 All right everybody. Thank you for joining us. Hopefully you can hear me, okay? Welcome to the CPSC webinar series. My name is Shelby Mathis. I'm the small business ombudsman at the Consumer Product Safety Commission and our topic today is a children's toy overview. So without further ado, let me get started. I've got to begin with a disclaimer, which is that this presentation was prepared by CPSC staff. I'm a CPSC staff member here at the Consumer Product Safety Commission and as a result of it being prepared by staff, the views expressed here may not reflect the views of the Commission. So for the agenda today, we wanted to kind of start out with a broad overview and then kind of drill down to the specific requirements of the toy standard because we get questions that kind of run the gamut on very generic questions to very specific questions on parts of the toy standard. So we'll start out today by talking about children's products in general and the labeling requirements that apply to them along with the product classification and age grading that applies to them and then testing and certification requirements on children's products as a whole. Children's toys are considered children's products. So all those categories are going to be applicable to children's toys just like they are to children's products in general. Then we'll move to children's toys and specifically the new U.S. Toy Standard, which is ASTM F 96317. We'll talk about the requirements there. Everything from testing requirements to labeling requirements and it's a big standard. We're not going to be able to cover everything today, but we are going to highlight some things that may be of interest to your business and hopefully you'll find that useful information. And then we're going to move to what I hope will be a fun part of today's presentation, which is a test your knowledge section where I'm going to ask you guys to participate in some audience polling that I'm going to do where I will send out questions into the ether and ask you guys to guess the answers and then we'll find out whether or not you're right on what sections of the toy standard apply to hypothetical toys. Once we move through the interactive part, I'll talk about what it means to be a small batch manufacturer with the CPSC and what some of the registration benefits are for small batch manufacturers. Then I'll talk about children's product certificates, when you need to have them and what the content is in a children's product certificate and how you can meet that requirement. And then I'll move to business resources that are available through the CPSC on our website, cpsc.gov and through things like our YouTube channel where webinars like today's webinar will appear. And then finally we'll move to a Q&A session that'll be at the end where I'll go through some of the questions that have been submitted and provide some answers. But again, as we move through the slides or as I move through the slides, please feel free to submit questions via the toolbar on the right hand side of your screen. All right. First off, let's talk about tracking information because this is a requirement that applies to all children's products. Tracking information has to be permanently affixed to both the children's product and its packaging if it's practicable to do so. And the following identifying information must be ascertainable from your tracking label and this is pursuant to the Consumer Product Safety Improvement Act, section 103. So you want to look for these four things on your label or tracking information on the product and packaging. You need the name of the manufacturer, importer, or private labeler. You need the location where the product was produced. You need the production date of the product and then lastly other identifying information which could include things like a batch or a run number or both or purchase order numbers. But keep in mind here that other identifying information doesn't have to be a number. It could be letters, symbols, colored markings, a date wheel. It could be your website, any other types of identifying information that would help you figure out where in your product chain a product was made. Because we get so many questions on tracking label and tracking information requirements here at the CPSC, our office has actually put together in conjunction with a lot of other staff here that have expertise on tracking requirements a frequently asked questions page that's our tracking label FAQ site and it is available via the hyperlink at the bottom of your screen. But again you're not going to be able to click that hyperlink unless you download the handout on the right hand side of the screen in PDF and then follow the link there. But it is available via cpsc.gov forward slash tracking label and it'll have a lot of questions and answers on commonly asked questions about tracking labels. In terms of product classification and age grading, this is another topic area that we get a lot of questions on. There are basically two categories or classifications of products. One would be children's products and we consider a children's product to be something that is primarily intended for a child aged 12 and under to interact with. If it doesn't fall under that definition that it's a general use product and whether or not your product is a children's product or would be considered a general use product is something that a lot of businesses kind of struggle to figure out. So again we've put together a