IFIA Presentation on Cases Where Laboratory Testing was Missing or Contributed to a Solution International Training Seminar Shenzhen, China August XX, 2017 The Testing Inspection and Certification Sector October 2016 Washington, DC Thank you so much for the opportunity to have this meeting between the CPSC staff and IFIA. We hope this will be the first of many other interactions on the future and we look forward to discussing with the CPSC opportunities for collaboration. IFIA members play a key role in providing guidance and educating the supply chain on CPSC requirements – manufacturers, importers come to our members all the time with technical questions and we also provide trainings and webinars on a wide range of topics. Therefore, IFIA members are an important allay for the CPSC in this aspect, as consumers are safer when manufacturers understand and build safety in the earliest stages of design and production process – and our sector play a key role in this preventive approach by providing greater levels of assurance that products are safe and comply with the required standards and regulations

Historical Case Studies Case Study #1 ASTM F2640, Standard Consumer Safety Specification for Booster Seats Section 6.4, Child Restraint System A client submitted a booster seat and the booster seat yielded passing results for all sections of the safety standard. The same product was submitted for full testing the following year and the product was issued a failure for section 6.4, child restraint system. The client complained due to inconsistent test results. According to the client, the product design and structure was not changed. Following an internal investigation, it was discovered that the restraint straps on the current model were different from the previous submission. It was also discovered that the factory made a change to the straps and did not notify the client of the changes.

Historical Case Studies Case Study #2 ASTM F2057, Standard Safety Specification for Clothing Storage Units Section 4, Performance Requirements (Tip Over) A client submitted 3 drawer dressers for the tip over evaluation Samples of the dresser were received from two separate factories The manufactured samples are intended to be identically manufactured Visual inspection of the products are identical. One sample weighed three pounds more than the other. One sample failed the tip over test while the other passed the tip over test.

Historical Case Studies Case Study #3 Canadian Toy Regulations, SOR/2011-176 Eyes and Nose, Section 31 A client submitted plush toys that yielded passing results for all sections of the toy regulation The same product was submitted for full testing the following year and the product was issued a failure for Section 31, Eyes and Nose Following an internal investigation, it was discovered that eyeball from the passing product was constructed with a felt backer which prevented it from removal under tension. The failed product’s eyeballs did not contain the felt backer which allowed for the eyeballs to release consistently under tension

Historical Case Studies Case Study #4 16 CFR 1501 / ASTM F963, Standard Consumer Safety Specification for Toy Safety Small Part Hazards A client was receiving complaints regarding the eyes of a plush product releasing The client decided to conduct a store audit and dozens of product were submitted to the lab for testing to determine the cause It was discovered that a small percentage of product contained a cracked retaining ring on the inside of the eyeball. The product with a non-cracked retaining ring passed the tension test while the product with the cracked retaining ring failed the tension test due to small part releases of the eyeballs

Historical Case Studies Case Study #5 ASTM F2085, Standard Consumer Safety Specification for portable Bed Rails Section 6.4, Openings Created by Bed Rail Displacement of Adjacent Style Portable Bed Rail A client submitted a bed rail that yielded passing results for all sections of the safety standard. The same product was submitted for full testing the following year and the product was issued a failure for Section 6.4, bed rail displacement The client claimed that the product design has not changed The client submitted additional samples and visited the test lab to discuss the issue and personally witness the testing During the testing, one side of the bed rail restraint strap slipped. Upon review, it was noted that the teeth on the slipped strap clip side were worn. The client attributed this anomaly to component mold wear.