CPSC Small Business Office Webinar Series: Toy Standard Update (ASTM F963-16)

>>Shelby Mathis: Alright,
hopefully everybody can hear me, and you aren’t having any sound issues;
hopefully I’m coming through loud and clear. First off I just want to thank everybody
for signing up for this webinar, we had overwhelming positive
interest in attending. This is the US Consumer Product
Safety Commission. I am Shelby Mathis, the small
business ombudsman. I will be your guide, as it were, for the first of what we hope will be a monthly
webinar series put on by our agency. And this topic today is going to be the toy
standard update, which as many of you know, the new toy standard is ASTM F963-16. So before we get started, let me
just do a few housekeeping issues. First of all, many of you are getting acquainted
with the GoToWebinar series technology that we’re using to run this webinar. You do have the ability to ask
questions throughout the webinar, but I would ask if you have a question,
just make a note of it, do not ask it yet because I’m not going to be able to
present the webinar and answer those questions. So, hold your questions until the end, and we’ll talk a little bit
about how to submit those to me. And then, I would also ask, there’s a chat
function on your GoToWebinar toolbar that’s on the right, that you not
use that chat function, because I’m not going to
be able to respond to that. And a few more points. One is for those of you that are live on
the webinar right now, tomorrow you can look in your email, for an email from me that will
include the audio and video of this webinar, and that should come about 24
hours after the webinar ends. For individuals that registered but were not
able to attend live, they will also receive that video of today’s webinar, the video and
the audio tomorrow from an email from me. And then lastly, I need to
start with a disclaimer, which is that I am a CPSC staff member, and the
views that are expressed here represent my own as a CPSC staff member and not
necessarily those of the commission. So with that, let’s get started. So the agenda today, first
of all I’m going to start off by doing what I’m assuming is mostly
refresher for everybody on this webinar, which is to talk about toy labeling and
testing requirements and what hasn’t changed. Everybody should, on this webinar, have been
exposed in some way or another to these topics, and I think it’ll jog a lot
of memories for you guys. And then number two, we’re going to talk about
the new toy standard itself, ASTM F963-16. We’ll talk about the new testing requirements,
and I’ll do my best to highlight some of the important changes
that are coming as a result of the new toy standard going into effect. Third, I’m going to speak hopefully
directly to importers, manufacturers and testing labs that are
attending this webinar. We’re going to talk about what happens in terms
of finding a new testing lab that can test to the toy standard, or continuing
to use your existing testing lab. What do you do if you’re a lab? How do you test to the new toy standard? What do your reports need to say? And manufacturers and importers will
want to know that information as well. And then the fourth thing we’re going to
cover is I’m going to do three examples, using testing toys, or example toys
that are going to highlight some of the changes in the toy standard. And then for the fifth part of our agenda, we’re
going to turn it over to you, our audience; I’m going to introduce you to Franky Toy,
which I hope you will love as much as I do. And we’re going to conduct a
little bit of audience polling, where we’re going to ask interactive questions
and see if you guys can get the right answers on how the new toy standard applies
to different parts of Franky Toy. Second to last I will highlight some business
resources that are available through our agency, and some of the good work that we’re
doing here in terms of outreach and providing information to our stakeholders. And lastly we’ll do a question and answer
session, and that’s where I’ll ask you guys to submit the questions that you
have as this webinar is going on. I estimate that that question and answer
session will be between 15 and 20 minutes. The good news is, if I can’t get to
your question, then we have the ability to download a report that has the
questions that were asked, who asked them, so that we can respond directly
after the fact to you guys. Alright, so toy labeling and
testing: what hasn’t changed. Well, tracking information hasn’t changed. And tracking information requirements are
— three main things to remember here. One, tracking information on all children’s
products, including children’s toys, needs to be permanently affixed,
and it needs to be on the product and the packaging where it’s
practicable to do so. The pieces of information
that we are generally looking for in tracking information are the domestic
manufacturer or private labeler name. If you are an importer, your
importer name should go there. Location and date of production of the product. Detailed information on the manufacturing
process, such as batch or run number if you’re utilizing that information
in your manufacturing runs. And then finally any other info to
ascertain the source of the product. The purpose here is to benefit
a consumer and a manufacturer. As a consumer, I should be able to look on
a label that is on my children’s product, including a children’s toy, and
tell whether or not I have a product that could be subjected to a recall. As a manufacturer, you need to get
that information from a consumer that may be having an issue with a product and