frequently asked questions page that might be of interest to you guys and that's at our CPSC staff FAQs that's available via the address that appears on your screen and again that hyperlink is available via the handout for download on the right hand side of your screen under the handout section. In terms of age grading and age determination guidelines the CPSC staff put together a document entitled age determination guidelines related to children's ages to toys characteristics and play behavior in September of 2002. That document is available via our CPSC.gov website it's also available via hyperlink and handout but we're looking to update that document and we've actually published a revised draft that we would like for you guys to take a look at and we would like to receive public comment on it. So that draft updated age determination guidelines is entitled draft guidelines for determining age appropriateness for toys and public comment the public comment period on that document is currently open now and comments can be submitted by visiting the federal register and referencing the docket ID on your screen or again if you want to submit public comments you can follow the hyperlink that is available in the handout for download on the right hand side of the screen. Important thing to remember here once you've reviewed that draft guidelines document that we're looking to get public comment on you're going to want to make sure you comment by the deadline which is June 11th of 2018. Now let's move into testing and certification requirements on children's products. Children's products again this does cover children's toys that is a category of children's products must be tested at a CPSC accepted third party lab and you have to make sure that you're testing to the applicable CPSC product safety requirements which we're going to talk about in more detail a little bit later in this webinar. Now important to remember here there may be some exceptions that it could apply if you're a registered small batch manufacturer but we're going to discuss those in a little bit more detail later in the webinar today. In terms of trying to find a CPSC accepted third party lab that can help you test your children's toy you're going to want to visit our CPSC accepted lab page which we have just revamped and we hope that you'll find it as useful as we do in its enhanced search functionality that's available via cpsc.gov forward slash lab search. On the new lab search page you can include multiple terms in a keyword search such as flammability in China which would apply to something like children's clothing. If you're having that made in China or you're looking to test in China you could type in flammability China in the keyword search and you would find labs located in China that can conduct flammability testing for you. On the labs search page you also have the ability to narrow the search by region which includes country, city and state and you can also narrow the search by testing scope and when looking for labs you're going to want to make sure that you include all the testing that you'll need to have done on your product so that you find a lab that can conduct all the testing that you'll need done on your children's toy. Now last thing to remember here and we'll cover it in more detail a little bit later are that manufacturers and importers once the testing has been completed on their product need to certify that their children's toys are compliant in a children's product certificate and we'll talk a little bit more about what's included in a children's product certificate in just a second. Moving on to actual testing requirements here the first one is lead content testing and this is a testing requirement that applies to all children's products again including children's toys. This is a requirement straight from Congress at 15 USC 1278A. The limit is that no more than 100 parts per million of lead can be in accessible component parts of children's toys. Now in terms of testing burden reduction we do have good news here there are several substrates that our agency has released via reg that we know we're not going to exceed the lead limit in an untreated and unadulterated state. So if you are making a children's toy that is primarily based on one of the four bulleted items shown on your screen or any of the untreated unadulterated materials that are listed in our regulation 16 CFR 1500.91 then you would not need to conduct lead testing on those components of your children's toy and I've highlighted a few here but the list at 1500.91 is pretty extensive. It includes things like wood paper and similar materials made from wood. It also includes CMYK process printing inks which are inks that do not fully or inks that fully incorporate into the substrate or a textile for instance and don't sit on the surface. Natural and manufactured fibers and dyed and undyed states there's a pretty extensive list of both natural fibers and manufactured fibers in 1500.91 that are not going to exceed the lead limit and therefore don't require lead content testing. And then there's a whole list of other materials that are detailed in that regulation so if you have a product that you're curious whether or not lead content testing is needed on or whether it might fall under this list of substrates that don't exceed the lead limit I encourage you to visit 1500.91 and you can do that again via the handout on the right hand side of your screen by following the hyperlink in the PDF version of