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vj

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Hello All,

I was wondering about the rules and regulations for producing toys for sale in the US.   A trip to Consumer Product Safety Commission’s web site took me down the rabbit hole. 

For example:

From CSPS.gov

All toys intended for use by children 12 years of age and under must be third party tested and be certified in a Children’s Product Certificate

Manufacturers and importers of children’s products must certify, in a written Children’s Product Certificate (CPC) based on test results from a CPSC-accepted laboratory, that their children’s products comply with applicable children’s product safety rules. 

The toy safety standard refers to ASTM F963-17, as incorporated with a modification shown in 16 CFR Part 1250. All children’s toys manufactured or imported on or after February 28, 2018, must be tested and certified to ASTM F963-17.

There are too many to list here, but some of the items listed for testing are:  wheels and axles, substrate materials, coating materials, projections, fasteners, holes…   And many many more.  You get the idea.

The rules for third party testing stretch on forever, I understand (I may be wrong on this) that toys are submitted in batches for testing, with records kept of date and location of manufacture, Third party testing is at the submitter's expense.  And much more.  There is so much information on that site that it is hard to digest, and then you are referred to other sites, and then there are regulations that are not online but for sale (for over $80).  I am overwhelmed.  

My questions is:  How do you comply with the rules that the CPSC has set out?   What am I missing?

Thanks for any and all help, 

vj

Nick

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Following.
john lewman

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Thanks for posting and I understand your concern. That said, there is nothing for you as a wood toymaker to be alarmed about. I personally have called and talked to a representative at the U.S. government office about the manufacture of wood toys on a small scale as a sole proprietor. This is what he told me and what I have lived by with no problems from the agency or customers and I have produced over 30,000 wood toys over the years.

1. Use common sense.
2. Do not use lead-based paint. All USA paints made for consumer use for the past 30 years are safe to use and are lead-free plus non-toxic when dry. That includes Krylon, MinWax, Rustoleum and all other retail paints and stains. As long as you are using brand name finishes and keep a record of what you use it is not necessary to have batches approved by an agency.
3. Round all wood edges to prevent splintering or scratching.
4. Avoid pinch-points from hinged or levered parts.
5. For children under 3 all parts should be of a size to prevent choking.
6. Avoid sharply pointed parts that could puncture the skin.
7. Avoid using lumber that has been treated for outside environments. These can contain arsenic as a preservative.
8. When making teethers for infants use hard-rock maple only. This will not splinter when chewed.

For you to be charged with neglect, a parent or guardian must file a lawsuit against you and then prove that any damage or injury was definitely from the use of your toy. 

Enjoy your time in the shop and enjoy sharing your creations.

John
Nick

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Thanks for weighing in on this subject, John! Your knowledge and experience is greatly appreciated and sets my mind at ease.
BadBob

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To Johns list I would add: Do not make toys with round holes in them small enough to get a finger stuck in. I got this from the testing document.

Little kids will stick their fingers in holes, and sometimes they get stuck. If it is a round hole, their finger can swell and cut off the circulation. Children have lost fingers in round holes.
 
I occasionally made toys with round holes until I read this. Now as a standard practice I don't use round holes unless they are quite large. 
 
 




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john lewman

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Excellent advice BadBob Thx.
AJ

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I live in Tasmania , Australia and about 6 months ago I was asked by a friend could I supply his wife with wooden toys she could sell at her weekly stall at a City Council run market.
Seemed like a simple request until I started jumping through the council  hoops.
I was required to supply certificates for the Child safe finish I used, Sustainability of the timber resource, and then send samples of the toys I was going to supply to her along with Designs that contained no nails or loose parts.
After supplying all the Material data sheets I obtained from the suppliers I use and having my original designs and sample toys passed I was given certification as a Child safe wooden  Toy Producer.
I have been Now been granted permission to Design and make toys without having each one inspected by the council committee.
When I questioned the need for this process apart from child safety I was told as the market was under Local Government control, they were responsible for Public Liability issues.
All up it took about 5 weeks before my toys were allowed to be sold at the market but I as there are only 2 stalls selling wooden toys and mine are hand made from local native timber it was well worth the Hoops.


john lewman

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This is a great story AJ. And one we can all appreciate. I also avoid all types of metal fasteners in my designs for safety reasons.
vj

