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Legislative - Product Safety Presentation

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1. POWERED y LEGISLATIVE ACTION WATCH Product responsibility is everyone s job e Distributors must protect their customer s brand as if it were their own and do their own due diligence e Suppliers must ensure compliance with all regulations and oversee all factories e Everyone is responsible for providing safe products that will not cause harm to the end user e Education and awareness are critical in SF vy Ese ee X Government Relations State Affairs lt lt i n _ me 3 a k gt ea iy ea x a mae i 4 P 2014 National Conference of State Legislatures LEGISLATIVE ACTION WATCH E N fa pAn vy EREE X Placing Safe Products on the Market Identifying hazards Assessing risks Implement risk reduction measures Reducing risks in production Traceability Communicating use and warning information to consumers Monitoring the product in the marketplace centitying any safety risks and managing them LEGISLATIVE ACTION WATCH OO N Ooh dN Embracing Corporate Responsibility Distributors are in the brand protection business e Compliance with Federal and state regulations is not optional Damage to brand value and hefty fines associated with non compliance e It can be a strategic advantage and increase your value to your customers e Every day more end buyers begin to care e Corporate responsibility is a key marke
2. laser pointers failed US FDA legal laser power limit 90 of green laser pointers failed 44 of red laser pointers failed One laser pointer emitted 66 5mW limit 5mW very dangerous Retailers Distributors may have concerns about selling illegal hazardous laser pointers e Online retailers and distributors could require a 3 party such as UL to evaluate the laser pointer before they sell or distribute them http www nist gov pml div686 pointer 032013 cfm A gt da 4 LEGISLATIVE ACTION WATCH L E A D Local Pennsylvania Bruce Korn CAS George Jackson Larry Whitney PPAl GR Manager Seth Barnett and Charles Machion at the Pennsylvania State Capitol PPAI PRODUCT 4am SAFETY LEGISLATIVE ACTION WATCH Pv re baa Methods for Evaluating Laser Pointer Safety e Checking the safety of laser pointers could involve one or more of a variety of evaluation types based on the specific need from laser power testing only to full Certifications to the laser safety Standards LEGISLATIVE ACTION WATCH Methods for Evaluating Laser Pointer Safety e NEW in process Full UL Certification Listing of a laser pointer e Full safety Certification that can result in the UL Mark upon successful completion e Includes an evaluation of ALL potential hazards including electrical flammability laser radiation etc e Benefit to Customer Industry v Can be used to
3. such as luggage belts wallets footwear tags phone covers eyeglass cases e lead e lead and phthalates to ETY LEGISLATIVE ACTION WATCH e Tableware Picnic products e Distilled spirits e Plastic items Wine Beer T _ especially if lead phthalates Sa 100 PVC made with PVC sulfites 73 WA e phthalates one e Electronic Sporting products goods i e lead cadmium children s phthalates toys e Items with an e lead electrical cord phthalates phthalates LEGISLATIVE ACTION WATCH California Proposition 65 Settlements e Ceramicware that is externally decorated e Aluminum cookware e Beverage containers with colored artwork made of glass aste ceramic resin vacuum meta ming olomite and or meta e Brass handled cookware e Fooq use items such as glasses pilsners mugs ar ion tumblers boti condimen iSBENSETS wis cups saucers p ales trays pitchers punch bowls serving utensils and serving platters ottles and soft beverage containers made ol BYE 3 LEGISLATIVE ACTION WATCH IT S A JOB IT ISN T PERSONAL WELL MAYBE A LITTLE Enforcement of Prop 65 JENNIFER ANISTON GERARD BUTLER BOUNTY THE PURSUIT BEGINS e Private Enforcers any individual may bring an action to enforce e State Attorney General s Office enforces Prop 65 District Attorneys and e Very prolific vast City Attorneys can too majorit
4. For sunscreens it may state For sunscreen use liberally may be replaced with generously an option may state apply to all skin exposed to the sun If the product is not water resistant then reapply atleast every 2 hours use a water resistant sunscreen if swimming or sweating vy Ese ee X LEGISLATIVE ACTION WATCH FDA Labeling Requirements Drug Facts Other information protect this product from excessive heat and direct sun Other Information Information which is required by or is made optional under an appropriate OTC drug monograph other OTC drug regulation or is included in the labeling of an approved drug application sunscreens The actual requirement is protect the product in this container from excessive heat and direct sun LEGISLATIVE ACTION WATCH FDA Labeling Requirements Drug Facts water tiethanolamine tocopheryl acetate aioe ance Inactive Ingredients A listing of the established name of each inactive ingredient The inactive ingredients are listed In alohabetical order The hand sanitizer list is not in compliance sometimes Other Information follows Inactive Ingredients rather than coming before it LEGISLATIVE ACTION WATCH FDA Labeling Requirements Drug Facts Questions Must have the telephone number of a source to answer questions about the product It is recommended that the days of the week
5. ribbon rope or string unless it contains intentionally added lead and is listed as a class 2 material All natural decorative material including amber bone coral feathers fur horn leather shell wood that is in its natural state and is not treated in a way that adds lead and Adhesive Class 2 Materials Electroplated metal Unplated metal not otherwise listed as a class 1 material Plastic or rubber including acrylic polystyrene plastic beads and stones and polyvinyl chloride PVC A dye or surface coating Class 3 Materials Any portion of jewelry that meets both of the following criteria e Nota class 1 or class 2 material ae rere LEGISLATIVE ACTION WATCH Children s Jewelry lf lead content in the surface coating or substrate is lt 40 ppm no labeling is required If lead content in the surface coating is gt 40 ppm and lt or 90 ppm labeling is required lt lead content in substrate is gt 40 pom but lt or to 300 ppm labeling is required Adult Jewelry If lead in the surface coating or substrate is lt 600 ppm labeling is require WARNING CONTAINS LEAD MAY BE HARMFUL IF EATEN OR CHEWED MAY GENERATE DUST CONTAINING LEAD PPAI amp PPAI vy EREE X LEGISLATIVE ACTION WATCH Mercury Content in Batteries United States Public Law 104 142 110 and State Legislation Novelty items or items designed for children lt 5 mg per cell Non novelty items lt
6. 10 1 13 e Establishes a process to identify consumer products and chemicals of concern e Approx 1200 chemicals in total may be identified 164 initial candidate chemicals vy Ese ee X LEGISLATIVE ACTION WATCH CALIFORNIA S GREEN Green Chemistry CHEMISTRY rage INITIATIVE 1 Designated 3 priority products and chemicals for assessment of safer alternatives e Children s foam padded sleeping products containing the flame retardant TDCPP also known as chlorinated tris e Paint and varnish strippers and surface cleaners with methylene chloride e Spray polyurethane foam SPF systems containing unreacted diisocyanates insulation 2 Will require alternative assessments for Priority Products Chemical combinations 3 Will impose conditions for compliance i e warnings notices restrictions or bans on use of chemicals or products LEGISLATIVE ACTION WATCH Green Chemistry Promo e Apparel beauty personal care and hygiene named as categories under the initiative s purview in a Safer Consumer Products SCP Draft Priority Work Plan Alongside apparel a number of products in the promotional products industry such as body wash and soaps lotions and lip balms and gloss could be affected by these regulations e The work plan does not specifically identify priority products or chemicals of concern Lists categories from which those products may come The department says the plan gives m
7. 2015 e Senate Finance Committee Chairman Max Baucus resigns and Senator Ron Wyden tax the gavel e MAP 21 Suggested updates made by Department of Transportation e Tax Refom Proposals are submitted in House and Senate in July e Fair Pay Executive Order Released in August e Oversight Committee Indicts Department of Labor on government spending e Tax Technical Corrections Chairman Dave Camp releases language for tax corrections e Midterm election changes political landscape for 2015 e GSP PPAI joins coalition to renew GSP e Both houses pass tax extenders e Both houses pass CR Omnibus budget package LEGISLATIVE ACTION WATCH 4 POWERED X Safety In Production r JE T a fa eh r n i i i ills Vile To r J F gt safety Culture Verification of raw materials components and subassemblies Production Quality Monitoring ie re Finished Product Testing a N PPAI POWERED y a lal ie Safety in the Marketplace Pre purchase agreement Proactive data collection Ongoing assessment of product conformance Warranty and servicing Product incident investigation ISO 10393 Product Recall Differentiation Through Corporate Responsibility e Don t just take the orders e Go beyond just selling products e Use your product responsibility knowledge to differentiate yourself from your competition Position yourself as an indispensible resource e Be a partner to you
8. ACTION WATCH Confusion about Environmental Claims e Historical confusion about what is and what isn t green e Many vague claims in our industry e Use the newly revised Federal Trade Commission FTC Guidelines on the Use of Environmental Marketing Claims to understand rules on Recyclability Recycled content Biodegradability Eco Friendly Natural or other vague claims LEGISLATIVE ACTION WATCH Timelines and Planning e Educate your clients on the importance of planning ahead to allow for creative and well thought out products e We use the risk lens when discussing the importance of being able to select good products and good suppliers Principles and Policies Unaligned e Sixty two percent of respondents said their company CEO has a strong commitment to sustainability however only 16 percent said their company has a chief sustainability officer e Sixty plus percent of top companies have Corporate Social Responsibility policies but less that a quarter of those have sustainable purchasing policies e Our buyers are often junior staff who may not view promotional purchases through a strategic or risk based lens LEGISLATIVE ACTION WATCH LIFE CYCLE STAGES AND AREAS OF IMPACT OF TEXTILE PRODUCTION END OFTLIFE MATERIALS MATERIALS se eres PROCESSING ZERO LANDFILL oe a i G Resource Management co aK a r A mae eee R 27 i A
9. An example battery pack that would have UL Recognized would be one with no enclosure shrink wrapped and does not demonstrate the ability to be a limited power source with non limited hazardous voltage and current at the terminals LEGISLATIVE ACTION WATCH UL Unlisted Component e UL s Unlisted Component service is provided to end product manufacturers rather than component suppliers for those situations where they have a customized component employed ina specific end products that is not UL Certified e Under this program the component is evaluated in accordance with the applicable component requirements taking into consideration the specific end product application The component is only evaluated for factory installation not field installation Once the component is found to be in compliance with the applicable component requirements the component is placed under UL s follow up surveillance program Since the component is intended for a specific application no information is published on UL s Online Certifications Directory or UL s directories vy Ese ee X UL Unlisted Component e Similar to UL s Component Recognition and Listing Service the Unlisted Component Program creates value by increasing the confidence that the component complied with appropriate UL requirements when it was manufactured since it is under UL s Follow up Program e Also similar to UL s Recognition service the battery pack UL 2054 evalua
10. Manufacturers must develop a Periodic Testing Plan to ensure continued compliance that includes Tests to be conducted Intervals at which the tests will be conducted Number of samples tested e At minimum periodic testing should be performed annually LEGISLATIVE ACTION WATCH Material Change Requirements e A material change includes changes in Product design Manufacturing process Sourcing of component parts Tooling Changes in manufacturing facility e New certification testing will be required on the new product LEGISLATIVE ACTION WATCH Recordkeeping e Children s Product Certificate CPC for each product e Records of each third party certification test e Records of period tests e Records of descriptions of all material changes e Records of undue influence procedures including training materials and training records of all employees e These records must be kept for 5 years and may be maintained in languages other than English if they can be immediately provided to the CPSC and translated into English within 48 hours of a request by the CPSC LEGISLATIVE ACTION WATCH Consumer product labeling program e MEETS CPSC SAFETY REQUIREMENTS Label must be visible and legible Product must comply with all applicable rules bans standards and regulations enforced by the CPSC Additional labels may be added Verbiage must not imply that the CPSC h
11. Safety powered by PPAI Webinars Best Practices Turbo Test Tracking Label system Product Protocols Code of Conduct LEGISLATIVE ACTION WATCH
12. and neck drawstrings on children s upper outerwear present a substantial strangulation hazard sizes 2T to 12 or equivalent Federal Regulations for Children s Apparel Drawstrings In Children s Apparel e Waist and bottom drawstrings on children s upper outerwear also present a substantial product hazard Length of drawstrings at the waist and bottom of children s upper outerwear limited to 3 inches outside of the drawstring channel when garment fully expanded sizes 2T to 16 or the equivalent Must be free of toggles knots and other attachments at the free ends of drawstrings If one continuous string it must be bar tacked stitched through PPAI Director of Public Affairs Anne Lardner Stone Eric Ekstrand MAS PPAI GR Manager Seth Barnett Mitch Rhodus CAS and Jeff Shaw at the Ohio State House PRODUCT PPAL 36 ey ere LEGISLATIVE ACTION WATCH Federal Regulations for Children s Apparel CPSIA Section 101 Lead in substrate Applicable if the ink becomes part of the garment e 100 ppm limit e Composite and component testing allowed LEGISLATIVE ACTION WATCH Federal Regulations for Children s Apparel CPSIA Section 101 Lead Paint Rule e Applicable if the ink can be scraped off the garment 90 ppm limit e Composite and component testing allowed HDXRF or wet chemistry LEGISLATIVE ACTION WATCH What About Bling Any hard attachments Both
