The current acoustic requirements for push/pull toys contained in section 184.108.40.206 are inappropriate for the following reasons: 1) During the pass-by test for push/pull toys, the contact between the wheels of the product and the test surface will produce a continuous sound that will significantly contribute to the overall sound pressure measurement. The tester will be unable to distinguish between the contributions to the overall sound level made by the wheels versus those made by the mechanism designed to produce sound. Therefore, a true measurement of the intended continuous sound producing mechanism cannot be achieved by the methodology given in the standard. 2) Among other factors, the levels in the standard are based a use distance of 25 cm (do not confuse this with the measurement distances specified in the standard). The distance from the noise producing mechanism to the ear of the child on the push/pull toys discussed here would be much greater than 25 cm. Because the relationship between sound pressure level and distance follows the inverse square law, an increase in the distance from the sound mechanism to the ear of the child would reduce the sound pressure level at the ear of the child dramatically. The risk of hearing loss would be reduced to such an extent as to make it insignificant. 3) It is implausible that a child could sustain the maximum speed at which the push/pull toy is tested (2 m/s). The speed represents a worst-case condition that would only be achievable momentarily at best. This supports regulating against immediate, acute hazards such as impulsive sounds versus chronic hazards that are presented by exposure to long-term, excessively loud continuous sounds. In addition, the proposed changes would further harmonization between F963 and the European standard EN71-1.
Draft Under Development