be able to isolate within your processing runs, your manufacturing runs where the problem could
be so that you can recall, from the market, whichever defective products
may be in your run process. So, we get a lot of questions
about tracking information at the small business ombudsman office. Because you guys are attending via webinar,
I can’t provide you with a hyperlink that you can just click, but we’ve got a
frequently asked questions site that’s a really good resource. That is how you get to it. You also have the ability if you go to
CPSC.gov, which is our agency website, to just type in the search bar FAQs
on tracking info and it will also pull up the frequently asked questions site. People find it really useful and it answers
a lot of the questions that they have. So what else hasn’t changed? Lead content, this is certainly something
we’re still concerned about in children’s toys. If the toy is — well, if it’s a children’s toy
it’s intended for children ages 12 and under. Two lead limits to be mindful of. One is the total lead content,
and that’s 100 ppm. It cannot exceed that amount. And then on surface paint, on the
children’s toy, cannot exceed 90 ppm. And I’ve got this rubber duck here, because it
also represents a potential phthalate concern. And phthalates are plasticizers. There are three types of phthalates
that are permanently banned. And those three are listed on your screen
under the permanently banned section. Those phthalate concentrations cannot exceed
more than .1 percent in a children’s toy. There are three other temporarily banned
phthalates that are also listed on your screen, and they are temporarily banned, pending
adoption of final rule by commission, and those concentrations can
exceed no more than .1 percent. On the three phthalates that are temporarily
banned, that applies to children’s toys that can be placed in a child’s mouth, and then
childcare articles that facilitate sleeping or feeding or help with sucking or
teething of a child that’s three or under. What else hasn’t changed? Age grading of toys — it remains
important that a toy be properly age-graded to determine what regulations apply. And specifically there we’re talking about small
parts, which we’ll touch on in just a second. But the goal is always, when age grading
a toy, to match the attributes of the toy to the abilities and behaviors of the child. So what would our commission look at in terms
of determining the proper age grading of a toy? Well, three things. One is the manufacturer’s stated intent:
what do they say the age grade is? The second is advertising, promotion, and
marketing materials: are there photographs or videos of children using this toy? And if so, what is the age
range of those children? That can sometimes be indicative of
the proper age grade for the toy. And then thirdly, how is the article commonly
recognized as being intended for children? Because we, as a society, attach age ranges
to certain toys based on our own experiences. So I mentioned small parts a second ago. This is something else that has not changed. As we all know, small part present a
choking, aspiration, and ingestion hazard. And what classifies as a small part? Anything that can fit into a small
parts cylinder, and the dimensions of the cylinder are specified in the
regulation that appears on your screen. On the left-hand side, the bottom left-hand side of the screen is a picture
of a small parts cylinder. And there are five potential small
parts that appear there on the screen, and you can see that the four that are laying
on the table are all going to fit easily in that small parts cylinder, and the
one that is there is the largest one, but you can see it also easily
fits in the cylinder. So what does this mean if you got
a small part on a children’s toy? Well, if the children’s toy is intended
for children under three years of age, then that’s a problem; there is a
ban on small parts in children’s toys for toys age graded for children under three. If the toy is graded for children
between the ages of three and six, there are labeling requirements
where you have to notify the consumer that this toy could produce a small part,
and those labeling requirements are outlined in the regulation that appears on your screen,
and that regulation outlines the sizing of the font, the placement,
and the language itself. So how are small parts traditionally
encountered? Well, one way that we certainly
see it in our small office at the Consumer Product Safety Commission
is that sometimes toys contain a small part, and a good example of this are
little things that can be tucked into the pockets of maybe a doll. If they’ll fall into the small parts cylinder,
then that toy itself contains a small part. Another way that we encounter small
parts is through use-and-abuse testing, and use-and-abuse testing produces small
parts in two ways: one, through the drop test where you’re truly holding a toy at a
certain height and you’re dropping it; the second way is the tension test where you’re
applying a certain amount of force to a toy to see what comes off the toy
when that force is applied. So we’ve got three pictures on the bottom
of your screen that show the results of a drop test with this little toy horse. So on the bottom left, you can
see that the little toy horse, when dropped, lost one of its wheels. And there’s a small part cylinder in the picture
on the far left and it’s zoomed in the size of the wheel versus the size of the little
screw that affixed it in the middle picture. You can see that the wheel is clearly
bigger than the small parts cylinder, so this would not be a potential small
part that would be banned on this toy. However, the screw that is sitting next