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Reply with quote  #9 
Thank you all for your feedback.  I have made several hundred toys for the local Children's Hospital over the past few years.  (The toys conformed to the Hospital's rules:  ie:  only approved child safe finishes, no metal parts, no loose parts...)  Then I became aware of the CPSC and the requirements for toys.  In discussions with other toy makers, it seemed that it was impossible to conform to the regulations as a small time producer, and hence we were all afoul of the law.  
I have been abiding by John Lewman's points all along.  They seem almost intuitive.  The Hospital has more restrictive rules regarding finishes, but I use Rustoleum 2X for the most part.
Thank you all Again
vj
adeafguy

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DO NOT use wood from old pallets.  Many are reused after there first time use.  A wood turner friend was using old pallet wood.  Broke out in a rash and had lung problems.   After many tests the wood dust was tested.  The chemicals in the wood was caustic.  Chemical spills.  You never know where that pallet has been.
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john lewman

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You are absolutely right about wood pallets. Some have been soaked in a solution of arsenic.
Rod T

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Reply with quote  #12 
An interesting and important topic.

I too have been investigating the rules here in Australia for selling toys at markets etc. 
There are 3 Australian standards for toys here which are currently under review. 
The only way to get hold of the Standards documents is to purchase them for about $350 each. So about $1000 just to be able to read the documents. Go figure, you would think in the essence of safety, these documents would be freely available. 

One of the standards relates to under 3 yr olds. Another to toys in general above 3 yr olds and the the third relates to toys with projectiles.
As they are under review they are only drafts at this point, so I haven't bought them or read them. 

Discussions with other toy makers and woodworkers have come up with the same points that John and BadBob made.

Insurance at markets here in Canberra, Australia is the responsibility of the stall holder. Generally available at a day rate of about $40 from the Market organiser. It is also available from insurance companies etc.
The insurance is broken into Public Liability and Product Liability. 
Public Liability covers you for injury/damage etc. that could be caused by the stall. Someone tripping over, market gazebo/umbrella blowing over in the wind and hitting something/someone etc. 
Product Liability covers you for the actual product sold and injury/damage derived from the toy. Kid choking on part etc. 
Only 1 insurance company here (That I can find) will cover the product liability portion for toys. 
In discussions with them, they have said that testing doesn't need to be done as long as there is compliance with the Australian Standards. It also depends on expected annual $ turnover. The product is geared specifically for market sellers selling anything. From what I can tell most woodworkers here in Australia use this insurance. It is priced at about $260 a year. 

Having only done a few stalls I have purchased the day rate insurance each time, but am currently looking at the annual policy as this will also cover Etsy sales and other sales etc. 

Hope this info is useful.

Cheers
Rod T




 
Lexie

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Yes there are all sorts of rules. I am also just beginning to make kids toys. Just be smart, go read up on what  size a choking hazard size is. Easy to google it.

Amazon even sells the "choking hazard tester" for as low as 8 dollars. In a nut shell if your small part fits inside the tester..it is a choking hazard to infants and toddlers. If your toy does have a small choking hazard part do not sell it as a baby-toddler toy, mark it for an older child, like 5 or 6 years and up who won't be using the toy as a teether etc.

As far as glues-paints-sealers-waxes etc. again google it and you will discover what symbols to look for when you are buying non toxic paints and sealers for your wood products.You will find as i did that keeping the wood natural or unfinished is safest, but you can paint them, just have to read the safety labels.

Almost all wood glues are non toxic, read the labels. Instant glues wont have a safety label good for kids so stick to the traditional wood glues.

Wood choices also are important as kids do have allergies to nuts etc.
Absolutely use no pallet wood or woods treated for outdoor use as pallets even if labeled...who can trust them? And outdoor woods are treated to prevent molds etc, so when buying wood read if it has hazardous treatments, ask the vendor to be sure.
Milk paints sound wholesome but again some kids have milk allergies.
Making teether toys for babies..obviously paint and wood sealers are best avoided. Probably just use beeswax/mineral oil as a sealer or no sealer at all.

No one wants to see our toys injure or kill a child so take no chances!
vj

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Reply with quote  #14 
Once again, thanks to all.  I have been following almost all of these suggestions ( they are almost intuitive with a little thought) ie: no pallet wood, treated wood, small holes etc.  Thank you Lexie for the "choking hazard tester".  Good thought.
You guys are the greatest
vj
AJ

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Reply with quote  #15 
The market stall I supply toys to wanted me to hinge some joints and as The council had already told her no screws or nails I got her to clear Their use with them.
I hinged 2 pieces of timber with one of the hinges I would be using with screws and epoxy glue and She took it into the committee that approved the original toys I make .  
They destroyed the hinge but the timber tore before the screws and glue gave out. 
They now have approved the use of these hinges as long as they are screwed and glued with apoxy.
It seems that they make up the regulations for wooden toys as they see fit , possibly to justify their position.
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