 Let's go ahead and get started. First off, a disclaimer which is that I am a CPSC staff member and the views expressed here are my own. They may not reflect the views of the commission, which reminds me I should probably introduce myself. My name is Shelby Mathis. For those of you that don't know me, I am the small business ombudsman here at the Consumer Product Safety Commission. And again, just wanted to say thank you to everybody for your interest in this webinar series, this monthly series that we're trying to pilot here. This is the second one in our round of webinars. And today's topic will be stuffed toys. So with that, let's go ahead and get started. So our agenda for today, first we're going to take a look at age grading, which is something that we receive a lot of questions about. I bring this up not because age grading is something that we want everybody doing on their toys, because that is not the case. I bring it up because we get a lot of questions on what is an appropriate age that we should consider our toy in terms of age range of an intended user. So I've tried to make this as practical as possible, so we're going to go through some examples. I'm also going to touch on tracking information, and we're going to go through some frequently asked questions, because we get a lot of questions in our office about tracking labels, tracking information, what the requirements are and how best to comply. So I'll try to touch on that hopefully in a very useful way. I'll talk about the testing requirements for stuffed toys specifically. And in terms of testing requirements, we're talking about chemical and physical and mechanical testing requirements, and we'll watch a demo video, which I hope will be instructive for you guys, that will highlight some of the testing requirements that may apply to your stuffed toy. Then I'll transition over to small batch manufacturer registration, how you qualify, and then what are the benefits of registering. I'll go through a children's product certificate, the seven sections that are required, and then the content that would go in each of the sections. I'll highlight two stuffed toy recall examples that have happened within the past five or six years. And the reason that I bring that up is because I think there is a huge benefit in learning from recalls of the past in terms of designing a safer toy going forward. I will give you guys some business resources that our agency has available that hopefully you'll find useful, and then lastly we'll do a question and answer session at the very end. So first off, age grading for children's toys. I guess I should begin by saying that the information that I've included in this age grading section comes actually from a document that is available via our website. And that is the age determination guidelines relating to children's ages to toy characteristics and play behavior. That document is a very lengthy one, and it doesn't just include stuffed toys, it includes a whole lot of other things besides stuffed toys. It's going to have the same disclaimer on the front of it that this presentation does, which is that that is a document that was created by CPSC staff that may not fully reflect the views of the commission. It was created in September of 2002. It's available via our website. And for those of you that are interested in taking a look at it after this presentation, you can do so via the handout just by clicking the link on that PDF slide. So a few things to note about stuffed toys is that dolls and stuffed toys are often a child's first sensory object. I mean, I know for myself, I don't think I'm unique in this way. I remember very fondly stuffed toys of my childhood, and that kind of gets at the next bullet point, which is that children become attached to these stuffed toys, and they use them for security purposes and rely on that stuffed toy as a sense of security. And then lastly, stuffed toys are known as an important symbolic function, or servicing a symbolic function in pretend and role play. And the reason that I touched on these three bullet points is because your takeaway for stuffed toys, and part of the reason we get so many questions about them is stuffed toys are in general for a younger demographic. They are usually soft. They're attractive to a child. They're certainly plush and squishy. So for little kids, they're very attractive to these items. So while we can't make any blanket statements about proper age ranges for certain stuffed toys, in general the trend is that stuffed toys are for a younger demographic of child. So with that being said, I thought it might be useful if I pulled from the age determination guidelines documents maybe a little bit of a breakdown of age ranges and examples of toys in general that would fall into those age ranges. And again, we're going to have the caveat here, which is age ranges for stuffed toys are very widely based on the way the toy is designed, the way that it's built. So I've put this on the screen because it comes from that age determination guidelines document, but you should think of this just as an illustration, and it's just meant for, you know, in this teaching setting. And these aren't hard and fast rules. So it is an individual toy by individual toy determination. So with that being said, for really young children, so we're talking kids ages, you know, zero birth up to one year, types of toys that generally fall into that age grading would be small, plushed animals, stuffed toys, and grab on stuffed toys or soft toys. Probably no surprise there. For age range, one to two years, you're looking at small dolls, things that are washable, maybe some rubber baby dolls, peg dolls, which kind of skew a little older in that one to two year age range closer to the two year mark, and then simple dress me dolls usually have about a two year age grading. And the reason for, you know, the parentheses here is because dress me dolls, that's a role play thing that can't, you know, can't be done by a child that's not able to, you know, move and function and walk yet. So