Hazard Identification

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Hazard Identification
Susan DeRagon and Haley Will UL / PPAI Product
Safety Consultants
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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.
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Agenda

• Mitigating Your Risk
• The Psychology of Human Factors
• Anthropometrics
• A Forward Look

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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 childrens product?
• Who bears the responsibility for determining if a
  product is a childrens product?

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Product Recalls - Children

• Regulatory compliance does not always equal
  product safety

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Product Recalls - Adult

• Design hazards cause recalls of adult or general
  use items as well

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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.

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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

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Hazard Identification Tools

• Standard Available Checklists
• ISO Guide 50
• Canadian Safety Requirements for Childrens Toys

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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

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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

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What is Human Factors?

• An area of psychology that studies the
  relationship between people and their environments

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Goals of Human Factors

• Maximize performance
• Enhance user experience
• Comfort and fit
• Minimize errors
• Foreseeable use and misuse
• Safety
• Injury prevention

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Who Can Conduct?

• Personnel with specialized skills (i.e. human
  factors, industrial design, child development)
• Internal or external team
• Independent from the product designer

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When To Conduct?

• Concept stage
• Sculpt or working model
• Engineering pilots
• Early production samples

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Components of Human Factors Review

• Evaluate concept or product for
• Intended and unintended users
• Function foreseeable use and misuse
• Design fit, comfort and size

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Childrens Product Determination

• Manufacturers 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

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Foreseeable Use and Misuse

• Instructions
• Product look and function
• Similarity to other products

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Design Fit

• Anthropometry
• Static measurements
• Dynamic measurements

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Risky Behavior
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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

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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

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Steps for Hazard Identification

1. Design the hazard out of the product
2. Guard or shield against the hazard
3. Warn against the hazard

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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_at_ppai.org

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Thank you! Questions?