Efforts to Align US/EU/ISO Toy Standards for Cadmium

Transcription

1 2011/SOM1/SCSC/CON1/005 Session 3 Efforts to Align US/EU/ISO Toy Standards for Cadmium Submitted by: Toy Industry Association (TIA) 6 th Conference on Good Regulatory Practice Washington, D.C., United States 1-2 March 2011

2 Efforts to Align US/EU/ISO Toy Standards for Cadmium Carter Keithley, President Toy Industry Association (U.S.) 6th APEC Conference on Good Regulatory Practice Washington, DC March 1, 2011 Key Outcomes of the APEC Toy Safety Initiative Greater transparency in regulatory systems The APEC Toy Safety Survey completed by all 21 APEC economies 2 March 1, 2011 Page 1

3 Key Outcomes of the APEC Toy Safety Initiative Greater transparency in regulatory systems The APEC Toy Safety Survey completed by all 21 APEC economies Concrete moves towards better alignment A pledge by ASTM International and ISO to support greater technical cooperation and an agreement to hold future joint meetings Establishment of ISO Advisory Panel to determine toy standard alignment priorities 3 Key Outcomes of the APEC Toy Safety Initiative Sustained international regulatory cooperation APEC Product Safety Contact List shared with the OECD Participation by eight (8) APEC Toy Safety Regulators in ICPHSO Chile Chinese Taipei Indonesia Malaysia Mexico Peru Philippines Thailand 4 March 1, 2011 Page 2

4 Background: Standards Alignment for Cadmium (1 of 2) January 2010 U.S. syndicated news story breaks Cadmium found in trinkets from China 5 Background: Standards Alignment for Cadmium (2 of 2) Products cited were children s jewelry NONE were toys Toy industry decision to proactively enhance U.S. Cadmium (Cd) and Heavy Metals standard for toys Existing US Standard Surface coatings only Existing EU Standard Surface coatings AND substrates TIA Working Group formed Membership includes toy companies, labs, retailers and representatives of the EU CPSC informed ASTM contacted and outside experts retained 6 March 1, 2011 Page 3

5 TIA Initiatives Development of simplified screening test Check for total Cd to determine whether additional, lengthier testing is needed Can reduce testing expenses and time, while assessing compliance Review scientific basis for EU Standard Confirm its effectiveness 7 CPSC Jewelry Investigation CPSC launches jewelry investigation No existing standards for children s jewelry Toy industry initiative suspended CPSC findings released October 2010 Indicated effectiveness of existing ASTM F963 standard (soluble HM in surface coatings) No concerns regarding Cd in plastic 8 March 1, 2011 Page 4

6 CPSC Jewelry Investigation New concern regarding jewelry of certain characteristics Accessible Swallowable Plated metal Requiring longer duration test Toy industry decides to add CPSC test Very narrow scope of toys and components to which this is applicable (Accessible Swallowable Plated metal) 9 Consumer Organization Challenge November 2010 Call for ASTM Task Group Challenge to industry-led initiative Initiate new effort from scratch Projected new date for revised standard Late TIA forms WG ASTM forms TG Projected Late 2011 Proposed ASTM F963 draft on Cd expected 10 March 1, 2011 Page 5

7 Case Study: Lessons Learned Circumstances complicate effort Abundance of other consumer product safety issues Emergence of U.S. state-level legislation 11 Case Study: Lessons Learned Circumstances complicate effort Abundance of consumer product safety issues Emergence of U.S. state-level legislation Resistance to alignment Skepticism about non-u.s. standards Concern whether EU standard is outdated 12 March 1, 2011 Page 6

8 Case Study: Lessons Learned Circumstances complicate effort Abundance of consumer product safety issues Emergence of U.S. state-level legislation Resistance to alignment Skepticism about non-u.s. standards Concern whether EU standards is outdated Earlier involvement of consumer reps 13 Case Study: Lessons Learned Circumstances complicate effort Abundance of consumer product safety issues Emergence of U.S. state-level legislation Resistance to alignment Skepticism about non-u.s. standards Concern whether EU standards is outdated Earlier involvement of consumer reps Separate CPSC investigation launched 14 March 1, 2011 Page 7

9 Promising Elements Forward-looking industry initiative Involvement of technical experts Review of technical basis for EU standard Addition of screening test Recognition by regulators for industry effort Addition of new test for rare toy parts based on CPSC investigation 15 Looking Ahead: Opportunities CPSC assessment of entire ASTM F963 toy safety standard Alignment of emerging standards Increased communications and coordination among global safety authorities 16 March 1, 2011 Page 8

10 Looking Ahead: Emerging Obstacles Unwarranted standard proposals Ban on all fragrances? Heavy metal limits at trace levels? Testing for list of CMRs not used in toys? Risk-assessment needed as basis for standards Unwarranted standards a barrier to trade 17 Conclusion Contributors to success Transparency Technical expertise Proven, risk-based standards Goal of enhancing safety Alignment of emerging standards New level l of confidence in global toy safety Opportunity for APEC 18 March 1, 2011 Page 9

11 Efforts to Align US/EU/ISO Toy Standards for Cadmium Carter Keithley, President Toy Industry Association (U.S.) 6th APEC Conference on Good Regulatory Practice Washington, DC March 1, 2011 March 1, 2011 Page 10