today's presentation. Now if there is paint or similar surface coatings on your product then lead in paint and similar surface coatings testing would apply and that requirement is from our regulation 16 CFR 1303 the limit there is that no more than 90 parts per million of lead can be in the paint and surface coatings on your children's toy. Now let's move to phthalates which is a topic that kind of can trip people up in terms of what it applies to and when this testing is required phthalates actually has a new regulation it's our regulation 1307 it became effective on April the 25th of 2018 on goods manufactured or imported into the US as of that date so in terms of phthalates testing and when it applies the limit here applies to children's toys and childcare articles and there are eight specified phthalates now that cannot exceed the 0.1% concentrations those phthalates are listed on your screen but for abbreviation purposes i'll go through them quickly they are d-i-n-p-d-p-e-n-p-d-h-e-x-p-d-c-h-p-d-i-b-p-d-e-h-p-d-b-p and b-b-p and a few important things to note here phthalates testing applies to children's toys and childcare articles but only if those toys and child or childcare articles contain plastic component plasticized component materials if you're making a product that doesn't contain a plasticized component material even if it's a toy or a childcare article phthalates testing would not apply to that product because there's no plasticized component that could contain phthalate also of note each individual phthalate is subject to the separate 0.1% limit which means theoretically that you could have a compliant children's toy that contains less than 0.1% individually of each of the eight phthalates that appear on the screen and the reason we've written them out and we've given the abbreviations is because sometimes your testing reports are going to abbreviate it and sometimes they will spell out the phthalates that the testing has been conducted on so this is should serve as an easy reference for you guys for testing burden relief on phthalates we do have good news there our agency passed a regulation 16 CFR 1308 which was determinations regarding certain plastics this became effective on September the 29th of 2017 and was subsequently amended on April 25th of 2018 in order to coincide with the updated phthalates rule that we just discussed the reason this is testing burden reduction is because seven types of plastics that are listed below are now no longer required to undergo third-party testing for compliance with mandatory phthalates prohibitions and again we're talking about toys and childcare articles here the list of seven plastics are polypropylene polyethylene high impact polystyrene acrylonitrile butadiene styrene general purpose polystyrene medium impact polystyrene and super high impact polystyrene and again the abbreviations are there because your documentation from your supplier or your manufacturer may reference either the abbreviations or the full list or the full designation of the plastics we wanted to give you something that was an easy reference point for you so if you're curious whether or not the plastics are the plastic components of your children's toys contain any of these seven plastics you'll want to check the paperwork from your supplier for reference now let's move on to the toy standard which I think is really why we're all here today as I mentioned the new toy standard is ASTM of 96317 we have incorporated the U.S. toy standard into our regulation 1250 and made the toy standard mandatory with a modification concerning sound producing toys which we will highlight in just a second the new toy standard applies to toys manufactured on or after February the 28th of 2018 and it requires them to be tested to the applicable sections of ASTM of 96317 now the U.S. toy standard is a copyright protected document that is available for purchase via ASTM.org and again that hyperlink appears in your handout the PDF of the slides today and you're able to just follow that link straight to purchase the U.S. toy standard from ASTM also of note flammability testing is something that is included in the U.S. toy standard at section 4.2 however congress chose not to mandate flammability testing on children's toys so it is likely that most toys are not going to be required to be tested to the flammability test in the toy standard even though it does appear in that standard so let's talk about some of the testing requirements and I mentioned earlier that this is a big standard so we're going to highlight a few of these today but I would encourage you if you're making several different types of toys or you're importing several types of toys it might be worth it to purchase the toy standard and just take a look at the document because it is quite extensive and covers a lot of different variations of toys so in terms of testing requirements today I just want to highlight the following the first is probably the most common test that applies to most children's toys and that's heavy elements that's from section 4.3.5 for sound producing toys there are testing requirements specific to those types of toys and I've already alluded to the fact that this is modified by our regulation 1250 for stuffed toys there are testing requirements for both the stuffing materials and the stuffed toys themselves and how they perform and those sections are referenced on your screen. For toys that contain small objects folding mechanisms and hinges cords