to the wooden wheel is a small part; you can see the picture on the far
right of it in the small parts cylinder. So what does this mean now that we know that,
when you drop it, it produces this screw that can fit in the small parts cylinder? Well, what it means is if the age range, or
the age grading for this toy is for a child under the age of three, this design is not going
to work, and the manufacturer is going to need to figure out a way to permanently affix
that wheel so that when the toy is dropped, it no longer produces a small part. If this toy is age graded for a child
between the ages of three and six, then it would require proper
labeling, notifying consumers. Manufacturer could keep this
design theoretically and label the toy, that it contains small parts. So what else hasn’t changed? And one of the reasons that I bring this
up is because this is kind of a new thing within our agency and it’s something
that not everybody knows about: we have a small batch manufacturer registry. And to qualify as a small batch manufacturer
with our agency, there are two requirements: the first is a revenue requirement. You have to meet both of these. For the revenue requirement, if your company
last calendar year in gross revenues aren’t less than right under $1.1 million — and this
is in US dollars for those of you attending from overseas, it’s $1,099,399 — or less,
and your business manufactured no more than 7500 units of a covered
product, then you would qualify as a small batch manufacturer
under our agency’s standards. What is the benefit of being
a small batch manufacturer? Well, the benefit, and part
of the reason that it’s part of this presentation today is this potentially
allows you to avoid third-party testing at an independent CPSC accepted lab for certain
types of tests on certain children’s products. But the real reason it’s here is because some
parts of the toy standard, you can test at home if you are registered as a small
batch manufacturer with us. So there’s a caveat with
this, as with all good things. The caveat is that, if you have registered with
us as a small batch manufacturer and you plan to conduct some of the toy testing at home
as opposed to using outside lab to do so, you need to, one, buy the toy standard
which is a copyrighted document from ASTM, so you’ll have to pay to purchase
the toy standard; and then secondly, you’re going to need to make sure that you can
comply to the letter with that toy standard. So if you don’t feel comfortable doing
so, then you can engage an outside lab. Now, registration with us is not
required by our agency, but again, it can lower your testing burden if you qualify. To register, you actually go to a portal
that’s hosted through SaferProducts.gov, and registrants, after registering
through the portal, will receive an email that contains their small
batch manufacturer number, and that small batch manufacturer
number is referenced in number seven on a Children’s Product Certificate,
which is a CPC; or a General Certificate of
Conformity, which is a GCC. And small batch manufacturer
registration is done each calendar year, so it runs from January to December. And for those of you that are on our small
business newsletter, thank you, first of all. And secondly, each December we send out an email
reminding all of our small batch manufacturers that it’s time to re-register
for the upcoming year. Alright. So let’s get to the matter
at hand which is the new toy standard. And let’s do a little bit of
background on the toy standard. Currently in effect is ASTM F963-11. That standard became effective
as of June 12, 2012. So toys manufactured on or after
June 12, 2012 must be tested to that new toy — to the 11 toy standard. Sorry. At the end of this
month, on April the 30th, 2017, the new toy standard, F963-16
will go into effect. What does this mean? It means that all toys that are manufactured on or after April 30th must be
tested to the new standard. And for a little bit of background information
on how this became the mandatory toy standard, we were notified by ASTM
on November first of 2016 that there was a new voluntary
toy standard, the 963-16. We published, in the federal register, a direct
final rule on February the second of 2017, and then 180 days after the notice
— that’s April 30th, 2017 — the new standard, the voluntary
standard becomes a mandatory toy standard under Section 106 of the CPSIA. Alright. So I’m going to, without belaboring
the point, highlight some of the changes in the toy standard, because I
know that this is the information that everybody is really here for today. Before I start, two notes. One is, at the bottom of your
screen, that this toy standard, for those of you who are a bit familiar
with the European Toy Standard or ISO 8124, a lot of these changes may look familiar. And why is that? Well, it’s because when ASTM was
putting together this new toy standard, they did it in an attempt
to align the US Standard with the European Standard
and the ISO standards. So that’s the first note. And then the second note, for those of you who
want to track the changes in the toy standard from the 11 version to the 16 version, I would recommend you purchase
the standard from ASTM’s website. They do have an option to purchase
a red line of the toy standard that will actually track
the changes from 11 to 16. We’ve gotten a lot of questions on, how we can tell the difference besides
comparing the documents side by side? The answer is purchasing the red line bundle
from ASTM when you get the new toy standard. Alright. So with all those caveats,
let’s look at some of the changes. The first one is on battery-operated
