Standardization News

Those of us of a certain age fondly remember the simple toys of youth. Hula hoops. Jacks. Silly Putty. All we needed were a couple of friends and someplace to play, and we were all set. The only potential danger? Your dimwit cousin Jerry trying to swallow a marble “just to see what would happen.”

Times, obviously, have changed. Toys have gotten much more complex, with microprocessors, batteries, magnets, and lots of tiny little parts. As toys have evolved, so too have the standards and regulations designed to ensure that these playthings are safe.

One of the key U.S. government actions taken to address the issue of toy safety was the 2008 passage of the Consumer Product Safety Improvement Act, one of the world’s most recognized consumer product laws. Though this legislation addressed safety issues related to a broad range of items, it focused heavily on children’s products, defined as “a consumer product designed or intended primarily for children 12 years of age or younger.” One of the most far-reaching CPSIA requirements is that children’s products be tested for compliance by a CPSC-accredited laboratory, unless subject to an exception. (CPSC is the U.S. Consumer Product Safety Commission, the federal agency that oversees the safety of over 15,000 types of consumer products.)

ASTM’s consumer safety specification for toy safety (F963) is the linchpin of the U.S. effort to ensure that toys comply with this and other provisions of the CPSIA.  It is specifically cited in the legislation as the mandatory consumer product safety rule for all toys sold in the United States. (For a summary, see the fact sheet about the standard.)

As part of the ongoing and continuous process of keeping this crucial standard relevant in an ever-evolving toy market, ASTM recently published a new update: F963-16. “The 2016 edition of the standard incorporates the latest ‘intel’ in children’s product safety, to keep pace with product innovation and with the always-evolving curiosity of kids,” said Joan Lawrence, senior vice president of standards and regulatory affairs at the Toy Industry Association.

Before we look at the updates, let’s take a step back and examine how toy safety has evolved over the years. 

The Ongoing Quest for Safer Toys

Keeping kids safe from harm caused by toys was a concern long before the CPSIA became law. In fact, F963 celebrates its 30th anniversary this year, having been developed long before CPSIA. Moreover, efforts to ensure toy safety go back even further into history.

Lawrence points out that TIA and its industry partners have focused on toy safety since the 1930s.  They spearheaded development of the world’s first comprehensive toy safety standard, unveiled in 1976.
The ASTM International committee on consumer products (F15) used this standard as the basis for F963, introduced in 1986. Since that time, ASTM’s flexible revision structure, open consensus process, and online communication tools have helped people from around the world work together on periodic updates of the standard. This wide range of stakeholders includes what Len Morrissey (the ASTM staffer who supports F15) calls the “holy trinity” of manufacturers, regulators, and consumer groups.

“Given the nature of the toy business, with new products being invented all the time — and because we are focused on the safety of children — the ASTM F963 toy safety standard is subject to an ongoing review process,” says TIA’s Lawrence, who has served as chairman of the F15 subcommittee on toy safety (F15.22) since 2001. “The 2016 revision is the culmination of that review over the past few years. We continually look to identify potential emerging safety issues, new product features, or new ways that toys are being used that may pose a risk to children, as well as existing portions of the standard that may need clarification or alignment.”

Morrissey echoes her point regarding the behavioral side of the safety equation: “Understanding the behavior of children of different ages, and how the toys are marketed to these various age groups, is crucial,” he notes. “The committee focuses more on the way toys perform, rather than solely on design. We look at incident data, the types of injuries kids are getting, and the mechanisms by which they occur.”

This emphasis on identifying potential risks stemming from the way toys are actually used is one of the core strengths of F963. “When a safety hazard is identified, wherever appropriate, the standard is written in a way to mitigate the risk associated with the hazard and the likely use/play pattern — regardless of the type of toy — now or in the future,” Lawrence says. “As such, even with increased product innovation, F963 provides some known protections that always apply, even to products never envisioned when the requirements were written.”

New Toy, Unexpected Problems

Expandable gel balls that dramatically increase in size when immersed in liquid are a good example of the kind of products that can come to the attention of Subcommittee F15.22 through careful and ongoing review of incident reports. Toys and non-toy items (such as florist supplies intended to keep plants hydrated) made of expanding materials could potentially create a safety concern if swallowed. 