straps and elastics there are specific testing requirements associated with those types of toys or limitations in the length depending on the applicable component to your toy and those sections are shown at your screen of note small objects has a regulation here at the CPSC that applies to it as well we'll cover it in a little more detail in a second which is our regulation 1501 for ride on toys there are stability and overload requirements which we'll touch on briefly and those are at section 4.15 in the toy standard pacifiers teeters and rattles are also covered in the toy standard and have testing required for them and so do projectile toys and there are toy gun marking requirements which we will touch on today as well we'll also go through battery operated toys and the testing requirements there in addition to electric toys that may plug into the wall lastly we'll touch on toys with magnets and the testing requirements there and we won't have time to cover today but it is of note because these were changes from the 16 version of the standard to the 17 version of the standard and that's expanding materials which was a new toy category added in the 16 version of the standard along with toy chest which were reincorporated in 16 from the 07 version of the toy standard so they each have their own testing requirements in the toy standard too I did want to say kind of as a disclaimer there are a lot of testing requirements in the toy standard and we're doing our best to highlight as many of them here as we can but this is not a meant to be an all-inclusive list so if you're curious whether or not there are more requirements for testing on your toy you'll want to see the actual toy standard itself so let's kind of go a little bit more in depth into most of these testing requirements for heavy elements the toy standard is worried about or concerned I guess with eight elements and the migration of those elements from the toy to the child playing with the toy those eight elements are antimony arsenic varium cadmium chromium mercury and selenium and again we've included the abbreviations for each of those elements for ease of reference in case you have a testing report that is referencing cr instead of chromium for a test that was conducted by your supplier the limits here vary by element and apply only to accessible toy components that can be sucked, mouthed or ingested in terms of testing burden relief on heavy elements testing as required by the toy standard we have a regulation our 1251 that excludes from heavy elements testing unfinished and untreated wood however of note the unfinished and untreated wood regulation does not include manufactured or engineered wood products however there is work being done at our agency now to try to move for a potential regulation that would offer testing burden relief on those sorts of products as well for sound producing toys there is section 4.5 of the toy standard that applies specifically to sound producing toys if you are making or importing a sound producing pull push toy so it would need to meet both of those requirements the pull push toy that also produces sound then you're going to want to make sure you comply with both our regulation 1250 which has a specific provision at 1250.2c instead of complying with the push or the pull push sound producing toy test of the toy standard so for sound producing pull push toys you want to take a look at 1250 and make sure that you conduct that alternative test from the toy standard for stuffed toys as I mentioned there is a test for stuffing materials at section 4.3.7 this stuffing materials test takes a look at loose fill for stuffed toys to make sure that they're free of certain types of objectionable matter and the testing there is actually outlined in 8.29 of the toy standard of note here is if you are making a stuffed toy that's filled with brand new polyester fiber filling or a similar non-organic brand new material then evaluation under this standard is likely not required the standard is trying to get at eco recycled reused stuffing components that may contain things that weren't in the original polyester fiber fill that was brand new. I also mentioned that for stuffed and beanbag toys there is a specific performance test and that's the seam strength test that's at section 4.27 of the toy standard and the testing procedure is actually at 8.9.1 if you're making or importing a stuffed toy and you want to know more about the specific requirements for stuffed toys I would strongly encourage you to visit our stuffed toys webinar which is available via our YouTube channel through that hyperlink again via the handout and pdf on the right hand side of your screen to learn more about stuffed toy requirements and actually see a seam strength test and some use and abuse testing on stuffed toys being conducted during that webinar. I touched on the small parts regulation this has a part of the toy standard it's at section 4.6 it's known as the small objects section it also has a portion of our regulation 1501 that is completely dedicated to small parts testing small parts present a choking aspiration and ingestion hazard and it's defined as one that fits entirely into a small part cylinder as specified in the regulation you can actually see a small part cylinder on your screen on the bottom right hand side you see that we've got a pole toy that during use and abuse testing has liberated a wheel which also dropped a screw which fits entirely into the small part cylinder