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Toy Safety Is Serious Business

Subcommittee F15.22 Keeps Pace with Innovations in Toys

by Joan Lawrence

Toys are among the safest consumer products in the home, (1) but have you ever considered what goes into making children’s toys safe? Many of us — parents, grandparents, aunts and uncles, caregivers — probably don’t realize all of the effort that goes into ensuring toy safety. Rest assured, there are people who are concerned with the safety of toys who go to great lengths to ensure that the toys children play with do not pose unexpected peril.

ASTM Subcommittee F15.22 on Toy Safety will soon complete its review of ASTM F 963, Consumer Safety Specification on Toy Safety. In the process, the subcommittee has considered new technologies for toys, new product innovations and all available incident data to ensure an up-to-date, comprehensive standard for toy safety.

History

Toy safety has long been a priority for the U.S. toy industry, going back to the 1930s. This concern was formalized by the first comprehensive industry safety standard, drafted in 1971 and published by the National Bureau of Standards (now the National Institute of Standards and Technology) in 1976 as PS 72-76. In the early 1980s, a thorough review of the standard was conducted under the auspices of ASTM by the newly formed Subcommittee F15.22 on Toy Safety. The final product, which incorporated published U.S. Consumer Product Safety Commission (CPSC) (2) generic safety requirements and technical and labeling requirements for additional product categories, was published as ASTM F 963. Since then, the standard has been revised eight times, based on incident data and product innovations. It expands upon the federal standards for toys. Under the 1981 Consumer Product Safety Act, the federal government is to support the development of voluntary standards whenever those standards will be effective in addressing a risk of injury.

A Comprehensive Review

Children today seem more sophisticated than ever, and just as their interests are constantly changing, so must toys to entertain them. It follows that with new, innovative toys come new safety considerations. Toy safety standards must keep up with these ever-changing trends. Accordingly, Subcommittee F15.22 set out to examine these new product categories, any newly-identified potential hazards in toys, and other areas where clarification to the existing standard was needed.

All work groups were charged with analyzing incident data, (3) where available, to assess the need for changes and, when warranted by the data, drafting language for consideration by the subcommittee. In addition, comments and questions of interpretation compiled since the last full review were considered for clarification. The subcommittee was divided into 10 work groups, with all interest groups represented, including CPSC, consumers and industry. Three work groups were charged with drafting sections for specific types of products for which hazards had recently been identified, based on incident data; six considered revisions to clarify existing provisions of the standard, and one work group faced the challenge of establishing a standard for the sound level of toys in the absence of any data that would suggest a hazard posed by noise-producing toys. Given the variety of products and number of comments to consider, data to be analyzed and product testing to be conducted to ensure that a proposed noise level section of F 963 adequately addressed the defined hazards, the process was a time-consuming, but fruitful one.

New Requirements

Recent recalls of three types of products led to the need to consider sections in F 963 for the following products, each of which had been involved in recent recalls: certain cup-shaped toys that could cover the nose and mouth of an infant; toys with spherical ends on a narrower shaft or handle such as a xylophone mallet, and battery-powered ride-on vehicles.

Cup-Shaped Toys — A work group was appointed to evaluate hemispheric, cup-shaped toys after two infants died in separate incidents when cup-shaped containers, received as fast-food restaurant premiums, covered their noses and mouths, forming a suction they were unable to break. Working expeditiously to identify the hazard and avoid further tragedy, the work group considered incident data, research (4) and continual input provided by the CPSC. The work group considered the common factors in the incidents — the fleshy cheeks of a young infant combined with saliva on the face, the age of the child and the size and shape of the objects involved — which all seemed to play a part in the suction being formed. They faced the challenge of devising a standard that prevented this combination of factors from occurring. To do so, they conducted extensive testing to determine the size and shape of air holes necessary to prevent future incidents (see Figure 1).

After extensive study, the work group identified the scope of products to which the new section would apply: toy objects that are cup-, bowl- or one-half egg-shaped with a nearly round, oval or elliptical opening with diameters between 2.5 and 4.9 in. (64 and 102 mm), volume less than 6.0 oz. (177 ml), depth greater than 0.5 in. (13 mm) and intended for children under three years of age. They also identified four acceptable product design features that could prevent a vacuum from forming: interrupting the plane of the cup’s opening by some type of divider, using a scalloped edge pattern, or having at least two additional openings. Size and placement of these design features are specified in the proposed section, as well as a list of products exempt from the requirement, such as toys intended for drinking or holding liquid.