for a three year old child, you've got more complex dress me dolls, and then wooden and plastic peg dolls would fall in here. And again, some of these toys that are listed here may not be completely stuffed toys. They may be partially stuffed, partially wooden, partially stuffed, partially plastic. I just thought this was a nice example because we do get calls about certain types of toys that would fall into these categories. And then for the older age range, four to five for stuffed toys, because the children are becoming increasingly aware of society things and cartoons and cartoon movies, they tend to enjoy fantasy character, action figures, more life-sized dolls that come with accessories, and then fashion, military or other thematic dolls. So the next thing that I want to touch on is tracking information, because we get a lot of questions here. And the three main things to remember on tracking information are that it needs to be permanently fixed, and that tracking information needs to be on the product and the packaging. And we'll talk about what those three underlined things mean in more detail in the Frequently Asked Questions section in just a second. So the four things that you need to make sure on your tracking information on a stuffed toy are manufacturer, private label or name, the location and date of production of the product, you need detailed info on the manufacturing process, and there we're talking about a batch or a run number, and then any other info that's going to help a consumer ascertain the source of the product or the stuffed toy that they're holding in their hand. So one thing that we recommend here is your web address. If you've got a website for your business, putting that on a tracking tag of some sort or tracking information permanently on your product, it's got two benefits. One is if I'm a consumer and I want to buy something else from you, it makes it easy for me to go to your website. If somebody like your product, maybe I look at more products that are available. The other thing is it makes it easy for me to get in touch with you as a business if something goes wrong with the product. So from a manufacturer standpoint, you have the ability to sell future products, and from a consumer standpoint, you always have the ability to know how to get in touch with a company. So that would be an example of any other information that's going to help a consumer ascertain the source of a product. And then in terms of who must make sure that their stuffed toy complies with this tracking information requirement, it is domestic manufacturers and then importers. So some frequently asked questions here. And again, I'll provide the link, but I have taken this information from our agency website, and these represent sample questions that we get a lot. So the first one is must the tracking label be tested and certified? And we'll talk about what the testing and certification requirements may be a little bit later on. But as a blanket answer here, the answer is no, but you've got to make sure that when you put a label or some sort of tracking information permanently on a product that you're not introducing lead or heavy elements with that tag or label itself. The second question we get has to do with whether or not something's permanently affixed. And the question is, does an adhesive label on disposable packaging meet the permanently affixed requirement? The answer is maybe. And again, it depends on the adhesability or the strength of the adhesive, I guess, of the label that's on the packaging. And the main concern here is that label needs to reach the end consumer. So if it's going to reach the consumer, then that is sufficiently permanently affixed. If it's not going to reach the consumer and the label is just going to fall right off of the packaging as it's shelved in the store or as it goes through the mail, that's not permanently affixed and it would not meet the requirement. So other questions, what meets the location of production requirement? For domestic manufacturers, you need to include the city and the state and the country, meaning USA, of manufacturer. And then for international-made products, you're going to want to put the province and the country on the tracking information. Should the importer's name appear on the tracking label instead of the manufacturer's name? The answer is yes. If the product's being manufactured outside the United States, the importer's name is going to take the place of the manufacturer's name on that tracking information. A question we get a lot, and we've seen a lot of examples of these exceptions that I'll go through, is must the product and packaging both be marked? The answer is yes to the extent practicable. Subject to exceptions, and I want to highlight here that there are many more exceptions that are available via our website on the FAQs page, which I'll provide you the link to in just a second. Actually, it's on the next slide. So here are some exceptions where a product and packaging might not both be marked. Either one or the other would be marked. So what if a product is too small to mark? That would be an exception to the product and packaging marking. What if the product is stored in a box? So an example here would be a board game. In the case of a board game, you're going to want to mark the box or the outside container in one integral piece of the product, but you don't have to mark each of the individual pieces. Another one we get questions on, what if the product's impossible to mark? Examples, elastic, beads, jewelry. With those types of products, you're going to mark the packaging because the product itself cannot be marked. When the aesthetics of a product are ruined by a mark and cannot be placed in an inconspicuous location, you're going to mark the packaging and not the product. And then for products sold in pairs, an example here would be shoes, where you need both of them to have the item function. You're not going to go out of the house with just one shoe on. You would mark only one of the pair because you know