so that screw would be considered a small part our small parts regulation bands toys that are intended for use by children under three that have small parts so that'd be small parts that are produced during use and abuse testing and those that actually come with an object so or as received small parts are not allowed in toys that are intended for children under three. Let's talk about stability and overload requirements for ride-on toys there are several requirements here we're going to touch on stability there are sideways stability requirements and then for and aft stability requirements so kind of a front and back rocking and a side to side rocking stability requirements and these requirements apply to all toys intended for use by children five years old or less and the category here cut or the testing here covers ride-on toys with three or more load bearing wheels ride-on action type toys such as hobby horses and rocking toys just like the one we see in the photograph here and then toy seats would also be subject to stability requirements overload requirements not covered here but they do apply to ride-on toys as well and are even more in-depth than the stability requirements shown on your screen for pacifiers, tethers and teething toys and rattles these are a little bit complex because they contain references in the toy standard and also references in our regulations for pacifiers they're at toy standard 4.20 and our reg 1511 you'll want to make sure that you comply with both of those requirements and of note pacifiers cannot be sold with clips or other strings and that is per our reg 1511 for tethers and teething toys you'll want to make sure that they comply with our reg 1510 if they fall under the cpsc jurisdiction along with the requirements of the toy standard which are shown at 4.22 please note that products intended to soothe sore gums due to teething may be medical devices that are regulated by the FDA so if you are creating a teething toy or a tether in general you'll want to check with the food and drug administration specifically to see if it falls under their jurisdiction and outside our jurisdiction for rattles rattles must comply with our reg 1510 and section 4.23 of the toy standard of note with pacifiers and rattles those are two products that the federal hazardous substances act which is a act that the cpsc enforces actually bans pacifiers and rattles that do not comply with 1511 and 1510 and that ban is actually at our reg 1500.18 of the fhsa so you'll want to make sure that pacifiers and rattles if you are making or importing those are fully compliant with the requirements on those products for battery operated toys and electrically operated toys there are requirements here that are pretty specific to those toy types for battery operated toys we're trying to address or the toy standard is trying to address the potential risk associated with battery use in toys things like battery over heating leakage explosion and fire and choking on or swallowing batteries are all concerns with battery operated toys so if you are importing or making a battery operated toy maybe like our little cat here that's connected or a robot cat that's connected to a little battery you're going to want to make sure it's been tested to the battery operated toys provisions of the us toy standard for electrically operated toys like our sad robot here sitting down on the floor recharging with the wall plug electrically operated toys fall under our reg 1505 and they're defined as products intended for use by children that are powered by electrical current from a nominal 120 volt branch circuit and again you want to make sure these comply with our reg 1505 if you're making or importing electrically operated toys for projectile toys the section of the toy standard that applies to section 4.21 and it's meant to address unexpected hazards that may be caused by a projectile firing toys and by the firing of improvised projectiles from such toys so what's an improvised projectile it is an unexpected object that can also fit in the projectile and shoot out of it so those are the hazards associated with projectile toys and as a result very extensive section of the toy standard on projectile toys that breaks product categories down into a few different subcategories based on projectile travel distance there are break points of 100 millimeters and 300 millimeters and then projectile toys with stored energy versus projectile toys without stored energy have different testing requirements in the toy standard for toy guns they're covered under section 4.30 of the u.s toy standard and the toy standard there is seeking to address the issue of toy guns being mistaken for actual firearms you'll see in your picture on the screen of the toy gun it's got an orange cap on the end that is actually part of the requirements of the u.s toy standard for toy guns as a cue that this is a toy gun as opposed to an actual firearm for toys with magnets those are covered under section 4.38 and per the u.s toy standard toys cannot contain a loose as received hazardous magnet and we'll get into what that means in a sec nor can it liberate a hazardous magnet after use and abuse testing under section 8.25 there is a special exception in the toy standard for magnetic or electrical experimental sets provided that they meet labeling requirements that are set out in section 5.17 so magnetic and electrical experimental sets can contain loose as received magnets but they have to make sure they