The Next Step in Toy Safety
Risk assessment gains greater prominence
By Malcolm Denniss -- Gifts and Dec, 9/1/2009 12:00:00 AM
Now that the initial hurdles of Consumer Product Safety Improvement Act (CPSIA) compliance have been more or less surmounted, the next big thing in toy safety is a voluntary but potentially important addition to your safety testing regimen: risk assessment.
"Risk assessment" is a hazard and risk analysis typically completed in the early engineering stages of new toy design to flag any problems before the product starts rolling off the line. For years, it has been used in other product areas as a means of weighing the threat of harm to the consumer. It's now emerging as a topic of discussion in the toy industry because of two new initiatives—one in the U.S., the other in Europe.
In the U.S., risk assessment is one of the pillar requirements of the new Toy Safety Certification Program (TSCP) developed by the Toy Industry Association and the American National Standards Institute. Inspired by a need to restore public confidence in the safety of the toys on the market, the program will enable toys that undergo a successful risk assessment, factory process control audit and production sample testing to carry a special safety mark indicating that they have passed rigorous safety screening.
In Europe, risk assessment is a requirement of the recently updated European Toy Safety Directive that is expected to go into effect in 2012. It says that manufacturers or private labellers must use a risk assessment process to identify and resolve potential hazards in a given toy before it is put on the market there.
An ounce of prevention
A risk assessment for toys involves taking an in-depth look at a product's design to identify potential safety hazards and/or design flaws that could lead to injury. The assessment team must look not only for potential violations of mandated safety standards but other potential design dangers that would be missed if the toy were evaluated only against existing regulations.
A risk assessment is best performed by a team consisting of in-house and/or third-party individuals with design, engineering, quality assurance and safety expertise, with a trained risk assessment professional overseeing the process. Toys should be evaluated using ISO/IEC Guide 50 and/or 51, the Handbook for Manufacturing Safer Consumer Products (CPSC, July 2006), Risk Assessment Guidelines for Non-Food Consumer Products from the European Commission, or other similar standards. Accident and injury data from the online Consumer Product Safety Commission database should also be considered, not only for the product at hand but for the particular hazards that the team identifies as being possible or likely.
Finally, you may find valuable information in the customer complaints you may have received from product returns on similar items, or on toys with dangers comparable to those the team may be anticipating. As discussed in "Returning the Favor," a column that appeared in this publication in March, toy returns can serve as a kind of litmus test for manufacturing flaws, safety concerns and toy usability.
The fringe benefits
If this sounds like just another safety burden, there are several silver linings to this particular cloud. First, of course, a risk assessment is a crucial step to get the TSCP safety mark or, eventually, to sell your goods in Europe. Second, it can help zero in on problems that may lead to injuries or recalls to allow redesign or corrective action before disaster strikes.
Finally, if your risk assessment is performed when a toy is still just a drawing on paper, it can save substantial sums of money. You won't incur costs for tooling that needs to be changed or remade due to a later risk assessment requiring design changes. Nor will you spend money producing inventory that turns out to be unusable, pay regulatory fines associated with safety troubles that could have been avoided, or incur expenses from the actual recall of products.
In that light, and when you consider that some studies estimate that 50 to 70 percent of all toy recalls involve design problems that are not covered by industry or federal safety regulations, the question becomes not "Why should I do risk assessments?" but "Why shouldn't I?"
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