We are really pleased to welcome Amy, a product safety officer for a large company, which deals with various items, including toys, as our guest blogger this week! (our very first!)
Today’s guest blog is all about risk assessments, and the importance of doing them before testing your toy. Its so easy to see it as a box ticking exercise, but really its the start of it all and a place to consider the design and where things could go wrong. (remember all those design and evaluation sheets in design technology at school?! Its not much different!)
Thank you Amy!
It’s very easy to fall into the mindset that testing is everything and if your toy passes the tests then it’s bound to be safe right? Wrong! A risk assessment of your toy is absolutely a must and arguably just as important if not more so than the testing. What better way to demonstrate this than with an example of just how important assessing your toy is.
Some time ago, a well-known retailer imported some soft toys from their suppliers in the Far East. The retailer did all that was required, tested all the toys to the EN71 standard and put together a technical file. The soft toys all had cotton wool-like pom poms on them and when the soft toys arrived, it was found that they had been glued on with a hot glue gun rather than sewn on. The retailer was obviously concerned as these pom poms could be a serious choking hazard if they came away from the toy. But after much deliberation and the fact that these toys had apparently passed all the tests, they decided to sell the toys.
After a couple of weeks of the toys being on sale, a serious complaint was made, and a pom pom had come off in a baby’s mouth. Luckily the parents were there to remove the pom pom before any serious damage had been caused. This sparked a series of investigations and the retailer confided in their consultants and the test labs. It turned out there’s a loop hole in the EN71-1 standard. When the lab did the pull test at 90N, the pom pom was excluded from being tested to EN71-1 Clause 5.1 as ‘fabric’ is exempt. The reason for this is the pom pom was more like a cotton wool ball so not filled with another material. If the pom pom was ‘soft-filled’ then it would’ve been considered. After this was discovered, it was decided to recall all the soft toys.
Even though a risk assessment was carried out, it wasn’t thorough enough to take into account the abuse that the pom pom would take and add into the equation that the test lab never even tested it because of the fabric exemption and it’s a recipe for a disaster!
The moral of the story here is really think about what it is that you will be selling to the public. You need to assess the risk of injury by considering the hazards, the environment and foreseeable use.
For example, any toy aimed at young children is likely to be put in their mouth whether you intended that or not. Are there any parts that are likely to come off, what about the varnish on your wood, is that toxic? Think about how children play, they tend to really abuse the poor toys. Despite what your test results say, is there anything else that you can think of that should be considered?
Once you have assessed your toy and found out the risks, you need to eliminate as many as possible. Do you really need that pom pom on there, is it worth the risk of injury?
When it comes down to it, you should take all reasonable steps and exercise all due diligence. This means it is up to you and only you to make sure that your toy is safe. That risk assessment will go a long way to helping you do just that.