comply with the labeling requirements of the section a hazardous magnet is defined in the toy standard as those that have a flux index of 50 or greater and how to calculate flux index is also outlined in the toy standard for toys that have magnets there is also a soaking test at section 8.25.4.1 that's required for wooden toys toys used in water and mouth actuated toys and then lastly there is additional use and abuse testing required for magnetic toys that's outlined in section 8.25 as well at the subsections that are shown on your screen so since we highlighted so much of the testing requirements from the toy standard let's take a look at the labeling requirements that are included there and again these are highlights there are other labeling requirements that are part of the toy standard but we're trying to give you a broad overview of some of the most asked about labeling requirements that we hear from businesses the first is there's a labeling requirement for aquatic toys in the toy standard crib and playpen toys also have a labeling requirement associated with them as do mobiles stroller and carriage toys and toys with functional sharp edges or points toys that contain small objects small balls marbles and balloons also have specific labeling requirements as do electric toys and battery operated toys which would include battery powered ride on toys and toys that are battery operated that contain button or coin cell batteries have labeling requirements associated with them and then lastly toys with magnets also have labeling requirements on them so you'll want to make sure that you check those specific provisions of the toy standard to make sure you're meeting those labeling requirements for toys that contain a small object small ball marble or balloon there are specific labeling requirements that I just kind of want to touch on briefly toys and games that are intended for used by children older than three but younger than six that contain small parts as received must be labeled with a choking hazard cautionary statement in addition toys that contain small balls marbles and latex balloons must also include certain cautionary labeling statements on the product packaging and in the marketing statements in terms of what these cautionary statements need to look like on the product packaging and marketing statements you'll want to visit our regulations fifteen hundred point one nine fifteen hundred point two zero and fifteen hundred point one two one for more information on those requirements of note for the cautionary statements that we're referencing here on toys and games that contain a small part as received that are meant for children uh older than three but younger than six and those with small balls marbles and latex balloons those statements do not need third party testing in order to ensure their compliance you'll just need to it is your obligation as a manufacturer importer of record to make sure that your products are meeting those cautionary statement labeling requirements all right now it's time for what I hope will be a fun part of today's presentation which is to test your knowledge of the toy standard and we're going to do five questions hopefully you'll find some of them challenging and some of them are going to be a complete breeze so first up we've got these three multicolored pacifiers and the question here is what would each colored pacifier need to be tested for chemical requirements so i'm going to put the question up on your screen and then i'm going to ask you to tell me whether or not each of those different colored pacifiers would require separate chemical testing and your answer options are yes no and it depends and it looks like lots of folks are participating i'll give you guys uh about 10 more seconds to get your answers in thank you to everybody who is submitting their guesses on what the answer is here on these colored pacifiers and whether each one needs separate chemical testing requirements all right i'm going to close the poll and let's take a look and see what we as a group thought the answer was on whether or not uh separate chemical testing was required for each of the pacifiers and it looks like overwhelmingly you guys thought that the answer was yes each of the multicolored pacifiers would need separate chemical testing let's see if you were correct the good news is we're off to a good start you guys work correct yes each individual component color needs to be tested for applicable chemical requirements so great work let's see if we can continue this trend on the next question so our second product is this pyramid that is built with what you're supposed to assume are magnetic balls and for purposes of this question we're going to assume this is a children's toy so we're going to assume that the age grade for it is 12 or under the question here is does the magnet soaking test at section 8.25.4.1 apply to the magnetic toy as shown and i'm going to put the question up i'm going to have you guys guess whether or not the magnet soaking test would apply to this pyramid magnetic toy and again thank you to everybody who's voting the answers are coming in i'm going to give you guys about 10 more seconds to get your guesses in all right and it looks like most of you have participated so i'm going to go ahead and close the poll and let's see what we as a group thought on whether or not this magnetic toy would be subject to the soaking test and it looks like 58 percent say no and 32 percent say yes with nine percent