For years, promotional products have demonstrated their effectiveness and value. However, today’s business environment increasingly looks beyond the product itself to evaluate its safety and social and environmental footprint.
End buyers want safe and reliable products, free from harmful chemicals and toxic material. They want products produced in non-polluting environments that meet social and environmental standards, and are not likely to embarrass a company through a product recall. The extra quality assurance, product testing, inspections and auditing necessary to produce these kinds of safe, quality products add more costs and increase the complexity of delivering a product into the stream of commerce.
When evaluating, developing or launching a product, you must conduct a formal evaluation of the product to ensure that it is safe, appropriate and meets the social and environmental expectations of the end buyer. This evaluation should address the product, its packaging and any decoration to the product itself.
All formal product evaluations are unique and can be complex, but some basic steps are common to all evaluations:
- Identify all critical parts and address potential manufacturing and decorating concerns
- Assess the performance and functionality of the promotional product, packaging and decoration
- Evaluate the life cycle of the product
- Who will use it?
- How will it be used?
- How long is the item expected to last?
- How will the user dispose of the product?
- Identify risks associated with the product, packaging and decoration (e.g., electrical, mechanical, chemical, environmental, toxicity and flammability hazards). Assess key potential safety issues, human factors, concerns and recommendations based on experience and available injury data relative to the type of product.
- Identify all applicable mandatory regulations, industry standards and end-buyer test specifications to which the item, packaging and decorating will be subjected. PPAI Promotional Products TurboTest (www.ppai.org/turbotest) is a useful resource for identifying regulations and standards.
- Identify all potential areas of non-compliance with applicable regulations, standards and end-buyer specifications; identify required modifications to bring the item into compliance
- Conduct age grade determination
- Evaluate labeling requirements specific to the submitted item
- Evaluate recall history, if any, of similar items
Given the challenges associated with identifying all standards and regulations, it may be worthwhile for your organization to rely on the advice and services of an independent accredited laboratory (often referred to as a testing partner).
The Consumer Product Safety Commission (CPSC) maintains a list of accredited labs on its website at www.cpsc.gov/cgi-bin/labsearch. The Consumer Product Safety Improvement Act (CPSIA) requires the CPSC to maintain a current list of testing laboratories that have been accredited to assess conformity with children’s product safety rules. The laboratories on this list have been accepted as accredited to test products to one or more of the children’s product safety rules and are therefore a useful place to start your testing partner search process.
Use this accredited laboratory selection checklist when evaluating labs:
|No conflict-of-interest. The lab should be a legal entity, organized in a manner that permits satisfactory performance of all required functions in an impartial and unbiased fashion.|
|Financial stability. The lab should have sufficient resources to enable it to properly use and maintain the test equipment and facility, to satisfactorily perform all required functions and to adequately indemnify itself against financial liabilities/penalties resulting from its operations.|
|Staff qualification requirements. Each staff member in the lab should have the education, training, knowledge and experience necessary to perform the tasks assigned, and an appropriate level of supervision should be maintained. The training of each staff member should be kept current and documented.|
|Adequate quality system. The lab should have a quality system appropriate to the type and amount of work performed. It should be suitably documented in a comprehensive manual that is readily available for consultation by staff.|
|Sampling requirements. If a lab receives test materials in quantities larger than the amount required for the test, the lab should sample the material to ensure the sample tested is representative of the entire quantity of material received, using appropriate sampling methods and/or techniques.|
|Sample control/integrity requirements. The lab should have an effective system to ensure both the identity and integrity of the test samples. Maintaining the samples’ integrity involves preventing them from being damaged during any stage of their collection, shipment, storage or handling.|
|Statistical methods requirements. The statistical methods used to interpret or to provide additional information about test data should be appropriate and adequate for the type and level of testing undertaken.|
|Recordkeeping requirements. A lab should maintain all test records, observations, calculations and derived data for all tests it performs for an appropriate time or as required by law.|
|Test report content/format requirements. Test reports should include all information relevant to sample selection, test performance and test results. They should be in a format that is easy to read and understand, and routinely audited and validated. Increasingly, labs are offering online test scheduling and online delivery of final test data.|
