ASTM F963 Upcoming Changes - Toy Industry … · ASTM F963 Upcoming Changes Alan P. Kaufman Senior...
Transcript of ASTM F963 Upcoming Changes - Toy Industry … · ASTM F963 Upcoming Changes Alan P. Kaufman Senior...
ASTM F963 Upcoming Changes
Alan P. Kaufman
Senior Vice-President, Technical Affairs
Toy Fair Toy Safety Seminar
New York – February 16, 2015
2 Toy Fair Toy Safety Seminar | New York February 2015
ASTM F963-11 Status
Published by ASTM December 2011 Endorsed by CPSC by unanimous vote March
2012 Became mandatory rule June 2012 Third-party testing and certification
required for products within scope of the standard
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Changes to F963-11
Heavy elements-addition of substrate requirements and compositing procedure. Standard essentially aligned with both EN71 (previous version) and ISO 8124, except that F963-11 contains the additional 24-hour cadmium and CPSIA total lead requirements
Addition of design guidelines for bath toy projections
Miscellaneous technical changes-spherical/nearly spherical ended toys; plastic film; jaw entrapment; stability/overload of ride-on toys and seats; yo-yo balls; acoustics
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F963-11 Heavy Elements
Updated to add CPSIA lead limits-90ppm for surface coatings/100ppm for substrates
Extends soluble element limitations to substrates (previously applied only to surface coatings)
Adds option of total screen to demonstrate compliance with soluble limits
Adds test methods for substrate testing Adds 24-hour cadmium migration test for metallic small parts; 200ug
maximum extraction limit Adds compositing procedure-compositing up to three samples
explicitly allowed for total element testing With the above changes, F963-11 now contains one of the most
comprehensive toy heavy element standard worldwide Standard essentially aligned with both EN71 (previous version) and ISO
8124, except that F963-11 contains the additional 24-hour cadmium and CPSIA total lead requirements
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Anticipated ASTM F963-15 Revisions
Magnets: Changes to align with ISO 8124 and EN71-add soaking test and compression test; change gaussmeter specs, specify metal disc; other misc changes
Projectiles: Changes to align with ISO 8124 and EN71-allowable KED now 2,500 J/m2 ; add 57mm length requirement for suction-cup projectiles; additional mouth-actuated toy requirements; foam dart and suction cup requirements; use of gauge for leading edge radius measurements of rigid projectiles; other miscellaneous changes
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Anticipated ASTM F963-15 Revisions (cont)
Batteries: Coin/button cell batteries: additional
labeling Lithium batteries-add temperature/current
requirements Adding definitions for secondary cell and
rechargeable batteries Microbiological safety: Requirements
clarified and defined; alternative methods (CTFA) allowed
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Anticipated ASTM F963-15 Revisions (cont)
Heavy Elements – largely clarifying amendments; WG is considering addition of HD-XRF for total screen in polymers
Impaction/Squeeze toy clarifying changes
Acoustics-partial alignment with EN71; push-pull toy definition;
Stuffing cleanliness: test method simplified
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Anticipated ASTM F963-15 Revisions (cont)
Cords and Elastics – miscellaneous clarifying changes
Miscellaneous changes: Strap exemption for ride-on toys; curb impact for ride-on toys; further clarify overload and stability requirements for ride-on toys; clarify non-powered scooters excluded from scope (ASTM F2264)
Expanding materials Toy Chests
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Thank You
Thank you for your attention Alan P. Kaufman
Senior Vice President for Technical Affairs
Toy Industry Association, Inc.
1115 Broadway, Suite 400, New York, NY 10010
Office: (646) 520-4868 | Fax (212) 633-1429 | Email: [email protected]
Our Website: www.toyassociation.org
Toy Safety in Canada and the United States
Regulatory Overview, Updates, and Cooperation
Note: Presentation Available for Download: www.slideshare.net/USCPSC
VIEWS EXPRESSED IN THIS PRESENTATION ARE THOSE OF THE STAFF AND DO NOT NECESSARILY REPRESENT THE VIEWS OF THE COMMISSION OR HEALTH CANADA.
