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Loss of grip due to the narrowness of the craft or its shape ... and medium-sized enterprises, trade, craft industries and consumer affaires suspended the ...
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DEFINITION • Water articles for children do not include armbands, swim-rings, bathing suits or swim-seats, that have been studied by the CSC in a recommendation on buoyancy aid products issued on 7 May 2003. The present recommendation deals with inflatables leisure articles
PETITION • An INTEX-THE WET SET brand inflatable crocodile • A 7 May2003 recommendation on « floating devices » (swimming rings, swim-seats, swiming armbands, floating bathing suits, swimming belts) • The legal framework varies (armbands : PPEs, swimming rings : toys, others : general safety obligation)
ACCIDENTOLOGYIN FRANCE • Study carried out by InVS (Health Monitoring Institute) and the Civil Defence and Safety Directorate of the Ministry of the Interior) from 1 June to 30 September 2003 : • 1154 victims, 435 (38%) deceased • 48,5% of the accidental drownings occured at sea, 14,9% in private swimming pools, 13,5% in lakes, 13,5% in rivers, 5,7% in public swimming pools and 4,1% in other places. • Children under 6 (15,7%) and adults over 45 (42,3%) are most vulnerable • Imposible to determine in what proportion and in what circumstances the accidents occured due to the use of a watercraft (incomplete informations, categories too broad : « water accidents, other…), the present categories refer only to drownings that occured at sea • Very low incidence of accidents : the designers of the study did not identify identical types of watercrafts for all the regions (inaccuracy of the information)
RISK ANALYSIS • It can reasonably be expected that despite or due to lack of parental supervision, a child will at some stage venture with these products into deep wate, surf on large waves, or become exposed to strong currents. .. The use of watercrafts thus constitutes in itself a posbible source of accidents • Causes • Punctures of single air chamber craft • Loss of grip due to the narrowness of the craft or its shape • Inability to move freely if entangled in the craft (crocodile-shaped craft). In 2002, the Minister of State for Small and medium-sized enterprises, trade, craft industries and consumer affaires suspended the marketing of a SURFBIKE brand watercraft (a 12 year-old child died while plaing on a craft composed of a surfboard with a seat, a pedal assemply driving a propeller and a burgee. The craft capsized, the child was unable to break free as his life jacket had become caught on the burgee because of the semi-circular shapes of its handles kept him attached)
STUDIES CARRIED OUT IN EUROPE AND IN THE USA • IN EUROPE - European draft standard. The CEN carried out a risk analysis - Article on drownings published in the January 2002 bulletin of the ISO. Gunther CORNELISSEN : Débate over swim-seats a range of products up until now excluded from the scope of existing regulations : that of inflatable products « overflow group », « grey area ». Articles that involve as many or even more risks than the main product itself. For example : the main product, inflatable boats, the residual product : floating islands, floating chairs, inflatable mattresses… Adequate safety standards in the near future for these « grey area » products are necessary. Target groups : children and young people. The places : beauches, rivers, swiming pools IN THE USA - A significant increase in accidents : 1300 in 1997, 4300 in 2003
HEARINGS • 2 manufacturers : SEVYLOR EUROPE, INTEX • A distibutor of sports and leisure articles : GO SPORT • Fédération of Toy and Child care product industries
REGULATIONS APPLICABLE TO CRAFTS • No well defined category of products allowing for application of a specific regulation. A « very empirical » legal system created by successive interpretative questions to the European Commission • General safety obligation (art. L 221-1 consumer code) in the absence of a specific regulation (couches, armchairs, bars for adults ofr chairs for children) • Regulations on toy safety (12 September 1989 decree transposing into French law the European Directive 88/378/CEE of 3 Mary 1988. • 5th preamble : some products are not to be regarded as toys because they call for supervision or special consideration of use (no literal interpretation by the European Commission, the watercrafts would have been excluded from the scope of the directive : they require close parental supervision and use in shallow water)) • Aquatic equipment intended to be used in deep water expressly excluded for the scope of the directive (Annexe 1,5) • Art. 2 of the decree : toys that meet the essential safety requirements and that bear the CE marking
STANDARDS • The NF EN 71 standard : • Water toys are defined : « articles, inflatable or not, intended to support the weight of a child and used as play accessories in shallow water »,while the toy decree does not define the scope of water toys • The standard excludes from its scope « articles such as inflatable boats which, because of their size and their design, are intended for use in deep water» (informative appendix C. 24) • Had the standard been in accordance with the requirements of the decree (appendix 2,II, 1f), it would have imposed requirements and test methods to protect users against the risk resulting from loss of buoyancy and lack of stability of watercrafts • Standard NF S 50-010 on the rules for marking of inflatable watercraft for children and inflatable mattresses (November 1985) • watercrafts • Inflatable mattresses • The European draft standard on « Inflatable leisure articles »