These items can be very small in their unexpanded state, ranging in size from about 3 to 10 millimeters. But after soaking in water for several hours some of these products can grow to roughly the size of a racquetball. Anyone ingesting an unexpanded product could develop problems in the digestive tract as the object absorbs liquid and expands.

Further complicating the issue is the fact that these toys and non-toy items can sometimes look to a child like a tasty treat in their unexpanded state.

As more evidence began to surface of the hazard potential of such materials in their various applications, members of Subcommittee F15.22 started discussing ways to address the problem for children’s toys. According to Lawrence, “We ultimately developed new requirements for materials in toys that could expand if swallowed. The tests are designed to limit the amount that these materials can expand over time, to simulate what might happen if swallowed, and to restrict use of such materials that would not be appropriate in children’s toys.”

Batteries, Projectiles, and Heavy Metals

Water-absorbing toys are just one of several product categories impacted by the newly revised standard. Here’s a sampling of some of the other important changes being made.

Battery Safety — A requirement for battery compartment locking mechanisms that make small batteries inaccessible to children has been part of F963 for years. In the 2016 revision, labeling requirements have been added to alert parents and caregivers to the presence of small batteries and the particular hazard posed by mouthing or swallowing certain button cell batteries. Also, issues with lithium-ion batteries (overheating, for example) in cell phones and computers led the subcommittee to add temperature and current-limiting requirements to prevent such problems in toys that may use lithium-ion technology.

Toys Involving Projectiles — As with water-absorbing products, incident report data led to a change in this portion of the F963 standard. The data showed that most injuries related to suction cups (often a part of projectile-related toys) occurred when children were chewing on the shaft portion of a dart with a suction cup tip. The data also showed that in the majority of cases, the darts actually met the then-current standard that projectiles be no smaller than the widely accepted small-parts testing cylinder, a key tool to evaluate toys for choking hazards under F963. The revision of the standard adds an additional 57 mm length requirement to align with the European standard and to further reduce the possibility of injuries.

Microbiological Safety — Aimed specifically at cosmetics and similar materials such as liquids, pastes, and gels intended for dress-up play (or for use in or on a toy or doll) the changes update existing requirements and test methods designed to measure the cleanliness of such products and reduce the likelihood of degradation or contamination. The revised standards also allow use of microbiology guidelines from the Personal Care Products Council, which are widely used to test adult cosmetics.

Heavy Elements in the Substrate Materials of Toys — Lead and seven other heavy metals (antimony, arsenic, barium, cadmium, chromium, mercury, and selenium) have been restricted in the surface coatings of toys for many years.  They have also been restricted in the substrate materials of toys since 2008 (for lead) and 2011 (for the others). As a result, heavy elements are not commonly found in toys and are not intentionally added to them; however, because these elements do occur naturally in the environment, the standards are important to ensure toys are not inadvertently contaminated. Changes in the latest version of the standard seek to improve the clarity of the substrate section of the standard, and allow an alternate test procedure, but do not change the requirements.

Other modifications reflected in F963-16 include new rules for ride-on toys — a curb impact requirement, clarification of overload and stability requirements, and a strap-length exemption for seat harnesses — and clarifications to other technical requirements for more consistent interpretation and understanding among stakeholders.

Refinements, Not Overhauls

Sometimes, when an ASTM standard is updated, it reflects a major new development in product performance, material science, or testing technology. However, most of the revisions to F963 focus on subtle refinements to existing requirements, helping clarify and improve understanding, Lawrence says. “This serves as evidence of the commitment and expertise of the subcommittee as well as the continued relevance and efficacy of this well-regarded standard,” she adds.

Under the CPSIA, changes made to F963 are reviewed by CPSC on publication. CPSC has 90 days to review the changes and decide if they do not improve safety, in which case they are not approved by the agency for incorporation into mandatory rule. Otherwise, the revised standard becomes mandatory 180 days after publication.

Jack Maxwell is a freelance writer based in Westmont, New Jersey.