Toys with Spherical Ends — Another work group studied the data for incidents involving certain toys with a small, spherical shape attached to a shaft or handle with a smaller cross section, such as certain xylophone mallets and antennae with ball-shaped ends (see Figure 2). The work group sought to prevent the potential impaction hazard posed by products of this design if the spherical end becomes lodged in a small child’s throat causing asphyxiation. Because the incidents with these types of products were similar to those for some rattles and teethers of a similar, spherical-end design previously addressed by use of the supplemental test fixture in ASTM F 963, the work group agreed this test fixture was an appropriate gauge for these additional products as well. Accordingly, the proposed section stipulates that toys of this design weighing less than 1.1 lb. (0.5 kg), and intended for children up to 18 months of age, shall be so designed that they are not capable of entering and penetrating past the full depth of the cavity of the supplemental test fixture (see Figure 3).

Battery-Powered Ride-On Vehicles — The third class of products for which a new, specific section of F 963 has been proposed is battery-powered ride-on vehicles. Faced with a large recall of these products, the CPSC asked Subcommittee F15.22 to write a section of F 963 that would cover these kinds of products. Overheating and fires, in some cases attributed to consumers tampering with the charging system or other misuse, suggested a need for standards to protect against further incident related to the electrical systems of these products.

The scope of products under consideration covered ride-on toys not intended for streets or roadways that use a battery power source capable of delivering at least eight amps into any variable resistor load for at least one minute. The work group devised requirements and test procedures for maximum temperature, stalled motor, nuisance tripping, start/stop and forward/reverse conditions, switch endurance, overload, battery overcharge, short circuit protection and strain relief. In addition, safety labeling requirements and instructional literature for consumers were also stipulated to avoid product tampering or other misuse. Because the safety of consumers is so important, this is an example of a product standard that covers both proper use as well as foreseeable misuse.

Noise Level — In response to unsupported draft standards circulating in Europe and encouragement from the CPSC and consumer organizations, a work group to address the noise level of toys was appointed. With no injury data on hearing loss in children specifically related to toy usage, the requirements for acoustics were developed after extensive review of known research on noise-related hearing injury and existing published recommendations for noise limits not specific to toys. These included, among others, Occupational Safety and Health Administration (OSHA) limits for workplace noise (85 dB(A) for eight hours of exposure), (5) the work of an independent audiologist who participated in all phases of work group activity, and research into continuous sound testing of toys conducted by ISVR Consultancy Services in Southampton, U.K. (6) The work group’s assumptions were consistent with the ISVR study, that is, that exposure to noise from toys is intermittent and integrated with other daily noises, and it is unlikely that a toy would present eight hours of continuous exposure to sound. The ISVR study determined the probable duration of play with a sound-producing toy to be 1.5 hours per day.

The work group looked specifically at the following categories of toys:

• Rattles;
• Squeeze toys;
• Toys intended to be used close to the ear (examples include toy telephones, among others);
• Toys intended to be played with while attached to or resting on a table top, floor, or crib (examples include, among others, toy vehicles, stacking toys, games, activity toys that attach to a crib rail); and
• Handheld toys (examples include, among others, toy tools, small electronic games, stuffed animals and dolls; excludes toys falling in the other categories above).

In determining test protocols for these products, the work group faced additional challenges. A wide range of noise-producing toys was tested and retested in multiple laboratories in order to standardize the procedure and assure that results could be obtained that minimize variability due to equipment differences or operator technique. While satisfactory test protocols were derived for most of the products tested, squeeze toys and earphone-type toys will require additional work to determine reliable and repeatable test procedures and were, therefore, ultimately left out of the proposed standard.

Caps and cap toys were not considered as they are already regulated under federal standards. Other excluded products include mouth-actuated toys where the sound level is determined by the child’s own blowing; toys such as drums and bells where the sound is child-actuated and depends on the muscular action of the child; tape players, CD players and similar electronic toys where the sound output is dependent on the content of the removable media such as a tape, CD or game cartridge; toys that are connected to or interfaced with external devices, such as televisions or computers, where the sound level is determined by the external device; and toys with wheels where sound is produced as a result of the wheels making contact with the play surface.

For a summary of ASTM Subcommittee F15.22’s proposed sound level requirements by product category, see Table 1.

