AND YOUR BUSINESS: Safety Rules & Regulations

Henry, The Makers Resource Shop

Step 2 - Age-Grading

The second thing to do is take an honest look at your product. This is probably the most in-depth part of the process as we have to really consider who is using our product and how they are using it. Let’s take a wooden name puzzle.

Who is going to be using it? Well, it’s likely to be used as nursery decoration, but then be given to the child to play with once they take an interest in it. So, you’ll treat it as a toy.

What age will the child be when they begin to play with it? This is important as it tells you how much and what kind of testing to consider. A child that is under 3y is more likely to put things in their mouths so you need to keep small parts in mind (and Small Parts lab testing). A child that is over 3y likely won’t stick things in their mouths, but if you have small parts, you’ll need to make it clear that they exist (small parts warning labeling). The CPSC determines that children around 12m will begin to take an interest in puzzles in general.

The next question is, what age will the child be able to play with it? Puzzles require three major skills: fine motor skills, visual discrimination, and cognitive planning. Name puzzles aren’t particularly difficult when it comes to visual discrimination or cognitive planning. Two year olds are able, and excited, to look and learn their letters and place them into well defined wells and an ‘A’ can only go into one place that is easily discernible after all.

However, I’m sure you’ve noticed that puzzles can be made in all sorts of ways with some having large knobs, some having tiny knobs, and some having no knobs at all. This is where you’ll have more room for age grading differences. For example, in the CPSC’s standards for age-grading, 3-year olds can start playing with puzzles without knobs, but may need something like a magnetic tool to pick up the pieces. Four year olds are able to easily play with puzzles that have no knobs without the need for magnetic tools.

We’ll say you’ve chosen to make a name puzzle with no knobs, so you can go with a 3y-4y+ age grading. Additionally, you may market specifically towards caregivers with preschoolers, so this 3y-4y+ age grading works with that too.

Step 3 - Testing

Now you’ll get into the testing. You are making a child’s wood toy with paint for children 3y+, so you’ll need to comply with the following:

• Total Lead Content (CPSIA Sec 101)

• Lead in Surface Coatings (16 CFR Part 1303)

• Heavy Elements (CPSIA Sec 106 / ASTM F963)

• General Toy Standard (ASTM F963)

Wood is generally exempt from all of the chemical/elemental tests (untreated). Paint & sealants need to comply with Lead in Surface Coatings and Heavy Elements. The finished toy needs to comply with ASTM F963. That is going to cost a LOT. Yikes!

Wait!

You registered with the CPSC so you can save a little moolah on this, remember? Instead of testing on your own right-away, you can contact your paint supplier and ask if they’ve already had their paints tested for Lead in Surface Coatings and Heavy Elements. Request a copy of their lab report.

Obtaining supplier statements of testing should be done every year to assure that nothing in the process of making the finished products or its components has changed.

If they cannot offer that information, then you’ll have to choose a different supplier or test on your own at a CPSC-accepted lab (CPSC.gov/labsearch).

Looking at your finished product, there may be some tests from the General Toy Standard that you can do at home. Huzzah!

Step 4 - Documentation

Once you’ve got either the information from your supplier, and/or have tested on your own, it’s time to document all the work you’ve done and certify your product. That’s right, you will be certifying your product on your own! You don’t turn this information in anywhere and instead will keep it in your records collecting digital dust until specifically requested from a CPSC agent.

The document is called the Children’s Product Certificate. This is a seven-part, single-page paper that you can create in digital format and keep in digital format. (It does not need to be fancy, I’m just a little extra.)

Because the date in #5 is done by month, you will create a new document every month that you create your product. Many makers will make a copy, then replace the date in #5, taking just a couple minutes on the 1st of the month to keep their documentation up-to-date.

Step 5 - Labeling

Finally, we are to the last step: Labeling! Some people dislike this part, but if I’m being frank, this is at bare minimum your branding and many small batch makers forget this step! This information needs to be permanent so that it lasts the useful life of the product through proper care and use.

For a wood puzzle, you can utilize the back of the board and include the information as an engraving, a printing, a stamp, or a very firm sticker (that can’t be removed except with Goo-B-Gone® or similar).

The purpose of this labeling is for the current consumer to know:

1. who you are (business name & website),

2. where the product came from (where it was made),

3. when it was made (month & year), and

4. be able to know if they are involved in a recall should one occur (batch/date).

This means that your labeling may look like this:

In the event of a recall, you can provide the consumer with your business name, the product image, the location it was made, the date it was made, and any other information you think would be helpful to them to know if they need to contact you about a remedy. You can look at how recalls are listed at CPSC.gov/recalls.

On your online listing, make sure you include your age grading, clear and conspicuous, so that shoppers can see who the toy is best for. Make sure your images match your age grading too!