toys and magnetic toys. If you are a manufacturer or importer or
testing lab, on those two types of toys, labeling requirements under
the toy standard have changed. For batteries, there are new testing
requirements on certain types of button and coin cell batteries that exceed 1.5 volts, and there’s four new testing methods which
appear on your screen for batteries and toys. The third bullet point, cleanliness. There are some changes in the test methods for
biological material, so we’re talking putties, gels, pastes that might be part of a toy. And there’s also some changes in testing on
stuffing materials, and one of those changes has to with microbial cleanliness as it
does for the biological materials. Good news: for heavy elements you can now use
an HDXRF to do that total element screening. And then for magnets, there is a new
cyclic soaking test for magnets in toys. However, this only applies to three
types of toys that contain magnets. One is a wooden toy that contains a magnet; the
second is a toy that’s going to be used in water because it could be exposed to moisture;
and the third is some mouth-actuated toy that could be exposed to saliva
as, being a mouth-actuated toy, that contains a magnet or a magnetic component. For mouth-actuated toys, there are
some design requirement additions that will prevent a projectile and
its design from entering the mouth if it’s a mouth-actuated projectile
toy, keeping the projectile from coming back to the user’s mouth. For projectile toys specifically, there
are kinetic energy density level changes that are now allowed for
certain types of projectile toys. And of note here is that our
staff here at the CPSC has elected to exercise enforcement discretion
on one specific section of the new toy standard, and that’s And in our discretion, we’re going to apply the
kinetic energy density or KED requirements only to projectiles with energy
greater than .08 joules. So for ride-on toys, there
are also some design changes. First one, stability. There is a spacing requirement now
on wheels that are on the same axis so that they can be counted
as two separate wheels. There are changes in the overload test for
ride-on and seated toys that are more stringent. And for restraints that might be on a ride-on
toy like a waist restraint or a seatbelt, those restraints are now free or exempted
from the free length and loop requirements so those waist restraints can
be longer on a ride-on toy. For sound-producing toys, there’s a new
definition for sound-producing toys that, it’s a little broader and
includes mouth-actuated toys. There are increases in the peak limits, addition
of a new noise limit, and a lower test speed for push-pull toys in that category. And then lastly, there are two
new sections to the toy standard, although one’s really a throwback
for those of you that track the toy standard through the years. Toy chest used to be a part of the
07-epsilon-1 version of the toy standard. Well, they’ve been brought back and their now in
the 16 version with one clarification that has to do with the multi-positional lid requirement
when you’re doing the maximum lid drop test. And then a second new section is
actually a new material or a new toy, and that’s an expanding material which we’ll
learn a little bit more about in just a second. The expanding materials are defined. There are some performance requirements that are
placed on them, and there is a test methodology and a test template which include a gauge to
determine whether or not they pass the test. The reasoning here is that there’s a
potential emerging hazard associated with expanding materials which
are very small materials that, when exposed to moisture, become much larger. The hazard here that we’ve
identified is potential GI blockage related to ingestion of them. So, the test methodology and the
test template were designed to try to address that potential hazard. So, for testing labs, now that there’s going
to be a new standard in place, what happens? The good news is, is that if you are a testing
lab that’s already accepted to the 11 standard in certain sections of the toy
standard, you can already start testing to the 16 standard in those same sections. For the two new types of toys that are
incorporated into the 16 toy standard, first of all, toy chest for labs
that were previously accepted on the 07-epsilon-1 Toy Chests
section, which was 4.27, great news: those labs that were previously
accredited to test to Toy Chest in ’07, on the 07 standard can now test
to the 16 standard for Toy Chest. And on Expanding Materials, a completely
new toy, labs that were already accepted to ASTM F963-11, that’s the standard
currently in effect that had been accredited for two sections — one is 4.6, that’s Small
Parts, and the second one is Squeeze Toys — if you are a lab that’s been accredited to
both of those sections on the 11 standard, you can test for Expanding
Materials to the 16 standard. So, how do you find a CPSC-accepted lab? There’s the lab search page URL on your screen. Again, it’s not a hyperlink because you’re
viewing just a picture of my screen, but when you go to that lab search page,
you have the ability to narrow your search by both country and the type of product
testing that you need to have conducted. So, for labs, what is the deadline for applying
for reaccreditation to the new toy standard? The deadline is February the fourth of 2019. As of that date, our agency is no
longer going to accept lab applications that reference sections of the 11 standard to
support being accredited to the 16 sections. Applications from labs should be
