1 ICPHSO February, 2010

2 2 Toy Safety Certification Program SM

3 Development of the TSCP  August 2007 – TIA engaged ANSI to coordinate a public-private partnership to develop conformity assessment guidance  February 2008 – Resulting guidance published for public comment  May 2008 – Program approved by TIA Board but still a work in progress  August 2008 – U.S. federal CPSIA signed into law  February 2009 – Phased in TSCP launch begins (GCCs)  March 17, 2009 – Board unanimously reaffirms moving forward  October 1, 2009 – Full launch for participants  November 18, 2009 – First TSCP certified toys  Ongoing – Stakeholder outreach, refining requirements, minimizing testing and auditing redundancies, CPSIA modifications  2010 – Addition of TSCP Mark and consumer outreach

4  Improve toy safety by providing a sustainable conformity assessment system to offer reasonable verification that toys meet applicable mandatory U.S. toy safety standards in an efficient and cost-effective way  Help facilitate the U.S. toy industry and its suppliers to meet requirements of the new Consumer Product Safety Improvement Act (CPSIA)  Enhance the confidence of regulators, toy companies, retailers and consumers TSCP is the toy industry’s solution to fulfill the requirements of federal law in an effective, efficient and low-cost manner Objectives of TSCP

5 TSCP Participants and Process

6 TSCP FOCUS

7 7 Program Requirements  Applicants are responsible for: 1.Hazard and/or risk assessment for toy design 2.Audit body (verification of ISO Factory process control audits by an independent 9001) 3.Production sample testing by an accredited laboratory to validate that the factory is capable of producing toys that meet U.S. safety standards  Will be verified by ANSI-accredited Certification Bodies

8 Why perform Hazard Analysis? Standards cannot address all hazards Standards cannot address all hazards Recommended good design practice Recommended good design practice Product innovation Product innovation Consumer innovation Consumer innovation Increasing amount of consumer assembly Increasing amount of consumer assembly

9 Hazard Analysis will prevent all recalls

10 The Manitoba Study Based on 2007/2008 research from University of Manitoba Based on 2007/2008 research from University of Manitoba Study concluded 61% of recalls due to design Study concluded 61% of recalls due to design 17 % due to manufacturing 17 % due to manufacturing

11 Defect Examples Design Design Openings causing entrapment Openings causing entrapment Strings causing entanglement Strings causing entanglement Broken parts Broken parts Manufacturing Manufacturing Lead Lead Faulty assembly Faulty assembly Substandard parts Substandard parts

12 Who performs hazard analysis Not your Grandmother Not your Grandmother

13 Not the guy in the next office

14 Qualifications for performing hazard analysis Appropriate background – engineer, technician, human factors expert, industrial design, consumer service, doctor, biomedical expert... Appropriate background – engineer, technician, human factors expert, industrial design, consumer service, doctor, biomedical expert... Experience – familiarity with toys, recalls, safety issues specific to children Experience – familiarity with toys, recalls, safety issues specific to children Product designer must not be the sole evaluator Product designer must not be the sole evaluator

15 Qualifications Dependant on type of product Dependant on type of product More complex product requires more technical background, more related experience More complex product requires more technical background, more related experience Factors to consider in determining acceptable qualifications Factors to consider in determining acceptable qualifications Play pattern Play pattern Complexity of product Complexity of product Previous experience of company Previous experience of company

16 Qualifications for performing a hazard analysis differ for these two products:

17 Each Unique Product requires Hazard Analysis New products New products Refresh of existing product involving new parts, revised design. Refresh of existing product involving new parts, revised design.

18 New products

19 Refreshes involving new molds

20 Refreshes involving revised design

21 Examples of products that are not unique, can reference existing Hazard Analysis Color or fashion variations Color or fashion variations New combinations of existing components New combinations of existing components

22 Color variations

23 Fashion variations

24

25 Hazard Analysis It is not a compliance review It is not a compliance review Intended to identify issues above and beyond the scope of compliance Intended to identify issues above and beyond the scope of compliance

26 Hazard Analysis Common issues discussed: Common issues discussed: Foreseeable use and misuse Foreseeable use and misuse Misassembly of the product Misassembly of the product Pinch points Pinch points Retention of small parts Retention of small parts Projection/fall-on hazards Projection/fall-on hazards

27

28

29

30

31

32 Why submit an attestation? Hard to assess the goodness of a Hazard Analysis Hard to assess the goodness of a Hazard Analysis

33