TODAY’S PRESENTATION
• Provide an overview of consumer product safety legislation and authorities in both jurisdictions
• Provide brief highlights of what’s new at CPSC and Health Canada
• Review key requirements for industry
• Highlight regulatory cooperation initiatives in North America
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CONSUMER PRODUCT SAFETY LEGISLATION IN CANADA AND THE
UNITED STATES
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KEY LEGISLATION
Canada Consumer Product Safety Act (CCPSA) • Addresses dangers to human health or safety that are posed by
consumer products in Canada, including those that circulate within Canada and those that are imported. • “General Prohibition” against the supply of consumer products that pose a
danger to human health or safety • 32 regulations, including several relevant to toys • No premarket certification requirements under CCPSA
• Onus is on suppliers to ensure products they bring to market comply with the Act and its regulations.
• Establishes responsibilities for manufacturers, importers, advertisers, and retailers of consumer products, including:
• Mandatory Incident Reporting • Record-keeping to allow traceability of products within the distribution
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KEY POWERS AVAILABLE TO HEALTH CANADA
• Issue public communications • Order suppliers to conduct tests or studies on a product to
verify compliance • Order suppliers to stop manufacturing, importation, sale, etc.
of a product • Order suppliers to carry out recalls and to take other
corrective actions • Prosecute criminal offences or apply Administrative Monetary
Penalties • Seize product, documents or materials • Disclose personal or business information necessary to
identify or address a serious danger to human health or safety
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KEY LEGISLATION
Consumer Product Safety Improvement Act (CPISA) • Manufacturers and importers must third party test and
certify children’s products to ensure products they bring to market comply with the Act and regulations.
• The act made the toy safety requirements in ASTM F963 mandatory
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WHAT’S NEW?
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WHAT’S NEW AT HEALTH CANADA
• In April 2014, Health Canada’s Minister announced its Regulatory Transparency and Openness Framework.
• An Action Plan for 2014-2015 is featured on the Health Canada website and includes 15 activities that focus on providing timely, credible and understandable health and safety information. Consumer Product Safety Program related activities under the action plan of interest to business include:
– Posting the Consumer Product Safety Risk Assessment Framework – Posting Quarterly Consumer Product Safety Incident Report Summaries – Posting Consumer Product Enforcement Summary Reports
• The website features a feedback button for Canadians and stakeholders to submit their comments pertaining to transparency and openness.
• Health Canada has committed to reporting annually on what is achieved in each fiscal year.
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WHAT’S NEW AT HEALTH CANADA
• On April 3, 2014, Health Canada published regulations amending Schedule 2 to the Canada Consumer Product Safety Act (CCPSA) to prohibit tris (2-cholroethyl) phosphate (TCEP) in certain products.
• As per item 16, Schedule 2 to the CCPSA, products that are made, in whole or in part, of polyurethane foam that contains TCEP and that are intended for a child under three years of age are prohibited.
• This prohibition came into force on October 23, 2014.
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WHAT’S NEW AT CPSC
• Notice of Proposed Rulemaking Prohibiting Children's Toys and Child Care Articles Containing Specified Phthalates – Based on Chronic Hazards Advisory Panel report to CPSC – Proposes banning 5 phthalates in addition to phthalates
already banned in CPSIA in concentrations greater than 0.1%
• Potential Ways to Reduce Third Party Testing Costs Consistent with Assuring Compliance – $1M being spent in 2015
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REQUIREMENTS IN CANADA AND THE UNITED STATES
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CANADIAN SAFETY REQUIREMENTS FOR CHILDREN’S TOYS
• The main regulation in Canada is the Toys Regulations (SOR/2011-17)
- The Toys Regulations is the new title for the previous Hazardous Products (Toys) Regulations that were in place from 1970 to 2011 under the Hazardous Products Act.
• The Toys Regulations set out mandatory safety requirements that address a wide range of mechanical, flammability, toxicological, electrical, thermal and other hazards associated with children’s toys (http://laws-lois.justice.gc.ca/eng/regulations/SOR-2011-17/index.html).
• Several other regulations under the CCPSA may also apply to a specific toy, depending on the toy’s design, construction, contents and, in some cases, how it is marketed.
