President’s Letter – September 6, 2011: Tools
to Help You Meet New EU Requirements
September 6, 2011 | On July 20th, the
revised European Union Toy Safety Directive (TSD) placed a new set of
requirements on companies selling toys in the European market.
There were two significant changes:
- First, the “risk assessment” that manufacturers must
perform on every toy sold in the EU must not only evaluate compliance
with safety standards but also assesses the safety of all
chemicals contained in that product.
- Second, the number and scope of documents that a toy manufacturer
must maintain for each SKU sold in the EU was expanded and the retention
requirements extended until 10 years after the product is no longer
available at retail.
“But,” you say, “I already know there aren’t
any prohibited chemicals like lead or phthalates in my toys because I
specify that they must not be there and I test to be sure they are
No longer good enough.
Your responsibility under the new TSD is to assess the safety of
every chemical in the toy – be it a pigment, stabilizer,
phthalate-alternative plasticizer or other – and to maintain the
assessment results in a long-term dossier. The tests can be a
complicated and expensive undertaking requiring labs and toxicologists.
And the record-keeping may be burdensome for many companies, especially
small and mid-size manufacturers.
Against this background, TIA and our colleagues at Toy Industries of
Europe (TIE) set out to find a convenient tool that could assist toy
companies in complying with the new chemical safety assessment
requirements in the most efficient and least expensive way. In
addition to the services provided by independent testing laboratories,
we found SciVera, a Charlottesville, VA-based company that has provided
similar tools for other industries. SciVera offers a web-based
product that evaluates ingredient information provided by you and your
suppliers against an extensive database of peer-reviewed toxicological
data to assess the product for a comprehensive panel of potential safety
hazards. And because chemical formulations may be proprietary,
this system securely preserves the privacy of proprietary formulas. The
SciVera platform allows personnel without extensive scientific or
toxicological background to manage a process which is compliant with the
revised TSD requirement, without the need to utilize toxicologists or
other more expensive options.
Meanwhile, our colleagues at the Hong Kong Toys Council (HKTC) have
worked with a software developer to create an online repository, the
Chemical Management Database, or CMD, for all the documents that must be
maintained by toy manufacturers. Because we have worked together
on these efforts, the information entered into the HKTC-led CMD can
easily be uploaded into the SciVera chemical safety assessment
TIA and TIE have no ownership stake in either of these new
tools. We assisted in their development because it is the duty of
your trade associations to provide collective solutions to industry
challenges. We believe these tools effectively address the
existing EU requirements, and will likely have application to the
emerging requirements in U.S. states such as California, Washington and
Maine, and those that may soon appear in other jurisdictions.
Additionally, the consistency of chemical safety assessments that are
provided through these systems will likely be a compelling argument
against a proliferation of new laws and regulations.
We will be providing additional information and details about these
tools in the near future. In the meantime, please know that we are
working hard to provide you with useful and cost-effective tools that
offer real value for your companies.