13. gram excluding any glass or crystal decorative component that contains lt 200 ppm Lead by weight and has no intentionally added Lead Printing ink or ceramic glaze that contains lt 600 ppm Lead by weight Class 3 Material that contain lt 200 ppm of Lead by weight a WDA A i LEGISLATIVE ACTION WATCH Materials Required for Jewelry Surgical implant stainless steel Surgical implant grade of titanium Body Piercing Jewelry Niobium Nb Any part of jewelry that is Solid 14 karat or higher white or yellow nickel free gold manufactured or sold for placement in a new piercing a Ea or a mucous membrane Dense low porosity plastic including by not limited to Tygon or Polytetrafluoroethylene PTFE if the plastic contains no intentionally added Lead Solid platinum Class 1 Material All other Jewelry Class 2 Material Class 3 Material vy Ese ee X LEGISLATIVE ACTION WATCH Jewelry Material Classes Class 1 Materials Stainless or surgical steel karat gold sterling silver platinum palladium iridium ruthenium rhodium or osmium Natural or cultured pearls Glass ceramic or crystal decorative components including cat s eye cubic zirconia cubic zirconium CZ rhinestones and cloisonne Gemstones cut and polished for ornamental purposes excluding aragonite bayldonite boleite cerussite crocoite ekanite linarite mimetite phosgenite samarskite vanadinite and wulfenite Elastic fabric
14. lead limits apply to the decoration e Use and abuse testing for attachments is recommended small parts sharp points sharp edges LEGISLATIVE ACTION WATCH Child Care Articles Defined Garment a child three years of age and younger would use for sleeping feeding sucking or teething j 7 e Blanket B e Sleepwear Federal Regulations for Child Care Articles e CPSIA Section 101 Lead in substrate e CPSIA Section 101 Lead in paint or ink e Any hard attachments Use and abuse testing for attachments is recommended small parts sharp points sharp edges e CPSIA Section 108 Products Containing Certain Phthalates LEGISLATIVE ACTION WATCH Federal Regulations for Child Care Articles CPSIA Section 108 Products Containing Certain Phthalates e Applies to toys and child care articles only e For any toy or child care article DEHP DBP BBP are not allowed in concentrations exceeding 0 1 e For any part of a toy or child care article DINP DIDP DnOP are not allowed in concentrations exceeding 0 1 interim prohibition e Interim banned phthalates limits apply to toys and child care articles that can be placed in a child s mouth whereas the permanent ban applies to any toy or child care article e Inaccessible component parts are exempt LEGISLATIVE ACTION WATCH Materials Containing Phthalates Phthalates may be found in the following materials Soft or flexible plastics except
15. polyolefins Soft or flexible rubber except silicone rubber and natural latex Foam rubber or foam plastic Surface coatings non slip coatings finishes decals printed designs Elastic materials on apparel such as sleepwear LEGISLATIVE ACTION WATCH Adhesives and sealants Assuring Ink Compliance e Have all your inks tested e Rely on ink suppliers tests and component testing rule e Perform third party tests on finished product PPI l TM FN POWERED X What worries me e Ajuvenile imprint can transform a general use item into a children s product e Discovering the intended audience can be difficult e Far too often test reports are out of date based on wrong standards incomplete or for a different product e Distribution site often unknown to the manufacturer vy EREE X LEGISLATIVE ACTION WATCH Testing and Labeling Pertaining to Product Certification 16 CFR 1107 e Establish protocols and standards for ensuring continued testing of children s products e Material change requirements Safeguards against exercise of undue influence Establish program for labeling of consumer products LEGISLATIVE ACTION WATCH Undue influence Undue influence occurs when one party uses his her position to influence the other party to gain some advantage e Pressure is typically exerted through persuasion rather than coercion LEGISLATIVE ACTION W
16. s product demand proof of compliance PPAI PRODUCT 4 SAFETY J PPAI AV LEGISLATIVE ACTION WATCH Social Responsibility Basics e Social standards refer to labor standards or working conditions and cover such things as Abuse of labor Child labor Hours and wages Workplace conditions Discrimination PPAI a vy EREE X Environmental Responsibility Basics e Environmental responsibility considers all applicable environmental laws and regulations Manage your environmental footprint to minimize the adverse impact on the environment Manage energy water and waste systems for maximum efficiency and minimal adverse impact on the environment PPAI ETY A LEGISLATIVE ACTION WATCH Environmental Responsibility Basics Eco friendly claims must be clearly stated and can be substantiated or proven An environmental marketing claim should specify whether it refers to the product the packaging a component of the product or packaging or a combination of these Environmental claims should not exaggerate or overstate attributes or benefits All environmental symbols or logos on products or marketing pieces have to be substantiated or proven Product Responsibility Basics e Even if the item is a general use item there may be regulations beyond CPSIA LEGISLATIVE ACTION WATCH Congressional response e In 2008 Congress passed the Consum
17. suppliers and manufacturers cannot segregate products sold in California so all products must comply with California regulations Using a warning label to comply with Proposition 65 does not relieve one of their obligations under the Jewelry Law e Regulations for jewelry are a matrix of e Materials comprising jewelry e Jewelry components and their contact pattern with the user e Age of the user e Jewelry means 1 Any of the following ornaments worn by a person anklet arm cuff bracelet brooch echain crown cuff link tie clip hair accessory earring necklace pin ring body piercing jewelry jewelry placed in the mouth for display or ornament 2 any bead chain link pendant or other component of an ornament specified in 1 above 3 a charm bead chain link or pendant attached to shoes or clothes that can be removed or 4 a watch in which a timepiece is a component of an ornament specified in 1 above excluding the timepiece itself if the timepiece can be removed from the ornament vy Ese ee X LEGISLATIVE ACTION WATCH Materials Required for Jewelry Children s Jewelry Nonmetallic Class 1 Material Made for marketed for use by Nonmetallic Class 2 Material or marketed for children ages 6 A metallic material that is either a Class 1 Material or and younger contains lt 600 ppm Lead by weight Glass or crystal decorative components that weigh in total no more than 1
18. the secondary tracking label e Even if the item is a general use item there may be regulations beyond CPSIA How can these regulations affect my company VOLUNTARY SAFETY RECALL Violations can be costly Product safety and Safety recalls may A good compliance damage a company s compliance problems can result are very track record builds brand and establish a damage relationships expensive and will equity with prior offense with clients and brand damage a company s customers the that will can result in partners brand supply chain higher fines and Claims and suits arise investors and penalties in the future often May result in regulators greater gov t scrutiny to vy Ese ee y LEGISLATIVE ACTION WATCH What can you do e Learn about the various regulations e Education programs and webinars e Build compliance into your systems and programs e Increase your value to your channel partners by ensuring all systems are compliant e Make yourself and our channel partners hard targets LEGISLATIVE ACTION WATCH Best Practices Key Elements of a Robust Product Safety Program e Compliance does not mean Safety Top leadership commitment e Transparency e Document Document Document e Trust but verify The cost of testing is a tiny fraction of the costs associated with recalls and violations LEGISLATIVE ACTION WATCH Leveraging Your Network Insurance Company Insight
19. under Marketed and or intended to be distributed primarily to children 12 and under Child sized ae CLASS OF ele Ss lt i Official soorts apparel Sports apparel are general use unless Marketed and or intended to be distributed primarily to children 12 and under Child sized F 5 Jij x gar ii a i DFii i AID ie i dae Piuma aE dee aye a i E im a 4 x r2 Ee 7 F J T r naag LEGISLATIVE ACTION WATCH Lunch and other bags e Lunch and other bags are general use unless Theme logo is primarily for children 12 and under Marketed and or intended to be distributed primarily to children 12 and under Child sized j Er IF M i a at i li in T T aS vy Ese ee X Water bottles e Water bottles are general use unless Logo is primarily for children 12 and under Marketed and or intended to be distributed primarily to children 12 and under 4 a LEGISLATIVE ACTION WATCH Sporting goods e Sporting goods are a general use item unless A toy version of a sporting good Marketed and or intended to be distributed primarily to children 12 and under ee VV Ese ee Children s Apparel Defined e Infant and youth size garments LEGISLATIVE ACTION WATCH Federal Regulations for Children s Apparel Drawstrings in children s apparel e Hood
20. 25 mg per cell FCC Part 15 Applicable to devices that generate more than1 705 MHz FCC Declaration of Conformity or FCC ID on product User manual with cautionary statements Mercury Containing amp Rechargeable Battery Management Act Regulated batteries and rechargeable consumer products without easily removable batteries must be labeled in accordance with the regulation vy Ese ee X LEGISLATIVE ACTION WATCH Federal Trade Commission FTC 16 CFR Part 23 Guide for the Jewelry Precious Metals and Pewters Industries Retailers vendors and manufacturers must truthfully represent and label the type kind grade quality quantity metallic content size weight cut color character treatment substance durability serviceability origin price value preparation production manufacture and distribution of their merchandise Any disclosures should be clear and prominent All labeled claims should be accurate An illustration or depiction of a diamond or other gemstone that portrays it in greater than its actual size may mislead consumers unless a disclosure is made about the item s true size vy Ese ee X LEGISLATIVE ACTION WATCH Hypoallergenic and Nickel Free Claims What does it mean why is it important and how do you properly describe and label your nickel free and hypoallergenic products LEGISLATIVE ACTION WATCH Hypoallergenic Jewelry Hypoallergenic jewelry is made out of pu
21. 65 e Internal Exposure e Total Immersion Externally Decorated Articles e NIOSH Wipe Externally Decorated Articles e Lip amp Rim Decoration within top 20 mm of rim e Society of Glass and Ceramic Decorated Products e Lip amp Rim Decoration within top 20 mm of rim LEGISLATIVE ACTION WATCH RS N j i POW Ese ia Quality Concerns and Performance Tests for Drinkware e Leakage burn hazard e Breakage e Drinking spout detachment e Handle temperature e Handle strength e Lid fit Microwave compatibility Dishwasher compatibility Heat retention Lid fit Leakage Stain resistance Breakage Handle strength Thermal shock LEGISLATIVE ACTION WATCH FDA Labeling Requirements e he labeling requirements for promotional over the counter drug products is the same as those drug products for sale eFocus ON Sunscreen Products and Hand Sanitizers Front Principle Display Panel PDP 21 CFR 201 60 e Statement of Identity 21 CFR 201 61 e Declaration of Net Quantity 21 CFR 201 62 E PPAI LEGISLATIVE ACTION WATCH FDA Labeling Requirements PDP 1 oe a 99 99 Germs Statement of Identity BRANDWZ sae A BROAD SPECTRUM SPF 15 Net Contents WATER RESISTANT 40 MINUTES Same active ingredient as Purell Hand Sanitizer 8 FL OZ 237 m LEGISLATIVE ACTION WATCH FDA Labeling Requirements PDP e Sunscreen Products PDP e You
22. ATCH Undue influence e Undue influence may result in undermining the integrity of testing data that can result in defective products that may injure or kill consumers bring liability to the company and cause loss of business LEGISLATIVE ACTION WATCH What is undue influence training e Undue influence training is training to ensure that manufacturers and their employees do not exert undue influence on testing laboratories to alter test methods or test results that a f 4 serve as the basis for _ certifying a product s compliance under federal law If you interact with a third party testing lab what must you do Establish procedures to safeguard against the exercise of undue influence by the manufacturer on a third party laboratory Written policy Training and retraining CPSC notification of any attempt to hide or exert undue influence over test results Staff assurances LEGISLATIVE ACTION WATCH Undue Influence Written policy e This policy should not only satisfy the rule but also accentuate to staff its importance to the company e Make the written undue influence policy visible and available to customers and the public e Consider including the policy in the company code of conduct ai code of LEGISLATIVE ACTION WATCH Undue Influence Training All employees who interact with testing labs must undergo training to ensure that no one engages in actions or makes s
23. Certificate e Citation to each CPSC product safety regulation to which this product is being certified e Identification of the US importer if applicable or domestic US manufacturer certifying compliance of the product e Contact information for the individual maintaining records of test results e Date and place where this product was manufactured e Date and place where this product was tested for compliance with the regulation s cited above e Identification of any third party laboratory on whose testing the certificate depends Tracking Labels e Required for all children s products manufactured after August 14 2009 e Enhance recall effectiveness e Required information Manufacturer name Month amp year of manufacture City amp state of manufacture Batch or internal order number Distributor PO number LEGISLATIVE ACTION WATCH Tracking Labels e Must be permanent Hangtags and adhesive labels not acceptable e Supplier should include tracking label information Depending on changes made to the supplier s product distributor may need to include additional tracking label markings LEGISLATIVE ACTION WATCH Secondary Tracking Label When a distributor sources from an apparel supplier contracts with a third party decorator to apply ink or thread to a garment and sells the product the garment has been altered and requires a second tracking label for the same purpose as
24. E ACTION WATCH Rhode Island Jewelry Legislation e First state to adopt ASTM F2923 11 as mandatory e Children s jewelry manufactured after December 18 2012 must conform to the requirements of ASTM standard F2923 11 Specification for Consumer Product Safety for Children s Jewelry LEGISLATIVE ACTION WATCH Polybag suffocation warning e Warning Label on Plastic cen Bags GER Jrut Yur Hlo FLAVIY o If polybag is less than 1 ONGTACTHIS mG CRBS BEDS CARR NAG mil thick seme NOSE AND our AND PREVEN Opening is more than 5 rast SNOT a gua a onna Should be trilingual GER Pi F OCATION it uae English Spanish and hl BEDS CARI French for Canada e Required in CA MA NY RI VA NERC Toxics in Packaging Northeast Recycling Council Intent is to reduce the amount Reducing the heavy metals of 4 heavy metals in packaging will reduce the amount that materials lead mercury leaches from landfills into cadmium and chromium 6 underground water and streams UODO SAFETY F vy EREE Should test packaging materials for compliance or obtain documentation currently 19 states are part of NERC alliance LEGISLATIVE ACTION WATCH Restriction of Hazardous Substances e California Minnesota and New Jersey have adopted RoHS requirements for Electronic Devices EN 1122 and EN 62321 method e Under this law a covered electronic device is defined as a video di