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TESTING TOYS FOR SAFETY - CANADA • In Canada, provincial and territorial legislation requires that electric toys must bear
a compliance certification mark from a certification body accredited by the Standards Council of Canada.
- The certification mark indicates that the toy has been tested and meets all relevant requirements under the Canadian Electrical Code.
• No other test or certification requirements are mandatory under the CCPSA for toys.
• However, testing a toy against the requirements under the CCPSA is the only way to verify compliance.
• Health Canada urges industry members to complete compliance testing before a toy is placed on the market in Canada.
• Instructions for obtaining Health Canada’s test methods: www.hc-sc.gc.ca/cps-spc/prod-test-essai/index-eng.php
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TOY SAFETY – HEALTH CANADA ENFORCEMENT
• Health Canada carries out regular compliance and enforcement projects where toys on the Canadian market are sampled and reviewed. • Suppliers can be asked to provide product tests or studies to verify
compliance. • Health Canada may conduct compliance testing.
• Health Canada investigates complaints and incident reports related to toy safety. • If a toy is found unsafe, or if a toy is found to violate a requirement, then
Health Canada will take action to protect the public. • This action can include product recall, seizure and prosecution.
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U.S. REQUIREMENTS
• Requirements in the CFR have been in effect since the 1970s
• CPSIA included the requirements of the CFR in ASTM F963, mandatory since 2008
• New changes to ASTM F963 are incorporated into regulation via Commission vote
• www.cpsc.gov/BusinessEducation
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• CPSC has ongoing enforcement programs and partnerships with Customs and Border Protection for imports
• Individual claims are investigated by the Agency
• Injury Data from hospitals are monitored
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US TOY ENFORCEMENT
U.S. REGULATED PRODUCT TESTING
• Three different divisions conduct regulated product testing – Mechanical – Electrical and Flammability – Chemistry
• Timing; Import samples • Priorities
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A FEW HIGHLIGHTS ON US/CANADA REQUIREMENTS…
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Head*: • Heavy Elements, including lead, in Surface Coating Materials– ASTM F963 section 4.3 outlines the
toxicology requirements for Antimony, Arsenic, Barium, Cadmium Chromium, Lead, Mercury, Selenium- US limits to not more than 100ppm
• Phthalates –Plasticized components of toys must be tested to demonstrate compliance with the phthalates limitations currently in effect.
• Hard Eye & Nose Attachments – depending on age determination, these features could be subject to a Torque and Tension test up to 15 lbs of force…small parts?
• Flashing- Most plastic flashing cannot be classified as a sharp edge, however the toy may be classified as a defect.
Torso*: • Stuffing – US requires that stuffing be clean, no
vermin, no sharpness, non-toxic • If the batteries are found to be accessible, they will
be subject to ASTM F963 section 4.25 • Seam strength test (16 CFR 1500.51) • Flammability (F963 4.2) is NOT a requirement for
CPSC testing per Congress
Hand, Pacifier*: Pacifiers – US specifies requirements for pacifiers in 16 CFR 1511, nitrosamines
Mouth: Sound – US specifies 85 dB LAeq and 115 dB LCpeak limits measured at 50 cm for this particular toy (ASTM F963 4.5)
Hand, Projectile Device*: Projectiles – ASTM F963 section 4.21
Feet*: • Hazardous magnets would be determined by ASTM F963 section 4.38 • Any material intended for children less than 6 years of age, that is, all
accessible parts and components where there is a probability that those parts and components may come into contact with the mouth are subject to the Heavy Elements requirements of ASTM F963 section 4.3
Neck Bolts*: • Small Parts – (16 CFR 1512) The same small parts
cylinder is used on both sides of the border • A flexure test could be applied (16 CFR 1500.51) if
the wire holding the head still could produce a sharp point
• Hazardous magnets would be determined by ASTM F963 section 4.38
*Product may be subject to additional requirements in the CPSIA and other CPSC requirements. www.cpsc.gov/BusinessEducatio
Head*: • Surface Coating Materials - Canada specifies limits for certain heavy elements & prescribes
specific test parameters. Seven regulated heavy elements: lead, mercury, antimony, arsenic, cadmium, selenium and barium (Toys Regulations, section 23).
