York, recalled nearly 142,000 Monday the Bullfrog books-plus sets because the plastic eye on the set's plush frog could detach, posing a choking hazard to young children. The set's board book has ISBN number 10: 1416912312. The code 13: 9781416912316 is printed in the mouth of the frog.
Evenflo, Miamisburg, Ohio, recalled 66,000 ExerSaucer 1-2-3 Tea for Me Activity Learning Centers sold in the U.S. (and 13,660 sold in Canada) because the candle flame attached to the top of a cake-shaped toy on the activity center could detach, posing a choking hazard to young children. Models included in the recall are 6161834 and 6161920.
Variety Wholesalers, Henderson, N.C., recalled 700 of its Super Rigs playsets because the toy trucks had surface coatings that contained high levels of lead. The recalled trucks have bar code 6-98567-67007-3 on their packaging and the code 45TNGO9 engraved on their trailers.
Maclaren USA, South Norwalk, Conn., recalled approximately 1 million strollers sold between 1999 and November 2009 because they posed a fingertip amputation and laceration hazard due to the product's hinge mechanism. The recall involved all single and double umbrella strollers with "Maclaren" printed on them.
Three Sisters Toys, Neptune Beach, Fla., recalled 20 Yayita Baby Hammocks because they pose a fall and strangulation hazard. The recalled design is model number YABN-1.

Safety Spotlight: Recalled Products

EduShape, Deer Park, N.Y., recalled 40 sets of Snap Beads (pictured) because the tip of the snap bead peg could break off under repetitive pressure, posing a choking hazard to small children.
Simon & Schuster, New York, recalled nearly 142,000 Monday the Bullfrog books-plus sets because the plastic eye on the set's plush frog could detach, posing a choking hazard to young children. The set's board book has ISBN number 10: 1416912312. The code 13: 9781416912316 is printed in the mouth of the frog.
Evenflo, Miamisburg, Ohio, recalled 66,000 ExerSaucer 1-2-3 Tea for Me Activity Learning Centers sold in the U.S. (and 13,660 sold in Canada) because the candle flame attached to the top of a cake-shaped toy on the activity center could detach, posing a choking hazard to young children. Models included in the recall are 6161834 and 6161920.
Variety Wholesalers, Henderson, N.C., recalled 700 of its Super Rigs playsets because the toy trucks had surface coatings that contained high levels of lead. The recalled trucks have bar code 6-98567-67007-3 on their packaging and the code 45TNGO9 engraved on their trailers.
Maclaren USA, South Norwalk, Conn., recalled approximately 1 million strollers sold between 1999 and November 2009 because they posed a fingertip amputation and laceration hazard due to the product's hinge mechanism. The recall involved all single and double umbrella strollers with "Maclaren" printed on them.
Three Sisters Toys, Neptune Beach, Fla., recalled 20 Yayita Baby Hammocks because they pose a fall and strangulation hazard. The recalled design is model number YABN-1.

Safety Spotlight: Recalled Products

EduShape, Deer Park, N.Y., recalled 40 sets of Snap Beads (pictured) because the tip of the snap bead peg could break off under repetitive pressure, posing a choking hazard to small children.
Simon & Schuster, New York, recalled nearly 142,000 Monday the Bullfrog books-plus sets because the plastic eye on the set's plush frog could detach, posing a choking hazard to young children. The set's board book has ISBN number 10: 1416912312. The code 13: 9781416912316 is printed in the mouth of the frog.
Evenflo, Miamisburg, Ohio, recalled 66,000 ExerSaucer 1-2-3 Tea for Me Activity Learning Centers sold in the U.S. (and 13,660 sold in Canada) because the candle flame attached to the top of a cake-shaped toy on the activity center could detach, posing a choking hazard to young children. Models included in the recall are 6161834 and 6161920.
Variety Wholesalers, Henderson, N.C., recalled 700 of its Super Rigs playsets because the toy trucks had surface coatings that contained high levels of lead. The recalled trucks have bar code 6-98567-67007-3 on their packaging and the code 45TNGO9 engraved on their trailers.
Maclaren USA, South Norwalk, Conn., recalled approximately 1 million strollers sold between 1999 and November 2009 because they posed a fingertip amputation and laceration hazard due to the product's hinge mechanism. The recall involved all single and double umbrella strollers with "Maclaren" printed on them.
Three Sisters Toys, Neptune Beach, Fla., recalled 20 Yayita Baby Hammocks because they pose a fall and strangulation hazard. The recalled design is model number YABN-1.

Safety Spotlight: Recalled Products

EduShape, Deer Park, N.Y., recalled 40 sets of Snap Beads (pictured) because the tip of the snap bead peg could break off under repetitive pressure, posing a choking hazard to small children.
Simon & Schuster, New York, recalled nearly 142,000 Monday the Bullfrog books-plus sets because the plastic eye on the set's plush frog could detach, posing a choking hazard to young children. The set's board book has ISBN number 10: 1416912312. The code 13: 9781416912316 is printed in the mouth of the frog.
Evenflo, Miamisburg, Ohio, recalled 66,000 ExerSaucer 1-2-3 Tea for Me Activity Learning Centers sold in the U.S. (and 13,660 sold in Canada) because the candle flame attached to the top of a cake-shaped toy on the activity center could detach, posing a choking hazard to young children. Models included in the recall are 6161834 and 6161920.
Variety Wholesalers, Henderson, N.C., recalled 700 of its Super Rigs playsets because the toy trucks had surface coatings that contained high levels of lead. The recalled trucks have bar code 6-98567-67007-3 on their packaging and the code 45TNGO9 engraved on their trailers.
Maclaren USA, South Norwalk, Conn., recalled approximately 1 million strollers sold between 1999 and November 2009 because they posed a fingertip amputation and laceration hazard due to the product's hinge mechanism. The recall involved all single and double umbrella strollers with "Maclaren" printed on them.
Three Sisters Toys, Neptune Beach, Fla., recalled 20 Yayita Baby Hammocks because they pose a fall and strangulation hazard. The recalled design is model number YABN-1.

Safety Spotlight: Recalled Products

EduShape, Deer Park, N.Y., recalled 40 sets of Snap Beads (pictured) because the tip of the snap bead peg could break off under repetitive pressure, posing a choking hazard to small children.
Simon & Schuster, New York, recalled nearly 142,000 Monday the Bullfrog books-plus sets because the plastic eye on the set's plush frog could detach, posing a choking hazard to young children. The set's board book has ISBN number 10: 1416912312. The code 13: 9781416912316 is printed in the mouth of the frog.
Evenflo, Miamisburg, Ohio, recalled 66,000 ExerSaucer 1-2-3 Tea for Me Activity Learning Centers sold in the U.S. (and 13,660 sold in Canada) because the candle flame attached to the top of a cake-shaped toy on the activity center could detach, posing a choking hazard to young children. Models included in the recall are 6161834 and 6161920.
Variety Wholesalers, Henderson, N.C., recalled 700 of its Super Rigs playsets because the toy trucks had surface coatings that contained high levels of lead. The recalled trucks have bar code 6-98567-67007-3 on their packaging and the code 45TNGO9 engraved on their trailers.
Maclaren USA, South Norwalk, Conn., recalled approximately 1 million strollers sold between 1999 and November 2009 because they posed a fingertip amputation and laceration hazard due to the product's hinge mechanism. The recall involved all single and double umbrella strollers with "Maclaren" printed on them.
Three Sisters Toys, Neptune Beach, Fla., recalled 20 Yayita Baby Hammocks because they pose a fall and strangulation hazard. The recalled design is model number YABN-1.

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