they're always going to be together. So again, there are more of these exceptions available via our website. And that information is actually on the FAQs page, which shows up as a hyperlink on this slide. And in your handout, the PDF itself has the live hyperlink. That path to find it on our website is from the main page, Business and Manufacturing. You click Business Education and then Tracking Label. And it will take you to a frequently asked questions page on Tracking Label. One last thing I wanted to point out because we do get questions here. When did the tracking information requirement go into effect? It went into effect after CPSIA in 2008, and it applies to children's products made on or after August 14th of 2009. And there is no retroactive application. So if you're actually putting into commerce a product, a stuffed toy that is older than August 14th of 2009, in terms of when it was manufactured, the tracking information requirement would not apply to that pre-August 14th 2009 made toy. All right. Now that we've talked about tracking information, I want to get into some of the testing requirements. And I've broken them into two types. And hopefully this makes logical sense to you guys. One is chemical. That's one bucket. And then the second bucket of testing is physical and mechanical. So we're going to start with chemical because we probably get more questions about chemical, honestly. The first chemical testing requirement for stuffed toys is lead content testing. And that's mandated by Congress. Actually, it's under 15 U.S.C. 1278A. The total lead content limit cannot exceed 100 ppm in accessible parts of stuffed toys. And this isn't unique to stuffed toys. It applies to all children's toys. It's just today's webinar is about stuffed toys. So I'm caveating things that aren't stuffed toy-specific and genericizing things that are. So for the total lead content testing, there are a few materials that through years of testing as an agency, we know are not going to exceed the lead limit as long as they're in an untreated, unadulterated state. And what does untreated and unadulterated mean? It means that they don't have surface coatings. It means that they have not been modified in any way from their original form. And these materials, and there's a pretty extensive list. I've just highlighted a few here in bullets, are found in 16 CFR 1500.91 of our regulations. And again, that's a hyperlink that goes directly to the code of federal regulations on the PDF handout that's attached. So materials that aren't going to exceed the lead limit. If you fall into these categories with your stuffed toy, it means that you are still going to have to certify that you're meeting the total lead content testing, but you might not have to have a third-party lab test if you fall under one of these listed materials or any combination of the listed materials. So the first one is wood, paper, and similar materials that are made from wood. The second is CMYK process printing inks. And those are actually inks that fully absorb into the substrate and don't sit on the surface. And then the last two bullet points here are natural fibers and manufactured fibers and dyed and undyed states that we know are going to comply with the total lead content testing. Again, this is not an exhaustive list. There are more listed in 1500.91 that I have not included on this slide just for space purposes. So you'll want to make sure to check out, if you're a manufacturer of stuffed toys, the list in 16 CFR 1500.91. The next set of chemical tests that could apply to a stuffed toy is lead in paint and similar surface coatings. If you have those on your stuffed toy, this comes from our Federal Reg 16 CFR 1303. The limit there is that the lead in paint and similar surface coatings can't exceed more than 90 ppm. You'll notice that limit is a little less than the total lead content of 100 ppm we were just discussing. If you have any plastic parts or plasticized parts on your stuffed toy, then they would be subject to both the permanently and temporarily banned phthalates that are listed below. The phthalates requirement comes from 15 USC 2057C. And the reason that I'm including the citations to where these testing requirements come from is because at the end of this webinar we're actually going to go through a children's product certificate and what needs to be in it. And you're going to want to have the regulations and the U.S. code references handy. So I thought this might be an easy way to kind of introduce you to them and then at the end we'll sum them up as we go through the children's product certificate sample. So for phthalates, again there are permanently banned phthalates. There are three of them. Those three phthalates concentrations cannot exceed more than 0.1% in a stuffed toy or any children's toy. And then the temporarily banned phthalates are temporarily banned depending on the commission completion of a final rule. And this applies to child care articles and children's toys that can be placed in the mouth. Those temporarily banned phthalates cannot be more than 0.1% and the three phthalate types that fall under that temporary ban are listed there. And then the last type of chemical testing is actually from the toy standard which is ASTM F96316 and it is heavy element content. The limit here varies by the element and there are seven elements that are listed there that each have their own content limit that cannot be exceeded in a toy. So the limit there is going to apply to accessible toy components that can be sucked, mouthed or ingested on the toy and in terms of making something out of a potential material that would not be subject to heavy elements testing because we know it will pass, the only material there is unfinished and untreated wood that we have in our regs as not exceeding the heavy metals limit and that is under 16 CFR 1251. So now that we've finished discussing the chemical testing requirements on stuffed toys, let's talk a little bit about the physical and mechanical testing requirements on stuffed toys. And the