• Lead (substrate) – Canada limits total lead content to not more than 90 ppm in toys for children under 3 years of age (Consumer Products Containing Lead (Contact with Mouth) Regulations, section 2).
• Phthalates - If material is vinyl Canada specifies limits for certain phthalates (Phthalates Regulations, sections 3 and 4).
• Flammability – In Canada the hair must not flame with a 1-second flame impingement or must self-extinguish in 2 seconds with flame removal (Toys Regulations, section 34).
• Hard Eye & Nose Attachments – Canada requires that each hard eye or nose component must not be grippable or must not detach when a 9 kg weight is freely suspended from it for 5 minutes (Toys Regulations, section 31).
• Flashing – a sharp edge must not be present after RFU testing (Toys Regulations, section 10(a)).
Torso*: • Flammability – In Canada the outer covering,
including clothing, must have a flame spread time greater than 7 s (1 s flame impingement, 45°) (Toys Regulations, section 32).
• Stuffing – Canada requires that stuffing be clean, no vermin, no sharpness, non-toxic and non-irritant (Toys Regulations, section 29).
• Stuffing – Canada does not allow plant seeds (regardless of toy’s age grade) (Toys Regulations, section 35).
Hand, Pacifier*: • Pacifiers – Canada specifies
requirements and tests for pacifiers in the Hazardous Products (Pacifiers) Regulations).
• In Canada, the Phthalates Regulations, Consumer Products Containing Lead (Contact with Mouth) Regulations also apply.
Head*: Sound – Canada specifies a 100 decibel limit (LAFmax) measured at an ordinary use distance from the user's ear (Toys Regulations, section 19) an ordinary use distance of 15 cm is applied for hand held toys such as this.
*Complete details are provided in the Canada Consumer Product Safety Act and its associated Regulations.
Hand, Projectile Device*: Projectiles – Canada specifies that projectiles capable of causing a puncture wound must have a protective tip (Toys Regulations, section 16).
Feet*: • Flammability – In Canada the outer covering, including clothing, must have
a flame spread time greater than 7 s (1 s flame impingement, 45°) (Toys Regulations, section 32).
• Small, Powerful Magnets – In Canada there is no specific regulatory requirement. The general prohibition for products that pose a danger to human health or safety is applied where a magnet or a magnetic component is loose or separable, small and powerful (Canada Consumer Product Safety Act, sections 7 & 8).
Neck Bolts*: • Small Parts – Canada specifies that small separable parts
are not allowed in toys likely to be used by children under 3 years of age (Toys Regulations, section 7). The same small parts cylinder is used on both sides of the border. Canada can apply a 4.45 N force to test if a small part can be totally enclosed in the cylinder.
• Small, Powerful Magnets – In Canada there is no specific regulatory requirement. The general prohibition for products that pose a danger to human health or safety is applied where a magnet or a magnetic component is loose or separable, small and powerful (Canada Consumer Product Safety Act, sections 7 & 8).
WORKING TOGETHER
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BILATERAL COOPERATION CANADA - US
• Although requirements between Canada and the United States vary, we share the goal of safe products, including safer toys, in the North American market.
• We schedule periodic calls to exchange technical information and best practices. • We work together to share information on new hazards and to develop proposals for
risk mitigation (e.g. public education, regulation or standards development).
• We regularly align efforts to announce Joint Canada-US Recalls (302 bilateral recalls between 2009 and 2014).
• Technical staff from both agencies participate on ASTM Subcommittee F15.22 on Toy Safety (ASTM F963). 23
NORTH AMERICAN COOPERATION ON CONSUMER PRODUCT SAFETY
• North America Free Trade Agreement has fostered the need for greater cooperation between Canada, United States, and Mexico.
• In 2011 Health Canada, CPSC and Mexico’s Profeco established a mechanism for enhanced collaboration on consumer product safety at the first Consumer Product Safety Summit in Bethesda, Maryland.
• The Cooperative Engagement Framework was updated and renewed at the
second Consumer Product Safety Summit in Ottawa, Canada in 2013.
• The Third North America Summit will be held in Mexico City, hosted by
Profeco in 2015.