25. Government Relations Programs PPAI PPA li LEGISLATIVE EDUCATION amp ACTION DAY A LEGISLATIVE ACTION WATCH GRASSTOPS LEGISLATIVE ADVOCACY PROGRAM LEG ji AUGUST RECESS Fite ADVOCACY LEGISLATIVE EDUCATION amp ACTION DAY CPSIA Requirements e Third party testing mandatory Lead in substrate Lead in paint and surface coatings Some phthalates e Children s Product Certificate mandatory e Tracking labels mandatory e Makes previously UNITED STATES OF AMERICA voluntary standards CONSUMER PRODUCT mandatory SAFETY COMMISSION n LEGISLATIVE ACTION WATCH We are in the brand protection business e Compliance with Federal and state regulations Is noi optional e It can be a strategic advantage and increase your value to your customer LEGISLATIVE ACTION WATCH Consumer Product Safety Two Deaths Reported with Ace Bayou Bean Bag Chairs Recall Announced Due to Suffocation and Choking Hazards Consumers should stop using this product unless otherwise instructed It is illegal to resell or atternpt to resell a recalled consumer product Recall date AUGUST 27 7014 Recall number 14 761 BRITA Recalls Children s Water Bottles Due to Laceration Hazard Consumers should stop using this product unless otherwise instructed It is illegal to resell or attempt to resell a recalled consumer product Recall date AUGUST 19 2014 Recall number 14 257 te
26. H Packing Instructions e Provides specific details of the packaging methods as well as the general requirements that must be met to ship the named products PI 965 Lithium ion or Lithium ion polymer cells and batteries PI 966 Lithium ion or Lithium ion polymer cells and batteries packed with equipment PI 967 Lithium ion or Lithium ion polymer cells and batteries contained in equipment General Requirements e Cells or batteries must be manufactured under a quality management system e No shipping of defective or damaged cells or batteries e Protected from short circuiting e Effective means to prevent accidental activation e Placed in strong outer packaging e Secured against movement within the outer packaging mp ra er LEGISLATIVE ACTION WATCH PI 967 Section e Applies to Batteries gt 100Wh or Cells gt 20Wh 5 4Ah for a single 3 6V nominal cell PI 965 Section only applies to larger cells and batteries contained in equipment not typical for a power pack Information provided by Energy Assurance vy Ese ee X LEGISLATIVE ACTION WATCH PI 967 Section II e Excepted from Class 9 Dangerous Goods Requirements Batteries lt 100Wh cells lt 20Wh Internal cell or battery must have passed UN Manual of Tests an Criteria Part Ill subsection 38 3 Cells and batteries must be manufactured under a quality management system that meets the 9 points in
27. ISLATIVE ACTION WATCH Reporting Undue Influence If you witness or are aware of what you believe is an incident of undue influence it is your responsibility to report it e Ideally you should report it to your immediate supervisor If you are not comfortable doing so you may report it to any company officer e The CPSC must be notified immediately of any attempt by the manufacturer to hide or exert undue influence over test results LEGISLATIVE ACTION WATCH Reporting Undue Influence For our purposes any action or statement that undermines the credibility and validity of the testing process used for the certification of children s products is undue influence e If you have any doubt report it LEGISLATIVE ACTION WATCH Undue Influence Staff Assurances e Manufacturers must inform their employees that allegations of undue influence may be reported confidentially to the CPSC and manufacturers must tell their employees how to make such confidential reports e Reports alleging undue influence should be filed with the CPSC Office of the Secretary LEGISLATIVE ACTION WATCH When undue influence occurs e Employees who have engaged in undue influence should be disciplined in accordance with the company s policy for employee disciplinary actions e Discipline may range from a written or verbal warning up and including termination of employment LEGISLATIVE ACTION WATCH Periodic testing e
28. PAI product manufacturer importer in the event of a recall Product Tracking Label Information Promotional Products Association International UPIC PPA Dallas 09 15 2009 Order123456 Paul Elfstrom 972 252 0404 LEGISLATIVE ACTION WATCH PPAI a vy EREE X Recordkeeping Manufacturer must maintain the following records e Copy of Children s Product Certificate for each product e Records of each third party certification test e Separate CPC s and test records required for each manufacturing site e Records of appropriate periodic tests e Periodic test plan and periodic test results e Production testing plan production test results periodic test results e Testing results of tests conducted by ISO 17025 testing lab and periodic test results e Descriptions of all material changes and the Certification tests related to these changes e Records of undue influence procedures including training materials and training records attestations LEGISLATIVE ACTION WATCH Recordkeeping e Records must be maintained for 5 years and made available to CPSC upon request e Records may be maintained in languages other than English if they can be provided immediately to CPSC and translated accurately into English by the manufacturer within 24 hours of a request LEGISLATIVE ACTION WATCH Best Practices Distributors ask your buyer 1 Who is the intended audience Will this item be distributed to children 2 H
29. PPAREL RECYCLING 1 Recycled Polyester 2 Recycled Nylon 3 Recycled Cotton 4 Organic Hemp 5 Tencel Beech Tree Pulp 6 Organic Cotton 7 Virgin Polyester 8 Rayon from Bamboo 9 e Wool 10 Conventional Cotton CLOSED LOOP APPAREL RECYCLING we take it back Areas of Impact eLand Use Intensity Water e Biodiversity Dyeing amp Finishing Textile Manufacturing Chemistry Toxics Human Health eChemistry Toxics Environment Use Wash Dry amp Iron 0 gt lt 2q Sicean Eeichi CR om w e Energy Use Trucking GHG s Warehouse Intertek Store Front interior Packaging Marketing Hang to Dry The Earth Will Thank You a in Tia Occupational Health amp Safety Sey LEGISLATIVE ACTION WATCH Step 1 Plastic PET containers are picked up at community recycling centers then sorted by type and color RECYCLED POLYESTER HOW IT S MADE Step 2 The ar stripped of their labels and caps washed and crushed then chopped into flake vy Ese ee y Step 3 The flakes undergo a second melting and are made into consistently shaped pellets Step 4 The pellets are melted and extruded to make fiber The fiber is crimped cut drawn and stretched then baled Step 5 The baled Tiber can be processed into fabric for a variety of textile product end uses LEGISLATIVE ACTION WA
30. TCH TurboTest Don t know where to start This intuitive online roadmap will help you ascertain what rules regulations and tests apply to your product Progress 11 Complete PPAI TurboTest a product safety roadmap 4 INFORMATION First we ll gather more information about you and how you d like to use this service LEGISLATIVE ACTION WATCH TurboTest Don t know where to start This intuitive online roadmap will help you ascertain what rules regulations and tests apply to your product Progress 32 Complete In its undecorated state is the item generally considered a children s product O Yes O No OI don t know lt lt Previous Next gt gt 2012 Promotional Products Association International PPAT All information materials and processes contained on this site are protected by United States intellectual property right laws and may not be copied reproduced distributed transmitted displayed or exploited in any other way 888 I AM PPAI 426 7724 SO OY LEGISLATIVE ACTION WATCH Remember e Most pens are general use e Think before you include a picture of a child interacting with the item on your website or in your advertising e Look for tracking labels no one size fits all solution e Test reports should include pictures e If itis a children s product ask for the CPC e No drawstrings Ask your screenprinter for ink test reports e Look for
31. and times of the day when a person is available to respond to questions also be Included e he hand sanitizer does not nave this and Is not in compliance Questions or comments Gall toll free 1 800 5 LEGISLATIVE ACTION WATCH FDA Labeling Requirements e Country of Origin and Distributed by must be on the label The hand sanitizer is in compliance but the sunscreen Is not In compliance 903083 97 DISTRIBUTED BY GREENBRIER INTERNATIONAL ING CHESAPEAKE VA 23320 MADE IN CHINA Labeling Concerns For Promotional Products Business e Cosmetics e Over the counter OTC drugs e Consistency in Principle Display Panel PDP Requirements Statement of Identity Weight LEGISLATIVE ACTION WATCH Facility Registrations Do have to register my facility with the FDA Only if you manufacture or store OTC drugs e Complicated process that requires specially registered computer with FDA with security certificates held by the FDA through FDA s submission portal LEGISLATIVE ACTION WATCH Is ita Drug or a Cosmetic Drug is defined as Products intended to treat or prevent disease or affect the structure or function of the body e Examples Sunscreen Dandruff Shampoo Acne treatment Antiperspirants Anything that makes a claim to treat or prevent LEGISLATIVE ACTION WATCH 2014 Legislator of the Year Rep Renee Ellmers NC J AVE fal x ae V With C
32. anufacturers importers and retailers a level of predictability regarding the types of products that can be considered for evaluation over the next 3 years vy Ese ee X LEGISLATIVE ACTION WATCH ON a 7 J Er dy es Bo a a 7 x o iN mt Chemicals of High Concern to Children e State is rept St a list of chemicals that manufacturers must report on 66 CHCC s have been listed to date e CHCC s include BPA phthalates formaldehyde mercury cadmium etc e Children s Product Tiers classification method depending on mouthable or contact with skin or mouth aspects of the product e Manufacturers must report to WA State if their products contain any CHCC s if exceed an established concentration limit if intentionally added or 100ppm if classified as a trace contaminant that is incidental to manufacturing to vy Ese ee y LEGISLATIVE ACTION WATCH Illinois Lead Poisoning Prevention Act e Products or packaging must have a warning label if e Toys child care articles 6 yrs and under and children s jewelry 12 yrs and under if lead in surface coatings is greater than 40ppm e Child care articles and children s jewelry if lead in substrate is gt 40 ppm e Products for adults if lead in surface coatings or substrate is greater than 600ppm t vy EREE y LEGISLATIVE ACTION WATCH Wisconsin Bisohenol A BPA is banned in baby Vy ee bottles and sip
33. as tested approved or endorsed the product LEGISLATIVE ACTION WATCH Balloon Requirements e Mechanical Hazards e Toy Safety and Labeling e Flammability e Chemical Requirements ies e General Labeling F LND we A DDI e Packaging Mechanical Hazards of Balloons e Sharp Edges Points Itis not likely to detect sharp edges or points on a balloon but other components sold with the balloon may present a hazard e Small Parts Balloons are exempt from 16 CFR 1501 Any components sold with the balloons must comply e Bite Test Mouth Actuated Toys Mouth intended toys are tested at 100 pounds evenly applied for 5 seconds and maintained for an additional 10 seconds LEGISLATIVE ACTION WATCH Toy Safety ASTM F963 11 e Use and Abuse Testing Simulate the exposure of a toy to mechanical damage through dropping and other actions likely to performed by achild during reasonable foreseeable use and abuse After testing the toy is examined for mechanical hazards LEGISLATIVE ACTION WATCH Toy Safety ASTM F963 11 e Material Quality Toys may be made from new or reprocessed materials and must be visibly clean and free from infestation e Safety Labeling Packages containing latex balloons and toys or games containing latex balloons shall comply with the labeling requirements of 16 CFR 1500 19 CHOKING HAGZARD Children under amp yrs can choke or suff
34. at the tests accurately demonstrate the ability of the product to meet all applicable safety rules Corrective Action Plan If sample fails Certification testing manufacturer must investigate reasons for failure and take necessary steps to address the reasons for failure LEGISLATIVE ACTION WATCH Best Practices Test Reports e Ask for an actual copy of the test report e Compare the test report to the certificate they should match e Test report is dated within one year e Testing was done by an independent third party lab Must be CPSC approved if children s product e Specific to your product look at the product description and photo e Make sure all of the product components have been tested e Make sure all regulations are covered e Look for the actual test result LEGISLATIVE ACTION WATCH Responsibility for Test Reports e The importer for products manufactured overseas and the US manufacturer for products manufactured domestically e Based on atest of each product or a reasonable testing program e Must accompany the applicable product or shipment of products covered by the certificate e Must furnish the certificate to your distributors or retailers e Provide a copy of the certificate to the CPSC and to the Commissioner of Customs upon request Best Practices Certificates e Ask for an actual copy of the test report to back up the certificate e Compare the test report to the ce
35. at the terminals LEGISLATIVE ACTION WATCH UL Recognition e The UL Recognition Mark is rarely seen by consumers because they are specifically used on component parts that are part of a larger product or system These components may have restrictions on their performance or may be incomplete in construction It also means UL found that representative product samples met some but not all UL s safety requirements e There are three variations of UL s Recognized Component Mark one for the United States only one for Canada only and one for both the United States and Canada The C UR Mark is applied to components only used in the Canadian market Components with this type of Mark have been evaluated to Canadian Standards The optional C UL US Component Recognition Mark indicates compliance with both Canadian and U S requirements vy Ese ee X LEGISLATIVE ACTION WATCH UL Recognition e Components covered by UL s Recognized Component program are intended to be installed in another device system or end product They are to be installed at the factory not in the field and they may have restricted performance capabilities that limit their use When a complete product or system containing UL Recognized Components is evaluated the end product evaluation process can be streamlined e In addition the battery pack UL 2054 evaluation would be allowed to waive certain tests such as Limited Power Source amp Mechanical Enclosure Tests e
36. bare battery cell T7 is conducted on a single or multi cell battery pack T1 Altitude 11 6 kPa for 6 h ambient temp nf nl nv nd nr Simulation ocv 90 T2 Thermal 72 2 Cto 40 2 C hold temp for 6h 10 cycles 24 nf nl nv nd nr h rest at ambient temp ocv 2 90 T3 Vibration sinusoidal WF w log 7 Hz gt 200Hz 7Hz in 15 min 12 nf nl nv nd nr cycle for 3 h for 3 mutually L dir 0 8 mm amp Small ocv 90 Cell and Bat 0 8 g peak acceleration T4 Shock half sine Small Cell and Bat Peak acceleration 150 nf nl nv nd nr gn pulse 6 msecs ocv 2 90 T5 External 554 2 C lt 0 1Q 1h or until case returns to 55 C nf nr nd 170 C Short Circuit temp Check results for 6 h Conditioning Cells and small batteries 1 cycle and 50 cycles Pie vv Ese Ee X LEGISLATIVE ACTION WATCH Overview of UN 38 3 Transport Requirements T6 Impact Crush a Impact test is nf nd 170 C Cell Conditioning 1 9 1 kg kg mass dropped 61 cm onto 15 8 mm cycle 50 SOC diameter bar across cell b Crush test is 13 kN flat plate crush at 1 5 cm s rate until force reached or 100 mV OCV drop or 50 deformation Check results for 6 h T7 Overcharge CC at 2 Bat lt 18 V CV 2 x Vemax or 22 V Bat gt 18 nf nd Battery Conditioning V CV 1 2 x Vimax Check results for 7 days Small 1 cycle and 50 cycle T8 Forced Discharge connect resistive load in series with test cell cell nf nd Cell Conditionin