first one is probably very familiar to everyone that is watching the webinar. It's small parts and small parts comes from 16 CFR 1501. It's also referenced in the toy standard and a small part is something that's going to fit entirely in a small parts cylinder and the dimensions of that small parts cylinder which we've certainly covered in webinars before and many of you may have them sitting on your desk is meant to replicate the airway of a three-year-old child. The small parts cylinder dimensions are available via our website. Now the two things to remember about small parts is that if you have a toy, a stuffed toy or any toy that is intended for children under the age of three, it cannot contain small parts. Small parts that are either produced following use and abuse testing or small parts that come with the toy as they are received or as the toy is received. And then if the toy is actually for a little bit of an older child and it's age graded for children ages three to six, it's either a toy or a game that contains a small part as received. Not following use and abuse testing, you need to make sure to label. And you're going to want to label the packaging. And if there are marketing materials that allow a consumer to buy the product for an example here, a website is a great example. You're going to need to label on the website that that product contains a small part as received. And the language of that label comes from 1500.19.20 and .121. It talks about the language of the label, how big the font needs to be and where it needs to be placed on the packaging and the marketing materials. Now in terms of physical and mechanical testing, obviously the toy standard is going to apply. The toy standard is an ASTM F96316 standard now. This is the new one. The previous toy standard was Dash 11 as opposed to Dash 16. That standard applies to toys manufactured on or after April 30, 2017 so that we actually just switched over to the 16 standard. That standard is available for purchase via ASTM.org. It is a copyrighted document, so we won't get into the specifics of it here today except to discuss some of the section names and section numbers. For those of you that might have the 11 standard, I want to track the changes that have happened from 11 to 16. You do have the ability at ASTM.org to purchase both the... You can purchase the standard, you can purchase the red line or you can purchase the bundle of the standard and red line bundle. For people wanting to track changes, we recommend the standard and red line bundle. It just makes it easier to see what's changed in the toy standard. In terms of finding a testing lab, it's going to help you test your toy to this new toy standard. The lab search page is available via that link which again, in your handout, that hyperlink is going to be live on the slide and you can always narrow your search by country in which it needs to be conducted and the type of product testing that you need done. From the toy standard, specific to stuffed toys, let's talk about some of the sections that may apply. Again, I'm going to caveat this because I'm trying to talk in general terms and general terms are very difficult for many consumer products. So please keep in mind that the list that appears on your screen are just representative and that testing sections for F963 are going to vary widely based on how your toy is designed and how it's constructed. So we're just using this for educational purposes. It's not meant to be a hard and fast rule on which sections could apply to your stuffed toy. Some may apply, some may not apply, other ones not listed may apply depending on how it's designed and constructed. So with all that being said, normal use testing is something that the toy standard requires to be conducted on stuffed toys and that's in section 8.5 of the toy standard. There's also abuse testing in 8.6, impact testing in 8.7. There's a torque test which involves twisting and pulling at a certain force in section 8.8, attention test which includes a seam strength test that is pulling at a seam to see if it opens. That's in section 8.9 and a compression test which is in 8.10 which has to do with applying a certain amount of weight to the stuffed toy to see how it performs. A note here and we'll go into a little bit more depth about these different types of toys and how it might vary or different types of testing and how it might vary depending on the age grading of your toy and how the toy is constructed. But I just wanted to note here, flammability testing, which we get a lot of questions on, is included in the toy standard F96316. However, it is not mandated by our agency that you conduct flammability testing on a stuffed toy and that's per the Consumer Product Safety Improvement Act and I've got the public law and section reference there. However, we're never going to tell a business that has additional testing funds to not conduct testing to ensure that their product is even safer. So for physical and mechanical testing, and I know nobody loves charts, although I might like charts more than most, I thought it might be useful just to see the differences in four types of tests that could apply to your stuffed toy and how the testing process varies based on the intended age of the user of the toy. So on the left-hand side we've got the age ranges or age grading I guess of the stuffed toy and then going to the right we've got an impact test, a torque test, a tension test and a compression test, which are all physical and mechanical tests from the toy standard that we just discussed. So things that I want you to take away from here and again you're going to have the slides here and you're going to get the webinar by email, the video, two days after this webinar is done so you can always re-access it that way. So the idea here is not to memorize the pound-force inches or pound numbers and the number of drops or heights, it's to look for trends. So the age ranges on the left-hand side start at 18 months or less. That's the first row across. After that is 18 months to three