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ACTIVITIES UNDER THE FRAMEWORK 1) Consumer Outreach
• Coordinated joint consumer outreach activities and campaigns: – Campaign on Sports Safety timed with FIFA World Cup (2014); Poison Prevention (2013);
Toy Safety (2014)
2) Industry Outreach • Joint presentations to highlight product safety requirements at key industry events
– ICPHSO (2014); Las Vegas ABC Kids Fair (2014)
3) Utilization of the XRF (X-Ray Fluorescence) Analyzer • Sharing technical information on current practices, product analysis and reference levels for
the XRF analyzer to screen for heavy metals in toys and children’s products
4) Customs Communications Work for Enforcement Purposes • Composed of product safety staff and customs officials • Identification of opportunities for enhanced communication, information sharing and actions
related to potentially dangerous consumer products at points of entry for the three jurisdictions
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JOINT RECALLS: CRITERIA
• Product sold in at least 2 or all 3 countries • Product must also be under the jurisdiction of all
agencies • Corrective measures and customer support
extended to customers in affected countries • Timing works for regulator and company • Have agreement from company to share all
information with both jurisdictions early in the process
• Recall is conducted voluntarily
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Joint Recalls JOINT RECALLS
Conclusion
• Though consumer product safety requirements may vary, we share the goal of safe products in the North American market
• We are working together to align where possible and collaborate on a range of activities, including recalls.
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KEY RESOURCES Health Canada www.healthcanada.gc.ca/cps www.healthcanada.gc.ca/reportaproduct www.hc-sc.gc.ca/cps-spc/pubs/indust/index-
eng.php www.hc-sc.gc.ca/ahc-asc/media/advisories-
avis/index-eng.php Consumer Product Safety Commission www.cpsc.gov/BusinessEducation www.cpsc.gov/DesktopGuide www.cpsc.gov/Testing www.cpsc.gov/DurableInfantProducts
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THANK YOU / MERCI
Ghislain Boucher Consumer Product Safety Program
Health Canada [email protected] John Massale Mechanical Engineer, Office of Laboratory
Sciences U.S Consumer Product Safety Commission
Health Canada
United States Consumer Product Safety Commission
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For Official Use Only
Toy Fair 2015
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Born of Necessity
Federal agencies with authority governing the safety of products imported into the United States acknowledge the need to share information about the safety of those products
In response to this need, the Department of Homeland Security (DHS) established the Commercial Targeting and Analysis Center (CTAC)
CTAC is a multiagency fusion center which targets commercial shipments that pose a threat to the health and safety of American consumers
The center functions to:
Enhance information sharing Increase automation Expand interagency partnerships
CTAC exemplifies how working together as one U.S. Government at the Border serves to protect the American public
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CBP hosts ten federal agencies at the CTAC: Partner agencies have signed a collective Memorandum of
Understanding to share information and systems access Other appropriate federal agencies may be added to CTAC in the
future
FSIS APHIS EPA PHMSA
NHTSA HSI NOAA CPSC
Interagency Collaboration
FDA
FWS
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CTAC employs a six-step import safety risk mitigation process
Qualify
Target
Examine
Evaluate
Identify
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5
3
1
2
Methodology
Report 6
5
Import Safety Risk
Trade Intelligence
Product Recalls
Port Seizures
Import safety risk is identified through a number of channels
Lab Samples e-Allegations
New Regulations /
Laws
Identifying Import Safety Risk
Qualify
Target
Examine
Evaluate
Report
Identify
6
4
5
3
1
2
6
Trade Intelligence
Qualify
Target
Examine
Evaluate
Report
Identify
6
4
5
3
1
2
trade in·tel·li·gence ~ Information regarding a regulated commodity that may result in an enforcement action or enable the flow of legitimate trade.