37. cannot use the following words to describe a sunscreen product e Sunblock e Sweat proof e Waterproof e All day or extended wear e Instant protection e The use of e Water Resistant statements May appear on the front panel provided the product passed required testing Must have a specified time 40 minutes or 80 minutes e Broad Spectrum part of the Effectiveness claim may only be used for products that pass that specific testing This provides protection against UVA and UVB ultraviolet rays LEGISLATIVE ACTION WATCH FDA Labeling Requirements PDP SPF Sun Protectant Factor is another part of the Effectiveness claim for the Sunscreen and must have a T prominent appearance and must follow the Broad Spectrum claim when applicable The following must be the same when both Statements are used Font style color and size Color of background The Water Resistant statement must appear just as it does on this label LEGISLATIVE ACTION WATCH BROAD aa SP FDA Labeling Requirements e Drug Facts Box 21 CFR 201 66 201 300 through 210 327 21 CFR 328 through 369 and current approved monographs Sunscreen Products 21 CFR 201 327 Black Type on Contrasting White Background e Active Ingredients Directions e Purpose Inactive Ingredients e Uses Other Information e Warnings Questions e The font Is italic and bold for each of these headings LEGISLATIVE ACTION WATCH FDA Labeling Re
38. complying US 2 EC 5 amp 6 Name and address of the manufacturer or his authorised representative within EC and US this is individual organisation maintaining records of technical documentation DoC etc US 4 EC 2 heaton of the US importer may be manufacturer or US domestic manufacturer US a EC andl of conformity is issued under the sole responsibility of the manufacturer 3 Date and place where this product was manufactured US 5 Date and place where this product was tested for compliance with the regulation s cited above US 6 Identification of any third party laboratory on whose testing the certificate depends US 7 Where applicable the notified body name number performed description of intervention and issued the certificate EC 7 10 Additional information eS ee SS e Signed for and on behalf of place and date of issue name function signature EC 8 vy EREE X LEGISLATIVE ACTION WATCH CPSC s Reasonable Testing Program e Required by Section 102 b of CPSIA e Basis for GCC CPC e Proposed rule published May 20 2010 Testing and Labeling Pertaining to Product Certification e Public comment period through August 3 2010 e Amendments published November 8 2011 LEGISLATIVE ACTION WATCH e Codified as 16 CFR Part 1107 AS Required Documentation US e Production Testing Plan e May include e Internal external
39. d FDA Labeling Requirements Drug racts Uses helpa prevent sunburn if usad a2 directed with other sun protection measures see Director demeng h 1 Sin aytan wal ey owe re ratte focornmendod or i the riak of skin cancer and early skin aging caused by thas FDA Labeling Requirements Drug Facts e Bullet 21 CFR 201 66 b 4 and d 4 e Means a geometric symbol that precedes each statement in a list of statements Here limited to solid squares or solid circles he same type of bullet must be used throughout the label LEGISLATIVE ACTION WATCH FDA Labeling Requirements Drug Facts Narnings For external use only Warnings For external use only Flammable Keep away from fire or flame Do not use on damaged or broken akin Do nol apply around eyes Do not use in ears amp mouth When using this product keep out of ayes Rinse with water to remove When using this product avoid contact wih eyes Stop use and ask a doctor if rash occurs in case of contac flush eyes wih water Fy ee EE E O A O OE Stop use and ask a doctor H redness or imtation Keep out of reach of children if product e swallowed get medical develop and ners for more than 72 hours help or contact a Poison Control Genter nght away Keep out of reach of chidren Chidren must be supervised in use of this product Warning or Warnings The above are examples of modified labeling formats To be clear
40. d or supplier UL 2054 certification for USA market UL in a Circle Certification Mark USA only Fe f TET Eme UL CSA 60950 1 certification for USA CAN UL in a Circle Certification Mark USA CAN IEC 62133 CB for international market CB Certificate can be also test report only BEATA 60950 LOr ULTON ori Caon erR A UL in a Circle Certification Mark USA only UL CSA 60950 1 or UL 1310 CAN CSA C22 2 No 223 certification for USA CAN market ULin a Circle Certification Mark USA CAN Not a certified product Test report stored with mfr and or supplier UL 60065 certification for USA market UL in a Circle Certification Mark USA only UL 60065 CAN CSA C22 2 No 60065 certification for USA CAN market IEC 60065 CB for international market CB Certificate Bluetooth Frequency Testing FCC Part 15 247 USA Test Report Bluetooth Frequency Testing EN300 328 Europe Test Report UL 60065 test report only UL in a Circle Certification Mark USA CAN BI hF Testing uetooth Frequency Testing Other Bluetooth Test Resor Standards Not a certified product Test report stored with mfr and or supplier UL CSA 60950 1 or UL 2089 for USA CAN market UL in a Circle Certification Mark USA only UL CSA 60950 1 or UL 2089 CSA C22 2 No 107 2 certification for USA CAN market UL CSA 60950 1 or UL 2089 test report only UL in a Circle Certification Mark USA CAN Not a certified product Test report stored with mfr IEC 60825 1 test re
41. dancy lt PPAI LEGISLATIVE ACTION WATCH vy Ese ee X Incorporating Human Factors Principles in Consumer Product Design Safety Hierarchy Design e Guard e Warn Children can fall inte bucked and drown Keep children away fromm buckel with even 2 gmail amount of liquid LEGISLATIVE ACTION WATCH Where do you find practical guidance e ISO Committee on consumer policy COPOLCO requested a project be initiated e In 2009 ISO PC 2483 was formed to write ISO 10377 LEGISLATIVE ACTION WATCH Purpose of ISO 10377 1 Reduce the product safety risk to consumers 2 Reduce the risks to suppliers 3 Provide consumers with the information they need in order to make informed choices with respect to the safe use and disposal of consumer products 4 Assist governments by improving the safety of consumer products A AA Production Marketplace Manufacture ISO 10393 Product Recall E Transport Import storage Export Distribute Retail t Consumer PPAI POWERED y LEGISLATIVE ACTION WATCH Basic Principals 1 Promoting a product safety culture within the organization 2 Promoting a product safety culture outside the organization 3 Commitment to providing safe products 4 Continual improvement 5 Precautionary approach 6 Sharing nor NEON LEGISLATIVE ACTION WATCH The Supply Chain Component Manufacture Assembl
42. e products have diminishing appeal to the 12 and under crowd Distributors Tell Your Suppliers e The intended audience e ifthe item will be given to children e The distribution method Certain events or delivery could encourage unintended distribution to children e The product you want LEGISLATIVE ACTION WATCH Distributors Ask Your Suppliers 1 Is the item considered a children s product 2 What regulations apply 3 Does the product comply with all applicable regulatory requirements 4 How has compliance been determined 5 Request copy of all related test reports LEGISLATIVE ACTION WATCH Distributors Ask Your Suppliers 6 Was all product made at the same factory 7 Was all product made from the same lot of materials 8 Ifa children s product what does the tracking label information mean 9 Will the modifications you plan to make to the product affect the product s compliance LEGISLATIVE ACTION WATCH Best Practices Strong Corporate Responsibility systems and Strategies Provide Direction Simplify the product responsibility process Need to be part of your sales culture May provide some protection against challenges LEGISLATIVE ACTION WATCH Purchase Order Best Practices e Create fields on all purchase orders that require answers to the following questions Is this a children s product Will children be rec
43. e found within a product Specification and Is likely to include a description of the features functions age grade performance requirements packaging instructions and a colour image of the toy Detailed Description of the Manufacture e his should identify the procedures and steps g Cutting LEGISLATIVE ACTION WATCH Required Content 2 eList of Components and Materials Used Typically contained within the Bill of Materials BOM and Bill of substance BOS which identify all materials used in manufacturing the item e The BOM lists raw materials purchased parts and sub assemblies e The BOS contains more detailed information about each material used such as the colorants and additives Safety Data Sheets For all chemicals chemical preparations or mixtures used in the toy must be included LEGISLATIVE ACTION WATCH Required Content 3 Safety Assessment Conducted to ensure that all hazards are identified chemical physical mechanical electrical flammability hygiene and radioactivity and adequately controlled by reference to the harmonised toy safety standards or other suitable means Conformity Assessment Procedure e he procedure followed should be identified and described LEGISLATIVE ACTION WATCH Required Content 4 EC Declaration of Conformity e he format for this is defined within the directive It must include a colour image of the toy and be compl
44. ent than US regulations US regulations are noted as State Variations when they are more stringent Air carriers and airport authorities will use IATA DGR Information provided by Energy Assurance LEGISLATIVE ACTION WATCH IATA ICAO DG Regulations e Identification of Dangerous Goods class is by the Proper Shipping Name and UN number within the identification table e 3 names under 2 numbers apply to Lithium ion cells and batteries UN 3480 Lithium ion batteries UN 3481 Lithium ion batteries contained in equipment and Lithium ion batteries packed with equipment All 3 product types are classified as Class 9 Miscellaneous Dangerous Goods Information provided by Energy Assurance LEGISLATIVE ACTION WATCH Definitions of Cell versus Battery e Cells e Battery UN A single encased UN Single cell battery means a electrochemical unit one positive single electrochemical unit fitted with and one negative electrode which devices necessary for use for exhibits a voltage differential across example case terminals marking its two terminals and protective devices AND Two or more cells which are electrically connected together and fitted with devices necessary for use for example case terminals marking and protective devices Sate Units that have a primary function of providing power to another piece of equipment PPAI t j WDA A LEGISLATIVE ACTION WATC
45. ent eumbiien ang eariy kir aging as well a5 s Afp os directed with othe pun pte thon pe ae Directions Geo eis The hk of skin cicer ard Salty Hpi dey Coed by ies Pur ADS OFevenn Sunburn Warnings Only products labeled with bom ee ee Se OO Broad Specium AND SPFIS5 or Do teat usa on damaged amp broken ikin When using this product keep utal yei Rime ith water to remove Stop use and ask a doctor if rash occurs Keep out of reach of children product it swallrveed gel mecical helpar contact a Poison Contri Center right maay higher have been shown fo 4 provide all these benetits B R A N Sunscreen immediately alter a ir BROAD SPECTRUM at least every 2 hours j Sun Protection Measures Spending time in the wan eneas your risk S PF 1 5 al in cane ad ew ly kin agg fe berea a isk ep Line a tiniee wilh a briad geci am SPF of 19 a higie cel other a paHetian measures Inchuding limit bie inthe aun especially from 10 am 2 pm aes borg eh Crt Peres ast aired claret 7 Phen ewer 6 fonda Ask a chee hae Directions apply liberally 15 minutes before sum mga a feaply ane 40 milrutes of sade oe deat imag inactive ingredients fier arbh banum wibe Geary olog cashier methine diegun EDTA ojota oll methylparaben cor tater ery Ae WATER RESISTANT copoly pairal erl 3 dittearate phenyl abt chal po p beer wibdan Gavearse sar bito weal arki ioco e lori Eh i40 MINUTES bicthanalamine wat
46. er Other information obec his predwel fran ecese heri atte dieci iam Questions or comments Cal tell freee 1 800 ENEKEL SO ee i LEGISLATIVE ACTION WATCH CAUTION e Regardless of the size of the container it must be labeled properly If you have a lip moisturizer in a lip balm tube making an SPF claim it must be label as an OTC So you have to put all of the information on the sunscreen bottle on the label of that lip balm tube LEGISLATIVE ACTION WATCH PPAI LAW Resources PPAILAW PPAI www ppailaw org LEGISLATIVE ACTION WATCH PPAI L E A D LEGISLATIVE ACTION WATCH Useful Labeling Resources Federal Register 21 CFR parts 201 and 310 Labeling and Effectiveness Testing Sunscreen Drug Products for OTC Human Use Final Rule http www gpo gov fdsys pkg FR 2011 06 17 pdt 2011 14766 pdf Federal Register 21 CFR 201 66 Format and content requirements for OTC drug product labeling Drug Facts Label http www gpo gov fdsys okg CFR 2012 title21 vol4 xml CFR2012 title21 vol4 sec201 In September of 2011 the FDA presented a webinar titled Sunscreens Marketed Under the OTC Monograph System http www fda gov downloads AboutFDA WorkingatFDA FellowshiplnternshipGraduateFac ultyPrograms PharmacyStudentExperientialProgramCDER UCM2 72114 pdf FDA Sheds Light on Sunscreens Shows a sample Drugs Fact Panel for a Sunscreen http www fda gov ForConsumers Consumer Updates ucm258416 ht
47. er Product Safety Improvement Act CPSIA CPSIA focus e Defines a child as 12 and younger e Applies to Children s products Childcare articles Children s toys LEGISLATIVE ACTION WATCH Lead in substrate Substrate is the material of which something is made and to which Surface coating i e paint may be applied 100 ppm lead as of August 14 2011 Lead Paint Rule Decorated or scrapable Surface coatings e 16 CFR 1303 in effect since 1978 at 600 ppm As of August 14 2009 sets limit at 90 ppm LEGISLATIVE ACTION WATCH Phthalates Applies only to children s toys and child care products For all such products DEHP DBP BBP limit of 0 1 For all such products or any part of the product that can be placed in a child s mouth DINP DIDP DnOP limit of 0 1 interim prohibition e Applies to accessible materials only before and after use and abuse testing nf LEGISLATIVE ACTION WATCH Children s Product Certificate CPC Importer or Domestic manufacturer is responsible for testing and certification All testing must be reflected in Children s Product Certificate CPC or General Conformity Certificate GCC e Must be produced and made available for every youth order e Sample certificates on the CPSC website LEGISLATIVE ACTION WATCH Children s Product Certificate CPC e Identification of the product covered by this