years and then three to eight years. And let's just take a look as the child ages and how the toy is tested in a different way. So the impact test otherwise known as the drop test applies to toys that weigh less than three pounds. So if your stuffed toy weighs less than three pounds the impact test may apply to it. And what I want you to see in terms of trends are that from the 18 months or less range down to the three to eight year range you're going to see that the number of drops decreases and you're going to see that the height from which it's dropped also decreases. And why is that? I'll caveat this with keep in mind that these tests are made with the average child in mind. And for those of you attending that have your own children, your children are no doubt extraordinary. We're not talking about your extraordinary children, we're talking about average children. So with that in mind for an impact test the reason that we've got the number of drops decreasing is because little kids like to drop things and throw things. Not your children again, these are average children. But the reason we go from ten drops down to four drops for the next two age ranges is because of an average child's propensity to drop something. And the reason that the height decreases is because little kids 18 months or less are generally being held by an adult or some sort of caregiver and that adult has a certain height associated with them. And as a result once the child starts walking and running it drops, he or she will drop their toy from their height and their height is much shorter than an adult height. So you can see the change there. For the torque test, again this is a twisting and a pulling. You'll see that as the child ages and gets older they're going to get stronger. So the torque test in terms of pound force inches that is applied is going to increase. Meaning it's going to replicate the increasing strength of a child and twisting and pulling on an arm of a stuffed toy. For the tension test, the same thing. The pounds that are there, that tension is meant to increase as the child gets older because the child's getting stronger. The same with compression. The child's getting stronger so as it smashes on a toy the weight that you're pushing on the toy is meant to increase as that child gets stronger too. So now we're going to take a look at a demo video. Before we get started I just want to say a few things. The demo video was actually produced at our testing lab. We intentionally asked that the testing engineers not use their standard testing equipment and use much more accessible equipment just to kind of show you guys in a non-laboratory way what the testing looks like. Because sometimes people want to know what kind of testing their toys are undergoing when they send them off to testing labs and there aren't a whole lot of videos of this so we thought it would be useful to take a look at it from that perspective. So in terms of tests that we're going to see in the demo video the first one's the impact test, which is the drop test. The second one is the tension test which is that straight line pull. And then the third one is a seam strength test and in the toy standard the seam strength test only exists in the toy standard. It's a mandatory test for stuffed toys. It is known as the tension test for seams and stuffed toys and beanbag type toys. So we'll see, so keep in mind we're going to be looking at those three tests and you'll see passing and failing samples for each. So the chart that you're seeing here actually sits at our testing lab and it should look familiar. This is the chart that we just saw with the impact torque tension and compression test. The reason that we've bolded 18 to 36 months that's the assumed age of the toys that we're going to test. So we've got a stuffed toy here and the reason we've got four shots is because we're about to do a drop test and we want to do it from four different orientations. Now the toys dropped four times on the floor from a height of three feet and nothing fell off so toy looked good. For the tension test again this is a straight line pull that we're going to do. These are the tools that we're going to use and there are three examples of clamps. So this is our first sample, this lion and here you can see that the clamp is actually placed under the eye substrate and you see the engineer is actually pulling at a certain force based on our assumed age grading for these toys of 15 pounds plus or minus 0.5 pounds which you're going to apply evenly for five seconds and then hold for 10 seconds and because the eye stayed on for this lion it's passed the tension test. We're going to do the same thing to this sample which is a white bear. You can see the lion looking on after passing its tension test and you see that the eye immediately ripped off as he was beginning to apply the pound force that was required and unfortunately that eye is a small part so that's a failing sample on the tension test and that eye was actually glued on so of course it was going to fail there. Next we'll do the seam strength test. These are the tools needed. This is going to be our first sample and the reason that you need a ruler here is because you need to make sure that you comply with the toy standard. Because the toy standard is a copyrighted document I'm not going to get into the details of what he's measuring here but you do need to make sure that you comply and again that standard is available via astm.org So once the clamps are affixed to both sides in the proper locations again based on the copyrighted text of the toy standard for the seam strength test the testing engineer is going to attach the pound force gauge and we're going to see him actually pull on that seam to see if it opens and he's going to apply 15 pounds plus or minus half a pound of direct force over five seconds like ramping up and then hold that for 10 seconds to see how it performs and you see that the seam stayed closed so this is a passing sample on the seam strength test. This is our bear from earlier. Things haven't