Toy Commenter Agrees with CPSC on Not Using F963 Noise Provision

CPSC got positive feedback in the single comment available as of the PSL deadline on its proposal against adopting certain noise-related elements of the F963 toy standard. However, there might be other comments as the docket tally indicated that two had not yet been made public yet. If those turn out to be significantly negative, then CPSC would need to reconsider the scheduled February 28 effective date. PSL will cover them once revealed.

In any event, on incorporating recent changes to the F963 standard, CPSC staff recommended (PSL, 11/20/17) that the agency not accept an update on push/pull toys and sound pressure. This is at 8.20.15(5) in the standard. The changes "reduce safety" they wrote. The commenter, a professional toxicologist, reacted (bit.ly/2CA1dJP), his emphasis:

"The 85 dB(A) limit recommended by [National Institute for Occupational Safety and Health] for 'continuous' noise workplace exposure for adults may serve as a reasonable initial limit for the present. For the future protection of children’s hearing which has a more sensitive threshold, I would encourage a more conservative approach which would include a 2-fold safety factor. This would limit the exposure as indexed to 82 dB rather than 85."

Outside the hearing-risk issue, CPSC would accept the other changes in F963-17, including:

• "Minor editorial changes" to the scope, labeling requirements and instructional literature sections.

 

• Nine new references involving microbiological guidelines.

 

• Three definitional tweaks: one removal, one clarification, and one editorial change.

 

• A fix of omitted wording in the 2016 version for stored-energy projectile toys. This oversight led CPSC last year (PSL, 4/10/17) to make an enforcement discretion decision because the error would have led to unnecessary testing costs. CPSC used the 2011 language.

 

• An annex rationale addressing the stored-energy update.