submitted via our online portal, and the web address is actually on your screen. Applications began being accepted
as of February second of 2017, and for those of you keeping track, that was
the date we published in the Federal Register that there would be a voluntary
standard, toy standard converting to a mandatory toy standard at the end of April. Labs are accepted on a test-by-test
basis, so labs may not be accredited to every section within the 16 toy standard. Maybe there are just a few sections
that they’re accredited for. And labs must remember to reapply with our
agency at a minimum, at least every two years. One last point, and I think it’s
important on the import side, it’s important on the manufacturer
side, and it’s certainly important on the testing lab side, is that if
you are conducting testing already to the new toy standard, ASTM
F963-16, you need to make sure that your testing reports reference
both the 16 standard and the sections from the standard that you are testing to. This is a requirement from our agency. It was part of the Federal
Register notice that got published. This requirement is as a result
of our agency wanting to track which labs have already started testing
to the 16 section, the 16 standard, and which sections they’re already testing to. Alright, so now that we have done a little
bit of background on all of the changes in the toy standard, I’m going to go through
three sample toys that highlight changes in the toy standard, distinctions between the
11 and the 16 standard, and then I’m going to turn it over to you guys
for some fun audience polling. Well, I hope it’s fun. So, our first toy that we’re going
to take a look at is this cute bear, which is a stuffed animal that’s filled with
marabou, and for those of you who don’t know, marabou is actually a stuffing that’s derived
from poultry feathers; it’s avian feathers. So, on the left-hand side of your screen, you
can see the CPSC and current toy standard, the 11 standard, testing requirements. So, let’s go through them pretty quickly. The first one, it looks like those are
little plastic eyes on our cute teddy bear, so they could require phthalates testing. Depending on how the eyes and the
ears and the nose are painted, there’s potential lead substrate and surface
coating testing that would need to be done. We’ve got, it’s a children’s toy, so we’ve
potentially got small parts concerns there. Look, the eyes are very small, we can’t
tell how small the nose is, potentially, the ears could even be small parts. And then, because it’s a toy, it’s going
to be subjected to use and abuse testing. So, let’s compare that to the right-hand side of
the screen, where we’re talking about the CPSC and new toy standard, the 16 standard
testing that would be required. So, first off, phthalates, the
two types of lead, small parts, and use and abuse, those all remain unchanged. The tests, the use and abuse test remains
unchanged, and the three things above it, those standards and requirements
have not changed. However, because we’ve got a stuffing material
here that’s made from poultry feathers, and we have changes in the cleanliness
test for stuffing, this is new. So, there’s a modified test for cleanliness
and in the stuffing in this bear, we’re going to need to do a visual
inspection and that section is modified in the toy standard, and then, there’s
a bacteriological safety test that needs to be conducted because these
are avian feathers. And that, again, is a new
change to the 16 standard. And important to keep in mind here, many
toys from a left and a right comparison of the 11 standard and the 16
standard are not going to have changes. I have truly selected these three examples because they highlight changes
in the toy standard. So, just keep that in mind. So, for our second example toy,
this is an expanding material. It’s a super-absorbent polymer ball, and you
can see from the far left how small the ball is, and then, when exposed to moisture,
how much larger it grows in size. So, on the left-hand side, we’ve got
the CPSC and current toy standard, the 11 standard testing that’s required. If there are plasticizers associated
with this, and there likely are, then phthalates testing would
need to be conducted. And then depending on the material that
it’s made of and how it is colored, we could have Lead Substrate and Surface
Coatings testing that needs to be conducted. Let’s compare that to CPSC
requirements and the new toy standard. Well, phthalates and the two types
of lead testing has not changed. That will still need to be taken care of,
but because this is an expanding material, and that’s a new type of toy, we have to conduct the Expanding Materials
Test, and how is that test conducted? Well, the original expanding
material, which is on the far left, has to be soaked in de-ionized water
for 72 hours to see how far it expands. If that polymer ball expands more
than 50 percent in any direction, it meets the definition of
an expanding material. And once it’s defined as an expanding
material, we need to make sure that it will pass through a gauge, and the dimensions of that
gauge are outlined in the new 16 toy standard. And again, the measurements on
that gauge reflect an intent to try to accommodate the potential GI blockage hazard
associated with these Expanding Materials. And our last example toy
is a push car for toddlers. It’s a ride-on toy, so, before
we go through the comparison on both sides, just a few things to point out. One is you see it’s got a steering wheel,
it’s got four wheels that are you, you know, affixed to the car in some way, and
it’s also got a waist restraint, or a lap belt for the child
that’s going to sit in it. So, on the left-hand side, we’ve got the CPSC