48. eted and signed by the manufacturer eAddresses of Manufacture and Storage Addresses where the product has been manufactured and stored including locations outside of the EU LEGISLATIVE ACTION WATCH Required Content 5 e Test Reports e O demonstrate that the product has been tested to the relevant harmonised standards e Alist of the harmonised standards that were applied should be held with the copies of the reports eConformity of Production Description of the means whereby the manufacturer ensured conformity of production with the harmonised standards if the manufacturer followed the internal production control procedure referred to in Article 19 2 e This can often be addressed by inclusion of quality assurance program details and quality assurance reports LEGISLATIVE ACTION WATCH Congressional District Visits Members of Rep Bob Gibbs OH staff with Chairman of the Board Mark Jenkins MAS and PPAI GR Manager Seth Barnett YODO OIN PPAI PPA AVV mia a rA LEGISLATIVE ACTION WATCH Required Content 6 elf Toy has been Subjected to an EC type Examination eNotified body identification and copies of documents submitted EC type examination certificate issued for the toy Description of the means whereby the manufacturer ensured conformity of the production with the product type as described in the EC type examination certificate Copies of documents submitted to the notif
49. from the air transport and ground transport authorities it focuses on the safety during transporting of the battery products and not during actual operation of charging and discharging e Normally an evaluation done for certification purposes to UL 2054 or IEC 62133 is a combination of construction analysis and product testing The construction analysis includes Review of the product s design including Electrical Circuit Product Ratings Mechanical Properties Verifying that sub level components have required safety certification including lithium ion cell specific circuit components the plastic enclosure material vy Ese ee X LEGISLATIVE ACTION WATCH Briefing UL 2054 amp IEC 62133 Fundamental Difference UL 2054 Scope e Reducing the risk of fire or explosion when batteries used ina product IEC 62133 Scope e Safe operation of batteries under intended use and reasonably foreseeable misuse gt UL 2054 e Proactively simulate any possibility that may trigger hazards e Through single fault Open circuit or short circuit of a component that Is likely to occur in the circuit Would result in over charging over discharging conditions LEGISLATIVE ACTION WATCH PPAI a vy EREE X Related Mobile Products and Recommended Testing Certification UL 2054 test report only may include UL CSA Not a certified product Test report stored with 60950 1 requirements battery mfr an
50. g 1 forced discharged for time equal to rated capacity cycle and 50 cycles initial test current Check results for 7 days LEGISLATIVE ACTION WATCH Overview of UN 38 3 Transport Requirements Power Banks with cells not previously test will need the cell and battery pack tested Depending on the power bank s configuration i e 1 cell or multi cell it will need either the T7 test or T1 T5 in sequence T7 tests LEGISLATIVE ACTION WATCH Why talk about other safety standards Safety in Production ISO 10377 Consumer product safety Guidelines for suppliers Presented by Robert Pollock UL hair US Technical Advisory Group for ISO 10377 Safety Culture Verification of raw materials components and subassemblies Production Quality Monitoring Finished Product Testing PPAI POWERED y LEGISLATIVE ACTION WATCH Government Relations Today E Newsletter SHARE f W in wore PROMOTIONAL PRODU OCIATION INTERNATIONAL Government Relations Today All Things Election In This Issue Volume 4 Issue 10 21 November 2014 All Things Election The 114th and Us Important Dates With the 2014 midterm election now in the history books Congress is working diligently to ensure a smooth transition before the its Important WWW p p a a W O rg conclusion of the current session The election resulted in the Republicans taking a majority in both the House and the Senate creating the firs
51. g made or assembled outside of the United States vy Ese ee X LEGISLATIVE ACTION WATCH Jewelry Quality and Performance Testing Clasp 500 cycle test force to open measured before and after testing Yield point failure destructive pull t Post Bending test yield strength Tensile pull test Cycle testing force to open measu RE and after testing Quality and Performance Testing Other quality and performance tests include e Chain strength a as e Breakaway features See ananos sett A e Rockwell hardness testing 15siri e Colorfastness ERNI Transit testing Promotional Jewelry Considerations i Se l pd s i ASG OF zo a Method of distribution e Who will it be distributed to e How will it be distributed e Where will it be distributed Size e Available in small sizes Logo Theme e Is it child appealing Federal and State Regulations e Consider the various definitions of e jewelry vy Ese ee X LEGISLATIVE ACTION WATCH Plush Toy Requirements e Hazardous Conditions Mechanical Safety Chemical Requirements Flammability Performance Labeling Hazardous Conditions sharp Accessible Points e Not allowed before or after use and abuse testing sharp Accessible Edges e Not allowed before or after use and abuse testing Small Parts e No toy intended for children of all ages can be small enough with out being compressed to fit with
52. hairman of the Board Mark Jenkins MAS and Paul Bellantone CAE LEGISLATIVE ACTION WATCH Cosmetic e Cosmetic is defined as articles intended to be rubbed poured sprinkled or sorayed on introduced into or otherwise applied to the human body for cleansing beautifying promoting attractiveness or altering the appearance e Doesn t claim to treat or prevent anything LEGISLATIVE ACTION WATCH Cosmetic Continued e Examples Moisturizers Perfumes Lipstick Fingernail polish Cleansing shampoos Hair colors LEGISLATIVE ACTION WATCH How Do tell the Difference e Drugs make claims Cosmetics do not Balm is a claim Moisturizer is not e Can it be both a drug and a cosmetic Yes A sunscreen that is also a moisturizer is both a cosmetic and an OTC drug if the moisturizing claim is on the container Proper labeling is imperative for FDA compliance LEGISLATIVE ACTION WATCH Cosmetic Label Sample A COMPLE ETE TRI PHA ASE FATU AL PEEL RIGHTEN TIGHTEN STEP 3 PPAI PRODUCT M A 3 E Y LEGISLATIVE ACTION WATCH POWERED BY PPAI OTC Drug Label Sample Sunscreen Labeling According to Drug Facts 2011 Final Rule Active Ingredients Anbei FH ron lis Homesalate 17 N used as directed with other MNI Dery methcayennamate 74 proteciion measures his product T i Ses reduces the ISK of skin Cancer hela prev
53. help meet 3 party laser safety check requirements retailers distributors etc may require Y Comprehensive Safety Certification of these devices by a 3 party ae rere LEGISLATIVE ACTION WATCH Parties involved in the US and Internationally by mode of a transportation e Shipping hazardous materials by all modes in the US US HMR e Shipping dangerous goods by sea internationally International Maritime Goods Code e Shipping dangerous goods by air internationally IATA Dangerous Goods Regulations DGR based on ICAO Technical Instructions Information provided by Energy Assurance LEGISLATIVE ACTION WATCH Shipping Regulations US Department of transportation DoT Pipeline And Hazardous Materials Safety Administration PHMSA Code of Federal Regulations CFR Title 49 CFR parts 100 185 Hazardous Material Regulations HMR Governs all modes of transportation within the US rail aircraft vessel and public highway Applies to each person who offers a hazardous material for transportation in commerce causes a hazardous material to be transported in commerce or transports a hazardous material in commerce Air transport is more internationally driven Regulations developed by International Civil Aviators Organization ICAO and adopted into the International Air Transport Associations IATA Dangerous Goods Regulations DGR In most cases it is more string
54. ied body if the manufacturer submitted the toy to EC type examination and rena the conformity to type procedure referred to in Article 19 3 LEGISLATIVE ACTION WATCH EC Declaration of Conformity No unique identification of the toy Name and address of the manufacturer or his authorised representative This declaration of conformity is issued under the sole responsibility of the manufacturer Object of the declaration identification of toy allowing traceability It shall include a colour image of sufficient clarity to enable the identification of the toy The object of the declaration described in point 4 is in conformity with the relevant Community harmonisation legislation 6 References to the relevant harmonised standards used or references to the specifications in relation to which conformity is declared Where applicable the notified body name number performed description of intervention and issued the certificate 8 Additional information e Signed for and on behalf of e place and date of issue name function signature Se ah N ae A LEGISLATIVE ACTION WATCH On The Hill a WDA A LEGISLATIVE ACTION WATCH Combined US Certificate EC Declaration 1 Unique identification of the toy that allows for traceability with color image US 1 EC 1 amp 4 2 Citation of each regulation legislation standards specifications to which product is being certified as
55. in the small parts cylinder e Applicable before and after use and abuse testing JR TM N j i LEGISLATIVE ACTION WATCH POW Ese ia Flammability Flammability of Solids Plush Stuffed Toys e A product is considered to be a flammable solid If it ignites and burns along it s major axis with a self sustaining flame at a rate greater than 0 1 Inches per second LEGISLATIVE ACTION WATCH Flammability Flammability of Textile Fabrics Plain Surface Fabrics e Specimens are acceptable if they did not ignite ignited but self extinguished or any combination thereof e Average burn time is 3 5 seconds or greater Raised Surface Fabrics e Specimens are acceptable if they did not ignite ignited but self extinguished or any combination thereof e Average burn time is 4 seconds or greater ry FN PPAI LEGISLATIVE ACTION WATCH Plush Labeling Country of Origin 19 CFR e Articles of foreign origin or its container imported into the United States must be marked with the name of the country of origin CPSIA Tracking Label e Product and its packaging must bear a permanent distinguishing mark as required to the extent practicable Producer Markings ASTM F963 e Toys or their packaging must be legibly and conspicuously ane with the name and address of the producer or istributor LEGISLATIVE ACTION WATCH Plush Labeling Age Grading Plush Toys e Toys should be labeled to indicate the mini
56. ines for identifying the primary intended users of the jewelry and descriptions of numerous possible hazards posed by hildren s jewelry R TM f N j i LEGISLATIVE ACTION WATCH POW Ese ia ASTM Requirements for Adult Jewelry ASTM F2999 13 Standard for Consumer Safety Specifications for Adult Jewelry eCurrently a voluntary standard eIncludes a migration threshold for acute exposure to cadmium as well as limits antimony arsenic barium cadmium chromium mercury and selenium in surface coatings Requirements for lead prescribes test methods body piercing jewelry batteries suction tongue studs magnets batteries and requires that statements of nickel content must be based on reliable testing LEGISLATIVE ACTION WATCH Jewelry and California Proposition 65 Jewelry is frequently targeted Settlements can be used as a guideline for companies to determine what chemicals to test for and allowable limits elf your company is named in a settlement you must comply with the limits prescribed by the settlement Settlements include Phthalates lt or 1 000 ppm Total Cadmium lt or 75 ppm Total Lead lt or 200 ppm for substrates lt or 90 ppm for coatings LEGISLATIVE ACTION WATCH California s Metal Containing Jewelry Law Born from Proposition 65 settlements with numerous jewelry manufacturers Limits Lead and Cadmium in certain jewelry Most distributors
57. ion they need to use medicines devices and foods to improve their health e FDA s responsibilities extend to the 50 United States the District of Columbia Puerto Rico Guam the Virgin Islands American Samoa and other U S territories and possessions TM f E vy EREE X FDA Definitions Food Contact Substance FCS Any substance that is intended for use as a component of materials used in manufacturing packing packaging transporting or holding food if such use of the substance is not intended to have any technical effect in such food Food Contact Material FCM Made with the FCS and usually other substances often but not necessarily a mixture such as an antioxidant in a polymer the composition may be variable Food Contact Article The finished product film bottle tray or whatever is formed out of the FCM LEGISLATIVE ACTION WATCH TM f E vy EREE X What does the FDA regulate Foods Dietary Supplements Human Drugs Vaccines Blood Products and Other Biologics Medical Devices Electronic Products Cosmetics Veterinary Products LEGISLATIVE ACTION WATCH FDA Regulations for Food Contact Material Title 21 Code of Federal Regulations Prior sanction letter Meeting the criteria for GRAS status Threshold of Regulation exemption request Effective Food Contact Notification FON May ask manufacturer for a Letter of Guaranty certifying that a particular product i
58. ipients of this product e If the answer to both of these questions is yes it is important to note clearly on the purchase orders This product is intended for distribution to children It must comply with all applicable federal and state LEGISLATIVE ACTION WATCH regulations Differentiation Best Practices e Add corporate responsibility to the mix Comfort comes with repetition e Back up your talk Establish guiding principles Properly vet suppliers Make sure preferred suppliers share your values Communicate your principles and best practices to your clients LEGISLATIVE ACTION WATCH Accessible e You do not need to be an expert e You do need to be familiar and aware e PPAI has the tools to guide you through the process Product Safety Aware e Creates confidence in promotional products as an advertising medium at every level e Required program elements CAS Required Product Safety Basics 60 90 minutes Prop 65 and State Regulations 60 minutes Undue Influence Training 60 minutes e Elective program elements Any additional session from an approved list LEGISLATIVE ACTION WATCH Product Safety Aware e Live webinars On Demand Webinars e Expo East e Regional Associations Product Safety Summit e Expo 2015 Adopt and Promote the PPAI Code of Conduct A Bt OD EE T H E PPA CODE CONDUCT How PPAI Can Help e Product
59. l of users children to business professionals 7 lt CENTRALIS NS j a J zf fa ae 4 rahe OPTIC DISK y P 5 a N MUSCLE OPTIC NERVE x SCLERA CHOROID LEGISLATIVE ACTION WATCH Laser Pointer Safety Concerns Background e US Laser Safety Requirements e Controlled by the CDRH Center for Devices and Radiological Health Branch of government under the US FDA e Product Standard 21 Code of Federal Regulations Part 1010 and 1040 Required before a laser product can be sold marketed or imported into the US e Outside US Laser Safety Requirements e Product Standard IEC 60825 1 Safety of laser products Part 1 Equipment classification and requirements e Required to show that a laser product meets the IEC based laser safety requirements These Standards contain laser test methods laser classification schemes and requirements for laser labeling laser construction features and user manual content vy Ese ee X LEGISLATIVE ACTION WATCH Laser Pointer Safety Concerns Background US FDA sets limits for laser pointer emitted power SmW equivalent to Class 3R e Other countries may have own power limits for these devices example 1mW equivalent to Class 2 Laser Pointer manufacturers can self certify compliance to the FDA laser requirements National Institute of Standards and Technology NIST research many existing self certified