Revisions to Existing Sections

A number of sections in ASTM F 963 required revision to remain current with innovations in the toy market, as new products and innovative designs often pose new questions of a standard’s applicability and highlight a need for further clarification. Battery-operated toys and projectiles are two areas where revisions were needed to keep pace with new toys in the marketplace. Other revisions included harmonization of some requirements with those of the toy safety standard of the International Organization for Standardization (ISO 8124-1: 2000 Safety of Toys —Part 1: Safety aspects related to mechanical and physical properties), a reorganization and clarification of the entire section on labeling of toys, other miscellaneous technical issues raised throughout the standard, and general editorial corrections. And while ASTM F 963 has, since its adoption under ASTM, referenced a document providing the rationale behind revisions made in each review — for the first time ever the rationale for the proposed changes has been incorporated into the standard as an informative annex for easy reference.

Battery-Operated Toys — Revisions to the section for battery-operated toys were made to clarify their applicability to both rechargeable and non-rechargeable batteries, given the wide use of both in the marketplace and incidents in which consumers have attempted to charge non-rechargeable batteries. The revised section also clarifies the applicability of use and abuse testing for battery-operated toys based on the age for which the toy is intended. This is consistent with other provisions of the existing ASTM F 963 and with the application of use and abuse test procedures in the federal standard.

Projectiles — The proposed revision for projectile toys includes clarifications to the standard, added design guidelines to minimize the ability of the user to fire improvised projectiles, as well as a list of possible improvised projectiles to better illustrate the intent of the requirement. Requirements limiting the kinetic energy density (KED) for projectiles that exceed 0.08 joules have also been proposed for ASTM F 963 in order to harmonize with the ISO and European requirements for toy safety (ISO 8124-1: 2000 and EN71-1: 2001 Safety of Toys — Part 1: Mechanical and Physical Properties, respectively). An additional requirement specifying that projectiles with rotors have a ring around the perimeter has also been proposed. However, as of press time for this article, the changes proposed to the projectiles section of F 963, particularly for KED and projectiles with rotors, have not yet been approved by the subcommittee. Additional work is being conducted by this work group and a revised draft requirement is expected to be ready for re-balloting in early 2003.

Next Steps

ASTM F 963 is a living document, calling for modification and improvement as toys change and as the CPSC injury data system is improved. The toy industry, together with the CPSC and knowledgeable consumer groups, all play an important, cooperative role. A large part of F 963’s success has been its broad acceptance and recognition in the U.S. and in other countries. This was achieved, in part, through cooperative efforts between industry and government — conducting toy safety seminars and producing other training tools such as a video demonstrating key safety tests. These efforts to promote acceptance of the standard will continue upon publication of the revision and the revisions made will be of great interest internationally.

It is this cooperation — through the ASTM consensus process and efforts to educate others on the standard — that makes ASTM F 963 a model standard. //

References

(1) Based on the report of the U.S. Consumer Product Safety Commission “Estimates of Hospital Emergency Room Treated Injuries Associated with the Use of Certain Consumer Products, October 1, 2000 - September 30, 2001” published in the CPSC’s 2001 Annual Report to Congress.
(2) U.S. Consumer Product Safety Commission (CPSC) is the independent federal agency charged with overseeing the safety of over 15,000 consumer products, including toys.
(3) Incident data sources include the U.S. CPSC’s National Electronic Injury Surveillance System (NEISS), which is based on a statistical sample of hospital emergency room treated injuries related to consumer products, and other sources.
(4) For a complete account of the CPSC research conducted, see “Suction-Type Suffocation Incidents in Infants and Toddlers,” Suad Wanna Nakamura, Ph.D., Carol Pollack-Nelson, Ph.D. and Aaron S. Chidekel, M.D., Pediatrics, January 2003.
(5) Code of Federal Regulations, Title 29 Labor, Part 1910.95 Occupational Noise Exposures.
(6) “Noise from Toys and Its Effect on Hearing,” ISVR Consultancy Services, Southampton, U.K.

Copyright 2003, ASTM

Joan Lawrence is vice president, Standards and Regulatory Affairs, for Toy Industry Association, Inc. (TIA) and serves as secretary of the ASTM F15.22 Subcommittee on Toy Safety. She is also Canvass Group chairman for ANSI Z315.1, Safety Requirement for Tricycles; a member of the U.S. Technical Advisory Group to ISO Technical Committee 181 on Toy Safety, and a member of the ANSI Consumer Interest Council.