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PHMSA
CPSC
NHTSA
EPA
Overlapping agency authorities are leveraged to prioritize high risk commodities
Aligning Product Risk and Authorities
Qualify
Target
Examine
Evaluate
Report
Identify
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4
5
3
1
2
8
Qualify
Target
Examine
Evaluate
Report
Identify
6
4
5
3
1
2
Leveraging a National Mandate
National targeting capabilities enable CTAC to remain agile in addressing import safety risk across
all ports of entry
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Qualify
Target
Examine
Evaluate
Report
Identify
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4
5
3
1
2
Managing Import Safety Risk
Lower Risk
Medium Risk
Higher Risk
Violations of Federal safety standards
A combination of entity-specific targeting, national operations and national programs are utilized to address import safety risk
Counterfeits
Trade Intelligence
Unknown Entities
Inherent Risk of Product
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Cargo exams are performed nationwide by CBP Officers, in conjunction with partner agency field resources as appropriate
CTAC-initiated exams account for less than 3% of total trade cargo exams
CTAC aims to provide a consistent workflow to ports of entry
Examining Targeted Cargo
Qualify
Target
Examine
Evaluate
Report
Identify
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4
5
3
1
2
National Operation Exam Totals (by month)
0
50
100
150
200
250
300
350
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
2011
2012
2013
2014
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Qualify
Target
Examine
Evaluate
Report
Identify
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4
5
3
1
2
CTAC currently utilizes targeting data from partner agencies
Evaluating Targeting Results
Automated Targeting System Automated Commercial
Environment Automated Commercial System Seized Asset and Case Tracking
System
Import Alert Tracking System Automated Import Information
System Public Health Inspection System
CPSC
Agriculture Quarantine Activity System
FSIS
CBP
Integrated Field System Import Examination Logbook
APHIS
MARCS ORADSS CMS
FDA
FWS
Law Enforcement Management Information System
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News Releases
CTAC takes a diversified approach to reporting data and communicating with internal and external stakeholders
Reporting
Qualify
Target
Examine
Evaluate
Report
Identify
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4
5
3
1
2
External
CBP Publications
Speaking Engagements
Internal
Weekly Updates
Targeting Reports
Seizure Alerts
CBP Partner Agencies Congress Trade Community Media General Public
Articles & New Releases
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CEE– CTAC Strategic Interaction
Interagency partnerships at CTAC increase visibility across the regulatory landscape to improve effectiveness and reduce
duplicative efforts
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International Coordination
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Your toy shipment stopped? What you can do
STEP 1: Email Toy Industry Association (TIA)-Ms. Rebecca Mond ([email protected]) STEP 2: Provide TIA with the following information:
Who: Your Importer Name What: Entry number of held shipment, When: Date shipment was stopped, Where: Port shipment was stopped at, and Why: Reason given for shipment being stopped.
STEP 3: TIA will forward this information to CBP. STEP 4: CBP will review information and respond promptly.
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Got Trade Intelligence? What you can do
STEP 1: Email Toy Industry Association (TIA)-Ms. Rebecca Mond ([email protected]) STEP 2: Provide TIA with the following information:
Who: Name(s) of companies involved, What: Product description, When: Date of suspected violation, Where: Location of company (city/state/country), and Why: Description of the suspected safety violation.
STEP 3: TIA will submit to CBP via e-Allegations: https://apps.cbp.gov/eallegations/ STEP 4: CBP will review information and respond promptly.
Avoiding the Pitfalls That Could Delay Release
File the Entry (CBP form 3461) early. Some issues may often be resolved prior to cargo arrival.
Carefully file the Entry data. Ensure all information is complete and accurate.
Ensure goods are classified appropriately.
Ensure the Manufacturer ID accurately portrays the actual foreign manufacturer of the product (avoid
using MIDs associated with distributors and/or forwarders).
Include product detail on the invoices.
Make certificates readily available.
Ensure the correct citation to each CPSC product safety regulation or statutory requirement to which
the product is being certified on the certificate.
Make sure 3rd party testing body is accredited by CPSC.
Purchase from reputable sources (foreign manufacturers and suppliers).
This information was prepared by CPSC staff and has not been reviewed, or approved by, and may not reflect the views of the Commission.