saying it depends so i'd say that's a pretty even split let's see who was right the answer here is no this toy would not be subject to the magnet soaking test because that magnet soaking test only applies to magnetic toys with mouth actuated components which this one does not have to wooden toys with magnets which this is not a wooden toy or for or to toys used in water which this would not fall under that category either the answer here is no speaking of water let's move on to our next toy which are two water guns and the question here is do the water guns shown need to meet the projectile toy section which is section 4.21 of the toy standard f96317 so would these water guns fall under the projectile toy testing section of the toy standard put the question up on your screen and your answer options again are yes no and it depends and thank you everybody for participating it's amazing the level of participation from you guys so i'll give you just a few more seconds to get your answers in on whether or not you think these water guns would fall under the projectile toy testing section of the toy standard all right let's see what we as a group thought the answer was it looks like 67 percent don't think that the projectile toy testing requirements of the toy standard would apply to these water guns and 30 percent think they would so let's see who was right the answer here is no so the majority was correct the projectile toy testing section would not apply here because these toys are water guns and they don't actually fire a physical projectile such as a foam dart or an arrow so let's move on to our fourth product which is this nice ride on toy and the question here is does the ride on toy shown need to meet the sideways stability and for an aft stability testing requirements of the toy standard astm f 963 17 so do we think that ride on toy would need to meet for an aft and sideways stability testing requirements and the answers again options are yes no and it depends you guys are getting even faster at submitting your answers and again i say thank you so much for participating in this i like that you can't see what everybody else is submitting because it keeps it keeps you guessing all right since it looks like most folks have participated i'm going to close the poll and let's see what we thought the answer was as a group looks like overwhelmingly 94 percent of you thought that this ride on toy would be subject to the sideways and for an aft stability testing associated with ride on toys in the toy standard let's see if you were correct yes you were absolutely correct you guys are getting great at this the reason that this ride on toy would be subject to the for an aft and sideways stability testing is because it's a ride on toy that's intended for use by children five years old and under and as a result those stability tests apply all right final product we got this nice teddy bear and the question on this stuff toy is whether or not the stuff toy as shown would need to be tested for small parts so what do you guys think answer options here are yes no or it depends we had to give you a potential it depends legal option there and answers are coming in i'm going to give you guys just a few more seconds to submit all your responses all right and it looks like most folks have participated so i'm going to close the poll and let's see what we thought as a group um on whether or not that stuffed bear would be subject to small parts testing it looks like 80 percent say the answer is yes although 12 percent say it depends so let's see whether or not the yeses were right and you were correct because the toys intended for children under three and it has the potential to produce small parts via those cute little plastic eyes small parts testing would apply to this stuffed toy so great work everybody and thank you for participating in the polling hopefully you found that fun now i want to move on to small batch manufacturer uh requirements and the benefits of registering as a small batch manufacturer in order to qualify as a small batch manufacturer you need to meet two requirements which is that your gross income or your sorry your gross revenue in prior calendar year 2017 cannot exceed 1.12 million dollars and you cannot have manufactured more than 7500 units of a covered product that qualifies you for registration as a small batch manufacturer if you meet those two requirements there are benefits associated with registering it allows you to potentially avoid third party testing at an independent cpsc accepted lab for specific test on certain types of children's products and the reason i bring this up is because testing to the toy standard is one of those tests that you could potentially avoid uh going to a cpsc accepted third party lab for if you are an eligible registered small batch manufacturer now um a few things to keep in mind here are the types of tests that you are required to undergo to the toy standard uh there are some that may be difficult for you as a manufacturer to do at home but for more information on what types of tests you can conduct as a registered eligible small batch manufacturer please visit our small batch manufacturer page which is available at cpsc.gov forward slash small batch and again the hyperlink is available via the handout for download on the right hand side of your screen so i wanted to put together a chart that would kind of be a useful reference tool for small batch manufacturers that would kind of chronicle potential