Susan DeRagon

TIA's Toy Safety Certification Program

I’ll be in New York this week for the TIA’s Toy Safety Certification Program (TSCP) Work Group and Technical Committee meetings, as we work towards launching this program.  For those not familiar with the TSCP, it – like the CPSIA – is a direct result of the extensive toy recalls throughout 2007.  The TIA started work on this program in August 2007 - together with small and large toy manufacturers, retailers, industry organizations, and "The Labs" - to better ensure the safety of toys and to restore consumer confidence.  
 

What I really like about the TSCP is that it does not focus solely on finished product testing but also addresses the root causes of many of the recalls – design issues and manufacturing process controls.

From a design standpoint, a product is not necessarily safe just because it complies with applicable regulations.  The regulations are minimum requirements, and product must be evaluated for other potential hazards.  The 2007 recalls included several toys with small magnets that detached and were ingested by children – these are design issues.  While these toys may have complied with the regulations, they presented serious hazards during use.

The TSCP requires that a hazard analysis and/or risk assessment be performed on all toys certified under this program.  The manufacturer can perform this assessment internally or use a third party such as STR (we have a team specializing in design hazard evaluations of toys).  The goal is to identify and address potential design hazards prior to manufacture and distribution of the toy.

Many of the 2007 recalls were because of excess lead in paint, in large part due to insufficient manufacturing process controls.  These toys may have been tested early in production and found to comply with all lead requirements.  Yet during production, new batches of paint may have been used that contained excess lead.  Or the paint may have been stored in containers that previously held leaded paint, or was otherwise contaminated.  If the factory does not have good process controls to confirm that each batch of material is acceptable for use and that cross-contamination is avoided, non-compliant paint may end up on the toy.  The TSCP includes a requirement that factories have good quality management systems in place, with ISO 9001 certification desired. 

The TSCP, of course, includes finished product testing to regulatory requirements, including the CPSIA.  This brings up another thing I like about the TSCP.  The program effectively defines a reasonable testing program by specifying requirements for testing frequency (which is based in part on the factory’s process controls), testing sample size, sample selection procedures, and other parameters. 

Let’s face it: testing one or two samples once at the start of production only tells you that these one or two samples do (or do not) comply with regulatory requirements.  But without a safe design, sufficient manufacturing controls, and a reasonable testing program, there can be little confidence in the safety of the entire production. 

Watch for the upcoming launch of the TSCP and look for STR and TIA to be providing seminars.  Together with the CPSIA, I think the goal of better ensuring the safety of toys and restoring consumer confidence is possible.

Posted by Susan DeRagon on May 11, 2009 | Comments (0)