|Available operational manuals/instructions. The lab should have readily available instructions on the operation and maintenance of all materials and equipment, copies of the test methods and standards employed with any additional instructions needed on their application, sample selection and handling procedures, and any other relevant information necessary to ensure the quality of the work performed.|
|Participation in proficiency testing programs. The lab should participate in proficiency testing programs (if they are available for the scope of the item being tested) to ensure the competence of its testing processes. Proficiency testing can provide the lab with valuable feedback on the competence of its testing processes.|
|Adequacy of facilities and equipment. The lab should own or have access to all equipment required to perform all test methods it conducts. The facility should require test methods to be conducted in a controlled environment to prevent any adverse effects on the test result’s accuracy.|
|Equipment maintenance/repair/calibration requirements. Equipment calibration, preventive maintenance and repair procedures and the choice of reference materials used for calibration should be appropriate for the nature and amount of work being performed. Equipment calibrations should be traceable to some ultimate or national reference standard. Complete records should be maintained on these procedures.|
|Adequate control over subcontractors. The lab should have a system to ensure that testing and related work performed by any of its subcontractors is at an acceptable level of quality.|
|Appeals procedure. The lab should have a mechanism to deal with technical questions, appeals, complaints and challenges, originating either from the customer or from interested regulatory or other parties.|
Can I Test The Product Myself?
With a few notable exceptions, particularly in the area of children’s products, the answer is yes—you can test a product yourself. If it is not a matter of law or a specific end-buyer requirement, the relevant questions for self-testing are: Can I meet the end buyer’s expectations with a conformity self-assessment? Do I have the capacity to identify the standards and tests myself?
Another tip: Often, testing costs are lower when performed in the same locale as manufacturing. If a product is produced overseas, consider having testing performed in the country of origin.
Anne Lardner-Stone is PPAI’s director of public affairs. Find dozens of product safety resources including guides, articles and archives of webinars at www.ppai.org/inside-ppai/product-safety.
In The News
In October 2011, the Consumer Product Safety Commission (CPSC) approved new regulations regarding the independent third-party testing of children’s products. The new rules specify periodic testing requirements and component-part testing rules for domestic manufacturers, importers and private labelers, requiring them to test and certify that their children’s products comply with safety standards set forth by the Consumer Product Safety Improvement Act (CPSIA).
Periodic testing, as required by the CPSC’s regulations, ensures continued compliance to product safety rules. Should a material change be made to the product—changes to the product design, manufacturing process or the source of component parts—firms will have to re-test and certify it remains in compliance with federal safety standards. Firms are required to keep records of all testing and certifications for their children’s products.
To ease the burden the regulations place on affected companies, the CPSC has issued a final rule regarding the conditions and requirements for relying on testing and certification of either component parts of consumer products, or another party’s finished product, or both, to demonstrate, in whole or in part, compliance of a consumer product with all applicable rules, bans, standards and regulations to support a children’s product certificate.
These rules governing testing and certification go into effect 15 months after publication in the Federal Register. Products in compliance with the law may be labeled “Meets CPSC Safety Requirements.” These regulations will not have any impact on existing testing obligations—all manufacturers, importers and suppliers of children’s products were required to conduct third- party testing for lead in substrate, inks and surface coatings by January 1, 2012.
PPAI Product Safety Summit: A Big Reason To Attend
Your clients expect you to be the expert on product safety and compliance. Are you ready? Take your product safety knowledge to the next level by attending the PPAI Product Safety Summit, August 14-15, in New Orleans immediately following the PPAI North American Leadership Conference. The Summit promises to immerse you in education focused on the most-pressing product safety issues, as well as the business implications, challenges and opportunities associated with compliance.
Facilitated by industry thought leaders, representatives from product safety labs and product certification groups, this eye-opening event will explore the latest developments, as well as best practices.
This limited-seating event is filling quickly—register now to secure your spot. Participation in the program earns you 12 MAS points—and more confidence in working with your clients.
PPAI Member/NALC attendee: $500
PPAI Member/PSS-Only: $575
Second PSS Attendee: $450
Hear what last year’s attendees are saying about this event and register online at www.ppai.org/education/product-safety-summit.