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Hazard Identification. Susan DeRagon and Haley Will UL / PPAI Product Safety Consultants.
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Hazard Identification Susan DeRagon and Haley Will UL / PPAI Product Safety Consultants
This information is being furnished by PPAI for educational and informational purposes only. The Association makes no warranties or representations about specific dates, coverage or application. Consult with appropriate legal counsel about the specific application of the law to your business and products.
Agenda • Mitigating Your Risk • The Psychology of Human Factors • Anthropometrics • A Forward Look
Industry Concerns • Products are often intended for use by adults, given out at trade shows and workplaces, but end up in the hands of children. • How to determine whether a product is a general consumer product or a children’s product? • Who bears the responsibility for determining if a product is a children’s product?
Product Recalls - Children • Regulatory compliance does not always equal product safety
Product Recalls - Adult • Design hazards cause recalls of adult or general use items as well
CPSC Recommendation “The safety of a product depends upon many factors. One factor is building safety into the product design. The circumstances under which products are used or misused by consumers is another factor. The ability of manufacturers to recognize and anticipate these factors is central to the effective design and production of safe products.”
Risk Reduction • Regulatory requirements • Assure product meets safety regulations • Quality assurance program • Age analysis • Determine the appropriate user • Design evaluation • Evaluate beyond regulatory requirements • Recall and injury analysis • A look at prior data to design in a safe manner • Manufacturing controls • Define and document your expectations
Hazard Identification Tools • Standard Available Checklists • ISO Guide 50 • Canadian Safety Requirements for Children’s Toys
Hazard Identification Tools • Decision Tree • ISO Guide 51 • EU Guidelines for Non-Food • Consumer Products • Top down method of analyzing • a series of foreseeable events
Hazard Identification Tools • FMEA – Failure Mode and Effects Analysis • EU Guidelines for Non-Food Consumer Products • Process of systematically identifying hazards to determine outcome and level of risk
What is Human Factors? • An area of psychology that studies the relationship between people and their environments
Goals of Human Factors • Maximize performance • Enhance user experience • Comfort and fit • Minimize errors • Foreseeable use and misuse • Safety • Injury prevention
Who Can Conduct? • Personnel with specialized skills (i.e. human factors, industrial design, child development) • Internal or external team • Independent from the product designer
When To Conduct? • Concept stage • Sculpt or working model • Engineering pilots • Early production samples
Components of Human Factors Review • Evaluate concept or product for: • Intended and unintended users • Function – foreseeable use and misuse • Design – fit, comfort and size
Children’s Product Determination • Manufacturer’s labeled age grade • Advertising, promotion and marketing • Age group for whom the product is commonly recognized • Age Determination Guidelines issued by the Commission http://www.cpsc.gov/PageFiles/113962/adg.pdf
Foreseeable Use and Misuse • Instructions • Product look and function • Similarity to other products
Design Fit • Anthropometry • Static measurements • Dynamic measurements
Resources • Mandatory & Voluntary Standards • Incident Data • Product Recalls • Age Determination Guidelines • Medical Resources • CPSC Public Database • Anthropometric Data • Hazard Identification Tools • Child Development Resources • Focus Groups & Child Observations • Similar Product Review
A Forward Look • EU Toy Safety Directive • CPSC Reasonable Testing Program • ASTM F15.22 Subcommittee – Emerging Hazards Workgroup • Product Consumer Product Safety Database – Saferproducts.gov
Steps for Hazard Identification • Design the hazard out of the product • Guard or shield against the hazard • Warn against the hazard
Product Safety Resources • PPAI: www.ppai.org • Product Safety powered by PPAI: http://www.ppai.org/inside-ppai/product-safety/ • Consumer Product Safety Commission: www.cpsc.gov, www.recalls.gov • American National Standards Institute: www.ansi.org or www.astm.org • FDA: www.fda.gov • UL: www.ul.com/consumerproducts • Questions? AnneL@ppai.org
Thank you! Questions?