been going well for this bear so let's take a look at how its seam between its head and its body performs on the seam strength test and again the measuring with the ruler that is done is from the specific text of the toy standard which you'll have to access yourself so I'm not going to get into that the specifics there but we're going to watch the testing engineer apply that straight line force to see if the seam is going to open you can actually see that that seam is slowly ripping open and it just released so this is a failing sample on the seam strength test and we're going to actually take a look at that seam to see what it produced you see it ripped open and a child could easily get their hand in there and start pulling out stuffing and choke on that stuffing so this is a failing sample for the seam strength test and to summarize these are the tools that we used to conduct those tests and again it was meant to be representative we wanted it to be accessible so we didn't use the normal lab equipment to do that and caveat this is a demo video it's for informational purposes may not represent all the testing that needs to be done on your toy but we thought it would be useful for you guys to be able to see that alright so now that we've taken a walk through all of the labeling the chemical and the physical and mechanical testing requirements that could apply to your stuffed toy let's talk about small batch manufacturers because we get a whole host of questions on small batch two things to remember to qualify you need to meet the gross revenue requirements and the manufacturer requirements that are listed there if you meet those it means you're an eligible small batch manufacturer you do need to register with us though still and the registration can be done via that link that's at the bottom of the slide eligible, registered small batch manufacturers may benefit from registering with us by being able to avoid their party testing at an independent CPSC accepted lab for specific tests on certain children's products that includes the toy standard which is why I've brought it up today so for eligible registered small batch manufacturers you may be able to conduct first party testing and again we can help you navigate whether or not that you are eligible and properly registered and depending on the type of toy whether you are eligible to first party test if you are eligible to first party test the caveat here is that you got to make sure that you're strictly complying with the physical and mechanical testing requirements that you may be able to conduct on a first party basis and again another chart not because I want to drown you guys in charts but because I think it is useful for reference purposes and again you're going to have the PDF handout of these slides to know the following so what I've done is I've listed on the left-hand side the types of testing that we've gone through today and we've got three categories here and you're going to see that two of them are flips of one another almost like flip sides of a coin the first one says third party CPSC accepted lab testing required you'll see if the answer is no that you can rely on written assurances from a supplier of compliance so few things to highlight here there are two specific types of testing on which a small batch manufacturer that is registered with us cannot rely on written assurances from a supplier and that's total leg content and it's phthalates and the reason that I I'm sorry, flip of that getting myself confused hopefully you guys aren't equally confused if you need lead and paint and surface coating testing or small parts testing as a small batch manufacturer you can't rely on the written assurances of a supplier for lead and paint and surface coatings or small parts what is a written assurance we get that question a lot written assurance is not a testing report it's not a timely testing report it is a letter that is on letterhead from your supplier saying that they have complied or the products that they're supplying you comply with certain portions of our testing requirements so written assurances cannot be relied on for lead and paint and surface coatings and small parts that's the takeaway message there now on the far right hand side if you are a domestic manufacturer can you rely on timely component part testing from your supplier to avoid retesting certain parts of your product the answer is yes for total lead lead and paint and surface coatings and phthalates for small parts it's a maybe and the reason here is because small parts testing has to be conducted on a finished stuff toy so if you have if you're a domestic manufacturer and you're somehow relying on a supplier to give you a completed toy and you're not doing anything except putting it into the stream of commerce then you could rely on a timely component part testing report but that is a really isolated example so keep that in mind for the toy standard testing the physical and mechanical and the chemical testing can you rely on timely component part testing there the answer is yes for chemical testing and maybe for mechanical and physical testing which we just went through but again that testing has to be done on a completed toy so it's a really isolated example where a domestic manufacturer has someone supplying them a finished toy that's already been fully tested so just things to remember here and last point that I want to comment on what does it mean to be a timely component part testing report it means it's done within the past 12 months and you of course always want to make sure that that testing report corresponds with whatever specific product they're supplying you we have seen in our office many testing reports that are on products that are quite different than those being supplied so children's product certificates another topic area that we get a lot of questions on there are seven parts to a CPC they are listed on your screen the ones that I want to highlight are two and it's just based on the information that we supplied here today the site to each CPSC