and ASTM F963-11 testing requirements which are: phthalates, because that looks like
a lot of plastic on that ride-on toy. Depending on how it’s painted and
what it’s made of, lead substrate and surface coatings testing
would likely need to be done. In terms of small parts, we can’t see them, but
there are potential small parts on the wheels, on the steering wheel, depending on what happens
when this is subjected to use and abuse tests, there could be quite a few
small parts that were liberated. Dynamic, because it’s a ride-on toy; dynamic
strength; cords, straps, and elastic; stability; and overload/collapse tests all need to be done. That’s all part of ride-on toy requirements. Now, let’s contrast that to the
right-hand side for the 16 standard, and you’ll see that much of
it has remained unchanged. Phthalates, the two types of lead, small
parts, use and abuse, and dynamic strength, which is how the toy functions when
it’s in motion, have not changed. However, three things associated
with this ride-on toy in terms of testing have potentially changed. First has to do with the
cords, straps, and elastic; and that’s that waist belt
that we talked about earlier. The waist restraint is now exempt from
the free length and loop requirements, meaning that it can actually be longer and still
be approved or passed the ride-on toy test. Secondly is the stability test,
and you see that there are wheels, there’s four wheels on this ride-on toy. We can’t see how far apart they’re spaced,
but to be considered separate wheels under the Stability standard, those wheels on the same axis must be spaced
out at least 5.9 inches apart. And then, lastly, for the overload/collapse
test, the standard now has you default to a heavier overload weight on that
ride-on toy to accommodate larger children. Alright, now that I, I’ve done some of the
work for you, we’re going to take a look at Franky Toy, which, before I start, I
need to say that Franky Toy is the result of a collaboration between our
government agency and Health Canada. This predates me at the agency, but as
I understand it, there were several, several brilliant toy individuals
that came together and said, “How can we create a toy that’s
got all of these neat components that could represent a whole myriad of toys?” Once that idea was fully formed,
Health Canada was kind enough to give us this beautiful illustration of Franky
Toy, so for those of you from Health Canada that are listening, thank you very
much for this beautiful illustration. Alright, so, with all that being
said, let’s meet Franky Toy. First of all, he’s meant to look a little
like the Frankenstein monster, I mean, hopefully that comes across
on everybody’s screen. His head is an injection-molded head. It’s got painted hair; his face is painted. He’s got a little mouth that’s actually
a speaker device, and the good news, for those of you that love the song, “Ride
of the Valkyries,” that is the only song that Franky Toy is going to play for you. So, hopefully you like it. For his neck, his neck is a stiff neck, and on
both sides, you can see there are little magnets that look almost like bolts
just with the Frankenstein, just like the Frankenstein monster had. Then, moving down Franky, he’s got two
hands that both have a lot going on. On his left-hand side is a projectile device
if he doesn’t like who’s playing with him. And then, on his right-hand side, if he
likes who is playing with him, is a pacifier. Franky’s got a stuffed torso that looks
almost like a plush fur outer coating. There is a battery compartment in Franky’s
torso, and then, going down his legs to his little feet, you can see at the bottom
of his feet, there are two large magnets that allow Franky Toy to stand
on his own on a metal surface. So, that’s Franky Toy. So, with all of that being said, let’s focus
on some audience polling, and for those of you that are using your computer, on the right-hand
side of your screen, you should have the ability to answer some polling questions
that we’re going to ask. So, I want you to focus first on Franky’s head,
and the question here, and I’m going to post It up on your screen, is, “What testing would
be required on Franky’s head by the CPSC?” And you can select all that apply. Alright, and votes are coming in, so we’re going to give you guys now just a few
more seconds to get your votes in. Alright, so we’re going to go ahead and close
the poll, and then let’s take a look at what we as a group thought the answer was in terms of
the testing that was needed for Franky Toy. And it looks like the majority of you guys
picked, “All of the above,” as your answer. Let’s see if that’s actually
correct on Franky’s head. Good news: everybody got
the first question right. Testing on Franky’s head would need to
be heavy elements, the two types of lead, use and abuse testing, and all that, so,
“All of the above,” was the correct answer, and small parts testing was
not one of those choices, but there’s a potential small
parts concern with Franky’s head. His head is plastic, so we’ve also got
a phthalates concern with his head, and the hair and nose and eyes on Franky. So, now that we’re warmed up, and we’re
performing well, let’s move on to the next part of Franky, which is his mouth, and take a
look at the speaker device on Franky’s mouth, and then our next question, I’m going to post on
your screen, which is, “Would the speaker device in Franky’s mouth be subject to decibel
limits testing under the new toy standard?” And, you should answer,yes or no. Alright, I’m going to give you guys a
few more seconds to get your answers in. Alright, it looks like pretty