60. lations Laws amp Standards 7 REE PE Si E 2 g Consumers Business Regulated infrasiructure ABOUT us PUBLIC registers M dia Publications Contacti us Regulations Mandatory Standards amp Bans CPSC publishes regulations to implement the Canada Consumer Product Safety RS Home Busiicss Trealing customers laity Product safely laws it administers and enforces These Act Webinar October 5 2011 regulations specify the requirements that apply Watch a video on the new Act Ca A to individuals businesses and others Mandatory Reporting o Guidance Document Search Regulations Mandatory Standards amp Product safety Bans Business nights amp o Consumer Incident Report Form mnnbecione REE A EAE i gyda ns a E NL i ae CRRA Search the Code of Federal Regulations at Fr q ntl A ked Q ti n All consumer products you supply must be sale and Meet consumer guarantees Under the Australian GPOAccess gov gt elle 2 Westions ia Treating customers falrly Consumer Law ACL You cannot sell banned Products and you must ensure that your products or product Consumes ngia amp related services congly with relevant mandalory sandands before they are offered for sale There are also I iS moig A P E me obligations iWin mandatory Hote amai Pe uIne tienes Debt collection Seling sale products Loorio door amp Product salety regulation talamarkeling sales Hang Mandatory standards Lay by agreements Mandatory nobfication regui
61. listed by OEHHA companies have 12 f T months to comply with warning requirements under Being the regulation Compliant LEGISLATIVE ACTION WATCH Methods of Exposure Prop 65 is an exposure regulation Measuring Exposure In most cases exposure is measured in micrograms Oral per day based on average Inhalation use of the product Very Transdermal difficult and expensive to Hand to mouth defend a claim since burden is on maker a vy Ese ee y Recent Lead and Phthalate Cases Newer cases involving lead and phthalates have mirrored CPSIA content limits LEGISLATIVE ACTION WATCH Exemptions under Cal Prop 65 e If your company has less than 10 employees including part time it Is exempt from warning requirements recent amendment clarified this to apply to non California companies tOO Exemptions under Cal Prop 65 e Safe harbor levels have been established for many Prop 65 listed chemicals Exempt if e No Significant Risk Levels NSRLs for Cancer causin chemicals an e Maximum Allowable iK Dose Levels MADLs for chemicals causing reproductive toxicity are not exceeded Frequently Targeted Products Under Prop 65 e Jewelry for adults and children e Decorated glass and ceramic drinkware e lead and e lead and cadmium cadmium e Padfolios desk accessories checkbook covers luggage e Leather goods
62. m a vy Ese ee y LEGISLATIVE ACTION WATCH Tech Products Lithium Battery Issues Ingestion incidents are life threatening Packaging requires special precautions Overheating and fire dangers lead to scores of recalls Fire risks lead to regulations for air transport Defects in manufacturing reveal QA challenge Replacement is not always foolproof End of life disposal creates safety and handling challenges LEGISLATIVE ACTION WATCH UL LLC UL offers an extensive array of services to our diverse customers that support every stage of the product life cycle from the testing of new technologies to market access e Product Safety Environment Life amp Health Verification Services Knowledge Services e Battery Websites e www ul com batt amp www ul com largebatt LEGISLATIVE ACTION WATCH Lithium Battery Safety Awareness Videos e Civil Aviation Regulator UKCAA Video Lithium Battery Passenger Handling Example Thermal Runaway e htto www youtube com watch Pv g c6bRPdO 8 e Good Morning America Samsung Cellphone Non OEM Battery Fire e http abcnews go com GMA video cell phone catches fire 24737967 e UL Power Bank Video charged t vy EREE y LEGISLATIVE ACTION WATCH Hazards of Li ion Battery e Hazards Explosion Fire e Cause thermal runaway Electrical abuse Over current Over voltage Over temperature Mecha
63. mum age for intended use or have such labeling on any packaging e Stuffed plush toys are typically tested for the safety of all ages regardless of the age grading on the label because they are commonly recognized as appropriate for young children Re a i a am as an RS f LEGISLATIVE ACTION WATCH Pv re baa Summary of State s Stuffed Toy Licensing and Labeling Laws Uniform Label e It is possible for manufacturers to utilize a uniform Stuffed toy label which is good in all three states Ohio Pennsylvania and Massachusetts e There is no color size or type requirement for the Uniform Label provided the print is legible and can be readily discerned e The label must be affixed to the toy itself LEGISLATIVE ACTION WATCH Summary of State s Stuffed Toy Licensing and Labeling Laws Uniform Label Requirements e The Pennsylvania license number of the manufacturer or vendor Ohio and Massachusetts will accept the use of a Pennsylvania toy registration number if that number if registered within these states and their fees are paid e The name and principal place of business city and state of the manufacturer or vendor e A statement that All New Materials with type of material or All New type Material was used In LEGISLATIVE ACTION WATCH Pennsylvania Plush Regulations License Fee e 25 initial registration e 25 annually Labeling Requirement
64. nds for 12 square inches Burns with a rapid surface flash in less than 7 seconds for 12 square inches with no fusing or ignition of base fabric When time of flame spread is 4 to 7 seconds both inclusive for 12 square inches with fusing or ignition of base fabric When time of flame spread is less than 4 seconds for 12 square inches with fusing or ignition of base fabric LEGISLATIVE ACTION WATCH Pennsylvania Plush Regulations Classification of Flammability of Non Fabrics e Non fabric materials include plastics paints and non fabric portions of a stuffed toy These materials which meet the requirements in Class V are accepted as having no unusual burning characteristics Materials which have burning characteristics Class VI are considered dangerously flammable and recognized as unsuitable for stuffed toys because of their rapid burning and intense burning e Class V Materials are classified as normal flammability when a 9 square inch sample does not burn or flash the full area during a 4 second flame exposure e Class VI Materials are classified as rapid burning when a 9 square inch sample burns or flashes the full area during a 4 second flame exposure Note 16 CFR 1500 44 and 16 CFR 1610 standards may preempt the Pennsylvania flammability requirements if the Pennsylvania requirement is not identical to the federal regulation applicable to toys LEGISLATIVE ACTION WATCH Massachusetts Plush Regulations Lice
65. ne e Inside back neck e Sewn in as a label behind the original care tracking label Secondary Tracking Label Best Practices e Permanent Tracking Labels Mandatory for all children s products piace WIR TNE PACT Can be incorporated into the decoration if done at different time or bya different vendor LEGISLATIVE ACTION WATCH ee PPAI Product Safety Tracking Labels gives the owner of a promotional product a way to identify and contact the WERED BY PPAI product manufacturer importer in the event of a recall LOOKUP CREATE MANAGE 13 Upload Multiple single Registration Create a Code http ps ppa org product identifier alphanumeric 4 7 0 9 and dashes example abc 123 Location of Production city state country factory example Irving TX Factory 5 Date of Production format MM DDYYYY example 04 04 2074 Identifying batch run number sources example BL 123 Bounce Ball Characteristics Contact Information phone email etc example amp 388 426 7724 productsafety ppai org By clicking submit you accept the terms of use Submit ae OY LEGISLATIVE ACTION WATCH Tracking Labels e Example using the PPAI tracking label system ps ppa org SAMPLEOO3 Promotional Products Association International T RAC KI N G LABELS B E L S PPAI Product Safety Tracking Labels gives the owner of a promotional product a way to identify and contact the POWERED BY P
66. nical abuse Other abuses Internal short circuit Transportation Miscellaneous RS N j i POW Ese ia LEGISLATIVE ACTION WATCH Safety Testing Protocols and Standards for Lithium lon Battery Cells and Packs Mandatory Depends on Mandatory Mandatory Depends on Mandatory Application for Intl Application for Intl Markets Markets Although similar tests exist in the 3 standards testing for UN UL and IEC standards do not have the same test methods sample requirements and or defined sample condition to vy Ese ee y LEGISLATIVE ACTION WATCH What is UN 38 3 e UN Recommendations on the Transport of Dangerous Goods Manual of Tests and Criteria e htto www unece org trans danger publi manual rev 5 manrev5 amendments htm e Amendment 1 contains the full test program of 8 tests e Amendment 2 contains clarification on when to conduct the 6 test known as T6 either Crush or Impact test LEGISLATIVE ACTION WATCH UN 38 3 is Required by US Department of Transportation DOT International Civil Aviation Organization ICAO International Air Transport Association IATA LEGISLATIVE ACTION WATCH Why UN 38 3 is Important PPAI AV LEGISLATIVE ACTION WATCH Overview of UN 38 3 Transport Requirements T1 T5 are conducted in sequence and on the bare battery cell as well as on a multi cell battery pack T6 and T8 are conducted on the
67. nse Fee e 300 initial registration e 300 annual renewal Labeling Requirements e Same as Pennsylvania Uniform Label is acceptable LEGISLATIVE ACTION WATCH Ohio Plush Regulations Licensing Fee e Annual fee of 50 e File quarterly reports accompanied by a tax of four cents per item sold in the State of Ohio in the preceding quarter Labeling Requirements e Same as Pennsylvania Uniform Label is acceptable LEGISLATIVE ACTION WATCH Battery Operated Plush Toys Labeling and instruction markings e Mercury content e Function and performance testing e FCC requirements e Noise level Not Just Children s Products e Federal regulations FDA particularly drinkware sunscreen e State regulations Cadmium Packaging Lead e International standards e And more LEGISLATIVE ACTION WATCH Applicable Laws Regulations and Stan G UNITED STATE L CONSUMER PRODUCT SAFETY COMMISSION Health Canada Home Naess alee e em Regulations Laws amp Research amp Statistics Business amp www hc sc gc ca Standards Manufacturing P 3 Regulations Safety gt Legislation amp Guidelines gt Acts amp Regulations Federal Mandatory Voluntary Register Advisory Standards and Consumer Product Safety Statutes Standards Rulemaking Notices Opinions Bans Print A Text Size S M L XL Help Share Canada Consumer Product Safety Act CCPSA Home Regu
68. ocate on uninflated or broken balloons Adult supervision required Keep uninflated balloons from children Discard broken balloons at once vy Ese ee X LEGISLATIVE ACTION WATCH Flammability e Product is considered a flammable solid tf ignites and burns along its major axis with a self sustaining flame at a rate greater than 0 1 inch per second LEGISLATIVE ACTION WATCH Jewelry Product Safety CPSC Consumer Product Safety Commission ASTM ASTM F963 amp ASTM F2923 California Proposition 65 Labelling Law eAdditional U S State Laws FTC Federal Trade Commission Performance and Quality vy Ese ee X LEGISLATIVE ACTION WATCH CPSIA Requirements for Children s Jewelry Factors to Consider Size and Shape Materials Used Colors Cause amp Effect Sensory Elements Level of Realism amp Detail Licensing amp Theme vy Ese ee X LEGISLATIVE ACTION WATCH ASTM Requirements for Children s Jewelry ASTM F2923 11 eSpecification for Consumer Product Safety for Children s Jewelry Defines children s jewelry as designed primarily or intended primarily for children 12 years of age and under includes ornamentation P i akaa in Rhode Island Rhode Island Children s Jewelry Safety ct Requirements and test methods for specified elements and certain mechanical hazards in children s jewelry eIncludes recommendations for age ww and hil phe guidel
69. om 2014 05 a look inside ipad chargers pricey html e Provides a detailed discussion of safety requirements for power supplies e Safety Considerations in Power Supply Design htto www ti com lit ml slup227 slup227 podf UL 60065 Safety Requirements for Coin Button Cell Batteries e Background e Developed by the Consumer Electronics Association CEA in response e to field incidents involving injuries and fatalities of small children due to e the ingestion of lithium coin button cell batteries e The batteries can become lodged in the esophagus where when in e contact with tissue fluids the batteries generate hydroxide through an e electrolysis reaction This hydroxide which forms causes alkaline burns e and perforations of the esophagus e Serious injury may occur in e as little as two hours LEGISLATIVE ACTION WATCH Laser Pointer Safety Concerns Background e Laser Pointers are generally used in a variety of applications such as e Presentations e Alignment e Entertainment e General Misuse unfortunately eas e Potential Safety Issues w Gf e gt Laser power is consistent along beam path even at great distances miles or kilometers CORNEA VITREOUS gt Temporary visual problems flash blindness saueous we gt Possible eye injuries aoit gt Possible skin burns larger laser pointers gt Easy to purchase gt Large intended and unintended poo
70. ow will the products be distributed What kind of logo do you intend to use 4 Do you typically keep items in stock for future use or do you distribute all items 5 Do the customer s preferred products have child like appeal or playful elements Or do those products have diminishing appeal to the 12 and under crowd id Best Practices Distributors tell your supplier and decorator The intended audience 1 If the item will be given to children 2 The distribution method 3 The product you want LEGISLATIVE ACTION WATCH When distributors become suppliers e A distributor who sources direct is a manufacturer e A distributor who uses a contract decorator would also be considered a manufacturer LEGISLATIVE ACTION WATCH How do you determine if something is a children s product e Whether the product is commonly recognized by consumers as intended for use by a child of the ages specified Similar product similar color size weight materials and quality marketed in retail store and primarily for children 12 and younger Historically marketed to young children Theme media appeal considered primarily for children under 12 Sold on websites catalogues primarily for children under 12 Play value Appeal more to children under 12 than 13 String backpacks String backpacks are general use unless Theme logo is primarily for children 12 and
71. packages may be placed in an over pack box if Each individual package is complaint with P1967 Section II on its own No packages within the over pack contain a different substance that h S it S own D G r e gu ati O n S Daa aay CAUTION Marked as OVER PACK y ial Labeled with the Lithium Battery label rounco N N LITHIUM BATTERY N N DO NOT LOAD OR TRANSPORT N S PACKAGEIFDAMAGED N For more tformatioa cal N 44 SAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAA Information provided by Energy Assurance vy Ese ee X LEGISLATIVE ACTION WATCH Summary and example Air shipments Small Lithium ion cells and batteries contained in equipment transported by air per IATA Classification Excepted Package 5kg net weight per Limits package Packaging Strong outer packaging Marking Lithium battery label greater than 4 cells or Specific dimensions 2 batteries and red border apply only to air transport Documents Yes PI967 Section II Training of N A staff POWERED X LEGISLATIVE ACTION WATCH Battery Good Bad News e Bad News Internationally there are various regulations and interpretations related to the classification of power packs These regulations are in constant flux and should be monitored as closely as possible e Good news Global harmonization is being pushed on all fronts The ind