safety rule to which you're complying and those A through E that are listed there are actually all the topics that we've covered today in terms of testing requirements that could apply and in number six the location of testing and date of test on which the certification is based if you are using a material that we know will comply with either total lead content or heavy metals or heavy elements content which we discussed earlier you're going to want to reference that list item in number six on the children's product certificate for children's product certificates they have to be done for every single children's product and manufacturers and importers are both responsible for making sure that their children's products are certified in a children's product certificate on our website at CPSC.gov forward slash CPC and there are sample children's product certificates available online there are two samples currently ones for a children's toy which would be very useful for your stuffed toy you can also use the language that's on the slide previously as a starting point to start your children's product certificate the other sample that we've got online is for children's clothing the availability of certificates for children's product certificates and general certificates of conformity are that certificates must accompany each product or shipment covered by the same certificate the certificate must be furnished to each distributor or retailer of the product although there's not a requirement that you provide it to the ultimate customer or consumer and a copy of the certificate must be made available to the commission and or customs upon either of those agencies request for electronic certificates you do have the ability to provide a CPC electronically the commission has come out with a rule that confirms that those are acceptable the caveat there is that you have to make sure that that CPC is created before the time of shipment or first distribution within the United States meaning you can't create one after the fact and act like it was created beforehand so next I want to talk about two different toy recalls and I want to let you know where I found these so if you're curious about other stuffed toy recalls on our site that you can find them these are actually available via cpsc.gov if you click on the menu button you'll get a drop down and one of the options is recalls and it'll take you to our recall site which is very search friendly it's got a search bar I typed in stuffed toy or plush toy and I've just used the two that I'm going to talk about here today as examples so the first one this recall was done in October of 2015 on this nice blue little he's a dragon, he's a star bright dragon stuffed animal and you'll see at the very bottom of your screen kind of in small text that there were 33,600 of these sold in the US and an additional 1,000 were sold in Canada this toy was recalled in conjunction with Health Canada the hazard here was that the seam opens and it allows the stuffing material to be exposed so just like that white bear in our demo video that poses a choking hazard and failed the seam strength test and as a result this toy was recalled in October of 2015 and then our second stuffed toy recall example is the colorful hearts teddy bear and in terms of units down at the bottom of the screen you can see there were 284,000 of these sold in the US and 13,200 were sold in Canada and the remedy here was a replacement bear because the problem with this bear was that its eyes could loosen and fall out and that eye could pose a small part and a choking hazard for children so that recall date is December of 2011 hopefully you guys if you're curious are able to go on to our website and search for recalls that are available there so I just want to highlight a few business resources and then we'll get to questions at the very end CPSC accepted lab search page on the bottom left of your screen that is the way to find a testing lab that can help you test your stuffed toy and we can help you conduct that search if you need help narrowing your search by the type of product that you're testing or the testing that needs to be done or the country where that testing needs to be done the desktop reference guide is there also again the links are in the PDF handout attached that desktop reference guide people find is a very useful tool for all different types of consumer products and lastly on the right hand side is the regulatory robot which if you're developing a new toy or you just have questions that you think an interactive bot could help you with we're very proud of the regulatory robot and it's available via that link below again my name is Shelby Mathis small business ombudsman my email is on the screen feel free to email me questions the telephone number that appears on your screen 301-5047945 is our small business line and both myself and my colleague will answer that line and if you are of the sort that likes Twitter we have a Twitter feed in our office and we're at CPSC small biz and we advertise things like this webinar other trainings that are going on with CPSC and potential commission action that could impact small business on that Twitter feed so if you are interested you can follow us on Twitter so with all that out of the way I'm going to leave my contact information up on the screen and we'll take just a few seconds to get some questions together and then I'll answer questions from the audience and the five minutes or so that we've got left on the webinar I do want to point out if you want to stay up to date on upcoming webinars that we have you can go to CPSC.gov forward slash email and you enter your email address and select small business ombudsman updates from the list of updates you can also sign up for recall notices other things that are going on at the commission there's lots of ways for us to get in touch with you so if you're interested in learning more about webinars then you can do that on that site so with that I'm going to close out the webinar and thank you everybody for attending today.