overwhelming response, so I’m going to close the
poll and post the responses. Let’s see what we thought as a group. It looks like overwhelmingly, we thought that
Franky’s speaker mouth would be subjected to the decibel limits testing
of the new toy standard. Let’s take a look and see if that is correct. Good news: you guys are right again. Franky’s mouth would be subjected to
decibel limits on sound-producing toys. Also, of note, use and abuse
testing, because he’s still a toy, and heavy elements testing would also need to
be done on Franky’s speaker mouth, potentially, but for decibel limits testing, the
only types of toys that are exempt from decibel limits testing that
are sound-producing toys are those that are mouth-actuated, where you’re
blowing into the toy to create some noise, those where sound is produced by a child hitting
something, like a xylophone, a bell, or a drum, and then those toys that are squeezed,
where you squeeze and produce a noise. Only those three types of toys are exempted from decibel limits testing
under the new toy standard. Alright, now for the next topic, I’m going
to have you guys take a look at Franky’s neck and the magnets on Franky’s neck. And I’m going to put up the next
question, which is, “Would the magnets in Franky’s neck be subject to
the new magnet soaking test?” Because the results are coming
in, and it’s very close, I’m going to give you guys a little
bit more time to get the answers in. And remember, this is a new
section on the toy standard. So, the magnet soaking test is something
that people may not be familiar with. Alright, it looks like most people
have gotten their answers in. I’m going to go ahead and close the poll,
and then let’s take a look at the results, and see what everybody thought the answer was. So, it looks like just by a little
bit, people thought that the magnets in Franky’s neck would be subject
to the magnet soaking test. Let’s see if you guys are correct. So, the correct answer here is actually no. The magnets in Franky’s neck would
not be subjected to the soaking test. They would only be subject to the
flux density measurement test. Also of note, the magnets have potential
small parts, use and abuse testing. His neck is stiff and could break, so sharp
points and flexure tests would need to be done. But on the soaking test for magnets, in the
new toy standard, that test only applies to three types of toys, which are: wooden toys
that contain a magnet, toys that are intended to be used in water, or mouth-actuated toys
that have magnets or magnetic components. And kind of a way to remember this is they
could easily be exposed to moisture, right? A wooden toy isn’t going to protect a magnet
from moisture exposure, certainly ones that go in water, and a mouth-actuated toy is
exposed to saliva, so there’s a wetness, exposure for the magnet, so the magnet
would be subjected to the soaking test. That’s in Section 8.25.4
of the new toy standard. Alright, now let’s look at
Franky’s pacifier hand. I’m going to put up a question
about his pacifier hand. Now, remember, this is a pacifier that is part
of a children’s toy, so the question here is, “Would Franky’s pacifier hand need to
undergo pacifier testing under 16 CFR 1511?” And the answers are coming in. Thank you to everybody who’s
participating in the polling. The participation level is very
high, so it’s great to see that. I’m going to give you a few more seconds
to get your answers in on the pacifier hand and whether it would be subjected
to pacifier testing. Alright, I’m going to go ahead and close
the poll, and then publish the answers, and we can see what we as a group thought. So, it looks like as a group, you guys thought
that the pacifier hand was going to be, was needing to be tested to the
pacifier standard, which is 16 CFR 1511, even though it’s a pacifier that’s part
of a toy, and not a pacifier by itself. So, let’s see if that answer is correct. You guys are correct. The pacifier on Franky’s hand would need to
meet the pacifier testing in the regulation in 16 CFR 1511, and that testing
includes a heat cycle test, small parts test, and nitrosamine level testing. And because the pacifier itself is plasticized,
it would also need phthalates testing. Alright, now, not another question, but
we’re going to look at Franky’s other hand, which is the projectile toy device,
because, remember, we talked about the fact that there’s some changes
in the projectile toys. So I just wanted to point
out, for Franky’s hand, that the kinetic energy density test
could potentially need to be applied here, if the kinetic energy of that projectile
device is greater than .08 joules, and because we don’t know that, and I
didn’t supply that information to you, I thought it would be a little, little
not nice for me to ask a question if I hadn’t given you all the
information, so just keep in mind that that kinetic energy density test could
need to be applied if it exceeded .08 joules. Again, that is per our agency staff enforcement
discretion decision that I discussed earlier, and that projectile device could be made of
plastic, so it could need phthalates testing. Alright, now, let’s take a look, we’re
going to do a few more questions. Let’s look at Franky’s stuffed torso,
which is a plush outer covering, and let’s, I’m going to put the question up on the
screen, and we’re going to see whether or not you think Franky’s stuffed
torso requires flammability testing in order to meet our agency requirements. Alright, and the answers are coming in. Again, thank you everybody for
how many people are participating. I’m going to give you just a few
more seconds to get your answers in. Alright, it looks like most
