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SAFETY
Enterprise and Regulatory Reform) guidance is occurring. Fortunately however, most hazards Method of test and performance requirements.
more digestible and is a must read for every associated with common products have been 4. National codes of practice, eg BS 7907 Code of
manufacturer, importer, wholesaler or retailer considered by the various committees developing Practice for the design and manufacture of
(http://www.berr.gov.uk/files/file22713.pdf). legislation and the different types of national, children's clothing to promote mechanical
BERR explains everyone's responsibilities under the European or industry standards, so compliance safety.
regulation – including actions in the event of a with appropriate standards implies a level of 5. Industry codes of practice, in-house
product being found to be unsafe (ie: what a safety. specifications such as those that major retailers
product recall is and the essential steps to be In its simplest form, your risk assessment can ask set for their own brand.
followed). if the product complies both with any applicable 6. State of the art, or "as consumers might
Briefly, GPSR requires products to be safe "under legislation (usually mandatory anyway) and all the reasonably expect".
normal and foreseeable use". For articles used by appropriate standards. A product which complies with the requirements
adults or always used with adult supervision GPSR helps here as it gives a list of the types in of one of the above will be presumed to be safe
"normal use" is fairly simple, but for items used by order of priority. but for that feature only, for example:
children, especially if used or worn with little or no ● EU legislation, eg Marketing and Use of – a child's nightdress which meets the UK
supervision, this becomes more challenging. Dangerous substances directive which includes nightwear safety regulations will be presumed safe
It is "foreseeable" that some of our products, azo dyes and colourants, Nickel or The Ceramic for flammability requirements – only;
including promotional items, may be given to or Articles In Contact With Food Regulations 2006, – any child's garment which has cords and strings
used by children. A child in the course of normal Toy Safety directive. meeting the requirements of EN 14682 will be
development will explore and use their ● National legislation, eg UK Nightwear (Safety) presumed safe for cords and strings – only.
imagination through play, so a large cardboard Regulations 1985,
box becomes a boat, car, castle, house, snail or ● A harmonised standard, eg EN 14682 Safety of
tortoise. Equally a hooded jacket, with the sleeves children's clothing. Cords and drawstrings on
pulled inside, becomes a Batman cape, and so on. children's clothing, specifications.
GPSR also requires products to be safe for the ● A current list of "harmonised standards" – that
lifetime of the product, and includes secondhand is standards relating to GPSD which have been
articles, in contrast, for example, with the UK 1985 published in the EU Official Journal – is found at
Nightwear (Safety) Regulations which specifically http://ec.europa.eu/enterprise/newapproach/stan
exclude secondhand garments – however, GPSR dardization/harmstds/reflist/gpsd.html
takes precedence (as explained in BERR's Advisory If none of the above is available then the
Note http://www.berr.gov.uk/files/file48151.pdf). following are used in descending order of
Essentially GPSR requires an assessment of risk for precedence:
safety to be made for all products. This sounds 1. A European standard, which has not been
daunting, but for most ranges of products, features harmonised, eg EN 13758 part 2 Textiles. Meeting
are common and templates can be drawn up. Solar UV protective properties. Classification these
Risk assessment, is best carried out by a team, and marking of apparel. standards or
including senior personnel and the designer. An 2. Community specifications. legislation will
assessment may identify that a feature is not safe, 3. National standards, eg BS not ensure 100%
but working with a designer and brainstorming, 8466 Hats. Protection safety, but it will
similar aesthetics can often be achieved by some against solar meet a minimum
minor design changes. This is particularly true with UVR. level of
children's clothing. requirements. And it is
Whatever the outcome, record the findings important to recognise
together with any actions, sign and date the any aspect, feature or
document and keep it on file. The assessment usage of a product that
should be reviewed each buying season (at least) falls outside any standards;
by formally posing the question "what has you still need to ensure these
changed?" which might include: do not present a hazard.
● Modification to design – change of decoration Another point of note is, that
or embellishment; unless the standards or
● Production route or supplier; legislation explicitly state a
● Changes in consumer behaviour; product has to be labelled, eg CE
● Reported accidents - in your own product or marking for toys and electrical goods,
competitor's in similar product. (GPSR requires no markings are required.
you to be aware of safety issues and incidents Finally the good news. Unless the
related to your own and similar products), and product requires formal testing, for
● Changes to legislation or standards. flammability or for chemical content, for
So how do we assess what is safe? What example, most of the risk assessments can
measures do we have? As individuals our ideas of be carried out in house by your own team.
safe can vary. The team may require some training and
Theoretically, we need to do a hazard assessment coaching to begin with and take advice for
to recognise if any aspect of our product or its use novel products or where novel embellishments
has the potential to cause harm – and if you are or production routes are being considered, but
developing a novel product you may still need to otherwise risk assessment is not "rocket-science".
do this – and assess the likelihood of this harm Safety matters are crucial to everyone in the
company if the brand is to thrive. With a little
training and some business systems most
aspects can be addressed in house with
minimal cost.
Sue Bolton, is an independent consultant
specialising in product integrity and
compliance. See
www.boltonconsultancy.co.uk
www.printwearandpromotion.co.uk September 2009 | 45 |
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