72. port only and or supplier IEC 60825 1 CB for international market CB Certificate can be also test report only FDA CDRH Informative Laser Report Confirms FDA CDRH laser safety requirements IEC 60825 1 or FDA CDRH testing only Letter report test results and laser classification Sey LEGISLATIVE ACTION WATCH UL Listing e The UL Listing Mark is one of the most common UL Marks If a product carries this Mark it means UL found that representative product samples met all UL s safety requirements e There are three variations of UL s Listing Mark one used only in the United States one used only in Canada and one for both the United States and Canada The C UL Mark is applied to products for the Canadian market The products with this type of Mark have been evaluated to Canadian safety requirements which may be somewhat different from U S safety requirements The optional C UL US Mark indicates compliance with both Canadian and U S requirements vy Ese ee X LEGISLATIVE ACTION WATCH UL Listing e A UL Listing Marking appearing on a product typically consists of four required elements e ULina circle symbol e Word Listed e Product name or company name file number e Issue serial number or alphanumeric control number e An example battery pack that would have UL Listing would be one with a fire and mechanical enclosure and also demonstrated ability to be a limited power source with limited hazardous voltage and current
73. py cups lt 3 yrs Children s items must be labeled BPA Free BPA Suspected as an endocrine disruptor risk to infants and young children Also may be present in epoxy resin coatings in cans and aluminum water bottles BPA also banned in 10 other states mostly in baby bottles and sippy cups CA CT DE ME MD MA MN NY WA and VT labeling not required Legislation pending in other states t vy EREE y LEGISLATIVE ACTION WATCH Other States with Chemicals of Concern Regulations for Children s or All Products enacted or pending e Maine Toxic Chemicals in Children s Products identifies 49 chemicals that are reproductive or developmental toxicants endocrine disruptors or carcinogens e Connecticut Florida North Carolina Oregon New York States with bans on certain kinds of flame retardants e TRIS TDCPP TDCP TCEPRTCPP PBDEs decaBDE and others e Found mainly in children s clothing and furniture due to potential cancer risk through skin absorption or mouthing e Connecticut Delaware Illinois Massachusetts Maryland Maine Missouri North Carolina New Jersey New York Oregon Vermont Washington rao LEGISLATIVE ACTION WATCH Pennsylvania PA is a NERC state E Wweleomes A i Fa Fr gt e Mercury in batteries regulations ee Vv Ese Ei l Mass Pike Boston BPA regulations Polybag suffocation warning regulation LEGISLATIV
74. quirements Drug Facts e Drug Facts The word is left justified bold italic and the first letter of each word is uppercase The type size is the largest in the entire box e Active Ingredients First letter of each word of the established active ingredient name is uppercase each is listed in alphabetical order and the dosage amount follows the name In both examples here it is the proportion rather than the dosage amount LEGISLATIVE ACTION WATCH FDA Labeling Requirements Drug Facts Active Ingredient continued Allowed Active Ingredients for Sunscreen Products Aminobenzoic acid PABA 15 Octocrylene 10 Avobenzone 3 Oxybenzone 6 Cinoxate 3 Padimate O 6 Dioxybenzone 3 Sulisobenzone 10 Ensulizole 4 Titanium dioxide 25 Homosalate 15 Zinc Oxide 24 Meradimate 5 Octinoxate 7 5 Octisalate 5 may not be combined with the ones marked with Each sunscreen active must contribute a minimum of SPF 2 to the product PPAI lt a PPAI y LEGISLATIVE ACTION WATCH POW Ese ia FDA Labeling Requirements Drug Facts Active Ingredient continued e Purpose Must be right justified italic and bold When the OTC drug monograph contains a statement of identity It shall also be stated as the Purpose of the active Ingredient If no monograph exists the principal pharmacological category or the principa intended action of the ingredient can e use
75. r customer e Bea brand steward LEGISLATIVE ACTION WATCH Engage in the Conversation Share with your customer The basic laws and regulations Your obligation and responsibility to the laws and regulations Your obligation and responsibility to protecting their brand and image That by working together the two of you can ensure they have the right product for the right audience In the end it s about protecting and promoting their brand with a memorable engaging and long lasting program LEGISLATIVE ACTION WATCH Engage in the Conversation e Social Responsibility e Code of Conduct e Company Organization Message and Mission LEGISLATIVE ACTION WATCH Engage in the Conversation e Environmentally responsible manufacturing practices e Recycled vs Recyclable e Reusability avoid the trash Will product serve customer s purpose or end up in a landfill LEGISLATIVE ACTION WATCH Ask the Questions No One Else Will Who is the intended audience Will this item be distributed to children e How will the products be distributed What kind of logo do you intend to use e What s the intended outcome LEGISLATIVE ACTION WATCH Ask the Questions No One Else Will e Do you typically keep items in stock for future use or do you distribute all items e Do the customer s preferred products have child like appeal or playful elements Or do thos
76. re metals such as platinum Karat gold higher than 18K titanium copper stainless steel and fine silver The term Hypoallergenic is not regulated by the FTC Only allowed to label Hypoallergenic if made entirely of one of the above listed metals Example A pair of earrings made out of a base metal or alloy with surgical Steel posts The earrings cannot be labeled Hypoallergenic Sell ll Label as Earrings with Surgical Steel Hypoallergenic osts LEGISLATIVE ACTION WATCH Nickel Free Jewelry It labeled Nickel Free Nickel testing is required European Union REACH Regulation Migration of Nickel in post assemblies lt 0 2 ug cm2 week Migration of Nickel in jewelry intended to come in contact with prolonged skin contact lt 0 5 ug cm2 week There are no federal regulations for nickel content in jewelry in the United States Misuse of Terminology Descriptive terms and adjectives such as Handmade Handcrafted Genuine Authentic Rare Precious Vintage Antique Made in the USA are examples of terms often used in the jewelry industry when describing and labeling items These terms are acceptable to use but only when they are in fact what they describe Examples Handmade means entirely handmade with no machine fabrication or cast metals The use of hand powered tools is allowed Made in the USA means entirely made in the United States with no components bein
77. renruerls Product sataty Recalls Mandatory neporteng Repairs amp spare peti aia Up to date Unier bosaness priechinis More infermation wwanmanbos Acwalisang amp prameateng Selling safe products FOU QUBINESS SEY LEGISLATIVE ACTION WATCH California Prop 65 A state regulation that impacts the entire US supply chain Primarily a warning requirement Covers 900 chemicals Based on exposure levels Applies to general use as well as children s products LEGISLATIVE ACTION WATCH Cal Prop 65 The Basics No Pre emption e California s Office of Environmental Health Hazard Assessment OEHHA must annually publish a list of chemicals known to cause cancer birth defects or other reproductive harm e List is approx 900 chemicals now e Purpose is to give consumers a chance to make an informed decision to protect them from exposure to chemicals T FN PPAI vy Ese ee y LEGISLATIVE ACTION WATCH Cal Prop 65 Warning Label e Provide a Clear and e WARNING This product contains Reasonable Wa rning a chemical known to the State of before knowingly and California to cause cancer intentionally exposing anyone to a listed WARNING This product contains chemical a chemical known to the State of California to cause birth detects or other reproductive harm LEGISLATIVE ACTION WATCH PPAI a vy EREE X Cal Prop 65 The Basics No Pre emption e Once a chemical Is
78. rtificate they should match e Certificate is dated within one year e Based on testing by an independent third party lab Must be CPSC approved if children s product e Specific to your product should be a specific product not a generic product or product line e Make sure all regulations are covered LEGISLATIVE ACTION WATCH Not Just Children s Products e Federal regulations FDA particularly drinkware sunscreen e State regulations Cadmium Packaging Lead e International standards e And more LEGISLATIVE ACTION WATCH FDA Overview e Science based regulatory agency e Organized by product area e Employs many types of scientific professionals lawyers analysts etc e Oldest comprehensive consumer protection agency in the US federal government e Began regulating food contact substances LEGISLATIVE ACTION WATCH FDA FDA Responsibilities FDA e Protect the public health by assuring that foods are safe wholesome sanitary and properly labeled human and veterinary drugs and vaccines and other biological products and medical devices intended for human use are safe and effective e Protect the public from electronic product radiation vor na cosmetics and dietary supplements are safe and properly abele e Regulate tobacco products e Advance the public health by helping to speed product innovations e Help the public get the accurate science based informat
79. s e Manufacturers must submit detailed Information as to the filler content of their Stuffed toys and specimens of the toys selected at random to the Pennsylvania Licensing Authorities Pennsylvania Plush Regulations Registration Requirements for Foreign Manufacturers e The manufacturer may register directly with the Department at the foreign manufacturer s locations This is identical to the requirement for domestic manufacturers or e An importer may hold a stuffed toy registration on behalf of each foreign manufacturer represented The Department does not permit pooling of registrations e The Department is not requiring registration of each plant for domestic manufacturers but only to ensure that each foreign manufacturer is separately registered Pennsylvania Classification of Flammability of Fabrics Class relatively slow burning Class I moderately flammable Class III relatively flammable Class IV rapid and intense burning No nap pile tufting flock or other type raised fiber surface When time of flame spread is 20 seconds or more for 12 square inches When time of flame spread is 8 to 19 seconds for 12 squares inches When time of flame spread is 3 to 7 seconds for 12 square inches When time of flame spread is less than 3 seconds for 12 square inches vy Ese ee X Napped pile tufted flocked or other type raised fiber surface When time of flame spread is over 7 seco
80. s acceptable for the intended food contact use LEGISLATIVE ACTION WATCH Legislative Education and Action Day LEGISLATIVE ACTION WATCH FDA Generally Recognized as Sate GRAS e Designation that a chemical or substance added to food Is considered safe by experts and so Is exempted from the usual Federal Food Drug and Cosmetic Act FFDCA food additive tolerance requirements e Example Stainless Steel LEGISLATIVE ACTION WATCH FDA Prior Sanctioned e A substance whose use in or on food is the subject of a letter issued by FDA or USDA offering no objection to a specific use e Prior sanction exists only for a specific use of a Substance In food delineating level s condition s and product s Food Contact Substance Notification Program e Streamlined the way the FDA conducted business e Established a notification process for food contact Substances Defined a food contact substance as any substance intended for use as a component of materials used in manufacturing packing packaging transporting or holding food if such use is not intended to have a technical effect in such food e Intended to replace the petition process as the primary means for authorizing new uses of food additives that are food contact substances ja 4 LEGISLATIVE ACTION WATCH FDA Ceramic Drinkware amp Tableware e FDA Guidelines 545 400 amp 545 450 e Internal Exposure Only e California Proposition
81. s midpoint the channel so it cannot the channel so it cannot 3inchrule be pulled out of the be pulled out of the channel channel 3inchrule 3inchrule Pie vv Ese Ee X LEGISLATIVE ACTION WATCH What can I do for my company Adopt Best Practices Source from only trustworthy and knowledgeable vendors Develop compan requirements and standards for compliance Educate your vendors of your requirements Require written verification of compliance with state and federal regulations Take other steps to make your company a hard target I will adopt Best Practice I will adopt Best Practices I will adopt Best Practices 1 will adopt Best Fractices I will adogt Best Practices I will adopt Best Practices I will adopt Best Practices I will adopt Best Practices I will adopt Best Practices I will adopt Best Practice I will adopt Best Practices LEGISLATIVE ACTION WATCH L E A D 2014 Meetings on the Hill Debra Simonette MAS T Neal Munn MAS with Rep David Price NC Jim Socci Charles Machion with Rep Michael Fitzpatrick PA PPAI AV LEGISLATIVE ACTION WATCH General Requirements Certification Testing e Third party testing by CPSC approved lab is mandatory on all children s products to support Certification e Manufacturers must submit a sufficient number of Samples for testing Number of samples must be sufficient to provide a high degree of assurance th
82. s to Enhance Product Safety e Insurance is key component in a risk management toolkit e Product Liability Prevention Program Management coordination and control Design product development Product warnings and instructions Manufacturing quality control Sales marketing statements Vendor management Legal oversight Monitor field service Document control Post sale management AS ta LEGISLATIVE ACTION WATCH vy EREE X Now Trending Advertising s Shared Connections with Safety Regulations e Social Media is a powerful tool e Marketing claims must be truthful CPSC product safety and compliance FTC marketing claims accuracy truth in advertising LEGISLATIVE ACTION WATCH Regional Trade The Trade Overlay Product Safety and Compliance Implications from TransAtlantic Negotiations e TTIP Transatlantic Trade and Investment Partnership agreement Largest economic relationship in the world Very significant trade agreement Addresses trade barriers that arise from different regulatory costs and redundant testing requirements There is a real opportunity for companies to get involved and help to shape discussion This will also create opportunities for regulators to collaborate once the agreement is established This isn t about harmonizing regulations but there are a number of tools you can use to eliminate some areas of redun