testing type that could apply to your children's toy on the left hand side and then go through whether or not you have to use a cpsc accepted third party lab to do the testing whether you can rely on written assurances from your supplier and a written assurance is something less than an actual physical testing report uh and whether you can rely on timely component part testing from a supplier to avoid retesting um i i won't go through the chart because that's going to be really time intensive but a few things i want to point out um for small parts in terms of component part testing um you may be able to rely on component part testing and avoid retesting on small parts but testing needs to be done on a finished toy small parts testing that's not done on a completed product is not useful small parts testing um so that's a caveat there and on the toy standard can you rely on component part testing from your supplier to the toy standard the answer is yes for chemical testing because those things aren't going to change when you assemble a toy however the physical and mechanical testing so we're talking basically all the testing that we just went through including use and abuse you want to make sure that that uh component part testing or testing from your supplier is done on a finished toy uh because that will impact uh the overall results um of a use and abuse test now let's get to children's product certificates there are seven required elements in a children's product certificate that are shown on your screen a few things that i just want to highlight are section two in a through e shown on the screen i've listed out all the testing requirements that could apply to your children's toy and could need to be referenced in section two of your children's product certificate and these should look familiar because we've gone through each of them uh today during the webinar uh for lead in paint and surface coatings and phthalates those would only apply to your toy if you have paint and surface coatings or if you have plasticized components on the phthalates testing phthalates testing would only apply to plasticized components if there are none phthalates testing is not going to be applicable to your children's toy in section six i also want to point out that if you are relying on testing exceptions or exemptions some of which we've talked about today then you're going to want to reference those in section six an example here would be a reference to 16 cfr 1500.91 which is a list of the materials or substrates that we know won't violate uh or exceed the lead limit you're going to want to make sure that you reference 1500.91 for lead testing exemptions i'm going to highlight a few business resources i've got my contact information including my email address and a telephone number up on your screen that telephone number 301 504 7945 rings at three desk now so we should all be able uh hopefully assuming we're not in meetings to answer calls so if you have questions and you want to talk to a live person give us a call on 7945 i also want to point out we have a twitter feed at cpsc small biz if you're wondering what's going on at the cpsc this is a great way for you to keep tabs on changes that could be happening uh our business guidance web pages which are available via cpsc.gov forward slash business education are also fantastic we have approximately 60 separate business education pages that are unique to product types so if you are importing a uh non-full-sized crib and you want to know what the requirements are go to cpsc.gov forward slash business education click on the non-full-sized cribs link on the right hand side of that page and it'll tell you what the requirements are for non-full-sized cribs i would be remiss if i didn't point out that we've updated our toy safety business education page uh to correspond to today's webinar you can follow the hyperlink in the handout on the right hand side of your screen we also have our youtube channel where all of our webinars like today's webinars live that's at youtube.com forward slash uscpsc and you'll want to click playlist and business education to view those webinars and then last but not least we have our regulatory robot an interactive bot that will answer questions uh or ask you questions about your product and based on your answers will tell you the requirements for that product type in a downloadable report that you can keep yourself for records so because we only have one minute left and i want to end on time i want to point out two things um of note for you guys before signing off today one is if you want to stay up to date on what's going on at the cpsc please sign up for our small business ombudsman newsletter or if you want to know about upcoming webinars we post those um or we email out the newsletter monthly and there's a large subscriber list we would love for you to join that you can sign up by visiting cpsc.gov forward slash email and selecting small business ombudsman updates my contact information is on the screen and lastly once i end the webinar there will be a short feedback survey that pops up if you have ideas for future webinars that you would like to see or topics that you want us to cover please let us know we would love your feedback and we really appreciate your attendance today apologies again on the technical issues and we look forward to uh you attending future webinars that we have here at the cpsc small business ombudsman office thank you and have a good rest of your day