RESULTS OF THE PRODUCT ASSESSMENT • 23 products were tested in order to evaluate their performance in terms of buoyancy, resistance, design, use risks, product response to inappropriate use, and markings : instructions for use, warnings
RESULTS OF PRODUCT ASSESSMENT - STABILITY • 12 products out of 23 are considered « stable ». • The remainder are either too narrow (mattresses or scooter-shaped or crocodile-shaped objects) or too small for the size of the users of the age range for whom they are intended
RESULTS OF PRODUCT ASSESSMENT – BUOYANCY • Subject to appropriate inflation, the initial buoyancy of the products is satisfactory. But after 24 hours, it decreases by more than 25 % for 16 crafts (inefficacy of the plugs and back flow stop valves). The 6 crafts that were satisfactory are exclusively boats and mattresses. • Shortcomings of the NF S 50-10 marking standard : it only deals with crafts with a buoyancy of at least or less than 2800 N. The difference between a toy and a low price yachting product (rubber boat) not easty to make.But the standard does not indicate a minimum buoyancy value, so it allows products with too low a beary capacity to be marketted. La flottabilité résiduelle après dégonflage de la moitié de chambres à air, devrai dépasser 50% de la flottabilité initiale. • All the products with multiple air chambers were satisfactory on that point. • 3 crafts with only one air chamber were described as « potentially dangerous if their cover gets teared.
RESULTS OF PRODUCT ASSESSMENT – RESISTANCE • Résistance to pressure, perforation and prolonged exposure to the sun : satistactory. • Tensile rupture point for the fabrics, PVC, handles and other accessories attached to the casing : good, but shows a very broad spectrum of values depeinding on the product (from 86 N to 180 N for the fabric, 184 to 791 N for the accessories). No reference text to evaluated these values. The rupture point never occured on a seal. • Abrasion tests : 9 samples of material out of 23 ripped, with constant material removal in the ordrer of 0,20 g regardless of the product. A determining factor of the resistance of watercrafts to wear and tear : the thickness of the PVC more than its intrinsic quality.
RESULTS OF PRODUCT ASSESSMENT – ANALYSIS OF MARKINGS • No watercraft meets all of the marking requirements requested. The markings are partial, sometimes difficult to read, although they resist the main corrosive agents (salt, chlorine, sweat, saliva)/. • 18 bear a CE marking in accordance with their classicfication by manufacturers in the toy category. The 4 others (2 mattresses, a chair and a boat) lack this • Only 2 products have instructions for use, 8 have inflation instructions (although inadequate inflation dangerously decreases their buoyancy). • All of the craft have a certain number of use warnings concerning the dangers of drifting or drowning, but only 10 are in strict accordance with the requirements of standard NF S 50-010 (all the camping mattresses only).
To public authorities : • To remove from water toys and their packaging as of 2005 any falsely reasssuring wording • To check water articles tested within the framework of this report that do not follow the marking rules provided for in the applicable regulations and standards, and to suspend the marketing of products that are not in conformity if necessary • Following additionnal tests done on a case by case basis, to require a modification of the design of products that have only one air chamber • To plan the establishment of a regulation applicable to all water articles that would include watercrafts, flotation aids, inflatable mattresses and floating furniture • To ensure the consistency of existing and future standards, in particular to avoid overlapping of the scope of these standards (toys and inflatable leisure articles) and to avoid that some products would not covered by any standard • To modify the statistical data sheet for drowning accidents (type of article used during the accident) • To involve the CSC in the drowning prevention campaign
To standardidzation authorities • Amendement to the EN 71-1 for its provisions concerning water toys : • To require the presence of back flow stop valves and a minimum of 2 air chambers • Appropriate tests for the resistance of the casing of the products to ripping and abrasion • absence of risks of catching of the child on parts of the craft • Mention on the product the maximum authorised loac in terms of weight and number of people • Future european standard on inflatable leisure articles : • Marking obligation : the products may only be used in shallow water and under the close supervision of an adult
To consumers • To prefer water products with several air chambers (residual buoyancy greater than or equal to 50%) and back flow stop vavles • To always supervise children, even in shallow water • To choose inflatable mattresses with a waide base support (risk of capsizing with a narrow base support) • To only use these products in areas free of currents, waves and strong winds (due regard to tides) • To refrain from using a compressor to inflate the craft, unless there are contrary recommendations from the manufacturer (early wear of the back flow stop valves), and from over inflating the air chambers • To check the efficacy of the back flow stop valve before each use • To avoid dragging such products on the ground (sand, road…) • That adults should not use products intended for children and adolescents without checking that they can bear their weight
THANK YOU ODILE FINKELSTEIN
