You are production manager for a company that manufactures toy stuffed animals.
ID: 460343 • Letter: Y
Question
You are production manager for a company that manufactures toy stuffed animals. The current stuffing in the manufacturing process has become prohibitively expensive and you have been tasked with finding an alternative stuffing. You have found a new stuffing that is compatible with your assembly line and within the price range set by the company. This new stuffing contains a fiber that may be linked to lung disease if it is inhaled after becoming airborne. You believe that risk can be effectively controlled by using a rayon cloth "second skin" to enclose the stuffing before attaching the outer covering of the animal. The cost of the stuffing and enclosing it in a "second skin" is still within the price range set by the company. Discuss the regulatory issues your company faces if it should choose to use this new stuffing with the "second skin." What federal regulatory agencies would regulate use of this stuffing, what requirements must your company comply with if it uses the stuffing?
Explanation / Answer
Even though the company can get the cheaper option and alternative material for toy stuffing, need to follow Toy safety standards as per federal and International standards. The new material seems to be hazardous and needs to validate through proper testing under these regulations.
Toy safety standards specify the following list as manufactured fiber as stuffing material for toys and need to test the material.
MAN-MADE OR MANUFACTURED FIBERS
Acetate Fiber
Acrylic Fiber
Azlon Fiber
Glass Fiber
Modacrylic Fiber
Nylon Fiber
Nytril Fiber
Olefin Fiber
Rayon Fiber
Saran Fiber
Spandex Fiber
Vinyl Fiber
Polyester Pneumatic
Metallic Fiber
Polyester Fiber
Vinyon Fiber
General background of Toy safety laws in US ASTM F963:
All toys sold in the U.S., regardless of where they are made, must be tested to verify compliance with rigorous U.S. toy safety requirements, including more than 100 safety tests and standards. These standards are shaped by a variety of considerations, including research on child development, dynamic safety testing, and risk analysis. U.S. toy safety requirements are among the most stringent in the world and are widely emulated in other markets around the globe.
A key element of the toy safety requirements in force in the U.S. is the ASTM F963 Toy Safety Standard, under the auspices of ASTM International. This international standard is a mandatory rule for all toys sold in the U.S. and is under continual review by the ASTM Subcommittee on Toy Safety. ASTM International welcomes and encourages participation in the development and review of its standards; those interested in participating in the review of ASTM F963 may visit the ASTM website for information on participation.
ASTMF963 has been recognized by the U.S. Congress, the U.S. Consumer Product Safety Commission (CPSC) and other regulatory bodies around the world as a gold standard for product safety. In 2008, Congress mandated compliance with, and mandatory testing to, the ASTM F963 standard and provided a mechanism for its ongoing oversight by the ASTM Subcommittee on Toy Safety, with the approval of the CPSC.
What la says about the safety:
SEC.106. MANDATORY TOY SAFETY STANDARDS. (a) IN GENERAL.—Beginning 180 days after the date of enactment of this Act, the provisions of ASTM International Standard F963–07 Consumer Safety Specifications for Toy Safety (ASTM F963), as it exists on the date of enactment of this Act (except for section 4.2 and Annex 4 or any provision that restates or incorporates an existing mandatory standard or ban promulgated by the Commission or by statute) shall be considered to be consumer product safety standards issued by the Commission under section 9 of the Consumer Product Safety Act (15 U.S.C. 2058). (b) RULEMAKING FOR SPECIFIC TOYS, COMPONENTS AND RISKS.— (1) EVALUATION.—Not later than 1 year after the date of enactment of this Act, the Commission, in consultation with representatives of consumer groups, juvenile product manufacturers, and independent child product engineers and experts, shall examine and assess the effectiveness of ASTM F963 or its successor standard (except for section 4.2 and Annex 4), as it relates to safety requirements, safety labeling requirements, and test methods related to— (A) internal harm or injury hazards caused by the ingestion or inhalation of magnets in children’s products; (B) toxic substances; (C) toys with spherical ends; (D) hemispheric-shaped objects; (E) cords, straps, and elastics; and (F) battery-operated toys. (2) RULEMAKING.—Within 1 year after the completion of the assessment required by paragraph (1), the Commission shall promulgate rules in accordance with section 553 of title 5, United States Code, that— (A) take into account other children’s product safety rules; and (B) are more stringent than such standards, if the Commission determines that more stringent standards would further reduce the risk of injury of such toys. (c) PERIODIC REVIEW.—The Commission shall periodically review and revise the rules set forth under this section to ensure that such rules provide the highest level of safety for such products that is feasible.
Toy safety standards specify the following list as manufactured fiber as stuffing material for toys and need to test the material.
MAN-MADE OR MANUFACTURED FIBERS
Acetate Fiber
Acrylic Fiber
Azlon Fiber
Glass Fiber
Modacrylic Fiber
Nylon Fiber
Nytril Fiber
Olefin Fiber
Rayon Fiber
Saran Fiber
Spandex Fiber
Vinyl Fiber
Polyester Pneumatic
Metallic Fiber
Polyester Fiber
Vinyon Fiber
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