83. section 3 9 2 6 e of the regulations For batteries the Wh rating must be marked on the outside of the battery case e Other items that apply Passenger and crew baggage restrictions Air mail restrictions Reporting of accidents and incidents Information provided by Energy Assurance LEGISLATIVE ACTION WATCH P 967 Section II Additional Requirements e Equipment must be packed in strong outer packaging Suitable material or adequate strength e Each package that contains more than 4 cells or 2 batteries contained in equipment must have Label Documentation Information provided by Energy Assurance ne NA j 1 LEGISLATIVE ACTION WATCH POW Ese ia PI 967 Label and Documentation Label Documentation must include e Lithium battery handling label e Package contains Lithium batteries e Handle with care Se ee er ore ee ee e Speci al procedures mu st be followed CAUTION if damaged N N e Contact number N i vy N e Lithium ion batteries in compliance S jam with Section II of P1967 A e e e N e Persons shipping the equipment X m BATTERY must have adequate instruction DO NOT LOAD OR TRANSPORT X N PACKAGE IF DAMAGED N l Bt e Does NOT require a shipper s NR declaration of Dangerous Goods Information provided by Energy Assurance vy EREE X LEGISLATIVE ACTION WATCH PI 967 Section Il Over pack boxes e Individual compliant
84. splay device with a screen greater than four inches measured diagonally Drawstrings in children s clothing e CPSC Final Rule on Drawstrings became effective in 2011 but CPSC has considered drawstrings in children s outerwear to be a substantial product hazard for years Several CPSC recalls per year e New York and Wisconsin have specific requirements banning hood and neck drawstrings on all children s clothing but with limited exceptions for waist of upper and lower clothing drawstrings vy EREE X LEGISLATIVE ACTION WATCH State Requirements Hood and Neck Drawstring and Ties Type of Apparel All children s All children s Upper outerwear clothing clothing Sizes 27 12 0 16 2T 12 Requirements No hood or neck No hood or neck Drawstrings and drawstrings drawstrings ties cannot be used allowed allowed in the head or neck area LEGISLATIVE ACTION WATCH PPAI Pie vv Ese Ee X State Requirements Waist of Upper and Lower Clothing Drawstring eonan O weona O O asea Type of Apparel Children s upper and Children s upper outerwear Children s upper outerwear lower clothing Sizes 2T 16 0 16 2T 16 Requirements No toggles knots or No toggles knots or other No toggles knots or other other attachments attachments attachments The drawstring must The drawstring must be The drawstring must be be attached to the sewn at the midpoint of sewn at the midpoint of garment
85. t differentiator LEGISLATIVE ACTION WATCH Why End Buyers Care e Responsible promotional products professionals will ensure that the investment made in their client s brand will be both promoted and protected e When regulations exist compliance is required by law e As consumers become more aware of product safety demand for compliant products will increase e Product responsibility is just smart business Increasingly the target audience wants assurances that products comply with environmental social and product safety regulations and standards Corporate Responsibility Facts e 88 feel a responsibility to purchase products they think are socially and environmentally responsible e 92 of respondents would buy a product with social and or environmental benefit e 90 of respondents would stop buying a company s products or services due to irresponsible business practices e 91 of global consumers are likely to switch brands to one associated with a good cause e 85 of this year s respondents say it s okay if a company is not perfect as long as it is honest about its efforts LEGISLATIVE ACTION WATCH 2013 CONE Communications ECHO Global CSR Study Where to Start e Know your sources Know your suppliers Talk to your suppliers about compliance Know that all products you sell meet regulatory requirements Ask the right questions If the item is a children
86. t truly divided government between the legislative and executive branches since the 104th Congress under the Yourself Clinton administration There is a chance that while Congress may be very productive over the next two years the President could use his veto power to stall bills approved by Congress During the 104th Congress President Clinton implemented similar tactics which caused the government to shut down once beginning in November of 1995 and again beginning in December of 1995 However after that time period faith was swiftly restored in Congress and the next few years resulted in the best national economics in decades Jan 11 15 2015 Today those on the Hill hope that compromise can be found quickly PPAI XPO The End Las Vegas December 12 will mark the conclusion of the 113 tn Congress one of the least productive in American history The much anticipated lame duck session that began on November 12 has so far been uneventful Those in the House spent nearly a week preparing and passing a bill that would fund the Keystone XL Pipeline only to have it stall out in the Senate by one vote Senators have been working to reorganize their leadership responsibilities for after they turn control over to the Republicans in January Presently both houses are recessed until December 1 when they will have just shy of two ae rere LEGISLATIVE ACTION WATCH Why talk about other safety standards e While UN 38 3 is a mandatory regulation
87. tatements that will be considered undue influence e If the undue influence policy changes all employees must be retrained LEGISLATIVE ACTION WATCH Best practices to avoid unduly influencing a third party lab Ensure you follow appropriate sample selection protocols Do not test golden samples e Don t threaten to change third party testing providers because of an unsatisfactory test report e Avoid developing personal relationships with the lab that could somehow influence test LEGISLATIVE ACTION WATCH results Obligation to exercise due care e Applies to each domestic manufacturer or importer of a children s product e The importer is not required to train employees of foreign manufacturers but must be sure to exercise due care LEGISLATIVE ACTION WATCH Obligation to exercise due care Train your factories in your policy and advise them that their acts of undue influence on labs may cause you to rely on their supplied test reports for CPCs that can be deemed invalid by the CPSC and bring liability to you as the certifier for failing to exercise due care in preventing undue influence in your supply chain Obligation to exercise due care If the importer receives a test report that is the result of undue influence the CPSC could deem the certificate invalid and the CPSC may hold the domestic manufacturer importer responsible for failing to exercise due care LEG
88. test reports of recurring testing e Process management records Control charts otatistical process control programs Failure modes and effects analyses FMEAs Factory QC plans Material Changes e Records of any change in product s design manufacturing process or sourcing of component parts that may affect compliance ertification tests on changed product or components as needed Undue Influence e Written policy with training records vy Ese ee X LEGISLATIVE ACTION WATCH EU Recordkeeping Requirements e The technical documentation has to be drawn up In one of the official languages of the European Community e When market surveillance authority of a Member State requests the technical documentation it may pose a 30 day deadline for receipt but this deadline can be reduced in the case of serious risk e Manufacturers are obliged to keep the technical documentation for a period of 10 years after the toy has been placed on the market Market Trends e Organic food products have grown at a rate double that of conventional products e A 2012 study of global executives by consultancy Accenture showed one third of those surveyed could not keep up with demand for sustainable products and services e Brands such as Wal Mart and Nike are phasing out hazardous chemicals and developing indexes to measure the environmental attributes of their products e Consumers are expecting more transparency LEGISLATIVE
89. the first e A secondary tracking label is still required for embroidered items even though most embroidery LEGISLATIVE ACTION WATCH Secondary Tracking Label The distributor is viewed as the manufacturer in this instance and becomes responsible for ensuring the contract decorator applies the secondary tracking label e Note The manufacturer is responsible for all required documentation and recordkeeping LEGISLATIVE ACTION WATCH Secondary Tracking Label Required Information e Distributor s Decorator s name e Month amp year decoration was applied e City amp state where decoration was applied e Decorator s batch or internal order number e Distributor s PO number XYZ Promotional Products POH Las Vegas Nevada 123456 2013 LEGISLATIVE ACTION WATCH Bel O lt Tracking Labels e Example using the PPAI tracking label system ps ppa org SAMPLEOO3 Promotional Products Association International T RAC KI N G LABELS B E L S PPAI Product Safety Tracking Labels gives the owner of a promotional product a way to identify and contact the POWERED BY PPAI product manufacturer importer in the event of a recall Product Tracking Label Information Promotional Products Association International UPIC PPA Dallas 09 15 2009 Order123456 Paul Elfstrom 972 252 0404 LEGISLATIVE ACTION WATCH PPAI a vy EREE X Secondary Tracking Label Best Practices Label Location e Bottom hemli
90. the following would be bold For external use only Do not use When using this product Stop use and ask a doctor Keep out of reach of children a Ro TM N j i Pv re baa LEGISLATIVE ACTION WATCH FDA Labeling Requirements Drug Facts Warning or Warnings continued If not using a modified format each statement would be followed by a bullet If the product is broad spectrum but with a SPF of at least 2 but less than 15 the first Statement under Waning Is Skin Cancer Skin Aging Alert Spending time in the sun Increases your risk of skin cancer and early skin aging This product has been shown only to help prevent sunburn not skin cancer or early skin aging in AR FDA Labeling Requirements Drug Facts Directions Directions pump as needed into your pama and apply liberally 15 minutes before sun axposure i F j reapply fhoroughy spread on both hands srub into sein unl dry otter 40 minutes of awimming or Sweating CE a immediately after towel drying at least every 2 hours Sun Protection Measures Spending time in the sun increases your nek of akin cancer and early skin aging To decreaae thia risk regularly use a sunacreen with a broad spectrum SPF of 15 or higher and other aun protection measures including limit time in the sun seapecially from 10 a m 2 p m wear long sleeve shirts pants hate and sunglasses children under 6 montha Ask a doctor Directions
91. tion would be allowed to waive certain tests such as Limited Power Source amp Mechanical Enclosure Tests e An example battery pack that would have UL Unlisted Component would be one where the end product customer does not want any marking on their battery pack but only on the final end product for example a Battery Operate Power Tool or a Battery Operated Handheld Device AS TM f N j i LEGISLATIVE ACTION WATCH POW Ese ia UL Website for more on UL Marks To know more about all lt the UL marks including Z ttre omenen mans the ones used for slic Global Markets that are x O issued by UL please visit http www ul com sglo Gy NCE DESIGNING PROMOTION e SIGNIFICANCE amp ORDERING amp ADVERTISING bal en ages corporat e aboutul ulmarks ul listing classification marks TM TN PPA t POW ERED y Mark Types DOWNLOAD HOLOGRAM ENHANCED UL UL MARKS UL MARKS CERTIFICATION MARKS Downloadable UL Marks Hologram UL Marks Enhanced UL Certification LEGISLATIVE ACTION WATCH Wall Plug In Chargers with USB outputs Vehicle Plug In Charges with USB outputs Safety Is yours certified LEGISLATIVE ACTION WATCH Safety Awareness Tiny cheap and dangerous Inside a fake iPhone charger e htto www righto com 2012 03 inside cheap phone charger and why you htm e iPad charger teardown inside Apple s charger and a risky phony e htto www righto c
92. ustry is well represented through organizations like PRBA Information provided by Energy Assurance ne N j i LEGISLATIVE ACTION WATCH POW Ese ia What is a Technical File A comprehensive collection of information and documents that details everything about your product LEGISLATIVE ACTION WATCH Tecnnical File Regulations e Technical File requirements for the European New Toy Safety Directive TSD e Record Keeping Requirements under the CPSC s Reasonable Testing Program 16 CFR 1107 LEGISLATIVE ACTION WATCH Requirements for the European Tecnnical File e The EU TSD requires manufacturers to provide documentation demonstrating that toys comply with design manufacture and operational requirements e The Technical File must be kept up to date and reflect any changes to the toy legislation or standards e The history of the product must be retained LEGISLATIVE ACTION WATCH Contents of the EU Technical File Detailed description of the design and man ture rst of components and materials used In Safety assessment s Conformity assessment procedure EC declaration of conformity Addresses of the places of manufacture Address of storage Test reports Internal production control procedure EC type examination certificate if applicable LEGISLATIVE ACTION WATCH Required Content 1 Detailed Description of the Design of the Toy e his information can b
93. y t WDA A i LEGISLATIVE ACTION WATCH Commitment to providing safe products 1 Competency and training 2 Adequate resource allocation 3 Records management and document control Continual Improvement Analysis of data from monitoring Develop action plan what ts problem and cause implemented by the Compliance with supplier regulations safety l 7 standards expected Identify address safety safety amp functionality Problem amp Acti feguiatory camied out by all Decision n pre supply chain llecycie and salety members Monitoring ee by all l May require Monitor members of changes in the supply customer complaints chain design of product Incidents production production marketplace comection action product standards PPAI t vy Ese ee y LEGISLATIVE ACTION WATCH Understanding the role of Consumers 1 Will consumers understand the intended use of the products or limitations on use 2 How will consumers use your product 3 Will your product be used by vulnerable consumers children elderly disabled LEGISLATIVE ACTION WATCH Risk Reduction Results of Risk Assessment Changes tothe design of the product e g eliminate small parts ETY amp LEGISLATIVE ACTION WATCH 2014 Legislative Highlights e DATA Act Creates government spending transparency Will be implemented in
94. y of claims vy Ese ee X LEGISLATIVE ACTION WATCH Enforcement of Prop 65 e Violations can be up to 2 500 day per violation private enforcers can enter into settlements and split with State the court approves and enters judgment against business owner LEGISLATIVE ACTION WATCH Who Wins With Prop 65 Other 12 Penalty 13 TM f A E WDA 2 LEGISLATIVE ACTION WATCH What Can We Do to Comply With Prop 65 NE AN LA RON NERO SARE OE NGA Proposition 65 Chemical List Approx 890 Chemicals Listed Known to cause Cancer Birth Defects of Reproductive Toxicity PRACTICE E Check Chemical List Confirm with Suppliers Test and Comply with Prop published and updated Confirm with supplier or 65 Settlements by the Office of manufacture that none Ask your customer if the Environmental Health of the chemicals have product may be distributed and Hazard been intentionally MEA Assessment OEHHA added e Ask for test reports and can be found at e Have products tested for www oehha ca gov usual suspects e Apply warning label a POWERED y LEGISLATIVE ACTION WATCH Wait there s more eh CALIFORNIA S A a GREEN iW __ CHEMISTRY from California wey MITIATIVE On 8 28 13 the California Dept of Toxic Substances Control approved the Safer Consumer Product Regulation e Intent is to protect public health and or environment e Took effect on

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