COMMERCIAL TARGETING AND ANALYSIS CENTER
European Update
Alan P. Kaufman Senior Vice-President, Technical Affairs
Toy Fair Toy Safety Seminar
New York – February 16, 2015
2 Toy Fair Toy Safety Seminar | New York February 2015
Revised TSD History
Physical requirements became effective July 2011
Chemical requirements became effective July 2013
Expanded heavy element testing from eight elements to 19
Set differing limits for liquid/sticky materials, scraped-off materials, and dry, powder-like or pliable materials
Prohibition of CMR substances above defined limits
3 Toy Fair Toy Safety Seminar | New York February 2015
Revised TSD History (cont)
Required safety assessment as part of technical file, including chemical safety assessment
Defined responsibilities of various “economic operators”
No requirement for third-party (or any other) testing, but technical file must provide substantiation of compliance
Certificate of conformity required
4 Toy Fair Toy Safety Seminar | New York February 2015
Significant Developments Post-TSD Revision
German attempt to enforce limits differing from TSD for barium, lead, antimony, arsenic, mercury, nitrosamines, nitrosatable substances-essentially dead –European Court of Justice decision
EC proposal to tighten lead limits-rejected by member states
SCHER decision to recommend to EC to tighten Chromium VI limits-reduced by factor of 25
Nitrosamines/nitrosatable substances limits
5 Toy Fair Toy Safety Seminar | New York February 2015
Significant Developments Post-TSD Revision (cont)
Limit for BPA from EN71-9 added to TSD –Effective December 2015
Proposed restrictions on BIT, phenol, CMI/MI rejected by member states-will likely return in revised form as separate directives
Formamide limit in foam mats French TRIMAN labeling effective
January 2015
6 Toy Fair Toy Safety Seminar | New York February 2015
Likely Future Developments
More restrictions on specific CMRs “Endocrine disruptors” – EC being sued
by Sweden and European Council to force proposal for designation of these substances
Nanomaterials-EC consultation; NGO pressure to approach these substances in a unique manner
Toy Regulation Update Gulf Cooperation Council Countries
Alan P. Kaufman
Senior Vice-President, Technical Affairs
Toy Fair Toy Safety Seminar
New York – February 16, 2015
8 Toy Fair Toy Safety Seminar | New York February 2015
Revised Registration Requirements
“G” Mark requirement has existed for some time
Requires application of conformity mark Proposed change requires individual
registration of each sku, to be renewed annually
“G” Mark label must display registration number
Significantly increased burden on importers
9 Toy Fair Toy Safety Seminar | New York February 2015
Additional issues
Some GCC localities not accepting labeling; Gulf Standards Organization confirms these are acceptable if reasonably permanent
Inconsistent Enforcement across GCC
10 Toy Fair Toy Safety Seminar | New York February 2015
Thank You
Thank you for your attention Alan P. Kaufman
Senior Vice President for Technical Affairs
Toy Industry Association, Inc.
1115 Broadway, Suite 400, New York, NY 10010
Office: (646) 520-4868 | Fax (212) 633-1429 | Email: [email protected]
Our Website: www.toyassociation.org
Toy Safety Update in conjunction with American International Toy Fair
State Issues Trends Impacting Toys and Other Children’s Products:
Ingredient Disclosure
Sustainable Design
End-of-life Management
Online Privacy for Minors
Toy Safety Update in conjunction with American International Toy Fair
Ingredient Disclosure Reporting programs Existing state laws:
Washington State “Children’s Safe Products Act”
Maine “Safer Chemicals in Children’s Products” Program
Vermont Chemical Disclosure Program for Children’s Products
Labeling programs Existing state law:
California Proposition 65
Toy Safety Update in conjunction with American International Toy Fair
Sustainable Design Product Materials
Green Chemistry
Life-cycle assessments
“Safer” Alternatives/Material Substitutions
Existing state law: California Safer Consumer Products Program
Packaging Recycled Materials
Source reduction
Existing state law: California Rigid Plastic Packaging Container Program
Toy Safety Update in conjunction with American International Toy Fair
End-of-life Management
Batteries Electronic Waste Packaging Plastics
Toy Safety Update in conjunction with American International Toy Fair
Online Privacy for Minors Online Advertising Do not track Minor’s personal information & content Mobile Apps Existing state laws: California
Toy Safety Update in conjunction with American International Toy Fair
Thank You
Jennifer Gibbons Senior Director of State Government Affairs [email protected] 646-512-1320