of our answers are in. We’re going to going to ahead and close the
poll, and I’m going to publish the results, and we’re going to see what we as a group think. So, it looks like as a group,
we pretty overwhelmingly think that Franky’s stuffed torso would need to undergo flammability testing
to meet our agency requirements. So, let’s see if that answer is correct. It is not correct. Under our agency requirements,
flammability is specifically exempted, and that was per Congress. However, for many of you at testing labs, you
do know that there is a flammability section in the toy standard that is not
mandated by our office, for toys. So, just keep that in mind. Franky’s torso does contain a battery,
so there’s battery-operated toy changes in the toy standard that
could apply to Franky’s torso. Again, it’s stuffed. We talked a little bit about
the testing for stuffing. We need to make sure it’s clean, there’s
no vermin, there’s no sharp objects, non-toxic materials are contained,
and then it’s still a toy, so we still need use and abuse testing. Alright, finally, we’re going to look at
Franky’s feet, and there’s no question here, but I just wanted to talk about the magnets
that are on the bottom of Franky’s feet. So, these magnets, again,
not subject to moisture; as best we know, this isn’t a water toy. So, the magnets would just need to meet
the flux density measurement requirement in the new toy standard, and again, we’ve
got a heavy elements, including lead, lead in surface coatings and
heavy metals concern there, so that portion of Franky’s feet would
need to be tested for heavy elements. And then depending on how they’re
constructed, they could be plastic. We can’t tell from this graphic; there
could be a phthalates testing requirement. So, guys, that’s the end of Franky Toy. I hope you really enjoyed the
audience polling portion of this. Let me talk a little bit
about our business resources. That’s my name: I’m Shelby Mathis. I’m the small business ombudsman. My email address is on your screen. You should feel free to send me an email
with specific questions that you have about the toy standard, or consumer products
in general, testing and labeling requirements. The telephone number that’s on
your screen is a US phone number. It’s area code 301-504-7945, and
that is our business line that rings at both my desk and my colleague Will’s desk. So, you can actually speak to a real, live
person here at a US government agency. For those of you that are so
inclined, you can follow us on Twitter. We’re @CPSCSmallBiz, is our handle, and
the benefit of following us on Twitter is that for things like this webinar, we post
those usually like two weeks in advance, so you can mark a date on your calendar. A few other resources I just wanted to
get through before we do the question and answer session is our regulatory robot. This is an interactive bot that is on
our website, and if you just don’t know where to start, it’s a great place to go. The URL is right below the little
regulatory robot graphic, and it’s a, it is an interactive system that will
ask you a series of questions to try to determine what type of product you’re making. At the end, it will spit out a report that
you can then download and keep yourself that lists labeling and testing
requirements that could apply to the product, based on the answers that you provided. Right below that regulatory robot is a
reference to a desktop reference guide. Many people find them very useful and
keep them posted at their workstation. The desktop reference guide breaks down
consumer products into certain categories and then tells you the labeling
and testing requirements associated with each type of consumer product. Moving to the right-hand side of the
screen, I just wanted to let everybody know, for those of you that are interested
in future webinars, we do, again, plan to do these on a monthly basis. This is our first one, if you want to
keep tabs on what the new topic areas are and what the dates are that are planned,
we send those out via our newsletter, so you can sign up for our
newsletter at cpsc.gov/email. You’ll need to select from the menu
there Small Business Ombudsman Updates. We try to send those out monthly, sometimes
they go out more or less frequently, just depending on what’s going on. It also includes commission actions
that could impact small businesses. And then, finally, to find testing labs, we
talked a lot about changes on the toy standard and what labs and manufacturers and
importers need to do to find a testing lab that can test to this new toy standard. You can go to our lab search
page, and that is on your screen. So, with that, I’m going to
conclude our webinar today. Thank you so much. We had such an outpouring of
interest for this webinar. There is potential that we will
rebroadcast it at another time, but certainly for everyone attending
today, you’re going to receive it by email, and you can review it or
share it as you see fit. And then, lastly, after you close out of this
webinar, a feedback survey is going to pop up on your screen, and it’s four
short questions about whether or not you thought this webinar was useful, and whether the content was
presented in a very clear way. We’re trying to get as much feedback
as we can as a government agency; we want to be more accessible to members of
the public, so if you guys would kindly fill out that feedback survey, it will also
be included in the email to you tomorrow. We would love to get as many
responses there as we possibly can. So, with that, I’m going to conclude this
webinar, and I thank everyone for attending.

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