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Toy safety – the law in brief The main requirements are that toys must: satisfy safety requirements (termed the ‘essential safety requirements’) bear the CE marking bear the required name and address details be accompanied by warnings where necessary
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The law – how it protects us If any toy is found to be unsafe according to the regulations, then the producer can be found guilty of a criminal offence. The producer can claim that in principle all reasonable steps were taken to ensure the toy’s safety to avoid prosecution, fines or even imprisonment, but the toy gets no such reprieve and will be withdrawn from sale across the EU straight away. All member states are automatically notified that there is an unsafe toy, and the toy is recalled.
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Legal Requirements Any toy sold in the UK must comply with Essential Safety and the Toy Safety Regulations which are made under the Consumer Protection Act It is possible to comply with these regulations by conforming to British Standard BS 5665 or European Standard EN7 It makes no difference whether the toys are mass produced by a large manufacturer or hand crafted and sold at a car boot sale
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BS 5665 BS 5665 "Safety of Toys" consists of four main areas shown below. These might form the basis of your product analysis and your initial design criteria. Physical and Mechanical risks. Flammability risks. Toxicity issues. Electrical Safety.
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Physical and mechanical Can the toy cut, stab, puncture, mangle or choke the child? Think about how this could be tested without causing injury What would you need to find out about the sizes of children?
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Flammability Does the toy easily catch fire if it is placed near to a heat source, fire, heater or sunlight? Are there tests that you could carry out on the materials you are considering using?
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Toxicity Are any of the components made from, or finished off with materials that are poisonous if sucked, chewed or swallowed? How can you find out whether the materials and finishes you are using will present this risk?
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Electrical safety Toys must have a low voltage supply. For younger children, toys must be battery operated and the batteries must only be removable by an adult. How can you find out what is available in terms of low voltage and how do manufacturers make battery access safe?
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Design criteria Toys must be safe Toy should not be easily flammable or combustible Any detachable parts must not pose a choking hazard The construction of the toy should not pose any risk of injury Toy should be CE marked Toy should not contain any dangerous chemicals Toy should carry appropriate warnings i.e. small parts not suitable for children under 36 months. Toy should be free from any sharp edges The toy should include instructions warnings The name of the manufacturer should be displayed on the product
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Materials The next few slides look at material properties: Wood Metals Plastics Fabric Finishes Glues You will need to undertake some additional investigations
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Wood All surfaces must be smooth enough to prevent splinters and have no loose knots nor insect holes. All edges and corners that can be touched must not be sharp. Find out what timbers are commonly used in toy manufacture and why Find out how edges are machined to make them smooth
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Metals All parts that can be touched must be smooth and free from burrs and not cut fingers. Thin metal sheets should be rolled over at the edges. Find out how the edges are made safe
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Plastics All edges and corners that can be touched must be smooth and free from burrs. Thin sections must be made so that they will not crack nor shatter if hit. Find out what plastics materials are available for you to use Find out how they can be shaped and formed How can you safely test whether these plastics will shatter?
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Fabrics No fabrics must be used that can become detached if chewed or pulled. i.e. hair, fur, ribbons How can you test these? What fastening methods can you use to ensure that parts cannot be pulled off?
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Finishes Applied finishes such as paints, varnishes, stains etc. that can become loose and flake off must not be used. No finishes can be toxic. How can you undertake tests to ensure the durability of finishes? How can you find out whether finishes are safe for use on toys from a toxicity viewpoint?
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Glues All glues must be non-toxic and hard setting. No jagged glue runs must be accessible. Find out how you can test these properties Find out how can you check out the toxicity of glues?
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Components Components are widely used in toys such as: Cords Springs. Wheels Screws Nails Nuts and Bolts. Fixings Wires Knobs
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Cords Very common in pull-along toys Must be at least 1.5mm thick to stop a child's finger from being cut. The cord must have no knots or loops which could turn into a slip knot or noose.
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Springs Must be covered if accessible and if a child’s finger or skin could become trapped or nipped in the coils when they close.
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Wheels Wheels and tyres should not come off if they are of such a small size that they could be swallowed. (Choke Test). Clearance between the wheel and the chassis should be less than 5mm or greater than 12mm.
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Screws The pointed ends of screws must be inaccessible and any screw head must be smooth to the touch. The heads of countersunk screws must be sunk below the surface. Screws must be protected from corrosion. (rusting).
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Nails Heads must be below the surface and protected from corrosion. Any accessible pointed ends must be removed not just punched or turned over.
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Nuts and bolts Both the head and nut ends of a bolt must be smooth to the touch and not cause cuts, punctures, tears to the skin or clothing, or damage to the furniture. Bolts must be locked so that they cannot become loose in use.
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Fixings No fixing should be used if it could potentially come off and be swallowed.
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Wires Wires that form part of the toy that a child can reach must have safe ends, i.e. Rounded, blunted, bent over or terminated in a ball. Wires that can be bent by a child must not break if repeatedly bent.
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Knobs Any small ball, knob etc. that could be swallowed must never be allowed to become detached.
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Other features The following features may also need to be considered: Hinges Levers Rotary mechanisms Holes and gaps Protrusions Separate parts Strength Packaging
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Hinges The gap at the hinge line should be either less than 5mm or greater than 12mm Explain why that should be the case
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Levers Collapsible toys (or parts of toys) must have stops to prevent the risk of fingers being trapped in the folding mechanism Explain how you could test this feature
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Rotary mechanisms No rotating mechanisms (levers, gears, pulleys, cams, etc.) can be accessible if there is a possibility that it might cause an injury
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Holes and gaps The toy is dangerous if a pencil can be poked into a hole or gap and touch moving parts or sharp objects which could cause injury. Explain why a pencil is mentioned
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Protrusions Any rigid part (solid or tubular) which sticks out must be protected by a firmly attached rubber or plastics cap if it is liable to cause an injury to a falling child
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Separate parts Any detachable parts must pass the Choke Test. Any non-detachable parts must be fixed so that either, a child cannot grip them with their fingers or teeth, or the parts cannot be removed when submitted to a force of 90 Newtons. Work out how you can test this requirement
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Choke tester Detachable parts must not fit inside this cylinder. If they do, there is an increased danger that the parts would choke the child.
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Strength Any toy can be used for a purpose for which it was not intended If the toy could bear some or all of the weight of a child when being used, then the toy must be designed to be strong enough to withstand that weight How can you find out how heavy children are?
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Packaging Packaging used for the toy should not be the cause of accidents. Any plastic bag must have a minimum thickness of 0.038mm, have air holes and not be fitted with a drawstring.
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Age Warning logo The "Age Warning" logo that consists of an unhappy child’s face alongside the numbers "0-3", first appeared on toys in 1995 and means that the toy is unsuitable for children that are younger than three years old. Sometimes, you may find the logo referred to as the "grumpy baby" symbol! Either beside the Age Warning symbol or within the toys packaging will be further information describing the risk in more detail. For example, the toy may contain small parts that represent a choking hazard.
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The Lion Mark The Lion Mark was introduced by The British Toy & Hobby Association (BTHA) in 1989 to promote high safety standards throughout the toy industry, the bright red and yellow 'Lion Mark' is an easily recognisable icon to help consumers identify toys that have been classified as being safe for children to use.
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