Susan DeRagon

TIA’s Toy Safety Certification Program® is Open for Business

On October 1, the Toy Industry Association (TIA) launched its new Toy Safety Certification Program® (TSCP) to industry participants.  This means that toy companies can apply for certification of their product, and TSCP-certified toys will begin to appear on store shelves next year.

The launch comes just over two years since the first meeting of toy industry stakeholders was held, in August 2007, to address the increased number of toy recalls during the Spring and Summer of 2007 (the so-called Year of the Recall) and to address the corresponding decrease in consumer confidence in the safety of toys. 

My May 11^th blog provided an overview of the TSCP, and the final program maintains those three important pillars to product safety – hazard and risk assessment of the toy design, factory manufacturing process controls, and finished product testing.

The finished product testing provides for compliance with the Consumer Product Safety Improvement Act (CPSIA).  CPSIA requires that all toys sold in the US meet applicable toy safety standards, that testing be performed by an accredited laboratory, and that companies certify that their toys have been tested to confirm compliance.  This is a Federal mandatory requirement, and TSCP compliance means CPSIA testing compliance.  The TSCP encompasses the framework for a reasonable test program, with details such as testing sample size and testing frequency, along with random sample selection procedures. 

But safety cannot be tested into a product, and this is why the other two pillars of the TSCP are as important as CPSIA compliance in improving the safety of toys.  CPSC Chairman Inez Tenenbaum, in her remarks at the 3^rd Biennial Consumer Product Safety Summit in Beijing last week, said “The best way to protect families is to build safety into products during design and manufacturing.” 

Hazard and risk assessment of the toy design is not currently a mandatory US regulatory requirement, although the CPSC strongly encourages a design review for any consumer product per their 2006 “Handbook for Manufacturing Safer Consumer Products”.  In addition, risk assessments have global recognition as an important step in developing safer toys and are a requirement of the recently updated European Toy Safety Directive.  The updated Directive requires that manufacturers use a risk assessment process to identify and resolve potential hazards in a given toy before it is put on the market.  Many of the toys recalled in 2007 presented safety hazards related to the design of the toy rather than regulatory non-compliance.  TSCP provides guidelines that can be used to perform a risk assessment internally if the toy manufacturer has qualified personnel, or it can be performed by outside experts.  We work with companies in both ways – training their staff on how to perform a hazard and risk assessment, or performing the assessment ourselves, depending on each company’s needs.

Even with the most robust and safe design, however, if the factory cannot consistently produce the toy in a compliant manner, there will likely be safety issues.  The lead in paint recalls are examples of poor manufacturing practices.  As a first step, the TSCP provides incentives for toy manufacturers to use only those factories with ISO 9001 certification.  The ISO 9001 certification requires that factory have a documented management system in place that addresses, among other things, statistically-based controls on incoming materials and procedures to verify that regulatory requirements are met.  The incentive in TSCP to using ISO 9001 factories, aside from more confidence in the production, is reduced frequency of third party testing required to obtain product certification.  As with design reviews, the CPSC has provided general good manufacturing guidelines to industry in their “Handbook for Manufacturing Safer Consumer Products”, which was first published back in 1975.  In it, they state “The essence of production is to assure that the final product retains intact all of the safety characteristics designed into it.”  While not codified as regulatory requirements, the CPSC clearly expects companies to take appropriate steps to ensure safe designs and robust manufacturing controls, and these are all part of the TSCP.

The TSCP is an open architecture program, and any entity meeting the requirements of TSCP can participate.  It is expected that, in the near future, certain retailers may require that only TSCP-certified toys be sold in their stores.  Once certified products are available on store shelves, TIA will initiate a major public launch of TSCP to educate consumers on what the mark means and why they should look for it.  The end result is expected to be safer toys and increased consumer confidence.

Posted by Susan DeRagon on October 28, 2009 | Comments (0)